IR 05000416/1982021
| ML20051A468 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf |
| Issue date: | 04/19/1982 |
| From: | Albright R, Barr K, Collins T, Franklin L, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20051A233 | List: |
| References | |
| 50-416-82-21, NUDOCS 8205140488 | |
| Download: ML20051A468 (14) | |
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UNITED STATES 8 -
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NUCLiiAR REGULATORY COMMISSION
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. 101 MARIETTA ST., N.W., SUITE 3100 REGION 11 o,
s ATLANTA, GEORGIA 30303 s
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Report No. 50-416/82-21
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Licensee: Mississippi Power and Light Company P. O. Box 1540 Jackson, MS 39205
' Facility Name: Grand Golf Nuclear Station Docket No. 50-416 License No. CPPR-118 Inspection at Grand G If site near Port Gibson, Mississippi Inspectors:(
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'/ / b !,Ms-C! M. Hosey ' '
Date Sighed
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. R. Collins Date Signed Wh
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// /&82 L. A. Franklin Date Signed E
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Date Signed
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A-4/ /9 82-Approved by:~K. P. Ba#, SecticRhief
'Wate' 6 f gned Technical Inspection Branch Division of Engineering and Technical Programs
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SUMMARY Inspection on March 15-19, 1982
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Areas Inspected This special announced inspection involved 132 inspector-hours on site in the
areas of radiation protection and preoperational testing of liquid, solid, and
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gaseous radioactive waste systems.
Results In the two areas inspected, no violations or deviations were identified.
8205140488 820420 PDR ADUCK 05000416
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. L. Stuart, Assistant Plant Manager
- R. R. Weedon, Chemistry and Radiation Control Superintendent
- J. C. Roberts, Start-up Engineering Supervisor
- T. G. Lee, Staff Health Physicist
- J. Vincelli, Staff Health Physicist
- D. H. Wells, Health Physics Supervisor G. D. Williams, Radiation Control Supervisor
- J. W. Yelverton, Quality Assurance Field Supervisor
- M. A. Lacey, Quality Assurance Consultant L. G. Temple, Instrument and Control Supervisor R. Shaddix, Radwaste Supervisor Other licensee employees contacted included two construction craf tsmen, three technicians, four operations and three office personnel.
Other Organizations A. Patzke - Numanco, Inc. (Training)
NRC Resident Inspector A. G. Wagner D. Scott
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on March 9,1982, with those persons indicated in paragraph 1 above.
The lack of response to previous inspector identified items was noted during this interview. The inspectors comments and concerns were acknowledged by the Assistant Plant Manager.
3.
Licensee Action on Previous Inspection Findings Not inspected.
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Unresolved Items
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i Unresolved items were not identified during this inspection.
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Inspector Follow-up Item
i (Closed) 50-416/81-56-01 Failure To Have An Administrative Procedure Imple-menting :the General Employee Training in Radiation Protection.
The inspector reviewed procedure 01-S-08-01, Administration of the GGNS Health
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Physics Program for the adequacy and implementation of the General Employee Training (GET) in Health Physics activities and radiation protection to plant employees, contractors'and visitors. The inspector concluded that the procedure was adequate and had no further questions.'
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6.
Radiation Protection Organization and Management The inspectors reviewed the radiation protection organization of the plant and how it relates to the overall plant organization.
The Chemistry and Radiation Control - Superintendent -(Radiation Protection Manager) reports directly to the Assistant. Plant Manager. The Chemistry and Health Physics
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functions are split below the Chemistry and Radiation Control Superintendent i
level. The Radiation Control Supervisor ~is responsible for the radiation
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protection program at the plant, which includes personnel dosimetry, res-piratory protection, and instrument calibration in addition to in plant health physics.
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The Radiation Control Supervisor has' one Health Physics _ Supervisor (first-
line supervisor) who suoervises health physicists (plant designation for i
health physics technicians) performing ' personnel dosimetry, respiratory protection and instrument calibration, as well as in.. plant radiation pro-
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j tection functions.
The plant's health physics staffing plan calls for a
permanent plant staff of thirteen health physicists and one production aide.
i The inspector stated that first line supervision of the health physicists I
should be strengthened by the addition of one or more health physics super-i visors.
These individuals should act -as the first line supervisors of a small group of technicians, determine the health physics requirements for jobs (approve radiation work permits), review survey results and serve as
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the primary contact in the health physics organization for personnel in-
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other departments. The licensee should also consider establishing a super-l'
vising position to be responsible for the support functions, such as
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dosimetry, instrument calibration and respiratory protection programs, in
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order for the remaining supervisors to devote their ~ full attention to the in plant radiation protection program. (82-21-05)
As indicated in the paragraph above, the plant's radiation protection i
organization staffing plan calls for 13 health physicist (technicians) and one production aide. At the time of the inspection, nine health physicist positions were filled with permanent plant staff (see paragraph 8 for a discussion of the qualifications of the plant HP staff).
Three other positions were filled with contract technicians. Although five additional
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contract -technicians are on-site, a licensee representative stated that they would be released prior to start-up.
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.i The inspector stated that the number of technicians appears to be _ inadequate to operate the plant's radiation protection program as a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 7'
days per week basis without excessive overtime. Particularly, since several-of the technicians will be'.used to perform support duties, such as external dosimetry, whole body counting, health physics counting room,- instrument calibration and respiratory protection.
The inspector also stated the number of budgeted technician positions is significantly less than that considered necessary by other commercial power plants of a similar_ size.
The inspector also stated that the plant's health physics organization staffing plan-was in. disagreement with the proposed Technical Specifica-tions.
Technical Specification 6.2.2 calls for_ the radiation control organization to have 15 health physicists (technicians).
Plant management acknowledged the discrepancy _and stated that_they would review the plant's radiation control organization (82-21-06).
7.
. Liquid Radioactive Waste Systems The inspector reviewed the preoperational test results for the following liquid radioactive waste system which are required to be completed as a part of phase I testing:
Equipment Drain System, Procedure SG17-PT01 Reactor Water Cleanup Waste System, Procedure SG17-PT04 Floor Drain System, Procedure SG17-PT03 The test results indicate the system will support plant operations and the system meet acceptance criteria.
During the review of preoperational test, the inspector noted that the licensee had not demonstrated the ability to transfer processed liquid waste from the floor drain or equipment drain system to the discharge basin. A licensee represen'ative stated that this portion of the system was initially to be tested as part of preoperational test of the chemical waste system.
However, when the two phase test program was established, testing of.the
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chemical waste system was moved to phase two. Therefore, testing of the l
ability to discharge to the discharge basin was overlooked.~
The ',icensee had discovered the oversight and was making preparation to test the dis-charge system as a phase I test.
The licensee representative also stated thzt the test would verify that all water being transferred to the basin
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actually reaches the basin. The inspector stated that the results of this i
test would be reviewed during a subsequent inspection (82-21-07).
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Representative Sampling of Gaseous Effluents The inspector reviewed the engineering drawings and design specifications for the isokinetic sample nozzles for the following gaseous waste process and release monitors:
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't SD17-nil 0 Radwaste Building SD17-N111 Containment Vent
~S017-N112 Fuel Handling Area Vent SD17-N113 Turbine Building Vent The ; sample probes appear to be designed 'to provide for isokinetic and representative sampling of the appropriate air streams. The inspector had'
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no further questions.
High Efficiency Filter System The inspector toured the plant and observed the installation of the fol. awing filter systems:
Fuel Handling Area Standby Gas Treatment System Turbine Building Exhaust Tank Vent Filter Train Radwaste Building
Auxiliary Building The inspector observed that the licensee has not loaded the systems with the
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required high efficiency filters (charcoal and/or. HEPA). A licensee repre-
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sentative stated that the loading of filters was postponed until most-l building painting was completed. He further stated that the workorders had-been issued and that installation of filters would begin during the-week of-
March 22, 1981.
In place testing of the filter will be performed by a
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contractor following the filter installations.
The inspector stated that the results of the' filter test will be reviewed during a subsequent inspec-tion (82-21-08).
8.
Health Physics Staff Qualification The qualifications of health physics personnel the licensee considers to be qualified as health physicists were compared to the educational and experi-ence requirements of ANSI N18.1-1971.
ANSI N18.1-1971 is the standard.
committed to in the Grand Gulf technical specifications for personnel
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l selection and qualifications. Qualifications of contract-technicians were
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not reviewed.
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The licensee has six health physicists who they have determined to be
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qualified in accordance with ANSI 18.1-1971.
The qualifications of these six personnel were compared to the qualiff cations required for a technician.
The background of one of these six individuals is in the calibration of-
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health physics instruments. Another individual with prior experience as a
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chemical, biological and radiological warfare monitor and instructor is ANSI l
'18.1-1971 qualified with less than one year onsite experience.
Another individual considered to be qualified has nuclear medicine type experience
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and nearly two years experience at the Grand Gulf facility. Two other i
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qualified individuals have previous U.S. Navy experience as radiological controls monitors.
The balance of their experience is at the Grand Gulf facility. The sixth qualified individual has approximately eight weeks of experience at an operating commerical nuclear reactor.
As described above the ANSI 18.1-1971 qualified personnel have a total of eight weeks of operating commercial nuclear reactor experience. The evalu-ation of applicable experience from the chemical, biological and radiolog-ical warfare field and nuclear medicine field are questionable.
If the balance of the plant health physics staff had sufficient numbers of per-sonnel possessing sufficient experience at commercial operating reactors, the well experienced personnel could give guidance to the lesser experienced personnel. The plant staff should not have to rely on an inexperienced health physics staff for their radiological safety in an operating nuclear power plant.
The inspector stated that the permanent plant health physics staff should not be put in responsible positions until they gain sufficient operating nuclear plant experience to enable them to provide adequate radiological safety evaluations for themselves and other plant employees.
Until such time as the health physics staff is able to provide confidence in their exper'ti se, the licensee should seek well qualified individuals from contractors or well qualified individuals to add to their staff (82-21-09).
A previous inspection identified that the Chemistry and Radiation Control Superintendent (RPM) did not have experience or training at boiling water reactors (BWR). At that time a licensee management representative acknowl-edged the deficiency and stated that the RPM would attend training on the plant systems. This commitment had not been satisfied at the time of this inspection.
The lack of BWR training or experience of the RPM also con-tributes to the low experience level of the plant's HP staff. This training should be completed in a timely manner (82-21-10).
On April 5,1982, a telephone conversation was held between C. K. McCoy, Plant Manager, and members of the plant staff and F. S. Cantrell of the Region II office concerning the qualification and job responsibilities of certain members of your health physics department. Plant management agreed to take the following actions to address these concerns:
a.
Routine surveys shall be performed by health physics personnel who are specifically qualified by direct observation of the HP Supervisor or alternate.* These surveys shall be reviewed by the HP Supervisor or
alternate before the survey results are considered complete (or usuable if performed by other than an ANSI qualified HP).
- HP Supervisor alternate includes the Chemistry / Radiation Control Superintendent, Radiation Control Supervisor, a Staff HP, or a Lead HP.
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" Work Surveys" shall be performed by ANSI qualified HPs who are also specifically qualified by direct observation of the HP Supervisor or alternate. Routine surveys may be used as work surveys after the HP Supervisor's review, and as deemed appropriate by the health physics individual authorizing the RWP.
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Authorization of RWPs (including required controls. etc.) shall be by means of the HP Supervisor or alternate. RWPs inittated in the absence of HP Supervision (Backshift, etc) may be authorized by the senior ANSI qualified HP on shift if it does not involve total projected exposures greater than 2 Man-Rem, extension of authorized administrative exposure limits, or the use of respiratory equipment. RWPs requiring any of the above must be authorized with the concurrence of the On Call Duty HP.
In an additional conversation with a member of the RII staff, the plant's Chemistry and Radiation Control Superintendent stated that it was MP&L's intention to change the proposed Technical Specifications to reflect a total radiation protection technician staff of 19.
This change will be followed up during a future inspection (IFI 50-416/
82-21-05).
9.
Radiation Protection Training for Plant Staff Administrative Procedure 01-S-04-4 titled " General Employee Training Program" requires that all plant personnel, permanent and temporary, shall participate in all phases of the General Employee Training Program.
In order to successfully complete this training an individual must complete an indoctrination in all of the following areas:
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Emergency Plan and Procedures 2.
Site Security Program 3.
General Description of Plant and Facilities 4.
Industrial Safety Program 5.
Quality Assurance Program 6.
Radiation Worker Training including Prenatal Exposure Risks
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Successful completion of this training requires a comprehensive written examination and a minimum passing grade of 70%. Retraining is to be given annually. This program is presented in one full day.
An inspector attended a portion of this training. In addition to lectures, visual aids are employed.
Definition of terms was good, ALARA was ade-quately explained, and radioactive waste reduction was stressed.
In addition to attending a class in progress,.the inspector spent considerable
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time in discussion with the two instructors that presented the health physics training. Both instructors have adequate health physics experience and educational backgrounds and appeared to be very knowledgeable regarding subject matter. Any changes to the curriculum must be approved by the Chemistry And Radiation Control Superintendent.
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10.
Internal Exposure Control Monitoring The internal exposure control pregram was reviewed for adherence to ANSI N343-1978 and Regulatory Guide 8.9.
A whole body counting system is available and has thyroid, lung, and lower torso counting capabilities.
Radiation procedure 08-S-01-32, Bioassay Program states that all personnel who require entry into bioassay areas'must participate in the bioassay program. Bioassay area is defined by the licensee as an airborne radio--
activity area, potential airborne radioactivity area, or any other area where unencapsulated radioactive material is present in a form and quantity such that the area has significant potential for becoming an airborne radioactivity area (generally greater than 50,000 dpm/100 cm ),
These licensee employees must receive a baseline whole body count and, at a minimum, an annual count. A provision is made in this procedure stating that routine bioassay may be waived by the radiation control supervisor if it is determined that routine analyses are not warranted. This waiver must be documented.
In ad'dition to routine whole body counts, urinalysis will be performed at six month intervals or following a period of major work effort. Approxi-mately 10% of plant staff personnel who have entered bioassay areas will participate in this sampling program. Special consideration will be given to these pesonnel:
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Who have worked under a Radiation Work Permit b.
Who have been involved in an incident with the potential for internal contamination c.
Who have been involved in work with a potential for tritium exposure The procedure appears to be adequate with the exception of Section 6.2 headed "Special Bioassays." Part 6.2.1 states bioassays must be performed when nasal swab or nose blow contamination is in excess of 1000 DPM.
The inspector stated that a whole body count should be performed any time activity is detected from nasal swabs or nose blows (82-21-01).
In addition to reviewing the above mentioned procedure the inspector reviewed the following procedures:
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Procedure Number 01-S-08-04, Radiological Respiratory Protection Program 2.
Procedure Number 01-S-04-22, Radiation Worker Training Program
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The procedures that apply to the Internal Monitoring Program involve those procedures that are written for the respiratory protection program as well as what has already been mentioned. With the exception of the comments above, the procedures reviewed appear adequate. The inspector noted that the plant has not issued a procedure that describes the actual air sampling program (82-21-02).
A procedure is in place for maintaining quality assurance for both whole
- cody counting and urinalysis.
Spiking of urine samples and analysis of unknowns in the whole body counter will be done on a routine basis.
11.
Respiratory Protection The respiratory protection program was evaluated on the bases of training program, medical qualification, procedures, equipment, engineering control and maintenance program.
The licensee respiratory program is addressed in procedure 01-S-08-4 titled
" Radiological Respiratory Protection Program." In addition to this proce-dure the following procedures were examined.
01-S-08-05, Radiological Surveys and Surveillances 08-S-01-40, Personnel Respiratory Protection Qualification 08-S-01-41, Radiological Respiratory Protection Device Issue Criteria 08-S-01-42, Maintenance of Radiological Respiratory Equipment 08-S-01-43, Radiological Emergency Response with Respiratory Equipment 08-S-01-44, Use of Radiological Respiratory Equipment 08-S-01-45, Guide for Selection of Radiological Respiratory Equipment 08-5-02-04, Qualitative and Quantitative Fitting of Respiratory Protec-tive Devices" 08-S-02-42, Inspection of Respiratory Protective Devices 08-S-02-44, SCBA Turn-Around Maintenance The procedures available appear to be adequate.
During the course of this inspection it was determined that the responsi-bility of the respiratory protection program is placed with the Station Chemistry and Radiation Control Superintendent.
The program below this l
level is fragmented. At the time of this inspection two technicians were i
responsible for operation of the quantitative respirator fitting and a-third
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technician responsible for procurement, testing, surveillance, and in a general sense, issuance of respirators. Decontamination and sanitizing of used respirators is to be done by a contract laundry in Vicksburg, Mississippi. On site facilities consist of one sink. In the event that the
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contract laundry service cannot meet the required " turn-around time" the inspector stated that onsite facilities appeared to be inadequate.
The inspector further recommended that the overall program be made the respon-sibility of one superviso.
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Respiratory protection training is not given to all radiation workers.
Those individuals who may be expected to use respiratory protective equipment and supervisors who direct workers requiring respirators are given training.
The training consists of lecture, visual aids, and practice in donning and removal of respirators. A written examination is given at the conclusion of this training.
Medical examinations are performed by a licensed physician. Medical certi-fication for all respirator users is required annually.
There appears to be adequate numbers of respirators for the start up phase of this unit. The licensee has purchased appoximately 500 respirators which includes 70 self contained breathing units and 50 rebreather type SCBA's.
Operating experience may show inadequate numbers of filter type respirators but these are usually available from vendors on short notice.
Certain aspects of the respiratory program are not as yet proceduralized such as class "D" air checks, a cascade system, filter testing, etc.
12.
Procedure Review Procedures reviewed were as follows:
Administrative Procedures 01-S-08-1
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Radiation Protection Policy 01-S-08-2
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Exposure and Contamination Control 01-S-08-3
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Personnel Monitoring 01-S-08-5
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Radiation Surveys and Surveillance 01-S-08-6 Radiation Material Control
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01-S-08-8
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ALARA Program Radiation Protection Procedures
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08-S-01-11
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Document Handling l
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Radiological Deficiency Reports
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08-S-01-13
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Task Schedules 08-S-01-14
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Guide for Preparation of Radiation Protection Instructions 08-S-01-16
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Health Physics Form Control 08-S-01-17
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Software Quality Control 08-S-01-20 Designation of and Access to Radiologically Controlled
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08-S-01-21 General Work Rules for Controlled Areas
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08-S-01-24
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Contamination Control 08-S-01-27
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Response to Abnormal Radiation / Radioactivity Levels 08-S-01-30
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Occupational Radiation Exposure Records and Reports 08-S-01-31
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Use of Dosimetry Devices l
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08-S-01-33 Extremity Monitoring
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08-S-01-60
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Radioactive Material Receipt 08-S-01-63
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Radiograph Monitoring 08-S-01-70
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Control of H. P. Instrumentation
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08-S-01-80
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ALARA Implementation 08-S-01-81
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ALARA Assessment Radiation Protection Instructions 08-S-02-12
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General Counting Techniques 08-S-02-20
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Establishing and Posting Controlled Areas 08-S-02-22
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Personnel Decontamination 08-S-02-27
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Radiation / Radioactivity Level Responses 08-S-02-31
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Issuance of TLD Badges and Pocket Dosimeters 08-S-02-33
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Direct Reading Pocket Dosimeters 08-S-02-34
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Lost or Damaged TLD's and Dosimeters 08-S-02-36
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Eberline TLD Issuance 08-S-02-37
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Analysis of TLD's 08-S-02-50
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Dose Rate Surveys 08-S-02-51
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Contamination Surveys 08-S-02-53
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Routine Surveys 08-S-02-60
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Receipt Surveys 08-S-02-62
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New Fuel Receipt Survey 08-S-02-63
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Estimating Activity of Packaged RAM 08-S-02-64
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Leak Testing of Sealed Sources 08-S-02-65 Radioactive Source Inventory
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08-S-07-01
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Operation and Calibration of Eberline Model RM-19 08-S-07-02
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Operation and Calibration of Geiger Counter Model E-120 08-S-07-03
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Operation and Calibration of Pcrtable Ion Chamber Model R0-1 08-S-07-04
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Operation and Calibration of PAC-4S Alpha Survey Meter 08-S-07-05
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Operation and Calibration Instruction for Eberline PS-1 Portable Scales 08-S-07-06
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Operation and Calibration of Ludlum Model-12 08-S-07-07
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Operation and Calibration of Portable Alarm Rate Meter Model 177 08-S-07-08
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Operation of Ludlum Model-15 08-S-07-09
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Operation and Calibration of the LM-2200 Scales Rate
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l Meter Model 177 08-S-07-10
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Operation and Calibration of the LM-2000 Portable Scales 08-S-07-11
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Operation and Calibration of Ludlum Model-3 Survey Instrument 08-S-07-12
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Operation and Calibration of the Model R0-7 Ion Chamber 08-S-07-13
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Operation and Calibration of the Eberline Model R0-2A Ion Chamber 08-S-07-14
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Operation and Calibration of Portable Ion chamber Model R0-3A 08-S-07-15
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Operation of the Eberline PNR-4
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08-S-07-16
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Operation and Calibration of Model-6112 Teletector 08-S-07-17 Operation and Calibration of the Shepherd Model 142-10
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Panoramic Irradiator 08-S-07-18 Operation and Calibration of the IRT Portal Monitor
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08-S-07-21 Operation and Calibration Eberline Model E-530N LM 220
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Scales Rate Meter Model 177 08-S-07-22 Operation of Model 570 Condenser R-Meter
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Operation and Calibration of the Eberline Model 1000B 08-S-07-24
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Gamma Calibrator 08-S-07-23 Operation and Calibration of the WBC-600 Whole Body
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Counter 08-S-07-25
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Operation and Calibration of the Ludlum Model 300 Area Monitor 08-S-07-26 Operation and Calibration of Direct Reading X and Gamma
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Radiation Dosimeters 08-S-07-27 Operation and Use of the Ludlum Model 500 Pulser
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08-S-07-29
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Operation and Calibration of the Tennelec LB-5100 08-S-07-30
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Use of the Area Radiation Monitor (ARM) Portable Calibration Unit, G.E. 846 D959G1 08-S-U7-31
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Operational Use of the 213 DMM Oscilloscope Exposure of Calibration TLD's 08-S-07-32
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08-S-07-33
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Operation and Calibration of the Xetec Model 409A Digital Alarming Dosimeter 08-S-07-34
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Operation and Calibration of the Panasonic UD-702E Manual TLD Reader 08-S-07-40
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Operation and Use of Mini Pulser Model MP-10 The inspectors suggested corrections, changes and additions to several procedures which were acknowledged by the cognizant supervisors.
The inspector had no further questions on the procedures listed above with the exception of two (01-S-08-7 and 08-S-01-64) which had not been finally approved. These will be reviewed at the time of the next inspection.
13.
Solid Radwaste Processing and Disposal The inspector discussed the plans for solid radwaste processing and disposal l
with licensee representatives and was informed that an on-site mobile solidification system was to be on contract from Chem Nuclear Systems, Inc.
(CNSI). The inspector reviewed the approved contract between MP&L and CNSI
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which appeared to be adequate for initial set up and operation of the mobile l
l solidification system. The inspector informed licensee management represen-tatives that prior to installation and operation of this system a safety evaluation must be performed as required by 10 CFR 50.59. The inspector stated that this evaluation would be reviewed at the time of the next inspection (82-21-03).
The licensee still has no burial allocation for disposal of low level radwaste at Chem Nuclear Systems, Inc. (CNSI) burial facility, however, the inspector was informed the licensee has contracted a disposal agree-ment with U. S. Ecology. The licensee plans to ship low level radwaste to V. S. Ecology for disposal until a burial allocation has been negotiated
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with CNSI. The inspector stated that this.would be reviewed at the time of the next inspection (82-21-04).
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14. ALARA Program
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The inspector reviewed Administrative Procedure 01-S-08-8, ALARA Program and -
Radiation Protection procedures 08-S-01-08, ALARA Implementation and 08-S-01-81, ALARA Assessment for the adequacy and implementation of the program.
The inspector stated the program appeared to be adequate and had no further questions.
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15.
Surveillance and Control The inspector reviewed Administrative Procedure 01-S-08-5, Radiation Surveys and. Surveillance and 01-S-08-2, Exposure and Contamination Control and Radiation Protection Procedure 01-S-01-25, Contamination Control and Radia-tion Protection Instructions 08-S-02-50, Dose Rate Surveys, 08-5-02-51,
'l Contamination Surveys and 08-S-02-53, Routine Surveys for the adequacy and implementation _ of the surveillance and control program.
The inspector stated the program appeared to be adequate and had no further questions.
16.
Health Physics Technician Training The inspector reviewed 08-S-01-10 and 01-S-04-9 for a description of the health physicist training program.. Retraining of health physics personnel
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is required on an annual basis. The material required to be covered by the retraining in 01-S-04-9 appears adequate. The inspector had no further questions, t
17.
Preoperational Test Procedure Review
The following preoperational test procedures were reviewed and appeared to be adequate to meet FSAR requirements.
ID17PT01 -
Main Steam Line Radiation Monitor Preoperational Test
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Liquid Process Monitoring Preoperational Test 1D17PT03 -
Venti 11ation Radiation Monitoring System 18.
External Exposure Control The external exposure control program appears adequate. Personnel entering the plant regulated areas are required to wear both pocket dosimeters and
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i TLD's. The licensee currently uses a contractor to supply TLD reading services. The licensee has purchased a TLD reading system and will perform this function on-site at some point in the future.
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In order to control exposure, the licensee has established administrative exposure limits. The daily and weekly exposure limits may be exceeded when work is being performed under an RWP. An exposure extension authorization form must be completed in ord6r for personnel to exceed the weekly exposure limit if their work is not controlled by an RWP.
The licenses has esta-blished additional exposure controls for fertile female employees inorder to ensure that the female employee will not receive ' greater than 500 mrem during the time period when pregnancy may not be evident. The inspector had no further questions concerning the external exposure control program.
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