ML17157B060

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Insp Repts 50-387/92-03 & 50-388/92-03 on 920121-24.No Violations Noted.Major Areas Inspected:Previously Identified Items,Response to Injured Contaminated Worker,Organization Changes,Outage Preparation & ALARA Status
ML17157B060
Person / Time
Site: Susquehanna  
Issue date: 02/19/1992
From: Noggle J, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17157B059 List:
References
50-387-92-03, 50-387-92-3, 50-388-92-03, 50-388-92-3, NUDOCS 9202280061
Download: ML17157B060 (17)


See also: IR 05000387/1992003

Text

'

y

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Inspection No.

Docket Nos.

License Nos.

50-387 92-03

50-388 92-03

50-387

50-388

NPF-14 NPF-22

Licensee:

Penns

Ivania Power and Li ht Com

an

2 North Ninth Street

Allentown Penns

Ivania

18101

Facility Name:

Sus

uehanna

Steam Electric Station Units 1 & 2

Inspection At:

Berwick Penns

Ivania

Inspection Conducted:

Janua

21-24

1992

Inspector:

J. N

gle,

iation Specialist

Facilities Radiation Protection Section

date

Approved by:

W. Pasciak, Chief, Facilities

Radiation Protection Section

34Hz

date

A~i.*d:A

  • dl dll p*l

l ldd':p

l

ly

identified items, response to an injured contaminated worker, organization changes,

outage preparation, ALARAstatus, and external dosimetry implementation.

Results:

The licensee has reorganized

and separated

the radwaste functions and staff

from the Health Physics Section for the purpose of providing better organization

effectiveness.

Outage preparations

and the review, of annual ALARAresults appeared

good.

The external dosimetry program appears to be strong.

The radiological hazard to

the victim of a hydrogen flash was low. The licensee responded very quickly and

effectively to this event.

9202280061

92021'V

PDR

ADOCK 05000387

8

PDR

'

DETAILS

1.0

Personnel Contacted

1.1

Licensee Personnel

"D. Crispell, Industrial Safety Engineer

D. Gallagher, HP Level II Technician

K. Harder, HP Level IITechnician

E.'Horstman, Sr. Health Physicist

J. Jessick, HP Specialist

L. Kalnoskas, Pipefitter

C. Kalter, Radiological Services Supervisor

R. Kessler, Health Physicist, Dosimetry

  • D. McGann, Sr. Project Engineer - Compliance

P. McGlynn, Health Physicist, Respiratory Protection

E. McIlvaine, HP Foreman, ALARA

W. Morrissey, Radiation Operations Supervisor

D. Pfendler, HP Foreman

  • H. Riley, Health Physics Supervisor

M. Rochester,

Sr. Health Physicist, Dosimetry

D. Shane, HP Asst Foreman

  • G. Stanley, Superintendent of Plant

Burn victim, Pipefitter

1.2

NRC Personnel

  • G. Barber, Senior Resident Inspector
  • D. Mannai, Resident Inspector
  • Denotes those present at the exit interview on January 24, 1992.

2.0

~Pur ore

This inspection was an unannounced

safety inspection of the Susquehanna

Steam

Electric Station radiation control programs.

The areas reviewed were:

response

to an injured contaminated worker incident, organization changes,

outage

.preparations, ALARAstatus, and implementation of the dosimetry program.

0

3.0 'eview of Previousl

Identified Items

During a previous inspection'he inspector identified the lack of proper controls

for locked high radiation areas containing HP instrument calibration sources.

The

licensee has developed

a new procedure, HP-TP-312, Rev. 0, entitled "Control of

High Radiation Sources" which requires HP supervision approval for qualified HP

technicians to be issued master keys to areas containing instrument calibration

sources.

Allother technicians

must sign out a specific high radiation key from a

controlled key cabinet.

The inspector was satisfied that appropriate safety

controls have been established for the HP instrument lab.

Also from the above mentioned inspection in June of 1991, the station practice of

detaching and reattaching TLD badges with security badges was identified as a

weakness when two individuals were found with incorrect TLD badges.

The

inspector's review determined that there was no dose discrepancy in that instance.

Since that inspection, the station reviewed the issue and recommended

several

human factor improvement suggestions,

only some of which have been

implemented to date.

The security control system for personnel

access to the

station was not originally designed'to accommodate

the TLD badge issuance and

has required manual matching of security and TLD badges prior to each

personnel entry to the station.

This root cause has yet to be addressed

by the

licensee but will be reviewed in the future.

4.0

Res

onse to In'ured Worker Incident

On January

18, 1992, at 8:47 a.m., a worker was injured when hydrogen gas in a

pipe ignited during a grinding activity on the plant's common offgas hydrogen

recombiner system.

The worker received first degree burns to his chest, throat,

and face with a second degree burn area on his chest.

The worker was slightly

contaminated

and was transported offsite to the Berwick Hospital for

decontamination

and burn treatment.

As a result of the hydrogen ignition and

hospitalization of a contaminated worker, an Unusual Event was declared at 9:00

a.m. with NRC notification made at 9:51 a.m.

This inspection reviewed the

licensee's

response

to the incident from a radiological perspective.

'nspection No. 50-387/91-08; 50-388/91-08, Section 6

The inspector witnessed the scene of the incident, reviewed all available

radiological survey information available, and interviewed the victim and several

workers directly involved with the incident to determine the radiological hazards

involved, the actions taken by the licensee with respect to the radiological hazards

and the timeliness of those actions, and a review of the follow up actions taken by

the licensee at the time of this inspection.

- The hydrogen combiner and condenser work was, being accomplished on

Radiation Work Permit (RWP) No.92-032 for Turbine 656 Common Recombiner

Room, System 73, Recombiner Vessel and Condenser Replacement.

This RWP

called for weekly radiological surveys and required one full set of protective

clothing for 'work in this area with respiratory protection required for working on

highly contaminated (> 75,000 dpm/ 100 cm~) surfaces or for welding or cutting

on contaminated

surfaces (>1,000 dpm/ 100 cm~).

The pipe being worked on prior to the hydrogen flash had been surveyed

as <

1,000 dpm/ 100 cm"- with no respiratory protection required, however due to the

expected grinding debris, a plastic face shield was worn. The inspector reviewed

all of the survey data available for the comm'on recombiner room area prior to

and after the event.

The room posed generally low radiological hazards, with

contamination levels in the room at about the clean area limit value of 1,000 dpm/

100 cm"- and radiation levels were ( 2 mR/hr which is below the level of a

radiation area.

Although the RWP only required weekly surveys, the inspector's

review discovered at least one radiological survey documented for each day and

up to 3 surveys per day while work was being performed.

Smear samples taken

from inside some of the recombiner piping revealed 2,000 - 3,000 dpm/ 100 cm~

which would require respiratory protection when cutting or welding on these

internal pipe surfaces.,

On the morning of January 18th, the injured pipefitter was beginning to grind a

weld preparation on the outside surface of a previously severed

10" pipe wearing a

full set of protective clothing and a face shield. A review of the air sampling data

showed that particulate air samples were taken during the recombiner

modification work. The particulate air sample results never reached the 25%

Maximum Permissible Concentration (MPC) value which would require airborne

radioactivity area posting and therefore never reached the level which would

,require respiratory protection, although filter respirators were worn for the pipe

cutting work evolutions.

No radiogas air samplirig was performed as would be

expected if this had been an on-line off-gas system.

The HP Section assumed that the common recombiner system had been isolated

from the sources of off-gases and prior to the modification work, the piping had

been purged of residual radioactive gases with air. Realizing after the incident

that off-gas had been leaking into the room, the inspector questioned the presence

of non-particulate airborne radioisotopes.

The licensee had attempted to evaluate

the likely presence of the unmonitored radiogases

in the room late the sa'me day

of the incident.

The licensee successfully isolated the piping from the off-gas

intrusion and provided another purge of the piping with air while the HP Section

drew a gas sample from the pipe exhaust for analysis.

This worst case pipe

sample contained

a total airborne radioactivity concentration of 21% MPC

composed mainly of Xenon and Krypton. This post-incident sample indicated that

leaking off-gas levels were low during the modification work in the common

recombiner room.

Later whole body counts of the injured worker confirmed the

absence of any intake of radioactivity.

The inspector determined that the RWP specified appropriate controls

commensurate

with the radiological hazards of the work and that surveys had

been performed as required.

Surveys confirmed that low radiological hazards

were present in. the work area.

The common recombiner room was not posted

as a hydrogen recombiner room.

Nor was there any warning of a possible combustion hazard associated with the

off-gas system.

At Susquehanna

Station, the sampling of hazardous

non-

radioactive gases

has been the responsibility of the Safety Section.

The HP

Section did not have the sampling instrumentation nor the administrative controls

to address the hydrogen gas hazard associated with the modification work. As this

industrial safety issue is beyond the purview of this HP inspection, this issue will

be addressed

in the Resident Inspector's inspection report-.

The inspector filed-

an Occupational Health and Safety Administration (OSHA) notification of this

accident via the NRC Regional OSHA Liaison Officer to the regional OSHA

office in accordance with a memorandum of understanding between the NRC and

OSHA agencies.

The inspector reviewed the adequacy and timeliness of the licensees

actions in

response

to the event. At 8:47 a.m. on January-18,

1992, a pipefitter started a

hand held disc grinder and as he touched it to the end of a severed recombiner

system pipe, a rapid hydrogen flash occurred which blew him off of a step ladder.

- Inspection No. 50-387/92-02; 50-388/92-02

The flash scorched

his coveralls and blew out the zipper on his chest area.

The

victim picked himself up off of the floor and removed his protective clothing as he

exited the room. An HP technician on normal rounds encountered

the dazed

worker and called the control room for assistance.

The victim had received first

degree. burns under his chin, neck, and chest area with an approximately 4" X 4"

area on his chest of blistered second degree burns. At 8:55 a.m. he was surveyed

by an HP technician resulting in 3,000 dpm detected on the second degree burn

area.

No other contamination was found. At 9:00 a.m. the control room declared

an Unusual Event and the local Berwick Hospital was notified of a contaminated

burn victim and an ambulance was requested.

Susquehanna

Emergency Medical

Technicians (EMT) arrived at about the same time and proceeded to measure

vital signs and place the victim onto a stretcher. A protective covering of cotton

gauze was placed over the chest wound and the victim was transported out of the

Radiological Controlled Area (RCA) at 9:11 a.m.

The ambulance arrived at 9:15

a.m. and by 9:20 a.m. the burn victim and an HP technician were on their way to

the hospital.

The hospital staff had been trained for response

to contaminated

workers and had already setup a plastic laydown area for contamination control

and distributed Susquehanna

supplied dosimeters to the receiving hospital

personnel.

The ambulance arrived at approximately 9:30 a.m. and the victim was

transported into the contamination controlled receiving area in the hospital.

The

victim was transferred from the stretcher to a wash table where the doctor

proceeded

to flush and dry dab the victim for decontamination

purposes

afterwhich the attending HP technician resurveyed the wound.

This practice was

repeated three times until the HP technician indicated less than 20 counts per

minute above background.

By 10:00 a.m. he was decontaminated,

the doctor had

dressed

the wound with burn ointment, bandaged

the area and the victim was

released.

The wash solution used for- decontamination

was collected from the

'wash table drain and the hospital personnel, areas and ambulance were surveyed

for contamination and released

by 10:20 a.m. At about 10:40 a.m. the licensee

terminated the Unusual Event.

In summary, the accident victim had left the station by way of ambulance thirty

minutes after the incident and was decontaminated,

treated for his injuries and

released forty minutes later. Twenty minutes later the hospital was surveyed and

released

back to normal operations and twenty minutes later the Unusual Event

was terminated.

It was commendable that the hospital staff were well trained and

equipped by the licensee to handle this event.

Interviews with the victim and

attending HP personnel confirmed that appropriate contamination controls were

taken and that safety considerations were appropriate.

In general, the licensee

reacted very quickly to this-event demonstrating management

preparations for this

type of accident.

An Event Review Team which included an HP foreman was

created immediately after the incident to establish causation and corrective

actions.

The final system isolation, purging and gas sampling was a result of the

team's actions.

The station's preparation and management's

response to this

event appeared

to be superior.

5.0

Or anization

As the result of the latest "Organization Effectiveness Review" conducted by the

lic'ensee, the Health Physics Section has been reduced in scope and size. Allof

the radwaste handling and radioactive material shipment functions have been

transferred to a newly created Effluents Management Section.

The HP staff

previously tasked with radwaste/shipping

duties have been reassigned

to the new

Effluents Management Section.

Under the previous HP Section organization, the

HP Supervisor (Radiation Protection Manager) had two supervisor direct reports.

The Radiological Operations Supervisor continues as before to provide the

operational HP support for the station.

The Radiation Protection Supervisor

(RPS) was promoted and tasked with leading the new Effluents Management

Section and the vacated RPS position has been deleted.

The HP Supervisor has

reorganized

the section adding a Senior Health Physicist - Technical Support

position with the responsibility for internal and external dosimetry and respiratory

protection functions.

The person promoted to this position was formerly the HP

Specialist - ALARAand is now expected to help the station make the transition

into compliance with the new 10 CFR 20 requirements.

The technical leads for

dosimetry and the respiratory protection program continue to run their respective

programs.

The previous HP Specialist for instruments and sources has been

elevated to a direct RPM report position, now designated

as the Radiation

Instrument Supervisor.

The effectiveness of this organization will be revised

during future inspections.

6.0

Outa

e Pre aration

The Unit 1'sixth refueling outage was sch'eduled to begin on March 7, 1992

approximately six weeks from the date of this inspection.

Aside from the normal

refueling and maintenance

activities, the station plans for a limited number of high

exposure modifications during the next outage.

One-high exposure job will be

replacement of two reactor water clean up (RWCU) pumps with low maintenance

seal-less pumps.

The inspector reviewed the radiological controls preparations for this outage.

vo

7.1

Approximately four months prior to the outage, the licensee awarded a health

physics contract for supplying additional HP technicians for the outage.

The

licensee has contracted for approximately 110 HP technicians to complement the

30 utilityHP technicians/foremen for this outage.

Two months prior to the outage

the individual resumes of technicians were screened

and names finalized.

Approximately six weeks prior to the outage several utilityLevel II HP technicians

(ANSI 18.1 qualified sr. HP technicians) will be upgraded to HP assistant foreman

positions to act as HP control point supervisors for the contract HP technicians.

In three waves, the additional HP technicians arrive for the outage approximately

four weeks before the outage and willbe given three days of generic personnel in-

processing activities followed by three days of contractor HP training consisting of

plant specific HP procedure familiarization. Following this training, plant layout

familiarity and specific outage assignments will be made allowing for specific duty

and performance expectations to be communicated by the acting HP assistant

foremen.

Aside from an apparently short HP technician formal training program,

it appears

adequate

preparations have'been

made and appropriate responsibilities

and controls will be in place.

ALARAStatus

Annual Collective Ex osures

The licensee uses'primarily historical data to derive an ALARAestimate.

This

includes benefits from ALARAmeasures

utilized in the past.

An ALARAgoal

includes the benefits from any additional new ALARAmitigating measures

and a

certain percentage

exposure reduction as a challenge factor.

The station's

1991 annual estimate was 563 person-rem with a station goal set at

500 person-rem.

The'final result for 1991 was 529 person-rem, with the maximum

exposure to an individual was 2.104 rem for the year.

The year of 1991 included

one refueling outage which accounted for 329 person-rem.

Although the ALARA

goal was not reached, the licensee considers it a successful ALARAyear since

they came in under their estimate,

The areas that exceeded their ALARAgoal

included the spent fuel pool clean out project representing

15 person-rem greater

than allocated.

Reasons

given were slightly higher dose rates around the cask

storage pit area,and

an unplanned decon and maintenance work evolution

performed on the reactor hardware shearing machine.

Routine maintenance

ran

9.3 person-rem above the goal from two identified causes.

More frequent

condensate

demineralizer resin change outs resulted in a 4.5 person-rem overrun

and higher th'an expected exposures were accrued from general cleaning and

derate walkdowns.

The refueling outage also proved slightly over its goal (9

person-rem over the goal of 320 person-rem).

Allof these overrun areas

appeared

to be legitimate dose expenditures.

The 1992 station collective exposure estimate which includes two refueling outages

was determined to be 835 person-rem with an ALARAgoal of 751 person-rem.

The ALARAgoals for the Unit 1 and Unit 2 refueling outages were 317 person-

rem and 254 person-rem respectively. Ifthe ALARAgoals are met, Susquehanna

will continue to rank above the average BWR for low annual exposures.

This

year',s collective exposure estimating has been subdivided along maintenance

functional groups as well as along station departmental groups.

This provides a

matrix accounting method to more clearly differentiate dose expenditures at the

station and provide appropriate ALARAgoals to the, responsible supervisors.

Susquehanna

utilizes a historical ALARAdatabase,

detailed ALARAestimating

and tracking, and detailed advance maintenance work planning resulting in a

strong ALARAtracking program.

ALARAInitiatives

The licensee indicated that Susquehanna

station's radioactive source term has

apparently reached

a plateau after many years of continued buildup of radioactive

corrosion products within the reactor piping systems causing increasing dose rates

for the first few years since plant start up.

Each year, the licensee has carried out

in-field gamma spectroscopy

measurements

to track this growth. During the

current SALP cycle, the station has been working to improve the chemical purity

of the feedwater to reduce the introduction of feedwater metals into the reactor

systems.

Two modifications have been made on the condensate

demineralizer

vessels to improve the amount of spent resins removed during resin bed

replacement.

Also, efforts have been made at achieving the best ion exchange

resin mixture to avoid pass-through of impurities.

These efforts serve to block

some of the more controllable sources of addition to the radioactive source term.

By the end of 1992, the licensee will have developed

a plan for reducing the

existing radioactive source term for the future.

Other station modifications affecting lower station exposures include RWCU

pump replacement, elimination of unnecessary

pipe support snubbers,

and

replacement of control rod blades.

After several years of accruing significant

exposures performing frequent maintenance

on RWCU pump seals, these pumps

will be replaced with seal-less

pumps during the 1992 refueling outages.

The

snubber elimination program will continue over the next four outages with project

0

10

completion expected by the spring of 1994.

Additionally,-approximately 36 control

rod blades containing activated cobalt stellite rollers willbe replaced in both

reactors this year.

By including the 98 control rod blades removed from both

reactor units during previous outages, approximately 37% of all control rod blades

will have been replaced by years end.

As a pilot project for this year, one valve

will be selected to be refaced with a low-cobalt containing hard face material to

measure

its performance

as a substitute for the high-cobalt containing traditional

stellite valve facing material.

In summary, the licensee has shown continued

attention to the lowering of the station's radiation exposure sources.

8.0

External Dosimet

The inspector reviewed the licensee's program for external dosimetry and external

exposure control.

Areas reviewed included:

dosimetry laboratory operations,

dosimetry exchange

and issue, field handling of dosimetry, and exposure control.

8.1

Dosimet

Laborato

0 erations

The Thermolum>nescent

Dos>metry (TLD) processing laboratory is located in the

licensee's office located in Allentown, Pennsylvania.

An inspection of this

laboratory was conducted on July 29 - August 2, 1991'.

The. current Susquehanna

based inspection focused on the review of the operations at the Allentown facility

that interfaced with the Susquehanna

site dosimetry operations.

The licensee utilizes the Panasonic Model UD-802-AS1 dosimeter which contains

two lithium borate TLDs and two calcium sulfate TLDs for determining personnel

record exposures.

This Panasonic

system has been in place since May 1987.

The

TLD laboratory is currently National Voluntary Laboratory Accreditation Program

(NVLAP) qualified in all ionizing radiation categories including neutron radiation

for the specified dosimeter.

The fairly recent qualification in neutron dose

measurement

had not been incorporated into station use at the time of this

inspection.

Vendor services continued to supply results for licensee records of

neutron exposures.

The licensee plans to perform in-field neutron spectrum

measurements

over the next two refueling outages and incorporate appropriate

correction factors in the TLD dose calculation algorithm. Additional software

, 'nspection No. 50-387/91-12; 50-388/91-12

changes are required prior to integrating the neutron monitoring category into the

licensee's

dose tracking system.

~ The TLD laboratory processes

approximately 3000 station TLDs on a monthly

basis with an inventory of some 13,000 TLDs. Element Correction Factor (ECF)

determinations are performed every 18 months for each TLD. Prior to reading

the personnel TLDs, the badges are surveyed for contamination, and,

accountability of all badges

is verified. After a 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> delay to account for fade,

the TLDs are read and a'omputational algorithm is used to compute the

resultant dose.

Doses are computed for shallow dose (0.007 cm depth), eye dose

(0.3 cm depth), and deep dose,(1 cm depth).

Prior to reissuing a personnel TLD,

the badges are annealed,and

checked to verify that complete anneals are attained

with each TLD reset to its ground state with no residual exposure energy retained

in the TLD (<10 mR). The lab technician cross checks final personnel TLD

results with the results obtained from the direct reading dosimeter (DRD) data for

the same time period.

Any anomalies require resolution by an appropriately

qualified HP Specialist.

The inspector reviewed the laboratory-to-site operation interfaces to determine

possible causes for mishandling or misprocessing of personnel dosimeters or

dosimetry data.

Appropriate cross checks have been incorporated to ensure,

accurate TLD issuance and processing results.

8.2

Dosimet

Issue & Exchan

e

Dosimetry is normally issued to personnel from the North or South Guard Houses

located at the entrance to the Restricted Area. Initial issue requires that

appropriate training, exposure history, baseline bioassay, and security background

investigation have been completed.

TLD numbers are assigned from the

Radiation Monitoring System (RMS) mainframe computer system at initial issue.

DRDs are allocated to the department supervisors for issuance

as needed.

Extremity TLDs and multiple whole body dosimetry are handled at the Unit 1 HP

Access Control Center.

Processing of the normal whole body TLD prior to issuing

multiple dosimetry monitoring packets is not generally required.

Normally, the

regularly worn whole body TLD is exchanged

at the Unit 1 HP Access Control

Center for the required multiple whole body badge packet.

Upon exiting the

RCA the multiple badge packet is again exchanged for the normal whole body

TLD badge.

The inspector noted that contrary to station radiation protection

policy, radiation workers are given their multiple whole body TLD packets in a

hand held bag without provision for whole body monitoring between the neck and

the waist of the individual. The licensee agreed to revise this current practice to

maintain wearing one of the whole body monitoring TLDs on the upper body area

at all times within the RCA.

Appropriate TLD control badges are placed in the North and South Guard

Houses and at the Unit 1 HP Access Control Center for background radiation

measurement.

During dosimeter exchanges,

the freshly annealed replacement

= TLDs are brought to the site and a manual verification of the badges to the active

dosimetry list is made.

TLDs are exchanged

on a one-for-one basis and all of the

collected TLDs are inventoried against the same active dosimetry list. Badges are

.taken to the Allentown dosimetry laboratory and surveyed for contamination (The

licensee stated that they have never had a contaminated badge).

The badges are

prepared for automatic TLD reader feed, daily QC routines are completed and

known exposed TLDs (reference standards)

are sandwiched in the reading

sequence

providing one reference standard TLD for every 50 badges.

After the

TLDs are read, the raw data is reviewed for correct computer file names and for

accountability of badges and then the final dose results are computed using the

appropriate dose algorithm. The background and reference standard TLD results

are'verified before the final results are downloaded into the RMS mainframe

computer system by TLD number and resultant dose.

TLD issue determines the

correspondence

between TLD number 'and personnel deinographics which allows

for correct dose history assignment.

As mentioned before, TLD processing

anomalies require the review and approval of appropriate HP specialists.

Any

final dose assignments

that required HP supervision resolution of conflicting data

. require the individual's concurrence prior to updating his or her exposure history

with the dose assignment.

The inspector was satisfied that the licensee has

provided appropriate quality control of the dosimetry processing and dose

assignment

activities.'.3

Dosimet

Field Handlin

After initial dosimetry issue, the worker is responsible for properly locating his

'osimetry

on the front upper body area.

HP technicians are responsible for

affixing the various multiple dosimeters to the appropriate body parts after

reading the DRDs and recording the initial readings.

After job execution, the HP

technician is again responsible for removing the dosimeters and recording the final

readings on the appropriate Radiation Work Permit (RWP) sign-in sheets.

Any

relocation of the normal singular whole body TLD and direct reading dosimeter to

another part of the whole body can only be performed by an HP technician as

dictated by the workers'adiation environment.

8.4

-

Ex nsure Control

TLD results serve as the basis for recording of personnel exposures.

Between the

routine monthly reading of these dosimeters, the direct reading dosimeters serve

to control individual exposures within station administrative and regulatory limits.

Monthly comparisons between TLD results and DRD results are routinely

performed to verify the adequacy of using the DRD for exposure control

purposes.

The licensee stated that on the average, DRD results have been 4%

'

higher than the record TLD results.

13

The station has various administrative dose control levels that require higher levels

of management

approval for each dose step increase.

Each worker is required to

know his or her allowable dose limit which is required for RWP sign-in. This

information is provided in an RMS computer report made up of the latest TLD

data supplemented

with DRD data called the RMS Exposure Tracking Report,

This report is issued daily throughout the year and twice:per day during outages.

The RWP sign-in sheets provide the HP technician with the information needed to

control exposures within the administrative and regulatory limits. The inspector

was satisfied that appropriate exposure control measures

were in place.

In

general, the licensee appeared

to have well controlled external dosimetry

processing and reporting programs in place.

9.0

K~M

The inspector met with licensee representatives

at the conclusion of the

inspection, on January 24, 1992.

The inspector reviewed the purpose and scope of

the inspection and discussed

the findings.

0