IR 05000334/1981032
| ML20054B439 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/23/1982 |
| From: | Knapp P, Mcbride M, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054B387 | List: |
| References | |
| 50-334-81-32, NUDOCS 8204160527 | |
| Download: ML20054B439 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-334/81-32 Docket No.
50-334 License No.
DPR-66 Category C
Licensee:
Duquesne Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Facility Name:
Beaver Valley Power Station, Unit No.1 Inspection at:
Shippingport, Pennsylvania Inspection conducted: December 14-18, 1981 Inspectors:
M.l k k'L3!67_
R. L. Nimitz, Rhdiation Specialist date signed
GC (
3lt3 }g t M. H. TcBride, Ph.D., Radiation Specialist date signed Approved by
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'5[7_3 / h %
b P. J. Knapp, Chief M
date signed Facility Radiological Protection Section Inspection Summary:
Inspection on December 14-18, 1981 (Rep _ ort No. 50-334/81-32)
Areas Inspected:
Routine, unannounced inspection of the licensee's radiological controls for the outage including:
training, planning and preparation, selection and qualification of personnel, radiation and high radiation area posting and control, radioactive and contaminated material control, respiratory protection, and ALARA.
Upon arrival at the site on December 14, 1981, at 7:00 p.m., areas where work was being conducted were examined to review adherence to radiation safety procedures and practices.
The inspection involved 60 inspector-hours onsite by two NRC regional based inspectors.
Results: No violations were identified.
820401 820416 05000334 PDR AD PDR
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DETAILS 1.
Persons Contacted Duquesne Light Company W. Brady, Radiological Controls Foreman
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Carey, Vice President - Nuclear Division A. Castagnacci, Radiological Controls Foreman T. Duberville, Radiological Controls Foreman B. Haney, Operations and Maintenance Instructor
- J. Kosmal, Radiological Operations Coordinator R. Nelson, Shift Supervisor E. Schnell, Radiological Controls Foreman
- J. Sieber3 Manager-Nuclear Safety and Licensing J. Vassello, Nuclear Training Supervisor Contractors C. Vergarri, Site Project Manager, Rad Services, Inc.
J. Orr, Assistant Site Project Manager, Rad Services, Inc.
D. Blair, Radiological Controls Engineer, ECI Energy Consultants, Inc.
USNRC D. Beckman, Senior Resident Inspector
- denotes those individuals attending the exit interview on December 18, 1981.
The inspector interviewed several other licensee employees including members of the Radiological Controls, Maintenance, and Operations staffs.
2.
Training The inspector reviewed selected portions of the licensee's Radiological Training Program with respect to the following:
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Regulatory Guide 8.27, " Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants," dated March 1981.
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Radcon Procedure 11.3, Chapter 3, Issue 1, " Radiation Worker Training"
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Duquesne Light Training Manual, Section 3.3, " Radiation Worker Training," and Section 3.4, " Radiation Worker Training Continuing."
10 CFR 19, " Notices, Instructions, and Reports to Workers;
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Inspections"
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a.
Regulatory Guide 8.27 The inspector reviewed selected portions of the licensee's training program with respect to Regulatory Guide 8.27.
Regulatory Guide 8.27 describes a radiation protection training program consistent with the ALARA objective and acceptable to the NRC staff for meeting the training requirement of 10 CFR 19 with respect to individuals that enter restricted areas at nuclear power plants.
Section D, Implementation, of the regulatory guide indicates that appropriate modifications of training programs at operating reactors should be made consistent with the regulatory guide as soon as practicable and no later than one year after publication of the guide (March 1982).
The inspector's review indicated the following:
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Regulatory Guide 8.27, section 2.3, recommends that high grades (i.e., 80?; or higher) be required on written and oral tests since each person's training should cover only radiation protection information relevant to the person's needs. The inspector noted that the licensee currentl, requires a minimum performance of 70?s.
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Regulatory Guide 8.27, section 2.2, recommends that the training program include annual refresher training as necessary to maintain awareness of the needs for, and each individual's responsibility for, maintaining exposures ALARA and to update and renew each individual's knowledge of appropriate subjects listed in the guide.
The inspector noted that the licensee currently requires only licensee personnel to receive refresher training annually while contractor personnel are required to receive this training every 2 years.
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Regulatory Guide 8.27, section 2.3, recommends that requalification testing be carried out in conjunction with refresher training.
The inspector noted that the licensee currently does not conduct requalification testing for l
individuals completing refresher training.
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l The inspector discussed the above with licensee representatives who
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indicated that a draft revision of the Training Manual has been prepared and is being reviewed.
The revision will require that all personnel receive refresher training annually.
Licensee
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l representatives also indicated that the regulatory guide l
recommendations are being reviewed and that they were unable to
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comment on their implementation of the recommendations pending
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completion of their review.
The inspector indicated this matter would be reviewed during a
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subsequent inspection.
(50-334/81-32-01)
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b.
Instructions to Workers 10 CFR 19 requires in Section 19.12 that all individuals working in or frequenting any portion of a restricted area be informed and instructed in those topics specified therein. Section 19.12 also includes requirements that workers be kept informed of the storage, transfer, or use of radioactive materials or radiation in such portions of the restricted area and that they be instructed in precautions or procedures to minimize exposure.
The inspector's review of the licensee's training of workers relative to the above indicated that licensee Radiological Procedure 8.1, " Radiological Work Permit," recommends that a pre-work discussion be held and the workers sign a " Pre-Work Discussion Record" signifying understanding and acceptance of the conditions and controls of the RWP. This recommendation is also included in licensee Radiological Procedure 8.4, " Radiological Work Permit (Access Control)." These pre-work discussions were indicated by Radiological Controls personnel to be a means to instruct the worker in the radiological conditions of the job and in any precautions or procedures to minimize exposure.
During a review of this process, the inspector noted an instance where the workers had apparently signed the pre-work discussion record without the pre-work discussion topics being listed on the record.
The topics were apparently filled in after the discussion.
Inspector discussions with licensee representatives regarding the above indicated that the RWP Pre-Work Discussion Record would be promptly modified to require listing of the topics prior to the workers signing the record and to include a statement that the worker's signature on the record indicated that he was instructed in the listed topics.
The inspector indicated the above would be reviewed during a
subsequent inspection (50-334/81-32-02).
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No violations were identified.
c.
Posting of Notices 10 CFR 19 requires in Section 19.11 that current copies of the regulations in Part 19 and 20 be posted along with the reactor j
license, license conditions, license amendments, operating i
procedures, and documents incorporated into the license.
In lieu of this posting, the licensee may post a notice describing where these l
documents can be examined. Also required to be posted is Form
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NRC-3, " Notice to Employees," and any notice of violation invciving radiological working conditions and the licensee's response thereto.
Section 19.11 also requires that the documents be posted in a l
sufficient number of places to allow workers the opportunity to observe them on the way to and from any particular licensed activit._
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Accompanied by a licensee representative, the inspector reviewed all licensee postings pursuant to 10 CFR 19.11. The inspector noted that the Administration Building, the Main Guardhouse and the Construction Guardhouse are normally posted.in accordance with 10 CFR 19.11. Excluding a notice describing where a copy of the facility license, operating procedures and supporting documents could be read,-which was not posted in the Construction Guardhouse, all postings were present.
Licensee representatives immediately posted the notice.
No violations were identified.
3.
Planning and Preparation The inspectors reviewed the licensee's advance planning and preparation in the area of radiation protection for the upcoming outage.
Based on discussions with licensee radiation protection personnel, the following was noted:
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The licensee plans to supplement his staff of radiation protection personnel by use of contractor personnel.
This is discussed in Section 4.a of this report.
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The licensee has inventoried his supply of anti-contamination clothing and has determined that a sufficient supply is on hand.
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The licensee has reviewed the number of airborne radioactivity sampling and radiation survey instruments and made provisions to obtain additional instruments if needed.
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The licensee plans to use containments during steam generator work to minimize airborne radioactive contamination.
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The licensee has ordered additional lead sheets for shielding purposes.
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Selected Radiological Controls personnel are attending outage planning meetings to maintain cognizance of scheduled outage work.
This is discussed in Section 8 of this report.
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In anticipation of the refueling outage, the capability to provide i
the radiation worker training course has been increased to provide
for 120 persons per week by increasing the number of classes offered.
No violations were identified.
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4.
Selection and Qualification of Personnel
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a.
Selection
The inspector reviewed the qualifications, through examination of resumes, of selected contractor radiation protection personnel indicated by the licensee to meet or exceed the requirements of ANSI N18.1-1971,"Section and Training of Nuclear Power Plant Personnel."
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The contractor personnel are being utilized by the licensee to supplement his radiation protection staff. The licensee's Technical Specification 6.3, Facility Staff Qualifications, requires that the radiation protection staff meet ANSI N18.1-1971.
The inspector randomly selected for review 11 resumes of contractor radiation protection personnel indicated by the licensee to meet the ANSI standard and reviewed the resume of one contractor technician identified by the inspector during a facility tour as performing respor.sible radiation protection monitoring on a task reviewed by
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the inspector.
The review of the above resumes indicated the technician identified by the inspector met the minimum requirements outlined in the standard.
Of the 11 other resumes, the inspector's review indicated that one contractor technician did not appear to meet the two year minimum experience requirement of the standard.
However, precise determination was not possible due to the manner in which the worker's experience was presented in the resume.
Pending review of the contractor employee's experience, this individual's responsibilities
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were reduced, i
As a result of the above, the licensee's Radiological Controls i
Foreman (Operations) immediately contacted the contractor's Site Project Manager and requested a review of the resumes of all contractor radiological controls personnel working at the site to ensure that
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applicable contractor personnel were ANSI N18.1-1971 qualified.
The inspector indicated this matter would be reviewed during a i
subsequent inspection (50-344/81-32-04).
I No violations were identified, b.
Qualification The inspector discussed the means utilized by the licensee to qualify the contractor Radiological Controls technicians for various positions within the Radiological Controls organization.
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Technical Specification 6.4, Training, requires that the facility
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staff retraining and replacement training program meets or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971.
Section 5.5 of the ANSI standard requires the establishment of a training program which maintains the proficiency of the operating organization. This section also requires that means be provided for appropriate evaluation of its effectiveness.
s Inspector discussions with licensee Radiological Controls personnel relative to the above indicated that no formally documented training, qualification or retraining program had been established for contractor radiological control personnel. Although contractor technicians are required to read and indicate, through their signature, that they have read the radiological control procedures, no formal means was in place to determine the effectiveness of this type of training.
The inspector noted that Radiological Controls foremen were apparently utilizing independent judgment to verify a technician's knowledge and that no acceptance criteria for use in evaluating the contractor
technicians had been established.
The inspector noted that approximately 124 contractor radiological control technicians were working at the site compared with approximately six licensee Radiological Controls foremen and 41 licensee technicians in training who were not yet ANSI-N18.1-1971 qualified.
Licensee Radiological Controls representatives. indicated that a number of the contractor technicians had been trained and qualified through the licensee's permanent Radiological Controls Technician training program.
Inspector discussions with licensee Radiological Controls
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representatives indicated action would be taken to establish formal criteria to measure the effectiveness of contractor radiological control technician training and qualify applicable contractor technicians prior to commencement of the outage.
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The inspector indicated the licensee's contractor radiological control technician training would be reviewed during a subsequent i
inspection (50-334/81-32-05).
j No violations were identified.
5.
Radiation and High Radiation Area Posting and Control
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The inspectors toured the controlled areas initially upon arrival and at various times during the inspection.
The inspectors performed radiation l
intensity measurements where necessary to verify licensee compliance with
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the requirements of 10 CFR 20.203, " Caution signs, labels, signals and controls" and Technical Specification 6.12, High Radiation Area.
The inspector's tours revealed that Radiation and High Radiation Areas were being posted, barricaded and/or locked in accordance with the above
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requirements.
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No violations were identified.
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6.
Radioactive and Contaminated Material Control
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The inspectors toured the controlled areas and reviewed licensee control i
of radioactive and contaminated material with respect to the requirements of 10 CFR 20.203, " Caution signs, labels, signals and controls," and Rad Con Procedure 3.2, " Labeling and Packaging Radioactive and/or Contaminated
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Material," dated October 21, 1980.
No violations were identified.
7.
Respiratory Protection Program
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i The inspector performed a limited review of selected portions of the licensee's respiratory protection program with respect to 10 CFR 20.103,
" Exposure of individuals to concentrations of radioactive materials in air in restricted areas," and Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection."
The inspector's review indicated the licensee had established radiological control procedures for: control, issuance, proper use and return of respiratory protective equipment (Procedure 10.1); training, fitting, removing and testing of respirator equipment (Procedure 10.2); inspection,
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i repair, and storage of full face respirators (Procedure 10.4); inspection, repair, and storage of air supplied hoods (Procedure 10.5), and the sodium chloride respirator test system (Procedure 10.6). The licensee j
had also issued procedures for use of the Chemox mask (Procedure 10.3);
use of 35% oxygen airline equipment in containment (Procedure 10.7); and
anti-contamination clothing specifications (Procedure 9.3).
Procedure 9.3 includes guidance for use of respiratory protective equipment based on airborne radioactivity level.
The inspector reviewed selected sections of the above procedures, toured the respirator repair and storage areas, and discussed the respiratory protection program with cognizant personnel.
The following was noted:
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Procedure 10.1, Section 3.5.1, provides guidance for setting the air flow rate provided to air supplied hoods.
Procedure 9.3, section
3.6.4 indicates the hoods can be worn in airborne radioactivity
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concentrations greater than or equal to the value specified therein.
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The procedures do not include the guidance provided in IE Bulletin i
78-07, dated June 12, 1978, " Protection Afforded by Air-line Respirators j
and Supplied-air Hoods," relative to allowable airborne concentrations
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to be entered based on air flow rates provided to the hood.
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NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Materials, which is referenced in Regulatory Guide 8.15, recommends, as a minimum, Grade 'D'
air be provided for breathing in air-supplied l
respiratory protection equipment.
The limiting characteristics for
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Grade 'D' air include a limit for condensed hydrocarbons.
The licensee's Procedure 10.1, which provides guidance for testing breathing air, does not include a test for condensed hydrocarbons.
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NUREG - 0041 states in Section 9.3.that respirators are to be packed
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or stored so that they are not damaged by adjacent equipment or twisted out of their normal configuration by improper storage.
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During a tour of the respirator maintenance area on December 16, 1981, the inspector observed Chemox facepieces stored at least 5 high in bins.
The inspector noted storage in this manner would result in deformation of the respirator face piece, i
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Procedure 10.2, Section 3.2, indicates that a " Hyper-Flow" valve is
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used to control air flow to full face, constant flow air line respirators.
The inspector noted this valve was no longer being used for fullface constant flow equipment. The licensee indicated these valves were removed from service and have been replaced with the appropriate NIOSH-approved valves.
The inspectcr's review revealed that the licensee's respiratory protection equipment maintenance procedures (Radiological Controls Procedures 10.4 and 10.5) provided limited guidance for repair of full face respirators.
For example, Procedure 10.4 indicated that if a respirator lens is damaged,
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it must be replaced. No instructions for replacing the lens were included l
in the procedure (such as inspecting lens seating surfaces prior to installation of the lens).
Other matters which were not addressed in the procedures included repair and replacement of respirator exhalation valves, inhalation port adapter, or inhalation flapper.
In addition, the procedure for repair of air supplied hoods (Procedure 10,5) contained no instructions regarding use of approved replacement parts including such items as approved hose lengths when replacing hoses.
These matters were brought to the licensee's attention.
The inspector discussed the licensee's respiratory protection program with the licensee's Acting Respiratory Protection Supervisor. The discussions revealed that the program was being reviewed by this individual.
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The licensee indicated they plan to take credit for the protection provided by respirators in the future. At that time the licensee must follow the regulatory guides cited above. Accordingly, the inspector indicated the above matters would be reviewed during a submquent inspection (50-334/81-32-06).
i No violations were identified.
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ALARA l
The inspector reviewed selected portions of the licensee's program for maintaining personnel radiation exposures as low as reasonably achievable j
(ALARA) with respect to:
Regulatory Guide 8.8, "Information Relevant to l
Ensuring that Occupational Radiation Exposures at Nuclear Power Stations t
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will be as Low as is Reasonably Achievable"; Rad Con Procedure 8.1, i
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" Radiological Work Permit (RWP)," dated May 12, 1981; Rad Con Procedure 8.4, " Radiological Work Permit (Access Control)," dated June 5,1981; and Rad Con Procedure 8.5, "ALARA Review," dated September 17, 1981.
Since the licensee was preparing to commence an outage, the inspector primarily reviewed the licensee's ALARA pre planning for the outage tasks.
Regulatory Guide 8.8, Regulatory Position C.3.a, " Planning and Preparation,"
states in part, "Before entering radiation areas where significant doses could be received, station personnel should have the benefit of preparations and plans that can ensure the exposures are ALARA while performing the services..."
The inspector's review of the licensee procedures referenced above with respect to pre planning indicated Procedure 8.1 requires that the Radiological Controls Supervisors determine if an ALARA review is required before issuance of an RWP and that copies of the ALARA reviews and the resultant actions be included with the RWP.
Procedure 8.4 requires completion of a radiological status report " dependent on radiological conditions of the area." The status report includes a block to indicate whether a man-rem estimate was made prior to the work.
Review of Procedure 8.5 with respect to pre planning indicated that Radiological Controls personnel may initiate an ALARA review upon receipt of an RWP request, may initiate an ALARA review when information from Planning and Scheduling or work supervisors indicates that significant radiation exposure may occur during a work task, and Radiological Controls supervision should initiate an ALARA review if an individual could receive a dose of 200 millrem or a work party could receive a cumulative dose greater than 1000 millirem.
The inspector's review of the licensee's ALARA planning for the current outage indicated that Radiological Controls personnel were attending outage planning meetings to maintain cognizance of planned outage work.
The inspector's discussion with licensee Radiological Controls personnel relative to these meetings indicated that during October 1981, an ALARA presentation was made as it related to work under RWPs.
Further, the discussions indicated that Radiological Controls personnel were provided with an outage work schedule. The inspectors review of a schedule on December 17, 1981 and discussions with cognizant personnel indicated the schedule provided the Radiological Controls group with a " general idea" as to what jobs would need Radiological Controls coverage and ALARA reviews. However, the schedule provided insufficient information to allow the Radiological Controls organization to perform an adequate ALARA review in that the schedule did not provide information on when the job would start or the estimated man-hours required to complete the job.
Consequently, the Radiological Controls group could neither prioritize their ALARA reviews nor estimate expected man-rem exposure. However, at several outage meetings (as early as 3 months before the outage) Radiological Controls personnel requested that supervisors provide the Radiological
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Controls group with RWP requests so that adequate work support could be provided and adequate ALARA reviews could be performed.
The inspector noted that on at least one occasion (December 10,1981),
the Radiological Controls group issued a memorandum to-various work supervisors requesting that they review their work packages and provide
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input to allow the Radiological Controls group to draft RWPs.
The inspector noted that as of December 17, 1981, 15 days before the start of the outage, only five RWP request forms had been submitted. Of the five, three were incomplete and could not be adequately acted upon.
The inspector's discussions with Radiological Controls personnel indicated
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numerous work jobs were scheduled to be performed during the outage which
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would require RWPs and ALARA reviews.
In addition, the inspector's discussions with cognizant Radiological Controls personnel indicated that routine, non-outage RWPs are requested with little advance notice to the Radiological Controls group, thus allowing insufficient time to perform pre-work ALARA reviews.
The inspector's review of this area did not identify any apparent areas where insufficient ALARA pre planning had occurred.
However, the inspector noted that lack of sufficient time to pre plan a job for ALARA purposes may compromise the adequacy of this review.
i As a result of the above, the matter was discussed at the exit interview with the licensee's Vice President - Nuclear Division.
This individual indicated that a memorandum would be issued to work supervisors requesting that they provide input to the Radiological Controls group to-allow them to adequately pre plan work in radiation areas for the upcoming outage.
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The inspector indicated the above matter and the licensee's ALARA program would be reviewed during a subsequent inspection (50-334/81-32-07).
j 9.
Exit Interview
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The inspector met with licensee representatives (denoted in Paragraph 1)
at the conclusion of the inspection.
The inspector summarized the
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purpose, scope, and findings of the inspection.
l Licensee representatives indicated the following:
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Action will be taken to establish formal criteria with which to determine the effectiveness of contractor radiological control technician training and the criteria will be used for qualifying applicable contractor technicians prior to commencement of the outage (details in Paragraph 4.b).
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Action will be taken to provide Radiological Controls Technicians
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with sufficient job information to allow them to adequately pre plan (for ALARA purposes) applicable outage work (details in Paragraph 8).
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Appropriate revisions to the Radiation Work Permit procedure will be
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made prior to the outage to ensure workers receive the required pre-work discussions (details in Paragraph 2.b).