IR 05000445/1993040

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Insp Repts 50-445/93-40 & 50-446/93-40 on 931025-29.No Violations Noted.Major Areas Inspected:Radiation Protection Activities in Support of Unit 1 Refueling Outage,Planning & Preparation,Training & Qualifications
ML20058C258
Person / Time
Site: Comanche Peak  
Issue date: 11/16/1993
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058C257 List:
References
50-445-93-40, 50-446-93-40, NUDOCS 9312020400
Download: ML20058C258 (7)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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Inspection Report: 50-445/93-40 I

50-446/93-40 l

Licenses: NPF-87 NPF-89 Licensee: TU Electric

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Skyway lower

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400 North Olive Street, L.B. 81

Dallas, Texas 75201 i

Facility Name: Comanche Peak Steam Electric Station, Units 1 and 2

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Inspection At: Glen Rose, Texas

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Inspection Conducted: October 25-29, 1993

Inspector:

L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section j

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Approved:

J B. Mu'rray, Chief ~,'Facili s Inspection Ddte /

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Programs Section Inspection Summary i

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Areas Inspected: Routine, announced inspection of radiatio'n protection activities in support of the Unit I refueling outage (IRF03), planning and preparation, training and qualifications, external exposure controls, internal exposure controls, and controls of radioactive materials and contamination.

Results:

Radiation protection supervisors spent sufficient time in work areas to

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e provide proper oversight of radiological work activities'(Section 2.1).

The radiation protection personnel planned well for the refueling outage e

(Section 2.2).

Contract radiation protection technicians hired to supplement the e

permanent staff met qualification requirements (Section 2.3).

Excellent exposure control programs were maintained (Sections 2.4

and 2.5).

'l 9312O20400 931116

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PDR ADDCM 05000445.

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Improved communications and control of contract technicians were noted

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s (Section 2.4).

Procedural guidance for internal dose calculations needed improvement

(Section 2.6).

Excellent responses to challenging contamination control situations were

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noted (Section 2.7).

There were a low number of personnel skin contamination events e

(Section 2.7).

Summary of Inspection Findinos:

Inspection Followup Item 446/9328-01 was closed (Section 3).

e Attachment:

Attachment - Persons Contacted and Exit Meeting

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-3-DETAILS 1 PLANT STATUS During the inspection, Unit I was conducting refueling outage, IRF03. The outage started on October 6, 1993, and was originally planned for 56 days.

Unit 2 was operating at 100 percent power.

2 OCCUPATION RADIATION EXPOSURE CONTROL DURING EXTENDED OUTAGES (83729)

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The licensee's exposure control program was inspected to determine compliance with Technical Specifications 6.8, 6.11, 6.12 and the requirements of the new 10 CFR Part 20, and agreement with the commitments of Chapter 12 of the Final Safety Analysis Report.

2.1 Audits and Appraisals The inspector noted that the radiation protection organization continued its program of supervisory tours of the radiological controlled area and the containment building during the outage. Supervisor observations were documented and forwarded to the radiation protection manager for review and action, if warranted. The inspector reviewed computer lists of containment entries and confirmed that supervisors and ALARA personnel made routine reviews of work in progress.

The inspector reviewed radiological occurrence reports and did not identify recurring problems.

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2.2 Plannina and Preparation The licensee implemented an effective dose reduction initiative involving the injection of hydrogen peroxide into the reactor coolant system during reactor cool down that resulted in crud burst with the removal of about 1900 curies of cobalt-58. The licensee estimated that an overall exposure reduction of about 20-25 person-rem involving outage activities was achieved with this procedure.

During the outage, the licensee hired 50 senior radiation protection technicians and 15 junior radiation protection technicians to supplement the permanent plant staff. The inspector observed work conditions and determined that the supplemental staffing was sufficient.

Individuals working on the reactor coolant pumps and vendor personnel taking part in the installation of eddy current testing equipment in the steam generators were given mock-up training.

The inspector determined that the licensee had appropriate supplies of protective clothing, temporary shielding, calibrated instruments, and air sampling equipment.

The inspector attended turnover meetings for managers and supervisors and determined that communications were goo.

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ALARA personnel had completed reviews of work packages prior to the start of the outage. ALARA work packages were complete and incorporated dose reduction techniques.

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2.3 Trainina and Oualifications The inspector reviewed selected resumes of contract radiation protection personnel and determined that they met the necessary qualification

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requirements.

2.4 External Exposure Control The inspector confirmed that radiation exposure information was updated daily.

Doses were reviewed by supervisors in the radiation protection department and

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presented to the managers of the respective departments for review. The dose

accrual for outage work was reviewed daily by ALARA personnel and compared

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with the projected dose to date to determine if additional precautions were necessary.

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During tours of the radiological controlled area and the containment building, the inspector observed radiation protection personnel's support of work l

activities, radiation workers' compliance with radiation work permit

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instructions, release of tools and materials -from contaminated areas, and area-

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posting and controls.

The inspector also preformed independent radiation

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measurements. No problems were identified.

During these observations, the inspector noted that there were no indications

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of the communication failures identified during the previous outage

inspection.

In order to maintain a better coordination of job coverage, the main radiation protection control point was located near the entrance of

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containment. All workers entering the containment building were. required to i

stop and review their work assignments with radiation protection personnel.

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Thus far, this action has prevented a recurrence of confusion among radiation protection personnel as to who was responsible for providing job coverage for various work items. Radiation protection support was drawn from a pt,ol of i

technicians stationed at the control point.

Inside containment,. roving

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radiation protection technicians, who were usually permanent plant employees, j

provided assistance and oversight.

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The inspector attended a prejob briefing and noted that the radiation l

protection department was represented by members of both the surveillance and l

control group and the ALARA group. During the previous inspection, this was

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not necessarily the case and the inspector noted instances in.which

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disagreements arose concerning the precautions necessary for certain work'

activities. During this inspection, there was better coordination between the groups. The quality of the briefing was good.

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The licensee's exposure goal for the outage was 145 person-rems. After l

23 days, the licensee had recorded approximately 40 person-rems.

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The inspector verified that the licensee implemented sufficient air sampling through the use of portable samplers and real-time air monitors.

In addition to the regular portable ventilation units, the radiation protection department used six, 250-cubic-feet-per-minute units. Their small size made it possible i

for them to be used in more areas.

Since the start of the outages, only two respirators had been issued for radiological protection purposes. No significant intakes have been l

identified.

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The inspector reviewed internal dose calculation procedures with dosimetry personnel. The inspector discussed several hypothetical sample situations and identified that Procedure RPI-507, " Internal Dose Calculation," did not l

provide sufficient guidance to ensure that the dosimetry representative could determ.ae an internal dose resulting from the ingestion of radionuclides. The procedure made no distinction between Annual Limits on Intake for ingestion and those for inhalation. Consequently, the individual calculating the internal dose did not determine the correct answer for one of the sample problems. Licensee representatives stated that they would review the procedure and provide increased guidance.

j The dosimetry supervisor stated that the computer software intended to satisfy the internal dose calculation requirements of the new 10 CFR Part 20 never functioned correctly; therefore, it was not available as either a primary or secondary means of dose calculation.

2.6 Control of Radicactive Materials and Contamination. Surveys, and l

Monitoring l

The inspector observed access control procedures, the surveying and releasing

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of materials from the radiological controlled area, and the use of portal monitors, personnel contamination monitors, and friskers by workers. No problems were identified in this area.

At the start of the inspection, the containment building had been decontaminated to a low enough level to allow general personnel entry in i

i street clothes. On October 26, 1993, two incidents resulted in approximately 24,000 gallons of contaminated water being spilled on the 808-foot level.

After decontamination efforts, radiation protection personnel found that contamination continued to leech from the floor surface. Consequently,

sheeting was placed on parts of the 808-foot level to allow access to the tool

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storage area by workers in street clothing and the majority of the 808-foot level was controlled as a contaminated area. The other levels of the containment building were not affected. The radiation protection department's responses to the two incidents were excellent. The details of the responses are discussed in NRC Inspection Report 50-445/93-41; 50-446/93-41.

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l Radiation detection instruments cbserved in use were within their calibration l

intervals and had been response checked.

Selected survey records contained the necessary information, and were reviewed by a supervisor.

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-6-To reduce the amount of contaminated trash, the licensee switched from Herculite to launderable cloth sheeting for selected applications.

By the end of the inspection, the licensee had recorded nine skin contamination events.

2.7 Conclusions

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Radiation protection supervisors spent sufficient time in work areas to l

provide proper oversight of work activities.

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The radiation protection personnel planned well for the refueling outage.

i Contract radiation protection technicians hired to supplement the permanent staff met qualification requirements.

j Excellent exposure control programs were maintained.

Improved communications and control of contract technicians were noted.

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Procedural guidance for internal dose calculations needed improvement.

Excellent responses to cha'

ngit t contamination control situations were noted. There were a low number personnel skin contaminations.

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3 FOLLOWUP (92701)

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(Closed)

Inspection Follewup Item 446/9328-01:

Bioshield Surveys on Unit 2 After studying NRC Information Notice 93-39, " Radiation Beams from Power Reactor Biological Shields," the licensee committed to performing more extensive surveys of the bioshield. Surveys were made in both units of the

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entire bioshield walls that could be reached from the floor with extendable survey instruments. Copies of the completed surveys were provided to the

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inspector for review. Additional precautions were placed in Procedure STA-620, " Containment Entry," warning workers that additional surveys are necessary if entry into overhead areas was required. The additional surveys did not identify dose rates that exceeded the zone designations in the Final Safety Analysis Repor.

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I ATTACMENT

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1 PERSONS CONTACTED j

1.1 Licensee Personnel A. M. Barnette, Staff Health Physicist

  • M. R. Blevins, Director, Nuclear Overview

S. E. Bradley, Radiation Protection Supervisor

  • W. J. Cahill, Jr., Group Vice President l
  • R. S. Carr, Dosimetry Supervisor i

l J. R. Curtis, Radiation Protection Supervisor i

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  • R. E. Fishencord, Radioactive Materials Control Supervisor

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  • N. S. Harris, Regulatory Compliance Engineer

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  • D. C. Kay, Radiation Protection _ Supervisor t
  • J. J. Kelley, Vice President, Nuclear Engineering and Support
  • D. McAfee, Manager, Quality Assurance

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  • R. J. Prince, Radiation Protection Manager _

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  • C. L. Terry, Vice President, Nuclear Operations l.2 NRC Personnel

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  • T. T.ais, Project Engineer

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  • L. A. Yandell, Chief Project Section B

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  • Denotes personnel that attended the exit meeting.

In addition to the personnel listed, the inspector contacted other personnel during this

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inspection period.

I 2 EXIT MIETING An exit meeting was conducted on November 3, 1993. 'The exit meeting was

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delayed to coincide with the exit meeting for NRC Inspection 50-445/93-41, i

50-446/93-41. During this meeting, the inspector reviewed the scope and

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findings of the report. The licensee did not express a~ position on the

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inspection findings documented in this report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector.

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