IR 05000456/1997017

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Insp Repts 50-456/97-17 & 50-457/97-17 on 971006-22. Violations Noted.Major Areas Inspected:Plant Support & Radiation Protection Program
ML20199G140
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 11/17/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199G091 List:
References
50-456-97-17, 50-457-97-17, NUDOCS 9711250105
Download: ML20199G140 (15)


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r U.S. NUCLEAR REGULATORY CCF/. MISSION ,

REGION 111 Docket Nos: 50-456;50-457 License Nos: NPF-72; NPF-77 Report Nos: 50-456/97017(DRS); 50-457/97017(DRS)

Licensee: Commonwealth Edison (Comed)

Facility: Braldwood Nuclear Power Station Units 1 and 2 Location: RR #1, Box 79 Braceville,IL 60407 Dates: October 6-22,1997 Inspectors: S. Orth, Senior Radiation Specialist D. Hart, Radiation Spedist Approved by: G. L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9711250105 971117 PDR ADOCK 05000456 0 PINT _

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, EXECUTIVE SUMMARY Braldwood Nuclear Plant, Units 1 & 2 NRC inspection Report 50-456/97017; 50-457/97017 This announced inspection included aspects of licensee plant support performance and, specifically, an evaluation of effectiveness of the radiation protection program. Two violations were identified concerning the inadequate control of a high radiation area and an individual who failed to properly follow radiation protection procedure ElaQLSupport

. The radiation protection (RP) staff provided thorough work planning and oversight of the core barrel removal. Although the inspectors observed some initial challenges to the work crew, the evolution was well performed, and the accumulated worker dose was below the licensee's original estimate. However, the inspectors identified a communications problem concerning the turnover of positive control for a very high radiation area (Section R1.1).

. One violation was identified concoming the failure of an individual to adhere to a radiological posting. Although the radiological plans and reviews for the chemical and volume control system valve work were comprehensive, the workers were not adequately prepared for pre job meetings. An RP technician provided good coverage for the breach of the 2CV223 valve, and the workers demonstrated good radiological practices (Section R1.2).

. One violation was identified concerning the failure to adequately control an identified high radiation area (HRA). Two RP technicians identified an HRA with radiation levels of greater than 1000 millitem per hour near the Unit 2 D steam generator drain line but fc'!ed to establish the required cont:ols. The RP staff completed corrective actions, but additional RP technician performance problems (concerning an individual who was allowed to perform work without an active electronic dosimeter) indicated that additional corrective actions were warranted (Sections R4.1 and R4.3).

. The RP staff identified radiation worker problems and inadequate radiological postings (Section R4.2).

. The quality assurance staff performed a good review of radiation worker practices and RP technician performance (Section 6).

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, Reoort Details IV. Plant Support R1 Raolological Protection and Chemistry (RP&C) Controls R1.1 Removal and Installation of Lower Reactor Intemals a. Inspection Scoce (IP 83750) -

The inspectors reviewed the radiological planning for the removal and installation of the lower reactor intemals, i.e., the core barrel. The insrectors reviewed the As-Low-As-Is-Reasonably-Achievable (ALARA) Action Plan and the radiation work permit (RWP),

attended several pre-job briefings, and observed the conduct of the evolutio b. Observations and Findinos During the pre-job briefings, the inspectors noted that appropriate radiological concems were discussed and that lessons teamed from the Unit 1 outage were incorporated into the planning. The radiation protection (RP) staff emphasized the need to maintain continuous communications between work grcups and discussed ventilation control and radiation monitor responses. In addition, the staff discussed the major contents of the ALARA plan, including contingency actions for potential scenarios involving severe radiological consequences. For example, the ALARA plan contained postulated actions for a mechanical failure of the polar crane with the lower intemals exposed and for the loss of cavity water level, in addition, the RP staff provided instructions for other potential equipment problems, including camera failure, major loss of power to containment, and loss of remote dosimetry monitoring. However, the inspectors observed that the licensee had not fully evaluated the implementation of some of the contingencies. For example, a member of the maintenance staff identified that several crane operators were not qualified for rest try protection, which was one of the potential contingency actions. Based on ti. mdividual's observation, the staff ensured that the crane operators had the proper qualification Prior to the evolution, the inspectors observed some pressure on the work crew to perfUrm tho evolution within certain time constraints. Although the time constraints did not appear to adversely affect worker performance and licensee management stressed that the evolution could be postponed, the inspectors observed some challenges of the work crew. Since thea schedule had indicated that the evolution would be performed during the day shFt, the RP staff did not prepare other work shifts. As other outage ,

activities delayed the core barrel evolution, the day-shift workers had to obtain special overtime approval to complete the evolution. Based on the extended work hours of the crcw, the inspectors observed that RP personnel were concemed over the level of fatigue of tM workers. In addition, equipment problems arose with the load cell and the wireless remote monitoring (WRM) dosimetry system. The load cell was quickly repaired; however, the final pre-job meeting was started while the RP staff continucd to repair the WRM dosimetry system. During the meeting, the staff determined that a lack

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of ccmputer memory had affected the operability of the WRM system, but the preferred *

computer was not accessible. With the understanding that potential problems niay have been experienced, the staff decided that they would use the non-preferred computer and correct the problem if it occurred. Consequently, the potential existed for the system to cease functioning, requiring the RP technician to re-initialize the compute During the evolution, the inspectors observed strong oversight and control by radiation protection personnel. The licensee posted the Containment Building as a very high radiation area (VHRA), maintained positive control of the area, and evacuated all personnel (with the exception of the crane operators) from the Containment Buildin To ensure that the evacuation was complete, the radiation protection manager and an ALARA planner performed a fMal, comprehensive walk-down of the Containment Building. In addition, the RP staff suspended all RWPs, and security personnel controlled access into the area. During the evolution and as the dose rates rapidly increased, the inspectors noted good communications between the RP technician monitoring the WRM system and the maintenance personnel. The inspectors also observed that the maintenance stLff demonstrated good radiological practice However, the inspectors had some concem over the communications between the GP technicians who provided the positive control for the VHRA. During the evolution, the RP technician, whe,was assigned to provide the positive control, and a maintenance worker entered tb s Containment Building to cc reci a cable problem. Another RP technician in the area noticed that the assigned RP technician was leaving his post and assumed the duties to maintain positive control over this area. However, the RP technicians did not perform any verbal or formal turnover of the control of the VHR Although the control of the area was maintained, the RP staff acknowledged that the lack of a formal turnover between the technicians could have resulted in a proble The inspecars attended the post job meeting and noted excellent worker involvemen Workers provided an execlient critique of the evolution and provided several suggestions for improvements. Worker dose for the evolution was about 30 millirem, which was significantly below the licensee's goal of 100 millire Conclusions The RP staff provided thorough work planning and oversight of the core barrel remova Although the inspectors observed some initial challenges to the work crew, the evolution was well performed, and the accumulated worker dose was Leilow the licensees'

origird estimate. However, the inspectors identified a communications problem concerning the turnover of positive contcol for the VHR R1.2 Radiological Plannino and Oversight of Chemical and Volume Control System Valve WDIh Lsoection Scoce (IP 83750)

The inspectors reviewed the radiological planning and the conduct of valve work performed on the chemical and volume control system (CVCS). Specifically, the

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, licensee was repacking valve no. 2CV223 and was also working on valve no. 2CV814 The inspectors reviewed the applicable Al. ARA Action Review and RWP, attended pre-job briefings, and observed the conduct of wor Observations and Findinas The inspectors noted that the ALARA Action Review, which was generic for various CVCS valve work in the Unit 2 Containment Building, contained appropriate radiological informat:on from lessons learned and provided dose reduction methods. For example, the action review stressed the use of catch containments, low dose waiting areas, and mockups; suggested the pre-staging of necessary tools and the evaluation of specialty tools; and contained pictures to identify interferences. An evaluation performed by the Al ARA and maintenance staff for the repacking of the 2CV223 valve identified work area needs and dcse reduction techniques which would be employed. Based on these reviews, the staff reduced the original dose estimate for the 2CV223 valve repacking from 900 millirem to 300 millire The inspectors attended pre-job briefings for both evolutions and identified some problems conceming the preparation of the attenders. The RP technician and ALARA analyst provided good discussions of the radiological conditions and requirements; however, several preparatory actior's had not been completed. Prior to the 2CV223 valve pre-job briefing, the work supervisor had not reviewed the work package and had not walked down the work area und the out-of-services. In addition, tne assigned RP technician questioned the ALARA analyst on the content of work history files, which had not been reviewed. The work crew raised an excellent suggestion to use a mockup to determine the types of tools; however, at the time of the briefing, the workers did not

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appear to be ready to perform the evolution. As a result of these problems, the evolution was delayed about 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. In the case of the 2CV8149 valve, the participants were better prepared. However, the work crew failed to evaluate the affect of a planned Unit 2 electrical buss outage on the position of the valve. .,onsequently, the work was delayed as the valve stem was found in the wrong positio During the 2CV223 valve repacking, the inspectors observed good awareness of radiological conditions and good RP technician oversight. Despite some delay in obtaining face shleids and lighting, the repacking was conducted in an organized manner. The workers AmonCated good radiological practices, and the RP technician provided excellent oversight of the valve breac While observing the work performed on the 2CV8149 valve on October 10,1997, the inspectors trientified an instance where a worker failed to follow a radiological postin The worker was inside of a posted high contamination area in the Unit 2 Containment Building and was required to remove outer protective clothing at the designated step-off-

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pad, when exiting, instead of exiting at the step-off-pad, the worker stepped over the high contamination area boundary rope and left the area without removing his outer boots and gloves. An inspector alerted an RP technician to the occurrence. Procedure BwRP 5010-1," Radiological Posting and Labeling Requirements", revision 7, requires, in part, that personnel entering any radiologically posted area read and comply with all

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associated postings. As the area was posted as a high contamination area, the step-off-pad directed the workers to remove shoe covers and gloves before leaving the are The inspector also noted that the proper way to exit this area was discussed during the ALARA pre-job briefing; however, this worker had attended the brieflag held the previous day ant not the brief held immediately prior to the work taking plac i Technical Specification (TS) 6.11 requires, in part, that procedures for radiation protection be adhered to for all operations involving personnel radiation exposure. The failure to follow the directions of a radiological posting as required by procedure BwRP 5010-1 is a violation of TS 6.11 (VIO 50-456/97017-01 and 50-457/97017-01). Conclusions One violation was identified conceming the failure of an individual to adhere to a radiological posting. Although the ALARA p!ans and reviews for the CVCS valve work were comprehensive, the workers were not adequately prepared for pre-job meeting An RP technician provided good coverage for the breach of the 2CV223 valve, and the workers demonstrated good rad lological practice R4 Staff Knowledge and Performance in RP8C R Failure To Control A High Radiation Area in the Un12 Containment Building IDSoection Scone (IP 83750) E On September 29,1997, the licensee identified that two contract RP technicians failed to properly control a high radiation area (HRA) which they had identified in the Unit 2 Containment Building. The inspcetors discussed the event with RP staff and reviewed applicable radiological survey data and licensee correcti.e action Observations and Findings On September 29,1997, two contract RP technicians were providing job coverage for the removal of insulation from the Unit 2 A and D steam generators (SGs). After the insulation was removed from the SG drain lines, the RP technicians measured radiation levels of greater than 1000 milliroentgen per hour at 30 centime',ers. Procedure BwRP 5310-2," Control of Access to High Radiation Areas and Very High Radiation Areas,"

revision 4, and TS 6.12.2 specify he required actions to be taken when HRAs are identified. In the case of the dralrs line from the A SG, the technicians measured radiation levels of about 1200 milliroentgen per hour at 30 centimeters; however, they dio not take any additional actions. Following the completion of the job, the RP technicians exited the Unit 2 missile barrier, which was posted as a HRA, and informed the RP supervisor of the results. The RP supervisor identified that the technicians had identified an HRA which required specific controls but that the technicians did not implement the required controls. Subsequently, the RP supervisor ensured that the area was property barricaded and that a red, flashing light was positioned, in accordance with procedure BwRP 5310-2 and TS 6.1 I I

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During interviews with the lead health physicist, the technicians indicated that they did not believe that radiation levels in the area were actually greater than 1000 millirem /h The technicians rationalized that they had measured the radiation levels with an instrument that typically over-responds in that range and that they were uncertain of the distance from the source. In addition, they measured relatively high contamination levels (about 3,000,000 disintegrations per minute) and were uncertain if the area should be decontaminated prior to taking any other actions. Additional radiological surveys performed with a variety of instrumentation measured radiation levels between 700 and 1200 milliroentgen at 30 centimeters from the drain lin Technical Specification 6.12.2 contains requirements for individual high radiation areas with radiation levels of greater than 1000 miliiroentgen/hr that are located within large rooms, such as containment, where no enclosure exists for the purposes of locking, and where no enclosure can be reasonably constructed around the individual area. In this case, the individual area shall be barricaded, conspicuously posted, and a flashing red light shall be activated as a warning device. The failure of the two RP technicians to barricade the D SG drain line and place a flashing red light in the area is a violation of TS 6.12.2 (50-456/97017-02 and 50-457/97017-02).

As corrective actions for the event, the licensee issued disciplinary &ctions for the two technicians. In addition, RP manepment conducted staff meetings to discuss the event and to stress the necessity to makt. conservative decisions and to perform required actions based on the results of field measurements. The licensee also reviewed the access to the area and verified that no personnel exposures resulted from the lack of area control. However, based on additional performance problems involving station personnel and RP technicians (Sections R4.2 and R4.3), the licensee's corrective actions did not appear completely effectiv Conclusions One violation was identified conceming the failure to adequately control an identified HRA. Two RP technicians identified an HRA with radiation levels of greater than 1000 millirem per hour near the Unit 2 D SG drain line but failed to take the required control The RP staff completed corrective actions, but additional RP technician performance problems indicated that additional corrective actions were warrante R4.2 Imoroner Manioulation of Radiolooical Postinos and Radiation Worker Practices Following the onsite portion o' the inspection, the radiation protection manager discussed additional RP problems which had occurred between October 18 and 21, 1997, with the inspectors. The radiation protection manager indicated that on at least two occasions HRA barriers were found to have been moved or inappropriately manipulated by plant personnel. For example, on October 19,1997, an RP technician identified that an HRA boundary (i.e., a rope) was not properly positioned in the tooi decontamination area of the Auxiliary Building. In addition, the AP staff identified occurrences where personnel may have inappropriately manipulated alarming barrier The RP staff did not believe that any unnecessary radiation exposures resulted from

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, these instances. As an immediate corrective action, each site work group conducted meetings to discuss the importance of not manipulating any radiological posting. The radiation protection manager indicated that the RP staff was conducting investigations into the incidents. The results of the licensee's review of the incidents and corrective actions will be reviewed in future NRC inspections (IFl 50-456/97017-03 and 50-457/97017-03).

R4.3 Individual On Steam Generator Platform Without Procer Dosimetrv

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On October 10,1997, an individualidentified to the RP staff that he had performed work on the Unit 2 A/D SG platform the previous day without the proper dosimetry. Although the licensee had not completed a full investigation into the incident, the !"' -taff indicated that the individual had accessed the SG platform at about 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> on October 9,1997, to add and to secure coa ' '+s associated with the SG testing ,

equipment. However, the RP technicians at tne SG control point failed to properly activate the individual's electronic dosimeter (ED), which was required by the individual's RWP and the licensee's procedures. Based on the worker's time in the area (15 minutes) and the area dose rates, the RP staff estimated the worker's dose to be about 20 millirem. The licensee's initialinvestigation identified the following concems:

(1) the contract RP technician and the individual did not properly verify that the ED was properly activated; (2) while the individual was on the platform, the contract RP technician noticed that the ED was not functioning but did not appear to take prompt action to inform the individual and to remove the worker from the platform; and (3) neither the contract RP technician nor the RP supervisor at the SG control point identified t,ie problem to RP managemen As immediate corrective actions, the RP staff suspended the RP technician and supervisor's access to the site, conducted a stand-down with all contract RP technicians, and conducted training with contract RP technicians and supervisors. The inspectors discussed with licensee management concems regarding the failure of the contract RP technician and supervisor to report the event. The NRC staff will review the licensee's completed investigation and corrective actions in future inspections (URI 50-456/97017-04 and 50-457/97017-04).

R6 Quality Assurance in RP&C Activities The inspectors reviewed the results of the quality assurance audits of RP activities, including audit reports nos. '.0-97-02 and 20-97-12. The quality assurance organization performed the audits to satisfy the requirements of 10 CFR 20.1101. The inspectors observed that the audits focussed on performance based issues and field observation For example, the scope included observations of radiation worker performance, radiological survey information, and RP technician performance. T;'e inspectors noted that the audit documented a thorough review of thosa areas but was not as comprehensive conceming programmatic issues. A member of the quality assurance

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., organization acknowledged the inspectors' observations and indicated that additional attention was planned to be focused on programmatic issues, such as the ALARA

program and shutdown chemistry contro R8 Miscellaneous RP&C Activities R8.1 (Closed) VIO Nos. 50-456/97003-01(a-d) and 50/97003-01(a-d) A violation with four examples was identified concerning the failure to adhere *o chemistry procedures and to aJsquately implement chemistry procedure In the case e Example A NRC inspectors had identified an expired aluminum standard in the chemistry laboratory, which had been improperly labeled. As corrective actions, the chemistry staff ,evised the chemistry standards data base to include the proper expiration dates for 10 parts per million (ppm) and 20 ppm aluminum standards. The staff had also implemented a nt.w data base which was controlled by the quality control chemist and chemistry hygiene officer, if reagents or standards were not found in the >

data base, only tnese individuals could add the new cheinical. During this inspection, the inspectors did not identify any expired or improperly labeled chemicals in the laborator In the case of Example B, NRC inspectors had identified that the chemistry staff failed to properly control cuality control limit sheets, which were posted in the - ) oratory,in accordance with procedures. As corrective actions, the chemistry staff created revision 2 of procedure BwCP PD 7A1," Laboratory AnalyticalInstrumentation Quality Control Program," to include the quality :ontrol limit sheet as attachment BwCP PD 7A1T During this inspection. the inspetors verified that the posted copy of BwCP PD-, \1T4 3 was the correct version, s In the case of Example C, NRC inspectors had identified that revision 1 of procedure BwCP PD-7A1 did not contain accepthn .e criteria or instructions as to corrective actions for unacceptablo results of the interlaboratory program. During this inspection, the inspectors verified ; hat revision 2 of BwCP PD 7A1 referred the user to additional documents which contained acceptance criteria and provided corrective actions. In addition to the procedure revision, the licensee also conducted a review of other chemistry procedures to ensure that acceptance criteria were adequate. The inspector observed that the review was comprehensive and that the licensee had implemented or had planned to implement corrective actions for identified prnblem In the case of Example D, NRC inspectore had identified that procedure BwCP 210-4,

" Geometry Efficiency Standardization of Intrinsic Germanium Detectors on the ND 9900 Counting Room System," revision 2, did not provide instructions which would ensure the adequacy of the calibration. As corrective actions, the chemistry staff implemented BwCP 210-14, revision 4, and BwCP PD-7A3, "Radioanalytical Quality Control Program," revision 4, to provide necessary instructions to verify the adequacy of calibrations. During this inspection, the nspectors reviewed the procedures and did not identify any problem ___

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On June 26-30,1997, the chemistry supervisor condacted training for the chemistry staff to provide the staff with a better understanding of regulatory requirements h the chemistry area. The training reviewed TS, Regulatory Guides, the licensee's Final S2fety Analysis Report, and other selected reference docements. During this inspection, the incpectors reviewed the trainq lesson plan and noted that the training was comprehensive. This violation is c'ose R8.2 [ Closed) VIO Nos. 50-456/97003-02 and 50-457/970u3-02: Procedure BwCP 323-13,

"High Radiation Sampling System Surveillance Procedure," revision 7, did not cor5in acceptance criter;n for performance checks. As corrective actions, the chemistry staff implemented adequate acceptance criteria in the following procedures:

BwCP 613 28," Performance Check Sampling of Diluted Reactor Coolant (Cold or Hot Leg)", revision 0; BwCP 013-29,"Performt.nce Check Sampling of Undiluted Rector Coolant (Cold or Hot Leg)", revision 0; and BwCP 613-20," Stripped-Gas Sampling of Reactor Coolant (Cold or Hot Leg),"

revision During this inspection, the inspectors reviewed the above chemistry procedures, which were adequate, in addition, the inspectors verified that the licensee's third quarter performance tests for 1997 were properly completed and were within the stated acceptance criteria As documented in Section R8.1, the chemistry staff also performed a review of other procedures and condacted training of the staff. This item is close ,

R8.3 (Qt en) Insoection Follow-uo item Nos. 50-456/.9]_@3-05 and 50-457/97003-05: The inspectors reviewed the licensees progress with the planned revision of the process and area radiation monitor alarm setpoint justification document. The inspectors observed improvement in the content and condition of the document, i.e. several calculations were ccrrected and the text was legible. The responsible health physicist had completed the revision; however, the revision had not been reviewed and approved. The licensee planned to approve the document before the end of 1997. This item is open pending l approval of the setroint justification documen R8.4 [ Closed) VIO Nos. 50-456/97008-01 and 50-457/97008-01: An NRC inspector identi'ied that the door to a locked HRA was not properly locked. The RP staff determined that the lock on the door had malfunctioned, rendering the door unlocked. As documented in NRC Inspection Report Nos. 50-456/97008 and 50-457/97008, the licensee had implemented corrective actions to correct the existing problem and to identify and to correct any other hardware problems. During the inspecilon, the inspectors verified that selected locked HRA doors were properly locked and that the licensee had not identified any similar probicms. This violation is close R8.5 (Qppn) VIO Nos. 50-456/97008-02 and 50-457/97008-02: An NRC inspector identified that vacuum cleaners stored in radiologically posted areas were not maintained in

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accordance with procedure BwRP 6210-17,"Use of Vacuum Cleaners and Fans in Radiologically Controlled Areas," revision 2. Subsequently, the licensee reduced the number of unnecessary vacuum cleaners stored in the radiologically posted area and implemented revision 3 of crocedure BwRP 6210-17 which contained less restrictive -

requirements for vacuum cleaner storage. The inspectors reviewed the BwRP 6210-17, revision 3, and found the procedure to have adequate controls for contaminated vacuum cleaners. Although no additional problems were identified, the licensee planned to perform an effectiveness review of this program area in December of 1997. As documented in the above inspection report, previous licensee corrective actions were not sufficient to prevent this violation; therefore, this violation will remain open pending the results of the licensee's effectiveness revie V. Management Meetings X1 Exit Meetina Summary The inspector presented the inspection results to members of licensee management at the conclusion of the onsite inspection on October 10,1997. On October 22,1997, an inspector discussed additional radiation protection events with Mr. R. Thacker of the licensee's staff. The

!icensee acknowledged the findings presented. No proprietary information was identifie l

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PARTIAL LIST OF PERSONS CONTACTED Licensen R.- Byers, Maintenance Manager M. Cassidy, Regulatory Assurance A. Crimean, Lead Radiation Protection Supervisor M. Finney, Lead health Physicist C. Herzog, Executive Assistant M. Holmes. Lead Chemist J. Kinsela, Quality and Safety Assessment J. Nalewajka, ISEG Supervisor M. Riegel, Quality and Safety Assessment Supervisor T. Simpkin, Regulatory Assurance Supervisor R. Thacker, Lead Health Physicist D. Turner, Assistant Security Administrator INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 92904 Follot op - Plant Support ITEMS OPEN, CLOSED, AND DISCUSSED Ooened 30-456/457-97017-01 VIO Failure to adequately implement radiation protection procedures conceming the adherence to posting /457-97017-02 VIO Failure to comply with TS 6.1 /457-97017-03 IFl 1.icensee to review several radiation worker problems affecting the adequacy of radiological posting /457-97017-04 URI RP technicians failed to ensure that worker's dosimetry was activated and may have attemptad to conceal the proble Closed l

. 50-456/457-97003-01(a-d) VIO Failure to implement chemistry procedures.

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50-456/457-97003-02 VIO Failure of post accident sampling system surveillances to specify acceptance criteri a- .

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50 456/457 97008-01 VIO locked HRA door was found unlocke Discussed 50-456/457-97003-05 IFl Licensee progress in establishing a basis document for process and area radiation monitor alarms setpoint /457-97008-02 VIO Failure to properly control radioactively contaminated vacuum cleaner ,

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. LIST OF ACRONYMS USED ALARA As-Low-As-Is-Reasonably-Achievable CVCS Chemical and Volume Control Sys%m HRA High Radiation Area IFl Inspection Follow-up item IP inspection Procedure PPM- Parts Per Million RP Radiation Protection RWP Radiation Work Permit S3 Steam Generator TS Technical Specifications  %

URI Unresolved item VHRA Very High Radiation Area VIO Violation

.-WRM Wireless Remote Monitoring

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. PARTIAL LIST OF DOCUMENTS REVIEWED ALARA Action Plan For Removal And Installation Of Unit 2 Lower Intenials (Core Barrel)

BwRP 5010-1 (Rev. 7)" Radiological Posting and Labeling Requirements" BwRP 5000-4 (Rev,0)' Procedure For Processing of Contract Radiation Protection Technic 8ans" BwRP 5310-2 (Rev. 4)" Control Of Access to High Radiation Areas and Very High Radiation Areas" BwAP 900-4 (Rev.14)" Personnel Access Control"

" Process Monitor Setpoint Calculation Document" Rev. 2 June 1997 Radiakon Work Permit No. 976065 Rev. O " Remove & Reinstall Lower Reactor Intemals (Core Barrel)" ,

Radiation Work Permit No. 976133 Rev 0 " Contractor Valve Work in Charging Valve Area As Approved By RP."

Radiological Survey Serial No.12495, dated September 29,199 ,

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