IR 05000445/1999006

Insp Repts 50-445/99-06 & 50-446/99-06 on 990329-0402.No Violations Noted.Major Areas Inspected:Planning & Preparation,External Exposure Controls & Quality Assurance of Radiation Protection Activities

ML20206F578
Person / Time
Site:	Comanche Peak
Issue date:	04/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20206F575	List: IR 05000445/1999006 ML20206F571
References
50-445-99-06, 50-445-99-6, 50-446-99-06, 50-446-99-6, NUDOCS 9905060177
Download: ML20206F578 (15)

Text

E

.

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l Docket Nos.: 50-445 l 50-446

)

License Nos.: NPF-87 NPF-89 Report No.: 50-445/99-06 50-446/99-06 Licensee: TU Electric Facility: Comanche Peak Steam Electric Station, Units 1 and 2 Location: FM-56 Glen Rose, Texas Dates: March 29 through April 2,1999 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch l

Accompanied By: James S. Dodson, Radiation Specialist Plant Support Branch Approved By: Gail M. Good, Chief Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information 9905060177 990430 PDR G ADOCK 05000445 PDR

.

.

-2-

. EXECUTIVE SUMMARY -

Comanche Peak Steam Electric Station, Units 1 and 2 NRC Inspection Report No. 50 445/99-06; 50 446/99-06

~ This announced inspection focused on the radiation protection program during Unit 2 refueling outage activities (2RF04).' Areas reviewed included: planning and preparation; external exposure controls; internal exposure controls; controls of radioactive material and contamination, surveying and monitoring; the program to maintain occupational exposure as i low as is reasonably achievable (ALARA); contract radiation protection technician training and qualifications; and quality assurance of radiation protection activitie Plant Sucoqd -

.

The ALARA program was acceptably irnplemented. ALARA considerations were properly incorporated into the outage schedule and were generally well implemente Radiological work packages were effectively planned, and ALARA personnel were involved during the implementation stage. Lessons learned from past similar work were incorporated into the radiological work packages. Station and task activity doses were tracked and trended by the ALARA staff. The Unit 2 refueling outage dose as of March 31,1999, was approximately 36 person rem. Effective chemistry shutdown plans and controls were implemented. Appropriate radiation protection instrumentation, protective clothing, and consumable supplies were available to support radiological work (Sections R1.1 and R1.5).

i in general, the external exposure control program was effectively implemented. High and locked high radiation areas were properly controlled and posted. Radiation workers wore dosimetry properly and knew the correct response to electronic dosimeter alarms (Section R1.2).

.

On two occasions, radiation workers, in a high traffic. area of containment, did not respond to continuous air monitor audible and visual alert / fault alarms in accordance with management expectations (Section R1.2).

A violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne

- concentrations and potential radiological hazards that could be present in the spent fuel pool work area on the 860-foot elevation of the fuel building. This is the first example of a Severity Level IV violation that is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's

- corrective action program as SMART Form SMF-1999-000808-00 (Section R1.2).

.

The internal exposure controls program was acceptably implemented. In general, continuous air monitors and high efficiency particul ate air filter ventilation units were used correctly to monitor and limit airborne exposures. The total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA) evaluations reviewed were acceptable for respiratory protection equipment use determination (Section R1.3).

-

l I

i

.

.3-

A violation of 10 CFR 20.1501(a) was identifie'd for failure to ensure the radioactive airborne quality from Steam Generators 1 and 4 portable ventilation units. This is the second example of a Severity Level IV violation that is being treated as a non-cited

. violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000808-00 (Section R1.3).

. .

l

. Radiation workers used the personnel and equipment contamination monitors in -

accordance with station procedures. Minor personnel contamination incidents and -

events were properly handled. ' Personnel stationed at the radiologically controlled area exit provided appropriate guidance to station workers who alarmad the personnel and equipment contamination monitors. Good controls were in place to prevent the spread of radioactive contamination. Portable radiation detection survey instrumentation was calibrated and source response checked in accordance with station procedures (Section R1.4).

.

A violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne concentrations and potential radiological hazards that could be present inside Steam l Generator 3. This is the third example of a Severity Level IV violation that is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000818-00 (Section R1.4).

. : Radiation protection personnel failed to evaluate radiation levels and post hot spots in

'

accordance with expectations (Section R1.4).

'.~ A violation of Technical Specification 6.8.1 was identified for failure to perform complete radiological exposure evaluations on three separate temporary shielding packages as -

required by a radiation protection program procedure. This Severity Level IV violation is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF 1999-000813-00 (Section R1.5).

. The contract radiation protection technician training program was effectively implemented. Radiation protection management was involved in the development of the contract radiation protection technician training program and quahfication task topic Qualification tasks included all the tasks assigned to contract senior radiation protection technicians. Contract senior radiation protection technicians met the technical experience requirement of Technical Specification 6.3.1.b and the training requirements

. delineated in station procedures (Section RS).

. The radiological SMART Forms reviewed were closed in a timely manner. No problems

.or negative trends were identified from the review of radiological SMART Forms written since November 1,1998; however, the inspectors noted that the licensee had not documented in Radiological SMART Forms survey problems similar to those identified by the NRC during this inspection (Section R7).

'

-

.

l l

Recort Details Summarv of Plant Status During the inspection, Unit 1 operated at 100 percent power, and Unit 2 was in the second week of Refueling Outage 2RF0 IV. Plant Support l

R1 Radiological Protection and Chemistry Controls R Plannina and Preoaration Insoection Scope (83750)

Radiation protection personnel involved in planning and preparation for the 2RF04 refueling outage were interviewed. The following items were reviewed:

• ALARA Job planning

ALARA considerations  !

• Incorporation of lessons learned from similar work l

l

Supplies of radiation protection instrumentation, protective clothing, and l consumable items i i Observations and Findinas  !

$

On March 30,1999, the inspectors attended the pre-job ALARA briefing for the transfer !

of five spent filters to a shielded high integrity container. The highest dose rate on l contact with the filter was 50 rems per hour. The briefing was conducted in a i professional manner and addressed task sequences, radiological conditions, i radiological hazards, contingencies derived from past spent filter transfers, precautions, l and postings. Following the briefing, the inspectors observed the transfer of the five spent filters. The task was completed in accordance with station procedures and ,,

~ Radiation Work Permit 99-2500, Task 1. The job planning, ALARA considerations, incorporation of lessons learned from similar work, and radiation protection job coverage were appropriate for the observed work activit On March 31,1999, the inspectors attended the pre. job ALARA briefing for the removal of Steam Generators 3 and 4 manways and diaphragms. The briefing was conducted in a professional manner and addressed: task sequences, ALARA work initiatives within the work sequence, radiological conditions, radiological hazards, radiological hold points, contingencies derived from past outages and industry experience, precautions, l

!

,

g

.

s

. and postings. The work package was well planned, and lessons learned were incorporated into job plannin Other radiological work package tasks were well planned, and ALARA personnel were involved during the outage planning stage. ALARA based initiatives were incorporated into the outage schedule. The following initiatives were included: steam generator secondary side drain down to maximize the shielding effect of the water, installation and

._ use of job. specific remote cameras with communications, use of remote wireless; ,

transmitting dosimetry, and chemistry shutdown controls to effectively reduce the source i ter The inspectors determined from field observations that there was appropriate radiation protection instrumentation, protective clothing, and consumable supplies to support radiological wor Conclusions ALARA considerations were properly incorporated into the outage schedule and were generally well implemented. Radiological work packages were effectively planned, and ALARA personnel were involved during the implementation stage. Lessons learned 4 from past similar work were incorporated into the radiological work package l Appropriate radiation protection instrumentation, protective clothing, and consumable

- supplies were available to support radiological wor R1.2 Extemal Exposure Controls Insoection Scope (83750)

Radiation protection personnel involved in the external exposure control program were interviewed. The inspectors conducted frequent tours of the radiologically controlled areas, including the reactor containment building. _The following were reviewed:

• Control of high and locked high radiation areas

~* General access permits and radiation work permits -

• Job coverage by radiation protection personnel

• Personnel dosimetry use Observations and Findinas -

The inspectors conducted several tours of the radiologically controlled areas and observed that high radiation areas (where the dose rates were greater than 100 but less than 1000 millirems in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters) and locked high radiation areas (areas where the dose rates were greater than 1000 millirems per hour at 30 centimeters but less than 500 rads in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 1 meter) were controlled and posted in accordance with station procedures and regulatory requirement The inspector's reviewed a random selection of general access permits and radiation work permits. In general, radiation work permits and general access permits were

.

t

.. written in a clear, consistent manner and provided radiation workers with the appropriate I controls and radiological information to safely accomplish assigned tasks. However, during a tour of the fuel building, the inspectors observed that the continuous air monitor was located in the dress-out room, adjacent to the spent fuel pool work area on the 860-foot elevation. The general access permit, GAP 99-06, Task 1, Revision 0, required, in part, that airborne sampling be performed during refuel bridge activities involving spent fuel or irradiated components. Since spent fuel movement was in progress, the inspectors notified radiation protection personnel of the continuous air monitor location. The inspectors were informed that this was not the normal monitoring location.' The licensee relocated the continuous air monitor to the normal monitoring location adjacent to the spent fuel pool. There was no evaluation to justify the as-found locatio CFR 20.1501(a), states, in part, that each licensee shall make or cause to be made, surveys that are reasonable under the circumstances to evaluate concentrations or quantities of radioactive material and the potential radiological hazards that could be present. The failure to evaluate the airborne concentrations and potential radiological j hazards that could be present in the spent fuel pool work area on the 860-foot elevation !

of the fuel building was identified as the first example of a 10 CFR 20.1501(a) violation and is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000808-00 (50-445; 446/9906-01).

During tours of the radiologically controlled area, the inspectors noted that radiation j protection job coverage was appropriate for radiological work observed. Radiation I workers observed wore dosimetry properly. When questioned, workers knew to leave the work area and contact radiation protection personnel if their electronic dosimeter alarmed. However, during a tour of the 808-foot elevation of the reactor containment ;

building on March 29,1999, the inspectors observed a continuous air monitor in a visual . ;

and audible fault alarm condition. This monitor was located in a high traffic are Workers in that area did not respond to the alert / fault alarm. Subsequently, the

'

. Inspectors notified the radiation protection staff, and the fault alarm was cleared by providing an alternate power source. When the monitor began the start up sequence, it went into visual and audible alarm. Again, workers in the area did not respond to the alert / fault alarm. This observation was discussed with radiation protection management

. and was promptly addressed with the licensee staff. On March 31,1999, inspectors observed another continuous air monitor audible and visual alarm in the same locatio This alarm was immediately acknowledged and addressed by radiation protection staf Conclusions :

In general, the external exposure control program was effectively implemented. High

.and locked high radiation areas were properly controlled and posted. Radiation workers wore dosimetry properly and knew the correct response to electronic dosimeter alarm Radiation workers, in a high traffic area of containment, did not respond to continuous air monitor audible and visual alert / fault alarms in accordance with management expectation m,J

.

A violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne concentrations and potential radiological hazards that could be present in the spent fuel pool work area on the 860-foot elevation of the fuel building. This is the first example of ,

a Severity Level IV violation that is being treated as a 'non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's

corrective action program as SMART Form SMF-1999-000808-0 R1.3 Internal Exoosure Controls Insoection Scope (83750)

Selected radiation protection personnel involved with the internal exposure control program were interviewed. Additionally, several tours of the radiologically controlled areas were performed. The following programs were reviewed:

• Air monitoring

• Respiratory protection Observations and Findinas

- in general, continuous air monitors and high efficiency particulate air filter ventilation units were used correctly throughout the radiologically controlled area to monitor and i limit radiation workers' airborne exposures. However, the inspectors observed on the 905-foot elevation of the reactor containment building, that there was no air sampler or continuous air monitor placed to ensure that the radioactive airborne quality of the exhaust from the portable ventilation equipment was monitored from Steam Generators 1 and 4. Additionally, the portable ventilation equipment exhaust was not directed to the plant ventilation syste Section 6.4.6 of Procedure RPI 612, " Steam Generator Work Control," Revision 6, stated, in part,-" perform airborne radioactivity surveys to ensure that the air quality at the exhaust of the portable ventilation equipment is monitored if the exhaust is not directed to the plant ventilation system. A continuous air monitor may be used for continuous j monitoring in lieu of performing airborne surveys at the portable ventilation exhausts."

'

The failure to perform airborne radioactivity surveys, use a continuous air monitor, or direct the exhaust from the portable ventilation equipment to the plant ventilation system ;

to ensure the radioactive airborne quality from Steam Generators 1 and 4 portable i ventilation units was identified as a second example of a 10 CFR 20.1501(a) violation l and is being treated as a non cited violation, consistent with Appendix C of the NRC i Enforcement Policy. This violation was placed in the licensee's corrective action

-

program as SMART Form SMF-1999-000808-00 (50-445;446/9906-01). j

. The inspectors reviewed a random selection of the TEDE/ALARA evaluations for various i tasks which involved the use of respiratory protection equipment. The inspectors concluded that these evaluations were acceptable.

e

e

.

8- Conclusions

- The internal exposure controls program was acceptably implemented. In general, continuous air monitors and high efficiency particulate air filter ventilation units were used correctly to monitor and limit airborne exposures. The TEDE/ALARA evaluations reviewed were acceptable for respiratory protection equipment use determinatio A violation of 10 CFR 20.1501(a) was identified for failure to ensure the radioactive airbome quality from Steam Generators 1 and 4 portable ventilation units. This is the -

second example of a Severity Level IV violation that is being treated as a non-cited - (

violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was i placed in the licensee's corrective action program as SMART Form SMF-1999-000808- )

0 {

l R1.4 Control of Radioactive Materials and Contamination: Survevina and Monitorina )

I Inspection Scope (83750) '

Frequent tours of the radiologically controlled areas were conducted by the inspector Areas reviewed included: .

• Radiologically controlled area controls l

=' Control of radioactive material I

=

Adequacy of the surveys necessary to assess personnel exposure

=

Housekeeping within the radiologically controlled area l

. Observations and Findinas i

Observations at the radiologically controlled area egress point revealed that workers ;

used the personnel and equipment contamination monitors in accordance with station -

'

procedures. Personnel stationed at the radiologically controlled area exit provided appropriate and timely guldance to workers who alarmed the monitors. Personnel l contamination incidents and events were properly handle The licensee provided good controis to prevent the spread of radioactive contaminatio ' During tours of the radiologically controlled area, the inspectors noted that radioactive l material containers observed were generally labeled, posted, and controlled in accordance with station procedures and regulatory requirernents. However, a contaminated trash drum was observed partially in/out of a contaminated area. The radiation protection staff was notified and promptly ensured that the drum was positioned fully inside the contaminated area. Contaminated areas were clearly identified and posted. Step-off pads were placed at the exits from contaminated area The inspectors observed radiation workers exit contaminated areas. In general, personnel used proper radiation protection practices during the removal of potentially contaminated protective clothin .

%

. . During a tour of the reactor containment building, the inspectors observed the removal of manways and diaphrams from Steam Generators 3 and 4.' Radiation and contamination surveys were performed inside the steam generators prior to installation of the eddy current testing equipment. The inspectors reviewed the radiological survey documentation and noted that an airborne radioactivity survey was performed in Steam ,

Generator 4, but not inside Steam Generator ~

10 CFR 20.1501(a), states, in part, that each licensee shall make or cause to be made, surveys that are reasonable under the circumstances to evaluate concentrations or ~

quantities of radioactive material and the potential radiological hazards that could be -

present. The failure to evaluate the airborne concentrations and potential radiological hazards that could be present inside Steam Generator 3 was identified as a third example of a 10 CFR 20.1501(a) violation that is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000808-00 (50-445;446/9906-01). j independent radiological survey measurements performed by the inspectors during radiologically controlled area tours generally confirmed that area radiological postings I were in compliance with station procedures and regulatory requirements. Section 3.15 and Attachment 1 of Procedure RPI-602," Radiological Surveillance and Posting," ,

Revision 17, stated, in part, that if the radiation levels from a 30 centimeter dose rate I are 5 times the average background general area dose rate and the contact dose rate is greater than or equal to 100 millirems per hour (mR/hr) the location should be posted as a hot spot. During a tour of the 808-fcot elevation of the reactor containment building on

'

March 29,1999, the inspectors identified two locations on the reactor cavity drain line at Valvo 2-SF-0027 and another downstream of that valve, where radiation levels met the conditions for hot spot identification and should have been posted in accordance with station radiation protection program procedure expectation Radiation Survey 99-03-5468, conducted on March 20,1999, indicated a maximum contact dose rate on the reactor cavity drain line of 100 mR/hr on contact and 30 mR/hr at 30 centimeters. On March 29,1999, radiation protection personnel were requested to accompany the inspectors to this area to perform a confirmation radiation survey. The licensee's radiation survey (99-03-2221) indicated a maximum dose rate at Valve 2-SF-0027 of 240 mR/hr o.n contact and 15 mR/hr at 30 centimeters and, at the open end of the drain line, a contact dose rate of 180 mR/hr and 12 mR/hr at 30 centimeters. This observation was discussed with radiation protection management, and the hot spots were posted in accordance with procedural expectation Housekeeping throughout the radiologically controlled areas was generally good. The

, inspectors noted that areas were free of debris, i

- All portable radiation protection survey instruments observed throughout the station were calibrated and source response checked in accordance with station procedure ;

. _ - -

'

l

-10-

-

i Conclusions Radiation workers used the personnel and equipment contamination monitors in accordance with station procedures. Minor personnel contamination incidents and events were properly handled. Personnel stationed at the radiologically controlled area exit provided appropriate guidance to station workers who alarmed the personnel and i equipment contamination monitors. Good controls were in place to prevent the spread {

of radioactive contamination. Portable radiation detection sun /ey instrumentation was !

calibrated and source response checked in accordance with station procedure {

Radiation protection personnel failed to evaluate radiation levels and post hot spots in !

accordance with expectation I

A violation of 10 CFR 20.1501(a) was identified for failure to evaluate the airborne concentrations and potential radiological hazards that could be present inside Steam Generator 3. This is a third example of a Severity Level IV violation that is being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Polic This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000818-0 R1.5 Maintainina Occuoational Exoosure As Low As is Reasonably Achievable (ALARA) Insoection Scope (83750)

Radiation protection personnelinvolved with the ALARA program were interviewed. The following programs were reviewed:

• Exposure goal establishment and status

• Temporary shielding

. Chemistry controls Observations and Findinos ,

- The 2RF04 refueling outage dose goal was established at 190 person-rem. The inspectors noted that this outage dose goal was higher than the outage dose goal of 140 person-rem established for the previous Unit 2 refueling outage. The licensee attributed the difference to additional work activities planned for this refueling outag From discussions with the licensee, the inspectors determined that the total current outage dose goal was established by a summation of dose estimates from each department, based on past performance and experience, and the ALARA committee members were involved in the development of the annual dose goals, outage dose goals, and exposure reduction initiatives. The inspectors noted that as of March 31, 1999, the Unit 2 refueling outage projected dose was 75 person-rem and the cumulative dose was approximately 36 person-rem. This was attributed, in part, to excellent shutdown chemistry control and the removal of radioactive cobalt and iron source term Station and high exposure task activity doses were tracked and trended by the ALARA staff, and dose status reports were distributed daily to station department ~

p

'

.

>

-11-

. The inspectors reviewed a random selection of temporary shielding packages. During this review, the inspectors identified three temporary shielding packages which did not contain person-rem exposure estimates in the evaluation process as required by i Procedure RPI-608, " Control of Temporary Shielding," Revision 6. Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A, of ' l Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(9) of Appendix A of this Regulatory Guide includes procedures for implementation of the ALARA progra Section 6.1.3 of Procedure RPl-608, " Control of Temporary Shielding," Revision 6,

.

stated, in part, "pedorm an evaluation considering person-rem exposure estimate for the'

task if no shielding was used. Compare this value with the exposure estimate for the task, if shielding was used plus the exposure estimate for the installation and removal of the proposed temporary shielding." The failure to perform these radiological exposure evaluations as required by procedure was identified as a violation of Technical Specification 6.8.1. This Severity Level IV violation is being treated as a non-cited !

violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was ;

placed in the licensee's corrective action program as SMART Form SMF-1999-000813-

- 00 (50-445;446/9906-02). I During discussions with chemistry personnel, the inspectors determined that management support for shutdown chemistry controls was excellent. The shutdown chemistry controls were effective in removing approximately 2,820 curies of cobalt-58 from the reactor coolant syste Conclusions An acceptable ALARA program was implemented. Station and task activity doses were tracked and trended by the ALARA staff. The Unit 2 refueling outage dose as of March 31,1999, was approximately 36 person-rem.' Effective chemistry shutdown plans and controls were implemente A violation of Technical Specification 6.8.1 was identified for failure to perform complete ,

'

radiological exposure evaluations on three separate temporary shielding packages as required by a radiation protection program procedure. This Severity Level IV violation is

' being treated as a non-cited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as SMART Form SMF-1999-000813-0 _

r

.-

..

-12 ,

?

!

'

R5L - Staff Training and Qualification ln Radiological Protection and Chemistry  ! Insoection Scooe (83750)

Personnel involved with contract radiation protection technician selection, qualification, !

and training were interviewed.- The following items were reviewed:

. Resumes of contract radiation protection technicians

Contract radiation protection training prograrn

~ Observations and Findinas ~

The inspectors reviewed the qualifications and training of randomly selected contract

- senior radiation protection technicians. Training material for contract radiation protection technicians included site and industry lessons learned. Radiation protection management was involved in developing the qualification task topics. All contract i radiation protection technicians were tested on site-specific information and station radiation protection procedures. The Northeast Utilities examination was used to assess the basic radiation protection technical knowledge of the contract radiation protection

' technicians. Performance demonstrations of knowledge, skills, and abilities were also required. Qualification certifications were signed by a radiation protection supervisor and the radiation protection manager, prior to technicians being assigned radiation protection tasks. The inspectors concluded that th'ese contract senior radiation protection technicians met the technical experience requirement of Technical Specification _6.3.1.b (2 years of radiation protection experience) and the training requirements delineated in station procedure Conclusions -

The contract radiation protection technician training program was effectively

.

implemented. Radiation protection management was involved in the development of the contract radiation protection technician training program and qualification task topic Qualification tasks included all the tasks assigned to contract senior radiation protection technicians. . Contract senior radiation protection technicians met the technical experience requirement of Technical Specification 6.3.1.b and the training requirements delineated in station procedure R7 - Quality Assurance in Radiological Protection and Chemistry Activities

- The inspectors reviewed a random selection of SMART Forms written since

~ November 1,1998. The inspectors noted that the licensee had not identified any similar survey problems as discussed in the inspection report. Generally, the licensee identified and documented radiological issues which provided management with an overview to .

assess the radiation protection program. The radiological SMART Forms reviewed were

- closed in a timely manner. No problems or negative trends were identifie ,

I

.

-13-V. Manaaement Meetinas j X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting on April 2,1999. A follow-up discussion of the inspection results was 1 conducted with members of the licensee staff on April 28,1999. The licensee acknowledged the findings presented. No proprietary information was identifie {

i

t I

I i

i I

l

.

%

ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee C.L. Terry, Senior Vice President and Principal Nuclear Officer M. Blevins, Vice President, Nuclear Operations D. Davis, Nuclear Overview Manager J. Curtis, Radiation Protection Manager R. Carr, Radiation Protection Supervisor S. Bradley, Radiation Protection Supervisor D. Kay, Radiation Protection Supervisor D. O' Conner, Radiation Protection Health Physicist J. Blaikle, Radiation Protection Health Physicist A. Barnette, Radiation Protection Supervisor R. Fishencord, Radiation Protection Supervisor T. Hope, Regulatory Affairs Manager C. Wilkerson, Senior Licensing Engineer NRC A. Gody, Jr., Senior Resident inspector INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED CLOSED AND DISCUSSED Opened and Closed 50-445;446/9906-01 NCV Failure to perform radiological surveys 50-445;446/9906-02 NCV Failure to perform complete radiological evaluations on temporary shielding packages

r

.

.

-2-LIST OF DOCUMENTS REVIEWED Procedures TRA 301 Radiation Protection Training, Revision 12 STA-609 Reactor Coolant Water Chemistry Control Program, Revision 5 STA-650 General Health Physics Plan, Revision 5 STA-651 ALARA Program, Revision 8 STA-652 Radioactive Material Control, Revision 7 STA 656 Radiation Work Control, Revision 10 STA-659 Radiation Protection Program, Revision 8 STA-660 Control of High Radiation Areas, Revision 7 RPl 213 Survey and Release of Material and Personnel, Revision 7 RPI-602 Radiological Surveillance and Posting, Revision 17 RPI-606 Radiation Work and General Access Permits, Revision 9 RPI-607 ALARA Planning, Revision 4 RPI-612 Steam Generator Work Control, Revision 6 RPI-902 Issue and Control of Respiratory Protection Equipment, Revision 9 Other SMART Form summary listing for November 1998 through March 1999 Radiation Protection Contractor Technician Training Guidelines Radiation Protection Conduct of Operations, Revision 5 Radiation Protection Contractor Technician Training Material Radiation Protection Contractor Technician Site Specific Procedure Exams Radiation Protection Contractor Technician Qualification Certification Sheets Radiation Protection Contractor Technician Resumes