ML17286A539

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Insp Rept 50-397/90-29 on 901113-16.Violation Noted.Major Areas Inspected:Radiation Protection Program Including, Radioactive Matl Transportation Activities,Internal & External Exposure Assessment & Controls
ML17286A539
Person / Time
Site: Columbia 
Issue date: 12/29/1990
From: Chaney H, Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17286A538 List:
References
50-397-90-29, NUDOCS 9101090041
Download: ML17286A539 (19)


See also: IR 05000397/1990029

Text

APPENDIX B

U.

S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report

No.

50-397/90-29

License

No.

NPF-21

Licensee:

Washington Public Power Supply System

(MPPSS)

P.

0.

Box 968

3000 George Washington

May

Richland,

MA

99352

Facility Name:

MPPSS Nuclear

Project,No.

2 (MNP-2)

Inspection at:

MNP-2 site,

Benton County, Washington

Inspection

Conducted:

November 13-16,

1990

Inspected

by:

raze./AD

aney,

en>or

a

)

son

pec)a

ss

a

e

sgne

Approved by:

Q. P.

u as,

ie

eac or

a lo ogica

Protec

'

Branch

Summary:

Ins ection

November

13-16

1990

(Re ort No. 50-397/90-29)

a

e

1gne

Areas Ins ected:

Routine

unannounced

inspection of the licensee's

radiation

pro ec ion

program including:

radioactive material transportation

activities, internal

and external

exposure

assessment

and controls,

radioactive material control, surveys

and monitoring, radiological work

preplanning

and maintenance

of occupational

exposures

ALARA,

revi'ew of RP

staff assignments,

follow-up on previous inspection findings and corrective

actions to previous Notice of Violation, and observation of work activities

involving decontamination

of the reactor

equipment pool.

Inspection

procedures

83750,

83722,

83726,

83524,

83728,

92701,

92702 were used.

Results:

One violation involving the verification of package

design

was

~l en~i ied (see

paragraphs

2.).

No deviations

were identif)ed.

The

licensee's

program appears

to be adequately

implemented to ensure

compliance

with most

NRC requirements.

The licensee's

self critical assessment

of Health

Physics

(HP)/Radiation Protection

(RP) program implementation is nearing

completion.

A December

1, 1990,

goal

has

been set for presentation

of the

findings to MNP-2 senior management.

Paragraph

2 discusses

the ability of the "Reactor Building Post

LOCA Grab

Sampler

to quantify radioactive

species

in post accident effluents.

9101090041

901224

PDR

ADOCK 05000397

8

PDR

DETAILS

Persons

Contacted

Licensee

"J. Baker, Plant Manager

"J.

Harmon,

Maintenance

Manager

  • D. Pisarcs k, Plant

HP Supervisor

"L. Pritchard,

HP Operations

Supervisor

~R. Graybeal,

HP/Chemistry

Manager

  • L. Harrold, Assistant Plant Manager

"C. Madden,

gA Engineer

"D. Larson,

Radiological

Programs

8 Instrument Calibration Manager

"R. Wardlow, Radiological

Services

Supervisor

~J. Allen, Radwaste

Supervisor

  • L. Bradford,

HP Planning Supervisor

D. Werlau, HP/Chemistry Technical Training Supervisor

~H. McGilton, Operational

Assurance

Programs

Manager

"P. Macbeth,

General

Engineer

~L. Morrison, Plant Chemistry Supervisor

  • L. Sharpe,

Nuclear

Engineer

Others

"C. Sorensen,

Senior

NRC Resident Inspector

"D. Proulx,

NRC Project Inspector

~W. Milbrot, Nuclear Engineer,

Bonneville Power Authority

T. Essig,

NRC Office of Nuclear Reactor Regulation, Division of

Radiation Protection

and

Emergency

Preparedness,

Radiation

Protection

Branch

F. Witt,

NRC Office of Nuclear Reactor

Regulation, Division of

Engineering Technology, Materials

and Chemical

Engineering

Branch

  • Denotes

those attending the exit meeting

on November 16,

1990.

Additional licensee

personnel

were contacted

during the course of the

inspection.

Follow-u

on Previous

Ins ection Findin s (92701,

92702)

Notice of Violation 397/90-22-02

(Closed):

This item involved the

licensee

s

as

ure

o per

orm

mme y an

accurate

assessments

of

radioactive material

uptakes

by workers.

The licensee's

response

to the

Notice of Violation dated

September

21, 1990,

and corrective action

commitments (revising procedures

and correcting exposure

data for the

affected individualsj were reviewed

and implementation verified.

The

licensee's

corrective actions (revision of Radiological

Program

Instructions

(RPIs) 5.6, 5.7, 5.8,

and Plant Procedure

11.2.4. 1) were

implemented

on or before October 31,

1990 and appear to be adequate

to

prevent

a recurrence

of the violation and ensure future compliance with

NRC regulations.

r>

<il

i

2

Unresolved

Item 397-50/90-22-03

(Closed):

This item involved the

icensee

s ina >> y

o provi

e

e

inspector with appropriate

documentation

or certification verifying that the design criteria of 49

CFR Part 178.350

had been satisfied for a Specification

7A type

radioactive material shipping package

used by the licensee

on March 21,

1990.

This item is closed.

The licensee

could not produce the certification required

by 49

CFR Part

173.415(a).

This matter was previously documented

in Inspection

Report

Nos.

50-397/90-22.

Failure to demonstrate

compliance with the criteria

of 49

CFR 173.415 represents

an apparent violation of 10

CFR 71.5

(50-397/90-29-01).

Unresolved

Item 50-397/85-20-04

(U date

This item has

been previously

iscusse

in

nspec

ion

epor

s

os.

50-397/85-20,

87-05, 87-29,

88-33, 89-20, 89-29, 89-32,

and 90-07,

and involved the licensee's

NUREG-0737,

item II. F ~ 1, Attachment

2 required ability to sam le and

uantif

the effluent release

rate for gaseous/particulate

ra ioiodine

un er reactor accident conditions.

During the licensee's

evaluations for

implementation of this requirement the licensee

determined that the

plants as-built post-accident

radioiodine effluent

~sam lin

system

(REA-SR-27

8 27A) would not be accessible

for use during reactor

accidents

in accordance

with the access criteria stipulated in Item

II.B.2 of NUREG-0737 (a design review of plant shielding for spaces

which

personnel

may need

access

during postaccident

operations).

The licensee

subsequently

installed

a pump driven, shielded,

isokinetic sampling

system

(REA-SR-48) to satisfy postaccident

iodine sampling requirements.

This postaccident

sampling system is described

in the licensee's

Final

Safety Analysis Report

(FSAR), Section 11.5.2.2. 1.5,

Amendment

No. 36,

and Appendix

BE 2,

Amendment

No. 35.'he

NRC questioned

the ability of

the system to representatively

sample effluent releases

under accident

conditions involving steam with attendant

high and low temperatures

along

the sample line.

These conditions would likely cause

severe

iodine

plate-out in the. sample lines

due to the reactivity of iodine and

generation of excessive

water (condensate)

in the sample line under these

circumstances.

In 1988 the licensee initiated independent offsite

laboratory testing of the sample

system via a representative

mockup.

The

independent testing laboratory submitted to the licensee their results of

the testing

on October ll, 1990,

and the results

indicated that the

sampling system

as designed

and operating at .isokinetic sample flows is

approximately

.002 percent efficient when operated

under simulated

reactor accident conditions.

Therefore,

a correction factor of

approximately

500 must be applied to sample results.

This large of a

correction factor is. considered

unacceptable

by the licensee,

the testing

laboratory',

and the

NRC.

The licensee

has requested

further testing of

the system

under greater than isokinetic flows to see if better

performance

can

be obtained.

MNP-2 Technical Specification

(TS) 3. 3. 7. 5, require, in part, that the

Reactor Building Post

LOCA Grab Sampler

be operable in operational

modes

1, 2,

and 3, or if not (a) Initiate the preplanned alternate

method of

monitoring the appropriate

parameter(s),

and (b) In lieu of any other

report required

by Specification 6.9. 1, prepare

and submit a Special

Report to the Commission pursuant to Specification 6.9.2 within 14 days

following the event outlining the action taken,

the cause of the

C

I

operational

problems

and the plans

and schedule for restoring the 'system

to OPERABLE status.

Currently the licensee is evaluating industry available on-line analyzers

and possible alternate

methodologies for quantifying iodine release

rates

in effluents during a reactor accident if the current sampling system is

declared

inoperable.

The licensee currently can not accurately quantify

the release

rate of radioiodine

except for limited reactor

accident

scenarios

during which the

RAE-5R-27

8

27A sample

racks would be

accessible,

and at larger accidents

must revert to default/credible

reactor accident release

scenarios

contained in Section

15 of the

FSAR

and/or field monitoring team

sample results.

However, these

methodologies

do not meet the intent of NUREG 0737,

Item II.F.1-2, to

establish

the ability to quantitatively determine

the rate at which

radioiodines

are being released

from the plant in gaseous

effluents

under

accident conditions.

Or anization

and

Mana ement Controls

(83722)

The

NRC inspector

reviewed the licensee's

offsite WPPSS Support

Services-Radiological

Programs

and Instrument Calibration l3epartment

(Corporate

HP group) staffing and management

controls.

The Radiological

Programs office is located in the Plant Support/Emergency

Operations

Facility (PSF) which is located approximately 0.5 miles from WNP-2.

This

group was initially developed

and organized to support all five WPPSS

nuclear facilities.

The Radiological

Programs

and Instrument Calibration Department

(RP8IC)

is a functional part of the

WPPSS corporate staff and is comprised of

'pproximately

33 personnel.

Approximately 16 skilled craftspersons

occupy positions in the laundry (3) and the measurement

and test

equipment/material

calibration facility (13).

The Radiological

Programs

group is comprised, of approximately

9 professional

Health Physicist

and

9

Health Physics

Technicians

(HPTs).

This staff provides professional

level

technical

support to the plant

HP group involving external

personnel

dosimetry supply, processing

and official dosimetry records

administration/maintenance,

internal dosimetry, including whole body

counting and respiratory protection equipment

(RPE)

use qualification,

and

RPE maintenance

and testing,

RP portable instrument calibration,

contaminated protective clothing laundry, plant design

change

ALARA

,

reviews,

environmental

dosimetry supply and processing,

Offsite Dose

Calculation Manual administration, offsite dose calculations,

and

semiannual

effluent release

report preparation.

The offsite radiation protection, program is implemented

by an extensive

and comprehensive

set of

RP procedures.

- These procedures

establish

assignment

of responsibilities

and division of authorities within the

Radiological

Programs'epartment.

Detailed implementing procedures

are

available for procedure

development

and control, internal

and external

dosimetry programs, offsite dose

assessment,

radiochemistry activities to

support plant operations,

radiation protect>on instruments calibration

and operation,

posting of radiological areas,

use of protective clothing,

transfer of radioactive materials

between facilities, radiation

and

contamination

surveys,

airborne radioactivity measurements,

RWP

preparation,

decontamination

of work areas

and personnel,

etc.

The

offsite group does not have

any operational

responsibilities

in-plant

f

il

other than providing technical

advise/support

to the in plant

HP group.

Members of the Radiological

Programs

Department provide technical

assistance

to the corporate

gA group during audits of plant

RP programs.

Radiological

Program implementing procedures

are reviewed

and approved at

the corporate level in accordance

with the conditions contained in TS 6.8.2.

I

/

The corporate

HP organization

appears

to be adequately staffed

and

functionally competent to support the WNP-2

RP mission

and carry out

safely the offsite radiological work activities involving the

contaminated 'laundry and instrument calibration facility.

The licensee's

program appears

adequate

in this area.

4.

Occu ational Radiation

Ex osure

(83750)

The licensee's

RP program was examined to determined

compliance with the

requirements

of Technical Specifications (TS) 6.2, 6.4,

6. 10, 6.11,

and

6.12

10

CFR Parts

19.11,

19.12,

19.13,

20.101,

20.103,

20.201,

20.202,

20.253,

20.401,

20.403,

20.405,

20.408,

and 20.409;

and agreement with

the commitments

contained in Sections

12.5, 13.1, 13.2, 13.4,

and 13.5 of

the

WNP-2 FSAR; and agreement with the guidance

contained in NRC

Regulatory Guides 1.8, 1.33, 1.97, 8.7, 8.8, 8.10, 8.14, 8.15,

and 8.27,

Industry Standards

ANSI N18.1-1971,

N13.11-1983,

and

NRC Inspection

and

Enforcement Information Notice (IEIN) 81-26.

a.

Audits and

A

raisals

The

NRC inspector

examined the licensee's

onsite (plant) Operational

Assurance

Division (quality assurance

surveillance

group) staffing,

staff qualification, schedule of surveillance,

and selected

surveillance reports.

The inspector

reviewed the following

survei llances:

2-90-98,

Spent

Resin Processing,

July 1990

2-90-100,

Sodium 24 Injection, August 1990

b.

The

NRC inspector

noted that

a surveillance, critical of the

Radiation Protection

Program implementation,

e. g.,

HP radiological

work control practices,

procedures,

supervisor oversight, etc., of

spent fuel inspections that took place during late July through

early August 1990,

had not been issued

as of this inspection.

However,

gA and

HP have

been reviewing the issues

associated

with

the surveillance

so that final documentation of the surveillance

findings is factual

and accurately

assesses

the safety significance

of each findings.

~Chan

es

There were

no changes

in facility design or operations,

other than

the

HP group reorganization,

that affected the

RP program.

The plant

HP staff assignments

have under

gone

a reorganization

as

of September

3; 1990.'wo

new supervisory positions

(Radwaste

and

HP Planning-ALARA) were created.

Nearly all

HP supervisory

positions

have

had

a change

in staffing and responsibilities.

Senior

HPTs were used to fill additionally created

ALARA technician

~

~

~

ositions in the

HP Planning group

and foreman (lead

HPT) positions.

his staffing has

reduced the number of senior

HPTs available for

day to day operational

support.

The licensee still depends

on the

routine use of overtime to satisfy operational

support requirements.

The licensee currently utilizes five contracted

senior

HPTs to-

support the

HP staff so continuing training needs

can

be met.

The

HP group

has

been granted authority to hire nine senior

HPTs (three

as replacements

for HPTs that were lost through in-house

transfers/promotions

and an additional six senior

HPTs in fiscal

year 1991).

This will bring the

HP group senior

HPT manning to

approximately

34 persons.

Even though the reorganization

has

been

in effect approximately three

months several

functional positions

had only been filled within the last few weeks preceding this

inspection.

The radiological/HP work planning group

(ALARA) is not

fully functional at this time and the licensee's

desire to

consolidate

radiological work permit

(RWP) development

and issuance

within this group has not fully materialized.

The consolidation of

RWP development

and issuance

should provide needed continuity

between work activities and standardization

of

RP controls.

The

current HP/Chemistry

Group organization

does not agree with the

descriptions

and organization chart (Figure 13. 1-11) in Section

13. 1

of the

FSAR.

The plant

HP group appears

to be marginally staffed

due to the

continue

use of contract personnel

and the routine

use of overtime

to accomplish

day to day operational

support of plant activities.

The reorqanization of the

HP group

has taken longer than expected

and

may impact on the efficient preparation for the R-6 refueling

outage,

especially in the area of ALARA reviews

and special

RWP

development.

Trainin

and

uglification of New Personnel

The

NRC inspector

examined the training and qualification program

for the offsite Radiological

Programs

Department staff.

This

training program is setforth in Radiological

Programs Instruction

(RPI) Manual

No. 0.8 and Technical Training Manual 5.1.2,

"HP and

Chemistry Training Program Description."

The licensee's

commitment

to training is contained

the in the

WPPSS Health Physics

Program

Description

(HPD)

contained in the Corporate Policy and Procedures

Manual

Volume 3, Management

Statement.

qualification and experience

requirements

for plant and offsite

RP staffs is setforth in HPD

3. 1.21.

Radiological

Programs staff personnel

must qualify, based

on performance,

in each of their assigned

functional areas, i.e.,

external

dosimetry, internal dosimetry, respiratory protection

equipment maintenance,

dosimetry records,

etc.

Discussions with

staff members

indicated that all members of the Radiological

Programs

Department

possessed

adequate

technical

knowledge in their

functional areas of assignment.

Discussions

with the laundry

facility staff (HP and laborers)

indicated that craft knowledge

and

RP/ALARA concepts

are well understood.

The training and qualification program for the plant

HP group is

currently undergoing task based analysis for the purpose of

4

0

0

upgrading the program and improving HPT performance.

This area will

be reviewed in subsequent

inspections.

d.

External

Radiation Control

and Oosimetr

(83750/83524)

The licensee's

external radiation dosimetry

and exposure control

was

reviewed for agreement

with the commitments

contained in Section

12

of the

FSAR

and compliance with the requirements

of 10

CFR Part

19.12,

19.15,

and 20.202(c).

The licensee currently has in place

an older automated

personnel

dosimetry processing

system consisting of a teflon card

(thermoluminscent

dosimeter-TLD) impregnated with thermoluminescing

materials.

The licensee

had elected to have this TLD accredited

by

NVLAP (National Voluntary Laboratory Accreditation Program-

conducted

by the National. Institute of Standards

and Technology) for

radiation exposure

measurements

in five of the eight categories

referenced

in ANSI N13.11-1983.

The three categories

that the

licensee's

system is not accredited

are:

Category - I, Accident,

low-energy photons.

Category - III, Low-energy photons.,

Category - VI, Photon Mixtures (low and high)

The licensee's

TLO system

was last accredited

in July 1990.

The

licensee

elected to not have their personnel

dosimetry system

accredited

in the above

noted categories

since they believed that

low-energy photon measurement

was unnecessary

at WNP-2.

Even though

there is a degraded

photon component in plant areas

due to inherent

system

shielding/gamma

photon attenuation/bremsstrahlung

the

licensee

considered that it was effectively masked

by the larger

high-energy

component

and would show up, if significant, during the

calculation of potential

beta exposure

in the systems

algorithms.

The inspector

agreed that the

need for low-energy photon

accreditation

was not warranted for WNP-2.

The vendor of this type

TLD has successfully

had it accredited

in all eight categories.

The

NRC inspector toured the dosimetry processing facilities, examined

equipment,

interviewed personnel,

and reviewed selected

personnel

exposure

records.

The licensee's

personnel

exposure

records

system

applicable equivalents of NRC Forms 4 and 5, extension

authorizations,

whole body countinq data, respiratory protection

physical qualifications

and mask fit testing results,

and copies of

termination letters were reviewed.

The files are maintained in fire

rated cabinets.

These

records

showed

a high level of maintenance.

The licensee

had recently purchased, 'installed,

and is

preoperational

testing

a state-of-the-art

computer driven TLD system

that employs hot gas heating of a multiple TL chip TLD.

This TLD

system will be placed in service following preoperational

testing

and full spectrum accreditation.

The

NRC inspector toured in-plant areas

and observed

the wearing and

use of personnel

dosimetry. 'he licensee

tracks personnel

exposures

between routine

TLD processing

(monthly and quarterly)

by the use of

1

>1

'

0,

self reading pocket dosimeters

(SRDs) that are issued

by the plant

HP group.

Personnel

are required to maintain their own accounting

of SRD exposure

each work shift.

The computerized

dose tracking

system

(RER-Radiation

Exposure Reporting) is normally update

each

night based

on

SRD tallies.

The licensee

maintains administrative

control over personnel

exposures

via personnel

exposure

guides

found

in Plant Procedures

Manual

Volume ll, HP Procedure

11.2.5.1.

The

licensee is committed to maintaining personnel

exposures

at less

than five Rem per calendar year.

This commitment is achieved

by

limiting personnel

exposures

to less

than .300

Rem per day and

1

Rem

per quarter.

For a person to exceed

these administrative

exposure

guides authorization

(HP Procedure

11.2.5. 1) must be obtained from

the HP/Chemistry

Manager

for quarterly extensions

and from the Plant

manager for yearly extensions.

Control of Radioactive Materials

and Contamination

Surve

s

and

one or)n

The

NRC inspector

examined offsite and in-plant controls over

radioactive material

(RAM) and contamination,

and conduct of

radiological

surveys for identification and evaluation of

radiological conditions.

The licensee

conducts radiological work

activities at the

PSF.

Activities include

RP instrument

calibration,

laundering of contaminated protective clothing,

and

limited radiochemical

analyses.

These activities involve, handling

seal

sources,

the generation of'adioactive wastes,

and working with

loose surface contamination,

including hot particles.

The

WPPSS Radiological

Programs

Department provides for its

own

radiological controls separate

from the WNP-2 plant

HP group.

The

NRC inspector

observed

contamination controls in place for the

contaminated

laundry operations,

reviewed transfer

and control of

contaminated

clothing to and from the WNP-2, segregation

of clothing

based

on radiation levels or hot particle threat,

the use of hand

held personnel

friskers

and automated"whole

body friskers.

The work

practices

and survey program for work activities at the

PST is

adequate

to control

RAM and contamination.

The content of RWPs

appeared

to be adequate

for the level of radiological

hazards

present at the

PSF.

The

NRC inspector

observed

ongoing preparation for decontamination

of the reactor building 606 foot elevation dryer/reactor

equipment

pit.

All workers appeared

to be knowledgeable of the

RP controls

for the work.

Work operations

did not start while the

NRC inspector

was present

due to electrical

grounding certification problems with

the equipment.

This was brought to the attention of the lead

HPT by

the. plant Operational

Assurance

engineer.

Semi-portable

exhaust

ventilation systems

equipped with HEPA filtration units were

extensively

used to control airborne radioactivity in the immediate

area of the dryer pit during high pressure

water wash

downs.

Respiratory protection is required during initial operations until

airborne radioactivity is evaluated.

Selected

workers were observed

inspecting,

donning

and testing full face

HEPA filtered air

purifying respirators,

The

NRC inspector

reviewed the qualification

records of three workers that donned

RPE for the work operations.

'I'j

0

h

8

The

NRC inspector brought to the attention of the licensee

an

industrial safety concern involving the high pressure

spray

equipment.

The spray unit,

an electrically driven positive

displacement

pump was rated to deliver liquid spray

under pressure

of approximately 10,000

pounds per square

inch.

Even though

approximately

75 feet or more of delivery hose

and attachments

comprised the downstream portion of the system,

including several

mechanical joints, the

NRC inspector did not observe

any

verification of testing of the hoses/fittings, or was the system

equipped with whip restraints

to protect workers if a hose or joints

'ailed.

During the setup of the high pressure

sprayer

wand it was

noted that several joints would be exposed to bending motions during

pit washdown activities.

Plant management

agreed to evaluate

the

inspectors'oncerns.

The

NRC inspector

observed portable

RP survey instrument calibration

,

facilities, response

check methods,

and technician preoperation

quality control check of instruments.

The licensee's

calibration

and instrument response

check program appear to satisfy industry

standards

and 'guidance.

Survey instruments

are proper]y segregated

or clearly tagged to indicate

an instrument's

functional status.

Maintainin

Occu ational

Ex osures

ALARA (83750

and 83728)

The

NRC inspector

examined the preparations

and planning associated

with the decontamination

of the reactor vessel

equipment pit/dryer

pit.

This operation involved measured

dose rates of 500-1,000

millirem per hour above the residual

water surface in the bottom of

the pit.

Mater depth

was about six inches.

The

RWP 2-90-00468

was

developed

by a senior

HPT and the

HP Planning Supervisor.

The

NRC

inspector

observed worksite preparations

for the high pressure

wash

down of the pit,

Documentation

was available at the work site

denoting that prework briefings (tailgate meeting)

had been held

prior to start of equipment setup,

The lead

HPT required everyone

that would enter the

606 elevation to be familiar and briefed on

RMP

requirements.

An Operational

Assurance

engineer

was in the area for

surveillance

of the ongoing work.

During discussions

with the lead

HPT about the content of the

RMP it became evident that not all of

the activities associated

with the work were detailed in the

RMP and

were maintained

as written notes in the

RMP package.

The

NRC

.

inspector

determined that all workers

had been briefed on the

RMP

and supplementary

information in the notes prior to start of work.

The

NRC inspector discussed

with HP supervision

and plant management

his concern that

a significant portion of the controls to be

implemented

by the

HP group were not written into the

RMP.

Licensee

representatives

indicated that normally

RMPs do not contain

information that is specific only to

HP operations.

It was noted to

the licensee that if workers did not know when

HPTs were to perform a

specific act/requirement

(which was

based

on the .worker's

activities) and the

HPT was distracted

then there would be

a good

chance that the act would be missed.

The licensee

provided the

NRC inspector with an

ALARA report of the

R-5 refueling outage that appeared

to be distributed only to WNP-2

managers

and then to no one manager in particular.

The report is

from the

HP staff.

This report

ss compilation of man-rem

l

performance for 220

RWPs,

concluding prejob man-rem estimates

and

hours of work associated

with the

gob/RWP.

Also included are

statistics

on skin and clothing contamination incidents

and other

radiological occurrences.

The report includes

a section

on

areas/work operations that are perceived

by the report originators

to need

more attention during future outages.

The report also

highlighted one area

(CRD rebuild room modifications) that showed

a

significant man-rem savings

over previous outages.

The licensee's

program appears

adequate

in this area.

5.

~E*it M ti

(30703)

The inspector

met with licensee

representatives

identified in

paragraph

1 of the report on November 16,

1990.

The inspector

discussed

the scope

and findings of the inspection.

The licensee

acknowledged

the inspectors

findings regarding the appar ent

violation and initiated action to evaluate

apparent corrective

actions that

may be necessary.

The inspector

informed the licensee

that the Regiona] office would be examining the history and current

test data involving the operability of the Post Accident

LOCA Iodine

Monitor (an unresolved

item, referenced

in paragraph

2 of this

report)

and determining what further actions to resolve the issue

are available to the

NRC.

The licensee

acknowledged

the inspectors

statements

with their concern that further testing of the sampler is

ongoing to determine if better

sampling efficiencies

can

be

obtained.

0,