ML17300B144
| ML17300B144 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/03/1987 |
| From: | Cicotte G, Russell J, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17300B142 | List: |
| References | |
| 50-528-87-38, 50-529-87-37, 50-530-87-39, NUDOCS 8712220030 | |
| Download: ML17300B144 (17) | |
See also: IR 05000528/1987038
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/87-38,
50-529/87-37,
50-530/87-39
Docket Nos; 50-528,
50-529,
50-530
Licensee:
Arizona Public Service
Company
P.
0.
Box 52034
Phoenix,
85072-2034
Facility Name:
Palo Verde Nuclear Generating Station
Inspection at: Mintersburg, Arizona
Inspection
Conducted:
October 26-30,
1987
J. +s'se11,
Health Physicist
G.
Ci ot e, Radiation
Sp
ialist
Inspectors:
Approved by:
P.
Yu
s, Chief, Facilities Radiological
Pro
ion Section
/z- f-P7
Date Signed
I
Q
IM
Da
e Signed
Da
e Signed
~Summer
Ins ection
on October 26-30
1987
(Re ort Nos.
50-528/87-38
50-529/87-37
and
50-530/87-39
inspectors
of occupational
exposure
during extended
outages (in Unit 1),
Allegation No.
RV-87-A-0066, followup of nonroutine events,
and
a tour of the
facility.
Inspection
Procedures
30703,
92701 and 83729 were addressed.
Results:
In the four areas
inspected,
one apparent violation was identified
involving Technical Specification 6.2.2.2.b
(see Section 2.B.).
87i 2220030 87i204
ADQCN 05000528
6
4
DETAILS
1.
Persons
Cont'acted
A.
Licensee
J. Allen, Unit 1 Plant Manager
"W. Ide, Unit 2 Plant Manager (Corporate.gA/gC
Manager)
"0. Zeringue,
Unit 3 Plant Manager
(Technical
Support Manager)
- L. Brown, Radiation Protection
and Chemistry Manager.
P. Brandjes,
Outage
Manager
"T. Shriver,
Compliance
Manager
"G. Perkins,
Central
Radiation Protection
Manager (Radiological
Services
Manager)
- L. Souza, guality Audits and Monitoring Manager
- J. Mann, Corporate
Health Physics/Chemistry
Supervisor
K. Oberdorf, Unit 1 Radiation Protection
Manager
"T. Bradish,
Compliance Supervisor
K. Contois,
Dosimetry Supervisor
R.
Selman,
ALARA Supervisor
"D. Bland, Compliance
Engineer
B.
NRC
"J. Ball, Acting Senior Resident
Inspector
"Denotes present at exit interview.
( )Denotes
stated title if different from present
licensee
proposal.
The inspectors
also met with and held discussions
with other members of
the licensee
and contractor staff.
2.
Occu ational
Ex osure Durin
Extended
Outa
es
A.
~Plannin
(1)
Pre-job reviews of outage
work were reviewed to determine the
level of review and adequacy of requirements
to ensure that
exposures
were kept As
Low As Reasonably
Achievable
(ALARA).
The licensee
performed estimations
of dose
as the work was
projected to progress.
Reviews
appeared
to be conducted
on a
case-by-case
basis,
rather than formatted for conformance with
each other.
No specific exposure
goal
had been set
by job
function.
The only exposure
goal set was
275 person-rem for
the outage.
The licensee staff stated that it was their
intention to set goals for following outages
based
on the
results of the current outage.
At the time of the inspection,
the licensee staff had calculated that cumulative exposure for
the outage
was approximately
70 person-rem.
This would, for
the point in the outage,
be just under
the cumulative
amount
expected,
consistent with a 275 person-rem
outage total.
No violations or deviations
were identified.
(2)
~Chan
ee
The licensee
was in the final stages
of an organizational
change.
The thrust of the change
was to place individual unit
Radiation Protection
Managers
(RPMs) under unit Plant Managers.
The
RPMs would also report to a Radiation Protection
and
Chemistry Manager.
Support functions,
such
as Dosimetry and
Respiratory Protection,
were to be under
a central
RPM.
Potential
impact of these
changes
is discussed
in paragraphs
2.B and 2.C,
below.
B.
Staffin
and Administration
Contractor
resumes,
work hour time records,
and training records
were reviewed.
Contract Radiation Protection
personnel
used
by the
licensee
to fill Technical Specification (TS) 6.3, "Unit Staff
Organization," positions
met or exceeded
the minimum qualifications
of ANSI 3. 1-1978,
as required in TS 6.3.
Work hour overtime
limitations are specified in TS 6.2.2.2 which states,
in part:
"6.2.2.2
The unit staff working hours shall
be as follows:
"a.
Administrative procedures
shall
be developed
and
implemented to limit the working hours of unit staff
who perform safety-related
functions; e.g.,
Senior
Reactor
Operators,
Reactor Operators,
radiation
protection technicians,
auxiliary operators,
and
key
maintenance
personnel..."
"...during extended
periods of shutdown for refueling, major
maintenance,
or major plant modifications,
on a temporary
basis,
the following guidelines shall
be followed..."
"...An individual should not be permitted to work more than
16
hours in any 24-hour period,
nor more than
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any
48-hour period,
nor more than
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, all
excluding shift turnover time..."
"Any deviation.from the above guidelines shall
be authorized
by
the
PVNGS Plant Manager or his designee
who is at supervisory
level or above,
or higher levels of management,
in accordance
with established
procedures
and with documentation
of the basis
for granting the deviation...."
A review of time records for contractor personnel
disclosed that two
individuals
had worked seven consecutive
days of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
each.
The
licensee
stated that the individuals,
who worked the
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days
respectively
on October
10 to 16,
1987, inclusive,
and October
13 to
19, 1987, inclusive,
had not received prior authorization,.since
they had days off work in the calendar
weeks preceding
and following
the period of work.
When presented
with the findings, the licensee
stated that procedure
10 AC-OZZ07, "Overtime Limitations," was
restricted to Arizona Nuclear
Power Project personnel,
and not to
contractors.
The technicians
noted above,
during the subject
periods,
were both assigned
to coverage of outage work, such
as
radiological
surveys
and monitoring of work activities.
Failure to limit the work hours of the technicians
represents
an
apparent violation of TS 6.2.2.2.a
(87-38-01).
C.
Trainin
and
ualifications of New Personnel
(1)
Training records
and
resumes
of several
contractor personnel
newly hired for the outage
were reviewed.
Observations
by the
inspectors
established
that personnel
assigned
to safety-
related positions
had the qualifications required
by ANSI
3. 1-1978.
Incoming radiation protection personnel
receive the
same training as other
new hires.
The licensee
used
a pre-test
to assess
the extent of training required.
Training for the
purpose of meeting
10 CFR 19. 12, "Instructions to Workers,"
was
either
a full training session
or an abbreviated
session,
governed
by the pre-test results.
The licensee
had assigned
escorts
and
a German/English interpreter to several
foreign
national contract technical
consultants
from the 'Reactor
Coolant
Pump
(RCP) manufacturer.
(2)
The licensee
had recently instituted procedure
"Hot
Particle Control," with an effective date of October 13,
1987.
Radiation Protection Technicians with whom this procedure
was
discussed
stated that training on the procedure
had consisted
of reading the procedure
once
and signing
a training doc'ument
indicating they had done
so.
Four technicians
responsible for
Hot Particle Control Areas
(HPCA) stated that they had
periodically reviewed the procedure
on their own, in addition
to the initial review.
The inspectors
discussed
hot particle control
and
with the following personnel:
Radiation Protection
and Chemistry Manager
(RPCM)
Central
Radiation Protection
Manager
(CRPM)
Unit 1 Radiation Protection
Manager
(RPM)
Radiation Protection
Outage Coordinator
(RPOC)
Three (Lead) Radiation Protection Technicians
(LRPT)
One
Seven Contractor
RPTs,
ANSI 3.1-1978 qualified, directly
assigned
to
HPCA work
Four Contractor
RPTs,
ANSI 3. 1-1978 qualified, not so
assigned
Three Contractor
RPTs,
not ANSI 3. 1-1978 Seniors
(Junior
RPTs)
During these
discussions,
the inspectors
made the following
observations:
Only three of the fifteen Senior
RPTs were able to
accurately
describe
the modified R02/R02A and discuss
survey techniques
appropriate- to the instrument.
One Senior
RPT was observed
using the modified R02/R02A
for surveys of personnel
in an
HPCA.
The
RPT used the
instrument at an angle that could have precluded incident
betas
from reaching the open window, and did not survey
all high contact areas
as called for in 75RP-9ZZ83.
One Senior
RPT assigned
to
HPCA work stated
he did not
trust and would not use the modified R02/R02A for
personnel
surveys.
One Senior
RPT in the Reactor Building (RB) described
the
modified R02/R02A as having
a "round hole" for a beta
window.
The instrument
had
a slotted window and the
had
an instrument in his possession,
i.e.,
on his desk.
Two Senior
RPTs in the
RB stated that 20,000
dpm per probe
.
area
on the modified R02/R02A would indicate the presence
of a hot particle.
The instrument
has
a scale calibrated
in mr/hr,
and
no external
probe.
The
had
an
instrument
on their desk.
Ten of the Senior
RPTs were unfamiliar with the action
levels associated
with stop-work orders
based
on radiation
exposure
estimates
specified in 75RP-9ZZ83.
Most of the
errors
were conservative.
The inspectors
concluded that
hot particles, if discovered
during surveys of personnel,
would be unlikely to result in unconservative
actions.
One technician stated that
he thought dose estimations for
hot particle exposures
were averaged
over the whole-body
skin area.
An assembly
from RCP-1B was
removed
from a hot particle
control area without being surveyed to preclude
the
presence
of hot particles
and placed in a tent not marked
as
an
HPCA.
The inspectors
called this to the licensee's
attention approximately eight hours after the
move
I
occurred.
The tent area
was posted
HPCA approximately
five hours later.
The Unit 1
RPM stated that
he had been
informed that
shaft/impeller assemblies
being decontaminated
were
"coming up particle-free."
RPTs assigned
to
RCP work in
the decontamination
area stated that they did not perform
surveys for particles
on material inside posted
HPCAs due
to excessive
dose rates.
The
RPOC stated that she
had not received
any formal
training on 75RP-9ZZ83,
but was sure that the contractor
had received
such training during initial General
Employee Training (GET).
The Unit 1
RPM stated that, although
he was not familiar
with operation of the modified R02/R02A,
he was sure the
RPTs were.
The
CRPM expressed
familiarity with 75RP-9ZZ83,
but was
unable to recall
dose estimation/stop
work action levels
called for therein.
The
RPCM stated at the exit interview that
he
had been
under the impression that the Nuclear Training Department
had presented
a formal lecture
on hot particle control for
new hire RPTs.
The inspector verified that
a formal
lecture
on hot particle control
had not been presented.
The inspectors
discussed
these
observations
with the licensee
during a meeting held on October 18, 1987,
and at the exit
interview.
The licensee
acknowledged
the observations
and
stated that
a video presentation
on hot particle control
had
been prepared for review prior to viewing by RPTs
on shift.
The licensee
showed the inspectors
two recent
memoranda
addressed
to all personnel,
emphasizing
proper radiological
controls in areas
where hot particles
were suspected.
No violations or deviations
were identified.
D.
External
Ex osure Control
~oosimetr
Personnel
dosimetry
was observed
in use
and representative
licensee
records
were reviewed.
The licensee
uses
pocket dosimeter
readings
for daily accumulated
exposure.
TLD readings
are
compared to pocket
dosimeter
readings
when the
TLD is read
and the record is updated to
reflect the
TLD reading.
Anomalous
comparisons
and lost/offscale
dosimeter
readings
are investigated.
The licensee's
dosimetry program is National Voluntary Laboratory
Accreditation Program (NVLAP)-certified.
guality control
and
abnormal
TLD readings
were reviewed.
Anomalous readings
are
0
investigated
by the licensee
through visual examination of TL
phosphors
and analysis
of causes
for abnormal
readings.
Dose
estimations
were performed for those
cases
in which defective
were determined to be the cause.
Representative
examinations
of
abnormal
readings
were reviewed
and observed to be adequate.
According to licensee
records,
no personnel
received
whole body
exposures
in excess
of the limits of 10 CFR 20.101(a) for the
current
and second quarters of 1987.
All personnel
records
reviewed,
except for those of the foreign nationals previously
mentioned,
contained
form NRC-4 equivalents
completed in accordance
with 10 CFR 20. 102, prior to approaching
the limits of 10 CFR 20.101(a).
The licensee distributes
an occupational
dose status
report twice
daily on weekdays
during the outage,
organized
by department
and by
record
number.
Department
managers
can then review their
department,
and individuals can locate their most recent
update
by a
unique
number assigned
to them, or alphabetically
by their
departmental
report.
No violations or deviations
were identified.
Internal
Ex osure Control
Licensee
records of MPC-hour calculations,
bioassay,
whole body
counting
and internal
exposure
estimations
were reviewed.
No
personnel
had exceeded
40 MPC-hrs for the outage.
Adequate air
sampling appeared
to be in use for airborne radioactivity areas.
Bioassay calculations
and air sampling results
appeared
to be
consistent.
Records for two personnel,
determined to have ingested
small quantities of Sb-124,
were examined.
No violations or deviations
were identified.
Control of Radioactive Mat'erial
and Contamination
Surve
s
and
~Monitorin
Use of field radiation instruments,
portal monitors, friskers,
and
monitoring practices
were observed
by the inspectors.
One
RM-20
frisker
No.
993 being
used
by personnel
for frisking in a clean area
was located just inside
an area posted
"contaminated
area."
One
RM-20, Serial
No. 725,
was available in the
same clean area,
but
with battery power too low to allow operation.
The instrument
was
not connected to a power line.
One
RM-20, Serial
No. 649, dated
calibration due October 26, 1987,
was observed to be in use at the
exit to the radiation control area
on October
27, 1987.
The
instrument
was immediately removed from use by an
RPT accompanying
the inspectors.
On October 29, 1987, the
same
RM-20, Serial
No.
649, dated calibration due October 26,
1987,
was observed
in use for
personnel
frisking in the Unit 1 Turbine Building.
The instrument
was immediately
removed
from use
by an
RPT accompanying
the
inspectors.
e
Waste
volume reduction efforts appeared
adequate.
Personnel
bringing material into the
RCA were observed to be removing
packaging materials prior to entry,
and the licensee
used
segregation
of waste to prevent mixing of uncontaminated
and
contaminated
waste.
The licensee utilized a group of contractor personnel
to perform
area decontamination,
in order to reduce the total area within
contaminated
areas,
and to reduce
contamination levels to minimize
the spread of contamination.
The process
appeared
to be effective
in that contaminated
areas
in the auxiliary and radwaste buildings
were smaller than during the last inspection.
Housekeeping
was
generally
improved.
No violations or deviations
were identified.
3.
Alle ation RV-87-A-0066
This refers to an anonymous allegation received
by telephone
concerning
radiation protection personnel.
The allegations
were
as =follows:
A.
Radiation Protection
(RP)
ersonnel
erformed
smear
surve
s without
loves or other anti-contamination clothin
Several
RPTs were observed
in the performance of smear
surveys.
No RPTs
among the several
observed
were noted to be performing
surveys without adequate
protective clothing.
The licensee's
procedures
and training describe
the protective clothing
appropriate
for performing surveys.
No other
examples
of this
allegation were observed.
B.
An RPT was re orted to have said.to the alle er that
he did not know
what the alle er should
do with some
e ui ment which caused
the
RPT's frisker to read off-scale hi h.
The inspector discussed
surveys
and disposition of contaminated
material with several
RPTs,
both
ANSI. 3. 1-1978 Senior Technicians
and three Junior
RPTs.
Procedure
75 RP-SZZ61,
"Radioactive
Material Storage
and Control," describes
actions to be taken to
control contaminated material.
No material
was observed to
leave contaminated
areas without an adequate
survey,
and all
personnel
engaged
in discussions
appeared
to understand
what actions
should
be taken.
This allegation
was not substantiated.
This matter is closed.
(RV-87-A-0066)
4.
~Fol 1 owo
At approximately 8:00 p.m.
on October 25, 1987, the licensee's
Fuel
Building (FB) was contaminated
extensively
by deposition of airborne
radioactivity when
an apparently vigorous chemical reaction took place
during decontamination
Pump
(RCP) components.
The
inspectors
discussed
the incident with licensee staff and toured the
area.
The licensee
stated that the
RCP shaft
and impeller assemblies
were being
decontaminated
by a chemical
process
developed
by Kraftwerk Union
(KWU)
and used extensively in nuclear power plants in Europe.
If the
components
remain in the decontamination
solution for long periods,
as
occurred with RCP-lB,
due to other equipment problems,
the contractor
procedure called for addition of a quantity of oxidizing agent,
calculated
by the "Decon Supervisor."
In this case,
the Decon Supervisor
was
a Federal
Republic of Germany
(FRG) national working under
a
Bechtel-KWU contract.
-The oxidizing agent
was to be added to break
down
a passivated
corrosion layer created
by the long-term immersion.
The
addition was required after 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of immersion.
The licensee
stated
additionally that about
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
had transpired with RCP-1B in'he
solution.
RCP-1B was resting
on the lip edge of the tank so as to form a
seal
between
the assembly
and the tank.
The mixture was being maintained
at 205~F.
Pressure
generated
from the exothermic reaction
between
the
decon solution and the oxidizing agent
was to relieve via the "kittybone"
labyrinth and out a seal water flange connected
to a 20-foot rubber hose.
The licensee staff stated that when they began to inject the agent at the
minimum speed of the-air-operated
pump, they heard
a rapidly
increasing
noise of escaping
pressure
and began to evacuate
the area
as
liquid and vapor from the tank began to spray out.
The licensee
estimated
approximately
20 gallons of mixture spewed out as water and
steam,
contaminating
the
FB.
No personnel
injuries occurred.
An air sample
taken at the time of the incident indicated approximately
0.5
MPC for the total nuclide mix observed.
Personnel
in the
FB at the
time of the incident were surveyed for contamination
and sent for
whole'ody
gamma
scans.
The results of whole body counting
(WBC) indicated
no
significant uptake of airborne radioactivity.
A licensee
review of the incident was in progress
at the time of the
inspection.
No procedural
changes
were required
by the licensee prior to
resumption of the process,
and decontamination
of the
RCP assemblies
resumed.
The licensee
representative
informed the inspector that the
Decon Supervisor
had been instructed to avoid the addition of chemicals
which could produce similar reactions.
No violations or deviations
were identified.
Facilit
Tour
A tour of the facility, during which independent
radiation measurements
were
made using
an
NRC ion chamber
survey instrument,
Eberline
R02A,
Serial
No. 897, calibrated
on September
28, 1987,
and due for calibration
on December
28,
1987,
was conducted.
The licensee's
postings
appeared
to comply with 10 CFR 19. 11, "Posting of
Notices to Workers,
and
10 CFR 20, "Standards
for Protection Against
Radiation.'"
However,
numerous
instances
of practices
inconsistent with
the licensee's
procedures
as stated in 75RP-OZZOl, "Radiological
Posting,", were observed:
A radiation area posting in the concentrated
radwaste
evaporator
room- had partially fallen such that it was not easily
readable.
A contaminated
area posting in a decontamination
area
on the
120'adwaste
Building was partially obscured.
A high contamination
area
(HCA) posting near door F101 for an area
which was
no longer an
HCA had fallen such that it appeared
that an
area outside the Fuel Building (FB) was
an
HCA.
The contaminated
area posting
on the laundry monitor in the Unit 1
Radwaste
Building was not visible from the side of the monitor from
which surveyed
laundry was
removed.
The barrier
and posting for a decontamination
cubicle
on the
120'levation
of the Unit 1 Radwaste
Building containing
an
RCP shaft,
posted
as
an High Radiation Area, Respiratory Protection
Required,
HPCA,
HCA, and Airborne Radioactivity Area had fallen to the floor,
but was still visible.
A tent containing scaffold material,
located outside the
FB near
door F101,
was posted inconsistently:
One side (the entrance)
was
posted with only the radiation caution symbol.
One side
was not
posted,
one side
was posted
as
a "Radioactive Material Storage
Area,"
as
was the roof which had fallen in, and the fourth side
was
posted
as "Radioactive Material."
A box used
by the Operations
Department for storage of radioactive
material
had its sign flipped over so it could not be read.
An area
contaminated
during the incident involving airborne
radioactivity in the
FB, was behind
a boundary rope,
posted only
with the radiation caution symbol.
RP personnel
stated that the
floor had been
decontaminated
and therefore
no protective clothing
was required,
but that other horizontal
surfaces within the area
(but not posted
"contaminated area"),
had yet to be released
as
uncontaminated.
The concerns identified above were brought to the attention of the
licensee
during the tour,
and were corrected
at that time by an
accompanying
the inspectors.
No areas
requiring posting were found to be
completely unposted.
The inspectors
noted that housekeeping
in the Auxiliary Building had
improved.
Little extraneous
material
was observed
in the
RB considering
the outage status,
'and
no unlabeled radioactive material
was observed in
uncontrolled areas.
In one instance,
yellow polyethylene
bags,
normally
reserved
by 75 RP-9ZZ61, "Radioactive Material Storage
and Control," for
radioactive material,
were being used in an uncontaminated
area 'walkway,
under
some
heavy objects.
The inspectors
were informed the material
was
not contaminated,
and that the plastic
was to prevent scuffing the floor,.
A tour of the radiologically controlled area outside of the
Radwaste
Building indicated that the
same level of attention
was not being given
10
to these
areas.
The outside yard area contained
numerous cigarette butts
and even
an empty soft drink can.
The area
was posted
"no eating,
drinking, or smoking."
Many of the caution signs,
though still visible,
were difficult to read
due to deterioration.
In the Radwaste Building,
most areas
posted
as either "Radiation Area" or "Contaminated-Area"
contained debris.
In one case,
a ladder within the
Radwaste
Evaporator
rooms
was blocked completely by protective clothing,
a fire extinguisher,
and other equipment.
In the
FB, the licensee
was in the process
of recovering
from a
contamination incident on October
25,
1987 (see
paragraph
4).
Much'f
the building, particularly within the hot particle control areas,
was
cluttered.
The licensee staff stated that they had experienced
difficultywith leakage
from various connections
on the decontamination
system,
and contamination levels were, according to
RP staff in the area,
extreme.
By the conclusion of the inspection,
however,
the areas
outside
contaminated
area boundaries
were
much improved.
The inspectors
noted that adhesive step-off pads
were
used extensively at
contaminated
area exits, but that many were not being kept sticky by
removal of expended
adhesive
pads.
During the tour, it was noted that three radiation monitors were alarming
and unacknowledged.
RU-2 and 3, for Essential
Cooling Water "B" and "A,"
respectively,
on the 70'levation of the Auxiliary Building, were
alarming.
RU-2 was alarming
on low flow.
The licensee staff
subsequently
stated that both were being acknowledged,
and that the
RU-3
alarm was determined to be spurious.
Waste
Gas
Decay Tank Monitor RU-12
was also alarming unacknowledged.
The licensee
RP staff provided the
inspectors with an "Alarm Response
Worksheet,"
showing the response
to
the alarm subsequent
to the tour of the facility.
The RU-12 alarm was
also determined
by the licensee
to be spurious, with a reading of 6.01
E-4 pc/cc
and
an alarm setpoint of 2.00 E-3 pc/cc.
During the course of the inspection,
a severe
thunderstorm
struck the
site
on October 29,
1987, resulting in a partial
power
outage.
The
inspectors
noted that postings
and barriers
located outside
had been
restored,
with the exception of a "potentially radioactive material
storage
area,"
where the barrier was visible.
The Central
RPM,
upon
discovering that power would not quickly be restored to respiratory
protection,
whole body counting,
and dosimetry areas,
promptly suspended
all work involving a high potential for uptake of radioactivity or high
external
dose, until such power could be restored.
No violations or deviations
were identified..
Exit Interview
The findings of the inspection
were brought to the attention of the
licensee
on October 30,
1987.
The licensee
was informed that failure to
limit overtime hours worked for Radiation Protection Technicians
was
an
apparent violation of TS 6.2.2.2.
The licensee
stated that
did not apply to contractor personnel,
and that this position
had been
agreed to by
NRC Region
V management.
The subject agreement
was related
to a resident
inspector identified overtime limitation being exceeded
by
a contractor
wor king on safety-related
equipment
(see
Inspection
Report
50-528/85-26).
The inspectors
determined that
RPTs are identified
specifically in Technical Specification 6.2.2.2
(see paragraph
2.B) and
the overtime limitations apply to contract
as we] 1
as
house technicians.
e