IR 05000302/1990011
| ML20043D310 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/21/1990 |
| From: | Gloersen W, Hughey C, Potter J, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20043D309 | List: |
| References | |
| 50-302-90-11, NUDOCS 9006070353 | |
| Download: ML20043D310 (11) | |
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UNITED 8T Af tt
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g NUCLEAN REGULATORY COMMISSION g
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101 teAmitTTA STRtiT.N.W.
I AT LANT A, etOmel A 30323
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MAY 2 31990 Report No.:
50-302/90-11 Licensee:
Florida Power Corporation Docket No.:
50-302 License No.: DPR-72 l
facility Nane:
Crystal River 3
Inspection Conducted:
April 2-6 and April 23-27, 1990 Inspectors:
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leersch Date Signed
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Accompanying Perso nel y E liott Approved by:
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Facilities and Radiation Protection Section
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l Emergency Preparedness and Radiological
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Protection Branch
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l Division of Radiation Safety'and Safeguards
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StJWARY Scope:
This routine, unannounced inspection was conducted in "the areas of implementation of strike plans during an extended strite and occupational
i radiation safety during extended outages.
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Results:
In the areas inspected, violations or deviations were not identified.
Based on interviews with licensee management, supervision. personnel from various
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station departments, and records review, the inspectors determined that the radiation protection program was managed adequately.
During the walkout of contract health physics personnel, the licensee provided adequate radiological job coverage.
The licensee's programs for external and internal radiation exposure controls were effective.
i One unresolved item was closed involving high dose rates in a radiation area (Paragraph 9).
9006070353 +o0523 PDR ADOCK 05000302 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Alberdi, Manager, Nuclear Plant Technical Support
- D. Beach, Supervisor. Site Nuclear Engineering Services
- G. Becker, Manager, Site Nuclear Services
'J. Brandley, Manager, Nuclear Internal Planning
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R. Browning, Dosimetry Supervisor
- 4R. Fuller, Senior Nuclear Licensing Engineer
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5. Gary, Corporate Health Physicist
- 4V. Hernandez, Supervisor, Nuclear Quality Assurance Surveillance
- B. Hickle Manager, Nuclear Plant Operations
- S. Johnson, Manager, Site Nuclear Services E. Kictaret, ALARA Specialist M. Manninen, Chief Health Physics Technician
- 4W. Marshall, Supervisor, Nuclear Operations
- 4P. McKee, Director, Nuclear Plant Operations
- J. Roberts, Assistant Chemistry Radiation Superintendent
- S. Robinson, Superintendent, Chemistry and Radiation Protection
- M. Siapno. Health Physics Supervisor
- R. Widell, Director, Nuclear Operations Site Support
- D. Wilder, Manager, Radiation Protection
- 4M. Williams, Nuclear Regulatory Specialist Other licensee employees contacted during this inspection included craftsmen, engineers, operators, technicians, and administrative-personnel.
NRC Resident Inspectors
- W. Bradford. RI
- P. Holmes-Ray, SRI
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- Attended exit interview on April 6, 1990
- Attended exit interview on April 27, 1990
- 4 Attended both exit meetings
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2.
Implementation of Strike Plans during an Extended Strike (92711)
Phase I of this inspection was conducted on April 4-6, 1990, to observe
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licensee performance during a walkout of contract health physics (HP)
technicians.
The licensee planned for 184 Contract HP technicians, decontamination personnel, and clerks to support refueling - outage operations that began on March 14, 1990.
On March 26, 1990, all but i
30 contract personnel walked off the job resulting from union activities.
The licensee innediately contacted other contract support companies and
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began to replace personnel participating in the wallout.
In the interim,
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job coverage for radiological operations was provided by 30 licensee and 30 contract technicians.
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The inspectors made tours of the Auxiliary and Reactor Buildings over a three day period observing licensee performance.
Major operations in progress included:
steam generator (S/G) eddy current testing, reactor coolant pump 1-D shaf t replecement, S/G nozzle dam installations; S/G drain valve repair, and pres rations for S/G water slap cleaning.
The inslectors also attended daily outage status meetings to determine HP tec1nician work load and impact on the outage schedule due to the walkout.
The inspectors determined that all critical path jobs and some priority jobs were being adequately covered by HP technicians and no discrepancies
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in HP performance in job coverage were observed.
Based on observations HP technician job coverage, discussions with HP management, supervision, and technicians, observation of training, attendance at outage progress meetings and records reviews, the inspectors determined that radiological controls for scheduled work were performed adequately and that HP management and supervision actions were conservative in controlling radiological operations during the outage.
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No violations or deviations were identified.
3.
Changes (83750)
The inspectors reviewed the licensee's Radiation Protection Program to determine if any major changes occurred since the last inspection in organization, personnel, facilities, equipment, programs and procedures.
The were no significant changes in the licensee's organization.
Radiation protection staffing levels were adequate to manage the normal operations for the one unit site.
To support the refueling outage, including major work activities such as the installation of the S/G nozzle dams and reactor coolant pump shaft inspections and maintenance, the licensee supplemented its staff of 30 HP technicians with approximately 140 contractor HP technicians.
During this inspection, the inspectors observed that the licensee had completed the modifications to the radiation control area (RCA) access control point.
The modified RCA access control point allowed for improved control of individual ingress to and egress from the RCA. The inspectors observed, upon exiting the RCA, that there was no information sign indicating that all per onnel items such as tools, notebooks, and writing instruments must be surveyed prior to exiting the RCA.
The licensee agreed that an information sign would help preclude an inadvertent release s
of radioactive material from the RCA.
During several observations of the RCA exit area, individuals leaving the RCA had their personal items surveyed prior to exiting.
In addition, the licensee had completed installation of the new Radiological Data Management System (RDMS) for improved control, monitoring, and tracking of individual and task dose.
The RDMS had limited use for this refueling outage since its
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implementation was concurrent with the start of refueling outage number 7 (Rf7) and there was an inadequate amount of time to enter the dose history records of all the contractors supporting outage work activities.
Once the RDMS is fully implemented, individuals entering the RCA would be
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required to interact with the system.
RCA access would be achieved by entering a radiation work permit (RWP) number for which that individual had been approved.
RCA access would be controlled by several nethods, for exam (1) was not approved for a particular RWP; (2)ple, if the individual: exceeded his administrative dose allotment; or (3 logged out of the RCA, then access would be denied.
Individuals who are denied RCA access are instructed to report to HP.
Upon exiting the RCA, individuals would be required to interact with RDMS and enter their accumulated dose as measured by their pocket ion chamber (PIC).
No violations or deviations were identified.
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4.
Training and Qualification of New Personnel (83750)
The inspectors reviewed the licensee's program for training contract HP personnel.
During the review, the inspectors attended site specific classroom training for the contract HP technicians and observed HP job coveraDe during nozzle dam installation training.
Contract HP technicians
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received 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of site specific training in a classroom setting. The inspectors attended classroom lectures for a class of approximately 60 contractors and reviewed the test results.
The inspectors also reviewed approximately 10 resumes and 40 training records of selected HP contract personnel to determine the experience level of the student and appropriateness of job assignments.
Prior to site specific training the contract HP technician must have passed general employee training (GET)
and a pre-test to determine the knowledge and skills of a candidate. The inspectors reviewed the training records and progress in training for approximately 40 students.
The inspectors determined through records review, observation in the classroom, and examination of completed tests that training was of high quality and well supported by lesson plans, that instruction and class participation in discussing the subject material was good, and that the licensee's training program for contract HP technicians was conducted in accordance with licensee procedures.
No violations or deviations were identified.
5.
External Exposure Control (83750)
10 CFR 20,202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment.
By direct observation, discussion with licensee representatives, and a review of selected records, the inspectors determined that personnel dosimetry was used effectively and in accordance with requirements for monitoring external exposure.
During tours of the Auxiliary Building and Reactor Building, the inspectors observed use of thermoluminscent dosimeters (TLDs) and PICS.
Individuals wearing protective clothing (PC)
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placed their TLDs and PICS in plastic beggies and attached the bag to the
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outside of their PC so that the dose as neasured by the PIC could be monitored frequently.
Each individual entering a high radiation area was also issued a dose rate instrument.
The inspectors reviewed selected dosinetry records for the period covering January 1,1990 to April 25, 1990, and observed that ten individuals had i
received greater than 1,250 millirem (mrem) during the second quarter of 1990. The maximum reported dose was 2,078 mrem. The inspectors determined that for selected individuals in that group, the licensee was in compliance with the requirements of 10 CFR 20.101(b).
The inspectors also verified
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that the licensee had determined the individuals' accumulated occupational dose to the whole body on Form NRC-4 and had complied with the requirements of 10 CFR 20.102.
The inspectors also determined that the licensee was in conpliance with 10 CFR 20.202(c) which requires that personnel dosineters used in accordance with 10 CFR 20.202(a) be processed by a laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the appropriate types of radiation. The licensee utilizes a vendor to process the TLDs.
The vendor was NVLAP accredited in test Categories I through Vll.
Although the vendor was accredited in Category Vill, the licensee does not routinely use the TLD to measure neutron dose equivalent.
The-licensee's normal practice was to restrict work in neutron fields.
In the event that the licensee must determine neutron dose, the licensee's preferred method was to multiply the time spent in the neutron field by the neutron dose rate.
During the refueling outage, the licensee's TLD processing vendor had a representative onsite with a TLD reader for special processing of dosinetry devices.
The licensee also had a quality control / quality assurance (QC/QA) confirmation program for monitoring TLD l
performance. The QC checks were perforned quarterly by another vendor who was not associated with the TLD processor. The inspectors reviewed the QC data for the fourth quarter 1989 and observed that the licensee's TLD processor passed in all testing c3tegories.
l The licensee provided weekly individual accumulated dose reports to l
departmental managers.
Individuals on the report were ranked by descending dose.
For contractor organizations involved with high dose jobs, the individual dose reports were provided once per shift.
l Individuals were also able to get a daily status of their dose indirectly by looking at their RFP dose margin.
No violations or deviations were identified.
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InternalExposureControl(83750)
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10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a l
l respiratory protective program that includes, at a minimum:
air sampling to identify the hazard; surveys and bioasscys to evaluate the actual exposures; written procedures regarding supervision and training of personnel and issuance of records; and determination by a physician prior
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respiratory protective equipnent.
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Respiratory Protection t
Eleven personnel were selected from two RWPs where respiratory protection was required.
These RWPs permitted eddy current testing
equipment installation inside the S/Gs.
The work areas had been determined through surveys to be potential radioactive airborne containination areas. The inspectors verified that all 11 workers had passed fit tests for the type of respirators indicated on the RKPs (Scott-o-ramic and MSA), had a current annual nedical examination, had a current whole body count (WBC), and had received General Respiratory Protection Training.
. This was verified throu Nuclear Operations Training and Information System (NOTIS)gh the This
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plant specific data base was updated daily, b.
Containnent Airborne Radioactivity Sampling Program The licensee's program for determining airborne radioactivity concentrations in containnent during the outage consisted of the following components:
(1) A portable continuous air monitor (particulate only) was located on the refueling floor in containment.
(2) Daily high volume grab samples for particulates and iodine
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activity, and grab samples (one liter) for noble gas activity were obtained on each level of containment.
(3) Particulate, iodine, and noble gas activities in containment were also continuously monitored through the Reactor Building VentMonitor(RMA-1).
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(4) Additional air samples were taken as needed for more specific i
and. localized RWP and work requirenents'in containnent.
(5) Once per shift air samples from outside containnent (outside air)
were collected and analyzed for naturally occurring radioisotopes.
The containnent high volune air samples results would then be corrected for any positive results from these outside samples. The licensee considered this necessary because of the close proximity of several collocated fossil fuel power plants and the high uranium / thorium content of the local soil.
A review of the air sample results from the second week of the inspection indicated airborne radioactivity concentrations in containment to be well below the requirenents for respiratory protection.
The inspectors concluded the containnent air sampling.
3rogram to be adequate in determining general airborne radioactivity iazards in containnent.
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c.
Whole Body Counting Program The licensee's WBC systems consisted of the following equipment:
(1) A Canberra Model 2250 Fastscan standup whole body counter containing two 4 x 4 x 16 inch Sodium Iodide detectors.
(2) A Canberra Model 228002 Accuscan II whole body counter containing two 25 percent relative efficiency intrinsic germanium detectors.
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i The Fastscan was routinely used for day to day WBC operations with a one ininute count time (two minutes for investigatory counts).
The Accuscan system was not routinely used because of recurring electronic problems.
The inspector reviewed the Fastscan QC plots for the period March through April 1990, which included those for background, percent ain, percent error, efficiency (activity), peak fit and resolution centroid channel).
These checks were perforned at least shiftly twice per day) using a mixed Cobalt-60/ Cesium-137 check source.
No significant deviations outside of the pre-established limits were t
noted and instrunent operability appeared stable.
These limits were based on data collected during the previous month QC checks, t
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The licensee and the inspectors discussed the possible need for
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annual calibrations of the WBC systems.
An initial calibration was
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perfonied by the vendor in 1987, and routine calibrations were not recomnended by the vendor.
The licensee maint61ned that any instrunent accuracy / drift problems would be detected during the routine shift QC checks.
The inspectors were concerned with long term drift from the original calibration since QC acceptance parameters were recalculated monthly using data from the previous
months QC checks and not from data. based on a recalibration.
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licensee agreed to address the issue of calibration frequencies further.
The inspectors also noted that the licensee was not involved in a cross-check program for the WBC systems.
The licensee and the l
inspectors discussed the benefits of participating in such a program as a general improvenent to the WBC QC program. :The licensee agreed
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to pursue it further although no formal consnitments were made.
The inspectors randomly reviewed 75 recent WBCs performed on the Fastscan whole body counter.
Of the 75, there were nine positive indications.
Of the nine positive indications, four were external'
body / clothing contaminations that were decontaminated and cleared.
The remaining five were due to internally deposited Cesium-137 and were all well below one percent maxirnum permissible body burden (MpBB).
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ho violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring (83750)
The licensee was required by 10 CFR 20.201(b) and 20.401-to perform surveys and to n.aintain records of such surveys necessary to show compliance with regulatory limits.
During plant tours, the inspectors examined postings to control contamination, high radiation, and radiation areas in the Reactor Building and Auxiliary Building.
The inspectors noted that survey practices were adequate and that the technicians demonstrated an adequate awareness of
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the limitations of the survey instruments.
Survey data and information on I
plant conditions for use in work planning and dose control were l
disseminated in a timely manner.
During tours of the Auxiliary Building, the inspectors observed some examples of apparent inconsistent postings of radiation areas.
For example, areas within the Nuclear Sample Room and the Block Orifice Room were posted as "High Radiation Areas, dose rates greater than 1,000 mR/hr" and yellow flashing lights were used to identify the hazards. A selected
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review of past survey records - of those areas and interviews with HP
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technicians indicated that contact readings of various pipes and valves were at times approximately 1,000 mR/hr, however general area dose rates
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at greater than 18 inches were much less than 1,000 mR/hr. Additionally, the inspectors noted that the make-up post-filter room was locked and posted as a "High Radiation Area" in accordance with Technical Specification (TS) 6.12; however, the usual extra information on the posting was lacking, indicating that dose rates were greater than 1,000 mR/hr, making the worker unaware of the actual radiological hazard that existed.
Information Notice (IN) No. 84-82 " Guidance for posting Radiation Areas" provided guidance to posting of radiation areas at
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nuclear power plants, including the intent of 10 CFR 20.203(b) to alert
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personnel to the presence of radiation and to aid them in minimizing j
exposures. Also, the circumstances of each situation must be evaluated to
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ensure that posting practices do not detract from this intent by
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(1) desensitizing personnel through overposting or (2)failing to i
sufficiently alert personnel to the presence and location of radiation l
j arent.
The inspectors also examined the licensee's radiation detection l
instrumentation and verified that (1) the portable instruments were in
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calibration; (2) there was an adequate supply; (3) the instruments were H
properly maintained; and (4) the performance checks of survey and f
monitoring equipment were performed daily.
To support this refueling outage, the licensee purchased an additional 16 Eberline R0-2As and l
10 R0-2s. The licensee performed all portable instrument calibrations
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onsite as well as minor repairs.
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O The inspectors also reviewed records of personnel contaminations for 1989 and the RF7 outage.
During 1989, the licensee only experienced 78 personnel contaminations (30 clothing; 48 skin).
During the tine period between March-May 1989, the licensee was in an outage due to the Reactor Coolant Pump 1A failure.
As of April 25, 1990, the licensee identified 67 skin contaminhtions and 11 clothing contaminations.
Most of the skin contaminations occurred on the hands.
The outage work was approximately 50 percent complete.
The 1990 station goal was 150 personnel contaminations.
Although the licensee had not experienced an excessive number of personnel contamination events (PCEs) during the past several years, the inspectors and licensee representatives discussed nethods for tracking personnel contaminations.
Some of the tracking methods discussed included:
root cause; work group or departnent; and body or clothing location.
No violations or deviations were identified.
8.
Maintaining Occupational Exposures As Low As Reasonably Achievable (ALARA)(83750)
10 CFR 20.1(c) states in part that licensees shall make every reasonable effort to maintain radiation exposures ALARA.
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ALARA Goals and Objectives The inspectors reviewed the facility's progress towards achieving its ALARA goals.
The licensee had originally established 288 person-rem as the 1990 collective dose goal for the station in September 1989. This goal was based on an outage duration of 74 days times an average daily collective dose of 3.8 person-rem and did not include any unplanned outages.
During November 1989, the Significant Job List (SJL) for RF7 outage was developed which resulted in a 327 person-rem
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collective dose estimate.
During January 1990, it was decided that a steam generator (S/G) nozzle dam installation project should be added to the RF7 outage plan (an additional 30 person-rem).
In March 1990, the hydro cleaning project (discussed further below) gen peroxide chemical was removed from the
>thedule which added an estimated 71 person-rem to the collective dose goal.
On March 16, 1990, a revised SJL was submitted which resulted in a 356 person-rem RF7 collective dose estimate. The licensee had recognized and acknowledged that the basis for the original RF7 outage goal of 288 person-rem was weak since at the time the SJL had not been completed.
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inspectors and licensee representatives discussed the importance
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of establishing realistic goals based on anticipated work,
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man-hour estimates, and representative job-specific dose rates.
The inspectors also discussed peasures of ALARA program effectiveness, including sucesses in meeting pre-established ALARA goals.
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b.
Radiation Source and Field Control Prior to the outage, the licensee had considered a hydrogen peroxide
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inducedcrudburstduringthecooldown(Mode 5)forRF7. The purpose of this crud burst was to loosen activated corrosion products from the oxide layers of the reactor coolant system (RCS) and remove them
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through the Mateup and Purification system thereby reducing radioactive source term and general dose rates.
During a previous mini-outage (RCV-8), testing had indicated unacceptable vibration
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levels in the reactor coolant pumps when running the pumps in Mode 5 (low RCS pressure).
These pumps were required to help remove the activated crud by keeping the crud in suspension during the process and thereby areventing redeposition.
A solution to the problem was
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found involving running the pumps at a higher RCS system pressure and raising various interlocks to allow the simultaneous operation of the
reactor coolant pumps (RCPs) and the Decay Heat system. However, due to time end equipment installation constraints the licensee did not
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perform the crud burst which, as di: cussed above, cost the licensee an estimated additional 71 person-rem for the outage. Current alens called for a hydrogen peroxide crud burst to be strongly consicered prior to the next outage (RF8),
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Other ALARA Initiatives
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During the outage the licensee installed RCS cold leg nozzle dams in the S/Gs.
These dams would allow flooding of the cold legs and therefore flooding of the refueling canal. This allowed simultaneous refueling and S/G maintenance activities hopefully reducing overall outage times.
In order to hold the nozzle dams in place, permanent i
retaining rings had to be installed in the S/Gs this outage at a cost
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of an additional 20 person-rem.
Exposure levels were kept to a
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minimum by the use of a S/G mock-up which maintenance personnel used to practice retaining ring installation.
The licensee indicated; however, that future exposure reductions around the S/Gs from the nozzle dams should be realized, due to increased water shielding in the coolant legs and the reduction in overall outage time.
Also noted was the use of prefabricated metal " tents" around the S/G lower manways during the outage.
These buildings appeared more effective than the plastic tents in that 1) improved ventilation should result in lower exposures (airborne); 2) the buildings are reusable resulting in radwaste reduction; 3) contamination would be more controllable and, 4) control of maintenance activities around the S/Gs would be more effective.
No violations or deviations were identifie,
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9.
Followup (92701)
(Closea) Unresolved Item (URI) 50-302/90-06-01:
High Dose Rate in a Radiation Area.
During routine area surveys, HP technicians located a plastic bag with a contact reading of 3.5 R/hr stored in a waste drum (40 niR/hr contact) in a posted radiation area.
The inspectors reviewed the event and determined that licensee personnel took appropriate corrective actions in relocating the plastic bag to a radwaste storage area and no apparent violations of NRC regulations occurred during the
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time the bag was stored in the radiation area. This item is closed.
10.
Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on April 6 and April 27, 1990.
The inspectors summarized the scope and findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regard to docunents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.
Dissenting comments were not received from the licensee.
One URI was closed involving high dose rates in a radiation area (paragraph 9).
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