ML20023C463
| ML20023C463 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 04/25/1983 |
| From: | Greger L, Lovendale P, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20023C445 | List: |
| References | |
| TASK-2.B.2, TASK-2.B.3, TASK-TM 50-295-83-07, 50-295-83-7, 50-304-83-06, 50-304-83-6, NUDOCS 8305170353 | |
| Download: ML20023C463 (11) | |
See also: IR 05000295/1983007
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-295/83-07(DRMS); 50-304/83-06(DRMS)
Docket Nos. 50-295; 50-304
Licensee: Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
Facility Name: Zion Nuclear Power Station, Units 1 and 2
Inspection At: Zion Site, Zion, IL
Inspection Conducted: March 11, 14-17, 22-23, and April 7, 1983
Inspectors:
P. C
ven al
26/83
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D. E. Miller
25/83'
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Approved By:
L.
re >r
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Facilities Radiation
Protection Section
Inspection Summary:
Inspection on March 11, 14-17, 22-23, and April 7, 1983 (Reports No.
50-295/83-07(DRMS); 50-304/83-06(DRMS))
Areas Inspected: Routine, unannounced inspection of the operational radiation
protection program during the Unit 2 refueling and maintenance outage, includ-
ing: advance planning and preparation; training; exposure control; posting
and control; and surveys. Also reviewed were past open items, TMI Action Plan
Items II.B.2.2 and II.B.3, further review of certain items of concern presented
in Inspection Reports No. 50-295/82-18; 50-304/82-16, and an unplanned gaseous
release which occurred on April 5,1983. The inspection involved 106 inspector-
hours onsite by two NRC inspectors.
Results: Of the eight areas inspected, one item of noncompliance was identi-
fied in one area (failure to follow radiation protection procedures - Sections
6.c and 9).
One deviation from a previous commitment was identified. - Section
10.
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DETAILS
1.
Persons Contacted
- D. Adam, CECO Technical Services Nuclear Representative
- E.
Brocoolo, Quality Control Supervisor
E. Fuerst, Assistant Superintendent, Opera 61ons
K. Graesser, Station Superintendent
- B. Harl, Quality Assurance Supervisor
- J. Jirka, Chemist
- K. Moser, Chemist
- F. Ost, Lead Health Physicist
- G.
Plim1, Assistant Superintendent, Administrative and Support
Services
F. Rescek, CECO Technical Services Nuclear Representative
- T. Rieck, Rad / Chem Supervisor
- P.
Zwilling, Station Chemist
- P. Hartmann, Resident Inspector, NRC
- J. Waters, Senior Resident Inspector, NRC
The inspectors also contacted several other licensee employees, including:
rad / chem foremen, engineering assistants, technicians, and members of the
technical and engineering staffs.
- Denotes those present at the exit meeting.
2.
General
This inspection, which began at 8:30 a.m. on March 11, 1983, was conducted
to examine the operational radiation protection program during the Unit 2
refueling and maintenance outage. Also reviewed were past open items,
TMI Action Plan Itecs II.B.2.2 and II.B.3, further review of certain
items of concern presented in Inspection Reports No. 50-295/82-18;
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50-304/82-16, and an unplanned gaseous release which occurred on April 5,
1983. During tours, the inspectors used an NRC survey instrument (Xetex
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305-B) and a licensee survey instrument (Eberline PRM-6) to monitor
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selected areas and equipment throughout the plant. Measurements made
were in agreement with posted survey data. Area postings and access
controls were good. Genaral plant housekeeping was very good.
3.
Advance Planning and Preparation
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The licensee's planning and preparation for this outage has provided an
adequate supply of equipment and personnel to ensure the radiation pro-
tection program is fully implemented.
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The station health ohysics staff has been augmented with 45 contracted
health physics technicians. No problems with contracted technician quali-
fications were noted. The inspector observed a portion of an oral examin-
ntion given to two contracted technicians by a station health physicist.
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The exam appeared sufficiently comprehensive, covering both health physics
theory and station procedures. No problems were noted.
4.
Radiation Protection Orientation Training
This training currently remains as described in Inspection Report Nos.
50-295/82-18; 50-304/82-16. The training provided complies with 10 CFR 19.12 requirements.
A new Nuclear General Employee Training (NGET) program is to begin
April 1, 1983. This training, which requires about eight hours of class-
room instruction, has been developed by CECO for presentation at all its
nuclear stations. This training includes radiation protection orientation.
The licensee intends to provide the new NGET to all newly hired employees
and contractors, and require retraining using the same training program
every two years. Employees and contractors will be required to take a
test in the intervening years.
If an individual receives a failing grade
on the test, he will be required to attend NGET during this intervening
year. Currently employed persons must attend the new NGET training when
one year has elapsed since last attending an NGET or retraining class.
The inspectors will review the content of the new NGET program during a
future inspection. This matter was discussed during the exit meeting.
(295/83-07-01; 304/83-06-01)
5.
External Exposure
The inspectors reviewed worker whole body exposure totals for the current
calendar quarter. All exposure totals were well within regulatory and
administrative requirements.
Several NRC-4 forms on file for contractor
workers were reviewed; all were properly completed.
The Rad / Chem Supervisor stated that the station would be converting from
vendor supplied film badges to a licensee administered TLD program in the
near future.
No items of noncompliance were identified.
6.
Internal Exposure Controls
a.
Whole Body Counting
Records showing the results of whole body counting conducted during
the period October 1, 1982 through March 14, 1983 were reviewed.
Adequate followup of elevated counting results were performed.
There was no indication of intakes of gamma emitting isotopes
greater than the 40 MPC-hour control measure. The inspector re-
viewed records of whole body counting of selected work groups, in-
cluding offsite CECO Substation employees, to determine if counting
is being performed at the required frequency.
It was noted that
the requiredents for whole body counting listed in ZAP 5-51-18
" Personnel Termination Procedure," and RP 1190-1 " Personnel Bio-
assay Sampling Frequency," are not the same.
Procedure RP 1190-1
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permits exceptions to the bioassay sampling frequencies under certain
circumstances, while ZAP 5-51-18 does not specifically describe
permitted exceptions. The inspectors discussed with the licensee
the apparent need to make necessary revisions to these procedures to
make them compatible, and to specify a time period after termination
when bioassay or written exemption should be completed. This matter
was discussed during the exit meeting and will be reviewed during
a future inspection.
(295/83-07-02; 304/83-06-02)
b.
Respiratory Protection
Selected aspects of the licensee's respiratory protection program
were reviewed. Respiratory protection equipment is issued from a
small room located near the access control area of the auxiliary
building. A cursory check of respirators that were ready for issue
did not reveal any problems with their general condition. However,
it appears that licensee practices for the storage of respirators
and spare parts needs improvement.
It was noted that full-face
respirators were being stored in a large drum which may cause unde-
sirable distortion of the face piece and spare parts bins appeared
to be in disarray and dirty.
A check of several self-contained breathing apparatus (SCBA) located
throughout the auxiliary building indicated a need for a more aggres-
sive inspection and maintenance program.
Noted deficiencies included
low air cylinder pressure, a broken pressure gauge, dirty face pieces,
and corroded alarms. After this matter was brought to the attention
of licensee management, an RCT foreman corrected all noted deficiencies.
During facility tours, the inspectors observed workers wearing respira-
tors while working on reactor head bolt detensioning (full-face re-
spirators) and reactor coolant pump seals (bubble hoods). No problems
were noted.
The following procedures were reviewed to determine their agreement
with 10 CFR 20.103 and ANSI Z88.2-1980, " Practices for Respiratory
Protection," requirements.
ZRP 1310-1
Maintenance and Care of Respiratory Protective
Equipment
ZRP 1310-2
Issuance and Selection of Respiratory Protective
Equipment
ZRP 1310-4
The Regulation and Use of Radiological Respiratory
Protection Equipment
Procedure ZRP 1310-2 needs revision to include a requirement that
the RCT issuing respirators check to ensure the worker is qualified
to wear the requested equipment. Procedure ZRP 1310-4 indicates
that credit (application of the allowable protection factor) may be
taken for wearing half-face respirators in airborne radioactivity
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areas. According to 10 CFR 20, Appendix A, credit for wearing
half-face respirators cannot be taken unless the wearer is subjected
to an irritant smoke test each time he dons the respirator. The
procedure needs revision to reflect the requirements of 10 CFR 20,
Appendix A, or state that credit cannot be taken for half-face
respirators. The problems identified above were discussed during
the exit meeting and will be reviewed during a future inspection.
(295/83-07-03; 304/83-06-03)
c.
Airborne Surveys
Records of air samples taken to support outage maintenance activities
were selectively reviewed.
It was noted that all job specific air
samples taken by the contractor technicians were counted on the
Ge(Li) system but apparently iere not counted for gross beta or
alpha as required by Procedure ZRP 1310-11, " Air Sampling and Post-
ing of Suspected and Known Radioactive Airborne Areas." According
to licensee personnel, this was done to reduce demand on the low
level gross counting equipment, but no temporary procedure change
was made. No program had been implemented for quick gross counting
of job specific air samples or for flagging elevated results.
Failure to count job specific air samples in accordance with Pro-
cedure ZRP 1310-11 is considered an item of noncompliance.
(295/
83-07-04; 304/83-06-04)
It was also learned that job specific air samples were not receiving
priority for counting equipment time and the records of results were
not always receiving a timely review by Rad / Chem Department manage-
ment. As an example, the results of a charcoal cartridge air sample
collected at the "C" steam generator platform on March 12, 1982 at
12:35 a.m. had not been reviewed by March 16, 1983. A review of the
results showed I-131 levels of about 35 percent of MPC and also showed
that the sample had not been counted until about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> after its
collection.
These matters including corrective actions were discussed during the
exit meeting and will be reviewed during a future inspection.
(295/83-07-05; 295/83-06-05)
7.
During a containment tour, the inspectors observed the licensee's arrange-
ment for performing steam generator maintenance. Dose saving efforts
include building shielded waiting areas, and increased use of job monitor-
ing with video equipment. Licensee records show a significant reduction
in total person-rems received for current steam generator work over pre-
vious similar work.
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8.
Posting and Control
a.
Containment Access
Control of access to containments during non-power periods when con-
tainment integrity is maintained was previously reviewed and dis-
cussed in Inspection Report Nos. 50-295/82-18; 50-304/82-16. During
this inspection, the inspectors discussed with licensee representa-
tives the apparent need to provide additional controls for contain-
ment access during these periods. The licensee stated that they
would either provide a uniformed guard, or require that the center
desk operator determine who will perform the guard function and log
that person's name on the key log. The licensee stated that the
new requirements would be included in appropriate procedures. This
matter was discussed during the exit meeting and will be reviewed
during a future inspection.
(295/83-07-06; 304/83-06-06)
b.
Radiation Work Permit System
The licensee has recently implemented, for a trial period, a revised
radiation work permit (RWP) system. The new system requires that
all workers entering the controlled area be on an RWP. Previously,
workers were allowed to enter controlled areas without an RWP pro-
vided their estimated whole body dose for the entry would not exceed
50 mrem. The new system should help to ensure that all workers under-
stand the radiation protection requirements for their job by requir-
ing the worker to read and sign the RWP before commencing work.
Also, the Rad / Chem Department is more cognizant of each worker's
activities within the controlled areas.
In addition to an RWP,
workers are required to fill out a dose card before entering a con-
trolled area. The dose card contains information needed to track
the worker's daily dose and dose by task including; the date, worker's
name and film badge number, time in and out of area, total time at
job site, RWP number, and self-reading dosimeter total for the entry.
The inspectors observed workers using the new system; no significant
problems were identified. The inspectors discussed the merits of
the new system during the exit meeting.
c.
Posting
During facility tours, the inspectors observed controlled area post-
ings and radioactive material labeling. No problems were noted.
d.
Containment Evacuation Alarm
Frequent false actuation of the containment evacuation alarm and the
resultant tendency to ignore the alarm is described in Inspection
Report Nos. 50-295/82-18; 50-304/82-16. The licensee has since
changed the alarm function from automatic to manual. Now when the
control room operator receives a source range monitor alarm in the
control room during refueling outage, he is directed to manually
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actuate the evacuation alarm in containment when an actual increase
in core neutron flux is verifed.
In addition, direct radiation area
monitors in containment would provide indication of increased dose
rates and provide local visual and audible alarm.
The licensee stated that the revised criticality alarm procedure was
being discussed at routine safety meetings, including instructions
to always evacuate upon actuation of the containment evacuation
alarm. This matter was discussed during the exit meeting and will
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be reviewed during a future inspection.
(295/83-07-07; 304/83-06-07)
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No items of noncompliance were identified.
9.
Transfer Canal Personal Contamination Incident
The inspectors reviewed licensee actions related to work conducted in the
fuel pool transfer canal and a resulting personal contamination incident.
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On March 1 and 2,1982, workers alarmed the portal monitor at access con-
trol after exiting the fuel transfer canal area. Upon investigation by
the licensee, the workers were found to have nasal contamination. The
workers had been wearing continuous flow bubble hoods and full plastic
coveralls while working in the area. The contamination may have resulted
from improper clothing removal. Removable contamination levels (beta /
gamma) in the area averaged about 2E+6 dpm/100cm . All affected workers
were decontaminated and whole body counted. No significant uptakes were
noted. External personal contamination levels and nasal smear results
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were not available for review because Procedure ZRP-1470-4 "Decontamina-
tion of Personnel," was apparently not followed. This procedure requires
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documentation of all personal contamination surveys in which internal con-
tamination is suspected or a major portion of the body is involved. This
is considered an item of noncompliance.
(295/83-07-04; 304/83-06-04)
No job specific air samples were collected for the fuel transfer canal
work. Air samples are essential for proper selection and assessment of
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respiratory protection equipment and determination of engineering con-
trol needs. Air sampling was particularly important for this work since
the normally wet transfer canal area had partially dried out.
Procedure
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2RP 1310-11 " Air Sampling and Posting of Suspected and Known Radioactive
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Airborne Areas," requires that air samples be collected in close proxi-
mity of the workers to ensure that a representative sample is obtained
and that the proper respirators are prescribed. The only air sample
available for this work was from an air sampler which runs continuously
on the fuel building operating floor. The filter from this air sampler
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is changed and counted daily. This sample point is not representative
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of the airborne radioactivity in the transfer canal and due to the daily
sampling interval, would not detect short term changes in airborne radio-
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activity in the transfer canal. Failure to collect representative air
samples in the transfer canal is considered an item of noncompliance.
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(295/83-07-04; 304/83-06-04)
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The air sample taken on the fuel building operating floor was not speci-
fically analyzed for the transfer canal work, but was analyzed at about
midnight on March I and 2, 1983. The results indicated slightly elevated
airborne alpha activity. Significant levels of alpha contamination in
the trancfer canal area had previously been found in October 1980
(Section 10). The potential for alpha activity was apparently not con-
sidered during pre-job planning nor during the job to determine if addi-
tional precautions were needed or if an uptake of alpha activity was
possible. Further evaluations, prompted by the inspectors, were con-
ducted and confirmed the presence of alpha activity in the transfer canal
and near the Unit 2 refueling cavity upender.
These matters, including the items of noncompliance and needed corrective
actions, were discussed during the exit meeting. The results of the li-
censee's corrective actions will be reviewed during a future inspection.
(295/83-07-08; 304/83-06-08)
10.
Alpha Activity Surveillance and Quantification
The inspectors reviewed the licensee's program for alpha activity surveill-
ance and quantification. As noted in Section 9, alpha activity was identi-
fied as being present in the transfer canal in October 1980.
In a letter
dated August 19, 1980, which responded to the NRC Health Physics Appraisal
Team findings, the licensee committed to implement additional alpha activ-
ity surveillance, including transuranic analysis by a private laboratory
of selected contamination smears and spent fuel pool liquid samples. The
smears were to be sent out semiannually and the fuel pool samples were to
be sent out quarterly. However, it appears that other than the smears
sent out in October 1980, no smears have been analyzed by a private labora-
tory. Also, it appears that quarterly fuel pool samples have not been
sent out for analysis. These surveillance commitments were apparently
not incorporated into station procedures. This is considered a deviation
from licensee commitments.
(295/83-07-09; 304/83-06-09)
It was noted that the licensee uses 2E-12 microcuries per milliliter
as the limit for unidentified airborne alpha activity. This MPC is
acceptable if it can be shown that more restrictive isotopes such as
curium-248 are not present. Although this may well be the case, no
supportive licensee documentation was found. This matter was discussed
at the exit meeting.
(295/83-07-10; 304/83-06-10)
During review of airborne activity survey data, the inspectors noted that
the apparent decay of alpha activity on air samples did not appear to
follow expected alpha activity decay. The inspectors discussed the need
to evaluate the counting methodolgy to determine if a fraction of the
beta activity in samples is being detected in the alpha channel.
If
such " crossover" exists, neither the beta or alpha activity is being
accurately counted.
Such error probably would be greatest in alpha
quantification because of a lower alpha detection efficiency. The
inspector also noted that the licensee's method of liquid sample prepara-
tion and analysis leads to a relatively insensitive Lower Limit of Detec-
tion (LLD) for alpha activity. Routine samples of the fuel pool are
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prepared by evaporation of one milliliter of sample, and analyzed by
counting for one minute. The resulting LLD for alpha activity is about
IE-5 uCi/cc which is well above the expected concentration.
Since the
analysis is conducted for trending activity in the pool this LLD is not
sufficient for the intended purpose.
Samples of lake discharge tank con-
tents are quantified by evaporation of 10 milliliters and counting for 20
minutes, resulting in a LLD of about 1E-7 uCi/cc for alpha activity. This
LLD meets the technical specification requirement but is still greater
than the expected alpha concentration in the tanks to be discharged.
Frequent positive alpha counting results greater than LLD seen on these
samples may be the result of beta " crossover" to the alpha channel and
result in unrealistic reporting of alpha quantities in the Station's
liquid effluent.
These matters and certain corrective actions were discussed during the
exit meeting. The results of these corrective actions will be reviewed
during a future inspection.
(295/83-07-10; 304/83-06-10)
11.
Independent Measurements
The inspectors performed independent radiation and contamination surveys
of the plant. Results compared favorably with licensee survey records.
Two air samples, two smears from the refueling cavity, and a fuel pool
liquid sample were collected for the inspectors' gross alpha determina-
tion on NRC counting equipment. The results of these analyses will be
communicated to the licensee during a future inspection.
12.
TMI Action Plan Item II.B.2.2
The alterations needed to complete this item are described in Inspection
Report Nos. 50-295/82-27; 50-304/82-24. During this inspection, the
inspectors verified that the alterations have been completed except for
installation of a solenoid operator and PING-3 software changes in the
control room ventilation system. This system has been placed in the
closed cycle mode, and will remain so until the alterations are completed.
13.
TMI Action Plan Item II.B.3
The High Range Sampling System (HRSS) is installed and operable. The
inspectors selectively reviewed procedures for operation of the HRSS,
training of technicians who will operate the HRSS, and toured the
facilities and routes involved in collection and analysis of post-
accident samples. No significant problems were identified.
In a letter
dated January 27, 1983, the Chief, Operating Reactors Branch No. 1,
Division of Licensing, NRC, requested that the licensee provided additional
information concerning compliance with five of the eleven criteria in
Item II.B.3 of NUREG-0737.
14.
Unplanned Gaseous Release on April 5, 1983
On April 5, 1983, Unit 2 Volume Control Tank (VCT) relief valve (2V8120)
was to be tested under work request No. 25030 as part of the in-service-
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inspection program. This relief valve is between the VCT and the waste
gas system header. When the workers began to remove the valve at about
1945 CST, they noted that gas under pressure began to leak from the loose
flange. The workers replaced the flange thus terminating the leakage.
The duration of the leakage was about ten minutes.
The licensee estimated the resultant unplanned release of noble gaseous
activity to be about 20 curies at a maximum release rate of about 4500
microcuries per second (about eight percent of the technical specification
instantaneous release rate limit). Release estimates were based on aux-
iliary building effluent monitor (R-14) response. Grab samples showed
Xe-133 to be the only identifiable isotope.
While reviewing the circumstances surrounding this unplanned release, the
inspector learned that shift operations supervisory review of the work
request correctly addressed the operational conditions of the VCT on the
upstream side of the relief value but failed to recognize that the pres-
surized vent header on the downstream side of the relief valve would be
open to atmosphere with the relief valve removed. The inspector noted
that Zion Administrative Procedure 3-51-1 " Originating and Routing of
Work Requests" had apparently been followed for this job. However,
ZAP 3-51-1 does not specify who is responsible for identifying and veri-
fying necessary valve positions, plant conditions, etc., to ensure ade-
quate isolation of the plant systems under repair. This matter will be
reviewed further by resident inspectors.
15.
Exit Meeting
The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the major portion of the inspection on March 23,
1983. The inspectors summarized the scope and findings of the inspection.
In response to certain items discussed by the inspectors, the licensee:
a.
Stated that the full NGET training program will be used for retraining
every two years.
(Section 4)
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b.
Stated that whole body counting requirements contained in Procedures
ZAP 5-51-18 and ZRP 1190-1 would be revised.
(Section 6.a)
c.
Stated that increased attention would be given to storage, maintenance,
and inspection of respirators.
(Section 6.b)
d.
Stated that needed respiratory protection procedure changes would
be made.
(Section 6.b)
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e.
Acknowledged the procedure violation and stated that a new program
for timely air sample evaluation of job specific air samples would
be implemented.
(Section 6.c)
f.
Stated that a new method for ensuring the containment entrance is
guarded when open would be implemented.
(Section 8.a)
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g.
Acknowledged the inspectors' comments regarding the merits of the
new radiation work permit system.
(Section 8.b)
h.
Stated that control room operators would take manual control of the
containment evacuation alarm to reduce the number of false alarms
and that all evacuation alarms would be adhered to.
(Section 8.d)
i.
Acknowledged the item of noncompliance for not documenting personal
contamination surveys and stated that action has been taken to im-
prove performance in this area.
(Section 9)
j.
Acknowledged the item of noncompliance for failure to take required
air samples and stated that the need for more job specific air
samples would be reviewed.
(Section 9)
k.
Stated that urinalysis of at least two of the involved workers would
be conducted to evaluate the possibility of an alpha activity uptake.
(Section 9)
1.
Acknowledged the deviation from a commitment and stated that required
alpha surveillance would be proceduralized.
(Section 10)
m.
Stated that use of 2E-12 uCi/ml unidentified alpha MPC would be
justified and documented.
(Section 10)
n.
Stated that an evaluation of the method used to determine alpha
activity in air, liquids, and on smears would be conducted, includ-
ing improved LLDs and alpha calibration.
(Section 10)
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