IR 05000529/1994024
| ML17311A181 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/02/1994 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17311A180 | List: |
| References | |
| 50-528-94-24, 50-529-94-24, 50-530-94-24, NUDOCS 9408150022 | |
| Download: ML17311A181 (32) | |
Text
APPENDIX U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-528/94-24 50-529/94-24 50-530/94-24 Licenses:
NPF-41 NPF-51 NPF-74 Licensee:
Arizona Public Service Company P.O.
Box 53999 Phoenix, Arizona Facility Name:
Palo Verde Nuclear Generating Station, Units 1, 2, and
Inspection At:
Mintersburg, Arizona Inspection Conducted:
July 11-21, 1994 Inspector:
Michael Cillis, Senior Radiation Specialist Facilities Inspection Program Branch Approved:
acne urray, ie Facilities Inspection Pr ranch at Ins ection Summar Areas Ins ected Units
2 and
Routine, announced inspection of radiation protection activities including:
audits and appraisals, changes, planning and preparations, training and qualifications, external exposure controls, internal exposure controls, controls of radioactive material and contamination, and the program to maintain occupational exposures as-low-as-reasonably-achievable (ALARA).
Results Units
2 and
Good audits were performed by qualified individuals (Section 2. 1).
Excellent communications and coordination existed between the radiation protection department and other departments (Section 2. 1).
The radiation protection department realignment had been completed.
The realignment appeared to have resulted in improvements concerning the implementation of the radiation protection program (Section 2.2. 1).
9408150022 9408i0 PDR ADOCK 05000528 Q
t f
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An Inspection Followup Item was identified involving the control of thermoluminescent dosimeters.
The licensee had not considered how they would continue to maintain positive control over the issuance and collection of thermoluminescent dosimeters when they convert over to a
"Palm Reading" security personnel access system (Section 2.2.2).
The licensee was well prepared for the Unit 2, mid-cycle outage (Section 2.3).
A challenging person-rem goal was set for the mid-cycle outage, and a
variety of advanced techniques were available for use to reduce exposures (Sections 2.3 and 2.7).
Training groups responsible for providing radiation protection training were sufficiently staffed with qualified instructors.
The training programs offered by the training organization remained strong and were staffed by experienced instructors.
An excellent radiation worker practical factors training course had been implemented (Section 2.4).
A high percentage of the radiation protection technicians were registered (certified) by the National Registry of Radiation Protection Technologists (Section 2.4).
The radiation protection group did not routine'ly screen qualification records of prospective contract radiation protection technicians that support outages (Section 2.4).
An effective permanent shielding program had not been established (Section 2.5).
A properly accredited dosimetry program which included state-of-the-art equipment was maintained (Section 2.5).
An excellent evaluation of electronic dosimetry devices was performed (Section 2.5).
The external exposure control program was very good.
Radiation areas, high radiation areas, and locked high radiation areas were posted and,
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properly controlled (Section 2.5).
An excellent program was implemented that challenged a worker's knowledge of the radiological conditions (Section 2.5).
An excellent contamination control program was in place.
Control of radioactive materials and contamination, surveys, and monitoring were good.
The number of personnel contaminations was low, housekeeping within radiological controlled areas was excellent, and excellent results were obtained by the licensee's program for control of contamination within each Unit (Section.
2.6 and 2.7).
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Several weaknesses were identified that involved trending of personnel contamination events and of exposure data, source term reduction, and evidence of workers smoking within the radiological controlled areas (Sections 2.6 and 2.7).
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The ALARA program was a strength (Section 2.8)
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Summar of Ins ection Findin s:
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Inspection Followup Item 528/9424-01; 529/9424-01; 530/9424-01 was opened (Section 2.2.3).
Attachments:
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Attachment Persons Contacted and Exit Meeting
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DETAILS
PLANT STATUS During this inspection, all three units were operating at approximately 100 percent power.
OCCUPATIONAL RADIATION EXPOSURE (83750)
The radiation protection program was inspected to determine compliance with the Technical Specifications, the requirements of 10 CFR Part 20, licensee procedures, and agreement with the commitments in the Updated Safety Analysis Report.
The inspection focused on the planning and preparations for Unit 2, mid-cycle outage which is scheduled to start on September 17, 1994.
The mid-cycle outage is scheduled to take approximately 29 days to complete.
2. 1 Audits and A
raisals The inspector reviewed the licensee's self-assessment program to determine compliance with Technical Specification and the Updated Safety Analysis Report.
The inspector reviewed selected radiation protection audits and self-assessments that were performed since the previous inspection.
No audits oF the radiation protection program had been accomplished since the previous inspection; however, the licensee's quality assurance staff was scheduled to perform an in-depth audit of the radiation protection program starting on or about July 18, 1994.
The inspector verified that the self-assessments were performed by personnel having expertise in the area of health physics.
The assessments offered good insight into daily operations related to the radiation protection activities.
The more significant assessment findings generally resulted in the initiation of one of the following for the purpose of documenting problems and to track corrective actions:
Condition Report Disposition Request equality Deficiency Report Material Non Conformance Report guality Assurance Recommendation Corrective Action Report Normally both audit and assessment findings were reviewed for probable cause and were trended for the purpose of identifying hidden problems which may require the implementation of additional corrective actions.
The inspector determined that good reviews were made of the assessment findings during weekly workshop meetings which were routinely held by the quality assurance and radiation protection groups.
The-workshop meetings were held for the purpose of discussing audit and assessment findings for corrective actions.
The workshop were helpful in the implementation of timely
and effective corrective actions.
The inspector noted that the cor rective actions proposed were technically sound and addressed the problems that were identified.
The assessments confirmed that the radiation protection programs were consistent with station procedures.
2.2
~Chan es The radiation protection department had been through a major realignment since it last was reviewed in NRC Inspection Reports 50-528/93-52, 50-529/93-52, 50-530/93-52 and 50-528/94-14, 50-529/94-14, and 50-530/94-14.
The realignment was instituted in response to the licensee's internal organization and programmatic review that was performed regarding the radiation protection organization.
The realignment was designed to change the organization from three separate unit radiation protection organizations to one centralized department.
The main objective for the realignment was to provide consistency and flexibility in the management of the radiation protection program.
The realignment started in March 1994 was recently completed.
Certain functions were centralized, such as:
routine plant operations for all three Units; central ALARA planning; a central radiation protection outage/maintenance group; support services group, which included radwaste and instrument/respiratory functions; technical assistant, which included radiological engineering, administrative/ALARA, and dosimetry functions.
The central ALARA planning group had been assigned the responsibility of preparing radiation exposure permits for all three Units, and the outage/maintenance group had the responsibility for the planning and preparation of outages.
A 10 CFR 50.59 evaluation was conducted prior implementing the realignment.
No unreviewed safety questions were identified from this review.
Additional, proposed changes to the Technical Specification, Updated Final Safety Analysis Report, and applicable procedures were submitted for inclusion in the next revision to these documents.
The revisions defined personnel responsibilities and levels of authority.
The 50.59 evaluation report, the proposed Technical Specification, and Updated Final Safety Analysis Report changes were reviewed by the inspector.
The licensee was considering performing a review within I year to determine if the objectives for the realignment had been achieved and, if the realignment resulted in an improvement of the radiation protection program.
The inspector noted that the realignment had resulted in several improvements, such as, coordination of radiation protection functions, communication within and outside the radiation protection department and in the attitudes and morale of the affected radiation protection staff.
The changes reviewed during this and the previous inspection did not adversely affect the radiation protection progra S?
2.2.2 Personnel The radiation protection department hired a health physicist.
The individual's training and qualifications were in compliance with Technical Specifications, Section 6 requirements.
2.2.3 Palm Readers The inspector noted that the Security Department was in the process of changing over to a "Palm Reading" system for personnel access and egress from the protected areas.
The current system, which is referred to as the ACAD system, utilized a photo identification card for gaining access to the protected area and vital areas located within the protected area.
The ACAD card was issued by the security force after entering the security building.
The ACAD card had been used to distribute and to collect thermoluminescent dosimeters that were assigned to workers needing to gain access to the radiological controlled areas or vital areas within each Unit. It had been convenient to attach the thermoluminescent dosimeters to the ACAD. It provided excellent control over the issue and return of the thermoluminescent dosimeters.
,Personnel will be able to take their ACADs home once the use of the "Palm Reader" is implemented.
Personnel will continue to use their ACAD for entering the vital areas.
However, the ACADs will no longer be used to issue and collect the thermoluminescent dosimeters.
The new "Palm Reading" system was scheduled for implementation in October of 1994.
The above concern was brought to the licensee's attention during the inspection and at the exit meeting.
The licensee acknowledged the inspector's concern regarding this issue.
The inspector asked the licensee's staff how they expected to maintain control over the issuance of thermoluminescent dosimeters.
At the time of this inspection, the licensee's staff had not yet determined how they intended to issue thermoluminescent dosimeters without sacrificing the current quality control provided by the ACAD system.
This is considered an Inspection Followup Item {528/9424-01; 529/9424-01; 530/9424-01).
2.3 Plannin and Pre arations The inspector reviewed planning and preparation activities to determine compliance with Technical Specification and agreement with licensee procedures and commitments in the Updated Safety Analysis Report.
Unit 2 was scheduled to star t a 29-day, mid-cycle outage on September 17, 1994.
The planning and preparations for the mid-cycle outage were reviewed during this inspection.
A copy of the Unit 2, mid-cycle outage report (U2NS-2) status meeting dated July 7, 1994, was reviewed.
Discussions
-7-related to the outage were held with the radiation protection outage and maintenance group.
The following information was obtained:
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The planning and preparations for the higher exposure work had been completed.
The ALARA reviews and person-rem goals had been established.
A person-rem goal of 75 person-rem and personnel contamination goal of 20 had been established for the outage.
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The licensee planed to conduct mock-up training for maintenance activities involving steam generator work.
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The licensee was planning for extensive use of engineering controls, such as auxiliary ventilation systems, and use of historical data during the outage.
The engineering controls and historical data along with air sampling results will be used to establish the radiological control and respiratory requirements for accomplishing work.
These requirements will be included on the applicable radiation exposure permit.
The inspector noted that a good supply of ventilation units were available.
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Approximately 50 radiation exposure permits will be required for outage work.
Most of these had been prepared at the time of this inspection.
High exposure jobs scheduled for the outage included:
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Steam Generator Inspections Installation of the Permanent Pool Seal Replacing Pressurizer Heaters Replacing Pressurizer Spray Valves Valve Maintenance and Repair The numbers of contract radiation technicians needed to supplement the permanent plant staff was under review at the time of this inspection.
The licensee was planning to supplement the Unit 2 radiation protection stafF with a minimum of 30 additional radiation protection technicians during the outage.
The 30 individuals may be composed of strictly contract personnel or a combination of contract personnel and technicians recruited from Units I and 3.
Contract technicians would be brought onsite early enough to complete site-specific training.
The contract. force was expected to included,a large number of persons who had worked previous outages at Palo Verde.
The licensee had sufficient supplies of protective clothing, respiratory protection equipment, radiological survey instrumentation, temporary shielding, and portable ventilation equipment to support outage activities.
The scope of Unit 2 mid-cycle was defined early the outage to allow adequate time for review by radiological controls reviews of outage related Radiation exposure permits generated from these radiological control requirements, ALARA prejob requirements related contamination control work enough prior to the start of all departments.
Excellent activities were performed.
reviews included the briefing requirements, and practice ~
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2.4 Trainin and ual ificati ons The inspector reviewed this portion of the licensee's program to determine compliance with 10 CFR 19. 12 and Technical Specification and agreement with commitments in the Updated Safety Analysis Report.
The licensee's radiation protection group had not developed a program for evaluating the qualifications and training of contract radiation protection technicians that were used to supplement the permanent radiation protection staff during the performance of maintenance or outage activities.
The radiation protection staff currently relied on the assigned vendor to supply qualified contract radiation protection technicians during outages.
This observation was discussed with the licensee's staff.
The licensee's staff stated that they relied on the vendor to supply them with contract personnel possessing the qualification as defined in the contract.
Screening examinations were used in the selection of contract radiation protection technicians.
Once selected, the contract radiation protection technicians were required to demonstrate proficiency in the licensee's procedures through a practical examination after completing a site-specific training course.
The extent of training provided to contract radiation protection technicians depends on whether the technician was a returnee or was new to Palo Verde.
Technicians that were new to Palo Verde were required to attend a more "comprehensive training program before they were assigned to perform plant activities.
Selected training records of contract radiation protection technicians were reviewed, and the inspector noted that the individuals had been given appropriate training.
The training group presenting general employee training and radiation worker training consisted of a group of well experienced instructors.
Excellent facilities and resources were available.
Each worker was required to attend a
comprehensive practical factors training course after completing initial or refresher general employee training.
The workers were required to demonstrate that entering and exiting from a radiologically controlled area in accordance with licensee procedures and posted instructions.
The training was geared towards emphasizing practical exercises involved in working in radiation and contaminated areas.
Hock-ups, mannequins, classroom instructions, video tape presentation, and simulated radiation exposure permits were. used, for this training.
Workers were graded on their overall performance and must receive a
passing grade or return to the initial general employee training program.
The inspector concluded that the licensee's general employee training program met or exceeded
CFR 19. 12 requirements and that the training provided to the radiation protection staff was consistent with Technical Specification requirements.
The radiation protection technician training group consisted of instructors who had previous radiation protection experience, and all were qualified instructors.
The group presented two cycles of continuing training per year.
The cycle training included discussions of hazards associated with plant systems and current industry events.
Other specialized training was presented during the past year to supplement the cycle training.
Vendors have been used at times to provide some of the specialized trainin The inspector determined that no new senior technicians had joined the radiation protection department since the last inspection; therefore, no resumes were reviewed during this inspection.
Many members of the radiation protection department and the training department were registered (certified) by the National Registry of Radiation Protection Technologists.
There was strong management support for the supervisor/technical training program.
Through a review of trip reports and interviews, the inspector confirmed that supervisors were provided opportunities to attend professional seminars, peer evaluations, or vendor-provided training.
The licensee maintained a continuing technical training program for radiation protection supervisors and professional staff.
The training consisted of vendor training, training on Industry Events, and professional meetings attended by professional staff members.
The inspector determined that the radiation protection organization had been very stable.
The turnover rate was low.
2.5 External Ex osure Control The inspector reviewed the external exposure control program to determine compliance wit'h 10 CFR Part 20, Technical Specification, licensee procedures, and agreement with commitments in the Updated Safety Analysis Report.
The licensee had recently completed the response testing of three different digital electronic dosimeters.
The purpose for the test was to determine certain response characteristics of the various electronic dosimeters.
Prior to performance of the response checks, each dosimeter was calibrated in accordance with the manufacture's procedure or a verification of the vendor's calibration was performed.
A copy of the licensee's evaluation report was reviewed by the inspector.
The tests included an evaluation of the dosimeters:
Accumulated Dose Linearity Indicated Dose Linearity Angular Dependence (Horizontal Plane)
Angular Dependence (Vertical Plane)
The results showed that the accumulated and indicated dose rates were linear for exposures ranging from approximately 0.05 Rem/hr up to 300 Rem/hr.
Some variance of greater than
+ 10 percent was noted starting at approximately 100 R/hr.
The horizontal plane angular dependence tests were linear over the range of minus 90 degrees to plus 90 degrees.
In all cases the vertical plane angular dependence read low at the lower radiation incidence angles ranging between 0-30 degrees and at the upper radiation incidence angle of 180 degrees.
The variance at the 180 degree range was from 27 percent to 47 percent low.
The licensee's staff stated that the use of electronic dosimetry for recording the record of personnel dose should be carefully considered to account for their angular dependenc The licensee's individual responsible for coordinating evaluation has been requested to discuss the test results with the NRC staff on September 27, 1994.
It was concluded that a potential for an overexposure could result if the angular dependence of an electronic dosimeter device is not considered.
For normal use, the dosimeters were programmed to alarm at a preset dose and/or dose rate and provide results that were generally in close agreement with the thermoluminescent dosimeters.
Additionally, the dosimeters were easy to read, thus, eliminating some human error in recording dose.
On tours of the radiological controlled area, the inspector noted that areas were posted properly with highly visible signs and that high radiation areas and locked high radiation areas were properly controlled.
The inspector observed individuals entering the radiological controlled area and noted that they wore appropriate personnel monitoring devices.
The licensee's external radiation exposure control program consisted of monitoring whole-body exposures using thermoluminescent dosimeters, self-reading dosimeters, direct surveys, radiation exposure permits, and administrative dose limits.
The licensee utilized radiological controlled area access control point clerks to read self-reading dosimeters and log individuals on the computerized radiation exposure permit work tracking system.
The inspector reviewed selected dosimetry records and noted that the appropriate records were maintained for each individual to satisfy
CFR Part
requirements.
The licensee's dosimetry program was accredited by the National Voluntary Laboratory Accreditation Program in all eight categories.
The inspector reviewed temporary shielding and long-term shielding logs at each unit. It was noted that the licensee relied heavily on the use of temporary shielding rather than implementing a more effective permanent/source term reduction program.
The licensee agreed with the inspector's observation when this matter was brought to their attention.
The director, radiation protection, informed the inspector that they had reached a similar conclusion and had taken action to reviewing different methods for improving their shielding/source term reduction program.
The radiation protection staff informed the inspector that they had implemented a pilot program during the recent Unit 3 outage which involved the questioning of workers regarding-their knowledge-of the radiological control conditions in the work areas.
Workers were asked a series of questions regarding the 'information obtained from the radiation exposure permits they had signed in on and from local survey data posted at the work sites.
Workers providing an unacceptable response to the questions were asked to leave the area and not to return until they fully understood the radiological control conditions and requirements for their job assignment.
The pilot program had received the full support of the various work groups and, in particular, upper management.
Improvements in worker performance have resulted because of this pilot program.
2.6 Internal Ex osure Control The inspector reviewed the internal exposure control program to determine compliance with Technical Specification, licensee procedures, the
-11-recommendations of Regulatory Guide 8. 15, NUREG-0041, Industry Standards ANSI 188.2-1980, and agreement with commitments the Updated Safety Analysis Report.
The inspector reviewed respirator issue records and respiratory protection qualification records and determined that workers receiving respirators met qualification requirements.
Use of respiratory protection equipment was low.
The inspector reviewed respiratory protection equipment issue records and verified that the individuals who were issued respiratory protection equipment met qualification requirements and that they received equipment of the proper size.
The inspector reviewed selected records and noted that the respirators that were issued had been inspected at the required frequency.
Engineering controls, such as portable ventilation units with high efficiency particulate filters, were used to limit concentrations of airborne radioactive materials and reduce the need for respiratory protection equipment.
Good ALARA planning was another method used to reduce the need for respiratory protection equipment.
Another method used to determine the need for prescribing the use of respiratory protection equipment was the review of historical data and from the results of air sampling data.
The inspector determined that the licensee had a good system for recording and tracking of derived air concentration hours for workers.
The inspector reviewed the whole-body counting program and whole-body counting records and determined that a good program was maintained.
whole-body counting was used to verify the effectiveness of the respiratory protection program.
No occurrences of any significant internal exposures were reported.
2.7 Contro'Is of Radioactive Materials and Contamination Surve s
and
~Monitorin The inspector reviewed the controls and survey program to determine compliance with Technical Specification, licensee procedures, and agreement with commitments in the Updated Safety Analysis Report.
During several tours of the radiological controlled area, the inspector observed that contaminated areas were controlled with appropriate rope barriers.
Housekeeping within these areas was good.
The inspector observed radiation protection technicians as they performed radiation surveys and contamination checks prior to releasing items from contaminated areas and determined that they used proper health physics practices.
The inspector reviewed examples of the licensee's surveys and determined that they were complete and easy to interpret.
Survey results were posted at the entrance-way of each work area for workers to use as a guide in the accomplishment of their assigned task.
The inspector confirmed that a suitable supply of calibrated, response-checked, radiation survey instruments were available for us Instruments in the field, such as friskers, personnel contamination monitors, and portal monitors were response checked daily.
The licensee had decreased the area of contaminated work spaces in all three Units'reas to an excellent level.
The licensee was taking this action to reduce personnel exposures, minimize the volume of radiative waste that was generated, and to decrease the number of personnel contaminations occurring when work was performed in these areas.
Each Unit had decreased the total area of contaminated floor space to less than 1 percent of the total square footage of floor that was available within the radwaste, spent fuel building, and auxiliary buildings.
While touring Unit 2, the inspector found four cigarette butts on the radwaste and auxiliary building rooftops on July ll, 1994.
Several days later, the Senior Resident Inspector found an empty cigarette package lodged on a
structural member in the Unit 2 high pressure safety injection pump room.
The licensee's quality assurance staff informed the inspector that they had identified a similar finding, and they,had initiated a Condition Report Oisposition Request to disposition the finding.
The Condition Report Oisposition Request was still open at the time of this inspection.
Licensee's management stated that smoking in an radiologically controlled area was an unacceptable practice.
The inspector observed entrance and exit access controls at the radiological controlled areas and found them to be good.
Individuals exiting the radiological controlled area were required to pass through both gamma and beta sensitive personnel contamination monitors.
Individuals were required to survey their hardhats before entering the contamination monitors.
Radiation protection personnel surveyed handcarried items for contamination prior to release.
The inspector reviewed selected personnel contamination reports and noted that they were handled appropriately.
Licensee representatives had identified 139 personnel contaminations for all three Units as of July 1, 1994.
This was above the licensee's goal of 114 personnel contaminations events for that time period.
Most of the personnel contamination events occurred during the Unit 3 1994 mid-cycle outage.
Personnel contamination events at Units I and 2 were actually below the established goals.-
The licensee, performed a root cause analysis for each personnel contamination event at each of the Units.
In addition, each unit performed a very basic trending analysis was accomplished to determine if some unidentified problem existed.
The inspector noted that the trending of results from the three Units were not collated for trending to further determine if a common problem existed.
Current trending accomplished by the licensee did not further break it down by work group to further determine if a common problem needed attention.
Sufficient supplies of protective clothing were available.
The licensee also made such items as straps for glasses, headbands, and face shields with headbands available in an effort to reduce personnel contamination.8 Haintainin Occu ational Ex osures ALARA The inspector reviewed the ALARA program to determine compliance with 10 CFR Part 20, licensee procedures, and agreement with commitments in the Updated Safety Analysis Report.
The inspector noted that ALARA staffing was appropriate.
ALARA personnel prepared radiation work permits and reviewed design changes, procedure changes, and maintenance work requests.
The inspector reviewed selected radiation work permits and ALARA procedures and determined that they were good quality.
The inspector noted that there was a strong management commitment to implement an effective ALARA program.
A recent change to the ALARA program included the appointed of ALARA coordinators from each working group.
The ALARA group stated that improvements in communications with other working groups and improved ALARA awareness of the ALARA program by wor kers had resulted since the group ALARA coordinators were appointed.
The ALARA group was in the process of evaluating other methods for improving the workers ALARA awareness program.
Consideration were given towards adopting an effective ALARA incentive program.
The inspector reviewed selected ALARA work packages for jobs scheduled during the Unit 2 mid-cycle outage and noted that 'they were of good quality and included adequate checklists, estimates of projected man-hours, radiation survey information, and radiation exposure projections.
The Unit 2 mid-cycle outage was expected to'ake approximately 29 days to complete.
The outage is scheduled to start on September 17, 1994.
The inspector reviewed the licensee's 1994 ALARA goals and selected ALARA package summaries for the Unit 2 mid-cycle outage.
ALARA packages were reviewed and found to be good quality.
The packages included adequate checklists, estimates of projected man-hours, radiation survey information, radiation exposure projections, and lessons, learned from previously accomplished similar work.
ALARA dose saving measures used by the licensee were the implementation of a good ALARA planning and preparations program.
Other dose saving measures included the use of temporary shielding, flushing, decontamination, video equipment to monitor workers in high radiation areas, thus reducing the number of support workers necessary',
and the use of robotics.
ALARA personnel normally track the doses for major work activities on a daily basis by reviewing computer printouts of exposures associated with those jobs and comparing the exposures with projected values.
The ALARA exposure data was trended for unidentified problems that may require attention.
A review of the trending data was performed by the inspector.
The inspector noted a
similar problem with the ALARA trending of person-rem expenditures that was observed with the personnel contamination occurrence trending discussed in Section 2.7.
The inspector noted that the licensee did not use all available data and information in their trending process that might reveal some unidentified problem in need of attentio N
-14-There were no major changes to the ALARA organization.
Radiation work permits were routinely generated by the central ALARA group.
The inspector noted that ALARA work packages prepared for the mid-cycle outage were complete and incorporated dose reduction techniques.
The ALARA Suggestion Program was very successful with regard to the soliciting of exposure reducing suggestions.
Some techniques and devices employed to reduce radiation exposure included:
mock-up training, video cameras, temporary shielding to reduce radiation levels, hot spot flushing, and the decreased use of respirators.
As of June 30, 1994, Unit 1 was below their monthly and year-to-date exposure goals.
Unit 2 was below their monthly goal; however, they were above their year-to-date exposure goal due to an increased scope and extended duration of the first quarter mid-cycle outage.
Unit 3 was above their monthly and year-to-date exposure goals due to an increased scope of the previous refueling outage.
2.9 Conclusions Excellent audits and self-assessment of radiation protection activities were performed by qualified individuals.
Meekly quality assurance and health physics workshops had helped to improve communications and in the implementation of timely and effective resolution of self-assessment findings.
The radiation protection organization had gone through a realignment since the last inspection of this area.
The realignment appears to have improved the implementation of the radiation protection program.
The licensee had not considered how they will continue to maintain positive control over the issuing and collecting of thermoluminescent dosimeters when they convert over to a "Palm Reading" security personnel access system.
A good planning and preparation program had been established for the 1994 Unit 2, mid-cycle outage.
An excellent inventory of radiation protection supplies and equipment were maintained for outage activities.
Excellent coordination existed between the radiation protection department and other departments.
The radiation protection group did not routinely screen qualification records of contract radiation protection technicians that were provided by their vendor to support outages.
Good general employee training programs were conducted by the nuclear training organization.
This organization was staffed with experienced instructors.
An excellent practical factors training program for radiation workers had been implemented.
A challenging goal was set for radiation exposure accrued during the outage.
New technologies were available for use to reduce pe:.sonnel exposure.
The radiation protection department had a stable work force with very little staffing turnove I
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-15-A high number of the radiation protection technician staff were registered (certified)
by the National Registry of Radiation Protection Technologists.
An excellent evaluation of electronic dosimetry devices was performed.
An excellent program involving the challenging of a workers'nowledge of the radiological conditions staff after the worker enters into a radiologically controlled area was implemented by the radiation protection staff.
An effective permanent shielding program and radwaste minimization program has not been clearly established The number of personnel contaminations was relatively low, and housekeeping within the radiological, controlled area was generally good.
Person-rem totals were very low.
The ALARA suggestion program received good support from radiation workers.
The ALARA program sponsored a number of initiatives designed to result in reduced personnel exposures.
The external exposure control program was very good.
The licensee used an accredited dosimetry program with state-of-the-art equipment.
Radiation areas, high radiation areas, and locked high radiation areas were highly visible and properly controlled.
Good internal radiation exposure controls in the form of respiratory protection, engineering controls, air monitoring, contamination surveys, and whole-body counting were implemented; however, evidence of failure of personnel to comply with the "no smoking" rule within radiological controlled areas were observed.
The number of personnel contaminations was low, housekeeping within radiological controlled areas was excellent, and excellent results were achieved for control of contaminated areas within each Unit.
A weaknesses was identified with the method used for trending personnel contamination events, exposure data, and source term reduction.
The licensee's ALARA program was a strength.,
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ATTACHMENT
PERSONS CONTACTED l. 1 Licensee Personnel W.
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- L L. Stewart, Executive Vice President, Nuclear Shea, Director, Site Radiation Protection Sneed, Operations Manager, Radiation Protection Steward, Manager, Radiation Protection Technical Services Flood, Plant Manager, Unit 2 Fullmer, Hanager, Plant Support Nuclear Assurance Akers, guality Assurance Monitor Draper, Site Representative, Southern California Edison Fountain, Supervisor, guality Audits and Monitoring Gaffney, Manager, Radiation Protection Gowers, Site Representative, El Paso Electric Larkin, Nuclear Regulatory Affairs, Operations Henry, Site Representative, Salt River Project Kanitz, Senior Engineer, Nuclear Regulatorv Affairs Kanter, Technical Advisor, Radiation Protection Krainik, Manager, Nuclear Regulatory Affairs Linares, Supervisor, Radiation Protection Whitney, guality Assurance Auditor Gray,'adiological Engineering Supervisor Bungard, Administration/ALARA Supervisor Lantz, Health Physicist Nelson, Radiation Protection Training Coordinator Morris, Site Maintenance, Technical Management Assistant Austin, Senior Radiation Protection Technician, ALARA Planning Clyde, Operations Manager, Unit 3 1.2 NRC Personnel K. Johnston, Senior Resident Inspector
- A. MacDougall, Resident Inspector H. Freeman, Resident Inspector In addition to the personnel listed, the inspector contacted other personnel during the inspection.
- Denotes personnel that attended the onsite exit meeting on July 15, 1994.
¹Denotes personnel that participated in the July 21, 1994, telephone exit meeting.
EXIT MEETING An onsite exit meeting was conducted on July 15, 1994.
On July 26, 1994, a
telephone conference call exit was held with the individuals to inform them of the results regarding the in-office review of licensee documents conducted on July 20-21, 1994.
During these meetings, the inspector reviewed the scope and findings of the report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspecto t
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