IR 05000282/1981003
| ML19347G021 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/21/1981 |
| From: | Greger L, Hueter L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19347G017 | List: |
| References | |
| 50-282-81-03, 50-282-81-3, 50-306-81-03, 50-306-81-3, NUDOCS 8105280069 | |
| Download: ML19347G021 (13) | |
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.h U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-282/81-03; 50-306/81-03 Docket Nos. 50-282; 50-306 Licenses No. DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 Facility Name: Prairie Island Nuclear Generating Station, Units 1 and 2 Inspection At: Prairie Island Site, Red Wing, MN Inspection Conducted: March 2-6, 1981 f '- }bbu Inspector:
L. J. Hueter b/E' 3/
dC y'.2/-s /
Approved By:
L. R. Gr ger, Acting Chief Facilities Radiation Protection Section Inspection Summary Inspection on March 2-6, 1981 (Reports No. 50-282/81-03; 50-306/81-03)
Areas Inspected: Routine, unannounced inspection of the radiation protection program for the Unit 2 refueling including: procedures, arbance planning and preparation, training, exposure control, posting and control, material control and surveys.
It also included review of a containment worker injury; onsite burial of nonradioactive spent resin; and licensee actions taken in response to a previous item of noncompliance, Health Physics Appraisal Findings, IE Bulletin No. 80-10, and other IE Information Notices and IE Circulatc. The inspection involved 50 inspector-hours onsite by one NRC inspector.
Results: No items of noncompliance or deviations were idertified in any of the 13 areas inspected.
Identification of a need for periodic evaluation and/or replacement of PAC filters is discussed in Section 8.
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DETAILS 1.
Persons Contacted J. Callahan, General Instructor, Training Department K. DeLong, Senior Radiation Protection Specialist
- A. Hunstad, Staff Engineer
- A.
Johnson, Radiation Protection Supervisor G. Kolle, Radiation Protection Instructor, Training Department J. Malinowski, Radiation Protection Coordinator J. Oelkers, Quality Control Specialist R. Pearson, Production Engineer
- D. Schuelke, Superintendent, Radiation Protection
- D.
Stember, Associate Production Engineer
- F. Tierney, Jr., Plant Manager W. Waldron, Instructor Supervisor
- E. Watzl, Plant Superintendent, PE&RP
- B. Burgess, NRC Resident Inspector
- C. Feierabend, NRC Senior Resident Inspector The inspector also contacted other licensee employees, including members of the technical and engineerita staff.
- Denotes those attending the exit interview.
2.
General This inspection began at 11:00 a.m. on March 2, 1981. Unit 2 was shut down for the refueling outage and Unit I was operating at power. At the beginning of the inspection a tour and observation of the facility included access control, Unit 2 containment, and the radwaste, auxiliary, and service buildings. During the tour, the inspector made independent survey measurements using licensee meters calibrated in January 1981 (PIC-6A, No. 893, in containment and Xetex 305-B No. 8291 in the radwaste, auxiliary, and service buildings). Measurements made were in agreement with posted survey data. Subsequent tcurs included the control room and the turbine building. Housekeeping in general appeared acceptable and looked particularly good in containment which may in part be attributable to the rather early stage of the outage.
3.
Licensee Action on Previous Inspection Findings (Closed) Infraction (50-282/80-08; 50-306/80-09): Failure of some operations personnel to routinely take a dose rate indicating device into high radiation areas. The inspector reviewed the licensee's response dated August 29, 1980. Retraining of operations personnel in the requirements for dose rate indicating devices in high radiation areas was conducted.
In addition, a Surveillance Procedure SP 1663, Revision 0, September 12, 1980, has been established whereby radiation protection specialists make a weekly check of work conducted under-2-
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RWPs to determine compliance with requirements. Surveillance records f rom October 1,1980, through February 20, 1981, identified occasional problems, mostly minor in nature.
Identified problems had been dis-cussed with the individuals involved for purposes of correction. The licensee's corrective actions appear adequate.
(Closed) Significant Appraisal Finding (50-282/80-08; 50-306/80-09):
Upgrading of offshift radiation protection coverage. Twenty-four hour radiation protection coverage by Radiation Protection Special-ists (RPS) began February 21, 1981, and is to continue permanently.
To provide tb.is coverage, six additional RPSs have been hired. All have had nuclear navy experience in radiation protection.
In addition, three bsve had power reactor health physics experience.
Upon arrival at the plant, the new RPSs are given an eight-week training program which includes plant systems, radiation protection procedures, chemistry procedures, other applicable procedures, and on-the-job training. A " Qual-Card" check-off system is used to show satisfactory completion of training segments. Three of the new RPSs have completed the training program, a fourth was nearing completion, and the other two were just beginning the training program. Assign-ments are limited to demonstrated qualifications. About 15 additional RPSs have been contracted by the licensee for the current refueling, surveillance, and maintenance outage. The licensee's actions appear adequate.
(Closed) Significant Appraisal Finding (50-282/80-08, 50-306/80-09):
Assurance that radiation survey instruments are functional upon use and that appropriate radiation dose rate information is available to personnel in high radiation areas. To assure that portable survey meters are functional, the licensee, in late 1980, designed and con-structed three identical devices each containing two small cesium-137 sources for daily survey meter checks. Records are maintained of the daily checks. A functional test device is located at each of the three areas where instruments for routine use are stored:
(1) access control, (2) operators room on 695 foot elevation of the auxiliary building, and (3) entrance to containment. To assure that appropriate dose rate information was available to personnel in high radiation areas by January 1, 1981, the licensee had obtained 15 survey meters that provide a numerical visual dose rate indication, trained personnel in their use, and placed the units in service. These meters replaced previously used audible dose rate indicating devices. As an addi-tional safety measure, the licensee plans to obtain 10 Victoreen VAMP Area Monitors for use in specific high radiation areas. The licensee's actions appear adequate.
4.
Staffing and Qualifications In addition to the six experienced RPSs recently hired to upgrade offshift radiation protection coverage as discussed in Section 3, the licensee has two vacancies due to two RPSs transferiing to other positions in the company. One RPS transferred to the Training Department and has responsibility for all aspects of RPS training.
The other RPS transfered to the Quality Control (QC) Department and-3-
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has responsibility for developing and implementing a QC program for areas of responsibility covered by the radiation protection group, including:
chemistry, radwaste, and transportation. One of the two vacant RPS positions will soon be filled by an individual with nuclear navy and teaching experience. The licensee is pursuing the filling of the remaining RPS position.
The Senior Plant Chemist has formally notified the licensee of his intentions to terminate his employment. The licensee will be seeking a replacement for the vacancy created.
During the outage, the licensee has obtained the services of 15 contract technicians from Nuclear Support Services (NSS). The ten senior technicians (meeting qualification criteria from ANSI /ANS 3.1 1978) and five junior technicians (limited in assigned job functions)
were all given a full week of onsite training before~the outage began.
Except during outages and heavy work loads, the licensee utilizes a weekly session for comprehensive continuing RPS training.
No items of noncompliance or deviations were identified.
5.
Radiation Protection and Radwaste Procedures Outage radiation protection work generally is conducted under normal radiation protection procedures. The Superintendent, Radiation Pro-tection, meets monthly (daily during outages) with the Operations Committee to represent radiation protection regarding procedures for nonroutine maintenance and refueling activities. As an additional
radiation safety precaution, a Radiation Work Permit (RWP) is written to cover many,iobs even though the job is covered by a specific procedure. The following procedures were reviewed by the inspector.
SWI-RP-10 Revision 5 10/1/80
. Control of Radioactive Waste Drums, LSA Boxes and Resin Liners SWI-RP-12 Revision 0 8/25/76 Radiation Protection Section Specialist
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Retraining Program-SWI-RP-17 Revision 6 10/16/79 Calculating Radioactivity Released for Containment Purge SWI-RP-20 Revision 5 4/14/80 Radiation Protection Section Responsibilities SWI-RP-23 Revision 2 11/1/80 Radiation Protection Specialist Qualification Card-4-
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SWI-RP-28 Revision 3 i/1/81 Quality Control for In-
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strumentation and Analyses SWI-RP-32 Revision 0 4/15/80 Radiation Protection Key Control SWI-RP-33 Revision 0 22/23/80 Chemical Reagent and Resin Disposal and Hazardous Waste Sampling SWI-RP-34 Revision 0 12/29/80 Improved Radio-Iodine Monitoring Under Accident Condition SP 1663 Revision 0 9/12/80 Weekly RWP Compliance Check-No items of noncompliance or deviations were identified.
6.
Advance Planning and Preparation Adequate supplies of equipment and personnel have been provided through planning and preparation to fully implement the radiation protection program. As noted in Section 4, the plant health physics staff has been augmented with 15 contracted RPSs for the refueling outage. Supplies of protective clothing, respiratory equipment, and portable sur.vey instru-ments were adequate.
No items of noncompliance or deviations were identified.
7.
Training A review of the employee general orientation training program showed that requirements of 10 CFR 19.12 are included in the material presented.
No items of noncompliance or deviations were identified.
8.
Expesure Control a.
External E:cposure A random se.1.ection of recent exposure records were reviewed in-cluding forms NRC-4, pocket dosimeter totals, and TLD results. No problems were identified. As with previous outages, the licensee appears to be maintaining man-rems relatively low even though during this outage eddy current testing of steam generator tubes increased, fiber optic examinations of some damaged tubes and associated an-tivibration bars was initiated, and some tubes were plugged. A new reel system used with the eddy current probe has resulted in sign-ificant reductions in steam generator entries for maintenance of eddy current equipment which in turn has resulted in significant exposure reductions. Workers receive 300 to 500 millirem to the head for a typical 3-5 minute entry. This dose is about 1.5 times the dose to the chest and gonad areas.
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b.
Internal Exposure The inspector reviewed selected records of medical approvals, respirator training, respirator testing, routine and job specific air sampling, MPC-hour accumulation, and whole body count (WBC)
data. The WBC data was reviewed for the. period May 9, 1980, through January 31, 1981. No body burdens indicative of an exposure greater than the 40 MPC-hour control measure were noted.
No significant iodine-131 air activity has been identified by air sample analyses during the current outage. The - eactor head had not been removed yet. During the review c WBC data for the period June 27 through July 15, 1980, the inspector noted elevated body burdens of iodine-131 (less than the 40 MPC-hour control measure) and some external body contamination.
This period coincides with an unplanned unit 1 outage for repair of a steam generator tube leak. The exposures and cor tamination involved workers in containment. After a short period, it was determined that the source of iodine activity was a faulty or depleted charcoal filter on a PAC Unit (prefilter, absolute particular filter, and charcoal filter) used to filter air drawn-through the opened steam 9,enerator. The licensee has not tested or changed the charcoal filters in the other PAC units nor has the licensee established any criteria or frequency for testing and/or replacing the PAC unit filters. This matter was discussed at the exit interview. A review of effluent release data for the period involved showed that iodine releases were higher than nirmal but well within the design objective release rate.
c.
ALARA Although formalization of the ALARA effort could stand improvement, the ALARA program appears quite effective as evidenced by the rel-atively low radiation doses (average of about 200 man-rems per year for the past three years) and the low levgls of general contamination in containment (less than 1000 d/m/100 cm ).
ALARA efforts were spparent in the following areas.
l (1) Full week of training provided for contract RPSs before
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outage began.
(2) Pre-outage meeting with all RPSs for training in radiation protection procedures recently developed for certain major I
routine outage jobs to assure technicians are better organ-ized and to improve uniformity among RPSs.
(3) Development and use of a shift turnover log for RPSs at
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(4) Survey maps are now posted at entrances to local areas instead of the previous practice of posting survey information only at the controlled area access point.
(5) The Superintendent, Radiation Protection, meets daily during the outage with the Operations Committee regarding changes to procedures for nonroutine maintenance and refueling activities.
He also works closely with the Senior Scheduling Engineer who controls the Work Request Log.
(6) ALARA continues to be considered in writing RWPs.
(7) An individual has been assigned responsibility to assure that certain jobs with significant radiation hazards are properly completed and a critique prepared following work completion. This critique is used for training and to identify improvements to minimize exposure of perso'nel.
(8) A lead RPS position has been established in containment. This technician is provided a book of RWPs covering containment job activities to assist in controlling jobs that interface.
(9) The RWST was placed in recirculation through the clean-up system about a month before outage began to reduce radio-activity and improve clarity of the water.
(10) A TV camera is used to remotely monitor eddy current testing.
(11) Hydrogen peroxide was added to the primary system to improve removal of external contaminants from the fuel. This activity has been effective in significant reduction in radiation levels during fuel transfer.
During the inspector's tours of containment, several activities were observed which did not appear to reflect ALARA work practices.
One individual was observed in the immediate vicinity of the reactor head (about 100 mR/hr field) while not actively engaged in a work activity. He could have easily increased his distance from the reactor head, thereby reducing his dose rate, until his assistance was needed for the job in progress.
In two other instances, in-service inspection work by contractor personnel could have easily l
been performed in lower radiation fields. These items were dis-
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cussed at the exit meeting.
l No items of noncompliance or deviations were identified.
9.
Posting and Control l
l Thelicensee'spostingandcgytrolwasfoundtobeasdescribedin a previous inspection report-except as follows. The licensee is
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IE Inspection Report No. 50-282/80-08.
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implementing a system of posting radiation and contamination infor-mation at the entrances to posted areas in addition to the display of information maintained at access control. As noted in Section 3 the licensee has replaced audible dose rate indicating devices with visual dose rate indicating devices for individuals entering high radiation areas. The licensee also plans to obtain 10 Victoreen VAMP area monitors with local readout and alarm capabilities for use in high radiation areas.
No items of noncompliance or deviations were identified.
10.
Material Control The licensee's control of radioactive and contaminated materials was reviewed. No problems were identified.
11.
Surveys Selected daily and special area survey records for contamination and direct radiation were reviewed for the outage.
It was noted that general contamination levels have been kept quite low (see Section 8.c).
When elevated levels of contamination were identified, follow-up action appeared proper and timely.
Airborne survey data was reviewed for the outage period. Airborne activity in general has been very low. No significant iodine-131 airborne activity has been detected during this outage.
No items of noncompliance or deviations were identified.
12.
IE Circulars and IE Information Notices The following IE Circulars and IE Information Notices were reviewed with the licensee. No problems were identified:
IE Circular No. 80-18:
10 CFR 50:59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems IE Information Notice No. 80-22: Breakdown in Contamination Control Procedures 13.
IE Bulletin No. 80-10 The licensee's actions in response to IE Bulletin 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Un-controlled Release of Radioactivity to the Environment" were reviewed.
The station air system, used for breathing air purposes, was identified as occasionally having two interfaces with a contaminated system, both involving the condensate polishing system. Control valves and check valves separate the systems. Further, the breathing air is filtered (particulate and charcoal) at the point of use.
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The auxiliary boiler has interfaces, under certain conditions, with the boric acid evaporator and both waste evaporators. The path involves condensate to the deaerator drain line. A monitor on this line has a sensitivity of about SE-6/ACi/ce.
In addition, weekly samples are collected and analyzed from this pathway.
The demineralized water system has interfaces with the CVCS system (resin sluicing), boric acid evaporator package (flush water), waste evaporator package (flush equipment), #121 spent resin pump dis-charge header (water supply), and reactor cavity cleanup pump (water.
supply). Separation is provided by one or more isolation valves and in most cases, one or two check valves. Two additional check valves were ordered and installed in early September 1980 in the reactor cavity cleanup system to satisfy IE Bulletin No. 80-10.
In addition to the separation provided, the auxiliary building laboratory deminer-alized water is sampled and analyzed (sensitivity approximately E-8/>Ci/ml) two to four times each week.
The cooling water system interfaces with the containment fan coil unit, component cooling heat exchangers, spent fuel pit heat exchangers, RHR heat exchangers, and waste evaporator condenser. Separation is effected by pressure differential and/or level indicators.
In addition, the return line is monitored (sensitivity approximately 1E-6j Ci/ml).
p No interfaces were identified between the instrument air system, the miscellaneous gas system, or the sanitary system with contaminated systems. The sanitary system is a septic system.
It is not routinely sampled and analyzed.
Due to the sandy soil, no storm drains are provided at the site. The turbine building roof drains to the turbine building sump. This sump is sampled and analyzed weekly.
The licensee's evaluation indicates that the potable water (from well)
is separated from the demineralizer head tank by an 88 foot vertical siphon break. According to the licensee's evaluation report, this meets the acceptance criteria of Section 10.5.3 of the National Standard Plumbing Code.
No problems were identified by the inspector.
14.
Transportation Activities The following areas of the licensee's transportation program were reviewe'd: management controls; selection of packaging; preparation of packages for shipment; delivery of completed packages to carriers; receipt of packages; i.cident reporting; indoctrination and training; anlit program; examination of packages; and record keeping. No sign-ificant discrepancies were noted between the licensee's current program and NRC r?quirements in 10 CFR Part 71 and DOT' requirements in 49 CFR 172-173.
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The licensee appears to have a good overall solid radwaste and trans-portation program. This is attributable in large part to having one individual responsible for and having close oversight of all phases of waste handling, volume reduction, solidification, packaging and shipping.
An operations procedure, D11, Revision 0, September 26, 1978, " Radio-active Materials Shipment," (Revision 1 now in review stage) summarizes the basic requirements governing the packaging and shipment of radio-active material. Two augmenting procedures cover the two basic types of shipments made. Procedure D11.1, Revision 0, February 29, 1980,
" Radioactive Materials Shipment - LSA - Not Exceeding Type A Quantities, In Exclusive use Vehicles to Richland, Washington," covers compacted radioactive trash, cemented radioactive waste concentrates and "LSA Boxes" of tresh. Procedure D11.2, Revision 0, July 3, 1980, " Radio-active Materials Shipment - LSA - Greater Thaa Type A Quantities, in Exclusive Use Vehicles to Barnwell, South Carolina," covers radioactive dewatered resin.
The licensee uses 17H drums, which meet Type A package requirements, for compacted LSA waste. 2When trash is contaminated to levels above about 10,000 dpm per 100 cm, it is put in barrels without compacting to minimize potential for spread of contamination and the potential for an airborne uptake by the individual compacting the trash.
Evaporator concentrates are solidified in 17H drums using concrete.
Low-level activity steam generator blowdown regins have and will continuetogedewatered,generallyin80 feet steel liners and. e new 160 feet liners. To assure no liquid remains, a hole is dril.ed into the corner and 'ie liner is tilted for three or four days before welding the hole. Higher activity spent resins have been placed in liners, dewatered, and shipped to Barnwell, South Carolina in Hittman or Chem Nuclear Type B Casks. Any periodic maintenance on the cask is performed by the cask vendor.
In May 1981, the licensee plans to make three or four shipments of these higher activity resins usigg the mobile Hittman solidification (concrete) unit with nominal 80 feet liners and Type B casks to be shipped to Richland, Washington. Two Hittman tech-nicians will operate the unit and the licensee will provide health physics coverage. A procedure will be developed by the licensee for this particular operation.
Training appears to be commensurate with the type of job involved and the degree of supervision provided. Annual QA audits are conducted for the paper work involving all shipments. One senior health physics technician was recently transferred to the QC Department and has responsibility for developing a quality control program for health physics activities.
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cluded in this responsibility is the development of a quality control program for inspection of every radwaste shipment. This is in addition to inspections conducted by the Radiation Protection Engineer who has overall responsibility for all shipments. This should provide further assurances against recurrence of any problems such as noted by a State of Washington inspector when, on October 30, 1980, a waste shipment arrived at the Richland, Washington burial site with radiation levels in excess of that
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permitted at the undersurface of the vehicle; additionally two drums were i
not correctly marked as " Radioactive - LSA" in that shipment. Regarding the above occurrence, shipment No. 80-29 left the licensee's facility on
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l October 27, 1980, and arrived at the Richland site on October 30, 1980.
The State inspector, using a Victoreen Model 470A survey meter, iden-
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tified a reading of 500 mR/hr'at contact with the underside of the trailer i
bed between two metal I beams. There was about a six inch clearance between j
the beams. This-is in excess of the DOT surface radiation limit of
200 mR/hr specified in 49 CFR 173.393(j)(2). The licensee was promptly
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notified. A company representative arrived with a survey meter and measured 460 mR/hr at the same spot and 195 mR/hr level with the lower
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surface of the 1 beams. Up to this time it had been the licensee's
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practice to take surface readings at the latter location when I beams are in close proximity.
This matter has been referred to IE:HQ for resolution as to enforcement action. The licensee has changed their survey practice in that surface radiation levels are now measured on the bed of the truck, between the I beams.
l Four packages (55-gallon barrels) were selected at random and opened to obr:rve contents. All four were numbered for identification and marked " Radioactive - LSA. One of the barrels was first placed on
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its side for five minutes before opening. Two of the barrels con-i tained waste solidified in concrete while the other two contained
chunks of solid material removed from the turbine building sump.
Powdered cement had been mixed with the latter waste. No evidence of significant liquid was identified. Gaskets were in place under all
l four lids.
l 15. Onsite Burial of Nonradioactive Spent Resins
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The lice.nsee has a permit with the Minnesota Pollution ecntrol Agency for
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onsite burial of spent resins. Resins from three sources are permitted
for burial with the condition that the spent resins be nonradioactive.
j The three sources are:
(1) condensate polishing resin from the steam
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j generation secondary side condensate system, (2) the steam generator
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blowdown reclaim resin, and (3) the make-up water treatment demineralizer j
resin.
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To satisfy the permit requirement that the condensate polishing resin I
is nonradioactive, a minimum detectable activity (MDA) is determined for specified radionuclides using a germanium-lithium semiconductor detector svstem.
If the analysis of a one liter bottle of the resin counted for 1000 seconds results in the identification of any of the nuclides as present in the sample, the batch is considered as radio-active and can not be buried onsite.
Steam generator blowdown reclaim l
resins are to be evaluated in the same manner but, in addition, are to i
be evaluated for gross beta-gamma activity. Make-up water treatment
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demineralizer resins are exempted from radioactive monitoring as long as the sources of make-up water are surface and ground water and not.
recycled generating plant water. To date, only well water has been-
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used as the source of make-up water according to the licensee
representative.
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Resins buried to date have been 66 cubic feet of spent make-up water treatment demineralizer resins (no radioactive monitoring required),
1421 cubic feet of condensate polishing resin (all generated before contamination of the secondary system by the steam generator tube rupture in the fall of 1979), and 271 cubic feet of steam geterator blowdown reclaim resins (all generated before contamination of the secondary system). The latter two resins were monitored for radio-
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activity; none was detected, according to licensee records. The MDAs for the analyses were not greater than the following:
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Nucl..dj; Concentration cesina-134 5.1E-7#Ci/gm cesium-137 4.7E-7pci/gm cobalt-58 3.9E-7pCi/gm cobalt-60 8.8E-7 Ci/gm manganese-54 4.0E-7 Ci/t9 manganese-56 1.8E-5 Ci/gm iodine-131 6.3E-7 Ci/gm gross beta-gamma 6.2E-8 Ci/gm Considering the contaminated state of the secondary system and the small usage of resin volume for make-up water treatment, the licensee currently anticipates little if any further use of this onsite resin burial facility.
No items of noncompliance or deviations were identified.
16.
Injured Containment Worker On February 26, 1981, a worker in unit 2 containment lost consciousness for about five minutes after bumping his head on a protruding object.
He was carried by stretcher to an ambulance and transported to a nearby hospital where he was examined and released. Plant health physics per-sonnel preceded the ambulance to the hospital to assist in surveys and contamination control and returned the protective clothing worn by the worker, the bed sheets, and the stretcher to the plant. The stretcher and bed sheets had low levels of contamination (maximum of 300 cpm with Eberline survey meter with sensitive HP-210 pancake probe). The worker had no open wound and no detectable contamination following removal of the protective clothing. Smear surveys showed no contamination other than the stretcher and bed sheets. The licensee is re-evaluating the matter of protective head wear in containment.
No items of noncompliance or deviations were identified.
17. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. An unresolved item disclosed during the inspection is discussed in Section 14.
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18.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
on March 6, 1981. The following items were discussed:
a.
The purpose and scope of the inspection.
b.
The elevated levels of iodine airborne activity and contamination in containment previously experienced during steam generator work due to faulty or depleted charcoal filter in a PAC Unit (Section 8).
The licensee acknowledged the potential benefits of developing and implementing a program for periodic evaluation and/or replacement of PAC filters and agreed to do so within six months.
.c.
The inspector's observance of some work activities that did not appear to conform to the ALARA concept was discussed (Section 8.c).
Although the inspector had determined that ALARA concepts and re-sponsibilities are covered in general employee training and RPS training, the inspector stated that this observation may indicate the need for reemphasis.
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