IR 05000312/1985012

Insp Rept 50-312/85-12 on 850508-10 & 13-14.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Activities During Refueling Outage Conditions,Including Review & Audit Activities & External Occupational Exposure

ML20128A182
Person / Time
Site:	Rancho Seco
Issue date:	06/12/1985
From:	Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20128A181	List: IR 05000312/1985012 ML20128A176
References
50-312-85-12, NUDOCS 8507020581
Download: ML20128A182 (17)

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U. S. NUCLEAR REGULATORY COMMISSION REGION'V Report No. 50-312/85-12 Docket No. 50-312 License No.DPR-54 Licensee: Sacramento Municipal Utility District P. O. Box 15830 Sacramento, California 95813 Facility Name: Rancho Seco Nuclear Generating Station Inspection at: Clay Station and Sacramento, California Inspection conducted: May 8-10, 1985, May 13-14, 1985 and the telephone discussion of May 28, 198 Inspector: hh wh et g FI. CT ITi s , Radiatic i Specialist __4/12)igned Date s Approved by: 9 ok y p gg

. P.7 ns, Chief, Facilities Radiological Dateb[igned_

Protection Section Summary: Inspection onjfay 8-10,1985, May 13-14,1985 and the telephone iiTiscussion of May 28,1985 (Report No. 50-312/85-12)

Areas Inspected: Routine unannounced inspection by a regionally based inspector of radiation protection activities during refueling outage conditions; including review and audit activities, actions taken on enforcement and followup items, external occupational exposure, personnel dosimetry, contamination and radiation survey record reviews, radiation protection organization, contamination control practices, allegation number RV 85-A-024, and a tour of the licensee's facility. The inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> onsite time by one inspecto Results: Of the fourteen areas inspected, no violations or deviations were

_ identifie D0614 POR 0 ADOCK 05000312 PDn

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'2 Details 1. Persons Contacted Sacramento Municipal Utility D'istrict (SMUD) Personnel G. Coward,. Plant Superintendent ,

R. Columbo, Regulatory Compliance Superintendent

• R. Miller, Chemistry and Radiation Protection Superintendent (C&RPS)

• F.' Kellie, Assistant Chemistry and Radiation Protection Superintendent (AC&RPS) ,

• J. Reese, Plant Health Physicist  !

J. Jewett, Site QA Supervisor

• H Canter, QA Surveillance Supervisor '

• A. G. Schweiger, Manager QA

• N. Brock, Elect /I&C Superintendent

• S. Redeker, STA Supervisor

• J. J. Field, Engineering & QC Superintendent

• Speight, Regulatory Compliance S. Manofosky, Senior Chemistry Radiation Assistant (SCRA)

G. Martin, Acting SCRA S. Nichols, SCRA B. Rodgers, Engineering Specialist for ALARA F. Thompson, Maintenance Training Supervisor L. Kelly, Dosimetry Clerk S. Cox, Clerk Typist-N. Lucero, Clerk Typist J. Mau, Training Superintendent J. Bowser, Training Instructor

• R. Lawrence, Mecharical Maintenance Superintendent Nuclear Regulatory Commission

• J. Eckhardt, Senior Resident Inspector

• G. Perez, Resident Inspector Babock and Wilcox (B&W)

• J. Shelter, Outage Manager Applied Radiological Controls P. Sawyer, Supervisor, Senior Radiation Protection Technician D. Taras, Lead, Senior Radiation Protection Technician E. Clements, Senior Radiation Protection Technician (SRPT)

J. Butler, SRPT D. Butler, SRPT R. Rewalt, SRPT W. Young, SRPT J. Cambre, SRPT i

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. Nuclear Plant Service (NPS)

P. Courtney, Plant Superintendent C. E. Homen, Pipefitter Foremen C. Rowlings, Radiation Protection Coordinator

• Denotes attendance at the exit interview conducted on May 14, 198 In addition to the individuals identified above, the in>.pector met with and held discussions with other members of the licensee's and contractors staf . Licensee Actions On Previous Inspection Findings a) Enforcement Items (Closed, 50-312/85-03-01) Inspection Report 50-312/85-03, paragraph 3(a) identified that environmental radioiodine and particulate airborne samples were not obtained at the frequencies specified in the Technical Specification An examination of the actions established by the licensee for assuring samples are obtained at the required frequency was conducted. The examination included a review of environmental monitoring records and a discussion with the SCRA responsible for implementing the radiological environmental technical specification progra The examination revealed that the sampling which was previously conducted by contractor personnel is now being accomplished by the licensee's staff. The corrective action appears to be satisfactor This matter is close No violations or deviations were identifie b) Followup Items 1) (Closed, 50-312/83-18-02) Inspection Report No. 50-312/83-18, Section 5, identified inspector concerns related to the quality of internal audits conducted by the Chemistry and Radiation

< Protection group. The matter was discussed with the SCRA assigned responsibility for quality control (Q.C.) audit Health Physics and Chemistry internal check lists for the period of January 1984 through March 1985 were examined. The inspector also examined Quality Assurance surveillance and audit reports of the licensee's Chemistry and Radiation Protection program that were performed by the licensee's quality assuran,ce group during 198 The inspection' disclosed that internal quality control surveillances of Chemistry and Radiation Protection activities

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are conducted weekly. The results of the weekly quality control surveillances are reviewed by the SCRA responsible for QC, the Assistant Chemistry and Radiation Protection

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.. ., 3 Superintendent and,' as appropriate, the plant Health Physicist or Chemis The quality assurance group has recently hired two individuals having broad experience in Chemistry and Radiation Protectio The quality assurance group is also in the process of adding a senior reactor operator to their staf The inspectors examination of the internal quality control reports and quality assurance surveillances and audit reports revealed that there were remarkable improvements in this are This matter is closed (83-18-02).

2) (0 pen,50-312/83-12-05) Region V Inspection Reports 59-312/83-12 and 50-312/84-17 identified concerns with the licensee's retraining and replacement training programs for the SCRA's and CRA's which are required to be implemented in accordance with Section 6.4.1 of the Technical Specification An examination, consisting of a review of training schedules and discussions with the licensee.'s Training Superintendent and Maintenance Training Supervisor, was conducted for the purpose of determining what actions were taken to resolve the concerns identified in the inspection report The discussions revealed that the licensee has not accomplished any retraining of SCRA's and CRA's since March 1, 1985. The licensee's training staff indicated that no retraining will be provided during the remainder of the refueling outage which is expected to be completed before July 1, 1985. The Maintenance Training Supervisor informed the inspector of the following:

• A Chemistry and Radiation Protection training instructor had just recently resigned for a promotional opportunity made by another utility compan * Job Task Analysis studies for I&C, Chemistry, Ilealth Physics, Electrical Maintenance, Hechanical tlaintenance and the Technical Staff were recently performed to determine what improvements are necessary in order to achieve INPO training accreditatic A Vice Principal from the San Juan School District was recently hired to head up the implementation of the INP0 accreditation program. The Training Superintendent stated that the individual did not have any previous nuclear power plant experience. The superintendent added that the Vice Principal did have experience with the implementation of accredited training program * Both the Training Superintendent and Maintenance Training Supervisor indicated that the INPO accreditation program would probably not be ready for implementation until December of 198 .

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• The Training Superintendent stated that the responsibility for SCRA and CRA training would be reassigned under the direction of the General Employee Training Superviso The change is expected to take place upon completion of the refueling outag The Maintenance Training Supervisor informed the inspector that he did not feel that he could verify that the current replacement and retraining programs for SCRA's and CRA;s were consistent with Section 6.4.1 of the Technical Specifications due to poor documentation. The inspector informed the licensee of the need for maintaining the replacement and retraining program at a level that is commensurate with Section 6.4.1 of the Technical Specifications. This item will be examined during a subsequent inspection (83-12-05).

c) Action (s) taken on Information Notices (IN's)

(Closed, IN-84-50, IN-84-91, IN-84-94 and IN-85-06). The inspector verified that the licensee had received and completed an evaluation of the above listed IN's for applicability to Rancho Seco activities. This matter is closed (IN-84-50, IN-84-94 and IN-85-06).

3. Radiation Protection Program During the Outages Procedures and plans related to the licensee's radiation protection program for this refueling outage were reviewed and discussed with the licensee's staff. - Specific areas examined are as follows:

a) Supplie b) Job scheduling and plannin c). ALARA d) Exposure Contro *

a) External, b) Interna e) Survey ,

f) Radiation Work Permits, g) Audit h) Organization and Qualification of Personnel i) SCRA and CRA Training Program j) Personnel contamination occurrence The examination disclosed the following:

a) Supplies The inspector observed that sufficient supplies of anti-contamination clothing, respiratory equipment, portable dose rate survey meters, air samplers, pocket ionization chambers, (PIC's), personnel friskers, and portal monitors were available to

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conduct the work lr'elat'ed to the outage. The' supplies were distributed at,various locations throughout the licensee's facilit r .

-No violations or deviations'were identifie ~

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b) Organization,QualificationsandTrainig 1) Organization .

The licensee's Chemistry and Radiation Protection Organization

for the outage and normal. plant operations was examined. The

licensee's organization for the outage has not changed from what is described in paragraph 3.c of Region V Inspection Report 50-312/85-06. .The licensee 's Cherzistry and Radiation Protection Organization for normal operations has not changed from that' described beldw and in paragraph 4 of Inspection Report 50-312/84-17. The licensee's organization for normal operations is as follows:

Chemistry and Radiation Protection Superintendent (C&RPS)

Assistant Chemistry and Radiation Protection Superintendent (AC&RPS)

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Five Senior Chemistry Radiation Assistants (SCRA)

Twenty Chemistry Radiation Assistants (CRA)

Plant Health Physicist Plant Chemist The five SCRA's are assigned to waste management, environmental and Q.C., radiation protection, chemistry, and procedures. Two CRA's recently departed for promotional opportunities elsewher The current staff of 20 CRA's is four short of the authorized ceiling of 24. Only 11 of the 20 CRA's are

- currently qualified in both Chemistry and Radiation Protectio The remaining nine are only qualified in Cheaistry or Radiation

Protection. Plans for acquiring additional CRA's are being considere'd; however, a decision will not be made with respect to this topic until a General Dynamics study of the possible reorganization of the Chemistty and Radiation Protection Group has been completed. Discussions with SMUD management indicated that they expect the General Dynamics study will recommend that the Chemistry and Radiation Protection Croup be split into two separate groups.(e.g. Chemistry, Radiation Protection). The licensee stated that the four phases of the General Dynamics will take approximately one year. The phasgs and times involved are as follows:

Study /

Assessment Phase Area ' Time-1 Responsibility 4 weeks 2 Organizational 2 weeks 3 Organizational Analysis 5 weeks 4 , Assistance and Followup 9 weeks

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The licensee added that any recommendations made by General Dynamics will'. require a review and approval of both plant

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. management and the SMUD Board of Directors. The Plant Superintendent informed the inspector that they expected to receive the General. Dynamics recommendations sometime between July 1 and August 1, 198 ^

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-A The inspector was also informed that the C&RPS had announced

his intention for retirement. The effective date was set at-June 21, 1985. The' plant superintendent stated that he

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recently received authorization to replace the C&RPS. The

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plant superintendent stated that the C&RPS's position would be ,

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filled by any individual that could qualify.as a Radiation

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Protection Manager, (RPM) in accordance with Regulatory Guide 1.8, as prescribed in Section_6.3, " Facility Staff Qualifications" of the Technical Specificatio ,- _

The inspector was informed that the Assistant C&RPS would assume the C&RPS's duties until a replacement RPM was hire The inspector asked the licensee if the assistant C&RPS position would be filled until the RPM's position was fille ^

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The plant superintendent stated that they were strongly considering filling the assistant's position as wel .

The inspector discussed the above observations with the licensee's staff and at the exit interview. The inspector

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emphasized the need for expediting the completion of the

- o General Dynamics study and implementing a SCRA and CRA replacement.and retraining program that is consistent with

'Section 6.4.1 of the Technical Specifications. The need to

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provide the assistant C&RPS with assistance and consideration for replacing the departing C&RPS'with an individual that is

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certified was also emphasize '

No violations or deviations were identifie c) As Low As is Reasonably Achiev$able

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The' status of the work load and the outage work schedule -is discussed,in paragraph 3.d of In's'pection Report 50-312/85-06. The

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inspector verified that: (1) critical job planning meetings were

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held for the~ high' exposure jobs,: (2) mockup training was-conducted forithe critical jobs listed ~infthe inspection report, and (3) that

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the'ALARA man-rem goals, estimated for the outage were accomplished orbeing[ met. . Job planning man-rem expenditures records for the

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follcwing. work:were reviewed: 4-

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'o" '"A": Letdown Co~oler:

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• 1. 1. Letdown Piph,3 Modificatio'n

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"B"1 Reactor, Coolant' Pump Work

' Surveillance and Minor. Tasks

.* Steam Generator Eddy-Current and Tube plugging operations

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The inspector also observed steam generator mockup training evolutions in progress.at the time of this inspectio ~

A review of.an outage report of May 4, 1985 entitled as " Radiation Exposure Trend" indicated that.the man-rem. expenditures were .

slightly above the estimates originally predicted. The licensee

. expects that the man-rem expenditures will start to decrease and should subsequently decrease below the. original estimate-of 591 man .

rem. _The May 4 report. indicates that most' jobs are being-completed

- at exposures lower than originally predicted. The report indicates that there is increased surveillances by engineering,-supervision and health. physics personnel. The man-rem estimates for surveillances are currently approximately 60% higher than originally estimated. The licensee's ALARA group was in the process of evaluating the cause for this increas m The inspector observed that there was Lan increased emphasis on job -

planning meetings by the licensee's staff for this outage. Job planning-for critical jobs appeared to be improved over that

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performed during previous outage .The inspector observed that work during the inspection period-practices were consistent with the ALARA concep No violations or deviations were identifie ,

d) Exposure Control'

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1) External The licensee's personnel monitoring program for control'of'

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external occupational exposures during normal and outage-operations was examined and found consistent with the following requiremepts:

.Requireme t'

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10CFR Part 20.10 Radiation Dose-Standards for Individuals in Restricted Area '

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'e 10CFR' Part'20'102' . ,- Determination of Prior Dos ? -

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10CFR/Part"20'104' .

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Exposure of Minorsi

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"i 10CFR'Pa'rt>20i202' ,7 Personnel Monitorin av , y ,

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10CFR Part'20.408 - i eReports of Personn'el Monitoring

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on Termination. of Employment 'or -

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'( LThe li~censee[seimplementin[ procedures for assuring compliance

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with the 'above regulatory requirements were reviewed. The specific' procedures; reviewed are as follows:

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AP-305-1 Restricted and Controlled Area Access Requirements Including-Maximum Permissible Exposures, Film Badge 7 Issue, Multiple Badging, and Exposure

. Record 'AP-305-1A Maximum Permissible Dose AP-305-2 Radiation Dosimetry: Internal and

, , Externa AP-305-3 . Direct Reading Pocket Dosimeter Assignment and Us AP-305-4 Radiation Work Permit AP-305-8A Routine and Radiation Work Permit Survey ~

AP-305-20

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.Whole Body Countin '

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Representative personnel ra~diation exposure, bioassay,-prior exposure. history, PIC. records and termination reports were reviewed. Discussions with cognizant management personnel from

'..th'e lic'nsee's e staff were also hel s The'examina, tion and: discussions revealed that the licensee utilizes a personnel. film badge dosimetry service that is contracted from 'Landauer, Inc. . The licensee utilizes a back up Panosonic thermoluminescent (TLD) program of their own.The

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, plant-health physicist: informed.the inspector that the licensee

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was currently;considering going over to.a Landauer TLD personnel monitoring program Licensee records of pe'rsonnel extremity. monitoring were also reviewe The examination disclosed that the external occupational

.-exposures of workers were maintained at levels that are

- consistent with the regulatory requirements and applicable licensee procedure The examination of procedures revealed that they failed _to provide adequate instructions for determining the placement of

' dosimetry (see paragraph 5) on 'the portion of an individuals body receiving the highest exposur '

No violations or deviations were identifie , <

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The licens'ee's program.for. controlling internal exposures'was examined. The examination included a review of representative

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contamination and airborne survey records, and discussions

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Internal. exposures are controlled through' contaminatio'n surveys,' continuous air monitoring, grab air sampling, use of

NIOSH approved respiratory' protective equipment, and engineered

- controls designed to minimize personnel' internal; exposure The licensee's internal exposure control program appeared to be consistent with110CFR Part 20.103, " Exposures of Individuals to

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Concentrations of Radioactive Material in Air in Restricted Areas."

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No violations or deviations were identifie )- Personnel Contaminations Personnel contamination records for 1984 and 1985 were reviewed'

for the purpose of ascertaining the licensee's actions in the following areas:

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• Determining the need for external or internal dose assessmen Determining the cause for the contaminatio * . Trending and actions taken to prevent recurrenc The examination included a review of the following procedures:

4 * ' Emergency. Plan Prbcedure AP 316, " Personnel

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, Decontamination".

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Discussion's related to this topic were also held with the plant

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~The examination'discloie'd the following:

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Each skin conta'm'ination occurrence is investigated by the

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. plant' health physicis , f Trending of skin contamination occurrences are conducted

. quarterly by the plant health physicist or AC&RP .

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' *- Records'of. skin. contamination occurrences are placed in g 'the-individuals Exposure History Fil '

, iNeither * procedure (AP.-316 or AP-305-9C) requires: (1) an

' assessment of- the external exposure, -(2) determination of the probable cause,.:(3) orna record of personnel clothing

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, contamination occurrence ,

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'.Discussionstdith the health physicist revealed that the

, InstituteJof Nuclear Power Operations (INPO) had identified

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similar concerns during the first quarter of 1985. The-health physicist stated that he was in the process of preparing a

. procedure which will address the concerns identified by the

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inspector and'INPO. The health physicist stated that exposure assessments would be performed for the significant personnel contamination occurrences that were reported since 1983. The inspector concluded, from a review of the significant personnel contamination, occurrences, that nonpenetrating exposures of involved individuals appeared to be below 10CFR Part 20.101(a)

limit The inspector brought the above observation to the licensee's attention at the exit interview. The licensee committed to establish appropriate procedures for assessment of personnel exposures resulting from skin contamination. This item will be examined during a subsequent inspection (50-312/85-12-01, open)

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e) LSurvey The radiological monitoring program described in the licensee's Radiation Control Manual was examined to determine compliance with 10CFR Part 20.201, " Surveys". Representative radiation, contamination, and' air sample records for the period commencing with

. the start of this refueling outage were reviewed. . Control point posting survey data and surveys specific to Radiation Work Permits were also reviewed. Special surveys and/or non-routine surveys performed since;the start of the outage were also examine The inspector selected several instruments recorded as being used for performing surveys and reviewed.their calibration record ~

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The examination disclosed that the licensee's survey program appeared to be consistent with 10CFR Part 20.201. The examination,.

which included discussions with the licensee's radiation protection staff, disclosed that the radiation protection staff did not document the results of all of'the surveys they obtain as required by 10CFR Part 20.401 (b). This observation is further discussed in paragraph 5 herein and was brought to the licensee's attention at the exit meetin No violations or deviations were identified.

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The. inspection disclosed that the Quality' Assurance group audits and

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-W surveillances of radiation. protection and refueling outage-

, , < activities have improved,and are consistent with Section " Management s

', ' Safety- Review Committee" 6.5.2, of the : Technical Specification (see~ paragraph 2.b.1,-herein). The inspection' disclosed that 22 surveillances and 2 audits of radiation protection activities were conducted by.the licensee's quality assurance staff in 1985. The P -

audits and surveillances appeared to provide a more indepth

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appraisal of radiation protection. activitie No violations or deviations were identifie ~

g) . Radiation Work Permits The inspector reviewed the Radiation Work Permit (RWP) program for=

. conformance with the licensee's procedure AP 305-4, " Radiation Work

, Permits.". RWP.'s that were prepared for the outage were reviewed and were found to be consistent with procedure AP 305-4. The inspector noted from personal tours'and observations that workers were following the instruction provided~on the RWP' ~

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No' violations or deviatio'ns were identifie ~

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h) Respiratory Protection Progra ,

_Th'e inspector'noted from personal tours, observations, review of records,'and procedures that'the. licensee's respiratory protection program appeared to be consistent with 10CFR Part 20.103 (see paragraphs 3.~d.2 and 4, herein) an'd the guidelines and recommendations of the-following documents:

-Regulatory Guide 8.15, " Acceptance Programs for Respiratory Protection". ,

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• NUREG-0041, " Manual of Respiratory Protection Against

. . Airborne Radioactive Material".

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" Practices for Resp'iratory Protection".

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, .The licensee,'s jespiratory-protection program includes the

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Fit-up program. '

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Implementing Procedure The inspection'did not. reveal any instances where respiratory _

equipment had been issued to individuals who were not trained, fitted or~ medically screene No violations or deviations were identifie ' . Facility Tour The inspector and resident inspector toured the auxiliary, spent fuel storage, and turbine buildings. Confirmatory surveys were performed using an Eberline, Model 2 ion chamber and a Keithley, Model 36100 x-ray / gamma radiation detection instrument. The R0-2 instrument, SN#897 was due for calibration on June 1,1985 and the Keithley, SN#11108 is due for: calibration in August 198 The inspector noted that the licensees radiation detection instruments

.were operable and within current. calibratio The inspectors noted that personnel work p'ractices appeared to be consistent the applicable Radiation Work Permit (RWP) and radiation protection procedure A general improvement in cleanliness was observed during the tou The licensee's control of radiation areas, labeling and posting practices appeared to be consistent with 10CFR Part 19.11, " Posting of Notices to Workers" and 10CFR Part 20.203, " Caution Signs, Labels, Signals, and Controls".

The inspectors noted that a pressure measuring gauge, No. 5-16-74, installed on the New Resin Slurry Tank V-680 was filled with water. The-inspectors noted that a large backlog of contaminated tools and equipment used during the outage was beginning to accumulate in the veezzanine area of the auxiliary building. The inspectors _-noted workers were in the

. process of decontaminating the equipment. Decontamination methods

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consisted.of hand scrubbing and a Freon decontamination unit. The new *

ultrasonic unit installed in the decontamination room was not operational. Discussions with the. licensee's staff disclosed that the ultra' sonic unit;has never functioned properly since it was purchase ~

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The inspectors!b'rought the above , observations to the licensee's attention -

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uponicompletion of.the tour and at the exit interview. The inspector apprised the licensee of' commercially available decontamination units that 'would reduceithe" current ' labor costs expended for hand y i decontamination and'also reduce the amount of radioactive waste that is generated in themhand.decontami:ntion method, The inspector added that'

the commercially available' units would allow the licensee to maintain the b'acklo'g)of mater,ial to,a(minimum.;j

, i a $ !

The-inspector also noted'that the licensee has-leased a commercially

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-(e' g. }Iydro Nuclear) .available mobile trailer for processing respiratory

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equipment used'during the outage. The licensee informed the. inspector

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over what was used in the past. The plant health physicist informed the inspector that the licensee was considering purchasing a unit for permanent use. The health physicist stated that~the'new unit would include a respirator filter testing unit. , ,

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No violations or deviations were identified' .

, Allegation No. RV-85-A-0024 An individual, employed by a licensee contractor, contacted the NRC resident inspector on May 2, 1985 to express concerns with radiation protection polices and practices. To maintain anonymity the individual will be referred to as individual A. The concern expressed by individual A is as follows:

a) His whole body exposure may not have been properly evaluated due to

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the placement of his personnel monitoring devices during work associated with modification of the letdown piping. An examination of the allegation was conducted by the inspector between the period of May 8 and May 14, 1985. The examination included:

Interviews with Individual * Interviews with all remaining involved individuals from the licensee's permanent and contractors staf Review of applicable procedure *

Independent radiation measurements of the work are Review of all applicable radiation surveys, job planning records and personnel exposure record * A review of the applicable RWP used (e.g. RWP-239) for accomplishing the wor The examination disclosed the following:

a) Individual A, a pipe fitter, was assigned to support the dayshift activities associated with letdown piping modification work performed between the period of April 2 and April 30, 1985. His whole body exposure for the period of April 2 through April 27, 1985 was determined with dosimetry equipment (film badge and PIC) placed about three inches lower than chest level. The equipment was placed on a nylon lanyard. During the period of April 2 through April 27, 1985 radiation protection coverage was under the direction of a lead SRPT from ARC, Inc.. On April 27, the SRPT was replaced by another SRPT from ARC. The new SRPT, with individual A in attendance, performed a radiation survey. The new SRPT informed individual

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.A that the exposure rate in some locations of the work; are appeared to be double the radiation levels measured at where

. his dosimetry was-located. Both the new SRPT and individual-A i reported .th'e event. to their respective supervisors. Individual

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A_ continued to. provide support for the modifications until

- April 30, - 1985. Individual A's dosimetry was placed at head-

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s " level during the period of April,27 through April 30, 198 Individual A's concerns were reported'to'the licensee's plant

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- health physicist at the same time it was brought to the NRC's attentio "

. b) lAn investigation was started by the licensee upon receipt of the notification.by individual A's radiation protection:

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coordinator. The_ evaluation was still in progress at the time of this inspection, c) Individual A's exposure as' determined by PIC was 1610 mrem.on

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May 2, 1985. The individuals film badge was processed immediately. The exposure recorded from the film badge-

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processor was reported as 1580 mrem. A review of RWP's and

, . individual A's exposure history record revealed that only.1365-mrem of the 1580 mrem was received with his dosimetry placed at, chest level. The remaining 215 mrem was received while working

, other jobs or with dosimetry placed on his hea '

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d) Interviews with the dayshift ARC SRPT who covered the job between April 2 and' April 27 indicated that he had performed routine radiation surveys. The technician stated.that radiation levels were constantly changing during the time he covered the . job. The technician stated that the surveys h , performed indicated there was less than a 10% difference between chest and head level and _that he was constantly reminding workers of proper ALARA practices during the cours , ,

of work activitiest that were performed. The technician only

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recorded general area suivey's (e.g. reading taken at or.near

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- <j waist' level). : A profile. survey providing the chest and-head radiation measurements was not recorded. Individual A's-

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supervisor and co-workers stated.that the dayshift ARC-SPR that covered the work between April-2 and April 27 constantly reminded them of proper >ALARA work practic'es. The workers

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stated that'the ALARA practices imposed by the technician were

,_P instrumental.in reducing personnel exposures by a significant

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amount. ;

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e) The work ' space measured:approximately 4 feet wide x 16 feet long'x 7~ feet _high. The work space was very confined. Access to the area was difficult because of piping interference f) A radiation survey'taken on the swingshift. April 16, 1985

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indicated'the' chest radiation levels ranged from 30-40

, mrem / hour and head radiation levels ranged from 80-110 mrem /hr.

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A memorandum was placed in the job tracking file indicating-that the whole body dosimetry was placed at head level because of the difference between head and chest radiation levels. The

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, .memorandumindicatedihatftheplacementofdosimetryathea level was based on,the work evolution that was to be performe The dayshift ARC-SRPT:who covered the work between April 2 and April 27 stated he'did not see the April 16 memorandum nor had 4 anyone informed him of the~ memorandum or need for placing dosimetry at head;1eve .g) The radiation survey taken by the' ARC-SRPT on April 27 was a

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multi point survey.- 'A total of 50 points were surveyed on a

. horizontal and' vertical plane; The average head radiation

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' levels read 31% higher than at chest level, h) 'A subsequent multi profile survey (240 points) of the work area was taken by the SRPT who originally covered the work between April 2 and April 27. The survey taken on May 9, 1985 was in agreement with the survey performed on April 27. The technician stated that the radiation levels measured on May 9,'

1985 were not the same as the levels taken between April 2 and April 2 .

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i) The independent surveys performed by the inspector were in agreement with the survey levels reported by the licensee's April 27 and May 9, 1985 survey records. The surveys were obtained with Keithly Model 36100 survey instrument referenced in paragraph A review of the radiation work permit assigns the radiation protection technician the responsibility for evaluating location of whole body dosimetry. Procedure AP-305-4 which provides instructions related to the use of RWP does not provide instructions or guidelines for determining how to prescribe the location at which

. dosimetry is to be worn. Discussions held with other involved ARC-SRPT and Rancho Seco CRA's indicated they were uncertain of the proper criteria to use' for determining the location at which dosimetry should be. located.

.The above observation was discussed with the licensee's radiation protection staff and at the exit intervie During the -inspection the licensee made an adjustment on Individual A's personnel Exposure History records. The licensee added 31% of the 1385 mrem individual A had received to'his permanent personnel dosimetry records. Individual A's corrected total for the quarter was 2008 mrem. The licensee also committed to adjust the personnel exposure records of other involved workers who had received a total of 300 mre .

A memorandum, explaining the adjustment was provided to individual A by the licensee. The inspector also explained the licensee's actions to individual'A and his managemen Individual A and his management were satisfied with the results of the examination and the licensee's action Y p , .- , w 1 *e ,- --- ,w ,- - -- , , - ,

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The licensee agreed to establish criteria and to provide the instructions necessary for technicians to use in determining

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placement of personnel monitoring equipment. This item will be examined during subsequent inspection. (50-312/85-12-02).

6 Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 14, 1985. The licensee was informed that no violations or deviations had been identified. The scope and findings of the inspection were summarize The inspector emphasized the importance for:

1) Establishing guidelines for placement of personnel dosimetry (see paragraph 4). 85-12-01

2) Establishing procedures in the plant Radiation Control Manual for tracking personnel skin and clothing contamination occurrences and for evaluating personnel exposures resulting from such occurrences (see paragraph 5) 85-12-02 3) Completion of the General Dynamics study in an expeditious manner and providing the Assistant Chemistry and Radiation Protection Superintendent with assistance during the time it takes to find a replacement for the departing superintenden .

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