IR 05000395/1989023

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Insp Rept 50-395/89-23 on 891127-1201.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Activities,Including Review of Licensee Organization & Mgt Controls & External Dose Controls
ML20005E618
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 12/20/1989
From: Potter J, Wright F
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20005E617 List:
References
50-395-89-23, NUDOCS 9001100003
Download: ML20005E618 (13)


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101 MARIETTA STREET N.W.

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DEC 2 91989 Report No.: 50-395/89-23-Licensee: South Carolina Electric & Gas Company Columbia SC 29218 Docket No.: 50-395 License No.: NFF-12 Facility Name:

V. C. Summer Inspection Conducted N

iber 27 - December 1.1989 Inspector:

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/f F. y Wrif DfeSigned Approved by:'

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J.#. Pot;er Chief I)6te(Signed Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This. unannounced inspection of radiation protection activities included a review of the licensee's organization and management controls, external dose controls, surveys and control of radioactive material, solid radioactive waste controls, transportation of radioactive material, and follow-up of previously identified items.

Results:

No violations or deviations were identified. Licensee internal audits of the radiological controls program were strong. Procedural compliance and content inadequacies were documented in licensee surveillences and audits. Based on

.these findings licensee management had initiated improvements in the radwaste management. Completed improvements will be reviewed as an Inspector Followup Item (IFI). The licensee was experiencing frequent alarms from naturally occuring radioactivity on whole body friskers at exits to the radiation control area (RCA). Actions to document such elarms, being from naturally occuring radioactivity, will be tracked as an IFI. The licensee made significant progress in further implementation of the ALARA program, and recently appointed a new Associate Manager. Health Physics (HP).

The new Associate Manager's qualifications were adequate to meet the requirements of licensee Technical Specifications (TSs).

Overall, the licensee's radiation protection program 9001100003 891229 PDR ADOCK 05000395 O

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appeared to be generally effective in protecting the health and safety of l

workers.

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • W. Baehr, Manager, Chemistry and Health Physics
  • L. Blue. Manager, Corporate Health Physics, e'

Environnental Programs

  • H. Donnelly, Senior Engineer, Regulatory Comr sette G. Guy, Coordinator Radwaste Process
  • G. Hall, Associatu Manaaer. Health Physics
  • S. Hunt, Manager. Quality Systems
  • A. Koon Jr., Manager, Nuclear Licensing
  • D. Moore, General Manager, Engineering Services
  • K. Nettles, General Manager, Nuclear Safety
  • C Price, Manager Technical Oversight
  • J. Skolds, General Manager Nuclear Power Operations
  • G. Soult, General Manager, Operations and Maintenance Other licensee employees contacted during this inspection included technicians and office personnel.

Nuclear Regulatory Commission

  • L. Modenos Resident Inspector
  • R.

Prevatte, Senior Resident Inspector

  • Attended exit interview

2. Organization and Management Controls (83750)

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Organization Licensee TS 6.3.1. requires that each member of the facility staff meet or exceed the minimum qualifications of ANSI NI8.1-1971 for comparable positions, except for the Associate Manager, HP (Radiation Protection Manager) who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.

Reoulatory Guide 1.0, September 1975, required the Radiation i

Protection Manaaer to have a bachelor's degree or the equivalent in a science or engineering subject, includina formal training in radiation protection and at least five years of professional

experience in applied radiation protection. At least three years of the professional experience should be in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power plants.

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The inspector reviewed changes made to the licensee's organization, staffing levels and lines of authority as they related to radiation

protection, and verified that the changes had not adversely affected the licensee's ability to control radiation exposures or radioactivity. The Associate Manager. -HP position was vacated

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September 8,1989, and the licensee transferred an employee from the

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Environmental Center to the position October 23, 1989. The inspector verified that this individual met the minimum qualification i

requirements specified in licensee TSs.

The number of ANSI qualified HPs continued to increase in 1989 from 18 and 23 in 1987 and 1988, respectively. The total HP staff level was 53. That total includes 15 vendor HPs. The licensee has approved the hiring of five of the vendors into permanent licensee HP positions. The licensee has had three staff turnovers in the year which included the Associate Manager, HP.

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Management Controls

The inspector discussed the audit and surveillance program related to i

radiation protection, radioactive waste management, and transportation of radioactive material with licensee representatives.

The inspector reviewed the following audits:

SCE&G/QA Audit, #11-02-89-R, Radwaste, January 25 - February 3,

1989, dated January 10, 1989

SCE&G/QA Audit f!I-19-89-L. Radiation Control Program.

October 4-13, 1989, dated September 20, 1989 The inspector also reviewed the following V. C. Summer Nuclear Station - Surveillance Reports:

01-AEC-89-L Routine Radiation Survey, January 11, 1989, issued

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January 20, 1989

05-RDD-89-L Calibration of a R0-2 Survey Instrument, April 14, 1989, issued April 27, 1989 07-LPC-89-L, Control of Licensable Sources, April 28. issued

May 10, 1989 09-AEC-89-R, Liquid Waste Demineralization Evolution, June 29, 1989, issued July 28, 1989 11-BLT-89-L. Radiation Protection Practices, June 6-7, and July 10, 1989, issued August 3, 1989 l

12-LCN-89-L, Radiological Assessment August 31, 1989, issued

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12-ESL-89-L.

Calibration of H.P.

Field Instruments.

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September 26. - October 6, 1989 13-BLT-89-R, Operation of DURATEK, September 12, 1989, issued

October 6, 1989 Licensee Audit II-2-89-R documented seven findings concerning the licensee's radioactive waste program (Paragraph 6) and licensee Audit II-19-89-L included two findings, one related to respiratory protection and an other concerning FSAR revisions. Surveillance 13-BLT-89-R reported failure of a operator to follow a radwaste

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operating procedure and 12-ESL-89-L documented three findings concerning radiation survey instrumentation. Eleven of the fourteen findings reported in radiological protection and radioactive waste audits and surveillances were procedure related. Eight findings were

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issued due to inadequate or obsolete procedures, and three other findings documented failure to follow procedures. The inspector discussed the procedure findings with the Manager of Chemistry and HP.

The majority of procedure inadequacies were associated with

radwaste activities.

Licensee representatives reported that management was aware of the need to improve radwaste procedures and

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was in the process of rewriting all of the radwaste procedures (Paragraph 6). The inspector discussed the findings and the HP response to audit and surveillances findings with quality assurance (QA) auditors. The auditors reported that there was a willingness on behalf of the HP staff to identify and fix program inadequacies. The inspector stated-that, while the audit and surveillance findings indicate weaknesses in radwaste procedures and attention to detail by the HP staff, the licensee's proaram for identifying and correcting HP program deficiencies was a program strength.

No violations or deviations were identified.

3.

External Exposure Control and Personnel Dosimetry (83750)

TS 6.8 requires the licensee to have written procedures, including the use of radiation work permits (RWPs). The inspector reviewed selected RWPs for appropriateness of the radiation protection requirements based on work scope, location, and conditions.10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive material. Additional requirements for control of high radiation areas are contained in TS 6.12.

During tours of the plant, the inspector reviewed the licensee's posting and control of radiation areas, high radiation areas, airborne radioactivity areas, contamination areas, radioactive material areas, and the labeling of radioactive material.

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10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring equipment to specific individuals and require the use of such

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equipment. During tours of the plant, the inspector observed workers wearing appropriate personnel monitoring devices.

No violations or deviations were identified.

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4.

Surveys. Monitoring, and Control of Radioactive Material (83750)

10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations and (2) are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.

The inspector reviewed selected records of radiation and contamination surveys performed during the November 1989, and discussed the survey results with licensee representatives. During tours of the plant, the inspector observed HP technicians performing radiation and contamination surveys.

The inspector performed independent radiation and loose surface contamination surveys in the auxiliary and radwaste buildings and verified that the areas where properly posted. The inspector discussed with the licensee the methods used to release material from tne restricted area and observed technicians performing release surveys for material.

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During the inspection, the inspector observed persons performing personnel contamination surveys when exiting the licensee's RCA. The licensee has whole body friskers located at the licensee's primary RCA exit. Throughout the inspection, the inspector and licensee personnel repeatedly received contamination alarms from the whole body friskers when attempting to exit the RCA. When the personnel contamination monitors alarmed. HP personnel responded to investigate the nature of the contamination. The licensee was experiencing problems with naturally occurring radon daughter plateout on hard hats, clothing, and hair. The whole body monitors were sensitive enough to detected low levels of the naturally occurring radioactive i

contamination. The HP representative investigating the alarms attempted to determine the work location of persons contaminated and survey personnel with a thin window Geiger-Muller (GM) detector connected to a portable count rate meter. Persons working in clean areas of the RCA and having measurable activities, of several hundred counts per minute or less, were assumed to be contaminated with naturally occurring contamination. The inspector and other workers were instructed to wait several minutes and continue personnel monitoring with the whole body friskers until receiving a clear survey. Depending upon how much contamination was present, the workers waited for the radionuclides to decay off. Most of the workers observed by the inspector were able to clear the contamination monitors in a half hour. The HP personnel would occasionally have the worker don a

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pair of coveralls and keep the personnel clothina within the RCA survey area. This would enable the worker to leave the RCA and return later in

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the day to pickup personnel clothing after radioactive decay. The worker

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would then don the personnel clothing.and survey out of the RCA with the

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clothing on in a whole body frisker. The inspector also observed the licensee take personnel clothing from workers and acquire a short isotopic i

spectrum of-the contaminated clothing. The spectrum analysis was performed with a spectroscopy system in an adjacent counting room in the RCA. The licensee would look for isotcoic peaks identifying radon daughters. If the daughters were present, the worker would be allowed to exit the RCA with

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the item or clothing, even if the gross activity was greater than the gross unidentified contamination release limit. The inspector requested

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for review records of routine or special air samples demonstrating that the licensee was experiencino contamination problems from naturally

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occurring radionuclides. The licensee did not have any air samples that indicated a problem with radon, on the day of the request. The licensee did not have daily routine air samples in the facility except in one area where the licensee was having problems with noble gases. A sample was taken there daily. The rest of the routine air samples were made on a weekly frequency. The licensee also did not keep any records of the gamma spectroscopic analysis, or that a analysis was made, of the contaminated articles leaving the RCA. The inspector requested the licensee take air samples in the licensee's auxiliary buildir,g. Spectroscopy analysis of the

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air samples identified that radon daughters were present. The inspector stated that it was apparent that the licensee was experiencinq contamination problems from naturally occurring radioisotopes. However.

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the licensee did not have any documentation showing that radioisotopic

identifications were being made in air samples or of the personnel clothing being released from the licensee's RCA. The licensee committed to documentino qualitative assessments of radon daughters, made to release items from the RCA. in the shift loabook. The inspector determined that the shift logbook was a plant quality assurance record. The inspector stated that a review of the licensee's methods for evaluating natural radioactivity contamination would be reviewed in a future inspection.

The inspector determined that the licensee had 15 cases of skin contamination and 28 cases of personnel clothing contaminations documented

- throuch the end of November 1989. This compared with 76 and 54 in 1987 and 141 and 171 for 1988.

l The licensee had documented 15 personnel contaminations with hot l

particles. This compared with 3 and 80 for 1987 and 1988 respectively. The licensee had three cases of skin contaminations resultina in skin dose assignments greater than 100 millirad, and none in excess of 1.000 millirad for 1989 through November.

The licensee continued to do a good job limiting the area of the plant

controlled as contaminated. The area for contamination control tracking

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included the auxiliary and fuel handling buildings. At the time of inspection the licensee had a little over one percent of the area controlled as a contaminated area.

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No violations or deviations were identified.

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5.

Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)

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(83750)

10 CFR 20.1(c) states that persons engaged in activities under licenses issued by the NRC should make every reasonable effort to maintain radiation exposures as low as reasonably achievable. The recommended elements of an ALARA program are contained in Regulatory Guide 8.8

"Information Relevant to Ensuring that Occupational Radiation Exposure at

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Nuclear Power Stations will be ALARA," and Regulatory Guide 8.10

" Operating Philosophy for Maintaining Occupational Radiation Exposures ALARA."

The inspector reviewed the progress of several areas for improvement identified in an ALARA inspection made earlier in the year. The inspector noted that the licensee was making ALARA program improvements

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(Paragraph 8). The licensee had approved an employee reward system for implemented ALARA suggestions, scheduled RTD bypass replacement for the next refueling outage, and had begun installation of equipment and mockups in a ~" hands-on" trainino facility that should permit reduced occupancy time in radiation areas.

A " Loop Flow Trainer" had been approved for the facility that will have various components working together as a real operating liquid system. Example of the equipment to be in the loop are:

tanks - expansion, sumps, and chemical mixing; pumps - single stage centrifugal, screw, diaphragm and gear type; heat exchangers oil and water; various filters and strainers; cooling tower; instrumentation -

pressure, temperature, and flow gauges; valves - cates, checks, reliefs, swing, ball, and butterfly; transmitters; solenoid valves; oil free compressors; and cranes. The licensee also intended to operate a hydrogen recombiner system in the new facility.

The licensee's collective dose goal for 1989 was 22.7 person-rem. As of October 13, 1989, the licensee's collective dose was 56 person-rem. The licensee had five unscheduled outaoes in 1989 that resulted in 31.1 person-rem. The licensee's collective dose was not excessive.

No violations or deviations were identified.

6.

Solid Radioactive Waste (83750)

The inspector reviewed the licensee's solid radioactive waste management program, including: adequacy of implementing procedures to properly g

classify and characterize waste, prepare manifest, and mark packaoes, and the adequacy of required records, reports, and notifications.

i 10 CFR 20.311 requires a licensee who transfers radioactive waste to a

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land disposal facility to prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56. It further establishes specific requirements for conducting a quality control program.

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The inspector reviewed the methods used by the licensee to assure that i

waste was properly classified, met the waste form and characteristic requirements of 10 CFR 61, and also met the disposal site license conditions, and discussed the use of these methods with licensee i

representatives.

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Licensee QA Audit II-02 89-R Radwaste, made in January and February 1989.

documented seven findinas in the radweste program area. The findings identified problems with licensee procedures and included examples of outdated procedures. inadequate procedures, and failure to follow i

procedures. The inspector discussed the procedure problems with the Manager of Chemistry and Health Physics (C&HP). The licensee was aware that the procedures were a weak area in the licensee's radioactive waste program. The licensee was rewritino all of the radioactive waste procedures and was not just fixino the specifically identified problems.

According to licensee representatives, the procedures in their previous format were cumbersome and were difficult to use. The licensee had planned to have the procedures completely reworked, approved, and in use by March 1990. The procedure requirements agreed with regulatory requirements, and the inspector did not identify any regulatory problems with the procedures in use. However, the inspector stated that the licensee's revised procedures would be reviewed in a future inspection and tracked as IFI 50-395/89-23-01.

In the past year, the licensee combined the radwaste processino and shipping responsibilities under one Radwaste Coordinator reporting directly to the Manaaer of C&HP. As a result, many of the responsibilities for operating radioactive waste systems have been changed and are now assigned to the radweste group. The need to integrate the radioactive waste treatment and disposal responsibilities into the revised procedures was also recognized. The inspector reviewed the responses to the findings identified in the QA audit.

No violations or deviations were identified, t

7.

Transportation Of Radioactive Material (83750)

10 CFR 71.5 rtouires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivered licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.

10 CFR 71.91 specifies the records that the licensee is required to maintain for each nonexempt shipment of radioactive material. The inspector reviewed the records of radioactive material shipments made in 1989 during the inspection and verified that the licensee had maintained the records required by 10 CFR 71.91. The inspector verified that the radioactive manifests reviewed had been properly completed.

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The inspector reviewed plant procedures for the preparation, documentation, shipment and receipt of radioactive material end verified that the procedures were consistent with regulations.

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The. inspector observed the preparation and loading of a radioactive waste shipment containing dewatered bead resin in a high integrity container.

The inspector made independent radiation surveys on the radioactive waste

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transportation vehicle and verified the radiation levels were well within.

those allowed. The inspector verified that the transportation vehicle was properly placarded.

No violations or deviations were identified.

8.

Licensee Actions on Previously Identified Inspector Findings (92701 and 92702)

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(Closed) IFI 50-395/89-05-01:

Incomplete Implementation of Electric

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Power Research Institute (EPRI) Chemistry Guidelines A previous inspection identified incomplete implementation of adopted EPRI guidelines for secondary water chemistry for sulfate and cation

conductivity. The inspectors determined that the EPRI limits had been exceeded during a review of resin intrusion events. The resin intrusions, into the condensate /feedwater systems, had resulted in sulfate and cation conductivity spikes. The licensee committed to operation within the guidelines and to modify procedures to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of deviation from approved EPRI Steam Generator Water Guidelines. The inspector verified that the licensee had modified chemistry procedures to include action levels for correcting and reporting chemistry parameters exceeding EPRI guidelines. The inspector reported that the followup item would be closed.

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(0 pen) IFI 50-395/89-05-01:

Followup of ALARA Action Items by the ALARA Review Committee L

In a previous inspection the inspector determined that ALARA Action l

Items (AAls) and their status were not always discussed at ALARA Review Committee (ARC) meetings. In a licensee response to the NRC, concerning the item dated May 16, 1989, the licensee committed to discuss each item at each requiarly scheduled ARC meeting. The status and progress of each item was to be documented in the meeting minutes. The inspector reviewed the ARC meeting minutes for the most recent meeting held on August 25, 1989. The inspector noted that the

meeting minutes did report that the AAls were discussed at the meeting. However, the meeting minutes did not specify what the action items were or provide any information on their status. The meeting minutes reported that one Connittee member was requested to provide the status of two action items to the Committee Chairman following

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i the meeting. It was not clear, by a review of the licensee's ALARA l

Review Connittee Meeting Minutes alone, what items were discussed. It

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was clear, however, that the status at least 'two items were not

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discussed at the Committee meetino.. Licensee representatives

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L committed to identifying and documenting the status of each action

. item in future meeting minutes as an attachment. The inspector stated

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that 'the item would remain open pending a review of future ARC -

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Meeting Minutes, c.

(0 pen) IFI 50-395/89-05-03:

Minimal Use of the ALARA Suogestion c

Program A previous inspection identified a lack of participation in' the

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licensee's ALARA Suggestion Program as an ALARA weakness. In-a licensee response to the finding, dated May.16,1989, the licensee committed to examining methods to elevate the programs visibility and encourage employee suggestions. The licensee had originally planned

.to have ALARA Suggestion Program improvements implemented by the end of September,1989. The inspector determined that the licensee 'had approved an employee reward program for the ALARA Suggestions Program and planned to have it defined and presented to the plant staff for implementation by March 1,1990. The inspector stated that the IFI

would remain open and the licensee's program would be reviewed in a future inspection, following the program implementation, e

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(Closed) IFI 50-395/89-05-04:

Slowness in Evaluations of Dose Reductions

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During a previous inspection of the licensee's ALARA program, the inspector reported that the licensee had been slow in the evaluation of applicability of various industry dose reduction initiatives. The licensee responded to the finding in a letter dated May 16, 1989. The licensee's response stated, in part, that although the evaluation.of some dose reduction initiatives had taken several years, the licensee i

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did not consider their evaluation process to be unjustifiably slow.

L The licensee response also reported that licensee had scheduled some

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i ALARA initiatives and was considering others. The licensee has scheduled RTD bypass replacement in refueling outage 5 (Spring 1990)

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I and reactor vessel head shield installation in refueling outage 6 (Fall 1991). The inspector stated that the licensee's position would be noted and that continued progress in implementing dose reduction initiatives would be reviewed in future inspections. The inspector stated that the IFI would be closed.

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(Closed)IFI 50-395/89-05-05:

Infrequent Utilization of Photographs, L

Videos, and Mockups for Valve and Pump Maintenance l

In a license response to the finding dated May 16, 1989, the licensee reported that additional utilization of training aides and mockups

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was being emphasized. The licensee's actions to improve the training l

programs included the following:

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The purchase of a video camcorder to record selected in-progress maintenance evolutions to be used more frequently in pump and r

valve maintenance training.

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P,evision of the lesson plan development instruction to require

lesson plan developers to consider the use of photographs, video tapes, and mockups in training to support the stations ALARA L

objectives.

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Construction of a hands-on training facility for maintenance activities.

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Providing refresher training for HP personnel on the use of job code file slides in pre-job planning.

The inspector verified that the licensee had purchased several mockup systems and components that would enable multi-discipline, practical.

hands-on training for station worker. The liconsee was in the process

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of installing the equipment in a training building. The inspector

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also verified that the licensee had completed the other proposed

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program improvements and training. The inspector reported that the IFI would be closed.

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(Closed) IFI 50-395/88-30-01:

Methodology for Calculating Dose to the Skin from Hot Particles

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In a previous inspection the inspector determined that the licensee

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was not calculating dose to the skin utilizing VARSKIN methodology or L

an equivalent and tracked review of the licensee's methodology as a l'

followup item. The inspector determined that the licensee's p

procedures for determining dose to the skin were made using licensee a

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radioactive monitoring instrumentation and derived correction factors determined in a licensee study of hot particles. The licensee's method eliminated the need to quantify hot particle quantity of radioactivity and allowed quick dose estimates to be made directly from instrument measurements. The inspector notified licensee L

management that the item would be closed.

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(0 pen) IFl 50-395/88-30-03:

Calibration of Differential Pressure Gauges on High Efficiency Particulate Air (HEPA) Filters During a previous inspection, the inspector determined that the

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licensee's differential pressure gauaes on HEPA filters were not routinely calibrated. The licensee committed to calibrating the HEPA pressure gauges to ensure proper operation and providing training to HP personnel on the use of the pressure gauges in determining changing conditions (loading and breakthrough). The inspector verified that the licensee had placed the HEPA filter differential pressure gauges in the licensee's calibration tracking system and provided training to health physics personnel on their use. However, the inspector determined that not all of the HEPA filter pressure I

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gauges had been calibrated, and the licensee did not have their use i

proceduralized. The licensee committed to documenting HEPA filter operation instructions prior to the next refueling outage scheduled in the Spring of 1990. The inspector reported to licensee management that the IFI would remain open until all of the operating HEPA units

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had calibrated pressure gauges and operating procedures were-issued.

9. Exit Interview

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The inspection scope and findings were summarized on December 1,1989, with those persons indicated in Paragraph I above. The inspector

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discussed the earlier licensee staff commitment to document qualitative assessments of radon daughters, made to release items from-the RCA, in the shift logbook.

The inspector also described the areas inspected and discussed in detail the inspect. ion findings listed below. The licensee did not identify as proprietary an;r of the material provided to or reviewed by the inspector during this inspection. Dissenting comments were not received from the licensee.

Item Number Description and Reference 50-395/89-23-01 IFI - Review the licensee's procedures for preparing and shipment radioactive waste and material (Para 1raph 6).

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Licensee management was informed that three IFIs oiscussed in Paragraph 8 were closed during this inspection.

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