IR 05000498/1999007
| ML20206B332 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/22/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20206B331 | List: |
| References | |
| 50-498-99-07, 50-498-99-7, 50-499-99-07, 50-499-99-7, NUDOCS 9904290212 | |
| Download: ML20206B332 (16) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
50-498 50-499 License Nos.:
NPF-76 NPF-80 Report No.:
50-498/99-07 50-499/99-07 Licensee:
STP Nuclear Operating Company Facility:
South Texas Project Electric Generating Station, Units 1 and 2 Location:
FM 521 - 8 miles west of Wadsworth Wadsworth, Texas i
Dates:
April 5 to 9,1999
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inspector:
Michael P. Shannon, Senior Radiation Specialist Approved By:
Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment :
SupplementalInformation
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9904290212 990422 PDR ADOCK 05000498
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E-2-l EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report No. 50-498/99-07; 50-499/99-07 This announced rout'ine inspection' reviewed the radistion protection program focusing on Unit 1 refue' ng outage activities. Areas reviewed included: exposure controls, planning and d
preparation, controls of radioactive material and contamination, surveying and monitoring, the program to maintain occupational exposure as low as is reasonably achievable (ALARA),
contractor training and qualifications, and quality assurance in radiation protection activities.
Plant Suooort Overall, the 'extemal exposure control program was effectively implemented. High
radiation areas were properly controlled and posted in accordance with regulatory requirements. Radiation work permits and area radiological survey maps were written clearly and provided station workers with the appropriate controls and radiological
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information to safely accomplish assigned tasks. An excellent pre-job ALARA briefing
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was provided to the workers involved with the core barrel lift work (Section R1.1).
Two examples of a violation of Technical Specification 6.8.1 were identified which
involved the failure to follow radiation work permit instructions. These violations were placed in the licensee's corrective action program as Condition Reports 99-5232 and
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-99-5374. These Severity Level IV violations are being treated as a Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy (Section R1.1).
Housekeeping throughout the radiological controlled area was good. In general, areas
were free of debris; tools and equipment staged for work activities were properly controlled (Section R1.1).
A good internal exposure control program was in place.- Continuous air monitors,
portable air samplers, and high efficiency particulate air filter ventilation units were appropriately used to monitor and evaluate radiological conditions and limit airborne exposures, during work evolutions. No problems were identified with the whole-body counting and internal dose assessment programs (Section R1.2).
. Radiological cutage work planning was good. Radiological work tasks were well
planned, and ALARA personnel were appropriately involved during the outage planning stage. Post-job briefings captured lessons learned from craft workers and radiation protection personnel. The ALARA plan and nadation work permit used for the core barrel support lift properly incorporated lessy.s leamed from the industry and appropriate radiological controls and hold points (Section R1.3).
Effective controls were implemented to prevent the spread of radioactive materials.
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Workers exiting the radiological controlled area used the contamination monitoring
equipment in accordance with radiation safety training materia!.. Radiation protection o
personnel provi@d appropriate and timely direction to workers who alarmed the contamination m^nitoring cquipment. Radiation worka' used good health physics a
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-3-practices during the removal of potentially contaminated clothing. Good controls to prevent the spread of radioactive contamination were in place (Section R1.4).
Health physics personnel located at the 68-foot Unit 1 reactor containment building
radiation protection control point did not have a complete set of Unit 1 reactor containment building radiological survey records needed to inform Unit 1 reactor containment building ' workers of the radiological conditions in the work area. The 68-foot Unit 1 reactor containment building radiation protection control point was crowded and congested. Radiation protection personnel were not sasily identifiable to workers (Section RI.4).
A violation of 10 CFR 20.1501(a) was identified involving the fatiure to perform a
radiological survey. This Severity Level IV violation is being treated as an NCV, consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as Condition Report 99-5232 (Section R1.4).
A good ALARA program was maintained. The 1999 Unit 1 refueling outage dose goal
of 160 person-rem was established using past best performance and industry experience for similar scope work. Station department managers and the ALARA committee were appropriately involved in establishing outage exposure goals.
Chemistry controls reduced reactor coolant system dose rates by about 10 cercent (Section R1.5).
A good contract radiation protection technician qualification program was maintained.
- Radiation protection management was appropriately involved in the contract radiation protection program. Qualification cards included all the tasks assigned to contract radiation protection technicians (Section R5.1).
An effective quality assurance program was maintained. The primary auditor was well
qualified to perfor n radiation protection audits / assessments. The audit and monitoring reports were comprehensive and provided management with a good assessment of the radiation protection program. The station identified radiological concerns and issues at the proper threshold which provided management with a good perspective to assess the radiation protection program (Sectior '17.1).
The failure to lock or guard a Unit 2 reactor containment building door which provided
access to a Technical Specification required locked hk)h radiation area was identified as an unresolved item pending further NRC review. This item was placed in the licensee's corrective action program as Condition Report 98-15247 (Section R7.1).
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Report Details Summary of Plant Status
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Unit 1 was in the second week of a 29-day scheduled refueling outage during this inspection.
Unit 2 operated at full power.
IV. Plant Support R1 Radiological l'ratection and Chemistry Controls R1.1 External Exocsure Controls a.
Inspection Scoce (83750)
Selected radiation workers and radiation protection personnelinvolved in the external exposure control program were interviewed. Several tours of the Unit 1 reactor containment building and radiological controlled areas of Unit 1 and 2 were performed.
The following items were reviewed:
Control of high radiation areas
Radiological controlled area access controls
Personnel dosimetry
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Radiation work permits
Job coverage by radiation protection personnel a
Housekeeping in the radiological controlled area
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Observations and Findinas High radiation areas were properly controlled and posted in accordanco with regulatory requirements. All Technical Specification required doors were properly locked, and flashing lights were working and appropriately used in accordance with regulatory requirements. All radiological postings were clearly and consistently posted.
Field interviews with radiation workers revealed that, in general, workers were knowledgeable of the radiological conditions in assigned work areas and knew the proper response to electronic dosimeter alarms. All workers observed wore doumetry paperly. During tours of the Unit 1 reactor containment building, the inspector observed that workers appropriately used the flashing green light ALARA low dosre waiting areas in accordance with manacw sot's expectations, in general, radiation protection job coverage was appropriate for radiological work observed. Radiation work permits and area radiological survey maps were written clearly and provided workers with the appropriate controls and radiological information to safely accomplish tasks. However, on April 5,1999, the inspector identified two individuals, signed in on Radiation Work Permit 99-1-138, Revision 0, to perform work on the Digital Rod Position Indication System (on top of the reactor head), that did not fo!!ow radiation work permit instructions. Specifically, these individuals did not obtain a
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-5-pre-job briefing from health physics personnel, prior to the start of work activities, to verify work area radiological conditions. Additionally, based on an interview with one of the two individuals, the inspector concluded that the individual did not know the work area radiological conditions. Technical Specification 6.8.1 requires procedures for the radiation work permit system. Section 6.2.3 of Procedure OPGP03-ZR-0051,
" Radiological Access and Work Controls," Revision 10, stated, in part, that radiation work permit instructions shall be adhered to at all times. The failure to follow radiabon work permit instructions was identified as a first example of a Technical Specification 6.8.1 Violation.' On April 5,1999, this violation was placed in the licensee's corrective action program as Condition Report 99-5232.
On April 7,1999, the inspector identified that an individual signed in on Radiation Work Permit 99-1-94, Revision 1, to perform work in the cable trays located in the overhead of the 52-foot elevation of Unit 1's reactor containment building, did not follow the radiation work permit instructions. Specifically, this individual did not notify radiation protection personnel prior to accessing areas greater than 6 feet above the floor. The failure to follow radiation work permit instructions was identified as a second example of a Technical Specification G.8.1 Violation. On April 7,1999, this violation was placed in the licensee's corrective action program as Condition Report 99-5374. These two examples
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of Severity LevelIV Violations are being trea ad as a Non-Cited Violation consistent with i
Appendix C of the NRC Enforcement Policy (50-498;-499/9907-01).
On April,7,1999, the inspector attended a pre-job ALARA briefing for the Unit 1 core barrel lift. The briefing was conducted in a professional manner. Lead group personnel discussed the job scope in detail. The radiation protection supervisor distributed a copy of the radiation work permit and radiological survey information to each worker involved in the task and effectively used the white dry eraser board to re-enforce the staging areas and the projected radiological conditions. The radiation work permit, survey data, and ALARA work plan were discussed in detail. Radiological hold points, turn back conditions, and stop work authority were clearly communicated. Additionally, the day shift health physics division manager appropriately emphasized important radiological conditions and hold points. The inspector concluded that, overall, an excellent pre-job ALARA briefing was provided to the workers involved with the core barrel lift work.
During tours of the radic!cgical controlled area, the inspector observed a number of radiological work activities. In genera!, workers followed good health physics practices and radiation protection technician support was appropriate. The inspector closely followed the reactor core barrellift task. Health physics supervisor and technician support were excellent and provided the workers with the radiological information, conditions, and controls to safely accomplish assigned tasks.
Housekeeping throughout the radiological controlled area was good. In general, areas were free of debris; tools and equipment staged for work activities were properly controlled.
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Conclu'sions Overall, the external exposure control program was effectively implemented. High radiation areas were properly controlled and posted in accordance with regulatory j
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radiologicalinformation to safely accomplish tasks. A first example of a Technical Specification 6.8.1 Violation was identified which involved the failure to follow radiation work permit instructions. This violation was placed in the licensee's corrective action program as Condition Report 99-5232 A second example of a Technical Specification 6.8.1 Violation was identified which involved the failure to follow radiation work permit instructions. This violation was placed in the licensee's corrective action program as Condition Report 99-5374. These two examples of Severity Level IV Violations are being treated as a Non-Cited Violation, consistent with Appendix C of the NRC
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Enforcement Policy. An excellent pre-job ALARA briefing was provided to the workers involved with the core barrellift work. Housekeeping throughout the radiological controlled area was good. In general, areas were free of debris; tools and equipment staged for work activities were properly controlled.
R1.2 Internal Exoosure Controls a.
Inspection Scoce (83750)
Selected radiatiori protection personnel involved with the internal exposure control program were interviewed. The following areas were reviewed:
Air sampling program, including the use of continuous air monitors and filtration
units Rescitatory protec: ion program
Whole-body counting program
The internal dose assessment program i
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Observations and Findinas Continuous air monitors, portable air samplers, and high efficiency particulate air filter ventilation units were appropriately used to monitor and evaluate radiological conditions and limit airborne exposures during work evolutions.
As of April 8,1999, there was one task which required respiratory equipment for radiological work. The inspector reviewed the control and issue programs for this equipment and identified no problerr,s. Additionally, the inspector reviewed the total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA) evaluation for tW above task, which was performed to ensure compliance with the requirements of 10 CFR Part 20, Subpart H, and concurred with the licensee's conclusions that respiratory protection equipment satisfied TEDE/ALARA principles. No problems were identified with the TEDE/ALARA evaluation performed to justify respiratory us F
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l-7-As of April 7,1999, there were 47 positive whole-body counts that occurred during the refueling outage. The highest calculated internal dose was approximately 48 mrem.
No problems were identified with the whole-body counting and internal dose assessment programs.
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Conclusions A good internal exposure control program was in place. Continuous air monitors, portable air samplers, and high efficiency particulate air filter ventilation un;ts were appropriately used to monitor and evaluate radiological conditions and limit airborne exposures during work evolutions. A proper TEDE/ALARA evaluation was performed to ensure compliance with the requirements of 10 CFR Part 20, Subpart H. No problems were identified with the whole-body counting and internal dose assessment programs.
R1.3 Plannina and Preparation a.
Insoection Scoce (83750)
Radiation protection department personnel involved in radiation protection planning and preparation were interviewed. The following items were reviewed.
ALARA job planning
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ALARA packages
Incorporation of lessons learned from similar work
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Supplies of radiation protection instrumentation, protective clothing, and
consumable items b.
Observations and Findinos Radiological work tasks were well planned, and ALARA personnel were appropriately involved during the outage planning stage. Post-job briefings captured lessons learned from craft workers and radiation protection personnel. At the completion of radiological work tasks, job history comments were provided to ALARA personnel for evaluation and incorporation into future similar radiological work packages. A review of selected radiological work packages revealed that lessons learned from past similar work and the industry were properly incorporated into the radiological work packages to improve job task performance. No problems were noted during the detailed review of the ALARA plan and radiation work permit used for the core barrel support lift. The plan incorporated lessons learned from industry, and the radiation work permit it'cludeu appropriate radiological controls and hold points.
From field observations, the inspector determined that there were no problems with the radiation protection support, instrumentation, protective clothing, and consumable supplies needed to support outage radiological wor i
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Conclusions
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Radiological outage work planning was good. Radiological work tasks were well planned, and ALARA personnel were appropriately involved during the outage planning
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stage. Post-job briefings captured lessons learned from craft workers and radiation j
i protection personnel. The ALARA plan and radiation work permit used for the core barrel support lift properly incorporated lessons learned from the industry and
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appropriate radiological controls and hold points.
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R1.4 Control of Radioactive Materials and Contamination: Surveyino and Monis ru c
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Inspection Scope (83750)
Areas reviewed included:
Contamination monitor use and response to alarms
Control of radioactive material
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Portable instrumentation calibration and performance checking programs
Adequacy of the surveys necessary to assess personnel exposure
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Observations and Findinas t
Workers exiting the radiological controlled area used the contamination monitoring I
equipment in accordance with radiation safety training material. Radiation protection personnel stationed at the egress point were attentive to personnel contamination monitor alarms and provided timely guidance and direction to workers who alarmed the monitors. The inspector observed radiation worker decontamination. The worker's contamination levels were correctly assessed and recorded prior to decontamination.
l Decontamination methods were appropriate to eliminate the possible spread of l
contamination. The worker's skin dose was properly assessed in accordance with l
station procedures.
l Personnel observed exiting radiological contaminated areas used proper health physics l
practices during the removal of potentially contaminated protective clothing. The use of l
step-off pad monitors eliminated congestion at contaminated area exits and effectively
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reduced the possible contamination of personnel during the removal of potentially contaminated protective clothing.
The licensee provided good controls to prevent the spread of radioactive contamination.
During radiological controlled area tours, the inspector noted that all radioactive material containers observed were labeled, posted, and controlled in accordance with station procedures and regulatory requirements. Contaminated areas were clearly identified and properly posted. Trash and laundry containers were maintained to prevent the spread of radioactive contamination.
All portable raJiation protection survey instruments observed throughout the plant were calibrated and source response checked in accordance with r e frequency described in station procedure l
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Independent radiological survey measurements performed during tours of the radiological controlled area confirmed that radiological postings were in compliance with i
station procedures and regulatory requirements.
At approximately 2 p.m. on April 5,1999, during a tour of the Unit 1 reactor containment building, the inspector identified two individuals working on a scaffolding platform erected on the north side of the reactor head. These individuals were performing work
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on the reactor head connector plates. From a review of radiological controlled area access records, the inspector determined that the scaffolding was erected on the previous day. Surveys of the work area created by the s?affolding were not performed before the individuals entered the area. On April 5,1999, at approximately 11 p.m., the licensee performed a radiation and contamination survey of the work area that indicated that general area dose rates and contamination levels were 2 to 6 mrem per hour and up to 10,000 dpm/100 cm2, respectively.10 CFR 20.1501(a) requires that each licensee make or cause to be made, surveys that are reasonable under the i
circumstances to evaluate the potential radiological hazards that could be present. The
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failure to perform a survey of the work areas created by the scaffolding was identified as a Severity Level IV violation of 10 CFR 20.1501(a) and is being treated as an NCV i
consistent with Appendix C of the NRC Enforcement Folicy. On April 5,1999, this violation was placed in the licensee's corrective action program as Condition Report 99-5232 (50-498;-499/9907-02).
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Health physics personnel located at the 68-foc,, 1 reactor containment building radiation protection control point did not have L co,1ete set of Unit 1 reactor containment building radiological survey records needed to inform Unit 1 reactor containment building workers of the radiological conditions in the work area. For example, although a radiological survey on top of the reactor head was performed on April 4,1999, a copy of the survey was not provided to the 68-foot reactor containment building radiation protection control point until the inspector asked about the radiological conditions on the reactor head (approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later). A second example pertained to a radiological survey of the cable trays on the 52 foot elevation in the reactor containment building. A survey of the area was documented on March 30,1999; however, it was not distributed to the 68-foot Unit 1 reactor containment building l
radiation protection control point until the inspector asked to review the radiological conditions in the area on April 7,1999. The inspector commented that the failure to i
provide copies of radiological survey records to field locations could cause work delays and additional radiation protection personnel exposure to obtain duplicate radiological i
surveys. Radiation protection management acknowledged the inspector's comment and
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stated that the process of distributing timely radiological information to the radiation protection field locations would be reviewed.
During tours of the radiological controlled area, the inspector observed that, at times, the 68-foot Unit 1 reactor containment building radiation protection control point was crowded and congested. Two groups of workers were required to check in with radiation protection personnel at this control point prior to starting work. One group was workers assigned to perform refueling activities. The second group was workers who worked outside the bioshield in the reactor containment building. Additionally, radiation protection technicians assigned to this control point were not easily identified to the workers. Radiation protection management stated that they would review the process of
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-10-checking in and identifying radiation protection personnel to address the inspector's observations.
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Conclusions Effective controls were implemented to prevent the spread of radioactive materials.
Workers exiting the radiological controlled area used the contamination monitoring equipment in accordance with radiation safety training material. Radiation protection j
personnel provided appropriate and timely direction to workers who alarmed the contamination monitoring equipment. Radiation workers used good health physics i
practices during the removal of potentially contaminated clothing. Good controls to
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prevent the spread of radioactive contamination were in place. A violation of 10 CFR 20.1501(a) was identified involving the failure to perform a survey. This Severity Level IV Violation is being treated as an Non-Cited Violation consistent with Appendix C of the NRC Enforcement Policy. This violation was placed in the licensee's corrective action program as Condition Report 99-5232. Health physics personnel located at the 68-foot Unit 1 reactor containment building radiation protection control point did not have a complete set of Unit 1 reactor containment building radiological survey racords needed to inform Unit 1 reactor containment building workers of the
radiological conditions in their work area. The 68-foot Unit 1 reactor containment building radiation protection control point was crowded and congested. Radiation protection personnel were not easily identifiable to workers.
R1.5 Maintainina Occuoational Exoosure As low As is Reasonably Achievable (ALARA)
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Insoection Scoce (83750)
Radiation protection personnelinvolved with the ALARA program were interviewed. The following areas were reviewed:
Unit 1 refueling outage exposure goal establishment and status
Temporary shielding program
Chemistry controls i
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Observations and Findinas From discussions with the licensee, the inspector determined that the 1999 Unit 1 refueling outage dose goal of 160 person-rem was established using past best performance and industry experience for similar scope work. The inspector noted that there was good involvement by ALARA committee members and department managers in the development of the outage dose goal. The inspector concluded that the outage dose goals were aggressive. Station and task activity doses were tracked and trended by the ALARA staff, and dose status was distributed daily to station tiepartments. A review of the daily ALARA report for April 7,1999, revealed that the licensee was under its outage dose goal by approximately 25 person-rem.
A good temporary shielding program was implemented. There were 14 tempora'f shielding package installations planned during the refueling outage. From discussions
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-11-with the ALARA staff, the inspector de'7rmined that installing the temporary shielding would save the station about 10 person-rem.
During discussions with chemistry personnel, the inspector determined that management support for shutdown chemistry controls was excellent. The shutdown chemistry controls were effective in removing approximately 900 curies of activity from the reactor coolant system. From a review of licensee supplied information, the inspector determined that chemistry controls effectively reduced reactor coolant system dose ratos by approximately 10 percent, c.
Conclusions A good ALARA program was implemented. The 1999 Unit 1 refueling outage dose goal of 160 person-rem was established using past best performance and industry experience for similar scope work. Station department managers and the ALARA committee were appropriately involved in establishing outage exposure goals. ALARA personnel properly tracked, trended, and distributed outage exposure status. The temporary shielding program effectively reduced outage exposure by approximately 10 person rem. Chemistry controls reduced reactor coolant system dose rates by about 10 percent.
R5 Staff Training and Qualification in Radiological Protection and Chemistry RS.1 Radiation Protection Staff Trainina j
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Insoection Scope (83750)
Personnelinvolved with contractor radiation protection technician training and resume evaluation were interviewed. The following items were reviewed:
Radiation protection technician outage qualification process
Resumes of contractor radiation protection technicians
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Radiation protection management over sight of the training program
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Observations and Findinas The licensee hired 56 contract radiation protection technicians to support outage
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radiological activities. The inspector reviewed randomly selected resumes and i
concluded that contract radiation protection technicians met or exceeded the technical experience recommendation of an ANSI 18.1 technician (2 years of radiation protection experience).
Lesson plans used for training contract radiation protection technicians included site and industry lessons-learned. Radiation protection management was involved in developing the qualification task topics. All contract radiation protection technicians were tested on site-specific information and station radiation protection procedures. The Northeast Utilities examination was used to assess the basic radiation protection technical knowledge of the contract radiation protection technicians.
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-12-On-the-job traini_g and evaluations were given before contract radiation protection technicians were assigned independent tasks. Based on a review of contract radiation protection technician qualification cards, the inspector determined that the qualification cards were well developed and included all the tasks assigned to contract radiation g
protection technicians.
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Conclusions A good contract radiation protection technician qualification program was maintained.
Radiation protection management was appropriately involved in the contract radiation protection program. Qualification cards included all the tasks assigned to contract
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radiation protection technicians.
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R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Ouality Audits and Monitorina Reports. and Radiation Department Self-Assessments and Radioloaical Condition Reports a.
Inspection Scope (83750)
Selected personnelinvolved with the performance of quality audits and monitoring reports, and radiation department self-assessments were interviewed. The following items were reviewed:
Qualifications of personnel who performed quality audits and monitoring reports
Quality audits performed since October 1,1998 O
i Quality monitoring reports performed since October 1,1998
Radiation protection department self-assessments performed since October 1,
1998 Y
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Observations and Findinas l
Quality Audits and Monitorina Reports One individual on a 2-year rotational assignment from the radiation protection department was assigned as the primary auditor to provide quality assurance oversight j
of the radiation protection program. From an interview with this individual, the inspector j
determined that this individual had a number of years of applied operational radiation
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protection experience and was registered by the National Registry of Radiation Protection Technologists.
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No problems were identified during the review of the audit schedule and plans pertaining to the radiation protection program. One radiological audit and 28 radiological
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-13-i monitoring reports were performed since the last inspection of this area in October
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1998. Three technical specialists from other nuclear power sites were used to support the licensee during the performance of the audit. The inspector determined that radiation protection and quality management were appropriately involved in developing the audit scope. No problems were noted during the review of the audit checklist used to perform the audit. Quality Audit Report 99-01 (RC) identified 11 deficiencies, 7 recommendations and one feedback item. All items were documented in the station's condition reporting system, and the quality department appropriately tracked these items. The audit and monitoring reports were comprehensive and provided management with a good assessment of the radiation protection program.
Department Self-Assessments I
Three radiation protection department self-assessments covering the areas of condition reporting process, health physics records, and general employee training were performed during this inspection period. The self-assessments provided management with a good evaluation of the areas reviewed. Findings were appropriately documented in the station's condition reporting system. No problems were identified during the i
review of these self-assessments.
Radioloaical Condition Reoorts The inspector reviewed a summary of condition reports written since October 1,1998, and selected 16 of these condition reports for a more in-depth review. In general, no problems were identified. The station identified radiological concerns and issues at the proper threshold to provide management with a good perspective to assess the radiation protection program. Overall, condition reports were closed in a timely manner.
During the review of these condition reports, the inspector noted that on October 4, 1998, the licensee identified and documented in Condition Report 98-15247 that a Technical Specification locked high radiatior, area gate which provided access to Room 201 in Unit 2's reactor containment building was propped open by a drum and not guarded from approximately 11:15 p.m. on October 3,1998, to i:30 a.m. on October 4, 1998. Technical Specification 6.12.2 requires that areas accessible to individuals with radiation levels greater than 1000 mrem per hour but less than 500 Rads per hour be provided with locked or guarded doors to prevent unauthorized entry. The failure to lock or guard the door which provided access to a Technical Specification required locked high radiation area was identified as an unresolved item pending further NRC review (50-498;-499/9907-03).
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Conclusions An effective quality assurance program was in roe. The primary auditor was well qualified to perform radiation protection audits / assessments. The audit and monitoring reports were comprehensive and provided management with a good assessment of the radiation protection program. Findings were appropriately documented in the station's corrective action system. The station identified radiological concerns and issues at the proper threshold which provided management with a good perspective to assess the radiation protection program. The failure to lock or guard a Unit 2 reactor containment
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-14-building door which provided access to a Technical Specification required locked high radiation area was identified as an unresolved item pending further NRC review. This item was placed in the licensee's corrective action program as Condition Report 98-15247.
V. Manaaement Meetinos X1 Exit Meeting Summary
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The inspector presented the inspection results to members of licensee management at an exit meeting on April 9,1999. The licensee acknowledged the findings presented.
No proprietary information was identified.
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ATTACHMENT f
PARTIAL LIST OF PERSONS CONTACTED Licenstg P. Arrington, Licensing Engineer W. Bullard, Hea!th Physicist Supervisor T. Cloninger, Vice President Nuclear Engineering W. Cottle, President and Chief Executive Officer J. Groth, Vice President Nuclear Operation S. Head, Licensing Supervisor S. Horak, Quality Specialist F. Mangan, Vice President Business Services R. Masse, Unit 2 Plant Manager M. McBurnett, Director Quality and Licensing T. Powell, Health Physics Manager M. Smith, Plant Support Quality Manager NRC
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i N. O'Keefe, Senior Resident inspector INSPECTION PROCEDURE USED
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83750 Occupational Radiation Exposure LIST OF ITEMS OPENED. CLOSED. and DISCUSSED Opened and Closed i
50-498;-499/9907-01 NCV Failure to follow radiation work permit instructions 50-498;-499/9907-02 NCV Failure to perform a survey Opened j
50-498;-499/9907-03 URI Failure to lock or guard access to a Technical Specification required locked high radiation area.
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LIST OF DOCUMENTS REVIEWED PROCEDURES OPGP01-ZA-0037-Radiation Protection OJT/ Qualification Program, Revision 4 OPGP07-ZR-0009 ' Performance of High Exposure Work, Revision 12
. OPRP03-ZR-0050 Radiation Protection Program, Revision 2 OPRP03-ZR-0051 Radiological Access and Work Controls, Revision 10 OPRP03-ZR-0053 '
Rac;ioactive Material Control Program, Revision 5 OPRP03-ZT-0138 '
Contractor Training and Qualification Program, Revision 3 OPRPO4-ZR-0013
' Radiological Survey Program, Revision 6 OPRPO4-ZR-0015 Radiological Posting and Warning Devices, Revision 6 Other Quality Audit 99-01 Radiological Controls /Radwaste
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Quality Monitoring Report MN-98-2-0773 Quality Monitoring Report MN 98-2-0788
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Quality Monitoring Report MN-98-2 0798 Quality Monitoring Report MN-98-2-0810
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. uality Monitoring Report MN-98-2-0860
Q Quality Monitoring Report MN-98-2-0883 Quality Monitoring Report MN-98-2-0886 Quality Monitoring Report MN-98-2-0926 Quality Monitoring Report MN-98-2-0927 Quality Monitoring Report MN-98-2-0928 Quality Monitoring Report MN-98-2-0932
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Quality Monitoring Report MN-98-2-0933'
i Quality Monitoring Report MN-98-1-1035 Quality Monitoring Report MN-99-1-0044 Quality Monitoring Report MN-99-1-0046 i
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l A summary of radiological condition reports written since October 1,1998, until April 1,1999 I
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