IR 05000461/1998010
| ML20248J878 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 06/03/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248J849 | List: |
| References | |
| 50-461-98-10, NUDOCS 9806090342 | |
| Download: ML20248J878 (31) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lll l Docket No: 50-461 l License No: NPF-62 l Report No: 50-461/98010(DRS)
Licensee: lilinois Power Company Facility: Clinton Nuclear Power Station Location: Route 54 West Clinton,IL 61727 Dates: May 11-15,1998 Inspector: S. K. Orth, Senior Radiation Specialist Approved by: G. L. Shear Chief, Plant Support Branch 2 Division of Reactor Safety 9906090342 990603 PDR ADocK 05000461 PM
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EXECUTIVE SUMMARY
- Clinton Nuclear Power Station, Unit 1 l NRC Inspection Report 50-461/98010 This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) program. Specifically, the inspection consisted of a review of the implementation of the external dosimetry program and of the operability and quality control programs for the radiological environmental monitoring and meteorological programs. In addition, previous inspection items were also reviewed. The report covers a one-week inspection concluding on May 15,1998, performed by a senior radiation specialist. One violation of regulatory requirements was identified conceming the failure to post a radiation area (Section R4.2).
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. The RP staff properly implemented the external dosimetry quality control program. The licensee maintained National Voluntary Laboratory Accreditation Program accreditation in accordance with 10 CFR Part 20. In addition, periodic thermoluminescent dosimeter quality control tests were performed as required, and the results were evaluated for long term biases or trends. However, the inspector identified problems in the documentation of quality control test results and corrective actions performed during routine thermoluminescent dosimeter processing. (Section R1.1)
. The licensee continued to maintain administrative extemal dose levels to ensure that personnel doses were maintained ALARA. With the exception of one individual's total effective dose equivalent (TEDE), personnel doses for 1996 and 1997 were below the administrative dose levels. Although the RP staff investigated the incident and implemented corrective actions, the inspector noted that the licensee's actions were not l timely. In addition, the inspector noted some errors in the licensee's quarterly comparisons of doses measured via thermoluminescent dosimeters and electronic dosimeters. (Section R1.2) 1
. Environmental sample results did not indicate any discemable effects from plant operations and/or radioactive releases. The 1996 and 1997 annual reports were weli written, and the licensee had replaced some sampling instrumentation to improve operability of the air samplers. However, the inspector identified some problems conceming technician knowledge level and techniques. In addition, performance problems conceming well water compositors were not fully evaluated by the RP staff to .
ensure that a representative sample was obtained. (Section R1.3) - !
. The system engineer performed good trending of system operability for the primary meteorological tower. The calibrations and surveillance for the primary meteorological i tower were properly performed. However, one non-cited violation was identified conceming the failure to perform monthly meteorological tower operability verifications at the required frequency. In addition, the inspector identified some continuing problems l
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concerning the licensee's attention to the backup meteorological tower. Specifically, a 6-month preventive maintenance surveillance was scheduled for January 22,1998, but had not been performed. (Section R2.1)
- Two non-cited violations were identified concerning the deliberate falsification of a radiological survey record by an RP technician. The licensee performed a thorough investigation of the incident and implemented immediate corrective action (Section R4.1)
- A violation was identified concerning the failure to post a radiation area in the control rod drive filter area within the turbine building. Although the licensee identified this violation, the RP staff missed two prior opportunities to identify and correct this violation. On two independent radiological surveys, RP technicians measured and documented radiation levels in the area which would have required a radiation area posting but did not recognize that the area was not properly posted. (Section R4.2)
- Quality assurance assessments of the licensee's radiological environmental monitoring program, including the performance of the vendor laboratory, were thorough. In particular, the audit of the vendor laboratory identified notable weaknesses in the vendor's implementation of its quality control program. The inspector observed that the RP organization was aware of the issues and was taking actions to address audit findings and recommendations. (Section R7.1)
- The RP staff continued to initiate improvement actions to address radiation worker practices and RP program weaknesses and to perform self assessments to monitor performance. Although some reduction in radiation worker problems was noted, the inspector observed that radiation worker practices and RP technician performance continued to be a challenge. The inspector also noted that planned RP improvement actions were not always met with a high level of plant-wide commitment. (Section R7 2)
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Report Detalla l
IV. Plant Suonort j l
R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Thermoluminescent Dosimetry (TLD) Quality Control Proaram Insoection Scooe (IP 83750)
l The inspector reviewed the licensee's thermoluminescent dosimeter (TLD) processing and quality control testing. The inspector also reviewed the radiation protection (RP)
staff's implementation of the following procedures:
. CPS No.1024.15 (Revision 12), " Occupational Radiation Exposure Control and Monitoring;"
. CPS No.1903.20 (Revision 16), "Extemal Exposure Monitoring;"
. CPS No. 7700.01 (Revision 4), "TLD Quality Control Program;"
. CPS No. 7700.02 (Revision 2), " Calibration of the Panasonic Model UD-716AGL TLD Reader;"
. CPS No. 7700.04 (Revision 3), " Processing Panasonic TLDs;" and
. CPS No. 7701.08 (Revision 1), " Exposure investigations." Observations and Findings The licensee maintained two instruments which were used for processing TLDs at the station. In accordance with 10 CFR Part 20, the licensee was accredited under the National Voluntary Laboratory Accreditation Program (NVLAP) through December 31, 1998. The RP staff also conducted a quality control program consistent with the above procedures and with its program manual (" Quality Assurance Program Manual for Thermoluminescent Dosimetry Processing at the Clinton Power Station," dated December 19,1997). For example, the inspector reviewed the current semiannual TLD reader calibrations (performed on December 10,1997, and May 5,1998, respectively),
which were performed in accordance with the licensee's procedures, in addition, the inspector observed that the RP staff periodically processed TLDs which had been irradiated by the licensee and by a vendor to ensure that the instruments were operating properly and that the results of these analyses were graphed to identify any long-term biases. The inspector found the licensee's results to be very gccd c'.id the quality control program to be properly implemente The RP staff analyzed quality control TLDs at the frequencies specified in procedure CPS No. 7700.04 (i.e, two quality control TLDs were processed at the beginning and at the end of an analysis sequence and a quality control TLD was processed at the start of each new rack of TLDs within an analysis sequence). If the quality control TLD was not within the licensee acceptance criteria, procedure CPS No. 7700.04 directed the analyst to process two additional quality control TLDs. If both of the subsequent TLDs were within the acceptance criteria, the analyst was allowed to continue processing the TLDs
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l with the dosimetry supervisor's approval. However, if both of the subsequent two TLDs were not within the acceptance criteria, the analyst was required to contact the dosimetry supervisor for further instructions. In addition, an investigation was to be completed of all TLD results since the last successful quality control TLD was processe During the mview of the first quarter 1998 TLD analyses, the inspector identified problems concerning the documentation of the TLD quality control tests. For example, the licensee's records did not contain documentation of all of the quality control comparisons. In addition, the licensee did not adequately document the actions taken to resolve unacceptable quality control results. Specifically, on April 6,1998, the RP staff processed two sets of TLDs (File Nos. D98040012 and D98040022). Within each of these data sets, the inspector observed that the licensee had failed a quality control TLD l analysis and had not passed the two subsequent quality control TLD analyse Following the original two repeated analyses, the analyst performed an additional two quality control TLD analyses, which were within the licensee's acceptance criteria, and continued the routine processing. In the comment section of the TLD Processing Record, the analyst indicated that some of the quality control TLDs had not met the acceptance criteria, but that they were followed by two passing analyses. However, the analyst did not include any documentation to indicate that the dosimetry supervisor was notified or that an investigation was completed. The inspector discussed this matter with the dosimetry supervisor, who indicated that she had been notified of the unacceptable quality control results. Since the results were only slightly biased in a conservative direction, the supervisor indicated that she instructed the analyst to process the two additional quality control TLDs and to proceed with the analyses, if the results were acceptable. In addition, the supervisor indicated that the minor bias in the ;
I original quality control results were evaluated and that no further actions were take The supervisor acknowledged that the licensee's records of these actions were incomplete and planned to ensure that future actions were properly recorde Conclusions The RP staff properly implemented the external dosimetry quality control program. The I licensee maintained NVLAP accreditation in accordance with 10 CFR Part 20. In addition, periodic TLD quality control tests were performed as required, and the results were evaluated for long term biases or trends. However, the inspector identified problems in the documentation of quality control test results and corrective actions performed during routine TLD processin R1.2 Administrative External Dose Controls and Evaluations (IP 83750) Insoection Scoce (IP 83750)
The inspector reviewed the licensee's administrative extemal exposure controls, the 1996 and 1997 personnel dose reports, the RP staff's evaluations conceming unexpected differences between TLDs and self reading dosimeters (SRDs) results and the implementation of the following procedures:
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. CPS No.1024.15 (Revision 12), " Occupational Radiation Exposure Control and Monitoring;"
. CPS No.1903.20 (Revision 16), "Extemal Exposure Monitoring;" and
. CPS No. 7701.08 (Revision 1), " Exposure investigations."
b. Observations and Findinas The licensee maintained administrative dose levels to ensure that personnel doses at the site were maintained as-low-as-is-reasonably-achievable (ALARA). For example, procedure CPS No.1024.15 limited adult radiation workers to the following dose levels (received at the licensee's facility): (1) a total effective dose equivalent (TEDE) of 2 rem, (3) a total organ dose equivalent (TODE) of 20 rem, and (3) a shallow dose equivalent (SDE) of 40 rem to the skin. The inspector reviewed the licensee's 1996 and 1997 personnel dose records and found that all but one individual was maintained below these levels. As documented in NRC Inspection Report No. 50-461/96012(DRS), an individual received a TEDE of about 2.010 rem in 1996 at the licensee's faci!ity. The inspector observed that the licensee evaluated this exposure in a condition report; however, the inspector noted that the condition report was not resolved in a timely manner. The inspector noted that a significant aspect of the investigation was to resolve a nonconservative discrepancy between the TLD and electronic dosimeter (ED) results (i.e., the TLD results were about 20 percent greater than the ED results), which contributed to the individual exceeding the 2 rem TEDE dose level. As corrective actions, the RP staff revised program procedures to provide for a greater margin between TLD and ED dose results and to provide for more conservative dose review levels. Although the review was thorogh and the corrective actions addressed the problems, the RP staff completed the investigation and corrective actions in about 18 months. The RP manager acknowledged that the time to resolve the initial condition report was unacceptable and indicated that improvements had been made to ensure that future condition reports were evaluated and resolved in a more timely manne The inspector reviewed routine personnel dose investigations and observed that unacceptable discrepancies between TLD and ED results were properly reviewed, as required by procedures CPS Nos. 1024.15 and 7701.08. Following each calendar quarter, the dosimetry supervisor compared the licensee's quarterly dose measured via TLD to the dose measured by ED. During a review of this comparison, the supervisor and the inspector identified some errors in the values that were being compared, which were later corrected by the dosimetry supervisor. Based on the corrected data, the inspector noted that the dose measured via TLD was typically greater than the dose measured by SRD. The dosimetry supervisor partially attributed this discrepancy to errors in reading low doses from an SRD and to the lack of a consistent requirement for individuals to record the dose from all entries into the radiologically posted area (RPA).
However, the RP staff recently implemented the requirement that all entries into the RPA and dose from those entrie'; would be recorded by the individual, which was expected to increase the validity / accuracy of the TLD to ED comparison. The inspector reviewed the dose investigations for the first quarter of 1998 and found the dose discrepancies to be initiated, as required. In particular, the RP staff was currently evaluating a discrepancy identified following first quarter 1998 diving evolution _____- _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
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Although no unexpected exposures resulted from the evolution, the staff identified that doses determined by EDs were significantly lower than the doses determined by TLD The RP manager indicated that the staff planned to resolve the recently identified anomaly prior to planned diving in the fall of 199 Conclusions The licensee continued to maintain administrative extemal dose levels to ensure that personnel doses were maintained ALARA. With the exception of one individual's TEDE, personnel doses for 1996 and 1997 were below the dose levels. Although the RP staff investigated the incident and implemented corrective actions, the inspector noted that the licensee's actions were not timely. In addition, the inspector noted some errors in j the licensee's quarterly comparisons of doses measured via TLDs and ED Ri.3 Radiological Environmental Monitoring Program (REMP) Insoection Scoce (IP 84750) 1 The inspector reviewed the implementation of the radiological environmental monitoring program (REMP). Specifically, the inspector reviewed the 1996 and 1997 Annual Radiological Eny'ronmental Operating Reports, observed sample collection activities, and reviewed the calibration and operability of instrumentatio ' Observations and Findings The inspector reviewed the 1996 and 1997 annual reports and found the reports to be well written and to contain the information required by the Offsite Dose Calculation Manual (ODCM). Within the reports, the licensee documented sample anomalies and corrective actions for those anomalies. However, the inspector observed that certain sections of the report did not provide conclusions concerning the comparison of the sample results for certain environmental sample media. For example, the 1997 report indicated that the gross beta activity in broad leaf vegetation was greater than that measured during pre-operational measurements. Generally, the staff attributed the differences to minor fluctuations in background and/or statistical differences in the '
analytical results. However, the licensee did not address this difference in the text of the report. Based on the sample results, the inspector concluded that there was no measurable impact on the environment from plant operatio The inspector also observed the collection of air filter (air particulate and charcoal cartridges) and well water samples. The inspector noted that the instrumentation was operable and was acceptably maintained. For example, the licensee had recently replaced sample timers and some sample pumps to address equipment performance problems identified in 1996 and 1997. Although all of the primary sample timers were functioning, the sample technician found two inoperable backup timers, which were replaced. During these observations, the inspector noted that the technician did not demonstrate a thorough knowledge of the air sampling instrumentation and the procedure requirements. During the air in-leakage testing of the air filter train, the
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Inspector identified some problems concerning the technician's air flow measurement Instead of allowing the air flow indicator to stabilize, the technician noted and recorded the air flow as the lowest fluctuation of the indicator. For example, the technician routinely documented the in-leakage as less than 10 standard cubic feet per hour (SCFH), so long as the indicator showed some deflection below 10 SCFH. The RP staff acknowledged that the technician should have allowed the rotameter to stabilize to obtain an acceptable measurement. During the technician's investigation of an air in-leakege problem, the inspector also identified some problems conceming the technician's handling of air samples and trouble-shooting of the problem. However, the technician properly contacted his supervisor for additional direction and resolved the problem. The inspector did observe that the technician demonstrated good analytical techniques in preparing the samples for shipping to a vendor laboratory. The RP manager acknowledged the performance issues and planned to evaluate the technician training program to determine if additionalinstructions needed to be adde The licensee properly calibrated the air regulators and water compositors used in the collection of environniental samples. Based on the current calibration data, the inspector noted that air regulator accuracy was stable; however, the water compositors demonstrated notable fluctuations between calibration periods. For example, on April 16,1998, the volume of one of the samplers had to be adjusted by more than a factor of five. The inspector noted that these fluctuations could potentially effect the licensee's ability to obtain a representative monthly composite sample, as required by the ODCM. The RP staff acknowledged the performance problems with the water compositors and was preparing to install new instruments to correct the problems. In the interim, the sample technician was monitoring the level of water collection on a weekly basis to correct any anomalies in instrument performance. The RP staff indicated that the purpose of the weekly monitoring was to ensure that a volume of sample was collected; however, the staff was not monitoring / measuring the amount of sample. The technician indicated that the weekly water collection levels sometimes varied; however, the inspector reviewed the REMP log and did not observe any i descriptions of the weekly observations or of any adjustments to the equipmen Although the RP staff ensured that gross failures of the equipment were corrected, the inspector concluded that the staff had not fully considered the effect of the water l compositors' performance on the ability to ensure that a representative sample was obtained. Based on the consistency of the sample results, the inspector could not !
identify any abnormalities in the sample Conclusions l
Environmental sample results did not indicate any discernable effects from plant l operations and/or radioactive releases. The 1996 and 1997 annual reports were well written, and the licensee had replaced some sampling instrumentation to improve !
operability of the air samplers. However, the inspector identified some problems !
concerning technician knowledge level and techniques. In addition, performance problems concerning well water compositors were not fully evaluated by the RP staff to ;
ensure that a representative sample was obtaine l l
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R2 Status of RP&C Facilities and Equipment R2.1 Maintenance of Meteorological Monitoring instrumentation Insoection Scooe (IP 84750)
The inspector reviewed the operability of the meteorological instrumentation located in the primary and backup met towers. Specifically, the inspector reviewed trends of instrument performance, instrument calibration records, and preventive maintenance surveillance; discussed instrument performance with the system engineer; and performed a walk-down of the primary meteorological tower and instrumentation. The inspector also verified that the licensee had properly implemented the following procedures:
. CPS No. 3843.01 (Revision 3), " Environmental Monitoring Monthly Preventive Maintenance; and
. CPS No. 9437.14 (Revision 35), " Meteorology System Loop Calibration." Observations and Findinas The licensee maintained two meteorological towers to provide weather information for the purpose of offsite dose projections and emergency response actions. The primary meteorological tower consisted of instrumentation to measure the wind speed, wind direction, temperature, dew point, and precipitation. The backup meteorological tower provided alternate wind speed and direction indication. The responsible system engineer monitored and trended the operability of the primary meteorological tower. Based on the system engineer's data, the availability (i.e., recoverable data hours) for certain primary meteorological tower instrumentation (i.e., for wind speed, wind direction, and !
temperature indication) was greater than 90 percent; however, the availability of dew point and precipitation instrumentation was between 85 to 90 percent. Since the dew point and precipitation instrumentation were not required by the Technical Specifications ",
(TS) or the Operational Requirements Manual (ORM), the engineer indicated that the maintenance of these instruments was often not a high priority. However, the engineer planned to evaluate alternate parameters to trend meteorological tower instrument performance and to evaluate additional goals for all of the instrument The inspector observed the condition of the primary meteorological tower and did not identify any significant maintenance issues. On May 12,1998, the 60 meter wind speed instrumentation failed (as a result of severe weather conditions), and maintenance was ongoing to replace the associated sensor. Maintenance requests were also outstanding on problems with certain circuit breakers and the backup generator. However, the system engineer indicated that these maintenance issues did not effect the operability of the systems and that maintenance planned to be performed prior to the scheduled 6-month calibratio The licensee properly calibrated the primary meteorological tower as required by procedures and consistent with the ORM. At a 6 month freauency, the licensee 9 l
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performed a calibration of each of the instruments. The inspector reviewed the previous two calibrations (performed on April 18,1997, and on October 24,1997) and did not identify any problems. The inspector noted that the "as found" condition of the instruments was routinely within the licensee's acceptance criteria, indicating stable instrument performance. Although the current calibration had been performed over 6 months ago, the ORM allowed for a 25 percent extension period (i.e., * grace period") for the surveillance, and a calibration was planned for the week of May 19,199 However, the inspector identified a lapse in the preventive maintenance for the backup meteorological tower. At a 6-month frequency, the licensee scheduled a preventive maintenance activity for the backup meteorological tower instrumentation, which effectively replaced the wind sensor instrumentation with recalibrates instrument However, the inspector identified that the first performance of the preventive maintenance task had been scheduled for January 22,1998, but had not yet been performed. As documented in NRC Inspection Report No. 50-461/97002(DRS), the NRC had identified previous deficiencies in the licensee's attention to the backup meteorological tower. Based on the recent observations, the inspector discussed the continued lack of attention to the backup meteorological tower with licensee menagement, who acknowledged the inspector's concerns. As corrective actions for the late task, the system engineer generated a condition report to document the problem, and the preventive maintenance task was planned to be completed by May 31, 199 The inspectnr also reviewed the licensee's monthly reviews of the primary and backup meteorological tower instrumentation, as required by procedure CPS No. 3843.01. At a monthly frequency, the procedure required specific observations to ensure that the meteorological monitoring equipment was properly operating. The inspector reviewed the licensee's records of these observations and found that the procedure had been performed at the required frequency, with the exception of April of 1998. On May 8, 1998, the licensee identified that a scheduling error had resulted in the omission of the April 1998 performance of the procedure (i.e., the previous performance date was March 10,1998). As corrective actions, the licensee initiated a condition report and performed the procedur Technical Specification 5.4.1 requires, in part, that procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A. Section 7.h of Regulatory Guide 1.33, Appendix A, recommends that procedures conceming meteorological monitoring be established and implemented. The failure to perform procedure CPS No. 3843.01 between March 10,1998, and May 8,1998,is a violation of TS 5.4.1. This non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-461/98010-01).
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. Conclusions The system engineer performed good trending of system operability for the primary
! meteorological tower. The calibrations and sunreillances for the primary meteorological l tower were properly performed. However, one non-cited violation was identified I concerning the failure to perform monthly meteorological tower operability verifications at the required frequency. In addition, the inspector identified some continuing problems conceming the licensee's attention to the backup meteorological tower. Specifically, a 6-month preventive maintenance surveillance was scheduled for January 22,1998, but l had not been performed.
l l R4 Staff Knowledge and Performance in RP&C R4.1 Deliberate Falsification of a Radiological Survev Record
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1 Insoection Scoce (IP 83750)
The inspector reviewed a licensee condition report concerning a potential falsification of I an air sample measurement performed on October 24,1996. The Region lli Office of l
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Investigations (Rlil:Ol) also reviewed this incident and interviewed the involved individual Observations and Findinas l On October 24,1996, two individuals were performing valve lapping of valve N l 1821F304A in the A steam jet air ejector room. The individuals performed the activities under the requirements of Job Step 1 of minor radiological risk record (MRRR) N .006. Based on low levels of removable contamination on the valve intemals i e?d low general area radiation levels, the RP staff determined that the work was of low radiological consequences and that respiratory protection would not be required. Prior to beginning the lapping evolution, the RP shift supervisor assigned a contract RP technician to the evolution to provide oversight and to conduct air sampling. During the evolution, the RP technician obtained and analyzed one air sample. The air sample (No. 96-1049) was part of the licensee's routine radiological survey program to verify that the work area radiological conditions were as described in the MRP.R and that the expected personnel doses were within the regulatory limit During a review of the air sample result (Form CPS No. 7105.02D001, " Air Activity Data Sheet," dated October 24,1996), an RP supervisor noted that the calculated airborne activity was above the licensee's action level, which required an additional analysis via gamma spectroscopy; however, the survey record did not contain such an analysi Consequently, the RP supervisor questioned the RP technician about the missing analysis and indicated to the technician that a condition report would be initiated for the failure to properly implement the air sampling procedure (CPS No. 7105.02 (Revision 9),
" Air Sample Assay"). During this conversation, the RP technician indicated that the recorded sampling time of 1 minute was incorrect and changed the sample time to 2 minutes, which reduced the sample activity to below the licensee's action level. Since 11 I
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the original data sheet had not been approved, the RP staff believed that the data was incorrect and discarded the original shee On October 25,1996, another RP shift supervisor learned of a problem conceming the air sample and questioned the valve technicians involved in the lapping evolution. The valve technicians indicated that the RP technician called-out that the sample time was 1 minute and that the valve technicians, not the RP technician, had performed the manipulations of the sampling equipment. Based on this discrepancy, the RP supervisor stopped the ongoing valve work, collected an additional air sample, and performed in vivo bloassays of the two workers. The second air sample result (1.85 x 10* microcuries pe cubic centimeters) did not indicate an airborne problem, and the workers' bioassay results also did not indicate any intake of radioactive materia The licensee initiated a condition report and identified the following:
. The RP technician had the two workers, who were unqualified for the task, perform the evolution. Although this did not meet RP management's expectations, licensee procedures allow for unqualified individuals to perform these tasks, when directly supervised by a certified RP technicia . The RP technician did not verify the actual air sampler flow rate, but believed that it was about 2 cubic feet per minute based on the sound of the air sampler moto . The actual air sample collection time could not be determined. The workers stated that the RP technician told them to stop the sampling after 1 minute had passed, but the RP technician, who was the only individual wearing a watch, stated that the collection time was 2 minute Although the licensee did not conclude that the RP technician falsified the air sample data, RP management was confident that the sample was not taken appropriately and that the technician demonstrated poor knowledge of RP principles and poor sampling techniques. Since the licensee was performing a routine reduction in the contract RP labor force, the RP staff released the above technician via normal reductions in forc The Rlll:OI staff conducted an independent investigation of the incident and concluded that the RP technician had deliberately entered an incorrect sample time on form CPS No. 7105.02D001, " Air Activity Data Sheet." Based on interviews with the involved individuals, the Rlll:Of staff concluded that the RP technician was not cognizant of the exact sample time. Therefore, the Rill:Ol staff concluded that, in the course of changing the time on the air sample data sheet from 1 to 2 minutes, the technician deliberately recorded inaccurate information on the data sheet to prevent the initiation of a condition report. Consequently, the NRC determined that the survey was inadequate and that the survey record was not accurat CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are
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reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production,
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use, transfer, release, disposal, or presence of radioactive material or other sources of l radiation. The failure to perform an adequste airbome radioactivity survey on October 24,1996, is a violation of 10 CFR 20.1501. Although this violation is willfal, it was brought to the NRC's attention by the licensee, it involved isolated acts of a low-level individual, and it was addressed by appropriate remedial action. Therefore, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-461/98010-02).
10 CFR 50.9 requires, in part, that information required by the Commission's regulations to be maintained by the licensee shall be complete and accurate in all material respect The failure of the RP technician to record accurate information on the above required survey record is a violation of 10 CFR 50.9. Although this violation is willful, it was brought to the NRC's attention by the licensee, it involved isolated acts of a low-level individual, and it was addressed by appropriate remedial action. Therefore, this non-repetitive, licensee-identifie'J and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-461/98010-03). Conclusions Two non-cited violations were identified concerning the deliberate falsification of a radiological survey record by an RP technician. The licensee performed a thorough investigation of the incident and implemented immediate corrective action R4.2 Inadeauate Postina of a Radiation Area Insoection Scone (IP 83750)
The inspector reviewed an incident concerning a radiation area that was not properly posted in the turbine building. The inspector discussed the incident with applicable RP staff, reviewed the licensee's condition report, and reviewed survey record Observations and Findings On May 13,1998, an RP technician was performing routine reviews of the turbine building areas and noticed that the area containing the control rod drive (CRD) suction filters did not have a radiological posting. As this did not appear normal, the technician performed surveys and measured radiation levels of about 28 millirem per hour (mrem /hr) on contact with one of the filter housings and 8 mrem /hr at 30 centimeters (cm) from the filter housings. The technician posted the area as a radiation area and notified RP supervision of the proble _
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The RP manager and the supervisor - radiological operations reviewed the incident to determine the cause of the discrepancy. Based on RP logs and survey records, the RP staff noted that the area had been posted as a contaminated area and a radiation area on April 28,1998; however, the area was decontaminated between April 28 and April 29. Following the area decontamination, an RP technician performed a contamination survey and removed the posting from the area. Based on the survey record, the technician performed surface contamination measurements, which did not detect any removable contamination, but the technician did not perform / record any area radiation levels. Following the onsite portion of this inspection, the supervisor-radiological operations interviewed the RP technician, who acknowledged that he had mistakenly removed both the contaminated area and radiation area postings from the area on April 29,199 The RP staff also identified that RP technicians and an RP supervisor failed to identify this area during routine surveys of the area. During a review of the surveys of the area, the inspector observed that the RP staff had performed two additional, routine surveys in the CRD filter area on May 6,1998, and May 13,1998. These weekly surveys were performed to monitor radiation levels at reference points within the plant. On both survey documents, two independent RP technicians measured and recorded radiation levels of 6 and 8 mrem /hr, respectively,in the general area of the CRD filters. However, the survey documents did not indicate that a radiation area was posted, and the individuals did not recognize the discrepancy between the measured radiation levels and the area posting. An RP shift supervisor also reviewed / approved the survey records and failed to identify the problem. The RP manager indicated that these surveys did not meet his expectations and acknowledged that the two RP technicians and the shift supervisor missed two opportunities to identify and to correct the postin CFR 20.1901(a) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." As defined in 10 CFR Part 20, a radiation area is an are accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source or from any surface that the radiation penetrates. The failure to post the CRD filter area with a sign bearing the radiation symbol and the words " CAUTION, RADIATION AREA" is a violation of 10 CFR 20.1901(b) (VIO 50-461/98010-04).
Although the licensee identified and corrected this violation, the RP staff, who are responsible for implementing and monitoring the radiation protection activities, missed two opportunities to identify and correct the violation. As described above, two RP technicians performed surveys in the CRD filter area, measured and recorded general area radiation levels in excess of 5 mrem /hr, but did not identify the lack of an appropriate radiation area posting. In addition, an RP supervisor reviewed the survey records and also did not identify the posting violation. Based on these missed opportunities, discretion has not been applied, and the violation is cite During the inspection, the inspector also reviewed other survey documents and performed independent measurements to verify the documented results. Although no
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discrepancies were identified concerning the radiation levels on the survey records, the inspector observed that radiological postings and boundaries were not consistently indicated on the reference point surveys. The RP staff acknowledged the problem and indicated that management's expectations (as documented in a standing order) were to document the boundaries and postings on the reference point survey document Conclusions l
A violation was identified concerning the failure to post a radiation area in the CRD filiar area within the turbine building. Although the licensee identified this violation, the RP staff missed two prior opportunities to identify and correct this violation. On two independent radiological surveys, RP technicians measured and documented radiation levels in the CRD filter area which would have required a radiation area posting but did not recognize that the area was not properly poste R7 Quality Assurance in RP&C Activities R7.1 Assessments of the Radiological Environmental Monitoring Program Insoection Scoce (IP 84750)
The inspector reviewed the results of audits and assessments of the conduct of the REMP. In addition, the inspector discussed the audit findings and corrective actions with RP personne Observations and Findinas The licensee's quality assurance department conducted two reviews of the REMP in 1997 and 1998. The inspector reviewed the reports of these assessments, which were good in depth. During these reviews, the auditors examined the content of the annual reports, observed sample collections, and reviewed the material condition of REMP instrumentation. Overall, the audits found the REMP to be implemented in an acceptable manner; however, the auditors identified problems with the operability of REMP instrumentation. For example, the auditor found one air sampling pump to be inoperable and determined that the reliability of the instrumentation was in need of improvement. As corrective actions, the licensee replaced numerous air sampler timers and had plans to replace air sample pumps and composite water samplers (Section R1.3).
On April 1,1998, the licensee also performed an assessment of the vendor laboratory, which was used to analyze REMP samples. The audit was a thorough review and identified problems concerning the vendor's quality control program. Although the auditors verified that the laboratory's analytical performance was acceptable, the audit documented notable weaknesses in the vendor's quality control documents, review of the quality control program, and implementation of the program requirements. For example, the auditors identified that the vendor's quality control officer had not performed annual inspections in accordance with the vendor's quality control manua .
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At the time of this inspection, the RP staff was completing its review of the audit findings and planned to perform additional reviews of vendor activities in the futur Conclusions Quality assurance assessments of the licensee's REMP, including the performance of the vendor laboratory, were thorough. In particular, the audit of the vendor laboratory identified notable weaknesses in the vendor's implementation of its quality control program. The inspector observed that the RP organization was aware of the issues and was taking actions to address audit findings and recommendation R7.2 Radiation Protection Program Improvement Actions and Self Assessments Insoection Scoce (IP 83750)
The inspector reviewed the status of RP program improvement actions, including the results of assessments of RP performanc Observations and Findings The inspector discussed with the RP manager and supervisor - radiological operations the status of the RP staff's improvement actions. During this discussion, the RP manager discussed ongoing actions in several program areas including radiation worker performance, the ALARA program, instrumentation, and general program improvements. In particular, the RP manager indicated that radiation worker performance improvement actions were initiated to increase the RP staff's interaction l with plant organizations and to increase the presence of RP technicians and supervisors in the plant. For example, RP supervisors were performing plant tours with maintenance leaders and supervisors, and a greeter was periodically stationed at the entrance to the radiologically posted area. Although the RP manager recognized that the tours had not been performed on a regular basis and that plant department commitment to the greeter program had been a problem, the RP manager indicated that the goal of these initiatives was to improve the communication of RP requirements and changes in requirements with the other plant departments. In addition, plant (
management established a radiation worker accountability program to ensure that I personnel properly implement RP requirements. The licensee also placed additional ,
resources into the ALARA program to address previously identified weaknesses and I sent members of the RP staff to other NRC reactor licensee's to identify program improvements which could be implemente l The inspector reviewed selected assessments of the RP program which were performed by the RP staff. For example, the staff performed assessments of the extemal dosimetry program, the source control program, the free release program, contamination controls, and plant radiological conditions. Generally, the inspector found the assessments to be detailed and critical of RP performance. Based on the assessment findings and the RP staff's trending of RP-related condition reports, the inspector noted some reduction in the number and frequency of problems related to
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radiation worker practices. However, the RP staff identified continued problems conceming the proper use of the licensee radiation work permit (RWP) access control system and of the personnel contamination monitors at the control room entrance. In addition, RP technician performance problems (Sections R4.1 and R4.2) continued to be a challeng Conclusions The RP staff continued to initiate improvement actions to address radiation worker practices and RP program weaknesses and to perform self assessments to monitor performance. Although some reduction in radiation worker problems was noted, the inspector observed that radiation worker practices and RP technician performance continued to be a challenge. The inspector also noted that planned RP improvement actions were not always met with a high level of plant-wide commitmen R8 Miscellaneous RP&C lssues J R8.1 [Qoen) Violation (VIO) No. 50-461/96412-13: The licensee failed to restrict access to the drywell in accordance with the radiological safety work plan (RSWP). In addition to the immediate corrective actions documented in NRC Inspection Report No. 50-461/96012(DRS), the inspector verified that the licensee had completed the following corrective actions to prevent recurrence:
. The licensee implemented revision 2 of RSWP No. 96-01, "RF-6 Drywell Work During Refueling Operations," to clearly prohibit work above the 790' elevation of the drywell when the RSWP was in effect, to require written documentation for the authorization of additional work under the RSWP, and to provide a formal mechanism to temporarily suspend the RSW * On November 15,1996, the licensee communicated the details of the event to the RP shift supervisors and the RP technicians via the " Rad Ops Comm Line."
. On November 19,1996, the designated RP manager issued a memorandum to the staff to clearly delineate the authority of the en-shift RP shift superviso However, the inspector recognized that the licensee had not completed all of its corrective actions which were transmitted in the July 9,1997, letter from the licensee to the NRC concerning this violation. For example, the licensee had not completed its ,
review of the station procedure on RSWPs, which was to be completed by July 15, l 1998. In addition, the licensee planned to provide a briefing on the upper drywell RSWP requirements to task managers and supervisors of individuals working in the upper drywell prior to the next refueling outage. The completion of these corrective actions will l be reviewed in a subsequent inspectio R8.2 (Closed) VIO No. 50-461/96412-14 and 50-461/97013-01a: Violation of station procedures concerning the inadequate response to personnel contamination monitor l (PCM) contamination alarms. As documented in NRC Inspection Report No. 50-17 !
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461/97013(DRS), the licensee identified an additionalincident in 1997. In addition to the immediate corrective actions documented in NRC Inspection Reports No. 50-461/96012 l (DRS) and 50-461/97013(DRS), the inspector verified that the licensee had completed l the following corrective actions to prevent recurrence:
. Licensee management counseled the involved individuals and ensured that they understood that RP staff were to be notified in the event of two consecutive alarms at a PCM. The licensee also issued generic communications to the plant staff to address the proper response to PCM alarms and to provide examples of RP occurrences that would be considered condition reportable event Training Guide No. LP10141, "GET-SECURITY," was revised on May 8,1997, to include clear instruction on the proper use and response to PCMs. The guide stressed that all PCM alarms should be treated as contamination alarms and that an individual was required to wait for RP staff assistance if a second alarm was obtaine . To provide a simpler reference point for radiation workers, the licensee consolidated radiation worker requirements into five procedures: (1) CPS N .21 (Revision 0, dated October 31,1997)," Radiological Controlled Area Access and Exit;" (2) CPS No.1900.22 (Revision 0, dated October 31,1997),
" Radiological Posting and Barricades;"(3) CPS No.1900.23 (Revision 0, dated October 31,1997), " Work Place ALARA;" (4) CPS No.1900.25 (Revision 0, dated October 31,1997), " Radioactive Material Control;" and (5) CPS N .26 (Revision 0, dated October 31,1998), "Use of Radiological Work Documents."
= To reduce the frequency of false alarms, the licensee upgraded the PCMs at the protected area exit. The licensee also installed upgraded PCMs at the RPA exit to discriminate PCM alarms attributable to rado The inspector also verified that the RP organization provided two radiation worker checklists to the operations, maintenance, and facilities departments for inclusion into their assessment programs. These checklists provided examples of RP issues and/or areas to monitor. In early 1998, the operations and facilities staffs completed i assessmeNs of RP practices within their departments. In addition, the maintenance j staff had incorporated RP observations as part of its routine assessment activitie !
Although these assessments addressed certain aspects of the checklists, the RP staff !
indicated that further enhancements were planne As indicated above, the licensee continued to identify problems conceming workers response to PCM alarms throughout 1997. However, the licensee had not identified any l recent occurrences. During this inspection, tt e inspector also observed personnel l properly using the PCMs located at the RPA end protected area exit. This violation is close l l
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R8.3 (Closed) VIO No. 50-461/96412-15: The licensee identified evidence of sleeping and smoking areas within the RPA. As documented in NRC Inspection Report No. 50-461/98002(DRS), the licensee implemented corrective actions to address the original violatbn and to address additional examples identified in 1997. At the time of this inspection, the licensee located an additional area that appeared to have been used for sleeping within the turbine building. Since scaffolding had to be constructed to access this area, the licensee was confident that the area had not been recently established. In addition, the licensee had not identified any additional sleeping areas which could be attributed to current worker performance. The inspector also performed walk-downs of the RPA and did not identify any similar areas. This item is close .
I R8.4 (Closed) VIO No. 50-4fil/96412-16: An individual failed to remove nrotective clothing when exiting a contaminated area, as required by plant procedures. As immediate corrective actions, the licensee performed a survey of the area outside of the contaminated area which the individual entered (no contamination was identified) and counseled the individual. Since the licensee attributed the violation to a generallack of sensitivity to radiological work requirements, the licensee implemented the actions {'
described in Section R8.2 to prevent recurrence. As described in Section R8.2, the RP staff observed a reduction in radiation worker performance incidents; however, radiation worker performance continued to be a challenge. The NRC will continue to assess radiation worker practices and licensee oversight of radiation worker performance as a routine aspect of future RP inspections. This violation is close R8.5 (Ocen) VIO No. 50-461/96412-17: The failure to implement an adequate procedure resulted in the spread of contamination during radioactive waste sluic:ag operations. As )
immediate corrective actions for the incident, the licensee decontaminated the workers, perfornied dose assessments, surveyed and posted the affected area, and placed a hold on all sluicing operations pending a review of the circumstances and corrective actions. Following the incident, the licensee also placed the applicable pressure gauges within its calibration prograrn and obtained a sluicing wand which conformed to the vendor's drawings / instructions. To prevent recurrence, the inspector verified that the licensee had performed the following actions:
- The licensee counseled the RP technician and contract radioactive waste i technician and instructed the individuals that they were to notify management if I
similar problems were experienced in future evolution * Human error reduction training was attended by the RP departmen * The staff revised the vendor's procedure and implemented the procedure as station procedure No. CPS-P-03-028 (Revision 0, dated August 5,1997),
"Clinton Power Station Waste Sluicing Procedure." This revision required that management be notified in the event of an abnormal event, addressed the installation of a vent-divert valve, and was reviewed and approved by appropriate station personnel, which included RP representatives. The staff also reviewed other vendor procedures and implemented similar revisions. To ensure that
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procedures remained current, the licensee incorporated a task assignment to review the procedures on a 24-month frequenc During th s inspection, the inspector discussed these actions with a member of the RP staff. Although the procedure revision described above provided a generalinstruction to contact management in the event of abnormal events, the inspector observed that the procedure did not provide specific warnings or contingencies in the event of line blockage (also noted in NRC Inspection Report No. 50-461/96012(DRS)). The RP staff acknowledged this but planned to provide more specific instructions in the RWP and the pre-job briefing sheet to address this issue. The staff also indicated that the circumstances surrounding the January 1997 incident were planned to be discussed during pre-job briefings for future evolutions. Although no similar sluicing evolutions had occurred since the January 1997 incident, the staff planned to sluice contaminated resins from drums into a high integrity container within the next few months. The inspector planned to review the preparation, controls, and conduct of that evolution to determine the effectiveness of the licensee's corrective action R8.6 (Closed) VIO No. 50 461/96412-18: The licensee failed to perform an adequate radiological evaluation prior to disconnecting a clogged sluicing line. To correct this violation and to prevent recurrence, the licensee performed the actions described in Section R8.5. An assessment of the effectiveness of the licensee's corrective actions will be tracked as VIO No. 50-461/96412-17. This item is close R8.7 (Onen) VIO No. 50-461/96412-B The licensee failed to perform an adequate radiological evaluation prior to removing insulation. As imrnediate actions for this incident, the RP staff decontaminated the four individuals involved, surveyed and posted the effected areas as contaminated areas, and subsequently decontaminated and released the area. The inspector verified that the licensee had completed the following actions to prevent recurrence:
. The training staff implemented revision 2 to Training Guide No. LP32083,
" Radiological Systems," on November 19,1997. The inspector noted that the revision included a caution section which addressed factors which could cause the differential pressures between primary to secondary containment to be outside of their normal range, including the change in the status of equipment hatches during refueling activitie . The RP staff implemented revision 1 of Radiation Protection Work Instruction N , " Radiological Job Coverage," on April 22,1997. The inspector verified that the revision contained the caution to verify the air flow in the work areas to ensure the minimization of the spread of contamination. The staff also implemented revision 3 to Radiation Protection Werk Instruction No.112. "RWP Administration," on April 17,1997. The inspector verified that the revision contained the statement that the requirements from ALARA job reviews, RSWPs, and respiratory protection evaluations were incorporated into RWPs. In addition, the work instruction contained a section which addressed conservative decision making with respect to RWP development.,
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. The RP staff also implemented RP-2007-02,"RWP Initiation Checklist," dated August 22,1997. This checklist contained provisions to ensure that the requirements from ALARA job reviews, RSWPs, and respiratory protection evaluations and ventilation needs were incorporated into RWP The effectiveness of these actions will be reviewed in subsequent RP inspection V. Management Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on May 15,1998. The licensee acknowledged the findings presented. During the meeting, the licensee did not identify any proprietary information.
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PARTIAL LIST OF PERSONS CONTACTED G. Baker, Manager - Quality Assurance W. Bousquet, Director - Plant Support Services
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M. Byrd, Plant Engineering l R. Campbell, RP&C l O. Carter, RP&C l M. Dodds, Experience Assessment J. Forman, Licensing G. Hunger, Jr., Manager - Clinton Power Station M. Lewis, RP&C W. MacFarland, Chief Nuclear Officer T. Miracle, RP&C J. Place, Director- RP&C J. Ramanuja, RP&C
- J. Sipek, Director - Licensing M. Stickney, Supervisor - Regulatory Interface INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904 Follow-Up - Plant Support
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ITEMS OPENED, CLOSED OR DISCUSSED Open 50-461/98010-01 NCV Failure to propedy implement surveillance procedures for meteo ological monitoring equipment (Section R2.1).
50-461/98010-02 NCV Inadequate survey of airbome radioactivity (Section R4.1).
50-461/98010-03 NCV Inaccurate information on required survey document (Section R4.1).
50-461/98010-04 VIO Failure to post a radiation area (Section R4.2).
Closed 50-461/96412-14 VIO Failure to properly respond to PCM alarms (Section R8.2).
50-461/97013-01a VIO Failure to properly respond to PCM alarms (Section R8.2).
50-461/96412-15 VIO Unauthorized sleeping / smoking areas within the RPA (Section R8.3).
50-461/96412-16 VIO Failure to properly remove protective clothing (Section R8.4).
50-461/96412-18 VIO Inadequate radiological evaluation for radioactive waste sluicing operations (Section R8.6).
Discussed 50-4E1/96412-13 VIO Failure to restrict access to drywell in accordance with RSWP (Section R8.1).
50-461/96412-17 VIO Inadequate procedure for radioactive waste sluicing operations (Section R8.5).
50-461/96412-19 VIO Inadequate radiological evaluation for insulation removal (Section R8.7).
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LIST OF ACRONYMS USED i
ALARA As-Low-As-Is-Reasonably-Achievable l CRD Control Rod Drive l
ED Electronic Dosimeter IP inspection Procedure l MRRR Minor Radiological Risk Record l .NCV Non-Cited Violation NVLAP National Voluntary Laboratory Accreditation Program ODCM Offsite Dose Calculation Manual ORM Operational Requirements Manual PCM Personnel Contamination Monitor REMP Radiological Environmental Monitoring Program Rlll:Ol Region lli Office of Investigation RP Radiation Protection RPA Radiologically Posted Area RSWP Radiological Safety Work Plan RWP Radiation Work Permit SCFH Standard Cubic Feet per Hour SDE Shallow Dose Equivalent SRD Self Reading Dosimeter TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter TODE Total Organ Dose Equivalent TS Technical Specifications VIO Violation
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LIST OF DOCUMENTS REVIEWED Condition Reports Nos. 1-96-10-361,1-96-11-032,1-98-05-125, and 1-98-05-18 CPS Form No. 1512.01D001," Calibration and Maintenance Record," for Equipment ID No.:
FM 1000, performed on November 2,1996; FM 1097, performed on October 30,1996; FM 1012, performed on October 30,1996; FM 1014, performed on October 30,1996; FM 1001, performed on October 30,1996; FM 1006, performed on October 30,1996; FM 1098, performed on October 30,1996; FM 1002, performed on October 30,1996; FM 1005, performed on October 30,1996; and FM 1003, performed on October 30,1996.
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CPS Form No. 3843.01C001,"Enviror' mental Monitoring Monthly Preventive Maintenance l Checklist," dated April 4,1997; May S.1997; May 28,1997; July 12,1997; August 12,1997; September 12,1997; October 13,1997; November 11,1997; December 10,1997; January 9, 1998; and March 10,199 CPS Form No. 3843.01C002, * Environmental Monitoring Monthly Control Room and TSC Recorder Checklist," dated August 12,1997; September 12,1997; October 13,1997; November 11,1997: December 10,1997; January 9,1998; February 9,1998; and March 10, 199 ;
CPS Form No. 7700.02F001,"Panasonic Model UD-716AGL TLD Reader Calibration Record,"
dated December 10,1997, and May 5,199 CPS Form No. 7911.33F001," Composite Water Sampler Volume Programming Form," dated January 9,1998, and April 16,199 CPS Memorandum:
From D. Wells to R. Campbell,"Self Assessment of the Radioactive Source Dntrol J Program " dated May 5,199 I From D. Wells to J. Ramanuja,"Self Assessment of Free Release Program," dated 1 December 9,199 From D. Wood to P. Yocum, " Plant Radiation and Chemistry Self-Assessment Status Reports for the Third Quarter of 1997," dated September 29,199 From Lemons, Gaghan, and Wellman to M. Dodds," Radiological Self Assessment:
Engineering Controls," dated October 13-17,199 __ _ _ - _ . . . _ _ _ _ . _ _ _ _ _ _ _ ________.__________o
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From D. Hall, W. Janisch, and T. Rigg to M. Dodds, "Self-Assessment of Posting Verification," dated October 31,199 From J. Barstow, R. Gaghan, M. Underwood, J. Fowler, R. Kelling, and C. Lemons to Dodds," Contamination Controls," performed December 17-19,199 Froa T. Rigg and W. Janisch to M. Dodds, " Equipment Readiness," performed December 27,1997 through January 2,199 From J. Wade to M. Dodds, *RP Self-Assessment on Radioactive Source Control and Accountability CPS No. 1907.20," dated January 13,199 From T. Boddy, M. Craig, and H. King, Jr. to M. Dodds, " Engineering Controls Readiness," dated January 26,199 From B Team to M. Dodds, " Posting Verification," dated February 1 - 6,199 From B. King, E. Baughman, and D. Hall to M. Dodds, "AR/PR Self-Assessment," dated January 1,199 From M. Byrd to P. Telhorst, " Met. Tower Data Recovery," dated March 6,199 From D. Granberg to B. Campbell and M. Lewis, " Condition Report 3-98-02-070, Corrective Action 7 - Review of CPS Dosimetry Procedures Against 10 CFR 20 Requirements - Revision 1," dated March 31,199 CPS Procedure and Associated Forms CPS No. 9437.14," Meteorology System Loop Calibration," completed / approved on April 18,1997, and October 24,199 CPS Procedures:
CPS No.1024.15 (Revision 12), " Occupational Radiation Exposure Control and Monitoring;"
CPS No.1903.20 (Revision 16), "Extemal Exposure Monitoring;"
CPS No. 3843.01 (Revision 3), " Environmental Monitoring Monthly Preventive Maintenance;"
CPS No. 7105.02 (Revision 9)," Air Sample Assay;"
CPS No. 7179.16 (Revision 6), * Radiological Environmental Grass / Meat Sampling;"
CPS No. 7700.01 (Revision 4), "TLD Quality Control Program;"
CPS No. 7700.02 (Revision 2)," Calibration of the Panasonic Model UD-716AGL TLD Reader;"
CPS No. 7700.04 (Revision 3), " Processing Panasonic TLDs;" and CPS No. 7701.08 (Revision 1), " Exposure Investigations."
CPS No. 8699.19 (Revision 5)," Calibration of Gas Rotameters;'
CPS No. 9911.70 (Revision 33)," Radiological Environmental Surveillance Airbome Radiolodine and Particulate Monitoring;"
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CPS No. 9911.71 (Revision 28), " Radiological Environmental Surveillance Milk Monitoring;" and CPS No. 9911.79 (Revision 25), " Radiological Environmental Surveillance Ground Water Monitonng."
Quality Assurance Assessment Report of Radiological Environmental Monitoring Program, N , dated April 3,1998.
i Quality Assurance Audit of Radiological Environmental Monitoring Program, No. Q38-97-06, dated June 6,199 j Quality Assurance Audit of Teledyne Brown Engineering Environmental Services, No. Q38-98-12, dated April 15,199 Radiological Surveys Nos. 98-04-28-16,98-04-29-12,98-05-06-13,98-05-13-08, and 98-05-13-2 Radiological Technical Evaluation No. 97-020-ED (Revision 0), " Electronic Dosimeter /Thermoluminescent Dosimeter Dose Comparison Eva!uation."
Self Assessments:
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" RAM Tags," performed by B. King and E. Baughma " Assessment on the Use and Control of RWP's," dated September 17,199 "ALARA Self-Assessment," dated April 30,199 I i
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