ML20033F580
| ML20033F580 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/07/1990 |
| From: | Potter J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20033F576 | List: |
| References | |
| 50-413-90-02, 50-413-90-2, 50-414-90-02, 50-414-90-2, NUDOCS 9003220112 | |
| Download: ML20033F580 (14) | |
See also: IR 05000413/1990002
Text
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REGION 11
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
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MAR 0 91990
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Report Nos.': 50-413/90-02 and 50-414/90-02
Licensee:; Duke Power Company
422 South Church Street
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Charlotte, NC 28242
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Docket Nos.: 50-413 and 50-414
License Nos.: NPF-35 and NPF 52-
Facility Name: Catawba 1 and 2
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Inspection Conducted: . January 8-12 and February 6-9, 1990-
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, Inspector:
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Approved by:
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J. K Potter, Chief
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Facilities Radiation Protection Section
Emergency Preparedness and Radiological
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Protection Branch
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Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
' This' unannounced inspection of radiation protection activities included a
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. review of the licensee's. organization and management controls, external.
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exposure controls, dosimetry, as low as reasonably achievable (ALARA) program,
surveys and control of radioactive material, solid radioactive waste, ~
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transportation of radioactive material, and. follow-up of previously identified
items.
.Results:
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One violation was identified for failure to follow radioactive shipment
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procedures for radioactive contamination surveys.
The licensee's radiological
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protection controls for the Unit I refueling outage activities were well
organized. . Overall, the licensee's radiation protection program appears to be
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generally effective in protecting the health and safety of the worxers.
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9003' 20112 90030Y
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ADOCK 05000413
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
G. Courtney, Technical Supervisor, Radiation Protection
D. Clum, Staff Scientist, Radiation Protection
- P. Deal, Manager, Radiation Protection
- J. Forbes, Manager, Technical Services
J. Fox, General Office Radiation Protection Staff
- R. Glover, Manager, Compliance
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J. Isaacson, Staf f Scientist, Radiation Protection
B. Kimray, Supervisor, Radiation Protection Staff
- V. King, Compliance Engineer
J. Mode, General Supervisor, Radiation Protection
- T. Owens, Station Manager
R. Propst, Station Chemist
-L. Schlise, General Supervisor, Radiation Protection
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P. Simbrat. Staff Scientist, Radiation Protection
N. Strickland, Radioactive Waste Supervisor, Radiation Protection
Other licensee employees contacted during this inspection included
technicians, maintenance, and office personnel.
Nuclear Regulatory Commission
- M.-Lesser, Resident Inspector
- W. Orders, Senior Resident Inspector
- Attended exit interviews held January 12 and February 9,1990
- Attended exit interview held January 12, 1990
2.
Unit 3, End of Cycle 4, Refueling Outage
The 65 day refueling outage began January 27, 1990 and the unit was
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scheduled to be back on line the second day of April.
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inspection' the licensee experienced problems with the reactor head
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removal, primary water leaks from the resistance temperature detector
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(RTD) lines that were being removed, and leaking steam generator nozzle
dams. However, on February 9, 1990, the licensee was on schedule.
3.
Organization and Management Controls
In January 1990, the inspector discussed the planning and preparation for
the Unit I refueling outage with licensee representatives. Specific areas
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discussed included increases in staffing, special training, equipment and
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supplies, health physics involvement in outage planning, licet.see control
over health physics technicians, and dose reduction methods to be
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employed.
In February 1990, the inspector observed the implementation of
some of those plans.
The -inspector discussed with the raoiation protection staff the type,
methods of, and degree of interaction between plant groups. The licensee
had a series of meetings throughout the day to monitor, plan, and
coordinate outage work objectives.
The inspector attended selected
planning and briefing meetings throughout the inspection and observed
cooperation and coordination of plant personnel in meeting work, safety,
and radiological. protection objectives.
The inspector attended daily
shift turnovers during shift changes.
The typical shift turnovers
included status of outage progress, recent changing radiological
conditions and new survey information, job contacts, and the status of
radiation protection activities in supporting work.
The staff's sharing
of information during shift turnovers was an important element in managing
and implementing the facilities radiation protection program.
The
observed turnovers were effectively conducted.
The licensee had established five radiation control grcups, or stations,
to monitor and control outage work by plant area and task.
Each of the
groups provided seven-day, 24-hour coverage for their area. The assigned
personnel worked 12-hour days in rotation to keep total hours worked to
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less per week.
The major outage stations included upper
containment, lower containment, steam generator work, RTD replacement, and
Auxiliary Building work.
The inspector reviewed the staffing levels,
radiation work permit (RWP) control measures, and surveys for each
station.
The licensee appeared to be effectively monitoring radiological
conditions and controlling worker exposures to radiation and radioactive
contamination.
The licensee had distributed its radiation protection supervisors and
technicians on all shifts' to assist radiation protection vendor personnel
in implementing program requirements. The licensee had planned to utilize
137 -vendor radiation protection personnel to support planned outage
activities.
The licensee was utilizing two vendors to provide the
additional health physics (HP) personnel.
The licensee was not able to
use two of the personnel requested and had 135 vendor personnel on site-
during the inspection.
The vendor staff included 123 senior health
physics technicians (HPTs). The licensee's staffing levels appeared to be
sufficient to support, monitor, and control the outage work activities.
No violations or deviations were identified.
4.
Training and Qualifications
The inspector discussed the licensee's methods for reviewing and
evaluating vendor health physics personnel qualifications with the station
Radiation Protection Manager (RPM).
The licensee utilized a written
procedure to provide guidance in evaluating vendor qualifications.
Each
ANSI qualified vendor HPT was given a written examination.
The
qualification examination was initially required for each technician
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reporting to a utility facility. The examination was given~to verify that
the HPT had a basic understanding of applied HP principles.
The licensee had also provided the vendor HPTs with two-and-a-half days of
" site specific" procedure training.
The procedure training was required
for each technician on each visit to a utility facility.
The inspector
determined that the trainers providing . the procedure training were
assigned to the training departnent.
However, the trainers work stations
were located with the~ HP staff and both had been ANSI qualified HPTs at
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the station.
The RPM reported that the instructors had worked closely-
with the HP staff to keep current of radiation protection program
activities and issues..
The inspector also determined that the licensee had provided special
training to vendor personnel along with the facility staff when needed.
No violations or deviations where identified.
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5.
External Exposure Control and Personnel Dosimetry (83724)
a.
Radiological Postings
10 CFR 20.203 specifies the posting
labeling, and control
requirements -for radiation areas, high radiation areas, airborne
radioactivity ' areas, and radioactive material.-
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requirements for control of high radiation areas are contained in
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Technical Specification (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.
All areas appeared to be properly posted and
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controlled.
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No violations or deviations were identified.
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b.
10 CFR 20.203(2) requires that each entrance or access to a high
radiation area be maintained locked except during periods when access
to the area is _ required, with positive control over each entry.
Licensee procedure HP/0/B/1000/25, Catawba Nuclear Station High
Radiation Area Access, reflects those requirements.
In a previous inspection, resident inspectors identified a problem
with unlocked and uncontrolled high radiation area doors.
The
inspectors identified the unsecured access as a violation of the
requirements of licensee procedure HP/0/B/1000/25 and issued
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violation 413/89-16-01, on July 25, 1989.
In another inspection
conducted August 21-24, 1989, an inspector determined that the
licensee had identified additional occasions where high rediation
area doors were found unlocked.
The licensee's investigation of the
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root cause of the' events revealed that mechanical failure of door
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closures, latching mechanism, and personnel error were the root cause
of the events.
Since the licensee's corrective actions, to preclude
further events of this nature, had not been completed, no additional
violations were issued.-
However. the inspector informed licensee
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management representatives that subsequent violations could be. issued
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if adequate corrective actions were not taken to prevent unlocked.
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At the August 24, 1989 exit meeting, the
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inspector informed licensee management representatives that the issue
would- be considered ' an unresolved item (URI) pending corrective
actions taken to prevent unsecured and unlocked high radiation areas
(URI:
50-413/89-26-01).
The inspector reviewed the licensee's' corrective actions for
violation 50-413/89-16-01 and determined that the licensee had
revised procedures to require an investigation'whenever unlocked high
radiation doors were found open.
The licensee also specified
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additional responsibilities, for persons issued high radiation area
keys, on the High Radiation Door Key Issue Authorization Forms. The
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Operations staff discussed - the incidents during shift supervisor
meetings. -Additionally, the licensee's Maintenance Engineering staff
was required to design and coordinate a preventive maintenance
program for high radiation area doors.
The inspector verified that
the licensee had completed the proposed corrective actions.
The
inspector reported that the violation (VIO: 50-413/89-16-01) and the
unresolveditem(URI: 50-413/89-33-01) would be closed.
No additional violations or deviations were identified.
c.
RadiationWorkPermits(RWPs)
TS 6.8 requires the licensee to have written procedures, including
the use of RWPs.
The inspector reviewed selected RWPs for
appropriateness of the radiation protection requirements based on
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work scope, location, and conditions.
During tours of the plant, the
inspector observed the adherence of plant workers to the RWP
requirements and discussed the RWP requirements with plant workers at
the job site.
No violations or deviations were identified.
d.
Personnel Monitoring
10 CFR 20.202 requires each licensee to supply appropeiate personnel
monitoring equipment to specific individuals and require the use of
such equipment.
During tours of the plant, the inspector observed
workers wearing appropriate personnel monitoring devices.
The
inspector also observed the use of multiple and extremity dosimetry.
The licensee was utilizing a personnel radiation monitor in high
radiation areas inside containment that would give the user a
continuous dose rate for the gamma radiation field present.
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health physics staff set the monitors to provide an audible alarm at
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a desired dose rate and integrated dose value. The licensee reported
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that they had good' correlation with the monitors integrated dose and
dose neasured with self-reading pocket dosimeters (SRPDs).
The-
inspector noted good agreement between the monitors and assigned SRPD
during the inspection in lower containment.
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No violations or deviations were identified.
6.
Surveys, Monitoring, and Control of Radioactive Material
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Radiological Surveys
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10 CFR 20.201(b) requires each licensee to make or cause to be made
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such surveys as (1) may be necessary for the licensee-to comply with
the regulations, and (2) are reasonable under the circumstances' to
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evaluate the extent of radioactive hazards that may.be present.
The inspector reviewed the plant procedures which established the
licensee's radiological survey and monitoring program and verified
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that the procedures were consistent with regulations, TSs and good
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HP practices.
The -inspector reviewed selected records of radiation and
contamination surveys performed during the period of January and
February .1990, and: discussed the survey results with licensee -
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representatives.
During tours of the plant, the inspector observed
HPTs performing radiation and contamination surveys.
The inspector performed independent radiation and loose surface
contamination surveys in the - Auxiliary and Unit 1 Containment.
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Buildings and verified that the areas where properly posted.
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The inspector discussed with the licensee methods used to release
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material from the restricted area and observed technicians performing
release surveys for material.
No violations or deviations were identified.
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b.
Personnel Contamination Surveys
In previous years, the licensee has experienced problems with
inadequate personnel contamination surveys.
In response to that
problem, the licensee reduced the number of personnel entry / exit
points to the radiological control area (RCA) and stationed radiation
protection personnel at the primary access point, during high traffic
periods, to nonitor personnel contamination surveys.
The most
significant improvement in the personnel contamination survey program
occurred with the installation and use of whole body personnel
friskers.
The licensee installed the whole body friskers at the RCA
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exit points' and = clean change rooms in February 1989.
This reduced
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the staff's need to perform tedious whole body frisks utilizing small'
-geiger-muller (GM): detectors. The increased sensitivity of the whole
body ; friskers improved the licensee's . ability -to detect lower levels
of radioactive contamination.
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No violations or deviations were identified.
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c.
Personnel Contaminations
The licensee's number of documented personnel contaminations has
' increased in- the last two years.
In 1988 the number of personnel
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contaminations increased from 210 in' 1987 to 281.
In 1989, the
number of personnel contaminations increased to 390.
The licensee
documents.all personnel contaminations in which the licensee measures
contamination equal to or greater than 150 corrected. counts per
minute (CCPM) as measured with a thin window GM detector.
In those
totals, the licensee had included personnel contaminations attributed
to fission noble gases and naturally occurring radionuclides. One of
the reasons for the significant increases in personnel contaminations-
in 1989 was the use of the more sensitive whole body friskers in the
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licensee's contamination control program.
The licensee's ability to .
detect personnel contaminations, resulting from noble gases,
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naturally occurring radioactive contamination, and . low levels of
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contamination had significantly increased with the utilization of the
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whole body friskers.
Most of the personnel contaminations were personnel clothing
contaminations, primarily shoes, hard hats, and shirts or pants. The
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activity levels were low, typically several hundred ccpm. A majority.
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of the - 1989 personnel contamination reports (174) had listed the
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cause of contamination as unknown.
The licensee had realized the
root cause evaluations were a program weakness and had revised the
personnel contamination review procedures to improve the root cause
analysis process.
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The inspector reviewed the licensee's personnel contamination reports
for 1990.
Through the first week in February, the licensee had
documented approximately 60 personnel contaminations.
About 30 of
those had been recorded in the first two weeks of the Unit I
refueling outage.
The inspector noted that the licensee- had
performed better reviews of the personnel contamination events in
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1990 to determine the root cause. However, the licensee continued to
have personnel contaminations in clean areas of the RCA.
The
inspector determined that the licensee was evaluating its routine
clean area survey procedures and considering additional clean area
mopping to keep contamination levels in clean areas well below its
contamination limits of 1,000 disintegrations per minute per
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The- licensee's ' breakdown on the causes for personnel contaminations-
indicated.that the licensee did make' improvements in 1989, in that,
the contamination incidents attributed to worker performance declined
from 72 to 28.
These numbers indicate- that the radiation workers
were doing a better job. preventing personnel contaminations.
Continued evaluation 'of the licensee's contamination control program
and personnel contaminations is needed.
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No violations or deviations were identified.
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d.
Alpha Contamination Surveys
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The licensee- routinely analyzes ten percent of the contamination
- smears for alpha radiation.
In general, the licensee had not
' experienced contamination ~ problems with alpha radiation.
However,
. during the inspection the licensee detected alpha contamination
associated with the Unit.1 primary system.
The alpha contamination
did not appear to be wide spread; however, smear samples from lower
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containment showed alpha contamination levels up to 520 dpm/100 cm_,
While the licensee prepared to evaluate the scope of the ' alpha
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contamination problem, the licensee issued additional guidance to the
radiation protection staff for alpha contamination monitoring.
The-
guidance requested the staff to continue to analyze ten percent of
the routine. contamination smears for alpha contamination and begin
counting 100 percent of all smears, taken for release of tools and
equipment utilized in primary system work,
for alpha
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The licensee also began counting ten percent of all
contamination.
air samples taken. in Unit 1 lower containment for alpha
contamination.
The licensee made additional counting room equipment
available to the radiation-protection surveillance staff to use in
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the increased alpha contamination monitoring program.
A review of
the licensee's alpha contamination monitoring program will be
performed in future radiation protection inspections.
During the inspection, one radiological survey violation was
identified as failure to survey for alpha contamination on
radioactive waste containers.
The event-is discussed in Paragraph 8
of this report.
No other radiological survey violations or
deviations were identified.
7.
Program for Maintaining Exposures As Low As Reasonably Achievable (ALARA)
10 CFR 20.1.c. istates that persons engaged in activities under licenses
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issued by the NRC should make every reasonable effort to maintain
radiation exposures a low as reasonably achievable.
The recommended
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elements of an ALARA program are contained in Regulatory Guide 8.8,
. Information Relevant to Ensuring that Occupational Radiation Exposure at
. Nuclear Power Stations, will be ALARA, and Regulatory Guide 8.10,
Operating Philosophy for Maintaining Occupational Radiation Exposures
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The inspector reviewed the licensee's Station Directive 3.8.1, Catawba
Nuclear Station ALARA Program, dated August 1988. The licensee procedure
described the licensee's ALARA policies, goals, and responsibilities.
.During the review, the inspector determined that it was not clear how some -
of the licensee's objectives specified in the procedure would be
completed.
The procedure states, in part, that the purpose of an ALARA
Job Observation Report -(AJOR) is to determine the effectiveness of the
ALARA exposure control program in the field and bring attention to those
areas of the' job where corrective action should be taken.
Additionally,
action items identified on the AJOR required a response by the effective
group within 30 days to the ALARA Planning Group.
The . inspector requested a review of previously completed AJORs.
The
licensee had two 1989 AJORs on file.
One of the reports indicated that
employees working on Unit 2 conoseal removal wore protective clothing not
required by- the RWP.
The licensee was not able to show that any
corrective action occurred since there. was. no corrective action
information available for review and the document did not state that any
corrective action had been completed.
The inspector stated that Station Directive 3.8.1. did not adequately
describe the corrective action process for problems identified on AJORs.
Additionally, the licensee did not have any additional ALARA Group
procedures for implementing other requirements of Station Directive 3.8.1.
The inspector stated that the licensee's procedure for AJORs was a program
weakness, in that, the Station Directive was a plant document to prescribe
the' plants ALARA policies, responsibilities and goals.and did not contain
sufficient procedures for the ALARA Group -in implementing those
objectives.
Licensee representatives committed to the development of an
ALARA Group procedure that would provide the group necessary guidance and
instruction to achieve the requirements of Station Directive 3.8.1.
This
would enable the licensee to remove some of the implementing instructions
currently in the Station Directive.
The-licensee comnitted to complete
the procedure by the end of March 1990.
The inspector stated that a
review of the licensee's ALARA implementing procedures would be reviewed
in a following inspection as an inspector follow-up item (IFI:
50-413/90-02-02).
The inspector reviewed the licensee's preparations for its Unit 1 outage.
The licensee's outage goal was 375 person-rem. The licensee was removing
RTD piping in lower containment and the licensee estimated that the work
would result in approximately 120 person-rem.
Estimates for other
significant exposure jobs included steam generator eddy current testing,
tube plugging, and tube removal with 58 person-rem; steam generator nozzle
dam installation and sludge lancing with 25 person-rem; reactor head work
with 15 person-rem; valve repairs with 38 person-rem; and quality assurance
(QA) inservice inspection with 16 person-rem.
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The inspector reviewed the licensee's ALARA planning activities, ALARA
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goal setting processes, use of remote monitoring, temporary shielding .
program, and. management involvement in implementing the ALARA program.
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The inspector determined that the licensee was doings a better job at
setting ALARA goals through additional plant staff participation in that
process. The licensee's modification of the primary RTD manifolds was the
licensee's major activity during the Unit I refueling outage. Through the
end of the inspection the licensee's collective personnel exposures were
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slightly higher than estimated with the total collective exposure of
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105 person-rem.
The licensee had under estimated the dose rates of'the
The~ licensee expected the whole body dose rates-to be
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at 5 rem per hour. The measured dose rates were-approximately 8-9 rem per
hour.
The licensee was optimistic that the collective dose goal could
still be achieved.
No violations or deviations were identified.
8.
Solid Radioactive Waste
a.
Radioactive Waste and Classification Program
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The inspector reviewed the licensee's solid radioactive waste
. management program, including:
adequacy of implementing procedures
to properly classify and characterize waste, prepare manifests,' and
. mark packages; overall performance of the process control and quality
assurance programs; and the adequacy of required records, reports,
and notifications.
10 CFR 20.311 requires a licensee who transfers radioactive waste to-
a land disposal facility to prepare all waste so that the waste is
classified in accordance with 10 CFR 61.55 and meets the waste
characteristic requirements of 10 CFR 61.56.
It further establishes
specific- requirements for conducting a quality control program.
The inspector reviewed the methods used by the licensee to assure
that waste was properly classified, met the waste form and
characteristic requirements of 10 CFR 61 and met the disposal site
license conditions, and discussed the use of these methods with
licensee representatives.
No violations or deviations were identified.
b.
Review of Licensee Radioactive Waste Shipments 89-48 and 49.
Licensee TS 6.8.1.a requires written procedures to be established,
implemented, and maintained to cover the activities recommended in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,1978, requires written procedures
for radiation and contamination surveys.
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Licensee procedure HP/0/B/1006/09, Shipment of Radwaste Filters and
Filter Media, dated February- 1989, states, in part, that
contamination surveys shall- consist of .a beta-gamma survey with
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10 percent of the smears counted for. alpha.
The inspector requested selective radioactive waste classification
and transportation documents for radioactive waste shipments made in
1989. When the inspector received those records, later that day, the
RPM reported that his staff had' reviewed the requested documentation
and found problems with missing alpha contamination surveys on
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radioactive waste shipments CNS-89-48 and CNS-89-49.
The RPM stated
that contamination smears, taken for surveys of radioactive. waste
containers, had not been counted for alpha contamination as required
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by. radioactive shipping procedure HP/0/B/1006/09.
Additionally, the
RPM reported that a licensee employee knowingly allowed the shipments
to leave the site without the alpha contamination surveys required by-
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licensee procedures for the reasons discussed below.
The inspector interviewed- all of the radiation protection personnel
that assisted in the radioactive waste shipment preparations to
determine how the contamination surveys were missed.- The licensee
was shipping four drums of radioactive waste, containing dewatered
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mechanical filter media, for disposal. .The drums were divided and
processed into two radioactive shipments, 89-48 and 89-49.
The
radioactive waste was shipped to a land-disposal facility on December
29, 1989.
The licensee received the two shipping casks that would be used for
transporting the -radioactive waste on December 27, 1989.
The
shipping cask internals were surveyed for smearable contamination in
accordance with licensee procedures.
The shipping cask for
radioactive shipment 89-48 contained some loose beta-gamma
contamination.
However, licensee ' survey records showed that .the
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contamination was not wide spread and less- than the contamination
limits of 49 CFR 173.427 when averaged over 300 cm2
The licensee
did not detect any significant smearable beta-ganna contamination in
the 89-49 cask'or alpha contamination in either cask.
On December 28, 1989, the licensee loaded two HICs with the drums and
surveyed the HICs before placing them into the USA /9168 shipping
cask.
The licensee's survey included contact and general area
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radiation measurements.
The technicians also smeared the HICs for
loose surface contamination.
The licensee utilized the- direct
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contact ' radiation measurements of the HICs in determining the
radioactivity of container contents.
The measured general area dos;
rates from the HICs placed into casks 89-48 and 89-49 were 4 and 3 cen
per hour, respectively.
The smears for those surveys were counted
for beta and gamma contamination by a HPT and recorded.
The
technician planned to count the smears for alpha contamination as
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required .by licensee procedure HP/0/B/1006/09; however, the
technician counting the smears was called to other monitoring duties
and left the smears unattended.
Someone utilizing the counting
equipment, later in the day, threw the smears away.
The radioactive waste group determined the package activity and
shipment . requirements.
The licensee determined .that the' shipment
name for 89-48 would be Radioactive Material, Not Otherwise Specified
(NOS) and 89-49 would be Radioactive Material, Low Specific Activity
.(LSA). The Certificate of Compliance (C0C) for Radioactive Materials
Package USA /9168/B(U) requires, in part, that prior to each shipment
(except for the contents meeting the requirements for LSA material-
which is. transported by exclusive use vehicle), the packaging must be
leak tested in eccordance with the directions specified in the
package approval application.
Therefore, the licensee was required
to perform an inspection and leak rate-test on the lid of the package
for radioactive material shipment'89-48.
That evening, the radiation specialist responsible for coordinating
and preparing the radioactive waste shipments determined that the
contamination surveys of the H1Cs did not have alpha contamination-
information.
The specialist determined that the smears had not been
counted and had been disposed of. At that time, the specialist chose
not to lift the HICs out of their respective cask for another alpha
contamination survey and did not notify his management of the
problem.
The following day, the second leak rate test for shipment
89-48 passed and the shipments were allowed to depart.
In interviews with the radiation specialist that was in charge of the
shipment, the inspector determined that the specialist. did ~ not
perceive any safety significance to the lack of alpha contamination
assessment. The worker reported that he did not think the additional
exposure received in resurveying the HICs for alpha contamination was
justifiable or ALARA.
The employee reported that at the time he was
comfortable with his decision.
The employee also reported that,
upon review, his decision was incorrect.
The employee's supervisor
was on vacation when the shipments were made and the acting
supervisor did'not detect the survey inadequacies.
Failure to assess alpha contamination, in accordance with licensee
procedure HP/0/B/1006/09, for the HICs utilized in radioactive
shipments 89-48 and 89-49 was identified as an apparent violation of
TS 6.8.1 (50-413/90-02-01).
Although the licensee found the
procedure violation, it is not clear that the licensee would have
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detected the procedure inadequacy if the inspector had not requested
the documents for review.
The licensee had already made its formal
review of' the documentation without detecting missing survey
information. Additionally, the violation decision was deliberate, in
that, a licensee representative chose not to collect new smears, for
reasons he believed to be sufficient. The inspector did not identify
any additional examples of the procedure violation.
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One violation was identified.
9.
Transportation of Radioactive Material
.10 CFR 71.5 requires that licensees who transport licensed material
outside the confines of its plant or other place of use, or who delivered
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licensed material to a carrier for transport, shall comply with the
applicable requirements of the regulations appropriate to the mode of
transport of the Department of_ Transportation in 49 CFR Parts 170 through
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189.
The inspector reviewed selected records of radioactive waste and
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- radioactive material shipments performed - during 1989. The shipment
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manifests examined were prepared consistent with 49 CFR requirements. The
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radiation and contarnination survey results for the shipments were within
the limits -specified for the mode of- transport and shipment
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classification.
The inspector selectively . performed independent
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calculations using licensee records of radioactive material . nuclide
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corrposition and verified that the shipments reviewed had been properly
classified.
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The inspector reviewed plant procedures for the preparation,-
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documentation, shipment and receipt of radioactive material and verified
that the procedures were consistent with regulations.
.No violations or deviations were identified.
10. Licensee Actions on Previously Identified Inspector Findings (92701 and
92702)
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(Closed) VIO 50-413/89-16-01.
This item concerned procedural violations
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for failure to maintain high radiation areas locked.
The inspector
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reviewed the licensee's response to the violation dated August 25, 1989,
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and verified that the' licensee's corrective actions specified in the
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response had been completed (see Paragraph 5).
(Closed) URI 50-413/89-26-01.
This item concerned recently identified
procedural violations for failure to maintain adequate controls to prevent
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unlocked high. radiation areas.- The URI documented additional examples
where the licensee failed to keep high radiation doors locked when not
attended.
When the unresolved item was issued the licensee had not
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completed previously accepted corrective action for a similar violation
issued that year (see Paragraph 5).
11. Exit Interview
The inspection scope and findings were summarized on January 12 and
February 9,1990, with those persons indicated in Paragraph 1.
The
inspector described the areas inspected and discussed in detail the
inspection results listed below. The licensee acknowledged the inspection
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findings and took no exceptions.
Proprietary .information is not contained
-in this report.
The inspector reported that observed radiological protection program
controls including postings, surveys, and RWPs appeared to be adequate.
The inspector stated that the licensee's program for' controlling work
during the outage was good. and that licensee policies and procedures
for qualifying vendor HP personnel were a program strength.
Item Number
' Description and Reference
50-413/90-02-01
VIO - Failure to follow licensee procedures
for surveying radioactive waste containers
for alpha contamination (Paragraph 8).
50-413/90-02-02
IFI - Review the licensee's ALARA Group
implementing procedures (Paragraph 7).
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