ML17158A547
| ML17158A547 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/26/1994 |
| From: | Bores R, Randolph Ragland NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A546 | List: |
| References | |
| 50-387-94-21, 50-388-94-22, NUDOCS 9411030073 | |
| Download: ML17158A547 (16) | |
See also: IR 05000387/1994021
Text
'I
U. S.
NUCLEAR REGULATORY COMMISSION
REGION I
Inspection
Nos.
50-387/94-'21;
50-388/94-22
Docket Nos.
'.
50-387;
50-388
License
Nos.
Licensee:
Facility Name:
Inspection At:
Power
and Light Company
2 North Ninth Street
Allentown, Pennsylvania
18101
Susquehanna
Steam Electric Station,
Units
1
& 2
Berwick, Pennsylvania
Inspection
Conducted:
September
12
16,
1994
Inspector:
R.
C. Ragland
Jr.,
Radiation Specialist
Approved by:
Dr.
R, J.
es,
Chief
Facilities Radiation Protection Section
Areas Inspected:
Announced inspection of the radiation protection
program at
the Susquehanna
Steam Electric Station.
The inspection principally focused
on
the implementation of the revised
10 CFR 20 regulations,
including use of new
radiation dose limits, definitions,
and respirator
use philosophy.
Special
emphasis
was placed
on procedures,
training,
and policies associated
with
control of high radiation areas
(HRAs)
& very high radiation areas
(VHRAs),
planned
special
exposures
(PSEs),
declared
pregnant
women
(DPW), control of
embryo/fetus
dose,
and reviews for maintaining total effective dose equivalent
(TEDE)
as low as reasonably
achievable
(ALARA).
The inspector also performed
station tours
and reviewed routine radiological controls
and
an August 30,
.
1994, incident that
had the potential for an unplanned
exposure to several
individuals.
Results:
The overall implementation of the revised
10 CFR 20 regulations
was
found to be very good.
Training lesson
plans
were comprehensive
and complete,
implementing procedures
included appropriate
changes,
and individual knowledge
of the changes
to the regulations
was good.
Procedural
controls, training,
and policies for HRAs and
DPW, embryo/fetus
dose,
and maintaining total
effective dose equivalent
ALARA were very good.
The August 30,
1994, incident
that could have resulted
in an unplanned
exposure to several
workers resulted
from a system evolution that caused
a significant increase
in the radiation
levels in the Condenser
Demineralizer
Resin Regeneration
Room.
The unplanned
94ii030073 941026
ADOCK 05000387
8;
".
exposure
was prevented
by prompt action
by the Nuclear Plant Operator
controlling the evolution, but the lack of procedural
controls to prevent
such
an occurrence
is
a significant concern.
Corrective actions to prevent
recurrence
had
been initiated by the licensee.
No other safety concerns
and
no violations of regulatory requirements
were identified by the inspector.
DETAILS
1. 0
INDIVIDUALS CONTACTED
1.1
PRINCIPAL LICENSEE EMPLOYEES
K. Chambliss,
Manager of Operations
T. Dalpiaz,
Manager of Nuclear Maintenance
J.
Finnegan,
Nuclear Compliance Supervisor
A. Fitch, Operations
Training
D. Hagan,
Health Physics Supervisor
R. Kessler,
Health Physics Specialist,
Dosimetry
G. Kuczynski, Nuclear Plant Services
Manager
J.
Lex, Training Supervisor
E. Mcilvaine, Health Physics
Foreman,
M. Micca, Health Physics Training
D. Pfendler,
Health Physics-Operations
R.
Prego,
Site guality Verification Supervisor
B. Rizzo,
Instructor-Susquehanna
D. Shane,
Health Physics Assistant
Foreman
G. Stanley,
Vice President,
Nuclear Operations
P. Taylor, Nuclear General
Training Instructor
,
G. Walker, Health Physics Assistant
Foreman
R.
Wehry,
Compliance
Engineer
NRC EMPLOYEES
M. Banerjee,
Senior Resident
Inspector
Denotes
attendance
at the exit meeting
on September
16,
1994.
The inspector
also contacted
other licensee
personnel
during the course
of the inspection.
2.0
PURPOSE
AND FUNCTIONAL AREAS INSPECTED
The inspection
was conducted
to review the implementation of the revised
10 CFR 20 regulations
including use of new radiation
dose limits,
definitions,
and respirator philosophy.
The following areas
were
reviewed during the inspection.
implementation of the revised
dose limits, definitions,
and
respirator philosophy
(HRAs)
& very high radiation areas
(VHRAs)
declared
pregnant
women
(DPW)
8 embryo/fetus
dose
TEDE-ALARA reviews
5. respiratory protection
planned special
exposures
4
station tours
routine radiological controls
4
ACTIONS ON PREVIOUS
INSPECTION FINDINGS
4.0
(Open)
NRC Unresolved
Item 387/91-10-01
The inspector
reviewed the
licensee's
actions related to radioactive contamination
found outside of
the radiologically controlled area
(RCA) in the cement silo building on
July 8,
1991.
The inspector
interviewed
a Health Physicist-
Environmental
Services
who was assigned
to evaluate
release
pathways
and
estimate
or calculate
doses.
The inspector
found these evaluations
and
calculations
to be of high quality.
However, this document
was still in
a "Review" status
and several
action items are not scheduled for
completion until 12/31/1994.
This matter remains
open pending
completion of those action items
and
NRC review of them.
GENERAL REVIEW OF
IMPLEMENTATION OF REVISED 10 CFR 20
REGULATIONS
4.1
A general
review of the implementation of the revised
regulations
was performed to verify and evaluate
the use of new dose
limits, definitions,
and policies for maintaining total effective dose
equivalent
as low as reasonably
achievable.
The evaluation
was
performed
by a selected
review of procedures,
training documents,
plant
postings,
and interviews with licensee
personnel.
PROCEDURES
4.2
The following general
implementing procedures
for radiation protection
were reviewed
by the inspector.
NDAP-00-0620,
Rev.
1,
"Conduct of Health Physics"
NDAP-00-1191,
Rev.
2,
"ALARA Program
And Policy"
NDAP-00-0626,
Rev.
2, "Radiologically Controlled Area Access .and
Radiation
Work Permit
(RWP) System"
NDAP-00-0625,
Rev. 3,
"Personnel
Radiation
Exposure Monitoring"
NDAP-00-0624,
Rev.
2, "Respiratory Protection Policy And Program"
These
procedures
were found to contain the
new terms
and definitions,
respirator philosophy,
and information on postings required
by the
implementation of the revised
10 CFR 20 regulations.
The information
provided in these
procedures
pertaining to the revised
regulations
was noted
as
good by the inspector.
TRAINING
The following training documents
were reviewed
by the inspector.
HP-002,
Rev.
4,
"Health Physics
Level II Training"
HP-002R,
Rev.
6,
"Health Physics
Level II Retraining"
GET-OIR,
Rev.
5,
"General
Employee Retraining"
HP-007,
Rev.
6,
"Respirator Training/Retraining"
HP-157,
Rev.
0,
"The Revision
To
10 CFR 20 - Standards
For Protection
Against Radiation"
Station Respiratory
Philosophy Training
These
lesson
plans
and study guides
were found to be informative,
comprehensive,
and adequately
addressed
the revised
regulations.
4.3
INTERVIEWS WITH PLANT PERSONNEL
The inspector
c'onducted
interviews with various station personnel
to
assess
individual knowledge
and acceptance
of the revised
regulations.
In general,
individuals contacted
were knowledgeable
of
recent revisions to radiation protection regulations
and
upon
questioning,
these individuals appeared
to possess
an acceptable
level
of knowledge.
Individuals felt that they had
been provided adequate
training and/or
had ready
access
to information associated
with the
changes
to the regulations.
The inspector
concluded that general
implementation
and communications
to plant personnel
of the revised
10 CFR 20 regulations
were good.
No
safety concerns
or violations were noted
by the inspector.
5.0
8
VERY HIGH RADIATION AREAS
The inspector
reviewed the licensee's
controls for access
to high, and
very high radiation areas.
The review was with respect
to the
.
requirements listed in 10 CFR 20 and the guidance listed in Regulatory
Guide 8.38,
"Control of Access to High And Very High Radiation Areas in
Nuclear
Power Plants".
The evaluation of the licensee's
performance
was
based
on
a review of
procedures,
lesson
plans,
and other documents,
discussions
with
cognizant personnel,
and independent
inspector observations
during tours
of the station.
5. 1
TRAINING AND INSTRUCTIONS
5. 1..1 General
Em lo ee Trainin
The inspector
reviewed the following documents
to evaluate
the training
provided to plant personnel
concerning
access
to HRAs and
HP-002,
Rev.
4, "Health Physics
Level II Training"
HP-002R,
Rev.
6, "Health Physics
Level II Retraining"
GET-OIR, Rev.
5,
"General
Employee Retraining"
HP-157,
Rev.
0,
"The Revision
To
10 CFR 20 - Standards
For Protection
Against Radiation"
Specifically, the inspector
reviewed these training documents
to
evaluate
information provided in the following areas.
hazards
associated
with working in HRAs and
recognition of posted
HRAs and
access
controls for HRAs and
VHRAs including radiation work
permits,
use of keys, etc.
worker responsibilities while in HRAs and
use of radiation survey instruments
and digital dosimetry
industry events
and lessons
learned
from events
involving near or
actual
The inspector verified that each of the training areas
was addressed
and
found the level of information concerning
access
and control to HRAs and
VHRAs to be appropriate.
5. 1.2 Trainin
and
ualifications For Health
Ph sics Technicians
HPTs
The inspector
reviewed training
and qualifications for licensee
and
contract health physics technicians
(HPTs) with respect
to
HRAs and
This review was performed
by
a selected
review of procedures
and
training documents,
discussions
with cognizant personnel,
and interviews
with several
health physics technicians.
Specifically, the review was
performed to determine
the following.
if sufficient training is provided to contract
HPTs with respect
to high radiation
dose rates potentially found in HRAs and
if industry events
and lessons
learned
from events
involving near
or actual
are included in continuing training,
if HPTs are knowledgeable of their job coverage responsibilities
associated
with HRAs and
VHRs
if HPTs are knowledgeable of their stop-work responsibilities,
with respect
to departures
from the radiological conditions or
work scope
5.1.2.1
Health Physics Technician Training
The inspector
reviewed the following training documents.
HP076,
Rev.
4,
HP087,
HP134,
HP091,
HP135,
HP152,
HP155,
HP157,
Rev.
2,
Rev.
0,
Rev.
0,
Rev.
0,
Rev.
0,
Rev.
0,
Rev.
0,
HP158,
Rev.
0,
"SSES Health Physics
Practices
For Contractor
Technicians"
"Health Physics Technician Practices"
" Industry Events"
"Radiological Job Coverage"
"The Revised
"Nonstochastic
Effects of 10CFR20"
"10CFR20 Procedure
Implementation"
"The Revision
To 10CFR20
Standards
For the
Protection Against Radiation"
"Applied 10CFR20"
The review indicated that licensee
and contract health physics
personnel
are required to complete specific procedural training
and on-the-job
(OJT) training prior to assuming
independent
in-
plant work assignments
including work in HRAs or VHRAs.
Specifically, training included instruction
on the following
areas.
Radiological controlled area
access
and radiation work
permit
(RWP) system
HRA and
VHRA access
key control
Use of alarming dosimeters
Posting
and labeling
HRAs and
Health physics technician
stop work authority
Boiling water reactor specific systems training including
o
Reactor water clean-up
system
o
Liquid radwaste
processing
o
Fuel
pool clean-up
system
o
Traversing in-core probe
system
" o
Fuel handling
ALARA blocking for systems
t
Industry events
The inspector
found that the level of training provided to
licensee
and contract health physics technicians
was very good.
Lesson
plans
included revisions to
10 CFR 20 and adequately
addressed
work in HRAs and
5. 1.2.2
Health Physics Technician
Knowledge
The inspector
interviewed three
HPTs to evaluate
individual
knowledge of job coverage responsibilities
associated
with HRAs
and
VHRAs and stop-work responsibilities
with respect
to
departures
from expected radiological conditions or work scope.
These individuals were thoroughly knowledgeable of procedures,
controls,
and work practices.
Ho safety concerns
or violations
were identified.
The inspector
concluded that
HPTs were provided with sufficient
training,
had knowledge of their responsibilities,
and were
qualified to control work in HRAs and
VHRAs ~
5. 1.3
0 erator Trainin
The inspector
reviewed selected
reactor operator
lesson
plans for
radiation protection.
Although
a complete review was not performed,
the
inspector did verify that specific operator procedures
did include
radiological controls,
and that operations
personnel
had received
training
on these
procedures.
The inspector noted that the training
appeared
to be good in that it was procedure-based.
However, the
inspector
commented that consideration
could
be given to developing
a
lesson
plan that identifies procedures
in which operator actions
can
affect radiological conditions (e.g., start-up,
fuel movement,
fuel pool
work, resin transfers,
etc.),
and what communications
with HP are
necessary.
The licensee
acknowledged
the inspector's
comment.
PROCEDURES
AND WORK PRACTICES
The inspector
performed
a review of procedures
and work practices
for
access
to
HRAs and
The review was performed with respect
to the
requirements
of 10 CFR 20 and the guidance listed in Regulatory
Guide
8.38.
5.2.1
Procedures
The following procedures
were reviewed
by the inspector.
HP-AL-400,
HP-TP-310,
HP-TP-311,
HP-TP-312,
HP-TP-320,
HP-TP-500,
Rev.
8,
Rev.
13,
Rev.
8,
Rev.
2,
Rev.
11,
Rev.
13,
HP-HI-051,
Rev.
9,
NDAP-00-0620,
Rev.
1,
NDAP-00-1191,
Rev.
2,
NDAP-00-0626,
Rev.
2,
"Conduct of Health Physics"
"ALARA Program
And Policy"
"Radiologically Controlled Area Access
and
Radiation
Work Permit
(RWP) System"
and Evaluations"
"Posting
and Labeling"
"Locking Barricading
and
Key Control"
"Control of High Rad Sources"
"Radiation Work Permits
(RWPs)"
"Survey Techniques for Radiation,
High
Radiation,
and Very High Radiation Areas"
"Controls For Health Physics
Work on the Refuel
Floor"
Procedural
controls addressed
requirements
for access
to specific
and
VHRAs such
as transient
HRAs, the reactor water clean-up
(RWCU) and
fuel pool clean-up
(FPCU) hold
pump rooms,
TIP rooms,
RWCU and
backwash receiving tank rooms,
RWCU phase
separator
tank rooms,
phase
separator
pump rooms,
waste
sludge
phase
separator
tank rooms,
waste mix
tank room,
and the refueling platform.
Also, specific requirements
for
access
to
a
VHRA were listed in NDAP-00-0626.
Requirements
for access
to a
VHRA includes
a special
RWP, approval
from health physics
supervision,
approval
by the Vice President
Nuclear Operations,
coverage
by
a. Health Physics
Level II Technician,
a pocket alarming dosimeter
(PAD), pre-job briefing, system blocking as appropriate,
and
a unique
key.
The inspector
found the procedural
controls for access
to HRAs and
to be very good.
.I.I~
The inspector evaluated
the control of HRA access
keys.
The evaluation
was performed
by a review of selected
procedures
and training documents,
discussions
with cognizant personnel,
and
an examination of the key
storage
and issue
area.
The inspector
reviewed Health Physics
Procedure
HP-TP-311,
Rev.
8,
"Locking Barricading
and
Key Control".
The procedure
governs
the use
and control of keys including
HRAs and
Keys are color coded for
control purposes.
Keys for radiation areas
are tagged
green;
keys for
HRAs <1000 mrem/h are tagged
orange;
keys for HRAs >1000 mrem/h but
-.
<10,000
mrem/h are tagged blue;
and
keys for areas
>10,000 mrem/h
including
VHRAs are tagged black.
HRA keys are maintained
and issued
from the Health Physics office or in special
circumstances
(e.g.,
during
outages)
from some health physics control points. 'ach
issuance
of a
key to
a
HRA is logged
on
a "HI-Rad Key Issue
Log".
Keys are
inventoried
on
a daily or more frequent basis.
After keys for HRAs are
returned,
independent verification is preformed to assure
the lock is
secured,
and the verification is documented
on the HI-Rad Key Issue
Log.
Discrepancies
are reported to health physics'upervision.
Keys to areas
with dose
r ates
>10,000 mrem/h,
and for VHRAs are maintained
in a
separate
cabinet.
Currently, there
are only two locations at the plant
that are classified
as
These
areas
are the Traversing
In-core
Probe
(TIP)
Rooms in'each unit.
'he inspector
found that the storage
and control of keys for HRAs and
VHRAs were well organized
and effective in maintaining
HRA and
access
control.
5.2.3 Individual Knowled e
5.3
The inspector
interviewed supervisory
and non-supervisory
personnel
from
the maintenance
and health physics organizations
to evaluate their
knowledge of procedural
controls for access
to
HRAs and
All of the individuals interviewed were familiar with access
controls
for work in HRAs and
VHRAs including postings,
key control, procedures,
and radiation work permits.
The inspector
concluded that procedural
and work practice controls for
access
to HRAs and
VHRAs were consistent with the requirements
of 10 CFR 20 and the guidance listed in Regulatory
Guide 8.38.
Procedures
included appropriate definitions, survey requirements,
and controls for
access
and control of entry into HRAs and
Appropriate procedures
were in place
and being used for the control, maintenance,
and
use of
keys to HRAs and
Finally, individual knowledge of procedural
controls for access
to HRAs and
VHRAs was good.
No safety concerns
or violations were noted.
MANAGEMENT AND SUPERVISORY OVERSIGHT
The inspector
performed
a review of management
and supervisory oversight
of HRAs and
The review included training, procedures,
self
assessments
and corrective actions,
awareness
of HRA and
VHRA conditions
and access
controls.
The evaluation of the licensee's
performance
in this area
was
based
on
discussions
with personnel,
a review of training documents,
a review of
procedures
revised
as
a result of changes
to
and
a review of
recent corrective actions.
6.0
10
The inspector
found that supervisory
and management
personnel
were
aware
of conditions
and controls for HRAs and
Management
oversight
was
evidenced
by the quality of procedures
and training provided for HRAs
and
VHRAs, corrections of deficiencies,
and by communications
between
work groups
and supervisory
and management
personnel.
Management
and supervisory oversight of HRAs and
VHRAs was determined to
be good.
No safety concerns
or violations were identified.
DECLARED PREGNANT WOMEN 8
EMBRYO/FETUS DOSE
7.0
During combined
NRC inspections
Nos.
50-387/94-07
and 50-388/94-08,
the
adequacy.
and implementation of controls for Declared
Pregnant
Women
(DPW)
and embryo/fetus
doses
were reviewed.
The inspector
concluded
that the procedural
controls,
dose'evaluations,
work practices,
and
training for DPW were effective in maintaining exposures
to the
embryo/fetus
at
a uniform rate
and within regulatory limits.
However,,
the inspector did point out that
as
a result of revisions to training
modules that are required to obtain unescorted
access
to the restricted
area
(Health Physics
Level I
8 II), the focus
and emphasis for prenatal
radiation exposure training had shifted to
a training module provided
only to
DPW.
In response
to this observation,
the licensee
incorporated
additional
information concerning
the effects of prenatal
radiation
exposure
into Health Physics
Level
I
5. II training.
The inspector
reviewed these revisions during the current inspection,
and found them
to be appropriate.
No safety concerns
or violations were identified.
TEDE/ALARA
7.1
TEDE/ALARA TRAINING
The following documents
were reviewed to evaluate
the training provided
to plant personnel
concerning efforts to maintain
HP-002,
Rev.
4, "Health Physics
Level II Training"
HP-002R,
Rev.
6, "Health Physics
Level II Retraining"
GET-01R,
Rev.
5,
"General
Employee Retraining"
HP-007,'Rev.
6, "Respirator Training/Retraining"
HP-157,
Rev.
0,
"The Revision
To 10 CFR 20 - Standards
For Protection
Against Radiation"
"Station Respiratory Protection
Use Philosophy Training"
The inspector
noted that the majority of training relative to efforts to
maintain
TEDE ALARA was included in the "Station Respiratory
Philosophy
Training".
This training was conducted
by health physics supervision
through
a series of "tailboard" meetings with station personnel.
This
training introduced the
TEDE-ALARA concept
and went
a step further to
incorporate
the "total risk" (i.e.,
TEDE ALARA and industrial safety) to
workers in order to provide the best overall protection.
'
7.2
Licensee
personnel
also pointed out that formal training was
supplemented
by
RWP and
ALARA pre-job briefings.
They emphasized
that
the, evaluation for use of respiratory protection is based
on
a detailed
review of actual
and expected radiological
and environmental
conditions.
The inspector
concluded that the goals of the respiratory protection
program relative to efforts to achieve
TEDE ALARA and explanations for a
general
decrease
in use of respiratory protection were being adequately
communicated to station personnel.
WORKER ACCEPTANCE
7.3
The inspector interviewed several
plant workers,
including first line
supervision,
to determine
the level of knowledge
and support for the
station's policies
and procedures
for maintaining
Workers stated that they had received training on the
TEDE-ALARA concept
that included explanations for recent efforts to decrease
respirator
use.
They indicated that
as
a result of training there is
a general
acceptance
of the
new respirator protection policy.
They feel that work
efficiency increases
without respirators.
In addition,
the recent
success
in reducing respirator
usage
achieved during the last outage
has
resulted
in even greater
acceptance
and trust building between plant
workers
and the health physics organization.
They also stated that
although it is ultimately the responsibility of the health physics
organization to specify the use of respiratory protection,
workers are
included in the decisionmaking
process.
The inspector
noted that, in general,
workers were in agreement
with and
supported
the efforts to maintain
a reduction in
the use of respiratory protection.
However, this support
was limited to
situations that involved only minor or negligible intakes of radioactive
material.
Workers did not support the
TEDE-ALARA concept
when it
involved measurable
uptakes of radioactive material
even if the uptake
could
be justified by maintaining
TEDE-ALARA EFFORTS
The'inspector
examined licensee efforts to maintain
reviewing recent respirator
use
and
use of process
and engineering
controls to control concentrations
of radioactive material
in air.
7.3.1
Res irator Use
The most notable indicator of licensee efforts to maintain
was the reduction in respirator
use that
has
occ'urred
be'tween
1992
and
1994.
In 1992 approximately 7,300 respirators
were issued;
in 1993
approximately 2,700 respirators
were issued;
and in 1994 approximately
1,300 respirators
have
been
issued.
Although there were two outages
in
1992, there still has
been
a significant decrease
in the use of
respirators.
This decrease
in respirator
use
has
been attributed to
12
issuing respirators
only when conditions require respirator
use,
and
use
of process
and other engineering controls.
7.3.2
Process
and Other
En ineerin
Controls
The inspector
reviewed the licensee's
use of process
and engineering
controls to minimize work area
and airborne radioactivity and to
maintain
The inspector performed
a selected
review of jobs
with a high potential for airborne radioactivity.
The licensee
had documented
in ALARA reviews
and
RWPs frequent
use of
high efficiency particulate air (HEPA) filtration units; decontamination
by pressure
washing,
wiping by hand,
and vacuuming;
wrapping or covering
contamination;
and changes
in the work processes
to reduce
work area
.contamination
and airborne radioactivity.
The inspector also noted,
that dose associated
with the implementation of engineering
controls
was
being factored into TEDE-ALARA evaluations.
Based
on this review, the inspector concluded that process
and other
engineering
controls were being
used in accordance
with 10 CFR 20. 1701
to the extent practicable,
to control the concentrations
of radioactive
material
in air,
and
as
an alternative to the
use of respiratory
protection.
IMPLEMENTING PROCEDURES
7.5
The inspector
reviewed
HP-AL-400, Rev. 8,
and
Evaluations",
to evaluate
procedural
guidance
used for the performance
of TEDE-ALARA reviews.
The procedure
includes
an extensive
check list
used to evaluate
the need for process
and other engineering controls,
industrial safety respiratory considerations,
and methods for estimating
total derived air concentration-hours
(DAC-hrs) based
on contamination.
In addition,
the procedure
includes
a "Respiratory Protection/ALARA
Review" paradigm (decision diagram) to assist
in the evaluation for the
need for respiratory protection.
Also, the procedure
includes
several
graphs of "Ambient DAC VS Dose Rate,
Respirator Selection Criteria"
which assume
a
20% efficiency gain by not wearing respiratory protective
equipment.
The procedure
also allows for use of efficiency gains other
than
20 percent if necessary.
The inspector
concluded that appropriate
guidance for the performance of
TEDE-ALARA reviews
was provided,
and also noted that inclusion of
industrial safety risks in respirator-use
evaluations
was
a good
practice.
SELECTED SNPLE
OF TEDE-ALARA REVIEWS
The inspector
reviewed
a selected
sample of TEDE-ALARA reviews that were
performed using Procedure
HP-AL-400,
and
ALARA In
Progress
Reviews performed using NDAP-00-1191,
"ALARA Program
and
Policy".
Specifically, the inspector's
review was performed to
evaluate
use of work efficiency factors,
estimates
of airborne
13
7.6
concentrations,
historical data,
methods for determining
use of
respiratory protective equipment,
and general
compliance with the
procedure.
The inspector
reviewed evaluations that resulted
in
recommendations
for respirator
use
as well as non-respirator
use.
cj
The inspector
found that the use of work efficiency factors,
estimates
of airborne activity, historical data,
and methods for evaluating
respiratory protection
use were reasonable.
Respirator
use evaluations
were performed
and documented
in accordance
with the procedures
and
no
safety concerns
or violations were noted.
FACIAL CONTAMINATIONS
7.7
8.0
The inspector
performed
a review to determine if there
had
been
an
increase
in facial
and nasal
contaminations
associated
with decreased
use of respiratory protection,
and if any corrective actions
were taken
as
a result.
'The inspector
was informed that in 1994 to date,
there
had
been
48 facial contaminations.
Approximately
90% of these
have
been
attributed to decreased
respirator
use.
All of these
contamination
events
have
been less
than
10,000
dpm/100
cm', with no significant
uptakes of radioactive material.
No safety concerns
or violations were identified.
TEDE/ALARA IMPLEMENTATION CONCLUSIONS
The inspector
concluded that licensee efforts to maintain worker's
ALARA were very good.
Training was effective in obtaining worker
acceptance,
and licensee efforts were focused
on use of engineering
controls rather than reliance
on respiratory protection.
In cases
where
engineering
controls were not practical,
the licensee
increased
monitoring
and limited intakes
by access
control, minimizing staytimes,
and
use of respiratory protective equipment.
In addition,
TEDE-ALARA
reviews
appeared
to be effective in minimizing total effective dose
equivalent for work in airborne radioactivity areas.
PLANNED SPECIAL EXPOSURES
A review was performed to determine if the licensee
had implemented
provisions for planned special
exposures
(PSEs),
and, if so,
was the
guidance
provided in accordance
with 10 CFR 20. 1208.
The inspector
was
notified that
are not planned to be used during normal operations.
As
a result, there
are
no procedural
provisions for PSEs.
No violations or deficiencies
were noted.
9.0
STATION TOURS
HOUSEKEEPING
AND PLANT CONDITION
The inspector toured the Susquehanna
Station periodically during the
inspection
and reviewed station conditions.
Housekeeping
and material
conditions
were generally good.
Walkways
and aisles
were uncluttered,
14
free of debris,
and well illuminated.
Radiological control boundaries
were well maintained
and posted properly.
The inspector pointed out that there were several
minor instances
of
materials
being stored outside of designated
storage
areas
in the Unit I
and Unit 2 reactor buildings.
No deficiencies
or safety violations were identified.
ROUTINE RADIOLOGICAL CONTROLS
The inspector
reviewed routine radiological controls,
including control
of work in radiologically controlled areas,
and radioactive material,
contaminated
material,
and contamination control.
The evaluation of the
licensee's
performance
in this area
was
based
on discussions
with
cognizant personnel,
a selected
review of RWPs
and procedures,
in-plant
tours,
and independent
observations.
The following specific items- were
evaluated.
posting,
barricading
and access
control
as appropriate
to
contaminated,
radiation,
posting
and labeling of contaminated
and radioactive material
use of calibrated
and source
checked
equipment
use of radiation work permits
personnel
adherence
to radiation protection procedures,
radiation
work permits,
and good radiological control practices
Radiological control boundaries
were clearly delineated
and posted
properly.
All locked high radiation areas
checked
were securely
locked
according to procedures.
All RWPs reviewed
had proper authorizations,
and satisfactorily addressed
radiological
hazards.
All portable survey
instruments
checked displayed
evidence of calibration
and daily source
checks.
POTENTIAL FOR
UNPLANNED EXPOSURE
The inspector
reviewed
an August 30,
1994, incident that occurred in the
Unit 2 Condenser
Demineralizer
Resin Regeneration
(CDRR)
Room that was
referred to by the licensee
as
a near miss.
As described
by licensee
personnel,
a Nuclear Plant Operator
(NPO) started to transfer resin into
a tank in the Unit 2
CDRR
Room while individuals were in the room.
At
the start of the transfer,
the
NPO viewed
a remote
camera monitor for
the
room and noticed that individuals were in the room.
The
immediately notified these individuals
and they exited the area without
receiving significant personnel
exposure
from the increased
radiation
levels
on the tank.
Although high radiation area controls
were in place
at the time (key control, postings,
use of PADs)
AND no operations
or HP
procedures
were violated, it appears
that
no procedural
controls were in
place to prevent
an unplanned
exposure
as
a result of resin transfers
while the
CDRR room is occupied.
This appears
to be
a weakness
and
deserves
management
attention.
15
Upon inquiry, the inspector
was notified that the event
was entered
into
the licensee's
Human Performance
Enhancement
System
(HPES) for review
and evaluation;
a potential corrective action
was also entered
into the
ALARA Suggestion
system for review and evaluation;
and .a team of health
physics
and operations
personnel
was being formed to review operations
procedures
to determine
when radiological controls
and communications
should
be included in procedures.
The inspector
noted that these
actions
appear to be appropriate,
and the
results will be reviewed during
a future inspection.
No violations were noted.
12. 0
EXIT INTERVIEW
The inspector
met with the licensee
representatives
denoted
in Section
1.0 at the conclusion of the inspection
on September
16,
1994.
The
inspector
summarized
the purpose,
scope
and findings of the inspection.
The licensee
acknowledged
the inspection findings.
t