ML17312B345
| ML17312B345 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/31/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17312B343 | List: |
| References | |
| 50-528-97-07, 50-528-97-7, 50-529-97-07, 50-529-97-7, 50-530-97-07, 50-530-97-7, NUDOCS 9704020227 | |
| Download: ML17312B345 (36) | |
See also: IR 05000528/1997007
Text
ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
.
Location:
Dates:
Inspector:
Approved By:
50-528; 50-529; 50-530
50-028/97-07; 50-529/97-07; 50-530/97-07
Arizona Public Service Company
1
Palo Verde Nuclear Generating Station, Units 1, 2, and 3
5951'. Wintersburg Road
Tonopah, Arizona
March 10-14, 1997
Michael P. Shannon,
Radiation Specialist
Blaine Murray, Chief, Plant Support Branch
Division of Reactor Safety
ATTACHMENT: Supplemental
Information
9704020227
97033i
ADOCK 05000528
6
-2-
EXECUTIVE SUMMARY
Palo Verde Nuclear Generating Station, Units 1, 2, and 3
NRC Inspection Report 50-528/97-07; 50-529/97-07; 50-530/97-07
This routine announced
inspection focused upon the licensee's radiation protection
program during the Unit 3 refueling outage.
Areas inspected
included:
external and
internal exposurecontrol programs,
planning and preparation, contractor training and
staffing, control of radioactive material and contamination,
and nuclear assurance
audits
and evaluations.
En ineerin
Su
ort
~
No deviations to the commitments in Section 12.5 of the Updated Final Safety
Analysis Report were identified (Section E2.1).
~
In general,
a good external exposure
program was implemented.
A non-cited
violation was identified involving a worker who ehtered
using a radiation exposure permit. which did, not authorize such an entry.
A non-
'ited
violation was'identified involving the failure to inventory locked/very high
radiation area keys (Section R1.1) ~
Housekeeping
within the radiological controlled area was ve'y good (Section R1.1).
An effective internal exposure
control program was in place.
A very good air
sampling program was in operation (Section R1.2).
Radiological outage work planning was very good.
Lessons
learned were included
in work packages.
The as low as is reasonably
achievable
(ALARA)comm'ittee was
actively involved in outage exposure
goal setting (Section R1.3).
Effective radioactive contamination controls were implemented.
Radioactive
material was properly labeled and posted (Section R1.4).
A violation was identified involving the failure to post a radiation area
(Section R1.4).
In general,
a very good ALARAprogram was in place.
The station A'LARA
committee was supported
by all station work groups.
However, the operations
department
had not attended
an ALARAsub-committee
meeting since December
1995 (Section R1.5).
~
~
-3-
Management
demonstrated
support for the ALARAprogram by delaying the start of
the refueling outage by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in an effort to decontaminate
the reactor coolant
system (Section R1.5).
A very.good contractor radiation protection training program was maintained.
An
appropriate
number of trained and qualified contractor radiation protection
technicians were on site to support outage'work.
Radiation protection supervision
was appropriately involved in the development of the contractor radiation protection
program (Section R5.1).
An excellent audit program had been implemented by the nuclear assurance
department.
Nuclear assurance
auditors had strong radiological operational
and
technical backgrounds.
Self-assessments
perf'ormed by the radiation protection
department
provided management
with a good assessment
of the radiation
protection program (Section R7.1).
I
I4
~ 4
1
I
-4-
REPORT DETAILS
Summar
of Plant Status
Units
1 and 2 operated
at full power.
Unit 3 was in a refueling outage.
No events
occurred during this period that adversely affected the inspection.
iii. Encnineering
E2
Engineering Support of Facilities and Equipment
E2.1
U dated Final Safet
Anal sis Re ort Review
a.
Ins ection Sco
e
The inspector reviewed selected topics presented
in'Section 12.5, "Radiation
'rotection
Program," of the UFSAR to ensure agreement with commitments.
b.
Observations
and Findin s
A recent discovery. of a licensee operating their facility in a manner contrary to the
UFSAR description highlighted'the need for a special focused review that compares
plant practices, procedures,
and/or parameters to the UFSAR descriptions.
While
performing the inspection discussed
in this report, the inspector reviewed the
applicable portions of the UFSAR that related to the areas inspected.
The inspector
. verified that the UFSAR wording was consistent with the observed
plant practices,
procedures,
and/or parameters.
c.
Co'nclusion
J
r
No deviations to the commitments in Section 12.5 of the UFSAR were identified.
R1
Radiological Protection and Chemistry Controls
R1.1
External Ex osure Controls
Ins ection Sco
e 83750
Selected radiation workers and radiation protection personnel
involved in the
external exposure control program were interviewed.
The inspector performed
several tours of the radiolog'ical controlled area, including the Unit 3 containment
building.
The following items were reviewed:
'-5-
Radiological controlled area access/egress
controls,
Control of high radiation areas and high radiation area keys,
Radiation exposure permits,
Job coverage
by radiation protection personnel,
Housekeeping
within the radiological controlled area, and
Dosimetry use.
b.
Observations
and Findin s
High radiation areas were properly, controlled and posted.
All Technical
Specification-required
locked, high radiation area doors were locked and properly
posted.
Locked high radiation area flashing lights were operational.
Hi h Radiation Event:
On March 12, 1997,
the licensee informed the inspector, that'earlier that same
day, an Arizona Pubjic Service mechanic entered the locked high radiation area in
the low-level radioactive material storage facility without being on the proper
radiation exposure permit task or without receiving authorization frorri radiation
protection personnel.
On March 13, 1997, the inspector toured the low-'level radioactive material storage
facility with members of the licensee's radioactive materials control staff. The
inspector noted that the area was properly posted and controlled.
~During the tour, members of the licensee's staff walked the inspector through the
sequence
of events that occurred on March 12, 1.997.
The inspector concluded
~
.
that radioactive material control personnel
were always located between the worker
who had entered the area incorrectly and the radiation source
(an opened
radioactive waste vault with whole body dose levels as high as 2,500 millirem per
hour) and, thus, in this case the worker would not have likely received an unplanned
exposure.
The inspector also determined that radioactive material control personnel
took immediate and proper actions once they identified that the worker was not
authorized to be in the area.
The worker was escorted out of the area, radiation
protection management
was notified, and
a condition report/disposition request was
initiated by the staff.
The inspector was informed that the mechanic had entered the area several times to
repair the. contact 'relays for the bridge crane earlier on March 12, 1997, w'hile the
area was poste'd
and controlled as a radiological controlled area.
The inspector
determined that the employee was signed in on the. proper radiation exposure permit
(9-97-0009A, Task-1) for. such entries.
When the radioactive waste vault was
i
-6-
opened,
radiological work conditions changed
from a radiological controlled area to
At this point, radiation protection personnel
properly
posted the area with a locked high radiation area sign and one string of flashing
lights, which was added to the existing radiological controlled area posting and rope
boundary.
The inspector reviewed Radiation Exposure Permit 9-97-0009A, Task 1, which was
"used by the mechanic who entered the locked high radiation area and noted it
clearly stated "no high radiation area entry."
In order to be properly authorized to
work in the locked high radiation area, the mechanic should have been logged in .
under Radiation Exposure Permit 9-97-0009A, Task-3.
Technical Specification 6:12.2 requires, in part, personnel who enter a locked high
radiation area, work u'nder an approved
Radiation Exposure Permit.
On March 20, 1997, the licensee. provided the inspector
a copy of their
investigation report concerning this matter.
The report noted that the worker had
entered the area several times to repair the contact relays for the bridge crane on
March 12, 1997, while the area was posted and controlled as a radiological
controlled area.
The licensee determined that there was no willfulness on the part
.
of the worker because
he was not part of the pre-job briefing when the area posting
was changed.
It was'also determined that he followed previous work habits when
he re-entered the posted locked high radiation area.
The inspector reviewed the licensee's corrective actions regarding this event and
determined the corrective actions to be satisfactory to prevent
a similar occurrence.
This licensee ide'ntified and corrected violation is being treated as a non-cited
violation, consistent'with Section VII.B.1 of the NRC Enforcement Policy
(50-530/9707-01).
K
t
The inspector reviewed the locked/very high radiation area'key issue process
and
performed an inventory of locked/very high radiation area keys; .No problems were
identified with'the key issue program.
During the inventory of locked/very high,radiation keys, the inspector identified that
the locked/very high radiation area master keys. assigned to operations
and stored in
the operations shift supervisor's office had not been inventoried since August 12,
1994, when the locked/very high radiation area master keys assigned
operations
were inventoried'to close Condition Report/Disposition Request 94-0182.
The
inspector determined through interviews with operations personnel that they did not
maintain a key to open the box and could only gain access to the locked/very high
radiation area master keys by breaking the glass.
The inspector inspected the
locked/very high radiation area key box and determined that the box was intact.
~ 4
-7-
When key control was discussed with radiation protection management,
they stated
that it was never their intent to inventory locked/very high radiation area master
keys, because
they were not routinely issued.
The inspector determined
by
reviewing the key inventory records that the locked/very high radiation area master
keys assigned to radiation protection were inventoried each shift in accordance
with
radiation protection procedures.
After this matter was discussed
with radiation protection management,
a night
order was written requiring the radiation protection staff to perform an'inventory of
opeiations locked/very high radiation area master keys each shift until the master
keys were removed from the operations shift supervisors office.
Section 3.4.7 of Radiation Protection Procedure
"Control of Locked
High Radiation Areas and Very High Radiation Areas," Revision 10, states,
in part,
"..
~ locked/very high radiation area keys shall be inventoried each shift by the
designated
oncoming
RP technician. prior to the completion of shift turnover
. '..."
Technical Specification 6.8.1(a) requires,'in part, that written procedures
be
established,
implemented,
and maintained covering the activities recommended
in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Section 7.e(1)
of Appendix A of this regulatory guide includes procedures
for access
controls to
radiation areas.
The inspector determined that the failure to inventory locked/very high radiation.
area keys, was a violation of Radiation Protection Procedure
However, this failure constituted
a violation of minor significance and is being
'reated
as a non-cited violation consistent with Section IV of the Enforcement Policy
, (50-530/9707-02).
I
Radiation'Ex
osure Permits:
~
Radiation exposure permits were written in a clear consistent
manner.
The
. ins'pector noted that the limitations section of radiation exposure permit was written
in bold red letters informing the workers of areas and radiological co'nditions that
were not authorized.. The inspector concluded that by high-lighting the limitation
section of the radiation exposure permit, clear direction was provided to radiological
workers.
A review of randomly selected, active radiation exposure permit packages
concluded
that documentation
was.filed in accordance
with management's
expectations.,
The
inspector noted that the packages
contained survey documentation
used to develop
the radiation exposure
permit.
All personnel
observed
by the inspector wore their
dosimetry properly and knew to contact radiation protection personnel if their
electronic dosimeter alarmed.
-8-
The inspector determined that job coverage
provided by radiation protection
technicians was appropriate for the radiological work observed.
Field radiological
briefings given by the job coverage
radiation protection technicians discussed
the
radiological conditions in the work area and potential radiological hazards
and hold
points.
Housekeeping
within the radiological controlled area was very good.
All trash and
.
laundry containers were properly maintained.
On Tuesday, March.11, 1997, and Thursday, March 13, 1997, the inspector
attended
a night shift radiation protection supervisor's
plant status meeting with the
staff, and a radiation protection supervisor's shift turnover meeting, respectively.
The inspector noted a good exchange
of information between supervision and staff,
and determined that both meetings were informative and professional.
All personnel
were attentive and had the opportunity to address
any concerns.
C.
Gonclusions
Technical Specifi'cation-required
locked high radiation doors were properly locked
and posted.
A non-cited. violation was identified involving a worker that entered
a
locked high radiation area using a radiation exposure permit which did not authorize
such an entry.
A non-cited violation was identified for the failure to inventory
locked/very high radiation area keys.
Housekeeping
within the radiological
controlled area was very good.
All personnel
observed wore their dosimetry
properly.
R1.2
Internal Ex osure Controls
" Ins ection Sco
e 83750
Selected radiation protection personnel involved with the internal exposure control
program were interviewed.
The following items were re'viewed:
~
Air sampling program, including the use of continuous air monitors and high
efficiency particulate air filtration units,
~
Respiratory protection program,
~
.
Whole body coun'ting program, and
I
~
The internal dose assessment
program.
l
-9-
b.
Observations
and F!ndin s
All air sampling equipment observed
in the field had current calibration dates and
was response
checked
in accordance
with station procedures.
The use and
positioning of continuous
air monitors and air filtration units were appropriate to
monitor and limit airborne exposures.'ob
coverage
air sampling equipment
observed
by the inspector was appropriately positioned to alert workers of changing
airborne radiological work conditions.
As of March 13, 1997, three full-faced negative pressure
respirators
and eight
air-supplied bubble hoods had been issued for radiological work. The inspector
reviewed selected TEDE/ALARAevaluations,
which. were performed to ensure
compliance with the requirements of 10 CFR Part 20, Subpart H, and concurred
with the licensee's
conclusions that respiratory protection equipment satisfied
TEDE/ALARAprinciples.
No positive whole body counts occurred that exceeded
the licensee's
administrative action level for recording internal dose.
The inspector reviewed the licensee's
program used to determine internal dose
assessment.
No problems were identified with this program.
c.
Conclusions
The internal exposure control program was effectively implemented.
A very good
air sampling program was in place.
The use of continuous
air monitors and air
filtration units were appropriate to monitor and limit airborne exposures.
R1.3
Plannin
and Pre aration
a.
Ins ection Sco
e 83750
Radiation pr'otection department
personnel
involved in radiation protection outage
planning and preparation were interviewed.
The following items were reviewed.
ALARAjob planning;
Job scheduling
and sequencing;
ALARApackages;
Incorporation of lessons learned from similar work; an'd
V
Supplies of radiation protection instrumentation, protective clothing, and
consumable
items.
k
I
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b.
Observations
and Findin s
The inspector determined that radiation protection personnel were actively involved
with the outage radiological work job planning.
ALARApackages
included lessons
learned from past similar site and industry work.
It was.concluded
from a review of ALARAcommittee meeting minutes that the
committee was appropriately involved in outage exposure
goal setting and
monitoring.
The inspector reviewed some ALARAfield notes, which were written during
on-going work, and determined that,.appropriate
items to improve'uture similar
work were identified.
No problems were identified with the adequacy
of radiation protection
instrumentation,
protective clothing, and consumable
supplies to support
radiological work.
c.
Conclusions
Radiation protection personnel were appropriately involved with the outage
radiological work job planning.
ALARApackages
included lessons
learned from past
similar site and industry work. The ALARAcommittee was actively involved in
outage exposure
goal setting and monitoring..
'1.4
Control of Radioactive Materials and Contamination:
Surve
in
Postin
and
~Mon i to tin
a.
Ins ection. Sco
e 83750
Areas reviewed included:
~
Contamination monitor use and response
to alarms,
~
Control of radioactive material,
~
Portable instrumentation calibration and performance checking programs,
Adequacy of'he surveys necessary to assess, personnel
exposure,
and
~
Radiological postings.
b.
Observations
and Findin s
All personnel
observed
by the inspector used the personnel contamination monitors
properly.
Radiation protection technicians stationed at the radiological controlled
access
area responded
properly to the personnel contamination monitor alarms and
provided'lear and proper guidance to workers.
-11-
The licensee provided good controls to prevent the spread of radioactive
contamination.
Contaminated
areas were well posted and marked. with tape or
rope.
Step-off pads were placed at the entrances/exits
to these areas.
The
inspector observed
radiation work activities while exiting contaminated
areas,
and
noted good health physics practices.
AII containers,
including vacuums,
were
properly labeled and controlled.
All radioactive material observed was properly labeled and posted.
Portable radiation
~
protection survey instrumentation was properly calibrated and source response
checked.
The inspector reviewed
a number of surveys and determined that they were
documented
in a clear, consistent manner.
During a tour of the Unit 3 fuel building, on March 12, 1997, the inspector
identified that the west stairway leading to the 140-foot elevation was not posted
.as a radiation area.
After a review of surveys for the area, the inspector determined
that this condition had existed for at least 8 days.
Dose rates on the 140-foot
elevation were as high as 400 millirem per hour on contact and 10 millirem per hour
at 30 centimeters.
'0
CFR 20.1003 defines
a radiation area as an area accessible
to individuals in
which radiation levels could result in an individual receiving
a dose equivalent in
excess of 5 millirem in
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from
any surface that the radiatio'n penetrates.
'10 CFR 20.1902 (a) requires that radiation areas
be posted with a conspicuous
sign
or signs bearing the radiation symbol and the words "CAUTION RADIATIONAREA."
1
The failure to post the west stairway leading to the 140-foot elevation of Unit 3's
.fuel building as a radiation area is a violation of 10 CFR 20.1.902
(a)
.
(50-530/9707-03).
c.
Conclusions
E
Station workers used the personnel contamination monitors properly.
Good controls
to prevent the spread of radioactive contamination were implemented. All
radioactive material was properly labeled and posted. A violation was identified for
the failure to post the west stairway leading,to 140-foot elevation of Unit 3's.fuel
building as a radiation area..
-1 2-
R1.5
Maintainin
Occu ational Ex osure ALARA
a.
Ins ection Sco
e 83750
Radiation protection personnel
involved with the ALARAprogram were interviewed:
The. following areys were reviewed:
0
ALARAcommittee support,
Exposure goal establishrrient
and status,
Lesson learned capture,
programs,
and
Shutdown chemistry controls.
b.
Observations
and Findin s
During tours of the radiological controlled area, the inspector noted that ALARAlow
dose (cool areas) and radiological hot spot areas were identified throughout the unit.
The inspector. observed
a number of job coverage field briefings conducted
by
radiation protection technicians
and noted that ALARAwork practices were
stressed.to
all workers.
Workers interviewed by the inspector knew the general
radiological conditions in their work area and. the low dose waiting areas.
The inspector reviewed the minutes from the station ALARAcommittee meeting
since March 1996, and noted good involvement of all station groups.
In addition to
the ALARAcommittee, the licensee had established
an ALARAsub-committee
which was corhprised of working level personnel from all the major work groups.
A review of the sub-committee
meeting. minutes indicated that the sub-committee
w'as instrumental
in incorporating
a number of ALARAsuggestions
and
awards.'uring
the review of the ALARAsub;committee
meeting minutes, the inspector
identified that the operations department had'not attended
a meeting since
December 1995.
The. inspector noted that the ALARAcommittee'as
informed,.of
the lack of operations department support of the sub-committee
during thejr
February 29, 1996, meeting.
Licensee management
stated that they would work
with the sub-committee to improve the operations department support.
'I
The inspector reviewed the outage exposure summary data for the refueling
outage (U3R6) and noted that post shutdown dose rates were approximately twice
as high as the last Unit 3 refueling outage (U3R5), 160 millirem per hour versus
80 millirem, respectively.
The licensee has written a "level'1" investigation
report,'hich
requires senior station management
involvement, and two condition
reports/disposition
requests, to identify the cause of the unexpected
increased
dose
rates.
The licensee had not completed their investigation during this. inspection
period.
~
~
-13-
The inspector noted that station management
demonstrated
their support for the
ALARAprogram by delaying the start of the refueling outage by 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in an
effort tc decontaminate
the reactor coolant system and reduce the general area
dose
rates.'he
inspector determined that the 127 person-rem,
Unit 3 refueling outage exposure
goal, was challenging.
A review of the trending 'data verses remaining work
indicated that there was a good possibility of meeting the outage exposure'goal,
even with the-elevated
dose rates encountered
during shutdown.
Twenty O'LARA suggestions
had been submitted during 1996, and three ALARA.
suggestions'had
been submitted for 1997, as of March 13, 1997.
All 1996 ALARA
suggestions
had been reviewed, evaluated,
and closed in a timely manner.
The
inspector noted that the three ALARAsuggestions
submitted for 1997 had been
reviewed and evaluated.
The inspector determined that there was a good ALARA
suggestion
program in place.
c.
Conclusions
'5
Overall, a very good ALARAprogram was in place.
ALARAwork practices were
stressed
to all workers during field pre-job briefings,
The station ALARAcommittee
was supported
by all work groups.
The operations department
had not attended
an
ALARAsub-committee
meeting since December 1995.
Management
demonstrated
support for the ALARAprogram by delaying. the start of the refueling outage by
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in an effort to clean up the reactor coolant system.
Unit 3's refueling
outage exposure
goal was challenging.
Staff Training and Qu'alification in Radiological Protection and Chemistry
~,
R5.1, Radiation Protection Staff Trainin
a.
Ins ection Sco
e 83750
. Personnel
involve'd with contractor'radiation
protection technician training and
resume evaluation were interviewed.
The following items were reviewed:
~
Contractor radiation protection'technician
training lesson plans, and
~
Resumes
of contractor radiation protection technicians.
b.
Observations
an
Findin s
The inspector reviewed the qualifications of radiation protection instructors assigned
to train the contractor radiation protection personnel
brought on site to support
outage activities, and noted that these individuals had a number of years of
operational radiation protection and instructor experience.
'
-1 4-
Fifty-three senior contractor radiation protection technicians
and 17 junior
contractor radiation protection technicians were hired to support outage radiological
activities.
The inspector noted that approximately 70 percent of the contractor
radiation protection technicians
had worked previous Palo Verde outages.
Randomly selected
senior contractor resumes were reviewed.
It was noted that all
senior radiation protection contractors were all American Nuclear Standards
Institute 3.1 (3 years of radiation protection experience)
level technicians.
The lesson plans used for training contract radiation protection technicians were
well organized, developed,
and site and industry lessons learned were incorporated.
'adiation
protection management
was appropriately involved in 'developing the
'raining
topics.
However, the inspector noted that radiation protection, management
had not monitored the contractor radiation protection classroom training, as in past
outages.
Radiation protection management
acknowledged
the inspector's
comment, and stated they planned to monitor portions of future outage contractor
classroom training.
The Northeast Utilities'adiation protection screening program.was used to evaluate
the general radiological knowledge of the contract radiation protection technicians
brought on site to support outage activities.
The Northeast Utilities program is
recognized
and approved by a number of utilities as an acceptable
method to
evaluate radiation protection technician's general radiological knowledge.
The
inspector noted that both junior and senior contractor radiation protection
technicians were required to pass this examination within the last 2 years, prior to
performing radiation p'rotection activities.
All contractor radiation protection technicians were tested on site-specific
'information and'on-the-job training and evaluations were given and tracked by
radiation protec'tion supervision.
A
The on-the-job evaluation qualification program was reviewed.
Tasks listed were
'
appropriate
and evaluation guidelines were clearly stated.
Conclusions
R6
An appropriate
number of trained and qualified contractor radiation protection
technicians were on site to support outage work. A large percentage
of contractor.
radiation protection technicians
had worked previous Palo Verde
outages.'adiation'rotection
supervision was involved in the development of the contractor radiation
protection program.
Radiological Protection and Chemistry Organization and Administration
The inspector reviewed the present organization chart and compared it to an
organization chart obtained during the previous inspection.
The radiological
decontamination
group was recently placed under the radiation protection
-1 5-
organization.
The inspector noted fewer contaminated
areas
in the auxiliary building
than during past inspections.
Radiation protection management
stated that the.
reorganization
enabled them to better set the priorities pertaining to reclaiming an
area.
Because the changes
were recently implemented',
no conclusion was reached
with regard to the reorganization.
R7
Quality Assurance
in Radiological Protection and Chemistry Activities
R7.1
Qualit
Assurance Audits and Sur'veillances
and Radiation De.artment Self-
Assessments
and Radiolo ical Occurrence
Re orts
a.
Ins ection Sco
e 83750
Selected
personnel
involved with the performance of quality assurance
audits and
surveillance,
and radiation department self-assessments
were interviewed.
The
following items were reviewed:
4
Qualifications of personnel who performed nuclear assurance
radiation
protection a'udits and evaluations,
~
~
Nuclear assurance
audits performed since March 1996,
Nuclear assurance. evaluations performed since March 1996,
~
Radiation protection department self-assessments.
performed since
March 1996, and
~
Radiological condition'report/disposition
requests written since March 1996.
b.
" Observations
and.Findin
s
The inspector reviewed the qualifications of the lead nuclear assurance
auditors
assigned to assess
radiation protectio'n department activities.
Three individuals
were assigned to oversee radiation protection department a'ctivities.
The inspector
determined that all three nuclear assurance
auditors had a number of years of
operational
and technical radiation protection experience.
The inspector reviewed Nuclear Assurance Audit 96-008, which was performed
between March 5 and 15, 1996.
The audit provided
a good assessm'ent
of the
radiation protection program.
The audit identified four "areas for management
attention" (deficiencies) .. Areas for management
attention were tracked by the
licensee's
condition report/disposition
request system, which was used to track
corrective actions.
The inspector reviewed the recommended
corrective actions
pertaining to this audit, and determined that they appeared
appropriate to correct
'the deficiencies identified.
The inspector noted that these items were closed out in
a timely manner.
-'1 6-
The inspector reviewed the audit schedule
and determined that it covered the
appropriate
program areas to provide mana'gement
with a good overview of the
radiation protection program.
Radiation protection management
was properly
involved in the development
of the audit scope.
\\
Selected nuclear assurance
radiation protection evaluation reports were reviewed.
The reports covered
a broad range of radiation protection activities and provided
management
with a good tool to assess
the radiation protection "program.
E
Self-assessments
were clearly written and covered
a wide range of radiation.
protection activities.
The inspector determined that the self-assessments
provided a
good overview of.the radiation protection program.
No problems were identified
with the radiation protection self-assessment
schedule.
No problems were identified during the review of radiological condition
reports/disposition
requests.
The inspector noted'that recommendations
to prevent
a re-occu'rrence
appeared
to be appropriate
and corrective actions were closed out
in a timely manner.
No negative trends were identified by the inspector during his
review.
c.
Conclusions
The nuclear
Area
assurance
auditors assigned to assess
radiation protection activities had
strong radiological operational
and technical backgrounds.
'Audit 96-008 provided
a
good assessment
of the radiation protection program.
Radiation protection
.department self-assessments
provided management
with a good overview of the
radiation protection program.
No problems were identified with radiological
condition reports/disposition
requests.
R8
Miscellaneous Radiological Protection and Chemistry Issues
t
I
R8.1
Closed
Violation 529 9402-01:
Not Wearin
a TLD in the Radiolo ical Controlled
R8.2
This violation involved a contract employee working inside the radiological
controlled area, who had removed his security badge and dosimetry, and placed
them several feet away from himself.
The inspector confirmed that the corrective
actions described
in the licensee's
response
letter, dated April 13, 1994, were
. completed.
No additional examples were noted during the inspection.
Closed
Violation 529 9604-01:
Failure to Follow Radiation Protection Procedures
This violation involved:
(1) a,worker who performed work in the radiological
controlled area overhead without radiation protection authorization;
and (2) woikers
not following the protective clothing requirements that were listed on their radiation
exposure permit, as well as, radiation protection personnel who provided job
~ t
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coverage, that were not aware-of the protective clothing requirement.
The
inspector confirmed that the corrective actions described
in the licensee's
response
letter, dated May 22, 1996, were completed.
No additional examples were noted
during the inspection.
V. Mana ement IVleetin s
X1
Exit Meeting Summary
I
The inspector presented
the inspection results to members of licensee management
at an exit meeting on March 14, 1997.
The. licensee acknowledge'd
the findings
presented.
No proprietary information was identified.
ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED
Licensee
J. Levine, Senior Vice President,
Nuclear Operations
G. Overbeck, Vice President,
Nuclear Production
J. Burgard, Section Leader, Radiation Protection
D. Edwards, Section Leader, Technical Training
J.. Gaffney, Department Leader, Radiation. Protection
T. Gray, Section Leader, Radiation Protection
V. Huntsman, Department Leader, Radiation Protection
A. Krainik, Manager,.Nuclear
Regulatory Affairs
D. Larkin, Senior Engineer,
Nuclear Regulatory Affairs
D. Leach, Department Leader, Nuclear Assurance
D. Marks, Section Leader, Nuclear Regulatory
Affairs'.
Nelson, Training Coordinator, Technical Training
M. Shea, Director, Radiation Protection
NRC
K. Johnston,
Senior Resident Inspector
INSPECTION PROCEDURE USED
83750'ccupational
Radiation Exposure.
LIST OF ITEMS OPENED AND CLOSED
~Oened
530/9707-01
. 530/9707-02
530/9707-03
Failure to use a proper radiation exposure permit to enter a
e
Failure to inventory locked/very high radiation area keys.
Failure to post a radiation area
2
Closed
530/9707-01
530/9707-02
529/9402-01
529/9604-01
Failure to use a proper rad'ation exposure permit to enter a
'I
NCV'ailure to inventory locked/very high radiation area keys
Failure to Follow Radiation Protection Procedures
LIST OF DOCUMENTS REVIEWED
Radiation Protection Procedure
"ALARAProgram," Revision 5
Radiation Protection Procedure
75AC-9RP1 1,, "ALARACommittee," Revision 4
Radiation Protection Procedure
75DP-9RP01; "Radiation Exposure And Access Control,"
Revision 0
Radiation Protection Procedure
Radiation Protection Procedure
Radiation Protection Procedure
Instrumentation,"
Revision 8
"Radiological Posting," Revision 15
"Radiological Survey Schedule,"
Revision 2
75RP-9MC01, "Control Of Radiation Protection
Radiation Protection Procedure
"Control of Locked'High Radiation Areas and
Very High Radiation Areas," Revision 10
Radiation Protection Procedure
"Radiation Exposure Permits," Revision 13
Radiation Protection Procedure
"Radiological Surveys," Revision 8
Radiation Protection Procedure
"Vehicle, Equipment and Material Release,"
Revision 14
Operations Proceduie 40DP-9OP33, "Shift Turnover," Revision
1
Nuclear Assurance
Procedure
60DP-OQQ19, ."Internal Audits," Revision
1
Nuclear Assurance
Procedure
60DP-.OQQ17, "Conduct of Nuclear Assurance
Evaluations,"
Revision 6
Nuclear Assurance
Division Evaluation Schedule
1996
e
-3-
Nuclear Assurance
Division Audit Report 96-008, "Radiation Protection Occupational
Exposure"
A Summary of Nuclear Assurance
Radiation Protection Evaluation Reports From March
1996
A Summary of Radiation Protection Department Self-Assessments
From March 1996
ALARACommittee Meeting Minutes From March 1996
ALARASub-Committee
Meeting Minutes From March 1996
Radiation Exposure Permit 9-97-G009A
Radiation Exposure Permit 3-3022A
Radiation Exposure Permit 3-3319A
Radiation Exposure Permit 3-3501B2
1
S
e