IR 05000334/1993025
| ML20058D525 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/23/1993 |
| From: | Bores R, Joseph Nick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058D516 | List: |
| References | |
| 50-334-93-25, 50-412-93-26, NUDOCS 9312030180 | |
| Download: ML20058D525 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
i Repon Nos.
50-334/93-25 50-412/93-26 Docket Nos.
50-334 50-412 Licensee:
Duquesne Light Company One Oxford Center Pittsburgh. Pennsylvania 15279 Facility Name:
Beaver Vallev Power Station. Units 1 and 2 Inspection At:
Shippimmon. Pennsylvania Inspection Period:
October 18 - 22. 1993 Il!23h Inspector:
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J. Nic/, Radiation Specialist Date '
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Facilities Radiation Protection Section, DRSS Approved by:
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Facilities Ra iation Protection Section, DRSS Areas Inspected: Radiological controls during a planned shutdown of plant operations for refueling
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and maintenance. Program elements reviewed included organization and staffing levels, staff qualifications and training, external exposure contml, internal exposure control, radiological surveys, radiation protection logs and records, and ALARA planning.
Results:
The radiological controls program was genemlly very effective in protecting the safety of workers in radiological areas. Areas toured in the facility were well maintained and exhibited good housekeeping. The radiation protection group was staffed by qualified individuals with documented training and qualifications. Improvements were noted in the control of High Radiation Areas and contractor health physics training and documentation. Weakness was noted in the timeliness of required annual whole body counts. Within the scope of this inspection, no violations of NRC regulations were identified.
9312030160 931124 gDR ADOCK 05000334 PDR
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DETAILS 1.0 Persons Contacted 1.1 Licensee Personnel J. Baumler, Director, Audits and Surveillances
"J. Belfiore, Senior Quality Assumnce Specialist
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D. Canan, Senior Health Physics Specialist, Respiratory Protection
- E. Cohen, Director, Radiological Operations Unit 2 3. Freund, Radiological Controls Supervisor
- D. Girdwood, Director, Radiological Operations Unit 1
- K. Grada, Manager, Quality Services Unit M. Helms, Senior Health Physics Specialist, ALARA
I J. Johns, Supervisor, Quality Services Unit
- J. Lebda, Director, Radiological Engineering arid Health
- F. Lipchick, Senior Licensing Supervisor A. Lombardo, Health Physics Associate J. Nipar, Radiological Contmls Supervisor
- T. Noonan, General Manager, NESU l
- B. Sepelak, Licensing Engineer M. Shaw, Nuclear Training Instmetor
- D. Spoerry, Division Vice Pmsident - Nuclear Operations
- G. Thomas, Division Vice President - Nuclear Services
- R. Vento, Manager, Health Physics Various other licensee employees were contacted and interviewed during this inspection.
1.2 NRC Personnel S. Greenlee, Resident Inspector
- L. Rossbach, Senior Resident Inspector P. Sena, Resident Inspector
- Denotes those present during the exit meeting 2.0 Purpose The purpose of this announced inspection was to assess the licensee's implementation of radiological controls during an outage period.
Progam elements reviewed included organization and staffing levels, staff qualifications and training, external exposure control, internal exposure control, mdiological surveys, radiation protection logs and records, and ALARA plannin.
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3.0 Facility Tours The inspector toured many of the radiologically controlled areas (RCAs) of the facility including the reactor building, the spent fuel pool area, the auxiliary building, and the safeguards area. Most areas were generally well posted and exhibited good housekeeping.
Some minor discrepancies in postings were identified to the licenoe's radiological contruls staff.
These discrepancies were resolved and were verified by the inspector during subsequent tours. All High Radiation Areas (HRAs) were barricaded and locked as required
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by NRC regulations and licensee Technical Specifications.
I The licensee provided good controls to prevent the gread of radioactive contamination.
Contaminated areas were well posted and marked with tape or mpe. Step-off pads were placed at the entries / exits to these areas to alert workers of the change fmm a contaminated area to a cleaner area. A large inventory of pmtective clothing was available for work in contaminated areas.
After leaving a contaminated area and removing potentially contaminated protective clothing, radiological frisking instmments were pmvided to workers for checking their hands and feet for contamination. The receptacles provided for the collection of potentially contaminated protective clothing were periodically emptied and the undressing areas were neatly kept to prevent inadvenent spread of contamination.
4.0 Organization and Staffing The nonnal health physics organization that consisted of 50 se.nior technicians and 12 foremen was augmented with approxSnately 200 temporary contactor per anel. The contractor human resources included 119 senior health physics technicians,46 junior health physics technicians,17 foremen, and 18 assistants. Two station Health Physics (HP)
Specialists and one HP Supervisor were placed in the position of HP Coordinator for each work shift and reported to the Director of Radiological Operations. Five to ten foremen reponed to each shift HP Coordinator. The foremen's plant area responsibilities included steam generators, refueling activities, containment, auxiliary building, in-service inspection
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(ISI), foreign object search and recovery (FOSAR), and radiological waste activities. Six to eighteen technicians reported to each of the various foremen to pmvide the radiological support for work in each plant area. HP support functions were generally staffed for continuous outage support and included ALARA, radwaste, respiratory protection, count room, and dosimetry. The HP organization was adequate!y staffed to meet the outage workload and no deficiencies were noted.
5.0 Contractor HP Training The licensee continued to use the Site Specific Radiation Technician Training Program (SSRTTP) that was developed to supply site specific radiation protection knowledge to contractor HP technicians. The SSRTTP was reviewed during a previous inspection (NRC
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Inspection Report Nos. 50-334/92-06; 50-412/92-03) and had not been substantially changed since that time. After a passing grade was obtained on the SSRTTP exams, the technicians were given job performance measures (JPMs). The JPMs were developed to evaluate the mastery of on-the-job skills.
According to a licensee document, titled "SSRTTP Course Letter", maintenance of pmficiency could be satisfied in three different ways. The first method allowed an individual who was returning to the licensee's site from the pmvious refueling outage at the same job classification to myiew the SSRTTP material and take an open book exam. A JPM for returning technicians may be required. The second method allowed attendance in continuing training modules thmughout the year. The third method required the technician to complete the entire SSR'ITP if the technician was not present at the last refueling outage or has changed job classification. An additional waiver was allowed for any individual used as an instmetor for the SSRTTP, upon appmval fmm the Director of Radiological Operations.
The inspector had expressed concem about the documentation and guidelines for use of the waiver during the last NRC radiological controls inspection (combined NRC Inspection Report numbers 50-334/93-10 and 50-412/93-11). The licensee had not waived the SSRTTP for any individuals for this outage period.
An inspection of a random sample of qualification and training documentation for the contractor HP technicians did not reveal any deficiencies with the licensee's training requirements.
All selected records showed that the technicians met the licensee's commitments for experience and training.
6.0 External Exposure Control l
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The licensee maintained an exposure tracking system that recorded the worker's dose fmm self-reader dosimeter (SRD). The worker's radiation exposure was measured by both SRD and thermoluminescent dosimeter (TLD). After each entry into the radiologically controlled area (RCA), the worker was required to record the change in the SRD reading. The SRD
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continued to accumulate the dose and was not zerced. The licensee's procedure required zeroing of the SRD only when the TLD was processed and the dose was recorded. This practice allowed a worker to monitor the total accumulated SRD dose unless the TLD was processed. Since SRDs have a tendency to lose charge and potentially alter the dose reading over an extended period of time, the licensee also recorded all workers' total accumulated exposures from the SRDs approximately once every wee.k.
The inspector observed workers in the RCA wearing their assigned SRDs and the whole body TLDs with the correct body placement. The licensee had an onsite laboratory to process whole body TLDs. This allowed a good response time for obtaining official personnel dose from TLD results.
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The licensee's procedures required a myiew of the TLD reading versus the SRD reading for l
the same monitoring period. This allowed an independent verification of the TLD results.
I For differences greater than 25% between the TLD and SRD, the liccusee conducted an investigation and documented the reason for the difference. The licensee had previously used the total accumulated SRD dose that was recorded weekly to perfonn this comparison.
Since the accumulated SRD reading over an extended period of time may not tmly represent l
the tme dose accumulated, this infonnation did not always agree with the TLD reading.
Therefore, the licensee was attempting to retrieve the total accumulated dose from each entry into the RCA for the same monitoring period. The inspector reviewed some recent records showing a better correlation between the total RCA entry doses and the TLD reading than the accumulated SRD reading and the TLD reading.
When this process is fully implemented, it will improve the TLD to SRD comparison and provide meaningful data to the licensee's staff. However, the licensee is still limited in the use of these data because the SRD recording system is a manual pmcess and is not automated. The data would not
be correct if an employee made an error or omitted an entry from the RCA entry log.
l Another area for potential mistakes is the manual data entry into a computerized tracking
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system.
The licensee was considering a computerized dose tracking system that automatically updates the computer data base and mads accumulated dose from an electronic SRD. An automated system would eliminate any human errors and provide a more accurate comparison.
The inspector reviewed records of extremity and multiple whole body TLD assignments and dose totals. The licensee's procedure required the issuance of extremity TLDs to workers l
when the extremity dose was expected to be five times higher than the whole body dose and
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the total dose was expected to exceed 1875 millirem. The licensee's procedures contained r
the requirement for issue of multiple whole body TLDs when requested by the Dimetor of Radiological Controls or one of the following conditions was met; the work area was a non-
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unifonn dose and any whole body location could receive a dose one and one-half times greater than the chest, the highest whole body dose location was unknown, the dose rates in l
the area exceeded 100 millirem per hour, or the expected whole body dose was greater than l
300 millirem. The licensee had assigned multiple whole body TLDs for specific jobs that j
had non-uniform dose rates to different pans of the workers' bodies (e.g., steam generator entries). The extremity and multiple whole body TLDs were assigned to approximately 100 workers and the dose assignments were well under the regulatory limits. The highest
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extremity dose assignment to an individual was 2000 millirem for the calendar quaner. The NRC regulatory limit for dose to the extremities is 18,750 millirem per calendar quarter,
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The licensee's procedure required calculations for dose assignment fmm skin contamination or from discrete radioactive panicles found on the worker's skin or clothing. The inspector reviewed selected records of events when contamination was found on workers during the frisking process. The licensee had performed the calculations for skin dose assignment for l
the records selected. The highest skin dose assessment reviewed by the inspector involved l
contamination on a worker's shons. The beensee assigned a skin dose of 1270 millirem to i
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the worker. This skin dose assignment is below the NRC regulatory skin of whole body dose limit of 7500 millirem per calendar gaaner.
Other incidents of radioactive contamination and skin dose assignments were very well documented.
7.0 Internal Exposum Control The control of internal exposure control was inspected through a review of air sample results, internal dose assignments, the presence of air sampling instruments in the work locations, and the use of respirators or other engineering controls. Estimated internal dose was assigned to workers based on the results of air samples in the work; areas. Air sample results were calculated in Maximum Permissible Concentrations (MPCs) and multiplied by the time spent by the worker in the ama to obtain MPC-hours. After an individual had accumulated greater than 40 MPC-hours in any seven-day period or 52 MPC-hours in a calendar year, the individual was contacted for a bioassay determination.
The dose calculated from the bioassay replaced the estimated dose assigned fmm the air sample results.
The inspector myiewed the msults of sevemi bicassays to verify the dose assignments. The dose assignments from the air sample wem conservative, and most individuals were not assigned any significant dose from the bicassay determination. The highest internal dose assignment for the outage period was 6 MPC-hours and the NRC regulatory limit is 520 MPC-hours per calendar quaner. The total MPC-hours assigned to all personnel was 217 for the third quarter of 1993 and 57 for the founh quaner of 1993 up to the period of this inspection.
The inspector observed air sampling equipment in the work place when it was appmpriate.
Air filtration and air handling units were also placed in many areas to provide better breathing air in potentially contaminated area;. The inspector did not observe work in any areas that required ventilation or filtration without the units. The licensee had attempted to restrict the use of respirators when possible due to ALARA dose concerns. The radiation-protection staff believul that in many circumstances the individuals would receive more whole body exposure when wearing respirators than when performing the samejob without wearing respintors, and the historical data on some jobs had shown very little internal dose potential The licensee stated that respirator usage had decreased fmm past practice without a significant increase in internal dose assignments. Overall, the inspector concluded that the licensee provided adequate control of internal exposure to the workers.
The licensee maintained a bioassay program to verify the effectiveness of the respiratory protection program. The program included annual whole body counts for personnel with RCA access, whole body counts after personnel radioactive contamination events, and random whole body counts for individuals with RCA _ access for respintory protection verification. The inspector reviewed the records of selected individuals to determine the effectiveness of the licensee's progam.
Most personnel were routinely measured for-bioassay determination according to the licensee's procedures: however, them were some individuals who did not receive an annual whole body count on a timely basis. The licensee
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maintained a list of personnel who had RCA access and had not received a whole body count within the one-year period. Several personnel were overdue by more than 30 days. After thiny days, the radiological contmis staff sent a notice to the individuals concerning their mquirement for an annual whole body count. The inspector observed that this method did not produce effective results because many personnel wem overdue by gmater than 60 days.
One individual was overtiue by over three months. The inspector found this to be a weakness in the licensee's bioassay pmgmm since the licensee did not restrict the individual's RCA access when the annual whole body count was overdue.
8.0 Radiation Surveys The inspector reviewed selected radiological survey documentation for various areas of the licensee's mdiologically contmiled areas (RCAs). The survey records wem completed by fully qualified technicians and myiewed by supervision. Current dose rate and contamination results were used to generate Radiation Work Permits (RWPs) for the survey areas.
Radiation survey records and RWPs were posted on the walls at the entrances to the RCA.
The selected records were completed according to the licensee's procedure requirements.
The inspector found that the documentation of radiation surveys was adequate.
9.0 Radiation Protection Loes and Records Radiation protection logs kept at the RCA access control points and radiological controls work areas were reviewed by the inspector. The logs contained general information such as personnel assigned to particular jobs and job specific updates. They also contained information necessary for turnover to personnel on the next shift. Locations and times of radiation surveys and air samples wem also recorded.
The radiation pmtection logs contained useful and accurate information.
10.0 ALARA Planning and Trending As of October 21,1993, the Beaver Valley Unit 2 founh refueling outage personnel had accumulated 167 person-mm. The personnel exposum goal for all outage work was 240 person-rem. Work on the steam generators represented approximately 35 % of the personnel exposure for the outage to date. The highest personnel whole body total exposure to an individual for the founh calendar quaner of 1993 was 1150 millirem. This number is well below the NRC regulatory limit of 3000 millirem for an individual per calendar quaner.
The licensee continued to use various ALARA tools for the fourth refueling outage. These tools included; pre-outage planning meetings incorporating lessons learned from previous outages, shielding design packages, automated tools for work in high dose rate areas, use of closed circuit television for surveillance activities, training on mock-up systems and
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components, use of a digitizing camera to reproduce component drawings, engineering I
controls for ventilation and filtration of airborne radioactivity, pre-job briefings and
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discussions, and surveillance ofjobs in pmgress to determine if further ALARA techniques could be utilized. The primary system was mn in a heated mode with a lower pH level for an extended time period during shutdown which helped to reduce the contamination levels and lower dose rates in the steam generators.
The inspector reviewed the documents containing the ALARA reviews for reactor coolant pump seal work, FOSAR/ sludge lancing, and steam generator eddy current testing and maintenance. The ALARA reviews were well written and incorporated lessons learned from similar previous work.
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l A pre-job briefm~ g was held for the resin transfer operation that the licensee had planned to perfonn during the time period of the inspection. Although the operation did not take place until after the inspection, the inspector attended the briefing. Licensee personnel conducted the briefing with all workers involved with the operation. The briefm' g contained pertinent radiological information such as dose mtes, radiological area postings, radiological sunrey frequency, dosimetry requirements, methods for maintaining personnel radiation exposures
ALARA, and radioactive material spill contingencies. The inspector found the briefm' g very informative and created a format for workers and radiological controls personnel to discuss the job requimments.
The accumulated radiation exposures for steam generators and other major dose jobs were compared to target goals and past performance. Actual total man-hours and total man-rem accumulated for work on the steam generators were below the estimated target values.
Overall dose rates were lower for this outage period than the last outage for steam generators B and C, but were similar or slightly higher for steam generator A.
I1.0 Radiolocical Job Support
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11.1 Steam Gerierator Work During the period of this inspection, the steam generator work had already been completed.
Therefore, the inspector was not able to observe the work in progress. Through interviews
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with the licensee's staff, the inspector reviewed the radiological contmls used for the steam
generator maintenance and repairs. The steam-generator work included leak testing and steam generator tube plugging on all three generators, and adding steam generator tube
stabilizers in one generator (steam generator B).
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I Before work was performed on steam generators A, B, and C during this outage, the licensee extensively planned the work and trained personnel on a steam generator mock-up in an adjacent wanhouse. The licensee made an effort to create a realistic model of the steam generator and the general work area. This included enclosures, shielding, protective covers, air filtration units, other radiological controls, and worker's tools and equipment.
Before the steam generator work started, radiation dose rate surveys were conducted using both radiation survey instmments and a group of thermoluminescent dosimeters (TLDs).
The TLDs were arranged on a pole that was placed in each steam generator bowl for a period of five to six minutes. The TLDs were pmcessed and the results were compared to the radiation survey instrument data to ensum a close correlation. This was an important
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step to verify that the survey dose rates would correspond to the personnel radiation dose as
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monitored by TLDs.
Based on the radiation dose rate survey data, the health physics personnel controlled stay times in the area of the generators and actual steam generator entries. RCM Form 5.3,
" Authorization for Steam Generator Platform Work",was used to record all current dose and
allowable dose margins. The form was well designed and provided important information to control access and stay times in the area.
Steam generator work was controlled from a desk outside the bioshield wall through the use
of video and audio equipment. This allowed surveillance from a lower dose rate area than the area near the open steam generators. Temporary shielding was erected between the steam generators and the entrance to the steam generator cubicles. A containment tent was
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also erected around the openings of the steam generators to control contamination. A
technician was assigned to dress and undress workers when they entered and exited the steam l
generator work area.
Appropriate multiple dosimetry sets were created for the different types of steam generator j
entries. When an entry for a worker's entire body was planned, the worker wore dosimeters on the head, chest, back, upper arms, thighs, ankles, wrists, and fingers. If only the worker's head and shoulders wem planned to enter the steam generator opening (manway),
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then the worker wore dosimeters on the head, chest, upper arms, wrists, and fingers. Other
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workers that were not allowed to enter the steam generators were monitored by dosimetry
wom in the normal chest location. The dosimetry monitoring for the steam generator j
workers was appropriate and no weaknesses were noted.
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11.2 Other Containment Work Various other radiation work pennits (RWPs) were reviewed for appropriate. stmetions to workers and proper radiological contmis. These RWPs included pressurizer work, steam generator inspections and sludge lancing, reactor cavity decontamination, and reactor coolant pump work. The instmetions to workers were adequate and no deficiencies were noted.
12.0 Other Items 12.1 Radiography Controls As noted in a previous inspection repon (combined NRC Inspection Report Nos. 50-334/93-10 and 50-412/93-11), the licensee did not pmvide adequate radiological controls during radiography operations. The licensee had taken effective immediate corrective actions that were also documented in the inspection repon. During the period of this inspection, the inspector reviewed the long tenn corrective actions for this violation. The licensee had incorporated the preventative measures in a revision of the radiological controls procedure (Chapter 3, Pmeedure 8.9, " Control of Radiography Operations"). The inspector verified that the procedure revision was timely and changes reflected the licensee's cor% itments.
The licensee had experienced no funher problems with radiological controls during radiography operations.
12.2 High Radiation Area Controls The licensee also experienced problems with control of other High Radiation Areas (HRAs)
as was documented in various NRC inspection repons. The licensee had documented these problems in three different Licensee Event Reports (LERs) in 1992 and 1993 (92-006,93-006, and 93-009). In response to these events, the licensee issued a letter to all individuals l
who were qualified to use a radiation dose rate meter to enter an HRA. The letter outlined the requirements for personnel entering an HRA and the individual's responsibilities when -
entering or exiting an HRA. The letter also outlined the initiatives taken by the licensee's staff to address HRA control problems.
The first action was to add another " zone code" to the licensee's existing codes. The l
licensee used zone codes to alen workers to changes in radiological conditions from one area to the next. The zone code "6" was used to mark areas with radiation dose rates above 1000 millirem per hour. As per licensee Technical Specifications, these locked High Radiation Areas (LHRAs) must be locked to prevent unauthorized entries. The licensee's second action was to form a task force to assess the root causes of the loss of controls for HRAs and identify appropriate corrective actions. The third action was a temporary administrative control that required personnel to log all LHRA entries on a small card. This action was intended to increase accountability for maintaining LHRA entrances and to remind personnel
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to close or lock barriers when entering or leaving the LHRA. The inspector found the licensee's actions appropriate and timely.
Since the implementation of the licensee's initiatives, the licensee had not experienced any funher problems with the control of HRAs.
The long term corrective actions for these events will be reviewed in future inspections.
12.3 Calibmtion of Automated Friskine Devices The inspector noted that the required frequency for the calibration of PCM-1B automated friskers was once every 18 months. All PCM-1B machines were marked with calibration stickers that recorded the last calibration and the calibration due date. The inspector expressed concern to the licensee's staff that this calibration frequency did not meet the ANSI N323 - 1978 requirement for annual calibration of radiological survey instmments.
The licensee responded that the automated friskers wem comprehensively checked weekly with a large area (100 square centimeter) cobalt-60 source. The quality control check
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included an efficiency determination for each detector. Additionally, the detectors were tested daily with another radioactive source to ensure that the alarms functioned properly.
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Although the calibration period seemed longer than usual for this type of instmment, the comprehensive efficiency checks would catch any detection problems associated with the equipment. The inspector agreed that the minimal calibration together with the weekly checks was adequate.
13.0 Unit One Outage The inspector conducted limited tours of RCAs within Unit 1. The licensee maintained very good housekeeping and provided good postings to inform workers of changes in mdiological conditions. All high radiation areas were controlled by a barricade and locked as required by NRC regulations.
The inspector observed personnel performing work on the reactor coolant system stop valves located in the reactor containment building. This work involved cutting a metal valve out
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of a line, quickly plugging the line while reactor coolant spilled out to a containment device, grinding the surface, and welding the plug in place. The licensee's radiological controls staff provided good health physics assistance to the vmrkers.
The workers were wearing respintory protection and air sampling equipment used to monitor for airborne radioactivity.
Air sample results showed little or no airborne mdioactivity during the job. The workers were monitored with SRDs and TLDs to measure personnel radiation exposure. One individual was slightly contaminated by reactor coolant during the cutting ponion of the job.
The radiological controls staff handled the contamination event according to the licensee's procedures. Overall, the inspector found the radiological controls comprehensive and very
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well planned. Job planning included practicing ponions of the job on a realistic mock-up that contained non-radioactive wate :
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14.0 Exit Meeting A meeting was held with licensee representatives at the end of the inspection period on October 22,1993. The purpose and scope of the inspection were reviewed and the findings
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of the inspection were discussed. The licensee acknowledged the inspector's findings.
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