ML16342A527

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Insp Repts 50-275/94-12 & 50-323/94-12 on 940411-15. Violations Noted.Major Areas Inspected:Radiation Protection Program
ML16342A527
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 05/26/1994
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16342A526 List:
References
50-275-94-12, 50-323-94-12, NUDOCS 9406060300
Download: ML16342A527 (26)


See also: IR 05000275/1994012

Text

APPENDIX B

U.S.

NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection

Report:

50-275/94-12

50-323/94-12

Licenses:

DPR-80

DPR-82

Licensee:

Pacific

Gas

and Electric Company

(PGIIE)

77 Beale Street

San Francisco,

California 94106

Faci 1 i ty:

Inspection

Inspection

Inspector:

Diablo Canyon

Power Plant,

Units

1 and

2

At:

San Francisco,

San Luis Obispo .County, California

Conducted:

April 11-15,

1994

Michael

Ci llis, Senior Radiation Specialist

Facilities

Inspection

Programs

Branch

Approved:

Blaine Hurray,

Ch ef

Reactor

Inspection

Branc

~Summa r:

Areas

Ins ected:

Routine,

announced

inspection of the radiation protection

program including:

audits

and appraisals;

changes;

training and

qualifications of personnel;

external

exposure control; internal

exposure

control, control of radioactive materials

and contamination,

surveys,

and

monitoring, maintaining occupational

exposures

as-low-as-i s-reasonably-

achievable

(ALARA); and tours of the licensee's

facilities.

Results:

'o

major changes

in the Radiation Protection

Program

had

been

made since

the previous inspection

(Section

1. 1) .

Very good survei llances of radiation protection activities

were

performed

(Section 1.2).

Contract radiation protection technicians

were qualified and trained

appropriately

(Section

1.3) .

An excellent

ALARA program,

ALARA awareness

and incentive program,

ALARA

mock-up training program,

and

an aggressive

ALARA goal

program were

implemented for Refueling Outage

1R6 (Sections

1.4,

1.4. 1, 1.4.2,

and

1.4.3).

9402)060300

9'405>i

PDR

ADOCK 05000275

PDR

Good external

exposure

controls were implemented

(Section 1.5).

~

Good internal

exposure controls were implemented

(Section 1.6).

E

Respirator

usage

during the refueling outage

were significantly reduced

(Section 1.6).

~

Increases

in personnel

contamination

events

were noted during the

refueling outage

(Section 1.7).

~

Control of radioactive materials

and contamination,

surveys,

and

monitoring were generally

good (Section

1.7) .

~

Housekeeping

was generally

good (Section 1.8).

A poor ALARA practice in the auxiliary building,

a poor

OSHA safety

practice in the reactor containment building, and poor ALARA practice in

the reactor containment building were observed

(Section

1.8) .

~

A violation was identified for failure to post

a high radiation area

(Secti on l. 9) .

Ins ection Findin s:

Violation 50-275/9412-01:

50-323/9412-01

was

opened

(Section 1.9).

Attachment:

Attachment

Persons

Contacted

and Exit Meeting

J

DETAILS

1

OCCUPATIONAL EXPOSURES

DURING EXTENDED OUTAGES

(83729)

The radiation protection

program implemented during Refueling Outage

1R6 was

inspected to'etermine

compliance with Technical Specifications

and with the

requirements

of 10 CFR 19. 12 and 20. 1001-20.2401.

1.1

~Chan

es

No major changes

in the licensee's facilities and organization

had occurred

since the previous inspection.

The inspector reviewed

numerous

changes

in

procedures

that were

made since the previous inspection.

The changes

should

result in program improvements.

1.2

Audits and

A

raisals

The inspector

reviewed the licensee's

quality assurance

schedule of radiation

protection related audits

and appraisals

for Unit 1, Refueling Outage

1R6.

At the time of this inspection,

quality assurance

had just initiated an

Audit 940117I to verify that the radiation protection

and dosimetry processing

programs

were being effectively implemented

and to provide for the evaluation

of radiation hazards

and protection of workers.

No quality- assurance

survei llances of outage activities

had

been conducted;

however,

one surveillance

activity was conducted

in December of 1993

(Surveillance

Report S(A-93-0063) to verify the licensee's

readiness

for

implementation of 10 CFR 20.1001-20.2401.

The inspector

noted that supervisory

and management

oversight of work

activi ties were frequently conducted

during the outage.

The licensee's

management staff expects their first line supervision

and foremen to monitor

the performance of work activities.

Licensee Action Requests

generated

as

a

result of supervisory,

foreman,

and management

survei llances

were reviewed.

The surveillances

were of good quality and generally

focused in on procedure

compliance

issues.

Radiological

Occurrence

Reports written by the Radiation Protection

Branch for

the period of January

1 through Narch 31,

1994,

were reviewed.

The reports

identified problem areas

and required corrective actions

be implemented to

prevent

a recurrence

of the problems.

1.3

Trainin

and

ualifications

The qualifications

and training program for contract radiation protection

technicians

who were hired in support of Refueling Outage

1R6 were examined.

Selected

resumes

and training records

were reviewed

by the inspector.

It was

determined that the contract radiation protection technicians

met the

qualification requi rements

specified in Technical Specifications 6.3, "Unit

St'aff gualifications."

0

'

A standardized

screening

examination

was

used

by the licensee's

radiation

protection staff for the selection of returning radiation protection

technicians

and contract radiation protection technicians

who had not

previously worked at the site.

First time contract radiation protection

technicians

were required to demonstrate

their knowledge of health physics

by

taking

a written entrance

examination.

The licensee's

screening

process

was

effective in ensuring that the selection of radiation protection technicians

was in compliance with the Technical Specification.

Each

new hire radiation protection technician

and returning radiation

protection technician

attended

4 days of site-specific training.

Four written

examinations

were administered

during the site-specific training that was

provided.

All of the radiation protection technicians

were required to

demonstrate

their knowledge of the licensee's

procedures

before being assigned

to support the outage.

Most of the

100 senior radiation protection

technicians

and

10 junior radiation protection technicians

who were hired for

the outage

were returnees.

Approximately 25 radiation protection technicians

were

new hires.

The inspector interviewed the licensee's

training representatives

and

radiatio'n protection staff and determined that the training program for

contract radiation protection technicians

emphasized

lessons

learned

and

management's

expectations.

The licensee's

program for maintaining personnel

exposures

ALARA was examined

for compliance

with 10 CFR Part 20.

Planning

and preparation for Refueling

Outage

IR6 was previously addressed

in

NRC Inspection

Report 50-275/93-35;

50-323/93-35.

This inspection

focused

in on the implementation of licensee's

ALARA program.

The scheduled

57-day outage started

on March

12,

1994,

and

w'as approximately

4-5 days behind schedule

at the conclusion of this inspection.

The inspector

noted that the

ALARA program received direct attention

and

strong support of upper management.

Similar comments

were expressed

to the

inspector

by the licensee's

staff and contract workers during the inspection.

The licensee's

staff and workers were encouraged

by observed periodic

management

tours of work activities in the radiological controlled area during

the outage.

1.4. I

Worker Awareness

and Incentive Pro

ram

A high level of ALARA awareness

was present

among licensee's

management,

supervision,

and workers interviewed during facility tours.

Workers were well

aware of the

ALARA goals that were established

for the outage.

Workers

were

continually made

aware of the progress

being

made

towards achieving the

ALARA

goals.

This was accomplished

by displaying posters

in appropriate

locations,

through plan-of-day meetings, craft group meetings,

and by supervision.

'

Each worker had

been provided with a refueling outage

handbook.

The handbook

contained

useful

information such as:

list of telephone

contacts,

diagrams of

Unit 1, outage

schedule,

site layout diagram,

emergency

signals

and responses,

radwaste minimization program,

ALARA program guidelines

and goals,

and

a list

of other useful information.

The licensee

developed

a formal worker awareness/recognition

program for the

outage.

The objective of this program

was to increase their competitive

edge

and enhance

the quality of worker awareness

by eliminating excessive

radiation

exposure

and encouraging

greater efficiency.

The strategy of the program was

to stimulate worker awareness

of the

ALARA program

and to recognize

ALARA

suggestions.

Approximately 25 ALARA suggestions

were under review at the time

of this inspection.

Incentive awards

were given to those individual who

submitted

suggestions

that are adopted for implementation.

The inspector

reviewed the sixth refue'ling outage incentive program described

in a Pacific

Gas

and Electric Company

memorandum

dated

March 28,

1994.

The

memorandum described

the awards that all workers (e.g., contractors

and

'ermanent

staff) could receive for completing the outage

under schedule

and

also for completing the outage

under the person-rem

goals that were

established

for the outage.

The program provides workers with awards

(e.g.,

material

goods,

meal tickets,

and monetary

awards)

for good performance.

Workers interviewed during the inspection

were aware of the program and used

good

ALARA work practices

to maintain their exposures

as

low as possible

so

that they could avail themselves

of the incentive awards.

Except for the isolated observations

discussed

in Section

1.8, work practices

observed

during the inspection

appeared

to be consistent

with the

ALARA

concept.

1.4.2

Mock-u

Trainin

During the outage,

the licensee

used

mock-up training as

a tool to reduce

person-rem.

The following mock-up training was provided in support of the

outage:

Steam Generator

Hanway Cover

Removal'eactor

Coolant

Pump seal

Removal

Steam Generator

Nozzle

Dam Removal

and Installation

Resistance

Temperature

Detector Modifications

Steam Generator

Sludge

Lance

Reactor

Head Bolt Inspection

The inspector

observed

steam generator

nozzle

dam removal

mock-up training

which was provided

on April 12,

1994.

The quality of the training was good.

1.4.3

ALARA Goals

and Results

At the beginning of the outage,

an

ALARA goal of 350 person-rem

was

established

for the Outage

1R6.

As of April 13,

1994,

the licensee

expended

approximately

280 person-rem.

This was

26 person-rem

under their expected

0

goal for the April 13,

1994 date

and

75 person-rem

under the outage

goal of

350 person-rem,

with only 2 more weeks remaining in the schedule.

ALARA in-progress

reviews for high exposure jobs,

such

as, for the resistance

temperature

detector

bypass

piping modifications

had already

been completed.

A review of the debrief package

disclosed that the,licensee's

staff was very

self critical with their performance.

Many useful

comments for improvements

should prove to be useful

in reducing person-rem

the next time similar work is

scheduled.

During the outage,

the licensee

used video cameras,

shielding,

and hydrolyzing

to reduce

person-rem.

ALARA prejob briefings were

a

common practice

used

by

the licensee

to reduce

person-rem.

Discussions

with the

ALARA coordinator

disclosed that the licensee

was considering

the purchase of a surrogate travel

technology

program.

The program

has

been

used with great

success

at*other

nuclear

power plants

as

a tool in reducing person-rem.

By using

an

interactive videodisc

system

areas

of the plant that are normally inaccessible

can

be viewed without entering the plant.

Low-dose areas

were posted

throughout the plant for workers to spend their

time when they were not actively engaged

in productive work.

Workers were

reminded

by the training group, radiation protection,

and supervision to stay

in a low-dose area

when they were not actively engaged

in work and can not

exit the area.

1.5

External

Ex osure Control

The inspector toured the radiological controlled areas,

reviewed

area

postings,

and performed

independent

radiation measurements.

All postings

except for the event discussed

in Section

1.9 were correct

and easy to

understand.

It was determined that high radiation areas

and locked high.

radiation area controls were in compliance with Technical Specification

6. 12,

"High Radiation Area,"

and

10 CFR 20. 1902(c).

All personnel

observed

in the-radiological

controlled area

by the inspector

were equipped with proper dosimetry equipment,

The inspector also reviewed

personnel

exposure

records for the period of January

1993 through March 1994.

The review disclosed that personnel

exposure levels were well below the

occupational

exposure limits established

in licensee

procedures

and

10 CFR Part 20.

1.6

Internal

Ex osure Control

The licensee's

respiratory protection

program was examined for compliance with

10 CFR Part 20 requirements

and consistency with the recommendations

of

Regulatory

Guide 8. 15,

"Acceptable

Programs for Respiratory Protection";

NUREG 0041,

"Manual of Respiratory Protection Against Airborne Radioactive

Materials";

and American National

Standards

Institute

(ANSI) Z88.2, "Practices

for Respiratory Protection."

The examination

included

a review of the training program provided to users of

respiratory protection

equipment,

medical

examination requirements,

and

'

-7-

respirator fit-up testing program for respiratory

equipment

users.

Applicable

respiratory protection

program implementing procedures,

an inspection of the

respirator issuing facility, and various

emergency

use respirator

storage

locations

were also performed.

The inspector verified that the routine monthly inspections of several

self-contained

breathing apparatus

had

been

performed within the past

31 days.

The control

and issue of respiratory

equipment

were determined

to be

consistent with implementing procedures

and the documents

referenced

above.

Respiratory

usage

during Refueling Outage

1R6. had decreased

by approximately

82 percent.

The decrease

was attributed to the implementation of the

new

10 CFR Part 20 regulations

on January

1,

1994.

The licensee's

respiratory protection

program was determined

to be consistent

with regulatory requirements

and the other documents

referenced

above.

The licensee's

air sampling program

was examined

and determined

to be in

compliance with 10 CFR Part 20 and Licensee

Procedure

RCP D-420,

"Sampling and

t1easurement

of Airborne Radioactivity."

The inspector

observed that air

sampling of work evolutions being performed during the inspection

were

representative

of the workers'. breathing

zone.

1.7

Control of Radioactive Haterial

and Contamination

Surv'e in

and

~Monitorin

The inspector

observed

entrance

and exit access

control at the radiological

controlled areas

and found them to be good.

Selected

radiation

and contamination

surveys for 1994 were reviewed for

completeness,

use of appropriate

survey instruments,

and timely management

review.

Survey results

were documented

properly.

Records of clothing and skin contamination

events

were examined for

thoroughness.

Timely decontamination,

trending,

and followup actions* of the

events

appeared

to be. appropriate.

As of April 14,

1994,

a total of

226 clothing and skin contamination

events

were reported during the Refueling

Outage

1R6.

This represents

an increase

from personnel

contamination

events

that occurred during the Refueling Outage

2RS.

Clothing contaminations

outnumbered

skin contamination

events

by a 6: 1 ratio.

Each event receives

a

detailed

review for possible

dose

assessment,

probable

cause,

and corrective

actions.

The inspector verified that none of the personnel

contamination

events

reported during Refueling Outage

1R6 resulted in a significant internal

or external

exposure.

During the tours of the Auxiliary Building and Reactor Containment,

portal

monitors

and frisking equipment

appeared

to be used properly and were in

current calibration.

In addition,

the inspector

noted that monitoring

instrumentation

was in good supply and was in current calibration

and

had been

routinely performance

checked.

Individuals exiting the radiological controlled areas

were requi red to pass

through both

gamma

and beta sensitive

personnel

contamination monitor.

All

tools

and equipment

removed

from the radiological controlled areas

were

surveyed for release

by a qualified radiation protection technician.

Tool

monitors were also

used to survey equipment.

In general,

surveys,

moni toring,

and releases

of potentially contaminated

materials

to unrestricted

areas

were

good.

The licensee's

surveillance

program for verifying accountability

and leak

checks of sealed

sources

was examined

and

was

found to be in compliance with

Licensee

Procedure

RCP D-620, "Control of Radioactive

Sources";

and Technical

Specifications 3/4.7.8,

"Sealed

Source Contamination."

The licensee

had

completed its most recent

sealed

source surveillance

on January

12,

1994.

All

of the sources

were accounted for and

no leaking sources

were identified.

1.8 F~ili

T

Tours of the licensee's facilities were conducted

by the inspector.

Areas

toured included the Spent

Fuel Building, Auxiliary Building, Reactor

Containment,

and

Radi oacti ve Storage

Faci 1 ity.

Work evol uti ons observed

included:

Core reload

(Spent

Fuel Building and Reactor Containment)

Radioactive

waste

compaction

Steam Generator - manway cover inspection

Charging

system - hydrostatic testing

Reactor Coolant

Pump restoration

Yalve refurbishment

Hot machine

shop activities

Preparation of a radwaste

shipment

Feed Mater

Pump overhaul

Other miscellaneous

activities

Areas toured were clean but were cluttered with material

from the outage.

Except

as noted below, personnel

interviewed

knew their assigned

tasks

and for

the most part,

used

good

ALARA work practices.

All workers interviewed

had

signed in on the appropri ate radiation work permi t.

Additional observations

by the inspectors

include the following:

~

On April ll, 1994, six workers were observed

performing a hydrostatic

test of the charging

system

on the 100-level of the Auxiliary Building.

It appeared

that the work could have easily been

conducted

by three

workers.

Radiation level in the work area

ranged

from 2 to 3 mrem/hr.

The observation

was brought to the attention of the lead mechanic

and

radiation protection

who instructed the workers to move to a lower dose

area.

On April 14,

1994,

core reload workers in the Reactor Containment

were

observed walking along the edge of the cavity without donning

a life

jacket and/or

a life-line as required

by the licensee's

safety manual.

On April 14,

1994,

a contract worker was observed picking up an alarming

dosimeter

from a tool

box located adjacent

to Reactor Coolant

Pump 1-2

on the 115-foot level of the Reactor

Containment.

Discussions

held with

the individual revealed that the individual had signed in on Radiation

Work Permit

94 01050

02 which provided the radiological control

requirements

for performing reactor cool ant

pump mai qtenance activities.

The radiation work permit required

an alarming dosimeter if entry into a

high radiation area

was expected..

As a precautionary

measure,

the

mechanic

signed out for an alarming dosimeter

even

though

he did not

expect to enter

a high radiation area.

The worker also

had

a

thermoluminescent

dosimeter

and

a low range pocket ion chamber which

were required

by the radiation work permit.

The worker stated that

he placed

the alarming dosimeter in the tool.box,

because

he

was afraid that it would fall off his person

when

he climbed.

on

some piping that was adjacent

to the tool box.

The worker added that

he had not actually entered

a high radiation area.

Radiation

measurements

taken in the area

by the inspector indicated

levels of approximately

10 mrem/hr by the tool

box and approximately

30 mrem/hr where the worker was

seen climbing off the piping.

These

dose rates

were subsequently

verified by the licensee's

radiation

protection staff.

The observation

was brought to the attention of the radiation protection

staff who implemented appropriate

corrective action.

On April 14,

1994,

the inspector

observed

a situation that did not agr ee

with good

ALARA practices.

A contract quality control inspector,

who

had signed in on Radiation

Work Permit 94 01006 00,

was observed

to be

lying down flat on his back.

The quality control inspector stated that

he was providing support for a welding operation that was being-

performed

on the 91-foot level of the Reactor Containment.

The worker

had his feet propped

up against

a stairwell structure,

and his eyes

were

closed.

The worker appeared

to be in an extremely restful position when

observed

by the inspector.

The worker jumped

up immediately when

he heard the inspector talking to

the welders working nearby.

Radiation measurements

in the area

were

approximately

2-3 mrem/hr.

The welders stated that they still had

approximately

20-30 minutes of welding to be performed before they would

need

the services

of the quality control inspector.

The observation

was reported to the lead radiation protection technician

who instructed

the worker to move to a low-dose area.

The radiation

protection technician

subsequently

instructed the Norker to exit the

Reactor Containment.

Subsequent

corrective action taken

by the individual's supervisor

appeared

to be satisfactory.

1.9

Unit

1 Letdown

S stem Hot

S ot Event

At approximately

2:50 a.m. Pacific daylight time

(PDT)

on April ll, 1994,

the

radiation protection staff was informed that the operations

group iritended to

'

-10-

fill and vent the let down line and the volume control tank.

The radiation

protection

group was informed that radiation levels could change

because

of

this planned activity and that the dose rates

may even

go down.

Approximately

20 minutes earlier, at 2:30 a.m.

(PDT)

on April ll, 1994, radiation protection

had just completed

a daily survey of the let down header

area

on the 100-foot

elevation of the Auxiliary Building.

Results of this survey indicated the

expected

normal

dose rate of approximately 0.2 mr/hr to 0.5 mr/hr adjacent

to

the let down header

area.

The next survey of the area

was scheduled

to be

accomplished

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> later

on the morning of April 12,

1994.

The vent-and fill operation

was performed

between

the hours of 2:58 a.m.

and

4:03 a.m.

(PDT)- on the morning of April 11,

1994.

Radiation surveys

were not

performed during the evolution,

because

radiation protection expected

the

same

or possibly that the radiation levels would go down.

At approximately

4 p.m.

(PDT)

on April 11,

1994,

a contractor junior radiation

protection technician while performing routine work activities noted that her

Eberline Hodel

RO-2 dose rate meter

pegged

on the low range (e.g.,

0-5 mr/hr)

as

she

was walking adjacent

to the let down header

area located

on the

100-foot level of the auxiliary building.

The junior radiation protection

technician notified her supervisor

and took immediate action to assess

the

problem and assigned

personnel

to guard the area to prevent inadvertent entry.

The radiation protection staff responded

immediately.

A radiation survey-of

the area

was conducted.

The results of this survey indicated that there

was

a

5 R/hr hot spot

on the let down header piping and dose rates at 30

cm ranged

from

1 R/hr to 1.5 R/hr.

Dose rates of 350 mr/hr at

a meter were also

detected.

The area

was immediately posted in accordance

with Technical

Specification,

Section

6. 12, requirements

and

a licensee's

investigation

was

started.

The licensee

quickly determined that the probable

cause for the elevated

radiation levels

was associated

with the vent fill operation of the liquid

hold up tank and volume control tank that had taken place approximately

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> earlier.

Increased

radiation levels were also noted

on the volume

control tank and piping adjacent

to Residual

Heat Removal

RHR-1-8804A.

These

areas

were isolated

from normal traffic.

The vent and fill lines in question

were flushed,

and the radiation levels

were returned

back to normal approximately

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the unposted

high

radiation

area

was discovered.

It was determined that. the unposted

high

radiation went undetected

for about

a 12-hour period.

Indications

from a

continuous air sampler confirmed this assumption.

The air sampler indicated

a

rise in the general

area

background during this time period.

During this

period of time, personnel

who had logged. into the radiological controlled area

had

no appreci'able

dose indicated

on their pocket ionization chambers.

It was

also determined that no work had

been

performed in the area during the 12-hour

period,

and any

new jobs would have required the completion of a prejob

radiation survey.

This substantiates

the licensee's

belief that no one was

overexposed.

The inspector

agreed with the licensee's

assumption

that

no one

was overexposed

but concluded that this

was

a readily accessible

area

and that

-11-

a potential for an overexposure

did exist for the 12-hour period that the

elevated

dose rates

went undetected.

A review of Emergency

Procedure

EP G-I, "Accident C'lassification

and Emergency

Plan Activation" was conducted

by the Manager of Operations

Services

and

Director of Radiation Protection

to determine reportabi lity.

Attachment

7. 1

of Emergency

Procedure

EP G-1 stated that passageways,

occupied areas,

accessible

areas

<100 mR/hr, outside

boundaries of radiological controlled

areas

in which unplanned

or unanticipated

increase of,l R/hr or greater is

encountered

is reportable

as

an Alert.

This event

was not reported

as

such

based

on information found in NUREG 0654,

HUHARC/NESP-007, Regulatory

Guide

1. 101 and

Emergency

Procedure

EP G-1.

The rational for reaching this

decision

was discussed

during

a conference call held by the Vice

President/Plant

Manager

and his staff with the NRC's staff on April 14,

1994.

The

NRC staff determined that licensee's

decision to not declare

an Alert was

'appropriate

under the circumstances;

however,

Emergency

Procedure

EP G-1

needed

to be clarified.

The licensee initiated Nonconformance

Report DC1-94-HP-N017,

Revision 0,

on

April 12,

1994.

The Nonconformance

Report described

that

an unexpected

high

radiation areas

was

found on the west

end of the 100-foot elevation hallway of

the Unit Auxiliary Building.

The Manager of Operations

Services

assigned

his

staff to perform

a thorough investigation of the event to determine

why the

vent and fill operation resulted in unexpected

high radiation levels.

The

Operations

Services

Manager identified the following areas

that were in need

of improvement:

Communications

between

operations

and radiation protection

~

Emergency

Procedure

EP G-1 needed

to be clarified

~

A better

method for surveying future vent and fill operations

needed

to

be developed

by the radiation protection group.

The possibility of

utilizing a remote monitoring system

was discussed.

The licensee's

investigation indicated that the hot spots

appeared

to

occur when the flow was diverted to

LHUT 1-1 for a period of

1 to

2 minutes.

The 0.2 micron letdown filter was subsequently

found to be

ruptured.

The

NRC Senior Resident

Inspector will examine

the

operational

aspects

of the vent and fill operation that was performed

on

the morning of April 11,

1994.

The results of this examination will be

addressed

in

NRC Inspection

Report 50-275/94-11.

The failure to post

a high radiation area is

a violation of 10

CFR

Part.20.1902(b)

(VIO 275/9412-01;

323/9412-01)

.

1. 10

Conclusions

Very good radiological control surveillances

were performed.

No significant

changes

in the licensee's

organization or facilities had

been

made since the

previous inspection.

-12-

The selection,

training,

and qualification program for contractor radiation

protection technicians

hired in support of the refueling outage

was excellent.

The licensee's

overall performance

during Refueling Outage

1R6 appeared

to be

good.

Reduction in outage

exposures

was excellent.

The licensee's

program for controlling occupational

exposure

in the aspects

reviewed appeared

to be good in accomplishing

the licensee's

safety objectives

and in achieving the aggressive

ALARA exposure

goals.

Both external

and

internal radiation exposure

controls

were generally

good.

An excellent job of

reducing respirator

use during the outage

was performed.

Control

and labeling of radioactive materials

were consistent with 10 CFR Part 20 requirements.

Surveys

and monitoring were generally good.

However,

personnel

contamination

events

had increased

and

was

an area that was in need

of improvement.

Several

poor health physics

work practices

and

one poor safety practice

were

noted during the tours.

The licensee

took prompt corrective action in each

event.

In general,

posting of work areas

was good.

A violation was identified

concerning

the failure to post

a high radiation area.

A potential for an

overexposure

existed for the period of time that the high radiation area

was

undetected.

ATTACHMENT

I.l

Licensee

Personnel

J.

Townsend,

Vice President/Plant

Manager

  • D. Miklush, Manager,

Operations

Services

  • D. Taggart, Director

equality

Assurance

  • K. Hubbard,

Engineer,

Regulatory Compliance

  • M. Somervi 1 le, Senior

Engineer,

Radiation Protection

(RP)

  • S. Ehrhart,

Engineer,

Radiation Protection

  • C. Helmen,

Engineer,

Radiation Protection

R. Gray, Director, Radiation Protection

  • R. Rogers,

Foreman,

Radiation Protection

  • W. Rising, Auditor, Site guality Assurance
  • R. Flohaug,

Supervisor,

Site guali ty Assurance

"T. Bast, Director,

Work Planning

  • H. Persky,

Instructor, Training

'G.

Boi les,

Dosimetry Supervisor

  • R. Snyder,

Chemistry/Radiation

Protection Training Supervisor

T. Grebel,

Supervisor,

Regulatory Compliance

M. Lemke, Shift Supervisor

  • J. Hays, Director, guality Control

1.2

NRC Personnel

M. Tschi ltz, Resident

Inspector

N. Hiller, Senior Resident

Inspector

  • Denotes personnel

that attended

the exit meeting.

The inspector

met and held

discussions

with additional

members of the licensee's

staff during the

inspection.

2

EXIT MEETING

An exit meeting

was held

on April 15,

1994.

During this meeting,

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

inspector.

~

f

0