ML20045E552
| ML20045E552 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/04/1993 |
| From: | Bryan Parker, Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045E537 | List: |
| References | |
| 50-321-93-07, 50-321-93-7, 50-366-93-07, 50-366-93-7, NUDOCS 9307020192 | |
| Download: ML20045E552 (14) | |
See also: IR 05000321/1993007
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ATLANTA, GEORGI A 30323
JUN - 4 ~ 1993
Report Nos.: 50-321/93-07 and 50-366/93-07
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Licensee: Georgia Power Company
P. O. Box 1295
Birmingham, AL 35201
Docket Nos.:
50-321, 50-366
Facility Name:
Hatch I and 2
Inspection Conducted: Ma
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Inspectors:
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B. A,// Parker
Dat'e Signed
Approved by:
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W. H. Rankin, Chief
Date'Kigned
Facilities Radiation Protection Section
Radiological Protection and Emergency Preparedness Section
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Division of Radiation Safety and Safeguards
SUMMARY
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Scope:
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This routine, announced inspection was conducted in the area of occupational
radiation exposure.
Specific areas examined included:
organization and
management controls, audits and appraisals, training and qualifications,
external exposure control, internal exposure control, and maintaining -
occupational exposure as low as reasonably achievable (ALARA).
Results:
Overall, the inspector found the licensee's program to be functioning
adequately to protect the health and safety of plant workers and .the public.
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The licensee appeared-to be prepared---for -implementation of -revised
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10 CFR Part 20 requirements in that equipment, training, procedural changes,
and subsequent implementation were neariny completion. - Also various dose
reduction initiatives were implemented during the ongoing Unit 1 outage which
had been successful in maintaining outage exposure as projected. One apparent
violation was identified by the licensee for a worker who entered'a posted
high radiation-area without being on a Radiation Work Permit and without using
any of the controls as established by licensee procedure.
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9307020192 930604
ADOCK 05000321
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Also one licensee-identified, non-cited violation was identified regarding two
examples of failure to follow radiological controls as required by 1_icensee
procedures.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- J. Betsill, Unit Superintendent
- E. Borders, Foreman, Health Physics -(HP)
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S. Cowan, Foreman,-HP
- 0. Fraser, Site Supervisor, Safety Audit and Engineering Review (SAER)
- J. Hammonds, Supervisor, Regulatory Compliance
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- W. Kirkley, Manager, HP and Chemistry
- L. Lawrence, Specialist, SAER
- J. Lewis, Manager, Operations
M. Link, Supervisor, HP
- L. McDaniel, Supervisor, Plant Administration
R. Ott, Training
- W. Prince, Training
- J. Reddick, Supervisor, HP
- G. Riner, Plant Health Physicist
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- P. Roberts, Outages and Planning
- D. Smith, Superintendent, HP
- L. Sumner, General Manager
S. Tipps, Manager, Nuclear Safety and Compliance
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- P. Wells, Unit Superintendent
Other licensee employees contacted during this inspection included
engineers, technicians, and administrative personnel.
Nuclear Regulatory Commission
E. Christnot, Resident Inspector
- B. Holbrook, Resident Inspector
- Denotes attendance at May 7, 1993 Exit Meeting
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2.
Organization and Management Controls (83750)
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During the onsite inspection, the inspector reviewed the licensee's
staffing and organization for the Health Physics (HP) Department. No
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significant changes were noted in the organizational structure since the
previous inspection conducted November 2-6, 1992, and documented in NRC
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Inspection Report (IR) 50-321,-366/92-30. The HP organization remained
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relatively stable, maintaining a staff of approximately 80. This-
included managers, supervisors, foremen, specialists, technicians, and
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cl erks.
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For 'the Unit 1 Refueling Outage, the inspector noted that 104 contractor
technicians were employed to supplement the routine staff. This number
included senior technicians, junior technicians, dosimetry technicians,
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and health physics clerks. The inspector _ reviewed resumes for selected
contractors and verified their qualifications as ANSI 3.1 and 18.1
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technicians. The inspector noted that this level of additional .
technician support was consistent with previous outages and was adequate
for supplementing HP support during the outage.
Based on discussions with licensee representatives and observations of
activities in progress, no concerns were identified regarding the.
licensee's organization and staffing. The present HP organization and
staffing levels, including contract HP staffing, appeared adequate to
support ongoing and planned outage activities.
No violations or deviations were identified.
3.
Audits and Appraisals (83750)
Section 17.2.18, Audits, of the Hatch Unit 2 Final Safety Analysis
Report (FSAR) requires, in part, that audits of HP and radiation
protection (RP) be performed under the cognizance of the Safety Review
Board (SRB) at least once per 24 months, unless more frequent audits are
necessary due to certain specified conditions.
The inspector discussed the audit program with licensee representatives
within the Safety Audit and Engineering Review (SAER) Department. The
inspector reviewed the most recent SAER audit of the HP program, Audit
92-HP-1, which was performed during the period of September 14-28, 1992.
The inspector noted that the audit included a review of aspects of the
HP program relating to ALARA, dosimetry, bioassay, respiratory
protection, and radiation and contamination controls. The inspector
noted that the audit was well documented and thorough and contained'
items of substance related to the HP program. The inspector noted that
the report of audit findings and corrective actions and/or responses to
noted deficiencies were reviewed and provided final management approval
with an appropriate level of management oversight.
The inspector
reviewed corrective actions and/or responses to noted deficiencies, and
noted that corrective actions appeared appropriate to prevent
recurrence.
No violations or deviations were identified.
4.
Training and Qualifications (83750)
10 CFR 19.12 requires the licensee to instruct all individuals working
in or frequenting any portions of the restricted areas in the health
protection aspects associated with exposure to radioactive material or
radiation, -in precautions or procedures to-minimize exposure, and in the
purpose and function of protection devices employed, applicable
provisions of Commission regulations, individuals' responsibilities and
the availability of radiation exposure data.
The inspector reviewed the licensee's program for providing RP training
to licensee employees and contract employees. The inspector was
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informed that both licensee and contractor employees received General
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Employee Training (GET) prior to beginning work activities, and an
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abbreviated retraining annually. The inspector noted that topics.
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presented in GET included respiratory protection, industrial safety,
plant security, emergency response,' basic radiation theory and
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biological effects of radiation exposure, exposure limits,- revisions to-
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10 CFR Part 20 requirements, contamination control, access control,
procedural and Radiation Work Permit (RWP) compliance, and worker's
rights, including the right to open and private discussions with'NRC-
representatives.
The inspector noted that the training material-
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specifically addressed the licensee's policy for-. personnel and. equipment
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monitoring and proper response to alarms;' plant policy regarding-
compliance with RWP requirements; radiological postings and barriers and
consequences of worker noncompliance; and proper use of digital: alarming.'
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dosimeters (DADS).
The inspector also reviewed HP. technician orientation training as
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provided to contract HP technicians. The inspector noted that during
the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> training session, contract technicians were provided with an
overview of major building locations, major system locations, high~
radiation and contamination areas, monitoring. equipment used.at the~
facility, and selected plant procedures. and policies.
The inspector
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noted .that the training material and associated examination primarily -
focused on site specifics, The inspector was informed that the contract.
technicians' general knowledge of ' job coverage' and basic radiation and'
HP theory was required by the vendor contract and determined adequate by-
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licensee representatives during review of individual resumes prior to
accepting the individuals for employment.
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The inspector reviewed training records for selected licensee and
contract employees and noted successful completion :of GET, both initial
and retraining. 'The inspector also noted that:for those selected
individuals, all had reviewed and endorsed the form which stated that
all plant workers' were responsible for complying with High. Radiation
Area (HRA) entry requirements and for ensuring lock and closure of-
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Locked High Radiation Area (LHRA) doors and that noncompliance 'with such
requirements may lead to disciplinary actions. Additionally, the
inspector verified that for selected ANSI 3.1 qualified technicians,'HP
technician orientation training was successfully completed. Ove rall , -
the inspector found the RP training material -) resented:to both general
employees and contract-HP technicians to be tiorough and well prepared.
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No violations or deviations were identified.
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5.
External Exposure Control (83750)
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Program Implementation-
10 CFR 20.101(a) requires that no licensee possess, use, or
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transfer licensed material in such a manner as to cause any
individual in a restricted area to receive in any period of one
calendar quarter a total occupational dose in excess of 1.25 rems
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to the whole body, head and trunk, active blood forming organs,
lens of the eyes, or gonads; 18.75 rems to the hands, forearms,
feet and ankles; and 7.5 rems to the skin of the whole body.
The inspector noted that the licensee ended 1992 with a total of
200 personnel contamination reports (PCRs). The 1992 target was
181 PCRs. The inspector also selectively reviewed the licensee's
1993 PCRs, for which targets of 181 for the year and 81 for the
Unit 1 outage were set. As of May 6, 1993, the licensee had
documented approximately 92 PCRs for the year, 56 of which had
occurred thus far in the outage. The inspector also reviewed the
licensee's trending of PCRs and discussed the impact of the
respirator reduction program on the number of PCRs.
In general,
no adverse trends were noted. Some PCRs could be attributed to
the reduction of respirator use, as discussed in Paragraph 7;
however, the licensee indicated that the time and external dose
savings from working without respirators appeared to outweigh the
internal doses incurred from lack of respirator usage.
In most
cases, the committed effective dose equivalent (CEDE) for each
worker's internal exposure was determined to be in the range of
1ro to seven millirem (mrem). The additional external dose, had
the workers been in respirators, would have most likely been much
greater than seven mrem per worker.
The inspector discussed with
the licensee the possibility of quantifying the potential dose
savings.
Thus far in the outage, the licensee had performed three skin dose
assessments due to skin / clothing contaminations, all of which were
triggered by hot particle contaminations.
Skin dose assessments
were performed when contamination greater than
20,000 disintegrations per minute (dpm) per probe area was
detected on the skin and/or clothing. The only exception to the
rule was the bottom of the shoes, where at least 100,000 dpm/ probe
area was required to trigger an assessment. Two of the three
assessments resulted in calculated skin doses of less than
100 mrem.
The third assessment calculated a skin dose of 377
mrem.
The licensee utilized the updated version of VARSKIN to
calculate skin doses and, for conservatism, most of the
assessments were treated as point sources.
No regulatory limits
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were exceeded and no problems were identified with the licensee's
procedures or methods.
The licensee continued to track dose on a daily basis. Most
individuals were on an administrative exposure-limit of 1,000 mrem
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per quarter.
If an individual had 200 mrem or less remaining in
their administrative dose allowance and no dose extensions were
approved, the individual's TLD was pulled until their dose was
reviewed and, if appropriate, extended. Approximately 140 dose
extensions had been approved thus far in the year, consistent with
previous years under similar circumstances. The maximum dose
extension approved by the licensee at the time of inspection was
to 2,000 mrem.
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The licensee provided thermoluminescent dosimeters (TLDs) to
employees on a monthly basis. TLDs were stored with
identification badges in the security island when not being worn.
The licensee also used pocket ionization chambers (PICS) as a
secondary means of tracking dose for all entries into the
radiologically-controlled area (RCA).
PIC storage racks were
provided at the main RCA entrance / exit and PICS were read daily by
HP to track collective dose.
The licensee found that the PICS and TLDs normally correlated
within 15-25 percent.
For example, on May 5, 1993, the estimated
collective dose for the year was 535 person-rem. On May 6, 1993,
after the April TLDs had been evaluated and accounted for, that
dose fell " officially" to approximately 470 person-rem. The
65 person-rem difference equated to a 14 percent correlation.
The inspector noted during plant tours that workers wore dosimetry
as required.
DADS were used for all high radiation area entries
and other special cases.
No violations or deviations were identified.
b.
High Radiation Area (HRA) Controls
10 CFR 20.203 specifies the posting, labeling, and control
requirements for radiation areas, high radiation areas, airborne
radioactivity areas, and radioactive materials.
Technical Specifications (TS) 6.11 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 personnel
radiation exposure.
Administrative Control Procedure, 60AC-HPX-004-0S, Radiation and
Contamination Control, Revision 11, dated July 7,1992, Step 4.6,
requires that plant personnel comply with all radiation protection
postings, rules, regulations, and procedures, and to read and
comply with the requirements of the Radiation Work Permit (RWP)
whenever their duties require such authorization.
Step 8.1.3 of
the procedure requires that entrance to high radiation areas in
which the intensity of the radiation is greater than 100 mrem per
hour shall be barricaded and conspicuously posted as a high
radiation-area and entrance thereto shall be-controlled by
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requiring issuance of a RWP. Any individual or group of
individuals permitted to enter such areas shall be provided with
or accompanied by one or more of the following:
1.
A radiation monitoring device which continuously indicates
the radiation dose rate in the area.
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A radiation monitoring device which continuously integrates
the radiation dose rate in the area and alarms when a preset
cumulative dose is received.
Entry into such areas is
permitted after the dose rate level in the area has been
made known to personnel.
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3.
An individual qualified in radiation protection procedures _
equipped with a radiation dose rate monitoring device. This
individual shall be responsible for controlling activities
within the area and performing radiological monitoring at
the frequency specified in the RWP.
The inspector reviewed details surrounding an April 5, 1993,
incident, as documented in Deficiency Card (DC) 1-93-1316,
involving an individual's noncompliance with HRA entry
requirements.
During discussions with licensee representatives,
the inspector was informed that on April 5, 1993, from
approximately 1900 to 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br />, the licensee was setting up for
planned radiography in the Unit 1 HPCI room.
In accordance with
licensee Radiation Protection Procedure, 62RP-RAD-038-0S, Control
of Radiography, Revision 4, dated January 5,1993, a qualified HP
technician was responsible for establishing and implementing all
HP controls associated with the radiography. Also in accordance
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with the procedure, a special RWP had established appropriate HP
controls to protect personnel and maintain exposures ALARA during
the subject radiography.
Boundaries for the expected HRA were
established and posted by the HP technician.
In accordance with
the RWP, entry into the area after that point required
authorization by.HP, a pre-job briefing, use of a DAD, and
continuous HP coverage during the radiography.
Sometime during radiography setup, when the posted HRA was not
actually a HRA, the planner for the evolution made an unauthorized
entry into the area to review the progression of the job. The
entry was unauthorized in that the planner was not signed in on
the appropriate RWP and therefore was not utilizing proper
dosimetry, nor had fulfilled any of the other control measures as
required by the RWP. After authorized personnel in the area noted
the unauthorized entry, the planner was instructed to leave the
area, and did so immediately.
Following the event, the
responsible HP technician initiated a Deficiency Card to document
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the incident.
The planner indicated that since she was
responsible for planning the evolution and for scheduling the time
period-during-the outage that-the- radiography would be performed,
she therefore knew that the area was not a true HRA at the time of
her unauthorized entry. However, during discussions with
cognizant licensee representatives, the inspector was informed
that the planner's role in the evolution was mainly to coordinate
a timeframe in the outage schedule when the radiography _could be
performed.
Following setup by the radiographers and verification
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by HP personnel that all radiological controls were in place, the
Operations Shift Supervisor was responsible for giving
authorization for the radiography to commence.
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The inspector informed licensee representatives that the incident
was an example of personnel not complying with procedural
requirements for entry into HRAs and was an apparent violation
(50-321,-366/93-07-01).
Following discussions with licensee representatives and review of
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exposure records, the inspector noted that the planner did not
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receive a significant exposure to radiation upon entering the
posted HRA. Total exposure for the evolution, as measured by
DADS, was 30 mrem.
The inspector noted that following the incident, the planner was
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disciplined according to the licensee's Positive Discipline
Program. Additionally, plant management issued memorandums to
plant personnel stressing actions taken in response to past
noncompliances involving HRA entries and the responsibility of
each plant worker to obey all postings and signs throughout the
plant.
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One apparent violation regarding personnel noncompliance with
procedural requirements for entry into posted HRAs was identified.
c.
Access Controls
Administrative Control Procedure, 60AC-HPX-004-0S, Radiation and
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Contamination Control, Revision 11, dated July 7, 1992, requires
plant personnel to comply with all radiation protection postings,
rule.s, regulations, and procedures, and to read and comply with
the requirements of the RWP whenever their duties require such
authorization.
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The inspector reviewed DC 1-93-1128 and 1-93-1129, which
documented an incident occurring on April 5, 1993, in which two
workers violated a radiological posting at the Hot Machine Shop
(HMS) and made an unauthorized entry into a contaminated area.
During discussions with cognizant licensee representatives, the
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inspector was informed that during routine activities the HMS was
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posted as a Radiation Area, therefore requiring no special
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precautionary measures. The inspector was also informed that both
individuals routinely entered the- area to perform their regular
duties. However on April 5,1993, the area was temporarily posted
as a contaminated area due to activities associated with
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decontamination and rebuilding of control rod drives (CRDs). The
inspector noted that contrary to the radiological posting on the
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door to the HMS informing nonessential personnel to not enter the
area, the individuals made an unauthorized entry into the posted
area.' The inspector noted that neither worker was contaminated
due to their inadvertent entry into the contaminated area.
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inspec.or informed licensee representatives that the failure to
comply with radiological postings was an example of an apparent
violation of licensee procedure, 60AC-HPX-004-0S, Radiation and
Contamination Control, (50-321, -366/93-07-02).
The inspector noted that in response to the noted deficiency, the
licensee disciplined the workers concerning the importance of
complying with radiological postings. The licensee also reposted
the entrance to the HMS to make the nonroutine radiological
postings more obvious to plant workers.
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The inspector also reviewed DC 1-93-1638, which documented a
violation of RWP requirements and radiological postings concerning
an individual which entered the Unit 1 Drywell without a DAD as
required by the RWP and postings.
During discussions with
licensee representatives, the inspector was informed that all
individuals entering the drywell were required to comply with
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special RWPs. These RWPs required that special HP control
measures, including protective clothing and DADS, be utilized
during entry into the drywell. However, on April 26, 1993, an
individual entered the Unit 1 Drywell without a DAD as required by
the applicable RWP and radiological postings at the drywell
entrance. The inspector noted that the worker entered the drywell
to perform walkdown inspections with another individual who was
wearing a DAD. The inspector also noted that a HP technician
assigned to monitor ongoing drywell activities intermittently
checked on the individuals during their walkdowns. The inspector
verified that the individual did not receive a significant
radiation exposure during these walkdown activities, based on the
accompanying individual's DAD reading. The inspector informed
licensee representatives that the failure to comply with RWP
requirements and radiological postings was a second example of an
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apparent violation of licensee procedure, 60AC-HPX-004-0S,
Radiation and Contamination Control, (50-321, -366/93-07-02).
The inspector noted that in response to the incident, the licensee
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disciplined the worker concerning the importance of complying with
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radiological postings. Additionally, following several instances
of personnel noncompliance with radiological postings, the plant
manager issued a memorandum stressing the importance of and worker
responsibility for compliance with postings throughout the plant.
Due to the limited safety significance of both events and the
licensee's prompt corrective actions,- the-inspector informed the
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licensee that the criteria specified in Section VII.B of the
Enforcement Policy were met and therefore the violation was not
being cited.
One licensee-identified, non-cited violation for two examples of
failure to read and comply with radiological postings and RWPs in
accordance with licensee procedures was identified.
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6.
Internal Exposure Control'(83750)
10 CFR 20.103(a)(3) requires, in part, that the licensee, as.
appropriate, use measurements of radioactivity in the body, measurements
of radioactivity excreted from the body, or any combination of such
measurements as may be necessary for timely detection and assessment of
individual intakes of radioactivity by exposed individuals.
Administrative Control Procedure, 60AC-HPX-003-0S,
Bioassay Program,
Rev. 2, dated June 12, 1987, establishes responsibilities and methods
used to control, monitor, and evaluate internal occupational radiation.
exposure. The procedure also requires additional bioassays when
accidental internal exposures occur, whether real or suspected.
The inspector reviewed and discussed with the licensee actions taken and
evaluations performed in response to two internal exposure events which
occurred in April 1993 during the Unit 1 outage.
Both events occurred
during the drywell insulation job and resulted in inhalation of
radioactive materials by the workers. The inspector noted that the
licensee performed dose calculations using ICRP-30 methodology and based
on whole body count results, the assigned internal exposures were 17.5
and 25.5 MPC-hrs, respectively.
The inspector also noted that the
licensee calculated the CEDE for each worker's internal exposure (the
licensee has not yet adopted the revised 10 CFR Part 20 that requires-
such determinations). .The CEDES were found to be 26 and 38 mrem,
respectively. The inspector reviewed the licensee's evaluations of the
incidents and exposure assessm'ents, and determined that appropriate
measures were employed in order to assess the individuals' exposures.
According to the licensee, one of the contributing factors to the two
inhalation events may have been the lack of respirator usage during most
of the drywell insulation job; however, the licensee indicated that the
time and external dose savings from working without respirators appeared
to outweigh the internal doses incurred from lack of respirator usage.
The inspector reviewed the licensee's breathing air program and verified
that the air used for breathing purposes met the criteria as Grade D
air.
Breathing air was tested quarterly, the last being performed
February 1993. The licensee utilized a dedicated compressor for the air
used in each unit, with separate compressors used for filling self-
contained breathing apparatus (SCBA) bottles.
No air was purchased from
outside vendors.
The inspector noted no problems with the licensee's
testing methods or procedures.
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During a previous inspection in November 1992, the inspector noted a
concern regarding medical evaluations and approvals as documented in
Paragraph 6.b of NRC IR 50-321, -366/92-30. The concern was
acknowledged by the licensee and the inspector reviewed the licensee's
response to the concern during this inspection. The licensee slightly
modified their approval' methods and revised the guiding procedure SH-
GEN-008, Respirator User Medical Evaluation Procedure, Rev.1, dated
December 1, 1992. The new procedure indicated that if any questionable
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information was received from the patient, the medical history or the
physical examination, then the individual's evaluation would be put on
hold until it was reviewed by the physician. This should help eliminate
the potential of an individual being qualified by the medical evaluators
only to be disqualified later by the physician.
No violations or deviations were identified.
7.
Maintaining Occupational Exposure As Low As Reasonably Achievable
(ALARA) (83750)
10 CFR 20.1(c) states that persons engaged in activities under licenses
issued by the NRC should make every reasonable effort to maintain
radiation exposures as low as reasonably achievable (ALARA).
The inspector reviewed the. licensee's program for maintaining exposures
ALARA. The licensee ended 1992 with a total collective dose of
550 person-rem. The 1992 goal was 1,035 person-rem and licensee
representatives indicated that possible contributing factors to the
lower than projected exposure included staff reorganization which
permanently established an ALARA and RWP/MWO coordination group;
successful preplanning efforts by these groups; and successful
communication and coordination between outage management, HP, and the
work groups.
In addition, the use of closed-circuit cameras and DADS
were effective in providing for remote HP surveillance, thereby
maintaining HP exposures ALARA.
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Licensee representatives informed the inspector that through May 6,
1993, the year-to-date collective dose was approximately 470 person-rem.
The licensee's collective dose goal for 1993 was 630 person-rem.
The
Unit 1 outage dose goal was 400 person-rem. At the time of inspection,
approximately 10 days remained in the outage and outage cumulative
exposure was approximately 400 person-rem.
Outage dose appeared to be
running slightly high due to some areas with higher than expected dose
rates and significant dose overruns on a few jobs due to emergent work.
Also, the licensee had experienced a Unit 2 forced _ outage early in 1993,
that added approximately 37 person-rem to the 1993 collective dose that
was not planned for.
As mentioned earlier, the licensee recently implemented a respirator
reduction program that appeared to be saving significant external doses.
During the Unit 1 outage, respirators were being issued at an average
rate of 150 per day. During previous outages, respirators were issued
at rates of 400 - 600 per day.
As noted. thus far-the licensee had
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experienced a few minor internal uptakes directly related to respirator
reduction. With the implementation of the revised 10 CFR Part 20, the
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licensee will most likely be required to justify and/or quantify the
internal versus external dose savings with regard to respirator usage;
however, it appeared that the licensee's reduction in respirators was a
significant ALARA initiative.
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The inspector also reviewed the licensee's Plant ALARA Review Committee
(PARC) and found that the PARC continued to meet monthly to discuss
ALARA-related items. No problems with attendance or substance of the
meetings were identified. The inspector was informed that numerous
ALARA suggestions were received as lessons learned from the 1992 linit 2
outage.
Some of these suggestions were approved by the PARC for
implementation during the Unit 1 outage in an effort.to reduce outage
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exposures.
In particular, the inspector reviewed an approved suggestion
to replace RCS water in the Reactor Water Cleanup (RWCU) Heat' Exchanger
system with demineralizer water. The licensee estimated that typically
600 - 1000 man-hours were spent in the RWCU Heat Exchanger Room during
each outage. During Unit 2 surveys of pre- and. post- demineralizer
water flushes, the licensee noted a maximum 200 mrem decrease in contact
dose rates on one of the heat exchangers. The inspector noted, however,
that during the Unit 1 outage the approved and scheduled dose reduction
activity was not performed due to ineffective communications which led
outage management to misunderstanding that setup for the evolution would
be work intensive, thus impacting the outage schedule.
Due to critical
path activities the flushing of the heat exchangers was delayed which
resulted in the lose of gathering ALARA data for future reference and of
exposure reductions for activities in the room.
The inspector noted
that outage management cancelling the PARC approved and scheduled
activity prior to complete discussions with personnel knowledgeable of
all aspects of the evolution did not appear to be a good practice.
However, during discussions with cognizant personnel and review of
licensee procedures the inspector did not identify any regulatory
concerns with the licensee's actions.
The inspector informed licensee representatives that their program for
maintaining personnel exposures ALARA during outage activities appeared
to be functioning adequately.
No violations or deviations were identified.
8.
Followup of Previously Identified Inspection Findings (92702)
a.
(Closed) 50-321, 366/92-20-01: Multiple events where LHRA doors
have been left open and unattended.
In response to previously identified problems regarding HRA
entries, the licensee recently implemented a program to
rephre/ upgrade a number of HRA doors. These identified upgrades-
were completed during November 1992. The new entryways consisted
of (1) a- cage-type enclosure out and -around the doorways; (2) a
heavy-duty swinging door; (3) a heavy-duty automatic door-closer;
and (4) an interlock system that causes a red light over the
doorway to be on if the door is not completely closed.
In
addition to the new entryways, the licensee had also implemented
new procedures for controlling HRA keys. All HRA keys were signed
out by two individuals and, upon completion of the task in the
HRA, the same two individuals were required to verify that the
door was properly closed and locked. Also, in an effort to
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prevent problems associated with transversing incore probes
(TIPS), the keys for the TIP room and the TIP drive motor control
panel were placed on the same keyring so that the TIPS could not
be operated while the TIP room was occupied.
The inspector discussed LHRA controls with licensee
representatives and reviewed DCs since December 1, 1992, and noted
no significant problems with the licensee's control of LHRA. The
inspector also reviewed daily confirmatory checks of the integrity
of LHRA doors and quarterly checks of the operability of the. door
closures. The inspector noted that although no problems were
identified with the doors being appropriately closed and locked,
the licensee was identifying minor mechanical inadequacies. These
mechanical problems were being appropriately identified and
resolved in a timely manner.
The inspector informed licensee representatives that this item
would be considered closed based on the appropriateness of the
current LHRA control program.
b.
(Closed) 92-20-02:
Licensee reported two events where personnel
entered a HRA without meeting TS or procedural requirements.
In response to the subject violation for personnel failing to
comply with entry requirements for posted HRAs, the licensee
terminated the contractors who knowingly violated the HRA barrier
and counseled the personnel who in error violated HRA postings.
The inspector noted that in response to previously identified
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nonconformances with HRA postings the licensee had not only
disciplined the involved individuals but had also retrained them
on procedural requirements for entering a HRA.
Additionally,
during April 1991 all plant workers were retrained on HRA access
controls and stressed the importance of compliance with these
controls and consequences of noncompliance.
GET and contractor
training was revised to incorporate this added emphasis on the
importance of compliance and the consequences of noncompliance
with HRA access controls. The licensee has also implemented new
signs for radiological postings, each with unique shapes and
colors to be more conspicuous indicators of the radiation hazard.
The inspector reviewed GET and noted that the training material
'
appeared to be appropriate for conveying the importance of
compliance with radiological postings. The inspector also noted
the use-of large and conspiraous radiological postings during
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facility tours. The inspectors informed licensee representatives
that the item would be closed.
c.
(Closed) 92-24-01:
Individual failed to comply with licensee
procedures for exiting the RCA.
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During a previous inspection, the inspector noted an individual
who appeared to improperly perform a whole body survey and
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equipment survey prior to exiting the RCA.
In response to the
violation the licensee counseled the' individual and plant
management issued a memorandum to workers stressing the importance
of monitoring personal items when exiting the RCA. Additionally,
a notice describing proper monitoring techniques and response to
alarms posted at RCA exits was updated to correct inconsistencies
as noted and as required by licensee procedures.
During the onsite inspection, the inspector noted that the
licensee had an updated notice posted at RCA exits which in
accordance with procedure, 60AC-HPX-004-0S, Radiation and
Contamination Control, appropriately identified monitoring and
alarm response requirements for personnel and personal items prior
to exiting the RCA. The inspector also observed personnel exiting
the RCA and did not note any deficiencies.
The inspector informed licensee representatives that this item
would be considered closed based on the appropriateness of the
current contamination control program.
9.
Exit Meeting
The inspector met with licensee representatives as denoted in
Paragraph I at the conclusion of the inspection on May 7, 1993. The
inspector summarized the scope and findings of the inspection, including
the two apparent violations. Dissenting comments were not received from
the licensee. Additionally, the licensee did not identify any documents-
or processes reviewed by the inspector as proprietary.
Item Number
Description and Reference
50-321,-366/93-07-01
VIO - Failure to comply with
procedural requirements for entry
into a posted HRA (Paragraph 5.b).
50-321,-366/93-07-02
NCV - Failure to comply with
radiological controls as specified
by licensee procedure
(Paragraph 5.c).