IR 05000344/1988020

Insp Rept 50-344/88-20 on 880516-20.Violations Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings & Occupational Exposure During Extended Outages

ML20195H218
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/10/1988
From:	Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195H207	List: IR 05000344/1988020 ML20195H202 ML20195H210
References
50-344-88-20, NUDOCS 8806280244
Download: ML20195H218 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /88-20 Docket N License N NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Ranier, Oregon l Inspection Co., ducted: May 16-20, 1988 Inspector: N A.' Hooker,' Radiation Specialist d O!8/'

Date Signed Approved: k'

G.'P. Yuhas, Chief 4/NI[

Date' Signed Facilities Radiological Protection Section Summary:

Inspection on May 16-20. 1988 (Report No. 50-344/88-20)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings and occupational exposure during extended ous.;es. Inspection procedures 30703, 92701, 92702 and 83729 were addresse Results: In the areas inspectea the licensee's program appeared adequate to accomplish their safety objectives. The licensees performance, overall, appeared to be improvin One apparent violation was identified in one area: 10 CFR 20,201(b) failure to perform a dose evaluation of an individuals' extremities (paragraph 3.g).

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8806080244 880614 PDR O

ADOCK 05000344 DCD

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O DETAILS Persons Contacted Portland General Electric ( PGE )

• C. A. Olmstead, General Manager, Trojan

• J. W. Lentsch, Manager, Personnel Protection-(MPP)

• N. C. Dyer, Manager, Radiological Safety Branch ( RSB )

• T. O. Meek,-Manager, Radiation Protection ( MRP )

• R. C. Rupe, Manager, Performance Monitoring / Event Analysis (PM/EA)

• C, H. Brown, Manager, Quality Assurance ( QA) Operations Branch

• D. L. Nordstrom,, Compliance Engineer

• G. R. Huey, Supervisor, RP J. C. Wiles, Unit Supervisor, RP Planning M. Crafton, Unit Supervisor, RP R. Roth, Unit Supervisor, RP  ;

L. D. Larson, Unit Supervisor, Radwaste ' NRC Resident Inspectors G. Y. Suh, Resident inspector

• Denotes individuals attending the exit intarview on May 20,198 .

In addition to the individuals noted above, the inspector met and held discussions with other members of the licensee's and contractor's staffs.

" Licensee Action on Previous Inspection Findings (92701 and 92702)

(0 pen) Followup (50-344/88-04-01): Inspection Report No. 50-344/88-04 -

documented the review and need to examine the licensee's efforts to complete and implement their Integrated Plan for Improving RP Performance (IPIRPP). During this inspection, the inspector reviewed the licensee's updated Radiological Control Action Plan (RCAP), dated May 16,1988, compiled by the RSB. The. updated RCAP outlined actions completed, progress and expected completion dates for those to be completed on their IPIRPP. The inspector noted that the licensee had made major improvements in tracking the status of these commitments with apparent '

appropriate management distribution. Although the licensee had completed most of the action items, the following areas outlined on the IPIRPP needed further action according to the licensee: I l

• System Radicactivity Control Definition '

• Program to Identify Off Normal Events

! One of the action items for System Radioactivity Control Definition l included removal of the lower reactor vescel internals for search and  !

removal of foreign objects and loose fuel pellets. The licensee expended i

about five days for this operation during this refueling outage (April -

May, 1988). The licensee old not find any loose fuel during visual

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9 inspection and' reactor vessel. vacuuming. Based on this years results, the licensee does not plan on performing the same operation during che1r 1989 refueling outage. Paragraph 3 of this report also discusses licensee audits related to RP performance activitie The licensee's progress in completing the remaining actions on their IPIRPP will be examined in a future inspectio This matter remains ope (Closed) Unresolved Item (50-344/88-04-03): Inspection Report No. 50-34/

88-04 described a licensee identified problem involving errors made in changes to their radwaste computer program that resulted in the potant.al for improper classification of two waste drwns. The inspector verified that the licensee had; appropriately recalculated new waste scaling factors from their 1986 and 1987 waste stream sample analysis; determined that the two waste drums original waste classification ( "A" ) did not change; and the licensee was taking the necessary steps to ensure that their radwaste computer program would be properly validated and verified prior to future us The inspector considors this matter resolve (Closed) Violation (50-344/88-04-02): This violation involved failure to post radiation hot spots in accordance with licensee procedure Based on review of revised procedure RP-102, Survey Techniques, discussions with licensee representatives, and observations made during facility tours, the inspector determined that effective corrective actions had been implemented to prevent recurrence as stated in the licensee's timely 7etter dated April 27,1988. The inspector had no further questions regarding this matte . Occupational Exposure During Extended Outages

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The inspector examined the licensee's program for compliance with the requirements of 10 CFR Parts 19 and-20, TS, licensee procedures, and

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recommendations outlined in various industry standard l Audits and Evaluations 1 i

l The following reports were reviewed and discussed with cognizant '

licensee representatives:

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LEW-104-88 PGE QA Audit of Trojan Plant Radiation Protection Activities, dated April 14, 1988, conducted l

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March, 14-23, 198 The audit team consisted of '

four auditors that included a representative from the RSB as a technical adviser. The audit

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covered 17 functional areas of the RP program, including training and qualifications of contract RP Technicians and the RCAP. Two Nonconforming Activity Reports ( NCARs) and 11 '

recommendations were issued to the RP Department as a result of the audi The NCARs were administrative in nature and did not represent a significant safety problem. The audit concluded that overall, RP activities were observed to be i

well controlle Responses to the NCARs and recommendations appeared appropriate and timel __ _ _ . . ._ .

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One of the recommendations involving clarification.of responsibility for training of contract RP technicians, resulted from training problems before the start of the outag The RP

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Department had increased the formal RP training from about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (previous years) to about 16 >

, hours for this years outage, a major improvement. However, due to PGE's limited T' aining and RP Departments' staf fs, the .RP contract vendor was informed that they would i have to perform this trainin This caused delays in organizing and completing the training before the start of the outag The: training was shared between the long time onsite senior contractor RP personnel and the PGE R j Department. The RP Department stated that they  ;

would assume the responsibility for all contract RP Technician training in the futur RCR-028-88 Evaluation of Radiation Protection Outage Readiness, dated April 5,1988,"~c'onducted by PM/EA during March 28 - April 1, 1988. The evaluation concluded that generally, the RP ,

Depsetment appeared well prepared for the

outag As a result of this evaluation, the RP Depsrtment was provided nine recommendations for program improvements prior to to the refueling '

outage. The recommendations were implemented and

. peared to have been effective in minimizing

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problem RCR-033-88 Observation of Radiological Event Report (RER)

System, dated May 10,1988, conducted by PM/E !

l Three recommnndations were provided to the MPP  :

for improvements in the RER syster. The most i significant recommendation involved the read to ,

proceduralire the handling of Reportable Events (RE) and Technical Specfication (TS) violations O relating to 10 CFR Part 2 The licensee informed the inspector that procedure NPD 600-3, Event Reports, was under revision to include cli l

. immediate repor?.ing criteria including those '

from 10 CFR Part 20. Once fully implemented, the PM/EA recommendations will greatly improve the licensee's RER and ER system ;

Based on review of this area, the licensee's audits and observations of '

i the RP programs appear to be effective in identifying weaknesses and areas for improvement. The RP Department's corrective actions in ,

. response to audit findirigs and implementation of recommendations appeared

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effective in improving program performance. The licensee's performance >

in this area appeared to be improvin No violations or deviations were '

ident;fied.

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b. Changes The licensee had installed a new computerized Radiological Control Access System (RCAS) used in conjunction with two models (PAD 80R and RAD 85R) of programmable Ainor Digital Alarming Dosimeters (DADS). The new RCAS is tied to the workers TLD/ Security No.,

Radiation Work Permit (RWP) No., and allowable dose. The DADS provide workers with a digital readout of their accumulat,ed dose, an audible dose alarm (set at 85 % of their allowable dose), an audible chirping that increases with radiation level increases, and a battery / dosimeter defect alar The 85R DAD provides as 4ditional featfres a dose rate and dose rate alarm. The DADS are primarily worn on the torso with the TL According to the licensee the DADS normally indicate within 5% of the TLD result Pocket Ion Chambers (PICS) are still used when multiple dosimetery is require This new system was noted as a major improvement over the licensee's previous hand written log entry syste The licensee was able to instantly ascertain a workers accumulated, available, and additional exposure approval The new system can provide job historic '

exposure data which should be a major asset in the licensee's ALARA planning progra The inspector also noted that the licensee had made changes to '

their RWP system that included more specific detailed special instructions to the worker and RP Technician work instruction ALARA work plan packages were also included with the RWP fil The licensee's performance in this area appeared to be improving and seemed capable of meeting their safety objectives. No violations or deviations were identifie c. Planning and Preparation The licensee had employed about 78 Senior and 31 Junior RP contract Technicians to augment the RP staff during the refueling outag Other departments such as General Employee Training ( GET ) and 1 Dosimetry had also increased their staffs with contract parsonnel to ]

handle the influx of workers. With the exception of one contract person, selected senior RP technicians were given temporary upgrades I to coordinate RP activities for specific work tasks ( e.g., I refueling, balance of containment, bioshield, and balance of plant).

Selected contract senior RP technicians were upgraded to supervise specific RP act.ivities under the direction of the coordinato The inspector observed that the outage RP organizational structure ;

appeared to function adequately with limited staff and no major RP ;

or personnel problem '

The licensee had purchased a new steam generator (S/G) mockup that dimensionally resembles the S/Gs more than the old mocku Personnel involved in S/G work were provided mockup training to become familiar with specialized equipment and radiological controls for tasks they were to perfor The inspector observed such training in progress during the inspectio . . . - . , . - . . - .

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Selected RP personnel were assigned the responsibility for assuring that necessary survey instruments, respirators, protective clothing, and decontamination supplies were available for the outage. The RP ,

Department had set up their own counting room that was equipped with gross alpha and beta counters, and a GeLi detector gamma counting '

system for analyzing air samples and plant contaminant The licensee's new RP Planning group had preplanned and set ALARA

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goals for identified tasks prior to the: start of the outag ALARA goals were also set for new tasks that developed during the outage.

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The inspector observed that the licensee had available and w?s using portable filtered ventilation systems to cupport S/G work, and other activities to control potential airborne radioactive material The licensee's performar,ce in this area appeared to be improving and seemed adequate to meet their safety objectives. No violations or deviations were identifie d. Training and Qualification The inspector examined training records and resumes of selected contract RP staff. The inspector noted that the licensee had initiated a new program of giving technical exams to test the qualifications of contract technicians prior to the onsite formal RP trainin Training and qualifications were noted to be consistent with licensee procedures and TS 6. During the inspection, the inspector interviewed several of the centract RP technician staff .

and noted no problems with their qualifications. All personnel !

interviewed appeared to be knowledgeable of the licensee's hot particle program, facility RP procedures, and their assigned

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responsibilities.

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j The inspector attended certain portions of the licensee's GET program that consisted of a series of video tapes on the following subjects:

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• Introduction to the Trojan Nuclear Plant

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Quality Assurance i

• Security l

• Site Specific RP I

• Fire Protection

• Chemical Safety

Ctudents were given proctored exams following each video. All individuals who required _ access to radiological controlled areas had

to successfully demonstrate the proper method for donning and removal of PCs for the licensee's Discrete Radioactive Particle (DRP) work areas, classified as Red Zone The GET adequately l

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l addressed the licensee's DRP issues and the new RCAS. The chemical Safety. portion of GET was ncted to be a new part of the progra During facility tours,'the inspector interviewed'several workers regarding their knowledge in relation to GET and identified no .

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problem The licensee's GET was found to be-consistent with the l requirements of.10 CFR 19.12, "Instruction to Workers".

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l The licensee's performance.in this area appeared to be improving, i .and seemed adequate to meet their safety objectives. No violations

! or deviations were identifie External Exposure Control i

! Personnel monitoring was based on licensee processed TLDs, DADS, and

! PICS when appropriate. Exposure data from TLDs could be obtained within four hours for urgent need In addition to normal badging,

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supplementary TLDs and PICS were used to monitor whole body exposures in non uniform fields and extremity monitoring as required. During tours of the containment, fuel handling,-and auxiliary buildings, the inspector noted no failures of workers +.o properly wear personnel monitoring device Exposure records for selected individuals were examine The inspector verified that forms NRC-4 and NRC-5 or equivalent and administrative exposure extension forms were processed in accordance with licensee procedures. For terminated employees, letters documenting exposures pursuant to 10 CFR 19.13 had been prepared and sent. The inspector noted, from review of exposure data records, that as of May 19,1988, the highest whole body exposure to date for any single individual was 1230 mrem. The highest extremity exposure was 1070 mrem and skin was 210 mre Exposures from evaluations due to personnel contaminations or lost dosimetry devices were appropriately added to an individual's exposure recor No individual had exceeded the 10 CFR 20.101(a) or 20.101(b) limit During tours of the containment, auxiliary, and fuel handling ,

buildings the inspector made independent radiation measurements using an NRC R0-2 portable ion chamber S/N 2691, due for calibration on July 13,1988. The inspector noted that radiation areas and high radiation areas were posted as required by 10 CFR Part 20. Licensee access controls were observed to be consistent with TS, Section 6.12, and licensee procedure The licensee's use af their new OAD personnel monitoring device was discussed in section b., abov The licensee appeared to be maintaining their previous level of performance in this area and cppeared capable of accomplishing their safety objective No violations or deviations were identifie Internal Exposure Control The licensee had leased a Helgeson "Quickie" counter to augment their chair type whole body counting system for the refueling

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outag The licensee had added Ce-144 to the "Quickie" counter's radionuclide library, which was not included during their 1987

- refueling outage. Examination of whole body counts of selected

- outage workers indicated no positive intakes of radioactive material that would require further evaluation Air sample data and maximum permissible concer.tratior. (MPC) work sheet) for selected outage tasks were examined. -From the samples examined there was no indication of.any worker being exposed to an intake of radioactive material which would exceed the 40 MPC-hour control measure requiring an evaluation pursuant to 10 CFR 20.103(b)(2). The inspector also noted that the licensee had recently revised procedure RP-109, Airborne Radioactivity Sampling and Analysis, to include an analysis to determine the relative fraction of Sr-90/Y-90 and the addition of Pr-144 for MPC calculations. This change was' based on evaluations of data from air sample analysis obtained during the licensee's 1987 refueling outage fuel contamination problem. With respect to tracking MPC-hours for individual workers, the inspector made the following observations:

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10 CFR 20.103(a)(3) states, in part, "When assessment of a particular individual's intake of radioactive material is necessary, intakes less than those which would result from inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day or 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in any one week at uniform concentrations specified in Appendix B, Table I, Column 1 need not Et' included in the assessment.....". i The licensee's Radiation Protection Manual,Section II.A.4.,

Internal Uptake Limits, states, in part. that no individual

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shall receive greater than 2 MPC-hours exposure to airborne radioactivity without the permission of the RP Supervisor or his designe t Based on review of air sample data for selected RWPs and in plant routine samples, the inspector did not identify any instance where an individual was exposed to an intake of I radioactive material in excess of 2 MPC-hours. To make this I determination, the inspector had to review air sample logs, RWPs, and respirator issuance records. The licensee did not have a formal system for tracking individual worker's I MPC-hour Although the RP Department was made aware of this problem by memorandum, Airborne Radioactivity Sampling, dated December 30,1987, issued by the RSB, they had not developed a formal system regarding this matter. This matter was discussed l at the exit interview on May 20,1988, and the license

acknowledged the inspectors observations. The licensee's action to develop a formal system to track workers MPC-hours

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will be examined in a subsequent inspection (50-344/88-20-01). ;

l Ouring facility tours the inspector observed air sampling in progress, workers wearing respiratory protection equipment, the use l and controls of breathing air supplied systems, and the counting of I air samples. No problems were identified. Review of respirator 1 issuance and qualified users records identified no anomalie .

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The licensee appeared to be maintaining their previous level of performance in this area and their program appeared adequate to *

accomplish its safety objective No violations or deviations were identifie Control of Radioactive Materials and Contamination, Surveys,

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The inspector observed proper use of friskers and whole body i personnel contamination monitors (PCMs) by workers exiting the

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containment and auxiliary access control area The licensee had

! set up two PCMs at the 93 ft, and two PCMs at the 45 ft. containment i access control points. Four PCMs were being used at the 45 f ; primary access control are Workers were observed to be dressed in PCs as specified on their RWPs. The licensee had placed photo i posters at the major PC suitup and undress areas to demonstrate the proper donning and removal of PCs.

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The following procedures were reviewed:

, ' Radiation Protection Manual, Volume 10

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RPHP-10 Personnel and Clothing Contamination Reports

• RPMP-11 Decontamination of the Rafuelina Cavity i * RPMP-16 Discrete Radioactive Particle Control

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• RP-102 Survey Techniques r

• RP-136 Discrete Radiactive Particles Survey Methods i

i Based on review of the above procedures, the inspector noted that the licensee had appropriately developed and revised procedures to improve their DRP control a d routine survey programs. Red zones are established  !

where DRPs are susrected or known to exist, and categorized based on

survey frequency 6.id limiting DRP dose rate value. During facility tours, the inspector observed that red zones and personnel surveys for DRPs were being performed and documented in accordance with the )

licensee's procedures. Survey records indicated that detailed radiation l and contamination surveys were being performed with supervisory reviews '

for all cutage tasks.

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} Selected personnel contamination reports were examined. During the

period of January 1,1988, to May 18,1988, the licensee had experienced

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122 personnel contaminations. For the same peri 0d in 1987, the total was

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374. The licensee considered the main factor that attributed to this

} improvement was their effort to keep contamination levels in contaminated areas and the number of red zones to a minimum. Skin and personnel

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clothing contaminations were evaluated for root cause and corrective action taken to prevent recurrence. Dose ascessments were performed when 1

applicable by the RP Department and reviewet oy the health physics staff.

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RERs were also examined. The licensee had issued 89 RERs during the period of January 1,1983, to May 17,1988. The inspector reviewed RERs issued during March 25, 1988, through May 17,1988. Based on the reviews and discussion with cognizant licensee representatives, the inspector made the following observation On May 18,1988, the inspector noted that RER No. 88-81, dated May 8, 1988, involved a reactor operator (RO) who on May 8, 1988, contaminated his right hand while handling tygon tubing during draining of certain sections of the component cooling water system in the clean areas on the 45 ft. level of the fuel building and pipe facade. The draining was performed with a piece of tygon tubing routed to a floor drain. All of the drains in these areas are considered contaminated and posted as suc The licensee's personnel contamination report indicated that the

contamination level on the R0's right hand was 20,000 dpm for a two square inch are The contamination was effectively removed, the skin dose was calculated to be 8 mrads, and the RO was allowed to return to work without any restriction No contamination was identified on the RO's personal clothin Shortiy after the incident the tygon tubing was located and surveyed. The licensee's survey results indicated that the dose rate at the end of the tubing was 4.5 rads /hr beta and 150 mr/hr gamma at contact, uncorrected for source siz Dose rate measurements at 18 inches were 20 mrads/hr beta and 1.5 mr/hr gamm The clean areas where the R0 had traveled were tlso surveyed and a few small localized areas were found to be contai,iinated with levels that ranged from 1,000 to 80,000 dpm/100 sq.cm, and subsequently cleaned to less than 1,000 dpm/100 sq.cm. The contaminate in the tubing was subsequently identified to be an apparent resin bead thought to have been picked from within the floor drai The RER noted that a contributing cause of the incident was that the R0 had not notified the RP staff prior to draining systems as required on the RWP. For further root cause investigation and corrective action, the matter was forwarded to the Operations Departmen On May 19,1988, the inspector discussed the incident with the MR The inspector asked whether an evaluation of the dose to the R0's hand from handling the tubing, other than from the contamination, had been performed. The MRP informed the inspector that such an evaluation had not been performed. The ir,spector noted that no extremity monitoring devices had been worn by the RO. After this matter was brought to the licensee's attention, their preliminary investigation determined that the R0 had handled the contaminated end of the tubing with his bare hands and an evaluation of the direct dose was initiate CFR Part 20.201(b) requires that each licensee make such surveys as (1) are necessary to comply with regulations in 10 CFR 20 and (2)

are reasonable under the circumstances to evaluate the extent of

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radiation hazards that may be present. As defined in 10 CFR 20,201(a), "survey" means an evaluation of the radiation hazards-incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of condition The failure to evaluate the RO's extremity dose was identified as an apparent violation of 10 CFR 20.201(b) (50-344/88-20-02).

On May 18, 1988, at about 1:00 p.m. , during the removal of the "A" S/G cold leg manway flange, the licensee's survey of the S/G insert identified a hot spot that measured 12 R/hr gamma and about 27 rads /hr beta. The hot spot was at the bottom edge of the insert and determined to be on the S/G side. T. RP staff stopped the work and secured the area leaving the insert in plac The inspector observed a meeting batween members of the RP, planning, maintenance, operations, and S/G contract inspection staffs who met to develop plans and a procedure for vs.ioval of the S/G insert. The licensee's plans also included mockup training for removal of the inser The inspector noted that the licensee's plans appeared conservative and adequate to ensure that exposure and the spread of contamination were minimized. The licensee speculated that the hot spot could be a small fragment of irradiated fue On May 18, 1988, at about 11:00 p.m. , during a subsequent survey of the S/G insert, the RP Technician noted that some liquid had dripped apparently from the insert into the S/G platfor His survey of the wet spot identified a DRP that measured 12 R/hr window open and 1.2 R/hr window closed using a R0-2A survey meter. The DRP was picked up on a wipe of the wet spot and sent to waste for disposal. Due to the high dose rate, the DRP was not gamma counted. The dose rates-from the hot

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spot on the insert were measured to be 15 R/hr gamma and 5 rads /hr beta.

The licensee placed a container under the insert to catch any further drippings. As of the exit briefing on May 20, 1988, the licensee had not removed the inser On May 19, 1988, during a routine floor scan DRP survey of the "A" "D" ,

S/G playpen, the licensee detected a DRP that measured 90 rads /hr beta and 2R/hr gamm The DRP was noted to be imbedded (could not be removed by wipes) in the floor and under the plastic floor covering used in the i are A section of the plastic was cut out and the DRP was removed using +

tape and subsequently analyzed. In the same general area several ,

additional DRPs that measured up to 1 rad /hr were also found embedded in '

the floor under the plasti The licensees analysis indicated that the DRPs were irradiated fuel fragments. Since this the plastic playpen covering had been placed on the floor prior to any S/G work, the licensee speculated that the DRPs were present when the playpen flooring was being placed. The licensee initiated an investigation to determine the cause

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and potential dose hazard from the DRPs. The in=pector will examine the licensee's investigation of this matter in a subsequent inspection (50-344/88-20-03).

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One apparent violation was identifie However, based on the <

observations in this area, the licensees overall performance in this arca indicated an improving tren ALARA ,

The licensee had established a goal of 295 person-rem for 1988 and 254 person-rom for the outage. As of May 17, 1988, the licensee had used 177 person-rem, mostly attributed to the refueling outag Daily computer updates of all routine and refueling outage work were utilized by the licensee to evaluate their effectiveness in maintaining preestablished ALARA goals. The licensee identified ;

several major tasks that were expected to be a major contribLtion to personnel exposures (e.g. reactor disassembly, reactor coolant pump (RCP) seal inspection, RCP bearing oil cooler work, valve maintenance and repair, storage of lead shielding, S/G sludge lancing, reactor assembly, inservice inspection, and S/G eddy current testing). ,

The licensees' new RP Planning group appeared to be a major improvement in the licensee's. preplanning, coordinating, and scheduling of RP activities with other work groups during the outage This group performed the prejob ALARA reviews prepared and

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generated RWPs with detailed RP instructions to insure that appropriate radiological controls were identified and in place prior '

to the jo This new group was also establishing a data base as an aid in future ALARA planning for each job performe Tho inspector also noted that this group has instituted a documented ,

system to monitor work in progress in order to evaluate good and ;

poor ALARA practices. The planning group utilized this system to improve poor ALARA practices identified in connection with inplant i valve inspection and repair task i During facility tours the inspector did not observe any poor practices that would have an adverse effect in the licensee's ALARA progra ,

i The licensee's performance in this area appeared to be improving and adequate to meet their safety objective?. No violations or deviations were identifie . Exit Interview l

The inspector met with the licensee representatives, denotcd in paragraph !

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1, at the conclusion of the inspection on May 20, 1988. The scope and l I findings of the inspection were summarize l l

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The licensee was informed that one apparent violation of 10 CFR 20.201(b) l

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was identified. The inspectors observations described in this report !

were acknowledged by the license !

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