ML18036B184
| ML18036B184 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/02/1993 |
| From: | Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18036B182 | List: |
| References | |
| 50-259-93-03, 50-259-93-3, 50-260-93-03, 50-260-93-3, 50-296-93-03, 50-296-93-3, NUDOCS 9303160049 | |
| Download: ML18036B184 (21) | |
See also: IR 05000259/1993003
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
ATLANTA,GEORGIA 30323
8
lS93
Report Nos.:
50-259/93-03,
50-260/93-03,
and 50-296/93-03
Licensee:
Valley Authority
6N 38A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket
Nosd I
50-259,
50-260
50-296
"License Nos.:
DPR-,52
and
Facility Name:
Browns Ferry 1,
2,
and
3
Inspection
Conducted:
February 8-12,
1993
Inspector:
E.
D. Testa,
P.
ate
igned
Accompanied
by:
D.
B. Forbes
ddd
dd:
dd
Ba.
'. H.'ankin, Chief
at
Signed
Facilities Radiation Protection
Section
Radiological
Protection
and
Emergency
Preparedness
Branch
Division of Radiation Safety
and Safeguards
SUMMARY
Scope:
-Thi's routine,
announced
inspection of the licensee's
radiation control
(RC)
program involved
a review of health physics
(HP) activities including
organization
and staffing; self-assessment
programs; training and
qualifications; internal
and external
exposure controls; control of
radioactive material;
and
ALARA program implementation .primarily associated
with 1993 Unit 2 Cycle
6 Refueling Outage
(U2C6-RFO) activities.
d
Results:
The
RC technician staffing appeared
adequate
to support outage activities.
The
RC technician
and general
employee training
(GET) programs
were conducted
in accordance
with approved
procedures.
The licensee
continued to implement
effective internal
and external
exposure
programs with all exposures
less than
10 CFR Part 20 limits.
Reduction in Personnel
Contamination
Events
(PCEs)
and
ALARA outage initiatives were considered
program strengths.
9303i60049
930304
ADOCK 05000259
6:
'PDR
A NRC'dentified failure to properly label Radioactive
Containers
was
determined to be
a violation (VIO) (Paragraph
S.a) ..A NRC identified poor
contamination control practice
was noted
when three
vacuum cleaners
were
observed with suction inlets
open while not in use.
This was determined
to be
a non-cited violation
(NCV) (Paragraph
S.b).
REPORT DETAILS
Persons
Contacted
Licensee
Employees
- H. Bajestani,
Manager,
Technical
Su'pport
- R. Baron,
Manager,
Site guality
"S.
Bugg,
Manager,
Radwaste
p~
- J.
Bynum, Vice President,,Nuclear
Operations
- R. Coleman,
Radiological Protection Supervisor
- J. Corey,
Manager,
Radiological
Controls
- H. Herrell, Manager,
Plant Operations
- G. Hudson,
Corporate Radiological
Controls
"*J. Haddox,
Manager,
Nuclear Engineering
- E. Mastich, Manager,,Recovery
and Outage
- J. HcDaniel,
gA Evaluator
- G. Pierce,
Manager,
Regulatory Licensing
- J. Rupert,
Manager,
Engineering
and Modifications
- J. Sabados,
Manager,
Chemistry
and Environmental
- P.=- Salas,
Manager,
Compliance Licensing
- J. Scalice,
Plant Manager
F. Spivey,
ALARA Supervisor
- J. Wallace,
Compliance
L. Wilson, Radiological
Control Shift Supervisor
- 0. Zeringue,
Site Vice President
Other licensee
employees
contacted
during the inspection
included
technicians,
maintenance
personnel,
and administrative personnel.
Nuclear Regulatory
Commission
- J. Hunday,
Resident
Inspector
- R. Husser,
Resident
Inspector
- C. Patterson,
Senior .Resident
Inspector
- W. Rankin, Chief, Facilities Radiation Protection Section
- Attended February
12,
1993, Exit Meeting
Organization
and Staffing (83729)
The inspector
reviewed
and discussed
with licensee
representatives
changes
made to the radiation control
(RC) organization
since the last
inspection of this area
conducted
March 30-April 3,
1992,
and documented
in Inspection
Report (IR) 50-259,
260, 296/92-13.
Cognizant licensee
representatives
stated that
no significant changes
had
been
made to the
organizational
structure or lines of authority as they related to the
RC
function.
The inspector
noted that
a few minor personnel
changes
had
been
implemented,
which included temporarily reassigning
a Field
Operations
Manager to a second
Recovery/Outage
Manager.
The vacated
position was filled from within the
RC group with no loss in program
continuity noted.
2
The licensee
continued to maintain
a core radiological control
organization with approximately
169 personnel.
For U2C6-RFO, the
inspector
noted that approximately
52 contractor,
HP technicians
were
employed to supplement
the routine staff.
This number included senior
technicians,
junior technicians,
and
HP clerks.
Review of documentation
associated
with technician qualifications revealed that
a number of the
technicians
had previous experience
at the Browns Ferry site.
Based
on discussions
with licensee
representatives
and observations
of
activities in progress,
no concerns
were identified regarding the
licensee's
organization
and staffing.
The staffing levels
appeared
adequate
to support
ongoing
and planned
outage activities.
No violations or deviations
were identified.
Audits and Appraisals
(83729)
a.
Audits
Technical Specification
(TS) 6'.5. 1.6 requires that audits of plant
activities
be performed
under the cognizance of the Plant
Operations
Review Committee
(PORC)
encompassing
the conformance of
plant operation to provisions contained within the TSs
and
applicable license conditions at least
once per
12 months:
and the
Process
Control
Program
(PCP)
and implementing procedures
at least
once per
24 months.
The inspector discussed
the audit
and surveillance
program related
to radiation protection with licensee
personnel
and reviewed the
results of audits performed
by Nuclear guality Assurance
since the
last inspection.
In general,
the audits
were found to be well
planned
and documented
and contained
items of substance
relating
to the radiation. protection program.
Corrective actions to audit
findings were being accomplished
in a timely manner.
b.
Radiological
Awareness
Reports
(RARs)
Browns Ferry Procedure
RCI-14 implements the
RAR program providing
guidance
on the preparation,
use, tracking,
and trending of RARs.
The inspector
reviewed
RARs since the last inspection.
Some
RARs
documented
that
a small
number of workers
had exited the radiation
Control Area without logging out on the
RWP Radiation
Exposure
System
(REX) System.
Corrective action
was initiated and
documented.
The new recently installed
REX System will not allow
a worker reentry
on
an
RWP until they have
been properly logged
out from the previous entry.
C.
Personnel
Contamination
Reports
(PCRs)
The licensee's
goal for personnel
contamination
was to maintain
them at
a rate of 0.9
PCRs per 10,000
RWP-Hours.
In 1992, the
licensee
achieved this goal with 62
PCRs during 986,531
RWP-Hours.
This was approximately 0.64
PCRs per 10,000
RWP-Hours.
For U2C6-
RFO which began January
3,
1993, the licensee',s
goal
was
established
at 0.5
PCRs per
1000
RWP-Hours.
The licensee
has
had
six
PCRs during. the outage
as -of February
12,
1993, for a rate of
0.08
PCRs per
1000
RWP-Hours.
The licensee
has continued to achieve their 'goal in maintaining
a
low number of PCRs.
.This. is considered
a program strength.
No violations or deviations
were identified.
Planning
and Preparation
(83729)
The inspector discussed
the planning
and preparation for the .outage with
licensee
representatives.
Specific areas
discussed
included increases
in
staffing, special
mockup-training,
equipment
and supplies,
involvement in outage planning,
licensee
control over
HP technicians,
and dose reduction
methods to be employed.
The licensee
has prepared
a lessons
learned
manual
from previous
outages
to aid in the planning
and preparation for U2C6-refueling outage.
The
inspector
reviewed licensee
procedure,
Refueling Operations,
Revision
(Rev.)
9 and the lessons
learned
manual
and discussed
the process
of
incorporating lessons
learned with the licensee
ALARA Hanager.
preplanning
packages
for U2C6-RFO Recirculation
Pump Shaft replacement
and Recirculation
System chemical
decontamination
were reviewed.
The
preplanning
packages
reviewed
appeared
to be adequate
and lessons
'earned
were well documented
to avoid repeat
problem occurrences.
No violations or deviations
were identified.
Radiation Protection Training (83729)
10 CFR 19. 12 requires
the licensee to instruct all individuals working
or frequenting
any portions of the restricted
areas
in the health
protection aspects
associated
with exposure to radioactive material
or
radiation,
in precautions
or procedures
to minimize exposure,
and in the
purpose
and function of protection devices
employed,
applicable
provisions of the Commission Regulations,
individuals responsibilities
and the availability of radiation exposure
data.
a.
Contractor
Technician Training
The inspector
reviewed with licensee
representatives
the process
for qualifying and training
RC contractor technicians for the job
functions they were expected
to perform.
The training program
consisted of site familiarization, health physics procedure
reviews,
and specific job'actors
depending
upon the assigned
duties of the technician.
During the review, the 'inspector
observed
HP contractor
personnel
stationed
at access
control points,
surveying material,
performing
general
a'rea surveys, 'and performing whole body counting
functions.
The inspector
reviewed
resumes for the contractor technicians
employed onsite for U2C6-RFO
and verified compliance with
ANSI 3. 1,
1981 requirements.
The licensee
had employed contractor
technicians
from three separate
contractors
to support
'ctivities.
Review of training documentation
and interviews with
several
contractor
RC technicians
and licensee training staff
members
determ'ined
successful
completion of procedural
reviews
and
qualification tasks.
The licensee's
program for contractor
RC
technician training was adequate.
'I
No violations or deviations
were identified.
b..
General
Employee Training
(GET)
Licensee
Procedure
RCI-I, Rev.
31 described
the training required
for employees
granted
unescorted
access
to the site..
GET was
divided into two levels.
Level I training was provided to
employees
needing
unescorted
access
to only the protected
area.
For workers needing
unescorted
access
to the radiologically
co'ntrolled area
(RCA), Level'I training
(GET 022.001,
Rev.
1) was
required,
in addition to Level I training
(GET 012.000,
Rev. 3).
Both levels of training required
personnel
to pass
an examination
with a minimum passing
score of 80 percent.
Based
on the'review of selected training procedures,
examinations,
and course outlines,
the inspector determined that the licensee's
GET program met the provisions of 10 CFR 19. 12.
No violations or deviations
were identified.
External
Exposure Controls
(83729)
10 CFR 20.101 requires that
no licensee
possess,
use,
or transfer
licensed material
in such
a manner
as to cause
any individual in a
restricted
area to receive in any period of one calendar quarter
a total
occupational
dose in excess
of 1.25
rem to the whole body,
head
and
truck, active blood forming organs,
lens of the eyes;
or gonads;
18.75
rem to the hands,
forearms, feet,
and ankles;
and 7.5 rem to the
skin of the whole body.
Whole Body Exposure
TS 6.8. 1 requires
the licensee
to have written procedures,
including the
use of radiation work permits
(RWPs).
The inspector reviewed plant
procedure
Radiological
Control Instruction RCI-2.1, External
Dosimetry
Program Implementation,
Rev.
17.
10 CFR 20.202 requires
each licensee
to supply appropriate
monitoring
equipment to specific individuals and requires
the use of such
equipment.
During tours of the plant, the inspector
observed
workers
wearing appropriate
personnel
monitoring devices.
The inspector discussed
the cumulative whole body exposures
for plant
and contractor
employees.
Licensee representatives
stated
and the
inspector confirmed that all whole body exposures
assigned
since the
previous
NRC inspection of this area
were within 10 CFR Part 20 limits.
No violations or deviations
were identified;.
Internal
Exposure Controls
(83729)
t
10 CFR 20. 103 establishes
the limits for exposure of individuals to
concentrations
of radioactive materials
in the air in restricted
areas.
Section
20. 103 also requires that suitable
measurements
of
concentrations
of radioactive material
in air be performed to detect
and
evaluate
the airborne radioactivity in the air.
a.
Respiratory Protection
and Breathing Air guality
Lesson
Plan,
Respiratory Protection Training,
Rev.
6, provided the
training requirements for personnel
using respirators,
self-'ontained
breathing
apparatus
(SCBA); and bubble hoods.
The
inspector
found the training content appropriately inclusive of
respiratory protection principles.
Safety precautions for
emergency
removal of respirators
and
SCBAs was included in the
lesson
plan.
The'inspector
reviewed
a respiratory examination
key
and selected
respiratory examinations
which had
been
graded.
The inspector
reviewed
and discussed
with licensee
representatives
the program for testing
and qualifying breathing air as
Grade
D,
particularly as it related to preparation for U2C6-RFO activities.
The inspector,
accompanied
by licensee
personnel,
inspected
the
in-use breathing air system which included'
portable
compressor
air line system with backup compressor.
The licensee
stated
the
infrequently used portable
compressor
would be tested prior to
use.
The licensee
uses full face filtered respirators
much more
frequently than forced air respirators
or bubble hoods.
The
licensee
issued
5,513 respi,rators
in 1992 for a total of
0.009 respirators/
RWP entry and
has
issued
398 respirators
in
1993
as of February
10 for a total of 0.005 respirators/RWP
entry.
The licensee
exercises
the use of containments
and portable
filtered worksite ventilation to minimize internal
contaminations
and the use of respirators.
The inspector
examined breathing air
manifolds for physical integrity, current calibration of gauges,
and the presence
of carbon
monoxide monitoring equipment.
In
addition, the inspector further noted that the respiratory
equipment
staged for training and usage
appeared
to be in good
physical condition.
i
Review of breathing air testing records verified that the licensee
was calibrating in-line carbon
monoxide monitors
on
a monthly
basis or after maintenance.
The licensee
was sampling in-use
breathing air systems
on
a quarterly basis for Grade
D
certification in accordance
with procedural
requirements
or prior
to use if being
used infrequently.
For the tests
reviewed,
breathing air met or exceeded
grade
D requirements.
b.
Whole Body Counting
Licensee
procedure
RCI-1; 1,
Rev.
14, Attachment
A provides
procedures
to be followed for personnel
decontamination prior to
'erforming
bioassay
following the guidelines of RCI-'8,
Rev.
9.
The inspector
was informed by licensee
representatives
that nine
positive internal contaminations
had
been identified to date since
the last inspection
which included six positive internal
contaminations
in 1992,
and three positive internal
contaminations
in 1993 'he
inspector
reviewed the Internal
Dose Assessments
and
determined
no reportable limits had
been
exceeded
and the internal
doses
were determined to be
a small
percentage
of the regulatory
limits.
Based
on the above,
the inspector
concluded that the licensee
was
effectively controlli,ng internal contaminations.
No violations or
deviations
.were identified.
Surveys,
Monitoring, and Control of Radioactive Material
and
Contamination
(83729)
10 CFR 20.201(b) requires
each licensee
to make or cause to be
made
such
surveys
as
(1) may be necessary
for the licensee
to comply with the
regulations
and
(2) are reasonable
under the circumstances
to evaluate
the extent of radioactive
hazards that
may be present.
10 CFR 20.203 specifies
the posting, labeling
and control requirements
for radiation areas,
airborne radioactivity areas
and radioactive material.
Additional requirements
for control of high radiation areas
are
contained
in TS 6. 12. During tours of the plant, the inspector
reviewed
the licensee's
posting
and control of radiation areas,
high radiation
areas,
airborne
radioactivity areas,
contamination
areas,
radioactive
material
areas,
and the labeling of radioactive material.
requires
each
area in which licensed material is used
or stored
and which contains
any radioactive material
in an amount
exceeding
ten
(10) times the quantity of such material specified in
Appendix
C of this part to be posted with the sign or signs bearing the
radiation caution
symbol
and the words: "Caution, Radioactive
Materi al (s);"
h
0
The inspector
reviewed the plant procedures
which established
the
licensee's
radiological
survey
and monitoring program
and verified that
the procedures
were consistent with regulations,
TSs,
and good
practices.
The inspector
reviewed selected
records of radiation
and contamination
surveys
performed during the period of January-February,
1993,
and
discussed
the survey results with licensee
representatives.
During tours
of the plant, the inspector
observed
health physics technicians
performing radiation
and contamination. surveys.
a
~
Posting
and Labeling
10 CFR 20.203(f) requires,
in part,
each container of licensed
material containing greater
than Appendix
C quantities to bear
a
durable, clearly visible label identifying the radioactive
contents
and providing sufficient information to permit
individuals handling or using the containers,
or working in the
vicinity thereof, to take precautions
to avoid or minimize
exposures.
Licensee
Procedure
RCI-1, Rev. 31, detailed the licensee's
implementation of the aforementioned
regulatory requirements.
During tours of the Turbine Building, Containments,
and outside=
storage
areas,
the inspector
noted that radioactive material
areas
were appropriately posted,
however, during the tour of an outside
Long Term Radioactive Haterial Storage
Area,
two containers
containing radioactive material
were observed
by the inspector to
be unlabelled.
The labels
on two other containers of radioactive
material
were weathered
and
no longer legible to communicate
the
hazards of the material
contained.
The licensee
opened
the two
unlabelled containers
to identify, survey,
and characterize
the
material
and informed the inspector that the material
in each
container
was greater
than
10 CFR Part 2, Appendix
C quantities.
These observations
resulted, in a cited violation of
The inspector also observed
a portable
filter unit in Drywell number
3 that did not contain
a radioactive
material label.
Immediately upon identification by the inspector,
these
items were properly labeled
by the licensee.
No other
labeling problems
were identified.
These observations
resulted
in
a violation of 10 CFR 20.203(f).
VIO 50-259,
260,
269/93-'03-01:
Failure to follow 10 CFR 20.203(f)
for properly labeling containers.
One
NRC identified violation'and no deviations
were identified in
this area.
b.
Area Contamination
8
(
In 1992, the licensee
maintained
approximately 885,203
square feet
(ft') of floor space
as radiologically controlled.
As of
December
31,
1992,
the licensee
was tracking approximately
30,097 ft'frecoverable
space
as contaminated.
This represented
approximately 3.4 percent of the
RCA.
During plant tours,
the inspector
observed
three
vacuum cleaners
not in use in contaminated
areas
in which the inlet suction
ends
were not taped
over or bagged.
These
ends
are required to be taped
over or bagged
when not in use
by licensee
procedure
RCI-24,
Rev.
4.
The practice of leaving
vacuum cleaners
with open suction
inlets could result in unwarranted
spread of contamination to
personnel,
equipment
and 'areas.
This insp'ector finding was
determined to be 'a non-cited violation
(NCV) based
on the
licensee'.s
quick response
and low potential for the spread of
contamination.
No other instances
of similar practices
were
identified.
The inspector generally observed
good housekeeping
and contamination control practices.
NCV 50-259,
260,
269/93-03-02:
Failure to follow procedure
RCI-24,
Rev.
4 for control of vacuum cleaners.
One
NRC id'entified
NCV and
no deviations
were identified in this
area.
TS 6. 12. 1 required,
in part, that each
(HRA)
with radiation levels greater
than or equal'o
100 mrem/hr but
less
than or equal to 1000 mrem/hr
be barricaded
and conspicuously
posted
as
a HRA.
In addition,
any individual or group of
individuals permitted to enter
such
areas
are to be provided with
or accompanied
by a radiation monitoring device which continuously
indicates
the radiation
dose rate in the area or
a radiation
monitoring device which continuously integrates
the dose rate in
the area,
or an individual qualified in radiation protection
procedures
with a radiation
dose rate monitoring device.
Licensee
procedure
RCI-1,
Rev.
31 described
the licensee's
specific requirements for establishing,
posting,
and controlling
HRAs.
In addition,
Procedure
AP-504, Administrative Controls for
Locked
and Restricted
described
the
licensee's
specific requirements for entry into these
areas.
During tours of the Turbine Building, Containment Building, and
Unit 2/Unit 3 Drywells, the inspector
noted that all
HRAs and
locked
HRAs observed
were locked and/or posted,
as required.
During. the preplanned
chemical
decontamination
of Unit 2 Residual
Heat
Removal
System
and Recirculation
System, for U2C6-RFO, the
inspector interviewed
ALARA personnel
to discuss
actions for
controlling p'ersonnel
entries
and exits in drywell overhead
areas.
9
The licensee
had plans for upgrading
and downgrading
HRA postings
as
a result of transient radiation levels while personnel
may be
working in these
areas.
The licensee's
plan for personnel
stay
times
and posting of the affected
areas
was appropriate.
No violations or deviations
were identified.
d.
Radiation Detection
and Survey Instrumentation
During facility tours,
the inspector
noted that survey
instrumentation
and continuous air monitors in use within the
were operable
and displayed current calibration stickers.
The
inspector further noted
an adequate
number of survey instruments
were available for use.
,Background radiation levels at personnel
survey locations
were observed
to be within the licensee's
procedural limit.of 300 counts
per minute (cpm).
. No violations or-deviations
were identified.
e.
Independent
Surveys
During facility tours,
the inspector
independently verified
radiation and/or contamination levels in the Turbine Building,
Containment Building and Radioactive Material Storage
Areas.
Selected
hot spots
in the drywell were surveyed
and verified.
Radiation levels at eighteen
inches
from the hot spots
were below
the limits of 1000 mrem/hour
as specified in the licensee's
No violations or deviations
were identified.
I
Operational
and Administrative Controls
(83750)
a
~
Radiation
Work Permits
(RWPs)
The inspector
reviewed selected
routine
and special
associated
with the Turbine Building, Containment Building,
a'nd
Unit 2/Unit 3 Drywell activities for adequacy of the radiation
protection requirements
based
on work scope,
location,
and
conditions.
For the
RWPs reviewed,
the inspector noted that
. appropriate
pro'tective clothing, respiratory protection,
and
dosimetry were required.
In particular,
the inspector
reviewed'pecial
RWP 92-0061 related to reactor coolant
pump maintenance.
The inspector
reviewed licensee
procedures
RCI-9.0 Rev.
21
and
RCI-9. I Rev.
8 for the requirements,
preparation
and
administration of the
RWP process.
The inspector
observed
a
being prepared
by a
HP technician
and supervisor.
The inspector
observed briefings conducted for workers prior to
entering the
RCA.
The briefings included reviews of current
radiation surveys with emphasis
on high dose
areas
and low dose
10
waiting areas.
The interaction
between
RC and the workers
entering the
RCA was considered
adequate.
The inspector
found the licensee's
program for RWP implementation
to adequately
address
radiologi'cal protection concerns,
and to
provide for proper control measures.
No violations or deviations
were identified.
b.
Notices to Workers
10 CFR 19. 11(a)
and (b) require,
in part, that the licensee
post
cur'rent copies of 10 CFR Part 19, Part 20, the license,
license
conditions,
documents
incorporated
into the license,
license
amendments
and operating
procedures,
or that
a licensee
post
a
notice describing these
documents
and where they
be examined.
10 CFR 19. 11(d) requires that
a licensee
post form NRC-3, Notice
to Employees.
Sufficient copies of the required
forms are to be
-posted to permit licensee
workers to observe
them
on the way to or
from licensee activity locations.
During the inspection,
the inspector verified that the most recent
revision of NRC Form-3 was posted properly at the east
and west
entrance
portals permitting adequate
worker access'n
addition,
notices
were posted referencing
the location where the license,
procedures,
and supporting
documents
could
be reviewed.
No violations or deviations
were identified.
10.
Program for Haintaining Exposures
.As
Low As Reasonable
Achievable
(83729)
10 CFR 20. 1(c) states
that persons
engaged
in activities under licenses
issued
by the
NRC should
make every reasonable
effort to maintain
radiation exposures
as low as reasonably
achievable.
11
Regulatory
Guides 8.8 and 8. 10 provide informati.on relevant to attaining
goals
and objectives for planning
and operating light water reactors
and
provide general
philosophy acceptable
to the
NRC as
a necessary
basis
for a program of maintaining occupational
exposures
as low,as reasonably-
achievable
(ALARA).
The inspector
reviewed the following procedures
associated
with ALARA
program implementation:
RCI-2, Personnel
Honitoring,
Rev.
20, dated
February 4,
1993
RCI-15. 1, Haintaining Occupational
Radiation
Exposures
as low as
reasonably
Achievable
(ALARA), Rev.
7, dated
December
14,
1992
RCI-15.2,
Tempo ary Shielding,
Rev.
4, dated January
12,
1993
The inspector
reviewed
and discussed
with cognizant licensee
representatives,
ALARA program implementation
and initiatives for U2C6-
RFO and operations
during non-outage
periods.
The inspector
was
informed that the collective dose for 1992
was approximately
172 person-
rem (based
on TLD and pocket dosimeter data).
For U2C6-RFO,.'the licensee
had established
a goal of 455 person-rem,
'ased
on estimated
doses
from ALARA pre-job evaluations.
The most
significant work evolutions contributing to the dose estimate
included
Reactor
Water Cleanup Haintenance
(39.4 person-rem),
Recirculation
System
Chemical
Decontamination
(25.4 person-rem),
Recirculation
Pumpshaft
Replacement
(36.4 person-rem),
ISI (47.6 person-rem),
Installation of Decontamination
Taps
on Recirculation
System
(13.7 per'son-rem),
Installation
and
Removal of Hirror Insulation
(33.5 person-rem),
Refueling (15.6 person-rem)
and numerous
other
maintenance
evolutions of less
than 5.0 person-rem.
The inspector
reviewed the
ALARA pre-job evaluations-for the
Recirculation
Pumpshaft
r'eplacement.
In general,
the evaluations
considered
appropriate
dose reduction techniques.
Particular dose.
reduction
items of 'note included the use of temporary shielding,
worker
training,
and stay times based
on calculated
doses for pumpshaft
removal.
The inspector
noted that the
ALARA Committee
was required to review work
activities with a projected
dose of greater
than 5.0 person-rem.
A
corporate
review is required at 50 person-rem.
Discussions
with ALARA personnel
and workers involved in U2C6-RFO
activities revealed
several
dose reduction efforts.
These
included:
(1) increased
use of temporary shielding
based
on engineering
analyses;
.(2) increased
use of video cameras
(17 in containment);
(3) use of
remote
headsets
for various evolutions to improve communications
and
(4) implementation of a soft chemical
shutdown to enhance
crud removal
and lower dose during the outage.
i
0
12
Based
on the above,
the inspector
informed licensee
representatives
that
ALARA initiatives associated
with the current outage
were. considered
a
program strength.
No violations or deviations
were identified.
.11.
Exit Interview (83729)
At the conclusion of the inspect'ion
on February
12,
1993,
'an exit
meeting
was held with those licensee
representatives
indicated in
Paragraph
1 of this report.
The inspector
summarized
the scope
and
findings of the inspection
and indicated that
one violation (VIO) and
one non-cited violation
(NCV) was identified.
The licensee
did not
indicate
any of the information provided to the inspectors
during the
inspection
as proprietary in nature
and .no dissenting
comments
were
received
from the licensee.
The cited
and
non cited violations are
listed. below.
Item Number
Descri tion and Reference
50-259,
260,
269/93-03-01
50-259,
260) 269/93-03-02
VIO - Multiple examples of failure to
properly label radioactive material
containers
as required
by 10 CFR 20.'203(f)
(Paragraph
8.a).
NCV - Multiple examples'f failure to
follow licensee
procedure
RCI-24 requiring
taping or bagging
vacuum cleaner
hose
inlets
when not in use.
Licensee
corrective actions
completed prior to end
of onsite inspection
(Paragraph
8.b).