ML18152A410
| ML18152A410 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/01/1988 |
| From: | Hosey C, Lauer M, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A411 | List: |
| References | |
| 50-280-88-35, 50-281-88-35, NUDOCS 8811150462 | |
| Download: ML18152A410 (13) | |
See also: IR 05000280/1988035
Text
e
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W.
ATLANTA, GEORGIA 30323
MO\\/ O 9 i982
Report Nos.:
50-280/88-35 and 50-281/88-35
Licensee:
Virginia Electric and Power Company
Richmond, VA
23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.: DPR-32 and DPR-37
Inspection Conducted: 1 September 19-23, 1988
Inspectors: 0~"'-'\\ )'/Ji:;..J.-...-.,
F. N. Wrtght,
\\
,.** ,~::;v/
i
M. T . .{.auer
1
Approved
/1
. j
by: C/i/\\,,>j,*r ([f';,~ _J.;-V"'.
C. M. Hose~ Sectiofi Chief
and Safeguards
Division of Radiati~n Safety
SUMMARY
Date Signed
///(,fat"'
Date Signed
1, /1 /Jj
Date Signed
Scope:
This routine, unannounced inspection was conducted to review the
licensee
1 s radiatiqn protection program for controlling occupational exposures
during extended outages and licensee action on previous inspection findings.
Results:
Two violations were identified - (1) failure to control contaminated
material in accordance with licensee radiation control procedures and
(2) failure to use respiratory protection equipment in accordance with
respirator certification specifications .
- =:E: l 1 (>'?
050002SO
1.
Persons Contacted
Licensee Employees
- D. Benson, Station Manager
REPORT DETAILS
- R. Bilyeu, Corporate Licensing Engineer
W. Cook, Operations Supervisor, Health Physics
C. Foltz, ALARA Coordinator, Health Physics
- B. Garber, Technical Supervisor, Health Physics
- D. Hart, Auditing Supervisor, Quality Assurance
- H. Miller, Assistant Station Manager
- M. Olin, Corporate Health Physics
- S. Sarver, Superintendent, Health Physics
- F. Walking, Corporate Radiological Assessor
e
Other licensee employees contacted during this inspection included
technicians, deconers and administrative personnel .
Westinghouse Employees
R. Siskey, Site Coordinator
M. Dohse, Shift Supervisor, Eddy Current Crew
L. Herbert, Jumper, Eddy Current Crew
J. Horvath, Control Station Operator
P. Lopez, Platform Supervisor, Eddy Currerit Crew -
I. Seabold, Project Manager, Integrated Radiological Services
Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector
L. Nicholson, Resident Inspector
- Attended exit interview
2.
Occupational Exposure During Extend'ed Outages (83729)
a.
Unit 2 Refueling Outage
The licensee took the Unit 2 reactor off line September 10, 1988, for
a 81 day routine refueling outage.
Significant work planned for the
end of cycle 9 included the removal and replacement of four
recirculation spray heat exchangers, various non destructive testing,
extensive containment decontamination, eddy current testing on A and
C steam generators, motor inspection on reactor coolant pump
2-RC-P-18, residual heat removal (RHR) pump motor work, and control
rod guide mechanism cable upgrade.
The licensee planned extensive
2
decontamination of Unit 2 containment walls, floors, and components
during the first six days of the outage.
The licensee also removed
insulation on components requiring non-destructive testing and wiped
down exposed piping to lower contamination levels, reduce the need
for extra protective clothing and respirators, and to minimize the
spread of any hot particles.
Unit 1 was taken off line on September 14, 1988, to correct problems
associated with emergency diesel generators, repair a steam generator
tube leak and to replace a failed fuel assembly in its cycle 10 fuel.
The unscheduled shutdown of Unit 1 was impacting the 1 i censee
I s
outage planning and schedule for its Unit 2 refueling during the
inspection.
No violations or deviations were identified.
b.
Organization and Management Controls
The inspectors reviewed the licensee
1 s organization, staffing level
and lines of authority as they related to the outage radiation
protection programs.
The inspectors determined that the licensee had
established a new plant health physics organization.
The previous
health physics organization had two major work sections, technical
services and operations.
The section supervisors, senior staff
health physicist, and ALARA coordinator reported directly to the
Health Physics Superintendent.
The new organization includes four
major work sections that report directly to the Health Physics
Superintendent.
In addition to the technical services section and
operations section, the licensee
1 s health physics group now has a
radiological engineering section and a radwaste/decon section.
The
operations section is responsible for routine health physics shift
coverage and planning and scheduling.
The technical services section
responsibilities include dosimetry, bioassay, counting room and
environmental monitoring, respiratory protection, and instrumentation
programs.
The radwaste/decon section is responsible for facility and
equipment decon, contaminated laundry operations, radioactive waste
movement, and preparation of radioactive material for shipment. The
senior health physicist staff, and the ALARA Coordinator were
assigned to the new health physics supervisor of radiological
engineering.
The purpose of the reorganization was to increase the technical
ability of the plant
1 s health physics staff by adding the
radiological engineering section and to improve management efficiency
in the radwaste/decon section by combining two functions or work
groups, which work closely together, into one section.
In the past,
the licensee has experienced problems in filling professional health
physics positions.
The licensee temporarily assigned a licensed
operator * to supervise the techni ca 1 engineering sec ti on and two
contract health physicist were employed in the section until the
positions could be filled.
The licensee had also assigned a former
3
senior reactor operator shift supervisor to the Radwaste/Decon
Supervisor position temporarily until a permanent selection could be
made.
The licensee also had fourteen vacancies in the decon section
that were filled with contract support personnel.
No violations or deviations were identified.
c.
Training and Qualification
10 CFR 19.12 requires that all individuals working in or frequenting
- any portion of a restricted area be provided basic radiation
protection training.
'
The inspectors discussed, with licensee and contractor management
personnel, the licensee's program for the evaluation and training of
contract health physics (HP) technicians.
The inspectors also
reviewed Training Administrative Guideline (TAG) 4.2,
11Contract
Health Physics Technician Training,
11 Revision 1.
Resumes of contract technicians were reviewed by the licensee and
independent reference checks performed prior to acceptance of
individuals.
Once onsite, the acceptance of a contract HP technician
was contingent on the successful completion of a series of training
classes, practical factor (job performance measures) sessions, and
associated tests, including 10 CFR Part 20 topics, General Employee
Training (GET) and HP site-specific training.
The site-specific
training also included hot particle training. The inspectors reviewed
the site-specific and GET tests and determined that they included
appropriate topics at an adequate level of difficulty.
Job
Performance Measures were also reviewed.
Selected training records
of contractor HP technicians were reviewed to verify completion of
10 CFR 20 testing, GET, and site-specific training.
Technical Specification 6.1 requires that each member of the facility
staff meet or exceed the minimum qualifications of ANSI 3.1-1987 for
comparable positions. Section 4.5.3.2 of ANSI 3.1-1987 requires that
HP technicians have a minimum of two years experience one of which
shall include nuclear power plant experience.
The inspectors
reviewed selected qualification records of contractor HP technicians
and verified that all those reviewed met or exceeded the minimum
experience requirements.
No violations or deviations were identified.
d.
External Exposure Control and Personnel Dosimetry
(1)
10 CFR 20.202 requires each licensee to supply appropriate
personnel monitoring equipment to specific individuals and
requires the use of such equipment.
4
During the inspection, licensee representatives reported an
. unusual dosimetry response to the inspectors.
On the evening of
August 20, 1988, a contractor employee performed a steam
generator (S/G) jump on
11A
11 S/G in Unit 2 to install lamps and
nozzle dams.
The jump consisted of a forty second entry into
the hot leg side and a forty second entry into the cold leg
side.
Upon exiting the hot leg, the individual
1s self-reading
dosimeters (SRDs), located on his head, elbows, chest, groin,
and knees, were read by an HP technician on the S/G platform.
The technician stated that the highest reading, at that time,
was 180 millirem (mrem) from the head SRO.
Since this was well
below the licensee established control limit of 500 mrem for the
job, the SRDs were replaced and the individual was allowed to
enter the cold leg for forty seconds.
Survey data for the cold
leg indicated a maximum contact dose rate of 20 Roentgen/hour
(R/hr) and a general area dose rate of 15 R/hr.
Licensee
personnel stated that the job went as planned with no obvious
abnormal events.
Upon exiting the S/G platform, higher than
expected readings were observed on the individuals SRDs with the
chest reading 800 mrem and the groin area SRO reading 880 mrem.
The thermoluminescent dosimeters (TLDs) packaged with each SRO
and the TLD placed on each wrist were immediately processed.
The maximum dose recorded by the TLDs was 1590 mrem from the
chest TLD.
The TLD exposures were unusually high based on licensee survey
dose rates for the steam generator and the actual measured
exposure time.
Since the jumpers personal dosimetry
measurements were greater than anticipated the licensee halted
the steam generator work and initiated an investigation.
The
investigation included the testing of all TLDs and SRDs used by
the i ndi vi dua 1, multiple re-surveys of the S/G, and interviews
with the individual receiving the unexpected exposure, his
helper 1 ocated at the manway, and the two HP technicians
covering the job.
Licensee representatives stated that, based on the investigation
results, they believe the chest TLD result of 1590 mrem was an
anomalous reading possibly due to prior exposure remaining on
the TLD ribbon after the ribbon's last processing or high
activity surface contamination on the TLD casing.
Therefore,
the 1067 mrem from the right e 1 bow TLD was added to the
individual's whole body dose record.
A review of the
individual
1s NRC Form 4 indicated that he had zero dose for the
quarter prior to his arrival at the site.
Licensee
representatives stated that the individual had received
approximately 17 mrem, based on SRO results, since arriving
onsite.
The
inspectors
discussed,
with
licensee
representatives, the basis for
discounting the chest TLD
results.
5
The licensee's investigative efforts to identify the source of
the abnorma 11 y high exposure, 1590, mrem verses an expected
500 mrem exposure,
routinely observed for nozzle ~am
installation, were unsuccessful.
The inspectors reviewed survey
data, TLD/SRD calibration data, pre-job br1efing documentation,
HP technicians' qualifications, worker GET training, and RWP and
ALARA controls used.
The individual performing the S/G jump,
his helper, and their supervisor were also interviewed by the
inspector.
Inadequate or inappropriate actions by the licensee
which may have led to the elevated exposure where not identified.
During a telephone conversation on September 27, 1988, between
1 i censee representatives and NRC Region II management, the
licensee stated that S/G work would be restarted and delineated
actions which were being taken to preclude recurrence of higher
than norma 1 exposure for S/G work.
Licensee representatives
also stated that corrective actions were currently being planned
for those areas which may have caused the erroneous TLD
response.
No violations or deviations were identified.
(2)
10 CFR 20.203 specifies the posting, labeling and control
requirements for radiation areas, high radiation areas, airborne
radioactivity
areas
and
radioactive material
areas,
and radioactive material. Additional requirements for control of
high radiation areas are contained in Technical Specification 6.4.B.
During tours of the* plant, the inspectors reviewed the
licensee's posting and control of radiation areas, high
radiation areas, airborne radioactivity area, contaminated
areas, radioactive materials areas, and the labeling of
radioactive material.
The inspectors determined that the posting and controls for the
various radiological control areas was adequate to meet
regulatory and procedure requirements.
However, the inspectors
did identify a prob 1 em with the control of contaminated
equipment that is discussed in Paragraph 2.f. of this report.
No violations or deviation were identified.
e.
Internal Exposure Control
(1)
10 CFR 20.103(b) requires the licensee to use process or other
engeneeri ng controls to the extent practi cab 1 e, to 1 imit
concentrations of radioactive material in air to levels below
that specified in 10 CFR Part 20 5 Appendix B, Table I, Column 1
or limit concentrations, when averaged over the number of hours
in any week during which individuals are in the area, to less
than 25 percent(%) of the specified concentrations.
6
The use of process and engineering controls to limit airborne
radioactivity concentrations in the plant was discussed with
licensee representatives and the use of such controls was
observed during tours of the plant.
(2)
10 CFR 20.103(b) requires that when it*is impracticable to apply
process or engineering controls to limit concentrations of
radioactive material in air below 25% of the concentrations
specified in 10 CFR Part 20 Appendix B, Table 1, Column 1, other
precautionary measures should be used to maintain the intake of
radioactive material by any individual within seven consecutive
days as far below 40 maximum permissable concentration (MPC)
hours as is reasonably achievable.
When the use of respiratory protective equipment is used to
limit the inhalation of airborne radioactive material,
10 CFR 20.103(c) requires the licensee to use respiratory
protection equipment that is certified or had certification
extended by the National Institute for Occupational Safety and
Hea 1th Admi ni strati on/Mine Safety and Hea 1th Admi ni strati on
( N IOSH/MSHA) .
MSHA regulations in 30 CFR 11, Subchapter B, Section 11.2(a)
states that respirators, combinations of respirators, and gas
masks shall be approved for use in hazardous atmospheres where
they are maintained in an approved condition and are the same in
all aspects as those devices for which a certificate of approval
has been issued under this part.
During a tour of the licensee's Unit 2 containment on
September 21, 1988, the inspectors observed the 1 i censee
I s
pressure regulator settings on air distribution units for
supplied air respirators (hoods).
Supplied air distribution
system number seven which had been used on a steam generator A
jump the previous day indicated that a pressure setting of
13 psig was required to provide a respirator hood flow of 6 cubic
feet per minute (cfm) and 22 psig for a respirator hood flow of
8 cfm.
Air distribution system units numbers 3 and 5 required
10 psig for 6 cfm and 17 psig for 7 cfm hood flow.
Maximum
hose lengths were not specified on the air distribution units.
The licensee was using hose lengths up to 275 feet.
The inspectors reviewed the NIOSH/MSHA certification for the
licensee's supplied air hood (Approval No. TC-19C-140) and
verified that the range of pressure required to provide for a
flow of 6 cubic feet (ft 3 ) of air per minute to the licensee's
respirator hoods having a supplied air hose length of 25-50 feet
was 20-28 or 20-34 psig, depending on hose fitting used.
Hose
1 engths up to 275 feet required pressures in the range of
38-55 psig.
The pressure ranges were established for the
maximum hose length.
The inspectors also determined that the
e .
7
licensee was utilizing air supplied hoses with the supplied air
hoods that were not approved on the respirator certification.
Failure to operate the supplied air hoods within certified
pressure ranges for length of hose used and to use air supplied
hose not certified for the respirator was identified as an
apparent
violation
of
requirements
(50-280/88-35-01).
f.
Surveys, Monitoring and Control of Radioactive Material
( 1)
Surveys
10 CFR 20.20l(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 radiation hazards that
may be present.
The inspectors reviewed selected records of radiation and
contamination surveys performed during the inspection and
discussed the survey results with licensee representatives. The
inspectors performed independent radiation surveys in the
auxiliary building, radioactive material storage areas, and
Unit 2 containment.
No violations or deviations were identified.
(2)
Control of Contaminated Material
NRC Inspection Report Nos. 50-280/87-35 and 281/87-35 for
inspections conducted in December 1987, identified a violation of
Licensee Procedure HP-2.3, Contamination Equipment and Component
Control, dated February 2, 1987, which specified the requirements
for moving and storing radioactive material and contaminated
equipment.
During the December 1987 inspection, a tour of the
lower elevation of the licensee's auxiliary building was
performed and the inspectors noted that an unlabeled box
contained contaminated material and that the radiation protection
staff was unaware that the gang box was utilized to store
contaminated material.
The
inspectors
reviewed Licensee
Procedure HP-7.1.10,
Radioactive Contra l Program, dated August 29, 1988.
Licensee
Procedure HP-7.1.10 replaced HP-2.3.
The procedure described
the licensee's radioactive material control program including
criteria and requirements for identification, movement and
accountability for radioactive material generated on site or
received as licensed material.
Section 4.3.4 of the procedure
requires that radioactive material be appropriately stored in
such a way that control over the material is maintained and
access is limited only to authorized individuals.
(3)
8
While touring the basement of the auxiliary building on
September 19, 1988, the inspectors noticed a gang box that was
labeled Radioactive Material.
The inspectors opened the box
which was unlocked and noted that the box contained yellow poly
bags of tools and equipment.
Some of the bags were sealed with
tape and labeled radioactive material and had survey results
written on the bag a 1 ong with the date of survey and the
surveyors initials.
However, some of the bags were not sealed
and others contained material that did not have survey results
marked on the plastic bag containers. Through discussions with
1 i censee representatives, the inspectors determined that the
licensee did not have control of contaminated tools and equipment
that were being placed in and removed from the radioactive
material storage box as required by licensee procedures.
The
inspectors requested that the gang box contents be surveyed.
The
survey results indicated that the box was contaminated up to
14,000 disintegrations per minute (dpm) per 100 square
centimeters (cm 2 ).
Items in open bags had smearable
contamination up to 12,000 dpm/cm 2 and dose rates up to 6 mrem
per hour.
Failure to comply with 1 i censee procedures for
controlling contaminated material was identified as an apparent
violation of Technical Specification 6.4.D (50-280/88-35-02).
The licensee's response to the Notice of Violation contained in
Inspection Report No. 50-280/87-35 included labeling the box as
a radioactive material storage area and committing to perform
periodic inspections of radiological material storage areas to
ensure that the areas and containers were properly controlled.
The
specific corrective action identified in the licensee's response
appeared not to be effective in that the same box was involved
in the apparent violation described in this report.
The
licensee did initiate corrective action during the inspection by
placing health physics controlled locks on all radioactive
storage lockers.
Lost Strontium 90 Source
During the inspection the inspectors were notified of a missing
radioactive source that had been identified during a routine
inventory and radioactive material 1 eak check for 1 i censed
sources.
The 1 ost source was documented in a Surry Power
Station Deviation Report dated September 16, 1988.
The missing
source was a small button, 0.5 microcurie (uCi), Strontium
(Sr-90) source used in routine response checks of various
process radiation monitors.
The inspectors determined that the
1 i censee had attempted to find the source and was unab 1 e to
determine where the source could have been lost. The licensee
concluded that the source had last been checked out and returned
in March 1988.
The source was normally kept in a small lead
shield with a Cs-137 source which was al so used as a check
source.
The source 1 og book showed the Cs-137 source was
e
9
checked out several times since the Sr-90 source was last
documented to be in the radioactive source locker.
The licensee
interviewed each of the individuals that had checked out the
Cs-137 source and the investigations were inconclusive.
The
1 icensee documented in the deviation report that the Sr-90
source was probably discarded as radioactive waste.
The
licensee also concluded that the lost source did not present a
substantial health hazard to persons in unrestricted areas and
was therefore not reportable in accordance with the requirements
specified in 10 CFR 20. 402.
The inspectors and a 1 i censee
representative checked the response of the licensee's personnel
contamination monitoring instrumentation to a O .09 uCi Sr-90
source.
The lesser activity Sr-90 source alarmed the whole body
friskers at the RCA exit point, any standard portable
contamination monitor, and the portal monitors located at the
guard house exit point.
The checks indicated that it was
unlikely that an individual removed the source from the plant
through the normal personnel exit points.
No violations or deviations were identified.
g.
Facility Statistics
(1)
Personnel Exposure
The annual collective radiation dose through September 20, 1988,
was 90.674 person-rem based on TLD and SRO data.
Licensee
representatives stated that no individuals had exceeded
10 MPC-hours in ten consecutive days or 40 MPC-hours in a
quarter.
(2)
The licensee had established a collective radiation dose goal for
1988 of 1468.470 person-rem.
As of September 18, 1988, the
plant was at 102% of the estimated goal for that point in the
year.
For the most recent Unit 1 outage, in spring of 1988, a
collective dose goal of 629.600 person-rem was established.
Actual dose total for the outage was 705.747 person-rem.
For
the Unit 1 outage, 213 jobs required ALARA pre-planning.
Of
those jobs, 54 exceeded the estimated collective dose and 159
were below the estimated collective dose.
The current Unit 2
outage co 11 ecti ve dose goa 1 was 566 .160 person-rem.
As of
September 18, 1988, 37.320 person-rem had been expended for the
outage.
(3)
Contamination Control
As of September 1, 1988, 24,075 square feet (ft 2 ) within the
RCA,
excluding containment buildings, was controlled as
10
contaminated area.
This was approximately 25% of the total
92,000 ft 2 within the RCA.
In 1987, 493 personnel contaminations (174 skin and 319 clothing)
were observed at the plant.
As of September 21, 1988,
397 personne 1 contaminations had occurred.
The 1 i censee has
established a goal of having fewer than 440 personnel
contaminated in 1988.
(4)
Solid Waste
Licensee representatives stated that 24 waste shipment (21 Class
A, 1 Class B, and 2 Class C) had been shipped to waste
collectors or burial sites through September 21, 1988.
This
included 1145.5 ft3 (163.1 curies) of processed resins and
14,096.3 ft 3 (9.4 curies) of dry active waste.
As of
September 21, 1988, 1,470 ft 3 of dry active waste and 112 ft3 of
liquid process filters was being stored on site awaiting
shipment.
No violations or deviations were identified.
3.
Action on Previous Inspection Findings {92701)
a.
b.
(Closed)
Inspector Followup Item (IFI) 50-280/87-24-01 and
50-281/87-24-01:
Review the licensee's controlling document that
described the licensee's personnel dosimetry program.
The inspectors
reviewed 1 i censee procedure HP-3 .1.1 Externa 1 Exposure Centro 1
Program revision dated July 27, 1988, and determined that it
adequately described and made reference to documents that describe the
licensee's personnel dosimetry program.
(Closed) Unresolved Item 50-280/87-35-02 and 50-281/87-35-02:
The
Quality Assurance (QA) evaluation and actions for a potential
10 CFR 20 violation for issuing respirators to persons not meeting
the qualification and training requirements was reviewed during the
inspection.
During a previous inspection, the inspectors determined
that a licensee QA Audit S-87-19 conducted in July 1987, identified
severa 1 examples of persons issued res pi raters when training and
qualification records could not be located.
The Quality Assurance
Audit listed the potential 10 CFR 20 violations as
11 concerns
11 in its
report.
The records for all persons listed in the report were found
during an NRC inspection conducted in December, 1987.
During the
previous inspection, the inspectors were unable to determine if
Quality Assurance requirements had been satisfactory met.
The inspectors determined that the licensee was in compliance with
the existing quality assurance program procedures that were in place
during the previous NRC inspection. The inspectors also determined
that the QA "concerns" had been placed in a station corrective action
program after the Quality Assurance Report S-87-19 was issued.
--
e
11
However, the 1 i censee' s qua 1 ity assurance organization recognized
that the failure to include potential regulatory requirement
violations in its quality assurance corrective action program to
ensure timely corrective action was a program weakness.
The
inspectors determined that the Quality Assurance Program Procedure,
Quality Assurance Instruction Nuclear Audits-18, in place during the
licensee's audit S-87-19, had been revised in July 1988. The revised
procedure requires identified program deficiencies and
or
nonconformances to be identified and documented as
11fi nd i ngs
II that
would be officially tracked in the quality assurance corrective
action program to ensure timely completion.
c.
(Closed) IFI 50-280/87-35-03 and 50-281/87-35-03 Review criteria or
guidelines that could be used to initiate an investigation of
abnorma 1 TLD results.
The inspectors reviewed licensee procedure
Personnel Dosimetry - Dosimetry Issuance and Dose Determination,
revision dated July 27, 1988, and verified that the 1 i censee had
established criteria to investigate unusual dosimetry results.
d.
(Closed) IFI 50-280/87-35-04 and 50-281/87-35-04:
Review procedures
to test off-scale, dropped and found SRD's prior to re-issuance. The
inspectors verified that the licensee had changed dosimetry
procedures to remove from service a 11 off-sea 1 e dosimeters and
require a drift test and response check prior to their reissuance.
e.
(Closed) IFI 50-280/87-35-05 and 50-281/87-35-05:
Review the
licensee's controls for ensuring that Health Physics Procedures at
specific work locations were controlled copies.
The inspectors
verified that the licensee had implemented a document control system
for ensuring controlled copies of Health Physics Procedures were
maintained
by
reviewing the licensee's issue and receipt
documentation for procedure revisions.
However, the process was not
yet proceduralized.
The licensee plans to have the document control
procedure issued by the end of 1988.
4.
Exit Interview
The inspection scope and results were summarized on September 23, 1988,
with those persons indicated in Paragraph 1 above.
The inspectors
described the areas inspected and discussed in detail the inspection
findings listed below.
The licensee did not identify as proprietary any
of the material provided to or reviewed by the inspectors during this
inspection.
The 1 i censee took exception to the discussed violation concerning the
control of contaminated materi a-1.
Licensee representatives commented that
the violation was similar to a violation already issued in Inspection
Report No.- 50-280/87-35 and that if the initial response provided by the
licensee for that violation was not adequate the NRC should have notified
the 1 icensee that the proposed corrective action was inadequate.
The
inspector acknowledged the licensee's comments.
e
12
The inspectors requested licensee management to notify the Region II staff
Tuesday September 27, 1988, on the licensee's progress in its evaluation
of the abnormal personnel dosimetry results resulting from a steam
generator jump made during the inspection (Paragraph 2(d)). The licensee
agreed to the inspectors request.
Item Number
50-280/88-35-01
50-280/88-35-02
Description and Reference
Violation - Failure to operate respiratory
protection equipment in accordance with
NIOSH/MSHA
Certification
requirements
(Paragraph 2.e.).
Violation - Failure to control contaminated
material
in accordance with licensee
procedures (Paragraph 2.f.).