IR 05000321/1992030

Insp Repts 50-321/92-30 & 50-366/92-30 on 921102-06.No Violations Noted.Major Areas Inspected:Organization & Mgt Controls,Audits,Appraisals,Training,Qualifications & External Exposure Control

ML20125E535
Person / Time
Site:	Hatch
Issue date:	11/30/1992
From:	Bryan Parker, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20125E520	List: IR 05000321/1992030 ML20125E516
References
50-321-92-30, 50-366-92-30, NUDOCS 9212170102
Download: ML20125E535 (13)

Text

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - - _ .

. . < * *

g 0 ff UFJIT ED STATES l  %[g NUCLEAR REGULATORY COMMISSION

& )

-

n RE GION il 5 ,g 101 M ARIFTT A ST RE ET, *

A* ANT A, CEORGI A 30323

\.....lt O,]1 f

'

Report Nos.: 50-321/92-30 and 50 366/92-30 Licensee: Georgia Pcer Eomamy P.O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-321, 50-366 License Nos.: DPR-57, NPF-5 Facility Name: Hatch 1 3'd 2 I

InspectionCondug.ted:/No'jember2[f,"1992 / ,/

Inspectors: ( ( /42 h n/ M ///M

/ Dati S gned

E.B.fharr 'g'

) ,

/ AM 'Mr ///3C 92 B. A.! Parker Date' Signed Approved by:M W. H. Rankin, Chief M' mtM //

IDate/ Signed o/9%

Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine inspection was conducted in the area of occupational radiation exposure during extended outage Specific _ areas examined included:

organization and management controls, audits and appraisals, training and qualifications, external exposure control, internal exposure control, and maintaining occupational exposure as low as reasonably achievable (ALARA),

Results:

No violations or deviations were identified. Strengths were identified in health physics (HP) technician training regarding implementation of 10 CFR Part 20 revisions as well as a staff reorganization which permanently established an ALARA group and a Radiation Work Permit (RWP)/ Maintenance Work Order (MWD) coordination group. Successful preplanning efforts by these newly established groups, as well as good communications and coordination between HP, outage management, and plant work groups was beneficial in maintaining outage exposure below the projected dose goal. Additionally, the Safety Audit and Engineering Review (SAER) function was considered a strength in the 9212170102 921127 PDR ADOCK 05000321 0 PDR

_ _ _ _ _ _ _ - _ _ _ _ - _ - _

_ _ _ _ . _ . _ . . _ _ . . _ _ _ _ _ _ _ _ _ . . - _ _ . . _ _ . _ . _ -_. _ _ _ _ _ _ _ _

^

,

. .

.

licensee's overall program. A weakness was identified in the respiratory protection program concerning medical qualifications for outage contractor However, a procedure was being developed by the medical group to add consistency to the program and the respiratory protection group and medical unit were discussing efforts to improve communications between the two group Overall, the inspector found the licensee's program for protecting the health and safety of plant workers and the public to be effectiv .

l l

'

,

l l-l l-

. _ _ - .. . - - - _. _ _ _ . ._ _ __ - - - - . .- - .- . _ _ -

,

, . .

REPORT DETAILS Persons Contacted Licensee Employees

• P. Bryant, Supervisor, Safety and Health

• K. Dyer, Nuclear Specialist

• T. Ellis, Specialist, Health Services

• P. Fornel, Manager, Maintenance

, *0. Fraser, Site Supervisor, Safety Audit and Engineering Review (SAER)

• G. Goode, Manager, Engineering Support

• J. Hammonds, Supervisor, Regulatory Compliance

• Kirkley, Manager, Health Physics (HP) and Chemistry

• L. Lawrence, Specialist, SAER

• J. Lewis, Manager, Operations

• M. Link, Supervisor, HP

• C. McDaniel, Supervisor, Plant Administration

• S. Nevv, Secretary III

• R. Ott, Supervisor, HP/ Chemistry / General Employee Training

• D. Read, Assist ant General Manager, Plant Services

• Riner, Plant Health Physicist

• P. Roberts, Manager, Outages and Planning

• D. Smith, Superintendent, HP

• J. Thompson, Manager, Nuclear Services

• S. Tipps, Manager, Nuclear Safety and Compliance

• A. Wheeler, Supervisor, Plant Engineering Other licensee employees contacted during this inspection included engineers, technicians, and administrative personne Nuclear Regulatory Commission

• L. Wert, Senior Resident Inspector j *W, Tobin, Regional Inspector, Fitness for Duty

• Denotes attendance at November 6, 1992, Exit Meeting Organization and Management Controls (83729)

The inspector reviewed the licensee's staffing and organization for the HP and Chemistry Department and noted that several organizational changes had taken place since the previous routine inspection conducted March 2-6, 1992, and documented in Inspection Report (IR) 92-07. The reorganization had involved assigning the Plant Health Physicist the overall responsibility of ALARA Coordinator with an as low as reasonably achievable (ALARA) specialist and Radiation Work Permit (RWP)/ Maintenance Work Order (MWO) specialist reporting directly to the Health Physir.ist. As a result of the reorganization, the Plant Health Physicist now reported directly to the HP Superintenden As well, the I

- _, .. . -_<., ,,,_, -- -_, , ,, .

. . . . _ _ _ __ .

2 ALARA specialist had been permanently assigned three HP technicians for ALARA planning and two HP technicians were permanently assigned to assist the RWP/MWO specialist with RWP and work coordinatio Successful preplanning effor's by these newly established groups were beneficial in maintaining outage exposure below the projected dose goa Other aspects of the HP organization have been relatively stable and the present staff of 52 technicians appeared appropriate to support normal operation The inspector was also informed that a contract staff of 61 ANSI qualified technicians, four ANSI 18.1 qualified technicians, four junior technicians, six dosimetry technicians, and 16 terminal operators were onsite at the time of the inspection to support outage activities. The inspector was informed that this level of additional technician support was consistent with previous outages and was adequate for supplementing HP support during the outage. Through discussions with HP management and employees and direct observation of job support, the inspector noted that the present HP organization and staffing, including contract HP staffing, was adequate for ongoing activitie No violations or deviat ns were identifie . Audits and Appraisals (83729)

Secticn 17.2.18, Audits, of the Hatch Unit 2 Final Safety Analysis Report (FSAR) requires, in part, that audits of HP and radiation protection be performed under the cognizance of the Safety Review Board (SRR) at least once per 24 months, unless more fre_quent audits are necessary due to certain specified conditions.

!

l The inspector discussed the audit program with licensee representatives w; thin the Safety Audit and Engineering Review (SAER) Department. Three audits involving HP were conducted in the 1991-92 timefreme. Two of the audits were performed in 1991 and were reviewed during previous

,

inspections. The third and most recent audit, Audit 92-HP-1, was i performed during the period of September 14-28, 1992, and was reviewed I

during this inspectio The inspector noted that the audit was well-

documented and thorough and contained items of substance related to the HP program. The report of audit findings to management was also reviewed. The report, dated October 14, 1992, summarized the findings and gave suggestions for correction. _ Corrective actions and/or responses to noted deficiencies were not yet due and, therefore, were not reviewed by the inspector.

i The inspector noted that the experience-base of the auditors was wide and varied. Also, the training and qualifications provided to auditors was excellent. The SAER function was considered a strength in the licensee's overall progra No violations or deviations were identifie .

- . . - , - .

- -- . - - . - . -- . . - __ - .- -- -

.

. .

.

d

3

'

4. Training and Qualifications (83729)

10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portions of the restricted areas in the health protection aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protectior Svices employed, applicable provisions of the Commission Regub . ions, individuals' responsibilities and the availability of radiation exposure dat The inspector reviewed the licensee's program for providing radiati')n protection training to licensee employees. The inspector was informed that recently implemented HP-related plant policies and concerns were included in General Employee Training (GET), such as high radiation area entries and locked high radiation area doors. As well, the licensee's policy regarding proper use of digital alarming dosimeters (DADS) was included. The inspector was also informed that during recent GET sessions, employees were provided with an introduction to newly revised 10 CFR Part 20 and an overview of the programmatic changes which would result from the regulatory revision The inspector also reviewed HP technician continuing training. The inspector noted that during 1992, 73 hours8.449074e-4 days <br />0.0203 hours <br />1.207011e-4 weeks <br />2.77765e-5 months <br /> of continuing training material had been provided to HP technicians. During review of course outlines, the inspector noted that this training material included review of HP directives, new procedures, industry events and exposure concerns, emergency planning, and revised 10 CFR Part 20. The inspector reviewed the revised 10 CFR Part 20 training material presented to

licensee HP technicians. The inspector noted that the training included an overview of the regulatory revisions and how these revisions would apply to plant radiation protection activitie Additionally, the inspector noted that training was being provided to technicians l regarding HP procedure changes as a result of Part 20 revisions.-

The inspector found the radiation protection training material presented to both general employees and HP technicians to be thorough and well l prepare Particularly, the inspector noted the licensee's efforts to provide revised 10 CFR 20 training to both groups to be a strength of the overall progra No violations or deviations were Mentifie . External Exposure Control (83729) Personnel Dosimetry 10 CFR 20.101(b)(3) requires the licensee to determine an individual's accumulated occupational dose to the whole body on a Form NRC-4 or equivalent record prior to permitting the individual

! to exceed the limits of 20.101(a).

. - . _ . . - -

. _ _ . - ... . - - -- - - -.- . - -. _ .-. .-. . .

. .

.

4 >

10 CFR 20.202 requires each licensee to supply appropriate monitoring equipment to specific individuals and requires the use of such equipment. 10 CFR 20.202(c) requires that personnel dosimetry that are used in accordance with 10 CFR 20.202(a) be processed by a processor accredited by the National Voluntary-Laboratory Accreditation Program (NVLAP) for the appropriate types of radiatio CFR 20.408(b) requires that when an individual terminates employment with the licensee, or an individual assigned to work in a licensee's facility but not employed by the licensee completes the work assignment, the licensee furnish the NRC a report of the individual's exposure to radiation and radioactive material incurred during the period of employment or work assignment, containing information recorded by the licensee pursuant to 10 CFR 20.401(a). 10 CFR 20.401(a) requires each licensee to maintain records showing the radiation exposure of all individuals for whom personnel monitoring is required under 20.202 of the regulations. Such re;ords shall be kept on Form NRC-5 or equivalen The itcensee provided thermoluminescent dosimeters (TLDs) to employees on a monthly basis. TLDs were stored with identification badges in the security island when not being wor Processing of TLDs was accomplished through Georgia Power's

,

dosimetry laboratory _ located in Smyrna, Georgia. The Smyrna facility is NVLAP-approved for processing the licensee's type of dosimetr Background radiation was accounted for through the use of control badges also stored at the security islan Control

- badges arrived with each new batch of TLDs and were returned each month with the same batch for processing. " In-transit" dose was  ;

also acconted for through the use of additional control badges located in the TLD shipping containers.

I The licensee also used-pocket ionization chambers-(PICS) as a-I secondary means of tracking dose-for all entries into the radiologically-controlled area (RCA). PIC storage racks were .

provided at the main RCA entrance / exit-and PICS were read daily by i HP to track collective dose. Each PIC was " leak-tested" and source checked as needed or at least every 'six months.- If a PIC-failed either test, it was retested and, if_ it failed again,_ it was discarded. DADS were used for all high radiation area entries and other special case As mentioned,.the licensee was tracking dose on a daily basi Most individuals.were on an administrative exposure limit of 1000 millirem (mrem) per quarter. If an individual had 200 mrem

~

or less remaining in their administrative dose allowance and no

-

dose extensions were approved, the individual's TLD was pulled

- until their dose was reviewed and, if appropriate, extende Approximately 40 dose extensiti,s had been approved thus far in.the outage, t.'hich was a significant _ decrease from. previous outage _

+c'44 Tsr---9 y M V-1end 36 w+ t f54-*y'--=W 4d -ty' y-TN8-' f'*-*Wg-g- --W o 1y-w7g ge'. wyrp v, g,gweqeg gewg-gy-- ya.,-ngywy -,---t--e qr q =- ' p Fe-4*f *yy 'Nwe "a-'-rTm-T- , . . . . _ . . _ _ - _ . _ - . .

.

During previous outages, 100-200 extensions typically had to be given in order to complete all of the necessary work. According to the licensee, the decrease in the number of extensions needed this outage was due to overall lower dose rates and better ALARA planning. Tae maximum dose extension approved by the licensee at the time of inspection was to 2000 mrem and the maximum dose recorded to date in 1992 was 1964 mrem. As of November 4, 1992, no administrative or regulatory overexposures had occurre The inspector selectively reviewed the licensee's 1992 personnel contamination reports (PCRs). The 1992 goal for PCRs was 18 The goal for the Unit 2 outage was 80 PCRs. As of November 5, 1992, the licensee had documented approximately 180 PCRs for the year, 113 of which had occurred thus far in the outage. The licensee indicated that although overall dose rates were inwer, contamination levels were up, possibly due to failed fuel and/or hydrogen water chemistry. The licensee felt this was the major contributing factor to the PCR goals being exceeded. In response to the increase in PCRs, the licensee increased the frequency and scope of masslin surveys and moppin Thus far in the outage, the licensee hed performed ten skin dose assessments due to skin / clothing contaminations. Skin dose assessments were performed when contamination greater than 20,000 disintegrations per minute (dpm) per probe area was detected on the skin and/or clothing. The only excepticn to the rule was the bottom of the shoes, where at least 100,000 dpm/ probe area was required to trigger an assessment. Six of the ten assessments resulted in calculated skin doses of greater than 100 mrem with the maximum being 1400 mrem to the skin of an individual's thigh due to a fuel fragment. Of the six greater than 100 mrem, four were " hot" particles and two were distributed contaminations. The licensee utilized the recently updated version of VARSKIN to calculate skin doses and, for conservatism, most of the assessments were treated as point sources. No regulatory limits were exceeded and no problems were identified with tra licensee's procedures or method No violations or deviations were identifie High Radiation Area Controls 10 CFR 20.203 specifies the posting, labeling, and control requirements for radiation areas, high radiation areas (HRAs),

airborne radioactivity areas, and radioactive material Additional requirements for control of HRAs are contained in Technical Specification (TS) 6.12, including thos e areas accessible to personnel with radiation levels greater than ,

1000 milliroentgen per hour (mR/hr) at 45 centimeters (18 inches) '

from the radiation source or from any surface which the radiation ;

penetrates shall be provided with locked doors to prevant '

,

o unauthorized entry. TS 6.12 also states that for individual HRAs i

!

!

.- . ,. - .

- .. _ - - . --- - -- - . . ..

.

- .

. .

.

l 6 l

'

accessible to personnel with radiation levels greater than 1000 mR/hr that are located within large areas where no enclosure exists for purposes of locking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning devic In response to previously identified problems regarding HRA entries, the licensee recently implemented a program to replace / upgrade a number of HRA doors. The new entryways consisted of (1) a cage-type enclosure out and around the

doorways; (2) a heavy duty swinging door; (3) a heavy-duty i automatic door-closer; and (4) an interlock system that causes a j red light over the doorway to be on if the door is not completely closed. In addition to the new entryways, the licensee had also implemented new procedures for controlling HRA keys. All HRA keys

were signed out by two individuals and,'upon completion of the task in the HRA, the same two individuals were required to verify i that the door was properly closed and locked. Also, in an effort to prevent problems associated with transversing incore probes (TIPS), the keys for the TIP room and the TIP drive motor control

panel were placed on the same keyring so that the TIPS could not

'

be operated while the TIP room was occupie No violations or deviations were identified.

4 Internal Exposure Control (83729)

10 CFR 20.103(a)(3) requires, in part, that the licensee, as

.

appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.

l Bioassay Program Implementation

!

-

Administrative Control Procedure, 60AC-HPX-003-05, Bioassay i' Program, Rev. 2, dated June 12, 1987, establishes responsibilities and methods used to control, monitor, and

,

evaluate internal occupational radiation exposure. The procedure also requires additional bioassays when accidental internal

, exposures occur, whether real or suspected.

.

The inspector reviewed and discussed with the licensee actions

-

taken and evaluations performed in response to two internal exposure events which occurred during the Unit 2 outage. The inspector was informed that the first incident occurred on

October 2, 1992, in the Condenser Bay Moisture Separator Reheaters (MSRs). A HP technician entered both MSL to perform radiation and contamination surveys prior to work commencement. Protective clothing.and a particulate filter respirator were worn during the surveys, as deemed necessary by review of previous area survey .

, . _ . . - _ --,_., - _-- - , .. .

_ ._ _ _ _ - ._ _ ._ __ __ _ _ _ . . __ . _ _ _ . _ _ _ _ _ __

! .

.

-

Upon entering the area, the technician noted that the High-Efficiency Particulate Air (HEPA) ventilation units were not being properly utilized in either MSR. The technician corrected the situal10n and then proceeded with the surveys, which included air sample collection. After counting the air samples, iodine-131 (I-131) activity was detected on both samples. "A" MSR air sample rasults were 132.6 percent of the Maximu.n Permissible Concentration (MPC) for I-131 and "B" MSR results were

. 212.9 percent of the I-131 MPC. Nine individuals were in the area at the time of the elevated air sample results and all were whole body counted for a possible intake. Two individuals had detectable iodine intakes, however only one individual actually received a measurable iodine uptake to the thyroid, the critical organ for iodine. The inspector noted that the licensee performed dose calculations using ICRP-30 methodology and based on whole body count results. The maximum assigned internal exposure was 3.98 MPC-hrs.

'

The second licensee evaluation reviewed by the inspector involved a facial contamination event which occurred on October 5,1992, in the Unit 2 drywell during valve work. HP surveys after the contamination occurred revealed that the valve the individual was

, working had smearable contamination levels of up to 40 millirad (mrad). Initial contamination levels of 6000 dpm were detected on the individual's noustache and by nasal swabs. Followup whole body counts detected a cobalt-60 (Co-60) intake and assuming an ingestion pathway, the licensee calculated an internal exposure of 3.27 HPC-hrs.

l Based on the licensee's evaluations of the incidents and exposure assessments, the inspector determined that appropriate measures were employed in order to assess the individuals' exposures. The inspector reviewed MPC-hrs assigned to the iwolved workers six days prior to and six days following the incident and noted that l the individuals were not assigned additional MPC-hrs during either

seven day period. The inspector verified that the licensee had followed the procedure appropriately in their followup actions to the incident and that their evaluation was complete and accurate in their method of determining and assigning each worker's exposure. The inspector noted that no licensee action or

, administrative limits nor any regulatory limits were exceeded due to the incidents.

'

The inspector reviewed and discussed with licensee representatives, energy calibration checks and efficiency determinations performed semi-annually on the in-vivo counting equipment. The inspector noted that the 1992 calibrations were

performed within the time limits as prescribed by the applicable l procedures. The inspector also noted that the licensee participated in a quarterly cross check comparison program with a vendor laboratory. The inspector reviewed the results from the

_ _ _ __ _ _ _ , _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ - ___ -

. .

- . -_ - .

.

.

L

1992 second and third quarter cross checks and determined that the licensee successfully participated in the interromparison program with the vendor laboratory.

l No violations or deviations were identifie Respiratory Protection Program 10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protection program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit and maintain respirators; written procedures regarding the supervision and training of personnel and issuance of records; and determination bj a physician prior to the use of respirators, that the individual is physically able to use respiratory protective equipmen Administrative Control Procedure, 60AC-HPX-006-05, Respiratory Protection Program, Rev. 5, dated October 30, 1990, establishes requirements and responsibilities for a respiratory protection program. Determination by a physician that the individual is physically able to use respiratory protective equipment is required at least every twelve months. A fit-test is required every three years. Also, the procedure requires that all l personnel wbs "ay require respiratory protective equipment receive

annual trair, m. in the proper use of the equipment and the hazards associated with airborne radioactive material The inspector reviewed records for selected individuals involved in insulation removal and HP coverage activities during the outage. For 17 contractors, the inspector noted that although fit-tests and required training were completed and up-to-date, medical qualifications were not updated. Following discussions with licensee representatives, the inspector was. informed that during the contractors' inprocessing period prior to the outage, these individuals had successfully completed the physical examination by the medical staff and were therefore, respirator-qualified. However,'the supervising physician raised questions after formally reviewing some of the contractors' medical histories. This led to the medical unit disqualifying 17 contractors until the questions could be resolved. The inspector was informed that all the contractors that responded to the medical unit's request for further information were requalified following resolution of the medical history questions, with one exception. One individual was permanently disqualified from using respiratory protective equipment based on a complete-physical. examination and history reviews by two of the licensee's physicians. According to the licensee, that individual was eventually terminated due to failure to meet all conditions of employment (i.e. lack of respirator qualifications).

l

,

e -,r.- -

- w , . ,-, .,,--c ,.,,-----r--.,..e ,,+.- w --e, - - , -

. . _ _ - . .-- .__ - . - --

'

. .

The inspector reviewed the licensee's process for respirator issuance and determined that appropriate controls existed to prevent unqualified personnel from being issued respiratory protective equipment. The inspector also reviewed respirator issue logs for selected personnel during the period in which the 17 contractors were temporarily disqualified (September / October 1992). From that review, it was determined that respirators were not issued to those selected personnel reviewed, including the individual who was later permanently disqualifie During discussions with medical personnel, the inspector was informed that this Unit 2 outage was the first in which the onsite medical unit performed the physical examinations and reviewed medical histories for contractors so as to allow contract personnel to proceed with respirator fit-testing. The inspector was also informed that since medical histories were being reviewed more closely, questions concerning physical abilities to wear respiratory protective equipment arose more often, lhe inspector informed licensee representatives that more detailed review of medical histories for respirator qualification was a program strengt Although the licensee was complying with the requirements for approving respirator users, the revocation of medical approvals following successful completion of the physical examination did not appear to be a good practice. Licensee representatives acknowledged the inspector's concern. Prior to the end of the onsite inspection, the licensee informed the inspector that procedures were being revised / developed which would add consistency to the program for plant and contract employees and also for granting medical approvals or referring the employee to the physician for final approval. Additionally, the respiratory protection group and medical unit were discussing means for improving communications between the two groups so as to prevent inconsistencies in medical approvals / disapproval The inspector reviewed the licensee's methods for processing used respirators. After respirators were used and collected, they were prepared for cleaning. Following washing, rinsing, and drying, the respirators were surveyed and decontaminated further, if necessary. Each respirator was then inspected for damage / defects and bagged for reissue. The inspector noted that clear, heat-sealed bags were used to keep respirators clean and dur,t-free between uses. The licensee leak-tested 100% of the respirator inventory annually. Each respirator bore a colored tag that corresponded to one of the four calendar quarters of the yea Each quarter, those respirators with the appropriate tag (approximately 25% of the licensee's respirator-inventory) were pulled from service, leak-tested, and repaired / discarded, as appropriat No violations or deviations were identifie .

>,.. , _ .- - . - u -

. .

'

. . .

.#

7, Maintaining Occupational Exposure As low As Reasonably Achievable

(83729)

10 CFR 20.l(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures ALAR The inspector reviewed the membership of the licensee's Plant ALARA <

Review Committee (PARC) and found that it consisted of various representatives from the HP staff, HP management, Operations, Maintenance, Instruments and Calibration, Engineering, Buildings and Grounds, Training, and Planning. The Manager of HP and Chemistry was the PARC Chairman. The PARC met monthly to discuss ALARA related items. No problems with attendance or substance of the meetings were

,

identifie As of October 1992, the PARC had reviewed approximately 63 ALARA suggestions from plant personnel. IR 92-07 (see Paragraph 2) noted that all of the suggestions (33) up to that time had been submitted by PARC members by request of the PARC Chairman, indicating a lack of general worker participation. The inspector noted that since that inspection, worker participation in the program had increased as only five additional suggestions had been submitted by PARC members and the remaining 25 were made by the plant populous. The licensee informed the inspector that different forms of ALARA incentives were being evaluated and that. if an incentive program was adopted, worker involvement should increase accordingly. The inspector also found that ALARA posters, st.:kers, etc.. were being widely used to promote the ALARA concep The inspector reviewed the licensee's program for maintaining exposures ALAR Licensee re3resentatc.es informed the inspector that as of Noverrber 2,1992, tie collective dose was approximately 521 person-rem.

The licensee's collective dose goal for 1992 was 837 person-rem. The inspector also noted that the licensee had been proactive in implementing methods to reduce collective dose during the Unit 2 outag During discussions with licensee representatives the inspector was informed that the exposure goal for the outage was 390 person-rem. As of day 48, of the projected 60 day outage, the licensee's collective outage dose was approximately 314 person-re Licensee representatives informed the inspector that factors contributing to the lower than projected exposure had included the staff reorganization which had permanently established an ALARA and RWP/MWO coordination group; successful preplanning efforts by these groups; and successful communication and coordir2 tion between outage management, HP, and the work groups. In addition. the use of closed-circuit cameras and DADS were effective in providing for remote HP surveillance, thereby-maintaining HP exposures ALARA. The inspector noted that these efforts appeared particularly _ successful in that contamination levels of the l refueling floor and condenser bay, at well as general area dose cates in

'

the drywell, were higher than expected based on historic data. Licensee representatives infnrmed the inspector that this increase could be L

'

_ _ -. , . - . _ _ _ , . .___ _ _ _,_ ._. __ _ _ _. . _ _ _ __

- _ . _ _ _ _ _ _ _ _ -_ . __

,

J *

.

.

I i

l attributed to failed fuel during the previous fuel cycle and/or the use j of hydrogen water chemistry.

'

The inspector noted that the licensee's efforts to improve the content

-

and quality of and to implement ALARA suggestions, as well as better j outage planning and work coordination, had been successful in 4 maintaining the licensee's cumulative exposures below the projected goals. The inspector informed licensee representatives that their

i program for maintaining personnel exposures ALARA during outage i activities appeared to be functioning adequately.

!

l No violations or deviations were identifie . Exit Meeting i The inspector met with licensee ,apresentatives as denoted in l Paragraph 1 at the conclusion of the inspection on November 6,1992.

l The inspector summarized the scope and findings of the inspection.

1 Dissenting comments were not received from the licensee. Additionally,

the licensee did not identify any documents or processes reviewed by the l inspector as proprietary.

!

,

!

,

,

f r

!

l l

.

l l

L . , - , - . , - _ . .- -- . .- - - -. . . - , - . .-