ML18152A466

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Insp Repts 50-280/95-21 & 50-281/95-21 on 951002-06.Non- Cited Violation Noted.Major Areas Inspected:Occupational Radiation Exposure,Organzation & Mgt Control,Audits & Appraisals & Internal Exposure Control
ML18152A466
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/01/1995
From: Forbes D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152A467 List:
References
50-280-95-21, 50-281-95-21, NUDOCS 9511140307
Download: ML18152A466 (12)


See also: IR 05000280/1995021

Text

Report Nos. :

UNITED STATES .

NUCLEAR REGULATORY COMMISSION

  • REGION II

101 MARIETTA STREET, N.W., SUITE 2900

ATLANTA, GEORGIA 30323-0199

50-280/95-21 and 50-281/95-21

Licensee:

Virginia Electric and Power Company

Glen Allen, VA

23060

Docket Nos.:

50-280 and 50-281

License Nos.:

DPR-32 and DPR-37

Facility Name:

Surry Power Station Units 1 and 2

Inspection Conducted:

October 2-6, 1995

Inspector: ~ /3 ~

Approved

D. B. Forbes

by: ~ntt~ /< &d~h~0

T. Decker, Acting Chief

Plant Support Branch

Division of Reactor Safety

SUMMARY

Scope:

11/1 ~?5

D'ate igned

Date 'Signed

This routine, announced inspection was conducted in the area of occupational

radiation exposure.

Specific elements of the program examined included:

organization and management control; audits and appraisals; external exposure

control; internal exposure control; surveys, monitoring, and control of

radioactive material; and maintaining occupational radiation exposure as low.

as reasonably achievable (ALARA).

Results:

Based on observations, interviews with licensee management, superv1s1on,

personnel from station departments, and records reviewed, the inspector found

the licensee's program for occupational radiation safety was functioning

adequately to protect the health and safety of the radiation workers and the

general public.

Radiation Protection staffing levels appeared adequate to

support on-going activities and RP personnel interviewed were well trained.

The licensee's self-assessment program was conducted in accordance with

requirements.

The licensee continued to implement effectiv~ internal and

external exposure control programs with all exposures less than 10 CFR Part 20

limits.

However, one non-cited violation was identified as failure to wear

dosimetry as required by radiation protection procedure (Paragraph 5.).

9511140307 951101

PDR

ADOCK 05000280

G

PDR

Enclosure

1.

2.

REPORT DETAILS

Persons Contacted

  • M.
  • D.
  • M.
  • B.
  • D.
  • D.
  • B.
  • H.
  • J.

D.

  • G.
  • F.

D.

M.

  • J.
  • S.
  • R.
  • B.
  • E.
  • D.
  • T.

T.

  • J.

E.

Biron, Supervisor, Radiation Protection

Boone, Quality Assurance

Bowling, Manager, Nuclear Licensing

Bryant, Licensing

Christian, Station Manager

Erickson, Superintendent, Radiation Protection

Garber, Licensing

McCallum, Nuclear Training

McCarthy, Assistant Station Manager

Miller, Supervisor, Radiation Protection

Miller, Corporate Licensing

McConnell, Materials

Noce, Radiation Protection

Olin, Supervisor, Radiation Protection

Price, Assistant Station Manager

Sarver, Operations

Saunders, Vice President, Nuclear Operations

Shriver, Assistant Station Manager

Smith; Quality Assurance

Sommers, Licensing

Sowers, Engineering

Steed, ALARA Coordinator, Radiation Protection*

Steinert, Quality Assurance

Topping, Radiation Protection

Other licensee employees contacted during this inspection included:

craftsmen, engineers, operators, contract personnel, and administrative

personnel.

Nuclear Regulatory Commission

  • M. Branch, Senior Resident Inspector

D. Kern, Resident Inspector

K. Poertner, Resident Inspector

  • A. Belisle, Branch Chief, Division of Reactor Projects~ RII
  • Attended Exit Interview conducted on October 6, 1995.

Organization and Management Controls (83750)

The inspector reviewed the staffing of the radiation protection (RP)

organization as related to lines of authority and noted no changes since

the previous inspection conducted June 5-9, 1995, and documented in NRC

Inspection Report (IR) 50-280/95-11 and 50-281/95-11.

At the time of the

inspection, Unit 1 was undergoing a 37-day refueling outage and Unit 2 was

operating.

Enclosure

2

Based on a review of this area, the inspector noted that at the time of

the inspection, the licensee maintained an adequate level of staffing to

support ongoing operations and all RP personnel interviewed were well

trained to perform their assigned duties.

No violations or deviations were identified.

3. Audits and Appraisals (83750)

10 CFR 20.llOl(c) requires that the licensee periodi~ally (at least

annually) review the radiation protection program content and

implementation.

The inspector noted that since the last inspection in this area conducted

June 5-9, 1995, and documented in IR 50-280/95-11 and 50-281/95-11, an

audit had been conducted by the licensee's Quality Assurance Organization

entitled, "Radiological Protection Program Audit," 95-06, dated

September 5-9, 1994.

The audit assessed the following Radiological

Protection Program attributes:

Internal Exposure Control

External Exposure Control

Radiation Detection Instrumentation Program

Transportation of Radioactive Material and Waste

Training and Qualifications

Based on the audit results, the licensee concluded that regulatory

requirements were effectively being implemented.

The licensee audit

reported that this determination was based on interviews, observations of

work being performed, reviews of implementing documents, and applicable .

corrective actions implemented since the completion of the previous audits

in these areas.

However, some areas of weakness were identified in the

area of procedural compliance.

The licensee determined duri~g a follow-up

of previously opened items, that an RP audit finding {S94-07-0l), which

was issued because some workers did not understand survey data and

Radiation Work Permit (RWP) requirements prior to entering the

Radiological Control Area {RCA), would remain open.

The licensee did note

that worker awareness had improved and follow-up corrective actions had

. been performed; however, this item was not closed pending* further

evaluation by the licensee during the Unit 1 outage in September of 1995.

The inspector determined that the licensee was identifying areas of

weakness or non-compliance for improvement and that the audits being

performed were meeting the licensee's requirements for performing annual

audits in .the area of RP.

The inspector also reviewed the licensee's internal program for self-

identification of weaknesses as it related to the RP program other than

those identified during the annual audit and the appropriateness of

corrective actions taken.

The program included Station Deviation Reports

(SDRs) and Radiation Awareness Reports (RARs).

Both systems were utilized

by the licensee to document, investigate, and track items of concern.

The

Enclosure

3

SDR system was a plant-wide system for identification of concerns, while

the RAR was a lower-tier system utilized mainly by the RP organization to

identify a variety of minor concerns.

The inspector reviewed various RARs initiated in 1995 and noted that the

licensee was identifying substantive items of concern and was following

through with appropriate corrective actions to prevent recurrence.

In general, the audits reviewed were determined to be well planned and met

requirements for conducting audits in the area of radiation protection, as

required by the licensee's appraisal process.

4.

Internal Exposure Controls (83750)

10 CFR 20.1703(a)(3) permits the licensee to maintain and to implement a

respiratory protection program that includes, at a minimum:

air sampling

sufficient to identify the hazard; surveys and bioassay to evaluate the

actual intakes; testing of respirators immediately prior to each use;

written procedures regarding selection, fitting, issuance, maintenance and

testing of respirators; written pr9cedures regarding supervision and

training of personnel and monitoring, including air sampling and

bi. oassays; record keeping; and determination by a physician prior to the*

use of respirators, that the individual user is physically able to use

respiratory protective equipment .

The inspector reviewed portions of the licensee's incorporation of

10 FR 20.1703(a)(3) during this inspection tQ include: air sampling,

bioassay results, and records for six employees who had recently worn

respiratory protection equipment.

The inspector verified that for the

records reviewed, each worker had successfully completed respiratory

protection training, was medically qualified, and was fit~tested for the*.

specific respirator type used in accordance with the licensee procedural

requirements.

The inspector also reviewed bioassay results for

approximately 120 individuals who had worked in the RCA and reviewed air

sample results for three specific jobs where airborne radioactivity was

monitored. At the time of the inspection, the licensee was tracking

approximately 124 positive intakes for 1995, of which, all were less than

10 percent of an annual Allowable Limit of Intake (ALI).

Many of the

positive intakes resulted in no internal dose after evalu~tions were

performed.

Individual intakes for 1995 were reviewed with cognizant

licensee personnel to verify the methodology for assigning a Committed

Effective Dose Equivalent (CEDE).

The maximum CEDE for a single

individual was approximately 50 millirem which was a small percentage of

the regulatory limits of 5,000 millirem per year.

The inspector discussed with the licensee, respirator reduction efforts to

enhance ALARA concepts with respect to worker training and use of face

shields, decontamination efforts to minimize the potentia] for airborne .

radioactivity, and various engineering controls to include work site and

building ventilation* systems. Approximately six Radiation Work Permits

were reviewed by the inspector to determine if engineering controls were

being applied during the Unit 1 outage as required by licensee procedure

for jobs where surveys indicated that high levels of contamination existed

Enclosure

4

and respiratory protection was not worn.

The inspector noted that

engineering controls had been included on the Radiation Work Permits

(RWPs) reviewed.

Based on the review conducted in this area, the inspector*determined that

the licensee had controlled internal exposures*below regulatory limits.

No violations or deviations were identified.

5.

External Exposure Controls (83750)

10 CFR 20.1101, "Radiation Protection Programs", (a) states "Each licensee

shall develop, document, and implement a radiation protection program

commensurate with the scope and extent of licensed activities and

sufficient to ensure compliance with the provisions of this part."

Technical Specification 6.48 requires that procedures for personnel

radiation protection shall be prepared consistent with the requirements of

10 CFR Part 20 and shall be approved, maintained, and adhered to for all

operations involving radiation exposure.

10 CFR 20.150l(c)(l) and (2) requires that dosimeters used to comply with

10 CFR 20.1201 shall be processed and evaluated by a processor accredited

by the National Voluntary Laboratory Accreditation Program (NVLAP) for the

types of radiation being monitored .

10 CFR 20.1502(a) requires each licensee to monitor occupational exposure

to radiation and supply and require the use of individual monitoring

devices by:

(1) Adults likely to receive, in one year from sources external to the

body, a dose in excess of 10 percent of the limits in

10 CFR 20.120l(a);

(2) Minors and declared pregnant women likely to receive, in one year for

sources external to the body, a dose in excess of 10 percent of any of

the applicable limits of 10 CFR 20.1207 or 10 CFR 20.1208; and

(3) Individuals entering a high or very high radiation area.

10 CFR 20.1201 (a) requires each licensee to control the occupati-0nal

dose to individual adults, except for planned special exposures less

than 20.1206, to the following dose limits:

(1)

An annual limit, which is the more limiting of:

(i) The total effective dose equivalent (TEDE) being equal to

5 rems; or

(ii) The sum of the deep-dose equivalent and the committed dose

equivalent (CDE) to any individual organ or tissue other

than the lens of the eye being equal* to 50 rems;

Enclosure

5

(2)

The annual limi.ts to the lens of the eye, to the skin, and to the

extremities, which are:

(i)

An eye dose equivalent of 15 rems; and

(ii) A shallow-dose equivalent (SOE) of 50 rems to the skin or to

any extremity.

The inspector selectively reviewed the licensee's dosimetry program to

ensure that the licensee was meeting the monitoring requirements of

revised 10 CFR Part 20.

The inspector verified that the licensee was

NVLAP accredited based on the licensee maintaining a current NVLAP

certificate.

Licensee representatives stated, and the inspector confirmed, that all

TEDE, COE, and SDE exposures assigned since the previous NRC inspection of

this area were within 10 CFR Part 20 limits.

During tours of the RCA, the inspect.or observed personnel wearing

dosimetry devices appropriately as required by RWPs.

However, between

September 17-29, 1995, the licensee identified four individuals who had

entered the RCA not wearing dosimetry as required by the RWPs for the

areas entered.

The following multiple examples of failure to adhere to

radiation control procedures were identified:

On September 17, 1995, a worker.entered the Unit 1 Reactor Containment

Building to work on the "A" Steam Generator work platform.

Upon

exiting the area, the worker determined that he was not wearing

extremity thermoluminescent dosimetry (TLD) on the left and right

wrist as required by the RWP.

The worker immediately notified RP

personnel that he had not worn the required dosimetry.

Based on

records reviewed, the inspector determined that the l~censee had

appropriately assigned exposure to the individual for the left and

right wrist after the licensee performed an investigation of the

event.

On September 23, 1995, four workers entered the Unit 1 Reactor

Containment Building to perform the final inspection on the "A" Steam

Generator and install the hot and cold leg diaphragm.

Radiation

Protection personnel determined that teledosimetry was not being

detected at the telemetric system monitoring station for two of the *

workers in the work area.

An RP supervisor requested the two workers

to come down from the work platform to determine why the teledosimetry

was not registering on the telemetric system.

At this time RP

determined that the workers were not wearing dosimetry required by the

RWP.

Based on records reviewed, the inspector determined that the

licensee investigated this event and assigned exposure to the

individuals.

On September 29, 1995, a work~r ~ntered the Unit 1 Re~ctor Containmerit

Building to perform work in the Seal Table Room.

Upon exiting the

work area, the worker determined that he did not have the required

dosimetry and informed RP that he may have lost it. Further

Enclosure

' *

6

investigation determined that the worker had not carried the required

Digital Alarming Dosimeter (DAD) as required by RWP into the work

area.

Based on records review, the inspector determined that the

licensee investigated this event and assigned exposure to the.

individual properly.

The licensee investigated each event and corrective action was taken to

brief all plant workers on the importance of *complying with RWP

requirements.

Specific wofk groups were excluded from working in the RCA

until corrective action could be implemented.

Surry requested that an

independent assessment of the events be performed by the Virginia Electric

Power Company corporate office. Surry assigned an RP technician to the *

RCA entrance to monitor each individual entering the RCA to ensure that

personnel understood their RWP requirements.

The inspector reviewed

licensee procedures which provided guidance to personnel preparing,

briefing, and controlling work following radiation work permit

requirements and observed RP personnel conducting radiological pre-job

briefings.

The inspector reviewed selected RWPs and discussed the RWP

system with licensee representatives.

In addition, the inspector observed

personnel being briefed prior to e_nteri ng the RCA.

The RP group conduct~d

adequate briefings for personnel entering an area for the first time on a

specific RWP.

Personnel were also required to notify RP prior to entry

into the RCA.

The inspector noted in Paragraph 3, above, that the licensee had

previously identified problems with workers not complying with RWP

requirements.

The inspector informed the licensee that failure of workers

to follow RWP requirements for wearing TLD badges and other assigned

dosimetry was_a violation of licensee radiation procedure, VPAP-2101,

Radiation Protection Progfam, Paragraph 6.6.1, Revision 7, dated

August 10, 1995, which stated that workers shall wear assigned TLD badges-

and dosimetry.

Based on the licensee's efforts in ideDtifying and

correcting the violation, which meet the criteria specified in section

VII.B of the Enforcement Policy, the violation will not be cited, in

accordance with the Enforcement Policy.

External exposure controls for four other outage evolutions were .reviewed

by the inspector to assess potential exposures to workers, and to review

the licensee followup actions.

The events reviewed were as follows:

On September 14, 1995, while shutdown for refueling, the reactor

vessel water level (RVWL) standpipe indication for Surry Unit 1

  • Reactor Vessel experienced an unexpected drop from approximately 18

feet to 13.3 feet which resulted in a temporary loss of shielding to

workers in the immediate vicinity of the reactor head.

The workers

were performing head detensioning. Additional operational details of

this event are addressed in NRC IR 50-280/95-20 and 50-281/95-20.

The

inspector reviewed the licensee's actions to assess any additional

potential exposures received by the workers as a result of the loss in

shielding.

Based on a review of area radiation monitors, routine

radiation surveys for the work area, and histogram readings from the

DADs worn by the workers, no increase in dose *rates during the loss of

shielding could be determined.

The histograms indicated dose rates_

Enclosure

,,

  • '\\ *

7

increasing and decreasing during this time period as workers moved

around in the area to perform work.

The inspector conclude*d that the

licensee's actions to assess the exposures was adequate. Personnel in

the work area were being monitored with DADS and TLDs.

On September 13, at approximately 1830 hours0.0212 days <br />0.508 hours <br />0.00303 weeks <br />6.96315e-4 months <br />, the PRT was vented to

the containment without the use of the required procedure.

The Surry

NRC Resident inspectors noted, through interviews, and review of logs

and completed procedures, that section 5.5 of l-OP-RC-011, Pressurizer

Relief Tank (PRT) Operations, revision 1, established the method for

venting the PRT to the vent system.

The PRT was vented *by opening

l-RC-ICV-5025 which established a vent path from the PRT through

pressure transmitter PT-1472 to containment. A review of the release

permits for that day showed that there was no Gaseous Group Release

Permit for venting the PRT to the vent system as required by step

5.5.4.

Interviews determined that there was no poly hose connected

from the vent tap, l-RC-ICV-5025, to the nearest Containment Purge

Exhaust as required by step 5.5.5. Additional operational details of

this event are addressed in NRC IR 50-280/95-20 and 50-281/95-20.

The

inspector reviewed the radiological consequences of this event and

determined that Xenon-133 gas*had been released to the Unit 1 reactor

containment and workers in the area had been assigned an SDE based on

airborne radioactivity airborne results.

Maximum SDE assigned for

this event was approximately 5 millirem compared to an annual

regulatory limit of 50,000 millirem SDE .

On September 16, 1995, as a result of lifting the reactor head, the

licensee determined that Xenon-133 gas was present in the Unit 1

reactor containment at a concentration of approximately 3.35E-4

microcuries per milliliter. The inspector reviewed licensee air

sample results and licensee assigned SDE exposures for workers in the

affected areas.

The maximum SDE assigned was approximately 147

millirem compared to an annual regulatory limit of 50,000 millirem

SDE.

On October 5, 1995, a worker walked onto the reactor upper internals

to retrieve a screw that had possibly been seen lying on the upper

internals.

The contract worker was also to maintain communications

with the crane operator lowering the reactor head intb pl~ce. Durin~

this evolution a jack stand was bent which ~topped the evolution.

The

inspector reviewed this event based on the worker entering a dose rate

field of approximately 5 Rem. per hour general area and 15 Rem. per

hour contact with the jack stands. A review of this event determined

that the worker's whole body was monitored with TLDs and multi-badge

teledosimetry which was being constantly monitored by RP personnel..

An RP technician was also stationed in the reactor cavity to provide

constant radiological work coverage.

The inspector cpncluded that the

licensee closely monitored worker external exposure during this event.

Based on observations, records review, and interviews with plant workers,

the inspector concluded the licensee was effectively controlling external

radi.ation exposure consistent with the requirements of 10 CFR Part 20

Enclosure

'\\ *

8

limits. However, examples of workers failure to follow procedure

requirements for wearing dosimetry was identified as a non-cited

violation.

One non-cited violation was identified

6.

Control of Radioactive Material and Contamination, Surveys, and Monitoring_

(83750)

10 CFR 20.150l(a) 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 radiological hazards that may be present ..

a.

Posting and Labeling

. b.

10 CFR 20.1904(a) 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.

During tours of the Auxiliary Building, and various radioactive

material storage locations, the inspector independently verified that

selected containers of radioactive material were labeled consistent

with regulatory requirements.

The inspector interviewed selected

workers to ensure personnel were properly trained to understand

posting and labeling requirements.

Discussions were conducted with selected cognizant individuals in RP

regarding their responsibilities as described in the licensee

procedural requirements.

Based on observations during the inspectioQ,

discussions with cognizant licensee personnel, and records reviewed,

the inspector.determined that cognizant personnel were knowledgeable

of the licensee's procedural requirements for controlling and

surveying potentially radioactive material.

Based on a review of this area, the inspector determined that the

licensee was posting areas and labeling radioactive material

consistent with regulatory requi.rements ..

No violations or deviations were identified.

Personnel and Area Contamination

The inspector reviewed selected Personnel Contamination Events (PCEs)

and discussed contamination control practices for selected outage

operations.

During plant tours, the inspector observed adequate

housekeeping and contamination control practices. The inspector

observed handling, packaging, and surveying of contam1nated equipment

for movement and judged the work evaluations s*atisfactory.

At the

time of the inspection, the licensee was averaging approximately 2150

Enclosure

'I *

c.

d.

. 9

ft 2 (1.57 percent) of the RCA as recoverable contaminated space.

During non outage periods~ the licensee was maintained less than one

percent (less than 200 ft) of the total RCA as recoverable

contaminated space.

The licensee maintained approximately 1.8 percent

of the total RCA as recoverable contaminated space during the last

Refueling Outage of Unit 2.

At the time of the inspection, the licensee had incurred approximately

170 PCEs in 1995, of which 127 PCEs occurred during the Unit 2 ten

year In Service In~pection (ISi) refueling outage.

At the time of the

inspection, 34 PCEs had occurred during the current Unit 1 outage and

the remainder of the PCEs for the year had occurred during non-outage

periods.

Based on a review of records, facility tours and discussions with

licensee personnel, the inspector determined that the licensee was

effectively implementing contamination control practices.

No violations or deviations were identified.

High Radiation Areas

TS 6.12.1 required, in part, that each High Radiation-Area (HRA), with

radiation levels greater than or equal to 100 millirem/hour but less

than or equal to 1000 millirem/hour, be barricaded and conspicuously

posted as an 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.

During tours of the Auxiliary Building, *the inspector noted that all

HRAs and locked HRAs inspected were locked and/or posted, as required.

Based on a review of procedures, facility tours, and interviews, the

inspector determined that the licensee's implemented program for HRA

controls met the requirements of 10 CFR Part 20 and the licensee's TS

requirements.

No violations or deviations were identified.

Radiation Detection and Survey Instrumentation

The inspector reviewed the plant procedure which established the

licensee's radiological survey and monitoring program and verified

that the procedures were consistent with regulations, and good RP

practices. During facility tours, the inspector observed RP personnel

operating survey instruments during the performance of radiation and

contamination surveys.

The inspector noted that survey

instrumentation and continuous air monitors in use within the RCA were

Enclosure

10

operable and displayed current calibration stickers. 'The inspector

further noted that an adequate number of survey instruments were

available for use.

During the inspection, the inspector discussed.

source check requirements with RC supervision and based on

observations determined source checked instruments were being used for

documented surveys.

The inspector reviewed selected records of radiation and contamination

surveys performed during 1995 and discussed the survey results with .

licensee representatives.

Licensee personnel interviewed were

knowledgeable of the radiation survey results for the areas to which

they were assigned.

The inspector received a thorough br1efing on the

dose rates inside the Auxiliary Building prior to entry.

During facility tours, the inspector verified, by independent surveys

or observatioR of surveys, radiation and/or contamination surveys in

randomly selected areas of the Auxiliary Building, outside areas, and

other radioactive material storage areas.

Based on a review of this area, the inspectbr concluded th~t the

licensee was performing surveys consistent with regulatory

requirements.

No violations or deviations were identified in this area .

7.

Programs for Maintaining Exposures As Low As Reasonably Achievable (ALARA)

(83750)

10 CFR 20.llOl(b) states that the licensee shall use to the extent

practical, procedures and engineering controls based upon sound radiation

protection procedures to achieve occupational doses to members of the

public that are as low as reasonably achievable (ALARA).

Regulatory Guides 8.8 and 8.10 provide information 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 ALARA.

The inspector reviewed and discussed with licensee representatives

successful ALARA initiatives used during the current 37 day Unit 1

refueling outage. These initiatives included the utilization of temporary

shielding, teledosimetry, remote video cameras, and radio communications,

and mockup training. The inspector reviewed the current work scope

package for the Unit 1 outage as compared to the previous Unit 2 (46.1

days) outage performed in February and March 1995.

The l kensee

.

identified that the dose rates for *the two units were comparable.

Work

scope differences in the two Units identified an increase in work scope in

Unit 1 of approximately 18 person-rem.

The inspector determined, by a

review of documentation, that the.licensee had continued to track and

trend dose rates, develope engineering controls for exposure reduction,

perform TEDE ALARA evaluations, perform shielding evaluations and install

shielding to reduce dose rates, conduct post-job reviews with craft

personnel and supervision to improve preplanning and to e~tablish work

Enclosure

11

controls consistent with ALARA goals. Actual exposure expended as of day

23 in the current Unit 1 outage was trending slightly below exposure

projections for that day, which was consistent with the completion of

steam generator work being approximately 1 day ahead of schedule.

Based

on a review of exposure trending records for each unit, the inspector

determined that the licensee was meeting pre-establed exposure goals

during outages and that annual exposures per Unit had continued to trend

. lower.

Based on a review of the licensee's ALARA program, the inspector

determined that the licensee was continuing to implement procedures and

engineering controls to maintain occupational exposures ALARA.

No violations or deviations were identified in this area.

8.

Exit Meeting (83750)

The inspector met with licensee representatives indicated in Paragraph 1

at the conclusion of the inspection on October 6, 1995.

The inspector

summarized the scope and findings of the inspection.

The inspector also

discussed the likely informational content of the inspection report with

regard to documents or processes reviewed during the inspection.

The

licensee did not identify any such documents or processes as proprietary~

Dissenting comments were not received from the licensee .

Item Number

50-280, 281/95-21-01

Status

Closed

Description and Reference

NCV - Licensee failure to follow

procedures for wearing dosimetry.

(Paragraph 5.) .

Enclosure