ML17285A203
| ML17285A203 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/05/1989 |
| From: | Cicotte G, North H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A201 | List: |
| References | |
| 50-397-88-41, NUDOCS 8901230429 | |
| Download: ML17285A203 (18) | |
See also: IR 05000397/1988041
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No. 50-397/88-41
Docket No. 50-397
License
No.
Licensee:
Washington Public Power Supply System
P.
0.
Box 968
Richland,
99352
Facility Name:
Washington Nuclear Project
No.
2
Inspection at:
WNP-2 site,
Benton County, Washington
Approved by
Inspection
Conducted:
November
28-Decembe
2,
and
December
Inspector:
G.
R.
icotte, Radiation Specialist
H.
S. North, Acting Chief
Facilities Radiological Protection Section
12"16,
1988
Date Signed
/'e
Date Signed
~Summar:
Ins ection durin
eriod of November 28-December
2
and December
12-16
1988
Re ort No. 50-397/88-41
inspector of solid wastes,
open items, onsite follow-up and tours of the
facility.
Inspection procedures
30703,
84750,
92701,
92702,
93702,
and 83726
were addressed.
Results:
Of the four areas
addressed,
no violations were identified in two
areas.
In one area,
a violation of Technical Specification
6. 12. 1, failure to
use
dose rate monitoring devices in a high radiation area,
was identified
(Paragraph
4).
In another
area,
a previously unresolved
item, 50-397/
88-26-01,
was identified as
a violation of Technical Specification
4. 11.2. 1.2
(paragraph
3.B).-
The licensee's
program appeared
capable of meeting its
safety objectives.
However,
more attention is needed to assure that all
employees
adhere to licensee
procedures.
8. 012~a()$ 4/ 3P() f Q~~
A13OCK 0 000397
lg
'
DETAILS
1.
Persons
Contacted
" C.
M.
"+J.
W.
~+L
L
"+T.
M.
A. I.
~+L
J
"+R.
G.
+D.
A.
+W.
A.
D.
E.
+S.
F.
+D.
R.
"+K. A.
+S.
L.
Powers,
Plant Manager
Baker, Assistant Plant
Manag'er
Bradford, Health Physics Supervisor
Brun, Plant equality Assurance
(gA) Engineer
Davis, Senior Radiochemist
Garvin,
Manager
Programs
and Audits
Graybeal,
Health Physics/Chemistry
Manager
Kerlee, Principal
gA Engineer
Kiel, State Liaison-Licensing
Larson,
Radiological
Programs/Instrument
Calibration Manager
Peters
Plant Administration Manager
Pisacik,
Health Physics
Support Supervisor
Smith,
Radwaste
Program
Leader
Principal Plant Technical
Engineer
+Denotes
those present at the exit interview held on December
2,
1988.
"Denotes
those present at the exit interview held on December
16,
1988.
In addition to the individuals identified above,
the inspector
met and
held discussions
with other
members of the licensee's
and
contractors'taff
and personnel.
2.
Radioactive
Waste
S stems
A.
Audits and
A
raisals
The following audits
and completed/committed
corrective actions
wer e
reviewed:
Audit ¹87-420,
Radioactive
Process
Control
Pro ram,
November 24,
1987
Audit ¹87-420-A,
Corrective Action Follow-u
Review of 87-420
Radioactive
Process
Control
Pro ram,
December
2,
1988
Survei 1.lance ¹2-88-247,
Radioactive
Work Control, October 12,
1988
Audit ¹87-420 resulted in six major findings and 18 additional
concerns.
The Manager,
Programs
and Audits, stated that 87-420-A
was performed
due to the extent
and nature of the findings in
87-420, that
a re-audit of this program area would normally have
been
scheduled
in 1989.
Corrective action or resolution of 87-420
findings
had been completed.
In the 87-420-A review of the
same
activities,
the following concerns
were identified:
Audit ¹87-420 identified a problem with the method of
radioactive waste resin sampling.
Oiscussion with the auditors
and other staff revealed that the transfer/dewatering
system
operator,
a contractor,
obtained resin
samples
during transfer
by reaching into the resin stream with a sample bottle in his .
gloved hand.
The auditor stated that the operator did not use
respiratory or face protection during the sampling.
Other
actions
by the operator,
which had previously been
observed
by
the inspector,
resulted in the identification of concerns
indicative of an apparent laxity in the control of activities
during waste processing
by Health Physics
personnel
(discussed
in paragraph
2.C, below).
Audit ¹87-420-A identified a failure to take committed
corrective action,
again related to hand sampling of resin.
Part of the corrective action f'r audit ¹85-339
had been
completion of Plant Maintenance
Request
(PMR) ¹85-0712-0,
to
install
sample points in the transfer lines, in order to
eliminate direct glove contact with the resin.
The
PMR had not
been accomplished
by the time audit ¹87-420-A was conducted.
The inspector discussed
the appropriateness
of the licensee's
current method.
The licensee
stated that the radioactivity
concentrations
were low enough,
and the duration of contact
short enough,
to meet their criteria for not routinely issuing
extremity dosimetry.
This was verified through representative
review of waste records.
The inspector
expressed
concern that
the variability of concentrations
within each batch of resin
transferred,
and the lack of continuous monitoring of the
transfer lines, might cause
an unmonitored cumulative extremity
dose higher than anticipated
by the licensee.
This matter,
along with air monitoring as discussed
in paragraph
2.C below,
will be examined in a subsequent
inspection
(50-397/88-41-01).
Other problems identified by the audits
noted
above were
failure to have the current revision of a vendor procedure
(the
affected portions
had not been changed),
failure to hold formal
pre-job briefings (corrective action pending),
some equipment
only partially operable (corrective action pending or
corrected),
and inadequate
procedures
with respect
to sample
accountability
and analysis
(corrected).
Overall, the depth
and scope of licensee
audits
appeared
to
have
improved,
and appeared
consistent with guality Assurance
requirements
of 10 CFR 61.55-6.
The inspector
expressed
concerns,
with respect
to response
to the audits,
as noted
above.
The concerns
were acknowledged
by the licensee.
B.
Chanches
No major changes
in the licensee's
program
had taken place since the
last inspection.
A new Radwaste
Program
Leader
(RPL) had been
appointed,
however, in part in response
to audit ¹87-420,
noted
above.
The facility had originally been constructed
to process
resin
and
other wastes
to be solidified into 55 gallon drums.
The licensee
has for some time been
using high capacity
(190 cubic feet (CF))
liners, with low activity resin processing
taking place in the
original drum/liner storage
area.
High activity resins
are
processed
in, the transport
cask,
due to the low capacity
and
shielding limitations of the current drum/liner transport
mechanisms.
The licensee
stated that two improvements
are under
consider ation:
Upgrade or replace
the current bridge-crane rail system,
to
allow heavier and/or
more highly radioactive liners to be
carried remotely with minimal direct handling of rigging, which
would permit increased
storage
in the existing structure.
Construction of a low-level radioactive waste
storage facility
near the current Warehouse
80 storage
area
(see Inspection
Report (IR) 50-397/88-36).
Representative
records of processed
radioactive waste
were reviewed.
The licensee
characterizes
waste for classification using
a computer
software program,
which identifies concentrations
of nuclides which
exceed specified levels.
The
RPL stated that
he verifies each
characterization
by sample calculation.
No errors in the licensee's
methodology were identified,
and default values
used
by the licensee
appeared
to be conservative
with respect to 10 CFR 61 and the
Branch Technical Position
on Radioactive
Waste Classification
requirements.
Resin transfer/dewatering
operations
were observed.
The following
concerns,
identified by the inspector,
were brought to the attention
of the licensee:
A large
number of outstanding deficiency tags
were observed
on
Radwaste
Control
Panel
G-ll-P001-1.
The inspector
noted that
many of the deficiencies
were identified as
a result of the
assessment
of systems
by the licensee
(see
Paragraph
3, item
50-397/88-22-01,
below).
Although the number appeared
high,
discussion with the resident
NRC Inspector revealed that the
licensee
was making progress
in reducing outstanding corrective
maintenance
items.
RWP ¹2-88-00009, for resin processing,
requires
a protective
clothing (PC)
hood when hard hats are required to be worn,
and
glove changes after hose handling.
The operator
wore
a
skull-cap
and
no hard hat in a hard-hat required area,
and did
not change
his gloves, after disconnecting
the fill head
hoses.
A Health Physics Technician
(HPT) was present
but did not
challenge
those actions.
RWP ¹2-88-00009 did not specifically state that either an
escort or alarming integrating dosimeters
would be required for
The inspector
observed
the operator
make
routine entries into an area identified as having radiation
levels greater
than
1000 mrem/h, to operate
processing
equipment.
The operator
was observed to use
dose rate
monitoring equipment or
MP escort
as prescribed
by Technical
Specification
6. 12. 1.
However, lack of such
an
RWP stipulation
had been identi,fied -as
a contributing factor in an earlier
unauthorized
high radiation area entry (see
IR 50-397/88-22).
The operator stated to the inspector that if resin clings to
the fill head after dewatering,
he routinely washes
the resin
down into the liner before
removing the fill head.
The
inspector
asked if humidity and/or water content were again
monitored, or'f such
an action might affect the maximum free
standing water procedural
limitation of 0.5X by weight.
The
operator
responded
that the amount of water
he used
was
minimal.
When the concern
was expressed
to the
RPL,
he stated
that although
he had not been
aware of the practice,
no
instances
of failure to meet the freestanding
water requirement
had
been
observed at the disposal site.
He further stated that
such action
was not permissible,
and that
he would so inform
the operator.
No air sampling
was conducted
during disconnection
and removal
of the dewatering/fill
head
from a full, dewatered
resin liner.
The operator
removed the connections
and reached
into the fill
head,
placing his face within approximately
12 inches of the
openings,
without respiratory or face protection.
No survey of
the interior of the fill head
was conducted during or after
removal
from the liner.
The inspector
expressed
concern to the
HPT at the work site
regarding the lack of either respiratory protection or airborne
monitoring.
The response
was that
no problems
had in the past
been identified.
The inspector
asked the
HP Supervisor
when
that type of operation
had last been monitored for airborne
radioactivity.
The
HP Supervisor stated that it had been
approximately six weeks earlier,
and provided
a copy of the
analysis
record.
The analysis
record did not clearly indicate
whether it addressed
the breathing
zone described
above.
The
inspector
requested
that the licensee
provide an analysis of
whether
more frequent or comprehensive
controls
and monitoring
would or would not be appropriate,
and the basis for those
conclusions.
This matter will be examined in a subsequent
inspection in conjunction with open item 50-397/88-41-01,
identified above.
Although the concerns identified above were noted,
the licensee's
program appeared
capable of meeting its safety objectives.
No violations or deviations
were identified.
0
3.
~Oen Items
~Fol low-u
50-397/IN-88-63
Closed
This refers to an Information Notice (IN)
regarding Traversing In-core Probe
(TIP) hazards.
The licensee
had
received
and distributed the IN.
This matter is considered
closed
(50-397/IN-88-63 Closed).
50-397/IN-88-79 (Closed)
This refers to an IN regarding
misinterpretation of Standard 'Technical Specification
6. 12,
Hi
h Radiation Areas.
The licensee
had received
and distributed the
IN, and plant Health Physics
(HP) personnel
were aware of the
matters
discussed
therein.
This matter is considered
closed
(50-397/IN-88-79 Closed).
50-397/88-22-01
Closed
This matter refers to valve lineups
and
partially unused installed
systems
(see
IR 50-397/88-22,
paragraph
2.C. 1.).
Based
on discussions
with the Assistant Plant Manager,
the
Radwaste
Systems
Engineer,
and the Senior Resident
NRC Inspector, it
was determined that the licensee
had taken action to perform a
comprehensive
assessment
of the status of such systems.
The
licensee
had identified and corrected
erroneous
valve
identifications,
lack of valve identifications,
and system
diagram
errors,
had reperformed
numerous
valve lineups,
and
had developed
a
method for maintaining the improved system status.
This matter is
considered
closed
(50-397/88-22-01
Closed).
50-397/88-22-02
Closed
This matter refers to inadvertent transfer
of highly radioactive resins to a floor drain
sump and subsequent
inadvertent transfer to a floor drain tank (see
IR 50-397/88-22,
paragraph
2.C.3)
~
The licensee
had transferred
the resins for
disposal
and flushed the affected
systems.
Area radiation
dose
rates
were verified by direct measurement
to have
been significantly
reduced.
This matter is considered
closed (50-397/88-22-02
Closed).
50-397/88-22-03
Closed
This matter refers to difficulty in
reading the Area Radiation Monitor (ARM) strip chart recorder,
ARM-RR-600 (See
IR 50-397/88-22,
paragraph
2.C.4).
The licensee
was
performing continuing maintenance
to keep the recorder operating in
a readable
condition.
The recorder
was functional at the time of
the inspection.
This matter is considered
closed
(50-397/88-22-03
Closed).
Follow-u
on Items of Non-Com liance
and Unresolved
Items
50-397/88-26-01
Closed
This matter refers to an interpretation
by
the licensee
of TS 4. 11.2. 1.2 and of TS 4. 11.2.8.3
(See
IR
50-397/88-26,
paragraph
5.B).
The inspector
had concluded that the
licensee's
interpretation
was not correct,
and that this had
resulted in the licensee
being in non-compliance with TS 4. 11.2. 1.2
for many routine primary containment
vents and/or purges
during
plant operation
from November 25,
1985, to the time of that
inspection
(as reported in IR 50-397/88-26).
The licensee
disagreed
with the inspector's
conclusion.
The licensee
had been
informed on July 22,
1988, that this appeared
to be
a violation of TS 4. 11.2. 1.2.
The matter was subsequently
referred to
NRR on August 26, 1988, for review to determine:
If the licensee
is indeed required to obtain
and analyze
grab
samples of primary containment
atmosphere
prior to each vent
and/or purge during operation through the standby
gas treatment
(SGT) system,
in view of the licensee
s interpretation to the
contrary.
If the licensee
is required to include consideration of such
sampling
and analysis
in the calculation of dose rates
using
the methods
contained in the Offsite Dose Calculation Manual
(ODCM).
The results of the review by
NRR were sent to
NRC Region
V on
December
27,
1988.
NRR had concluded that in addition to samples
obtained monthly, or in conjunction with startup,
shutdown,
and
(greater
than
15K) thermal
(which the licensee
had
been obtaining) the licensee
is required to sample prior to each
vent and or purge of the primary containment,
whether or not the
effluent path is through the
SGT system.
NRR further concluded that
the results of sample
analyses
should
be addressed
in the
ODCM.
The inspector verified that the licensee's
previous practice
had
continued despite
discussi,ons
of the inspector's
concerns with the
licensee
on July 22,
1988.
Technical Specification 3/4. 11.2. 1 requires,
in part, that in order
to determine that the dose rate limits of 3. 11.2. 1 are not exceeded,
samples
must
be obtained in accordance
with Table 4. 11-2,
and the
dose rates
determined
in accordance
with the methodology
and
parameters
of the Offsite Dose Calculation
Manual
(ODCM).
Table
4. 11-2 requires,
in part, that iodine and particulate
be obtained prior to each vent and/or purge of the Primary
Containment
atmosphere.
Table 4. 11-2 further requires,
in part,
that these
samples
be analyzed for principal
gamma emitters,
as
specified therein.
The failure to take all the samples
required
and
to include the results of analyses
in dose rate calculations,
in
accordance
with ODCM methods,
appears
to be
a violation of TS
4. 11.2..1.2.
The unresolved
item 50-397/88-26-01 is closed
and item
50-397/88-41-02
is opened
(50-397/88-26-01
Closed)
(50-397/88-41-02
Open).
50-397/88-33-01
o en
This refers to a failure to obtain
a grab
sample of the main plant vent
(MPV) effluent, in accordance
with TS
Table 3.3.7. 12-1 (see
IR 50-397/88-33,
paragraph 4).
The licensee's
timely response
to the Notice of Violation (NOV) was received.
Verification of corrective action will await additional testing
'
during the next refueling outage,
to which the licensee
committed in
their response
to the
NOV.
The licensee
was reminded that the
results of a test conducted
October ll, 1988,
could not be
considered
conclusive, with respect to continued operability of the
HPV effluent radiation monitor,
REA-SR-37,
under low flow
conditions.
This matter will remain
open pending review of the
results of the tests
(50-397/88-33-01
Open).
50-397/88-36-01
0 en
.
This refers to a failure to post
a
radiation area in accordance
with 10 CFR 20.203.
(See
IR
50-397/88-36,
paragraph
5).
The licensee's
timely response
to the
NOV was received.
The licensee
acknowledged
the validity of the
NOV.
The inspector verified that the licensee
had reconfigured
one
posting
such that'ngress/egress
could be accomplished without
removing the barricade to which the sign was attached.
However, the
response
referred to the posting in the singular,
when in fact the
room could be entered
from another
direction (there are two
entrances),
without observing the posting,
as described
in IR
50-397/88-36.
The inspector
noted to the licensee that such
was the
case.
The physical configuration versus
personnel
performance
aspects
of radiological posting violations were discussed
with the
Plant Manager during the exit interview.
Mhile it was concluded
that the specific non-compliance
condition had been corrected,
corrective action to preveht recurrence will be verified after
receipt of the licensee's
analysis of Radiological
Occurrence
Reports,
as to which the licensee
committed in their response
to the
NOV (50-397/88-36-01
Open).
No other violations or deviations
were identified.
4.
Onsite follow-u of Events at 0 eratin
Power Reactors
At approximately ll:33 pm on November
30, 1988, the licensee
declared
an
Unusual
Event after determining that they were in a forced shutdown
condition, pursuant to TS 3.0.3
(See Inspection
Report 50-397/88-40).
The event
was terminated
when the licensee
achieved
a shutdown condition.
The inspector
observed
licensee
HP activities and preparation for
radiological work in conjunction with that forced outage.
Discussions
with various
members of the
HP staff and review of licensee
documents
revealed that
a lack of specific work prioritization was expected
to
result in cancellation or postponement
of some tasks requiring
coverage.
Most preparatory
work such
as
ALARA reviews
and Radiation Mork
Permits
(RMP) had been completed.
At approximately
12: 10
pm
PST on December
1, 1988, the inspector
observed
two individuals in a posted
on the 501'levation of
the Reactor Building (RB).
The high radiation area barricade
and sign
had been
removed,
and the individuals were erecting
a scaffold and
contamination control tent around
a floor drain line immediately inside
the location where the barricade
had previously existed.
The sign,
however,
was still visible when approaching
the area.
The inspector called the
Lead (HPT),
and asked if he was
aware of the
removal of the posting.
He stated that
he was not,
and that he would
send
an
HPT up to the area.
When the
HPT arrived,
he asked the workers
if they
ha'd informed an
HPT that they were removing the posting.
The
workers stated
they had.
The inspector
noted that the workers did not
appear to be wearing alarming dosimeters,
and asked the
HPT what were the
dosimetry requirements
for the area.
The
HPT asked the workers if they
were wearing alarming digital dosimeters.
When the workers responded
that they were not, the
HPT ordered
them to leave the area,
which they
dl d.
TS 6. 12,
Hi
h Radiation Areas,
states
in part:
"6. 12. 1
In lieu of the "control device" or "alarm signal" required
by paragraph
20.203(c)(2) of 10 CFR Part 20,
each high radiation
area in'hich the intensity of radiation is greater
than
100 mrems/h
but less
than
1000 mrems/h shall
be barricaded
and conspicuously
posted
as
a high radiation area...."
"...Any individual or group of individuals permitted to enter
such
areas
shall
be 'provided with or accompanied
by one or more of the
following:
a.
A radiation monitoring device which continuously indicates
the
radiation dose rate in the area.
b.
A radiation monitoring device which continuously integrates
the
radiation
dose
r ate in the area
and alarms
when
a preset
.
integrated
dose is received...."
c.
A health physics qualified individual (i.e., qualified in
radiation protection procedures)
with a radiation
dose
rat'e
monitoring device ...."
A licensee
HPT and the inspector
conducted
a survey at approximately 1:00
pm on December
1,
1988.
The results
were
as follows:
NRC Instrument
Model ORO-2
Serial
¹015843
Calibration
Due 4-26-89
Licensee
Instrument
Model PRO-2
Ser ial 8R0136
Calibration
Due 4-28-89
Maximum whole body dose rate
in the accessible
work area
130 mr/h
110 mr/h
Dose rate in the
remainder
of the work area
30-50 mr/h
30-50 mr/h
The laborers
had signed on, but stated
they had not read,
¹2-88-00032,
which clearly stated in part under "Special
Instructions":
"4)
Integrating alarming dosimeter required
when not accompanied
by
HP."
The laborers
stated
they had first entered
the area
under
¹2-88-00406,
which required constant
HP coverage,
at 7:20 a.m.
on
December
1,
1988.
The
HPT who accompanied
them stated
he had told
them they could sign on the routine
RWP (2-88-00032) for the
remainder of their work.
The workers
signed off of
RWP ¹2-88-00406
and subsequently
signed
on to
RWP ¹2-88-00032 at 7:45
am.
They
later stated that they .had not actually entered
the posted
high
radiation area until approximately ll:30 a.m.
Based
on discussion with the licensee
and review of their preliminary
root cause analysis,
the following observations
were made:
The workers did not understand
(having not read) their
RWP,
and
appeared
to, be unfamiliar with
RWP access
controls in that they
signed in on an
(HRA) work for long
periods of time without working in HRAs.
Additionally, they failed
to sign off of
RWP ¹2-88-00032 after they were ordered to leave the
radiologically controlled area (RCA).'he workers stated they had
seen
the video presentation
on access
controls,
which the licensee
had developed
as corrective action for a previous violation (See
IR
50-397/88-22,
Paragraph
2. E,
and
IR 50-397/88-36,
paragraph
3. A).
The decision of the
HPT to allow unsupervised
work on
¹2-88-00032
was consistent with the licensee's
procedures.
The area
had been well characterized
by surveys
and was properly posted.
The
licensee
stated that the
HPT had indicated to the workers that
construction of the tent should take place outside the area,
with
only erection of the tent to take place in the
HRA.
The workers
stated
they had
assumed
they had permission to remove the barricade
in order to construct the tent,
as the rope crossed
through the area
where the tent would need to be.
The licensee
had identified deficiencies
in the video noted above,
and in the wording of the
RWPs in use
by the workers,
which were
deemed
to have
been instrumental
in creating confusion for the
workers.
The licensee
had tentatively identified several
areas
in which
improvement
was
needed:
Reemphasis
of importance of
RWP signature
as witness to having read
Pre-work briefings for all
HRA work
Greater accessibility of "review copies" of RWPs
Reemphasis
of boundary relocation procedure
Additional briefings during work-scope/RWP
changes
Video upgrade
Evaluation of
RWP procedures
with respect to
INPO guidelines in INPO 88-010, Guidelines for Radiolo ical Protection of Nuclear
Power Stations.
The above matters
were discussed
with the licensee at the exit interview
on December
2,
1988.
The recur rent nature of inadequate
or ineffective
access
controls
was discussed
in particular with the Assistant Plant
10
Manager.
The entry into a high radiation area without the required
instrumentation
or accompaniment
appears
to be
a violation of TS 6. 12. 1
(50-397/88-41-03).
No other violations or deviations
were identified.
Facilit
Tours
Tours of the
RWB,
RB, and Turbine Building (TB) were conducted.
Independent
radiation surveys
were performed with an
NRC ion chamber
survey instrument
Model ¹R0-2, Serial ¹015843, calibrated
10-26-88
and
due for calibration 4-26-89.
Work in several
locations
was observed.
The inspector
accompanied
an
Equipment Operator
on
a tour of the turbine area.
Upon exit from the
posted
contaminated
area,
an
HPT who was guarding the
HRA access
was
observed
to pick up several
items from the inside of the contaminated
area,
while not wearing gloves.
Several
other instances
of personnel
using poor contamination control practices,
such
as touching the outside
of protective clothing and gloves to exposed
skin surfaces,
were
observed.
The licensee
stated at the exit interview on December
16,
1988
that part of their analysis of radiological events,
as discussed
in
paragraph
3.B (Item 50-397/88-36-01),
above,
would address
whether
such
instances
actually result in an increase
in contamination incidents.
Work on the refueling floor bridge crane,
approximately 30'bove the
606'levation of the
RB, was observed.
Two individuals were observed to
be working on the crane rai l in a contaminated
area, with another
individual assisting
below.
None were wearing hard hat head protection.
The workers
above were using hand tools passed
to them by the individual
assisting,
who then turned his attention to operation of a drill press
which was also located directly below the crane rai l.
The inspector
asked
another
individual nearby, if he was the supervisor for the
workers.
He stated that
he was,
and when the concern
was expressed
to
him,
he counseled
the workers
on proper industrial safety.
The concern
was brought to the attention of the licensee,
who stated'the
matter would
be examined.
Cleanliness
of the facility appeared
to have deteriorated
since the last
inspection
(50-397/88-36).
In particular,
the 606'levation of the
and the 507'nd 437'levations
of the
RWB, appeared
cluttered.
A later
discussion with the plant guality Control
(gC) group revealed that the
matter
had already
been
addressed
with respect to contamination control
practices,
in gC Surveillance ¹2-88-250.
Although some contaminated
areas
had
been
reduced in total area,
others
had increased
in size.
gC
surveillance
¹2-88-254,
Contaminated
Area Minimization, addressed
trending of contamination,
and
had concluded that the plant typically
varied from 20K-50K of total area
as contaminated,
compared to the
maximum lOX recommendation
by INPO 88-010.
This concern
was discussed
with the licensee.
The licensee
acknowledged
the concern
and noted that
the surveillance corrective action was still in progress.
While observing work in preparation for entry into the primary
containment,
the inspector
commented to an Instrumentation
and Controls
Technician
(ICT) that
no radiation dosimetry was visible on his
protective clothing (PCs).
The
ICT responded
by outlining his dosimetry
on his upper front torso inside his
PCs,
worn as prescribed
by, licensee
procedure
PPM 11.2.6.2,
Direct Readin
Pocket Dosimeters
and Xetex
Alarmin
Dosimeters,
Revision 6, dated 8-9-88.
The inspector
asked
the
ICT's escort
HPT whether the
RWP required
a digital alarming dosimeter.
The
HPT responded
by asking the
ICT where his alarming dosimeter
was.
The
ICT stated it was in his back pocket,
and that
he had been instructed
to place it there
by the
HPT who had escorted
him in the containment
on
his previous entry, "...to make it more accessible
to reading."
11.2.6.2 states
that alarming dosimeters
are placed next to the other
dosimetry except
when otherwise directed
by the
HPT.
The inspector
expressed
concern that the radiation sources
in the area in which the
was to work may not have
been considered
by the
HPT in directing him to
wear the alarming dosimeter directly opposite,
versus
adjacent to, his
other dosimetry.
The HP/C Manager committed to an evaluation of the
matter of dosimetry placement.
This matter will be reviewed during a
subsequent
inspection
(50-397/88-41-04).
While touring the 501'B
on November 30, 1988, it was noted that
a
flashing light, which the licensee
had placed at an opening in the
turbine generator
shield wall, was not lit.
The licensee
had placed the
light after determining that the opening might be large
enough to allow
access,
in accordance
with TS 6. 12.2, which requires
areas with dose
rates greater
than
1000 mrem/h to be locked.
The licensee
had initiated
Technical
Evaluation
Request
(TER) 088-0412-0 to further determine
accessibility
and/or
the
need for construction of an enclosure.
Licensee
records
indicated that the light had been
checked
and was operational
approximately
one hour prior to the discovery of the failure.
When the
light failure was brought to the attention of the licensee,
the light was
immediately repaired.
Overall, the licensee's
program appeared
capable of meeting it's safety
objectives,
although problems with access
controls
(see paragraph
4,
above) continue to be observed.
No violations or deviations
were identified.
Exit Interview
The inspector
met with those individuals denoted in Paragraph
1 on
December
2, 1988,
and at the conclusion of the inspection
on December
16,
1988.
The scope
and findings of the inspection
were summarized.
The
apparent violation discussed
in.paragraph
4,
and commitments
noted in
paragraphs
2 and 5, were acknowledged
by the licensee
in the meeting
on
December
2,
1988.
The licensee
was informed of NRR's verification of
sampling requirements
and subsequent
identification as
an apparent
violation with respect to item 50-397/88-26-01,
in a telephone
conversation
to the
HP/C Manager
on December
30,
1988.