IR 05000313/1999002
| ML20202B792 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/25/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20202B783 | List: |
| References | |
| 50-313-99-02, 50-313-99-2, 50-368-99-02, 50-368-99-2, NUDOCS 9901290200 | |
| Download: ML20202B792 (14) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV
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Docket Nos.:
50-313
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50-368
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License Nos.:
DPR-51 NPF-6 Report No.:
50-313/99-02 50-368/99-02 Licensee:
Entergy Operations, Inc.
Facility:
Arkansas Nuclear One, Units 1 and 2 Location:
Junction of Hwy. 64W and Hwy. 333 South Russelville, Arkansas
Dates:
January 11 to 15,1999 Inspector:
Michael P. Shannon, Senior Radiation Specialist Approved By:
Arthur T. Howeli lll, Director
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Division of Reactor Safety-
' Attachment :
Supplementalinformation
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9901290200 990125 i
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PDR ADOCK 05000313 G
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-2-EXECUTIVE SUMMARY Arkansas Nuclear One, Units 1 and 2 NRC Inspection Report No. 50-313/99-02; 50-368/99-02 This announced routine inspection reviewed the radiation protection program focusing on Unit 2 refueling outage activities. Areas reviewed included exposure controls, controls of radioactive material and contamination, surveying and monitoring, the program to maintain occupational exposure as low as is reasonably achievable (ALARA), contractor training and qualifications, and quality assurance in radiation protection activities.
Plant Sucoort Overall, the external exposure control program was effectively implemented. High
radiation areas were properly controlled and posted. Radiological postings were clearly and consistently written and posted. Radiation workers wore their dosimetry properly and were knowledgeable of the general radiological conditions in their work area.
Radiation protection job coverage was appropriate for radiological work observed.
Radiation work permits were clearly written; however, radiological conditions were not consistently recorded on the radiation work permits. Some workers involved in the removal of steam generator manway covers and diaphragms were not experienced or mock-up trained (Section R1.1).
Housekeeping throughout the radiologically controlled area was very good. Areas were
free of debris, and tools and equipment staged for work in-progress were properly stored (Section R1.1).
A good internal exposure control program was in place. Continuous air monitors,
portable air samplers, and high efficiency particulate air filter ventilation units were appropriately used throughout the radiological controlled area to monitor and limit worker's airborne exposures. No problems were identified with the control, storage, and issue of respiratory equipment (Section R1.2).
Radiological work package tasks were well planned, and ALARA personnel were
appropriately involved during the outage planning stage. i.essons-learned from past similar work were incorporated into the radiological work packages. Staff shift turnover meetings were effective (Section R1.3).
Radiation workers used the contamination monitoring equipment properly. Radioactive
material containers were properly labeled, posted, and controlled. Contamination boundaries were clearly identified and properly posted. Radiological postings were conspicuous and clear (Section R1.4).
A very good ALARA program was implemented. The Unit 21999 outage exposure
budget of 89 person-rem was approximately 17 person-rem less than the 1997 Unit 2 refueling outage actual exposure, and was established with appropriate involvement by ALARA representatives and the station's ALARA managers' committee. Station and task activity exposures were appropriately tracked and trended by the ALARA staff.
Effective chemistry shutdown plans and controls were in place to accomplish the
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successful reduction of reactor coolant system dose rates by approximately 23 percent i
(Section R1.5).
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A good contractor radiation protection technician training program was implemented.
- Radiation protection management was appropriately involved in the oversight of the
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l contractor radiation protection training program (Section R5.1).
The 1998 and 1999 quality assurance radiation protection surveillance schedule f
covered appropriate areas of the radiation protection program. No problems or negative i
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trends were noted during the review of radiological condition reports written since
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October 1598 (Section R7.1).
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-4-ReDort Details l
Summary of Plant Status j
Unit 2 was in the first week of a refueling outage. Unit 1 operated at full power.
t IV, Plant SuDDort i
R1
' Radiological Protection and Chemistry Controls I
R1.1 External Exoosure Controls a.
Inspection Scope (83729/83750)
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Radiation workers and radiation protection personnel involved in the external exposure control program were interviewed. Several tours of the radiological controlled area,
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including the Unit 2 reactor building, were performed. The following items were reviewed:
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Control of high and locked high radiation areas
Radiation work permits
Job coverage by radiation protection personnel
Housekeeping within the radiological controlled area
Personnel dosimetry use
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Observations and Findinas l
During tours of the radiological controlled area, including Unit 2 reactor building and
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turbine deck, the inspector observed that high radiation areas were properly controlled and posted. All Technical Specification required high radiation area doors were locked or properly guarded.
All radiological postings were clear and conspicuous. Color coded radiological survey
maps, which identified radiation, high radiation, and locked high radiation areas posted
outside each room, reflected general radiological conditions within the room. From field interviews with radiation workers, the inspector determined that these maps were easier for station personnel to read and understand than the previously posted non-color coded survey maps.
Radiation workers interviewed by the inspector wore their dosimetry properly and were knowledgeable of the general radiological conditions in their work area and the proper response to electronic dosimeter alarms.
During tours of the radiological controlled area, the inspector noted that radiation protection job coverage was appropriate for radiological work observed. Radiation protection personnel briefed radiation workers on radiological conditions in their work
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area, verified that radiological conditions had not changed prior to the start of the job, and provided proper air sample monitoring.
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Radiation work permits and area radiological survey maps were written clearly providing station workers with the appropriate controls to safely accomplish their tasks. However, the inspector identified that radiological conditions were not consistently recorded on the
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radiation work permits. Section 6.2.1 of Radiation Protection Procedure 1012.019,
" Radiation Work Permits," Revision 6, states, in part, when the need for a radiation work permit is identified determine the radiological conditions for the proposed work area.
i The inspector noted that when radiation protection personnel determined the
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contamination and radiation levels in the work area, the data was entered on the radiation work permit; however, when the licensee determined the airborne conditions in
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the work area this information was not recorded on the radiation work permit. From discussions with members of the licensee radiation protection staff, the inspector
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concluded that the radiological condition information was used by the licensee, in part,
to determine if current conditions differ significantly from planned conditions. Not i
recording expected airborne conditions on the radiation work permit could lead to improper radiclogical controls if airborne conditions differ significantly from expected
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conditions. The radiation protection manager stated that he would review the program to address the inspector's observation.
The inspector attended pre-job ALARA briefings for the removal of the Unit 2 steam generator manway covers and diaphragms and installation of the nozzle dams. Both briefings were conducted in a professional manner Lead group personnel discussed their job scope in detail. However, during the briefing for the removal of the steam
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generator manway covers and diaphragms, the mechanical maintenance supervisor did not know which maintenance worker would be assigned to a particular task or steam generator. The inspector noted that the briefing was not stopped to address this issue.
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The inspector commented that not having this assignment in-place prior to the meeting could lead to confusion between the mechanical maintenance workers and radiation protection personnel at the job site. The licensee acknowledged the inspector's comment.
At the end of the briefing for the steam generator manway cover and diaphragm removal, the inspector asked the 12 mechanical maintenance personnel involved in the task if they had performed this task before. Six people stated that this would be their first time performing the job. During questioning, the inspector determined that none of these six people had performed the task on the mock-up. Task 2 of the steam generator radiation work permit (1999-2042, Revision 2) was used for the removal and replacement of the steam generator manway covers and diaphragms. The inspector noted that Task 2 did not require workers to be mock-up trained,if not experienced.
The inspector noted that because of the increased radiation levels (approximately 1.2 rems per hour) when the manway covers and diaphragms were removed, mock-up training for personnel not f amiliar with this work would be beneficial because it should reduce work errors and exposure. At the exit meeting on January 15,1999, the maintenance manager informed the inspector that sending untrained personnel to perform the above task did not meet his expectations.
During both ALARA briefings, the radiation protection supervisor passed around a copy of the radiation work permit and radiological survey information to each person involved in the task. Both the radiation work permit and survey data were discussed in detail; however, during the briefing, the radiation protection supervisor held up the copies of
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6-information to refer to various sections. The inspector noted that the information was printed on a 8 by 11 inch piece of paper that made it extremely difficult for people more than 10 feet away from him to see where he was pointing. Additionally, the inspector noted that although workers were asked if they had any questions, no one was questioned about the radiation work permit, radiological conditions, or ALARA work methods to ensure that the information was correctly communicated to the workers involved in the task.
Housekeeping throughout the radiological controlled area was very good. The inspector noted that areas were free of debris and tools and equipment staged for work in-progress were properly stored.
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Conclusions Overall, a good external exposure control program was effectively implemented. High radiation areas were properly controlled and posted. All radiological postings were clearly and consistently written and posted. Color coded radiological survey maps posted outside each room were easy to read and understand, and reflected general radiological conditions within the room. Radiation workers wore their dosimetry properly and were knowledgeable of the general radiological conditions in their work area.
Radiation protection job coverage was appropriate for radiological work observed.
Radiation work permits were clearly written; however, radiological conditions were not consistently recorded on the radiation work permits. Some workers involved in the removal of steam generator manway covers and diaphragms were not experienced or mock-up trained. In general, ALARA briefings were good; however, some problems were identified. Housekeeping throughout the radiological controlled area was very
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good. Areas were free of debris and tools and equipment staged for work in-progress were property stored.
R1.2 Internal Exposure Controls a.
inspection Scope (83729/83750)
Selected radiation protection personnel involved with the internal exposure control program were interviewed. The following items were reviewed:
Air sampling program, including the use of continuous air monitors and filtration
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i Respiratory protection program
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Observations and Findinas Continuous air monitors, portable air samplers, and high efficiency particulate air filter ventilation units were appropriately used throughout the radiological controlled area to monitor and limit worker's airborne exposures.
There were no positive whole-body counts or full-faced negative pressure respirators issued for radiological reasons since the last inspection in October 1998. No problems
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7-were identified during the review of the control, storage, and issue of respiratory equipment.
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Conclusions A good internal exposure control program was in place. Continuous air monitors, portable air samplers and high efficiency particulate air filter ventilation units were appropriately used throughout the radiological controlled area to monitor and limit worker's airborne exposures. No problems were identified with the control, storage, and issue of respiratorv equipment.
R1.3 Plannina and Preparation a.
Inspection Scope (83729/83750_)
Radiation protection and chemistry department personnel involved in radiation protection planning and preparation were interviewed. The following items were reviewed.
ALARA job planning
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Incorporation of lessons learned from similar work
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Supplies of radiation protection instrumentation, protective clothing, and
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Observations and Findinas Radiological work permit packages were well planned, and ALARA personnel were appropriately involved during the outage planning stage. Lessons learned from past similar work were incorporated into the radiological work packages. At the completion of a task, job history comments were provided to the ALARA personnel for evaluation and incorporation into future similar radiological work packages. A review of selected radiation work permit packages and ALARA plans revealed that lessons learned from past similar onsite and industry work were appropriately incorporated to irnprove job task performance.
The inspector reviewed the ALARA plan and radiation work permit for the Unit 2 core barrel support lift and noted no problems. Lessons learned from the Unit 1 lift and ALARA work methods were appropriately included in the plan.
The inspector attended radiation protection staff shift turnover meetings. Good communication between shifts was noted, and turnovers were performed in a professional manner. Discussions on work status and problems encountered during the shift were effectively communicated.
From interviews conducted with radiation protection personnel and field observations, the inspector determined that no problems were identified with the adequacy of radiation protection instrumentation, protective clothing, and consumable supplies to support outage radiological wor.
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Conclusions Radiological work package tasks were well planned, and Al_ ARA personnel were appropriately involved during the outage planning stage. Lessons learned from past similar work were incorporated into the radiological work packages. Staff shift tumover meetings were effective.
R1.4 Control of Radioactive Materials and Contamination: Surveyina and Monitorina s.
Inspection Scope (83729/83750)
i Areas reviewed included:
Contamination monitor use and response to alarms
Control of radioactive material
Portable instrumentation calibration and performance checking programs
Adequacy of the surveys necessary to assess personnel radiological safety
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Observations and Findinas All personnc! observed exiting the radiological controlled area used the personnel contamination monitors properly. Radiation protection personnel stationed at the egress point provided appropriate and timely guidance to workers who alarmed the monitors.
While exiting contaminated areas, the inspector observed radiation worker activities and noted use of good health physics practices.
l During tours of the radiological controlled area, the inspector noted that all radioactive material containers were properly labeled, posted, and controlled. Oontamination boundaries were clearly identified and properly posted. Step-off pads were placed at the entrances / exits to contaminated areas. Trash and laundry barrels were properly j
maintained to prevent the spread of radioactive contamination.
All portable radiation detection instrumentation observed in use in the radiological controlled area were properly calibrated and source response checked in accordance with station procedures.
Independent radiological measurements performed by the inspector during tours of the radiological controlled area confirmed that area radiological postings reflected general
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radiological conditions within the room. All radiological postings were conspicuously and clearly posted in accordance with station procedures and regulatory requirements.
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Conclusions Radiation workers used the contamination monitoring equipment properly. All radioactive material containers were properly labeled, posted, and controlled.
Contamination boundaries were clearly identified and properly posted. Portable radiation detection instrumentation was properly calibrated and source response checked. Radiological postings were conspicuous and clea.
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RI.5 Maintainina Occupational Exposure As low As is Reasonably Achievable (ALARA)
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Inspection Scoce (83750)
Radiation protection personnelinvolved with the ALARA program were interviewed. The following areas were reviewed:
ALARA committee support
Exposure goal establishment and status
Temporary shielding program
Chemistry controls
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Q_bservations and Findinas
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The inspector noted that the outage exposure budget of 89 person-rem was approximately 17 person-rem less than the 1997 Unit 2 refueling outage actual exposure. From discussions with the licensee, the inspector determined that the 1999 Unit 2 refueling outage exposure budget was established using past best performance and industry experience. From a review of the station's ALARA managers' committee meeting minutes, the inspector concluded that there was appropriate involvement by all ALARA representatives and the station's ALARA managers' committee in the development of the exposure budget. The inspector concluded that the exposure goals i
were aggressive. Station and task activity exposures were appropriately tracked and trended by the ALARA staff.
A very good temporary shielding program was in-place. From a review of the temporary lead shielding packages planned to be installed this outage, the inspector determined that installing the packages would save the licensee about 40 person-rem. From field observations of temporary shielding installation sites completed, the inspector determined that the shielding installations were properly posted and installed in accordance with engineering specifications.
Effective chemistry shutdown plans and controls were in place. From licensee supplied data, the inspector determined that chemistry shutdown controls were effective in reducing reactor coolant system dose rates by approximately 23 percent.
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Conclusions i
A very good ALARA program was effectively implemented. The Unit 21999 outage j
exposure budget of 89 person-rem was approximately 17 person-rem less than the 1997 Unit 2 refueling outage actual exposure, and was established using past best performance and industry experience in conjunction with appropriate involvement by ALARA representatives and the station's ALARA managers' committee. Station and task activity exposures were appropriately tracked and trended by the ALARA staff.
Effective chemistry shutdown plans and controls were in place to accomplish the successful reduction in reactor coolant system dose rates by approximately 23 percen..
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Staff Training and Qualification in Radiological Protection and Chemistry R5.1 Radiation Protection Staff Trainino a.
Inspection Scope (83729)
Personnel involved with contractor radiation protection technician training and resume evaluation were interviewed. The following items were reviewed:
Radiation protection technician training lesson plans
Resumes of contractor radiation protection technicians a
Radiation protection management oversight of the training program
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Observations and Findinas Seven contractor senior radiation protection technicians and one contractor radiation protection technician were brought in to support outage activities. All contractor radiation protection technicians met or exceeded the Technical Specification requirement of an ANSI 18.1 technician (2 years experience).
Contractor radiation protection technicians were tested on site-specific material, which included industry and site lessons learned. The Northeast Utilities exam was used to assess the basic radiation protection technical knowledge of these technicians. The Northeast Utilities program is recognized and approved by a number of utilities as an acceptable method to evaluate a radiation protection technician's general radiological knowledge.
A review of the contractor lesson plans and qualification cards revealed that they were well developed and radiation protection management was appropriately involved in the development of the topics.
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Conclusions A good contractor radiation protection technician training program was ' implemented.
Radiation protection management was appropriately involved in the oversight of the contractor radiation protection training program.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Ouality Assurance Audits _and Surveillances and Radiation Department Self-Assessments and Radioloaical Condition Reports e.
insoection Scoce (83729/83750)
Selected personnel involved with the performance of quality assurance audits and surveillances and radiation department self-assessments were interviewed. The following items were reviewed:
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-11-Quality assurance audits performed since October 1998
Quality assurance surveillances perforrned since October 1998
Radiation protection department self-as.sessments performed since October
1998 Radiological condition reports written since October 1998
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Observations and Findinas Audits and Surveillances An audit of the radiation protection program was last performed in February 1998. The audit frequency of the radiation protection program was annually, thus no radiation protection audits were scheduled during this as.sessment period. One quality assurance operational radiation protection surveillance was performed since October 1998; however, the report was in draft and not ready for review during this inspection.
The inspector reviewed the quality assurance radiation protection surveillance schedule for 1998 and 1999 and noted no problems. Appropriate areas were identified and
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radiation protection management was involved in the development of the schedule.
Radioloaical Condition Reports The inspector reviewed a summary of condition reports written since October 1,1998, and randomly selected four of these condition mports for a more in-depth review. No problems or negative trends were identified. The station identified radiological concerns at the proper threshold to provide management with a good perspective of the radiation protection program. In general, condition reports were closed in a timely manner.
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Conclusions The 1998 and 1999 quality assurance radiation protection surveillance schedule covered appropriate areas of the radiation protect on program. No problems or negative
trends were noted during the review of radiological condition reports written since October 1998.
R8 Miscellaneous Radiological Protection and Chemtstry issues (92904)
R8.1 (Closed) Violation 50-313/9813-03: Failure to perform adeauate surveys The inspector verified the corrective actions described in the licensee's response letter dated May 14,1998, were implemented. No similar radiological survey problems were identified.
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V. Manaaement Meetinas j
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.X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at i
an exit meeting on January 15,1999. The licensee acknowledged the findings
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f ATTACHMENT l
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED
- Licensee R. Hutchinson, Vice President, Operations C. Anderson, General Manager Plant Operations R. Bement, Unit 2 Plant Manager M. Cooper, Licensing Specialist :
P. Dietrich, Unit 1 Maintenance Manager C. Eubanks, Unit 2 Outage Manager
- B. McKelvy, Technical Assistant Radiation Protection / Chemistry T. Nickels, Radiation Protection Supervisor W. Perks, Radiation Protection / Chemistry Supervisor S. Pyle, Licensing Specialist J. Smith, Radiation Protection Manager J. Vandergriff, Nuclear Safety Director C. Zimmerman, Unit 1 Plant Manager NRC K. Kennedy, Senior Resident inspector INSPECTION PROCEDURE USED
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83729 Occupational Exposure During Outages
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83750 Occupational Radiation Exposure LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED Closed 50-313/9813-03 VIO Failure to perform a survey.
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. 2-LIST OF DOCUMENTS REVIEWED Procedure 1000.031, " Radiation Protection Manual," Revision 18 Procedure 1012.017," Radiological Posting and Entry / Exit Requirements," Revision 6 Procedure 1012.018," Administration of Radiological Surveys," Revision 4 Procedure 1012.019, " Radiological Work Permits," Revision 6 Procedure 1012.025, " Radiation Protection Oversight Program," Revision 0
- Procedure 1012.027, "ALARA Program," Revision 2 Quality Assurance Procedure OAP-3, " Radiation Protection," Revision 13
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Quality Assurance Procedure OAO-6," Internal Audits," Revision 15 Quality Assurance Procedure OAO-9," Quality Assurance Surveillance," Revision 11 A Summary of Radiological Condition Reports written since October 1,1998
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