IR 05000295/1987022

Insp Repts 50-295/87-22 & 50-304/87-23 on 870824-28.No Violations or Deviations Noted.Major Areas Inspected:Gaseous & Liquid Radwaste Programs,Including Effluent Releases, Reactor Coolant Chemistry & IE Info Notices

ML20234E478
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/15/1987
From:	Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20234E436	List: IR 05000295/1987022 ML20234E433
References
50-295-87-22, 50-304-87-23, IEIN-86-107, IEIN-87-032, IEIN-87-32, NUDOCS 8709220407
Download: ML20234E478 (13)

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U.S. NUCLEAR REGULATORY COMMISSION i

REGION III

Reports No. 50-295/87022(DRSS); 50-304/87023(DRSS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 1 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion Site, Zion, Illinois Inspection Conducted: August 24-28, 1987 W .} .

Inspector: W. JV Slawinski 9 -# c- 8 7 Date

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Approved By: L. R. Greger, Chief 9-/5-87 Facilities Radiation Protection Date Section Inspection Summary Inspection on August 24-28, 1987 (Reports No. 50-295/87022(DRSS);

50-304/87023(DR$$))

Areas Inspected: Routine, unannounced inspection of gaseous and liquid radioactive waste programs including: organization, management controls and training; effluent releases; records and reports of effluents; calibration and operation of effluent control instrumentation; reactor coolant chemistry; gaseous' effluent filtration system tests; and audits and appraisals. Also, certain Licensee Event-Reports, open items, licensee internal response to selected IE Information Notices, and an allegation concerning whole body counting practices were reviewe Results: No violations or deviations were identifie PDR ADOCK 05000295 l G PDR l

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DETAILS 1, Persons Contacted

• J. Barlard, Quality Control Supervisor S. Ber zynski, HVAC System ' Engineer J. Carason, Technical Staff Engineer D. Dahlen, Radwaste Group Leader

• E. Fuerst, Superintendent, Production G. Geer, Radwaste Planner P. Harris, Instrument Maintenance Foreman G. Kassner, Health Physicist G. Plim1, Plant Manager

• T. Saksefski, Regulatory Assurance Engineer L. Schaeve, Chemist

• Schultz, Regulatory Assurance Supervisor T. Scott, Engineering Assistant

• Stone, Quality Assurance Supervisor W. Taylor, Engineering Assistant G. Trzyna, Rad / Chem Supervisor C. Wepprecht, Health Physicist

• Williams, Lead Health Physicist

'*P. Zwilling, Chemist

• Holzmer, NRC Senior Resident Inspector P. Eng, NRC Resident Inspector N. Williamsen, NRC Resident Inspector The inspector also contacted other licensee employees including rad / chem technicians, chemists, and members of the technical and operating staff * Denotes those present at the exit meeting on Augu t 28, 198 . General This inspection, which began at approximately 11:30 a.m. on August 24, 1987, was conducted to examine the operational gaseous and liquid radwaste management programs and review an allegation concerning whole body counting practices. Also reviewed were certain Licensee Event Reports, open items, and licensee internal response to selected IE Information Notices. Tours of controlled areas were made to observe postings, access controls, effluent monitors, and gaseous and liquid radwaste process equipment; no problems were note . Licensee Action on Previous Inspection Findings 10 pen)OpenItems(295/85034-02;304/85036-02and295/85034-03;

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304/85036-03): Establish a radiation monitoring program and monitor sump runoff, respectively, for the interim radwaste storage facility

<. (IRSF). The licensee has drafted procedures addressing these issues l

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and expects to complete the items in late 1987. The licensee has no immediate plans for use of the IRSF. These matters will be reviewed further during a future inspection, f

(0 pen) Open Items (295/85034-04; 304/85036-04): Review the potential !

for gaseous generation during long term radwaste storage in the IRS

This matter is pending review by SNED. No completion date has been assigne This matter will be reviewed during a future inspectio (0 pen) Open Items (295/85034-05; 304/85036-05): Develop an IRSF container inspection program. .The station's technical staff has drafted a procedure ;

addressing this matter and expects completion in late 1987. This matter !

will be reviewed further during a future inspectio !

(0 pen) Open Items (295/86021-01; 304/86019-01): Review turbine building a fire sump monitor operability problem This matter is discussed in i Section l (Closed) Open Items (295/86025-03; 304/86025-03): Review modifications to the DAW compactor area. The area has been enclosed in a stainless steel HEPA filtered structure and includes a ventilation system for the compacto No problems were noted with the modification . Organization, Management Controls and Training '

The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including responsibilities and changes in the organizational structure and staffin The staffing and responsibilities of the Rad / Chem Department remain essentially as described in Inspection Reports No. 50-295/86025; 50-304/86025 with the following exceptions:

• A station Health Physicist (HP) was transferred to the licensee's corporate office. (This individual has approximately one year of station HP experience.)

• A corporate Radiochemistry Group Leader was transferred to the station's health physics staff. (This individual has a P degree in chemistry, but limited plant operational experience.)  ;

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• A Radiological Engineer in the station's ALARA group was transferred l to the health physics staff. (This individual has an M.S. degree in I nuclear engineering and 18 months station experience in ALARA.)

• The Lead Rad / Chem Foreman will transfer to the station's training .

department in September 1987 and be replaced by the station's l current Chemistry Lab Forema l l

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! Overall, the changes outlined above should not negatively impact, and may prove beneficial to, the radiation protection progra The. station's Radwaste Operations staff is responsible for operating  ;

the radwaste processing systems and loading, blocking, and bracing of radwaste shipments. The staff consists of a Radwaste Planner and Shipper, 1 six Radwaste-Shift Foremen (non-licensed) working under the direction of a Shift Engineer, five Radwaste Stationmen/ Laborers responsible for certain system operations and six Radwaste Equipment Attendants (contractors).

The contractors have various duties including DAW segregation, compaction,

and shipment loading, blocking, and bracing. The Radwaste Planner reports ,

to a Radwaste 0perating Engineer. Staffing for the radwaste program i appears adequate in number and has remained fairly stable over the past'

year; however, stationmen/ laborers are normally rotated to other duties or promoted to other position i Radwaste Stationmen/ Laborers receive standard stationmen training as described in Inspection Reports No. 50-295/86025; 50-304/86025 and informal on-the-job training covering various radwaste operation No significant changes were made to the training provided to the Radwaste Operations staff as a result of.RETS implementation in October 1986. However, a required reading list pertaining to the RETS changes was completed by Radwaste Managemen No violations or deviations were identifie . Gaseous Radioactive Waste ,

The inspector reviewed the licensee's gaseous radwaste management program, including changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitor for compliance with maintenance and operational requirements; and experience concerning identification and correction of programmatic weaknesse The gas processing portion of the Waste Disposal System is shared between both units and consists of two waste gas compressors, six gas decay tanks and associated piping, valves and instrumentation. Gases vented to the vent header flow to the waste gas compressor header and are pumped by the waste gas compressors to one of the six gas decay tanks. Gas held in the decay tanks can either be returned to the Chemical and Volume Control System holdup tanks, or discharged to the atmosphere. Gas decay tanks, auxiliary buildin0 miscellaneous ventilation system, and containment gaseous effluents are collected in a common header before release to either Uni; 1 or 2 exhaust stack The licensee implemented the RETS technical s)ecifications and the Offsite Dose Calculation Manual (0DCM) in late Septemaer 1986. Procedure changes to reflect RETS included revisions to $0I-68, " Gaseous Waste," which describes the operations necessary for startup, special operations and precautions for the gaseous waste syste As a result of RETS, waste gas ,

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gdf 4-q u system gas analyzation is required at least every 24-hour To meet this requirement, an automatic gas analyzer was made operational and monitors .l the concentrations of oxygen and hydrogen in the cover gas of the Waste l Disposal System, CVCS tanks, boric acid evaporator and gas strippe j The licensee currently has both automatic ~ continuous and grab sample ,

gas analyzation capabilities. The automatic analyzer has operated k satisfactorily to dat The,ir.spector reviewed semiannual effluent reports for the last half of 1966 and the first half of 1987; no problems were noted. The reports show a gradual reduction in the total noble gas releases since 198 a ' Releases were quantified at about 3800 curies annually-(both units) in both 1984 and 1985, about 3200 curies in 1986 and less than 100 curies in the first half of 1987. However, during the first six months.of 1987, ii ' Unit-1 was in an outage for approximately 100 days and Unit-2 for 90 day s Over the last couple years, the licensee has had no significant fuel cladding problems and only minor primary to secondary leakage resulting in relatively low total releases of noble gases, iodines and particulate,

's To. identify leakage, the licensee has been performing 100% steam generator tube inspections and ISI group walkdowns during each refueling outag '

As part of the the station's Leak Reduction and Control Program (Procedure ZAP 10-52-4), the technical staff continues to perform and f trend daily balancing of waste gas inventory so system leakage can be l readily identified.' These programs began in 1982 and appear to have '

a positive impact-for reducing the gaseous effluent releases to the environment, j

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The majority of gaseous effluent releases result from batch type releases  ! '

made from waste gas decay tanks (WGDTs) and containments via venting and purging. The inspector selectively reviewed records of continuous and batch gaseous releases for 1987 to date. Fifteen WGDTs were released during this period; however, the majority of these releases were of high volume and low activity, performed to reduce tank pressure from nitrogen  !

purgc gases. No instances of a release exceeding Technical Specification limits were noted. The licensee reported 1986 gamma and beta air dose totals from gaseous effluents at the site boundary of less than 4% and 2% of Technical Specification dose limits, respectively. The 1986 1 naximum organ dose to the nearest resident was reported as less than 0.5% of the Technical Specif,ication dose limit. 00se totals for the first half of 1987 are reported as a fraction of 0.5% of the Technical j Specification dose limit j i

No violations or deviations were identifie { Liquid Radioactive Waste

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The inspector reviewed the licensee's liquid radwaste management program, .

. including changes in equipment and procedures; radioactive waste effluents i for compliance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse l

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g Liquid radwaste effluents are discharged from the station through two release pnints: (1) Liquid radwastes from either unit, including auxiliary building equipment and floor drains, containment floor drains and laundry drains, are pumped to one of two lake discharge tanks and mixed with ,

condenser cooling water for dilution before batch release to Lake Michigan ;

and,(2) A turbine building floor drain analysis tank collects liquid waste !

from the turbine building floor drain sump. The collected waste (normally l uncontaminated) is' sampled and discharged by the turbine building floor !

drain pump, through a filter, to the oil separator system or to the Waste Water Treatment Facility (WWTF) via the turbine building fire sump. To prevent contaminated water from reaching the WWTF from the turbine building, a radiation monitor is located on the turbine building discharge (fire sump monitor). If radioactivity is detected, the waste batch can be processed through either the blowdown system filter demineralized or the waste evaporator. The WWTF treats (nonradiologically) the turbine building fire sump discharge which consists of waste water from the turbine building makeup demineralized system and equipment and floor drain Since the implementation of RETs in late September 1986, the procedure l which describes operation of the liquid was'et disposal system was revise !

, This procedure, S01-67, " Liquid Waste Disposal," was reviewed by the inspector and discussed with the licensee. No problems were note <

The inspector reviewed semiannual effluent reports for the last half of

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1986 and the first half of 1987; no problems were noted. Gross activity in liquid releases from the plant shows a gradual decline since reaching j a peak in 1984. In 1985 and 1986, about 2 curies and 1.6 curies of gross y activity were released, respectively. For the first half of 1987, about 1.0 curie was released. Similar to the gaseous leak reduction and i f control program, the technical staff accumulates daily liquid radwaste inventory data and evaluates the data for leakage trend Liquid releases are primarily from the two (30,000 gallon) lake discharge tanks, typically comprised of waste water from the primary system which has been processed through charcoal bed filters and mixed bed .

demineralizers before release. Before any liquid is routed to the lake !

discharge tanks, it is sampled in a monitor tank. Each batch of waste from the discharge tanks are sampled, regardless of previous monitor tank sampling, and quantified prior to release. Flow rates are determined ;

from flow rate monitoring devices. The inspector selectively reviewed records of continuous and batch liquid releases for 1987 to date. Pre and post batch release analyses and minimum flow rates were found to comply with Technical Specification requirements. Lake discharge tank batch releases for 1987 through August 12 totaled 270; no instances of a release

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exceeding Technical Specification limits were identified. Samples are collected from the discharge canal on a daily basis and analyzed for gross 4

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beta gamma and tritiu Limited activity, primarily tritium, is detected by the fire sump monitor which continuously monitors the fire sump discharge line. Flow rates are based on pump capacity, run time, and-WWTS flow. Technical Specification required daily, weekly and monthly i

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sampling / analyses were found to be performe ll/'_

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operability problems are' discussed in Section 7.) The licensee reported whole body and maximum organ dose totals from liquid effluents for 1986 and the first half of 1987 of less than 0.1% of Tecnnical Specification limit >

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.it Noviolationsordevkationsspreidentifie . Calibrations, Functional Tosts and Operational Status of Gaseous and Liquid Process and Effluen_t MoMtors P I The inspectors revieweo i records of calibration and functional tests j

for monie m on the radioactive liquid system (including the two lake '

f discharge tanks and turtine building fire sump monitory) and monitors on the radioactive gaseous system (including the gas necay tanks, containment purge and vent, miscellaneous ventilation stack and one

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channel of the containme4 ventilation accident monitor for both unitN)./

Calibration and functiodVtest methods appeared appropriate and met '

Technical Specification frequency requirements. The calibrations and tests are performed by the lastrument Maintenance Department with the exception of the cortt.ainment accident SPING for Unit 1, which was lagt'

calibrated by the R6diation' Protection Department. All future t d

calibrations and tests will be performed by Instrument Maintenanc , 1 In 1987, special calibrations were performed to determinenitor mo,of the gaseous efficiency using monitor particulate two different activitychannels strontium-90 reference standards. Previous calibrations were per' formed using cesium-137 standards. The particulate release rate corresponding to the RETS dose rate limit at the site boundary is substantially more conservative for strontium versus cesium. Monitor alarm setpoints were modified to correspond to the strontium release rate and monitor efficiency to strontius, yielding a morel conservative alarm setprnt. The, strontium-90 standards will be use j for all subsequent / colorations of gaseous monitor particulate dhannels. AlarmsetpointS1cuhtionswere ,

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reviewed and discussetj with lidases personnel; no prolgems tere note , i One of the two lake cischarge W hitors (ORT-PRO 51 and the turbine building fire sump monitor were both replaced initate,1985 with newer more sensitive monitors. The newer monitors also allow easier removal of their liquid chambers to facilitate decontamination and minimize background ,

levels. The new fire sump monitor was initially calibratdd in.early 1986

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and exhibited intermittent spiking problems shortly thereafteF.' The ,,.

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licensee verified the spiking problems were not attributable to activity in the sump water, but resulted from electronic (BNC connector and related) '

problems. The monitcr was declared inoperable for various periods throughout 1986. The monitor was last calibrated in January 1987 and operated satisfactorily until exhibiting continuous false' alarm conditions midway through the year. The licensee has determined th e false alarms are due to elevated background from prolonged plate-cut ira ide the Unit 1 Lake

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[LLI di IfisUbarge Tank discharge pipe wh'ich runs within a few feet of the fire sump -

E detactor. The licensee is considering various actions to remedy the

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proolem including additional shielding and detector relocation. This ]

matter was discussed at the uit' interview and will continue to be reviewe i during; future inspections. Duripg periods of monitor inoperability, the j

? j inspec, tor verified that shiftly grab samples have been collected and l F /eanaly ed pursuant to Technical Specification requirement ,e l

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reveal 9d that an excessive number of process radiation monitors have been and continue to be inoperable. There appears to be no common cause for i

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the problems other than possible antiquated or worn-out equipmen )

Instrument Maintenance is reportedly back-logged with process monitor 1 3c renairs/maintenant'e ,The licensee was previously aware of t.his I

/ Srtblem; which was altl/ identified during a recent INP0 audi The j Jinspector verified thd.sgrab samples have been taken and Technical  !

SpWification' action statements met for selected out-of-service monitor l Thir watter was disudssed at the exit meeting and will be reviewed during l

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future jinsp Mtioiq (0 pen Item 295/87022-01; 304/87022-01). '

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g No violations or deviations were identifie ;

v lReactorConlantChemistry The inspector selectively reviewed reactor coolant sampling and analysis records for 1987 to date. Test results reviewed included dissolved

c oxygen, chloride, fluoride, and dose equivalent iodine-131 during various

) operational modes ,for both units. Technical Specification frequency and f) analysis requireraents were met; no problems were noted. The applicable

. / ; 'i parameters were not determined for Unit 2 during a 34-day period in April and May 19d7 because the core 9/as off-loaded for split pin replacemen p/  ; Technical. Specification surveillance requirements were not applicable j / )- under this condition. Surveillance was resumed prior to restoring fuel

/'n to the vessel and the coolant chemistry was verified as still within specification /  !

W No violations or deviationis were identifie '

, 'HEPA Filter and Charcoal Absor'oer Systems  !

g The inspector selectively revieyed records of in place testing of HEPA

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and charcoal filters, including laboratory analysis for methyl iodine

• removal efficiency from charcoal absorbers, from September 1986 to dat ;

Other than previgusly identified in Inspection Reports No. 50-295/66025; j 50-304/86025; no' problems were note Tests appeared to be conducted in 1 accordance with Technical Specification requirements and yielded results l which met acceptance criteria for leakage and iodine removal efficienc '

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No v olations or deviations were identifie .

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' 1 1 Audits and-Appraisals L i The inspector. reviewed reports of audits and appraisals conducted by 1 the licensee including audits required by Technical' Specification ' Also reviewed were management techniques used to implement the audit

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program and experience concerning identification and correction of j D . programmatic weaknesses.

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Annual audits-of the-radwaste program are conducted by the station's QA  !

l Department. The last audit was conducted from March 23 to April 2, 1987 i

to verify' implementation of the Radwaste QA Program; the previous audit

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.was. conducted in April 1986. The 1987 audit included review of radwaste ]l and'other radioactive material shipments and waste solidification. One finding was identified concerning proper maintenance of radioactive  ;

material receipt records; the finding has been satisfactorily correcte k

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A station QA audit was performed from April 27 to May 8, 1987, to review I calibration of station instruments including process radiation monitor l:

-The audit resulted in one finding and one observation. The finding partially dealt with process radiation monitors and concerned conflicts  !

between procedural calibration schedules and Technical . Specifications  !

required calibration frequencies. Calibration and functional test frequencies delineated in Instrument Administrative Procedures did not correspond to Technical Specification required frequencies; however, the audit did not identify violations of Technical Specification calibration requirements for radiation monitor This audit finding remains open and is subject to further NRC revie A station QA audit was performed from January 26 to. February 3, 1987, to assess radiochemical and chemical control including reactor coolant system water chemistry and verification of NPDES requirements. No problems in the above noted areas were identifie In addition to the above, monthly radwaste shipment surveillance are q typically performed by the QA Department. Records of these surveillance were reviewed for 1987 to date. No significant problems were noted; j however, one surveillance identified improper radiological control i practices exercised by contract laborers. The problem was quickly 4 corrected and included additional training for those involve These surveillance are scheduled to continue in 198 No significant problems were noted during selected review of audit and

. surveillance reports and the responses to findings and observation No violations or deviations were identifie '

1 IE Information Notice Followup

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The inspector reviewed the licensee's internal actions to selected IE Information Notices. The licensee's evaluations, conclusions

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Notice No.'86-107: " Entry Into PWR Cavity With Retractable Incore Detector Thimbles Withdrawn." This notice addresses potential radiological hazards associated with entry into'TIP rooms and cavities beneath reactor vessel Zion Station has two areas for each unit similar to that described in the notice, the seal table and incore reactor cavity areas. Both areas are potential very high radiation areas (> 1R/hr), depending on operational mode and location of incore detectors and thimble An event of the type described in the notice occurred at the Zion Station in 1982 and resulted in a personnel overexposure. Two violations were identified as described in Inspection Report No. 295/82-09. Corrective actions taken as a result of the problems identified in 1982 are outlined in the licensee's response letters dated August 9 and October 12, 198 To gain access to the cavity area, a special SR-key, controlled by the Rad / Chem Department, is necessary. This key is required to be controlled by an individual with at least five years of radiation protection experience at a reactor facility and is normally maintained by the Rad / Chem Supervisor or the Lead Health Physicist. Administ"ative Procedure ZAP 5-51-16 addresses reactor cavity access control and sets forth the conditions that must exist prior to issuance of the SR-ke Specifically, cavity access is allowed only if the following requirements are met:

• incore thimbles are in the reactor vessel

• incore detectors are taken out-of-service e incore detectors are in their shielded storage position or are inserted into the vesse Thece requirements must be verified prior to each entry by checking .

status with the Control Room and Rad / Chem Department. Prior to detector h or thimble movement, Operations Procedure TSS 15.6.0 and/or Maintenance Procedure RC001-12 require appropriate verifications, including Rad / Chem Foremen approval, to assure the area is not occupied. These requirements apply during all modes of operatio The hazards associated with incore detectors, thimbles, and cavity area entry are addressed in initial training and annual retraining for both Rad / Chem Technicians and Operator The access door to the Unit-2 cavity was recently stenciled with a warning, " Danger - Potential High Radiation Hazard." The door to Unit-1 has not been permanently stenciled, but is planned during its next outag No problems were noted with access controls or trainin Notice No. 87-32: " Deficiencies in the Testing of Nuclear-Grade Activated Charcoal." This notice alerts licensees to deficiencies found in the testing of nuclear grade activated charcoal used for accident mitigation in nuclear facilitie Although not officially received at the Zion Station from the licensee's corporate office, station personnel are aware

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of the problems described in the notice. Testing of charcoal filters is performed for the licensee by a vendor which reportedly performed ;

satisfactorily during the NRC/ Idaho National Engineering interlaboratory <

comparison study. The licensee reported that their charcoal filter banks have,'on occasion, failed the vendor's elemental iodine removal efficiency tests and were replaced. The licensee anticipates retaining the services of their vendor and do not plan to take any actions as a result of this notic No violations or deviations were identifie . Licensee Event Report (LER) Followup The inspector reviewed selected LERs to determine that deportability requirements were fulfilled and adequate and timely corrective action was accomplished, including actions to prevent recurrence. In addition, each event was evaluated for previous similar events, root cause, and potential generic applicability. The review consisted of in-office review, direct observations, discussions with licensee personnel, and review of record LER 295/87-010-00: " Missed Quarterly Surveillance on Gaseous Effluent Release Path Filters Due to Deficient Procedure." On May 4, 1987, the license discovered a failure to save filters from two Gas Decay Tank releases which_had occurred during the first quarter of 1987. Technical Specifications require quarterly composite strontium-89, 90 and gross alpha analyses be performed on such filters. This requirement is met by saving the filters and sending them for vendor analysis at the end of each quarter. Only two Gas Decay Tank releases occurred (March 6 and 7, 1987) since this Technical Specification become effective in September 198 The problem was caused by inadequate communications with the Chemistry Department and lack of procedural guidance to save the filter As required by Technical Specifications and station procedures, the tanks were sampled and analyzed prior to and after release and showed the dose rates from the release well within limit Adequate corrective actions were verified by the inspector to have been complete No further problems were noted for subsequent Gas Decay Tank releases or with other gaseous and liquid releases which require quarteriy composite analysi This Technical Specification violation appears to meet the criteria of 10 CFR Part 2, Appendix C, for self-identification and correction l of problem No inspector identified violations or deviations were note I l

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13. Allegation Followup Discussed below is an allegation concerning the radiation protection program at Zion Station which was evaluated during this inspectio The evaluation consisted of record and procedure review and interviews with licensee personne '

The Zion Station Resident Inspector's office received information from two )

contractor workers regarding concerns with the internal exposure assessment c (whole body counting) program at the station. The allegation and inspector's findings are discussed below (Allegation No. RIII-87-A-0096(Closed)).

Allegation: Two contract workers employed at Zion Station for about two weeks in June 1987 allegedly did not receive whole body counts at the time of their employment (incoming counts). The two workers stated that other contract personnel had received incoming count Discussion: It was determined that the allegers worked at the Zion Station on secondary systems in the Turbine Building for about two weeks in June 1987. The work was performed on clean (non-contaminated) systems not requiring an RWP. Station records show the individuals were issued personnel dosimetry (TLDs) and received termination (outgoing) whole body counts at the completion of their job assignment. No external exposure or internal deposition was recorded by the TLD or outgoing whole body counts, respectivel '

Station Radiation Protection Procedure (ZRP) No. 1201-2, " Personnel Bioassay Scheduling," specifies that bioassays (whole body counting normally) be conducted as necessary to aid in determining the extent of an individual's internal exposure to concentrations of radioactive material, and further states that incoming contractor personnel will be scheduled to report for whole body counting prior to being issued a film badg The procedure specifically exempts, however, individuals who will be onsite for a short period of time and who will not be working in a controlled area from the need for an incoming bioassay. Inasmuch as the two allegers were onsite for only a few weeks and did not work in a radiologically controlled area (no RWP work), they were exempted from the need for an incoming whole body count by the licensee's procedur ,

The inspector's reviews determined, however, that the licensee apparently did not intentionally exempt the allegers from baseline whole body count Normal station practice is to perform incoming and termination whole body counts on all workers issued dosimetry. Apparently, the allegers were inadvertently not scheduled for incoming counts. The inspector randomly selected several additional contractor workers that recently performed

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RWP work; records showed that both incoming and termination whole body l counts were performed as required. It was apparently fortuitous that the two all%ers did not work in areas which would have required whole body counts by ZRP 1201-2. This matter was discussed at the exit meetin The licensee should consider strengthening this area including scheduling of whole body counts and documenting exemptions thereto.

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Findings: While the allegation was substantiated, it does not represent a violation of regulatory requirements or licensee procedure No violations or deviations were identifie . Exit Meeting The inspector met with those noted in Section 1 on August 28, 1987, to discuss the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the f inspection. The licensee identified no such documents / processes as proprietary. In response to the inspector's comments, the licensee acknowledged the inspector's concerns regarding the excessive number of out-of-service process radiation monitors. The licensee stated

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this was initially identified by members of their Rad / Chem Department l

and brought to the attention of Station Management (Section 7).

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