IR 05000413/1993023
| ML20056G809 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/24/1993 |
| From: | Bryan Parker, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056G806 | List: |
| References | |
| 50-413-93-23, 50-414-93-23, NUDOCS 9309070191 | |
| Download: ML20056G809 (14) | |
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UNITED STATES !
jPp arsN NUCLEAR REGULATORY COMMISSION
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p k REGloN ll 7 E 101 MARIETTA STREET. N.W., SUITE 2900
% ;j ATLANTA, GEORGIA 30323-0199
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! AUG S 5 7333 t
Report Nos.: 50-413/93-23 and 50-414/93-23 l ,
Licensee: Duke Power Company l P. O. Box 1007 l Charlotte, NC 28201-1007 )
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Docket Nos.: 50-413 and 50-414 License Nos.: NPF-35 and NPF-52 Facility Name: Catawba 1 and 2
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' Inspection Conducted: July 26-30,1993
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Inspectors: I M'/[92 R. B. Shortridge / Date Signed lN: A' >ls S/2'l>l93 '
B. A. Parker "
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Date Signed Approved b 3 UG m W. H. Rankin, Chief
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Ddte Sitn'e3
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! Facilities Radiation Protection Section Radiological- Protection and Emergency Preparedness Branch ;
Division of Radiation Safety and Safeguards t e !
(- SUMMARY !
Scope:
This routine, announced inspection was conducted in the area of occupational
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radiation safety and included an examination of: organization and management controls, audits and appraisals, external exposure controls, internal exposure controls, control of radioactive materials and contamination, surveys and monitoring, and maintaining occupational exposures ALARA.
l- Results:
l Based oa interviews with licensee management, supervision, personnel from stat M departments, and records review, the inspector found the radiation
' prciection (RP) program to be effective in protecting the health and safety of
- plant employees. Two non-cited violations were identified, one for failure to post radioactive materials areas (see Paragraph 7.a) and another for failure to label radioactive' material (see Paragraph 7.b). The licensee.was observed
. to have a large number of hotspots..in the auxiliary. building (approximately h 170). The reduction of these dose intensive components and piping to reduce hot spots will be tracked by the NRC as an inspector followup item (IFI) (see Paragraph 8). Program strengths were noted in the areas of respirator reduction, control of contamination and shutdown chemistry.
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REPORT DETAILS l
1. . Persons Contacted L
Licensee Employees M.' Couch, Radiation Protection (RP) Supervisor, Dosimetry
- W. Deal,-RP Manager ,
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- J. Fox,-Nuclear Engineer, Corporate Radiation Protection ;
! *J. Isaacson, Supervising Scientist ;
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- R. Futrell, Manager, Regulatory Compliance i
- W. McCollum, Station Manager ,
- G. Mode, General Supervisor,' Technical Support
- K. Nicholson, Specialist, Regulatory Compliance
- J.' Twiggs, General Supervisor, . Radiation Protection ;
Other licensee employees contacted during the inspection included technicians, maintenance personnel, and administrative ;
personne ;
i Nuclear Regulatory Commission
- R. Freudenberger, Senior Resident Inspector l *B. Mallett, Deputy Division Director, DP.SS, Region II '
- denotes -attendance at exit meeting held on July.29,199 ! Organization and Management Controls (83750)
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( The inspector reviewed changes made to the licensee's organization, I l staffing levels, and lines of authority as they related to radiation i
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protection. Since the last inspection, Duke Power Company promoted the ll Radiation Protection Manager (RPM) to a new position. At the time of l this inspection, the RPM position had only been vacant several weeks and !
L: was expected to be filled by one of approximately 10 candidates in i August 199 In the interim, a General Supervisor *,as fulfilling the i duties as acting RP '
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Within. the licensee's organization, three General Supervisors reported !
to the RPM, one of which had recently been succeeded by a supervisor-from Corporate Radiation Protection. Fifteen permanent RP contractors assigned to the licensee's RP program were temporarily relocated to McGuire Nuclear Plant to assist in-their outage. In discussions with licensee ' management, the-inspector learned that the licensees's RP staff-has been downsized from 77 RP technicians in 1989 to 72 currentl Total number of RP staff stood at 97, including the RPM and all related
. staff member L L No violations or deviations were identified.
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2 Audits and Appraisals (83750)
The inspector reviewed the licensee's program for identifying and correcting deficiencies and weaknesses related to the control of radiation and radioactive materials, Audits l .. Technical Specification (TS) 6.5'.2.9 requires audits of facility
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activities to be performed under the cognizance of the Nuclear l Safety Review Board (NSRB) encompassing conformance of facility operation to all provisions contained in the TSs and applicable
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license conditions,~as well as the Process Control Program (PCP)
and implementing procedures.
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The inspector reviewed the most recent Quality Verification Department audit of the RP program conducted March 15 -
April 6,1993, and documented in Report NG-93-05(CN), " Radiation Protection, Chemistry and Process Control." .The audit included an evaluation of respiratory protection, radiological environmental monitoring, surveillance and controls, source control, and I training. The inspector determined that the audit was detailed L and addressed appropriate RP program areas. -The inspector noted that the audit included performance-based evaluations as well as
. review of pertinent documentation and procedures. Review of audit documentation and' discussion with licensee representatives indicated that the audit was conducted by individuals knowledgeable of the RP area, many of which held RP positions within the utility.
l' The audit identified five RP-related findings, three of which
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pertained to respiratory protection and one each pertaining to radiological controls and contamination control. The findings were placed into the licensee's plant-wide Problem Investigation Process (PIP) system for tracking. Review of selected audit findings revealed that corrective actions were both timely and appropriate. Overall, the inspector noted that the audit results contained issues of substance, were well documented, and were reported to facility management, as require '
. Other audit-identified findings were categorized as good l practices, followup items, observations, recommendations, and document; discrepancies. Some of the findings required a formal
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written response stating the corrective actions taken and the root cause.for the. finding. The inspector noted that all categories of findings were tracked for completion of corrective action by the !
Safety Review Group (SRG). !
l In addition to the required audits, the inspector was informed that other reviews were periodically performed in the RP are The last such in-plant review was conducted by the SRG
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September 22 - October 7, 1992, and documented in Report l' l
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SGR/92-026. 1he review addressed the completion of daily exposure ;
. time record cards and was performed as part of the followup to a ,
previous audit finding in which 11-18 percent of personnel l entering the. radiologically controlled area (RCA) failed to turn j in completed dose cards. The review noted that the corrective :
actions had been successful as the percentage of unreturned cards fell to 1.5 percent. The review also noted that the introduction .
of the Electronic Dose Capture (EDC) system would replace the dose l
' card system and would greatly enhance the capture and recording of
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daily dose. The EDC system was fully implemented in January 1994 '
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and dose cards were only used as a backu Overall, the audit program was conducted consistent with regulatory requirement i
- Radiological Incident Reporting System Licensee procedures HP/0/B/1009/22, Investigation of_ Personnel- ;
Contamination, Unplanned Uptakes, and Unplanned Exposures, and :
' HP/0/B/1009/23, Investigation' of Unusual Radiological Occurrences, l provided the primary procedural bases for the documentation and ;
investigation of Radiological Incident Investigation and .
Accountability Reports (RIIAs). The RP group. tracked RIIAs to l capture a variety of radiological occurrences and at certain i
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thresholds, the RIIAs were upgraded and placed in the plant-wide PIP system for- followup and resolutio I l
Through July 1993, the licensee had identified approximately l 97 RIIAs in 1993, 78 of which were associated with personnel contaminations events (PCEs). The 1993 non-PCE RIIAs were all !
problems associated with digital' alarming dosimeters (DADS) !
(failed batteries, EDC log-in problems, etc.) In 1992, the !
licensee identified approximately 128 RIIAs, 123 of which were associated with PCEs. The other five 1992 RIIAs pertained to some ,
lost /offscale dosimetry, a minor tritium uptake and a minor liquid )
releas I Review of selected RIIAs by the inspector noted no significant !
trends or indicators of.RP oerformance problems. RIIA root causes j were categorized in approximately.13 areas; however, the inspector l
. noted that many of the RIIA root causes were placed in the - .
" unknown" category. Licensee representatives informed the
. inspector that this had been noted and that the " unknown" category would probably be expanded. During.the inspection, the inspector ;
attended one of the licensee's quarterly RIIA review meeting l The inspector noted that the licensee used the meeting to evaluate the various incidents, to identify any potential adverse trends,
-and to identify any. corrective actions necessary to improve overall performanc ,
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The inspector reviewed RIIA history from 1987 through 1992 and noted that, overall, total PCEs were trending down, as were the number of PCEs involving hot particles. The rate of PCE occurrence per RWP-hour was also noted to be trending down, as were all of the RIIA root cause categories previously mentione In addition to the RIIA program, the licensee utilized the plant-wide PIP process for the identification, resolution, and tracking of significant radiological problems. For RP, this process was governed by licensee procedure HP/0/B/1000/40, Problem ,
Identification and Resolution Program, and encompassed problems such as observed poor radiation work practices, adverse trends in RIIAs, inadequate control of high radiation areas (HRAs) and extra high radiation areas (EHRAs), contamination outside the radiation control area, and exposures or releases in excess of regulatory requirement l The inspector reviewed selected PIPS associated with the RP function for the period January through July 1993, and noted that l all PIPS that documented radiological deficiencies had low I priorities for resolutio In discussions with RP staff, the l inspector learned that this was why the RP group did not abandon !
the RIIA process. After a review of the PIPS that were '
radiologically related, the inspector determined that the RP group .
was identifying, documenting, and resolving radiological l deficiencies despite the PIP system which appeared to have a high !
threshold for radiological deficiencie i No violations or deviations were identifie l 4. External Exposure Control (83750) Personnel Dosimetry 10 CFR 20.1502(a) requires each licensee to monitor occupational exposure to radiation and supply and require the use of individual monitoring devices by:
(1) Adults likely to receive, in one year from sources external to the body, a dose in excess of 10 percent of the limits in 10 CFR 20.1201(a);
(2) Minors and declared pregnant women likely to receive, in one :
year for sources external to the body, a dose in excess of !
10 percent of any of the applicable limits of 10 CFR 20.1207 or 10 CFR 20.1208; and t
(3) Individuals entering a high or very high radiation are l In January 1993, the licensee changed their personnel dosimetry of record from film badges processed monthly to four-chip thermoluminescent dosimeters (TLDs) processed quarterly. The site
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provided terminating workers with a letter estimating their dose while onsite and the licensee's General Office (GO) provided final termination letters once each quarter. The GO read all of the TLDs and the inspector verified that the licensee was NVLAP-certified in all eight categories, effective until April 1,199 As mentioned, DADS were used primarily for daily dose tracking and ,
the licensee maintained approximately 1500 DADS onsite. Extra DADS were available from other Duke sites, if needed. The DADS were manually calibrated every six months. All DADS examined by the inspector were calibrated as required. According to the licensee, the number of problems associated with DADS, many of which were captured by the RIIA system, was very low considering ,
the thousands of entries made into the RCA. The most common problem associated with the DADS appeared to be battery failure This was not surprising to the licensee based on battery life expectancy and the amount of time the licensee had had the DADS on hand, much of which was spent in storage. The inspector discussed the correlation of DAD dose and TLD dose and noted that, to date, correlation appeared good at approximately 90 percent. However, at the time of inspection, the licensee only had data analyzed from the first quarter of 1993 and they indicated that more data was needed to better define the actual correlatio During tours of the RCA of the auxiliary building, the inspectors noted that personnel were wearing DADS and TLDs properl b. Exposure Control 10 CFR 20.1201(a) requires each licensee to control the occupational dose to individual adults, except for planned special exposures under 10 CFR 20.1206, to the following dose limits:
(1) An annual limit, which is more limiting of : (i) the total i effective dose equivalent being equal to 5 rems: or (ii) the sum of the deep-dose equivalent and the committed dose <
equivalent to any organ or tissue other than the lens of the eye being equal to 50 rem (2) The annual limits to the lens of the eye, to the skin, and ,
to the extremities, which are: (i) an eye dose equivalent >
to 15 rems; and -(ii) a shallow-dose equivalent of 50 rems to
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the skin or to any extremit CFR 20.1501(a) 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 j circumstances to evaluate the extent of radioactive hazards that l may be presen j
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As previously mentioned, the licensee fully implemented an automated access system in January 1993 to enhance their ability to capture and track personnel dose on a daily basis. The EDC system tracked dose, dose alarms and radiation work permits (RWPs), and provided a means to restrict personnel from RCA entry if certain training or other factors needed addressing. The standard administrative dose limit was 2000 millirem per year. At 80 and 90 percent of the administrative dose, the EDC system had
" alert" and " hold" stopgaps at which point an individual's TLD would be pulled until their supervisor requested a dose extensio A daily EDC printout tracked administrative, TEDE, CEDE, shallow, and lens doses, as well as DAC-hours. From a review of an up-to-date EDC printout, the inspector noted that no administrative dose limits had been exceeded and no dose extensions had been given. All personnel were observed to utilize ,
the EDC system without problem and, when questioned, personnel '
were knowledgeable of the requirements regarutng RWPs, dose, alarms, et During tours of the Auxiliary Building, the inspector noted that l; the licensee had current surveys posted outside each room that had radiation levels inside. The surveys were informative but, for i large rooms or areas where dose rates were wide ranging, it *
appeared that personnel might have difficulty remembering the dose l rate (s) in their immediate area. The inspector noted that due to '
the large number of hot spots (see Paragraph 8), there were a :
number of areas near the hot spots that were substantially above ;
background levels but it was not readily apparent what the dose '
rate was in the adjacent are In addition, the licensee planned I to post some'high dose rate components with signs stating
"significant dose contributor" to inform workers, but was not informative with respect to specific dose rates. In general, the licensee had done a good job of posting radiation dose rates but !
lacked information to complete a well rounded program of informing i the worker of dose rates in highly traveled areas and areas adjacent to hot spot ! Declared Pregnant Women !
l 10 CFR 20.1208(a) requires each licensee to ensure that the dose i to an embryo / fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, does not exceed 0.5 re CFR 20.2106(e) requires each licensee to maintain the records I of dose to an embryo / fetus with the records of the declared pregnant woman. The declaration of pregnancy shall also be kept on file, but may be maintained separately from the dose record The inspector learned from discussions with licensee representatives that at the time of inspection, seven workers had declared to be pregnant. Two of the seven declared pregnant women
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(DPWs) were radiation workers and already badged at the time of declaration. The remaining five DPWs were clerical workers and were not badged until after their declaration. After declaring, the DPWs were badged with TLDs processed monthly. The inspector verified that none of the DPWs had exceeded any administrative or regulatory limits thus far in their pregnancie I The inspector reviewed two forms that the licensee developed for the protection of the embryo / fetus. Both forms were voluntary and consisted of a pre-natal exposure agreement form and a declared pregnancy form. No problems were noted with either type of for High Radiation Areas TS 6.12.1 requires, in part, that each high radiation area with a radiation level greater than or equal to 100 millirem per hour (mrem /hr) but less than or equal to 1000 mrem /hr be barricaded and conspicuously posted as a high radiation area. In addition, any
' individual or group of individuals permitted to enter such areas are to be provided with or accompanied by a radiation monitoring device which continuously indicates the radiation dose rate in the area; a radiation monitoring device which continuously integrates the radiation dose rate in the area; or an individual qualified in radiation protection procedures with a radiation dose rate monitoring devic TS 6.12.2 requires that areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 18 inches be provided with locked doors to prevent unauthorized entry in addition to the requirements of TS 6.12.1. The keys for the locked high radiation areas were to be maintained under administrative contro Licensee procedure HP/0/B/1000/25, High Radiation Area Access, described the licensee's specific requirements for establishing, posting, and controlling HRAs and EHRAs. During tours of the Auxiliary Building and Unit 1 Containment, the inspector noted that all EHRAs and HRAs were locked and conspicuously posted, as require No violations or deviations were identifie . Internal Exposure Control (83750)
10 CFR 20.1502(b) requires each licensee to monitor the occupational intake of radioactive material by and assess the committed effective dose equivalent to:
(1) Adults likely to receive, in one year, an intake in excess of 10 percent of the applicable Annual Limit of Intake (ALI) in Table 1, Columns I and 2 of Appendix B to 10 CrR 20.1001-20.2401; and
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(2) Minors and declared pregnant women likely to receive, in one year, a committed effective dose equivalent in excess of 0.05 re I 10 CFR 20.1204(a) states that for the purposes of assessing dose used to I determine compliance with occupational dose equivalent limits, each licensee shall, when required under 10 CFR 20.1502, take suitable and timely measurements of:
i (1) Concentrations of radioactive materials in air in work areas; or (2) Quantities of radionuclides in the body; or (3) Quantities of radionuclides excreted from the body; or (4) Combinations of these measurements.
l The inspector noted that initial, annual, and termination bioassay l measurements were routinely required for workers who were assigned l
dosimetry. The inspector reviewed records of selected contract and ;
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plant personnel and determined that routine whole body analyses were I performed as required. In addition, special bioassays were performed as
, necessary including when individuals underwent nuclear medicine ,
I procedures and when radiological incidents, such as personnel i contaminations, reached certain specified thresholds. The most I significant internal exposure noted by the inspector involved a worker !
who ingested a hot particle in August 1992. The licensee identified the i problem, tracked the particle through the worker, and retrieved and
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analyzed the particle following elimination. The particle was measured at 800 corrected counts per minute (ccpm) and calculated dose was minimal at approximately four mrem to the whole bod The licensee maintained an open geometry whole body counter for conducting most of the bioassay measurements. The unit was calibrated annually. Also, the licensee participated in a quarterly interlaboratory cross-check with the other Duke plants to assure and control the quality of bioassay measurement. The last cross-check was performed in July 1993 and no problems were note The inspector discussed respirator reduction and engineering controls with the licensee and learned that during the Spring 1993 outage, approximately one-third as many respirators were used as were used in the 1992 outage. Although respirator usage reduced drastically and overall work scope remained relatively unchanged, no significant increase in internal exposures were noted; however, some increase in facial PCEs was identified and was being evaluated by the license According to the licensee, use of engineering controls had not significantly increased, but were utilized as needed. DAC-hours were monitored primarily through general area air sampling. The licensee indicated that although lapel samolers were not routinely used, specific airborne or airborne-potential jobs were monitored closely. The inspector considered the licensee's effort to reduce the amount of
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l Based on discussions with licensee representatives, it appeared that the l most significant changes in the RP program from the implementation of !
revised 10 CFR Part 20 occurred in the area of internal exposure j control. Workers in general were trained on the new requirements for l l
internal dose assessment and, on several occasions, RP assisted in '
i counseling workers and supervisors on the changes. No significant l problems have resulted from the changes and the licensee appeared to l
have adapted wel \
l No violations or deviations were identifie l 7. Surveys, Monitoring, and Control of Radioactive Material and Contamination (83750) Posting Radioactive Material Areas 10 CFR 20.1902(e), requires that for posting of areas or rooms in which licensed material is used or stored, the licensee shall post each area or room in which there is used or stored an amount of >
licensed material exceeding 10 times the quantity of such material specified in Appendix C to 20.1001-20.2401 with a conspicuous sign or signs bearing the words " Caution, Radioactive Material (s)" or
" Danger, Radioactive Material (s)."
Radiation Protection Directive No. III-3, Posting of Radiation j Control Zones, Revision 1, dated April 1, 1993, requires, in part, i in step 5.4.5, to post the following areas " Radioactive Materials l Areas" where total activity stored exceeds 10 times the quantity specified in Appendix C of 10 CFR Part 2 During tours of the RCA, the inspector noted that a number of areas where radioactive materials were stored were not posted as i radioactive material storage areas (RMSAs), including- l l
- Elevation 565, Operation's storage area, where a j radioactive waste vacuum cleaner was noted in which the head !
was unclamped and both hose ends were ope * An adjacent area with storage cabinets that contained used catch containments, lead shielding labeled as contaminated, and a leak detector labeled as radioactive materia Both areas had three-bladed, yellow and magenta signs posted on the entrances, but no other information was posted. Radiation 1.evels on the items in the areas read from very low to 4 mrem /hr and 10,000 ccpm. Licensee RP representatives stated that the door to the elevation was posted as a radioactive raaterial storage area '
and they inquired if that was sufficient. The inspector noted that other individual RMSAs were properly posted on the same ,
elevation and pointed out this inconsistenc RP personnel took
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prompt corrective action to post the areas as RMSAs, correcting the deficiency. The inspector noted that the failure to post the i j
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- above listed areas was not safety significant, and was corrected by the licensee prior to the end of the inspection. A second example of a violation of posting was identified when the ;
inspector found a small component labeled as 125 mrem /hr next to a l radioactive material area rope barrier. The item, when surveyed, I
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read approximately 20 mrem /hr contact and 5 mrem /hr at the rope barrier requiring a posting of radiation area. The licensee promptly posted the area as a radiation area.
l In accordance with the NRC Enforcement Policy, the licensee was informed that these deficiencies would be documented as a non-cited violation (NCV) (NCV 50-413,414/93-23-01).
! b. Labeling Containers of Radioactive Material ,
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l 10 CFR 20.1904(a) requires the licensee to ensure each container I l of licensed material bears a durable, clearly visible label l bearing the radiation symbol and the words " Caution, Radioactive
! Material" or " Danger, Radioactive Material." The label must also j l provide sufficient information (such as the radionuclide(s)
l present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, kinds of i materials, and mass enrichment) to permit individuals handling or l using the containers, or working in the vicinity of the containers to take precautions to avoid or minimize exposure Licensee Procedure HP/0/B/1000/30, Use of Release / Radioactive Material Tags, in step 4.6.2, requires labels or tags on any containers of licensed material with contents exceeding 10 CFR Part 20, Appendix B. Table 1, Column 2, or Appendix C ,
quantitie j During tours of the RCA, the inspector identified a number of containers that contained radioactive materials that were not l abeled. On elevations 548 and 582, the licensee had large metal boxes that contained scaffolding. Most of the scaffolding inside the boxes had radioactive material labels that indicated levels of 1 to 10 mrem /hr and was properly packaged (contained); however, the licensee failed to label the outside of the metal box containers. The licensee labeled the containers in accordance i with their procedure prior to the inspector leaving site. The I inspector informed the licensee that due to the low safety significance of the failure to label the containers of scaffolding and the timely corrective action, these deficiencies would be documented as an NCV (NCV 50-413,414/93-23-02).
c. Arei Jontamination The licensee maintained approximately 184,000 square feet (ft2) as radiologically controlled. To control contamination at its source, the licensee's aggressive program focused on individual training, use of good radiological techniques, containments, and i
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maintaining clean areas of the RCA at levels well below the limit >
of 1000 disintegrations per minute (dpm). The licensee also '
implemented an aggressive drip-bag program to contain contamination from both active and inactive (" dry") leaks. As a result of these efforts as well as aggressive decon work, the licensee was able to reduce contaminated area in the RCA that l averaged between 500 and 1500 ft2 Based on the above, the inspector concluded that the licensee was effectively controlling the spread of contamination and considered ,
the effort a' program strengt l Two NCVs were identified, one for the failure to post radioactive l
material storage areas and a radiation area, and a second for failure to l label radioactive materia *
1 8. Program for Maintaining Exposures As low As Reasonably Achievable (ALARA) (83750)
10 CFR 20.1101(b) requires that each licensee use, to the extent practicable, procedures and engineering controls based upon sound l radiation protection principles to achieve occupational doses and doses to members. of the public that are as low as reasonably achievable (ALARA).
Just prior to the last inspection, the licensee's ALARA program as a i whole underwent a major reorganization. The reorganization resulted j from the licensee's desire to allow more interaction among the groups :
involved in ALARA planning. Prior to the reorganization, ALARA planning I consisted of the RP ALARA staff planning jobs expected to be greater j than one person-rem and the Planning Department handling all other jobs expected to be less than one person-rem. Upon completion, the job plans were forwarded to the appropriate group for execution. As part of the l reorganization, the licensee created the four-member ALARA Planning Center (APC) consisting of two representatives from RP ALARA, one representative from Planning and one representative from one of the designated groups responsible for execution of work (i.e. Maintenance).
Assignment of each representative to the APC is expected to be completed in one-year rotationals to provide ALARA planning experience to a greater number of staff. Licensee representatives stated that after j going through a refueling / maintenance outage in Spring 1993, ALARA planning was greatly improve The licensee's overall dose goal for the Spring 1993 outage was ;
141 person-rem. At the time of inspection, the estimated exposure was
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l approximately 175 person-rem toward a year end collective dose goal of l 557 person-rem. With one full refueling / maintenance outage remaining, I licensee ALARA personnel estimated that the total collective dose for 1993 could be near 450 person-rem.
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The i$spector discussed new dose reduction and out-of-core source term reduction initiatives with Chemistry supervision and staff. The licensee provided data that showed in a limited way that early boration and peroxide injection at shutdown was resulting in lower levels of radiation dose rates. The licensee was limited, due to equipment
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constraints and the number of sampling locations, from frequently measuring dose rates during the cleanup phase. Chemistry personnel stated that they were only able to get data from eight locations during the shutdown from the previous outage. The inspector discussed the apparent need for the licensee to characterize the out-of-core source term with licensee RP personnel. They agreed that more data points were needed to better determine the benefits of shutdown chemistry and stated that radiation instrumentation had been approved for purchase that would assist in this effort. Overall, we shutdown chemistry program was considered a strengt The inspector noted during tours of the RCA that a large number of l hotspots existed throughout the plant. When inquiring about this, the inspector learned that the licensee's hotspot identification program had identified and was tracking approximately 170 hotspots. Upon further review, the inspector noted that many of the areas in the plant had significantly higher than normal general area dose rates due to hotspots. In particular, certain areas within the NM sampling labs were fairly dose intensive due to a number of hotspots in the sampling l system. In fact, the inspector determined that approximately one-half of the dose to Chemistry personnel was received from the sampling lab The inspector discussed the hotspot program with licensee representatives. They indicated that the next step was to eliminate the hotspots and that prioritization for elimination had already begun; !
however, the only procress thus far was the establishment of a goal to ;
attempt to eliminate five hotspots each month. Due to the potentially ;
significant dose savings and ALARA implications associated with hotspot I elimination, the licensee was informed that this item would be tracked as an inspector followup item (IFI) for the future (IFI 50-413, 414/S3-23-03).
No violations or deviations were identifie . Exit Meeting On July 29, 1993, an exit meeting was held with those licensee representatives indicated in Paragraph 1 of this report. The inspector summarized the inspection scope and discussed the NCVs and IFI listed below. The licensee did not indicate any of the information provided to the inspectors during the inspection as proprietary in nature and no dissenting comments were received from the license ;
Item Number Description and Reference 50-413, 414/93-23-01 NCV - Failure to post radioactive material storage areas and a radiation area (Paragraph 7.a).
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50-413, 414/93-23-02 NCV - Failure to label containers of radioactive material (Paragraph 7.b).
IFI - Elimination of large number of
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50-413, 414/93-23-03
. hotspots through plant (Paragraph 8).
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