ML20045H863
| ML20045H863 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/17/1993 |
| From: | Bryan Parker, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045H856 | List: |
| References | |
| 50-369-93-08, 50-369-93-8, 50-370-93-08, 50-370-93-8, NUDOCS 9307220032 | |
| Download: ML20045H863 (13) | |
See also: IR 05000369/1993008
Text
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UMITED STATES
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NUCLEAR REGULATORY COENisslON
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REGION 11
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101 M ARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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J11N 171933
Report Nos.:
50-369/93-08 and 50-370/93-08
Licensee: Duke Power Company
P. O. Box 1007
Charlotte, NC 28201-1007
Docket Nos.:
50-369 and 50-370
License Nos.: NPF-9 and NPF-17
Facility Name: McGuire 1 and 2
Inspection Conducted:
May 17-21, 1993
Inspectors:
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R.'B. Shortridge
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B. A. Park (r
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Approved by:
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& y W. H. Rankin, Chief
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Date Signed
Facilities Radiation Protection Section
Emergency Preparedness and Radiological Protection Branch
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted in the area of occupational'
radiation safety and included an examination of organization and management
controls, training, audits and appraisals, external exposure control, internal
exposure control, surveys and monitoring, control of radioactive materials and
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contamination, instrumentation, maintaining occupational exposures as low as
reasonably achievable (ALARA), and a review of inspector followup items
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(IFIs).
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Results:
Based on interviews with licensee management, supervision, station personnel,
and a records review, the radiation protection program appeared to continue to
- >e effective in protecting the health and safety of the workers and the
publ ic.
Two violations were identified:
(1) failure to label radioactive
mtcrial in accordance with 10 CFR Part 20, and (2) a failure to review and
approve a procedure required by Technical Specifictions (TSs) 6.8.1 and 6.8.2.
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9307220032 930617
ADOCK 05000369
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
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- J. Boyle, Superintendent, Work Control
- W. Byrum, General Supervisor, Radiation Protection
- J. Foster, Manager, Radiation Protection
- G. Gilbert, Manager, Safety Assurance
- B. Hamilton, Acting Station Manager
- N. Pope, Superintendent, Instruments and Electrical
- J. Puckett, Radiation Protection /ALARA
- D. Scearce, Manager, Commodities and_ Facilities
- R. Sharpe, Manager, Compliance
Other licensee employees contacted during the inspection included
technicians, maintenance personnel and administrative personnel.
Nuclear Regulatory Commission
- K. VanDoorn, Senior Resident Inspector
- T. Cooper, Resident Inspector
- Denotes attendance at the exit meeting held on May 21, 1993.
2.
Organization and Management Controls (83750)
The inspector reviewed chanses made to the licensee's organization,
staffing levels, and lines of authority as they relate to radiation
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protection. At the time of the inspection, the licensee was
approximately 65 days into a 84 day refueling / maintenance outage. The
licensee contracted 83 health physics (HP) personnel to assist in
providing radiation protection during the eighth Unit I
refueling / maintenance outage. The contractor breakdown was: 55 senior
HP technicians, 20 junior technicians, and eight other administrative
personnel.
No violations or deviations were identified.
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3.
Training and Qualifications (83750)
10 CFR 19.12 requires the licensees instruct all' individuals working or
frequenting any portion 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
the Commission regulations, individuals responsibilities and the
availability of radiation exposure data.
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The inspector reviewed selected portions of the licensee's training
program, including ALARA training, digital alarming dosimeter (DAD)
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training, procedure training, and parts of General Employee Training
(GET). No problems were noted.
During tours of Unit I containment, the inspector inquired of personnel
their work area dose rates and the operational aspects of their
monitoring equipment. All personnel were wearing DADS and all personnel
were knowledgeable of the dose rates in their immediate work area and
the functions of their DADS.
No violations or deviations were identified.
4.
Audits and Appraisals (83750)
The licensee's quality assurance (QA) department periodically conducted
audits of various program areas within the plant.
The inspector
reviewed the most recent QA audit of the Radiation Protection (RP)
program, Audit N-93-06(MC), which was conducted March 29 -
April.7, 1993. The audit covered all aspects of the RP program and
included record and procedure review as well as
observation / surveillance.
In general, the audit was found to be
well-planned and documented and contained items of substance relating to
the RP program. A variety of findings and recommendations were
presented by the auditors and adequate corrective actions in response to
audit findings were taken in a timely manner.
In addition to periodic audits, the QA department conducted periodic
surveillances. These surveillances, or " mini-audits," generally
consisted of a performance-based inspection of a certain area or
activity. The last surveillance in the RP area, MC-92-9, was conducted
August 13 - September 1, 1992, and focused on receipt and storage of
radioactive material.
From review of the surveillance, the_ inspector
noted that the scope of the surveillance appeared. appropriate and there
were no significant findings.
The licensee maintained a Problem Investigation Process Report (PIPR)
system that was accessible to employees plant-wide and provided a means
for identifying, tracking and trending all significant concerns, issues
and problems within the plant. The inspector reviewed selected
RP-related PIPRs and no significant adverse _ trends were noted since the
last inspection. An issue regarding the licensee's procedures for
receipt of radioactive material was noted by the inspector due to three
occurrences in which radioactive material was not properly received
since July 1992. The inspector reviewed the circumstances surrounding
each occurrence and determined that the safety significance was minimal
and that appropriate and timely corrective actions were taken by the
licensee. The inspector discussed possible additional long term actions
to prevent recurrence with licensee representatives. No other problems
were identified.
No violations or deviations were identified.
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5.
External Exposure Control (83750)
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a.
Personnel Dosimetry
10 CFR 20.1201(a) requires each licensee to control the
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occupational dose to individual adults, except for planned special
exposures under 10 CFR 20.1206, to the following dose limits:
(1)
An annual limit, which is the more limiting of:
(i)the
total effective dose equivalent being equal to 5 rems; or
(ii) the sum of the deep-dose equivalent and the committed
dose equivalent to any individual organ or tissue other than
the lens of the eye being equal to 50 rems.
(2)
The annual limits to the lens of the eye, to the skin, and
to the extremities, which are:
(i) an eye dose equivalent
of 15 rems; and (ii) a shallow-dose equivalent of 50 rems to
the skin or to any extremity.
10 CFR 20.1502(a) requires each licensee to monitor occupational
exposure to radiation and shall supply and require the use of
individual monitoring devices by:
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(1)
Adults likely to receive, in one year from sources external
to the body, a dose in excess of 10 percent of the limits in
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(2)
Minors and declared pregnant women likely to receive, in one
year for sources external to the body, a dose in excess of
10 percent of any of the applicable limits in 10 CFR 20.1207
or 10 CFR 20.1208; and
(3)
Individuals entering a high or very high radiation area.
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10 CFR 20.1502(b) requires that each licensee shall monitor (see
10 CFR 20.1204) the occupational intake of radioactive material by-
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and assess the committed effective dose equivalent to.
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(1)
Adults likely to receive, in one year, an intake in excess
of 10 percent of the applicable Annual Limit of Intake (ALI)
in Table 1, Columns 1 and 2 of Appendix B to 10 CFR 20.1001-
20.2401; and
(2)
Minors and declared pregnant women likely to receive, in one
year, a committed effective dose equivalent in excess of
0.05 rem.
During tours of the Unit I containment, the inspectors observed
plant personnel wearing DADS. As previously indicated, all
personnel were knowledgeable of their dose and the operation of
their dos 1 metry.
However, the inspector noted that all personnel
were observed to place their DADS in the pocket of their
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protective clothing which made frequent reading of the DADS
somewhat difficult. The licensee indicated that they were working
on implementing changes which would make it easier for the workers
to monitor their dose.
The following RP Directive Procedures were reviewed during the
inspection concerning personal monitoring and external exposure:
11-1, Radiation Area Access and Monitoring Devices, Revision
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(Rev.) 2, dated March 1993;
III-1, Use of the Radiation Work Permit, Rev.1, dated April
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1993;
III-3, Posting of Radiation Control Zones, Rev. 1, dated
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March 1993;
III-4, Use of Alarming Dosimeters, Rev. O, dated January
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1993; and
III-13, Steam Generator Work, Rev. O, dated January 1993.
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Based on discussions with licensee representatives and review of
the above procedures and selected records, the licensee was found
to be in compliance with the aforementioned requirements.
The
inspector noted that RP Directive II-1, Step 5.3.5, did not
require the worker to read his or her self-reading pocket
dosimeter (SRPD) or DAD except at the beginning and end of a job
in the radiologically controlled area (RCA).
The inspector
previously noted during a review of Dose Assessment Due to Unusual
Dosimetry Occurrence Reports that the root cause of a number of
the problems identified in the reports was the failure of plant
personnel to read their SRPD or DAD frequently during the
performance of their job in a radiation area. The licensee agreed
to consider expanding the scope of the requirement in the
procedure for reading personnel monitoring equipment more
frequently. This same point was previously discussed by the
licensee in the occurrence reports and the licensee had agreed to
incorporate the guidance in GET.
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No violations or deviations were identified.
b.
Personnel Contamination Events
The inspector reviewed the licensee's personnel contamination
events (PCEs) to date in 1993.
PCEs were tracked as either skin
or clothing events and, according to the licensee, some overlap in
total numbers did occur. The inspector noted that when potential
PCEs involved licensee-supplied modesty garments only with no skin
contamination, a PCE report was not generated. This is an
acceptable industry practice.
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The 1993 PCE targets were 60 skin and 85 clothing. As of May 18,
1993, a total of 76 PCEs were documented, 20 of which were skin
and 56 of which were clothing. The maximum calculated skin dose
was 3090 millirem, due to a hot particle on the skin of the neck.
No regulatory limits were exceeded and no other problems were
noted with the licensee's methods or procedures.
No violations or deviations were identified.
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6.
Internal Exposure Control (83750)
10 CFR 20.1701 requires that the licensee shall use, to the extent
practicable, process or other engineering controls (e.g., containment or
ventilation) to control the concentrations of radioactive material in
the air.
10 CFR 20.1702 requires that when it is not practicable to apply process
or other engineering controls to control the concentrations of
radioactive material in the air to values below those that define an
airborne radioactivity area, the licensee shall, consistent with
maintaining the total effective dose equivalent ALARA, increase
monitoring and limit intakes by one or more of the following means: (a)
control of access; (b) limitation of exposure times; (c) use of
respiratory protection equipment; or (d) other controls.
10 CFR 20.1703(a)(3) requires that if the licensee uses respiratory
protection equipment to limit intakes pursuant to 10 CFR 20.1702, then
the licensee shall implement and maintain a respiratory protection
program that includes: (i) air sampling to identify the hazard;
(ii) surveys and bioassays to evaluate the actual exposures; (iii)
written procedures regarding selection, fitting, issuance, maintenance
and testing of respirators; supervision and training of personnel;
monitoring; and recordkeeping; and (iv) determination by a physician
prior to the initial fitting of respirators, and at least every
12 months thereafter, that the individual user is physically able to use
respiratory protection equipment,
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The inspector reviewed the licensee's respiratory protection program
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with regard to medical qualification for respirator users. The licensee
evaluated designated individuals as to their physical ability to wear
respiratory protection equipment on a frequency not_to exceed 12 months.
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The scope of each examination varied with age and included check-ups and
spirometry tests, as well as comprehensive physical . examinations. All
results were reviewed by the licensee's physician.
Physician
specialists were also on contract for extra coverage and consultation.
The inspector noted that the licensee provided the medical services to
Duke Power employees only.
Contractors only had to provide
documentation of their medical qualification, but were required to meet
the same criteria. According to licensee representatives, approximately
130 - 200 medical evaluations were conducted each month, including all
respiratory protection users onsite (rad workers, firemen, asbestos
workers,etc.).
No problems were noted.
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The inspector reviewed the licensee's efforts to reduce the numbers of
respirators issued as well as their efforts to increase the use of
engineering controls. The inspector noted during plant tours that-
special ventilation units and tents were used in various areas.
It appeared that the licensea was issuing roughly half of the number of-
respirators and bubblehoods during this Unit 1 outage as compared to
previous outages of similar scope. These efforts were noted as
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significant ALARA initiatives. Also, during plant tours, a number of
self-contained breathing apparatus strategically located throughout the
plant were randomly checked by the inspector. All were found to be
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fully charged and ready for use.
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Based on a review of selected records and respirator issuance, no
concerns were noted.
No violations or deviations were identified.
7.
Surveys, Monitoring, and Control of Radioactive Material and
Contamination (83750)
a.
Procedural Review
The following RP Directive Procedures were reviewed during the
inspection concerning control of radioactive material and
contamination:
III-1, Use of the Radiation Work Permit, Rev. 1, dated April
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1993;
III-5, Airborne Radioactivity Control and Accountability,
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Rev. I, dated February 1993;
III-7, Use of Protective Clothing and Related Equipment,
Rev. O, dated January 1993;
III-8, Personnel Contamination Monitoring, Rev. O, dated
January 1993; and
III-9, Tool, Equipment and Area Decontamination, Rev. O,
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dated January 1993.
No violations or deviations were identified.
b.
Contaminated Area
As of May 20, 1993, the licensee was maintaining 2,905 square feet
of contaminated area within the RCA. This equated to
approximately 2.6 percent of the total RCA area. At the end of
1992, the licensee had only 160 square feet contaminated, which
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was well under one percent of the total RCA.
The licensee
continues to have an aggressive program to control contamination
at the source.
No violations or deviations were identified.
c.
Surveys and Posting / Labeling
10 CFR 20.1501(a) requires each licensee to make or cause to be
made such surveys as (1) may be necessary for the licensee to
comply with the regulations and (2) are reasonable under the
circumstances to evaluate the extent of radioactive hazards that
may be present.
During tours of the plant, the inspector noted that the licensee's
posting and control of radiation areas, high radiation areas,
airborne radioactivity areas, contamination areas, radioactive
material areas, was adequate. All doors posted as locked high
radiation areas were found locked and the keys were controlled.
During tours of the plant, the inspector observed HP technicians
performing radiation and contamination surveys. The inspector
performed independent radiation / contamination surveys in various
areas including Unit I upper containment and the Auxiliary
Building.
No radiation or contamination beyond allowable limits
was found.
In addition, the inspector made direct observations of
individuals exiting Unit I lower containment and other sections of
the RCA with regard to disrobing and frisking the whole body and
hand-carried items (lunch boxes, tools, etc.) and no concerns were
noted.
10 CFR 20.1904(a) requires the licensee to ensure that each
container of licensed material bears a durable, clearly visible
label bearing the radiation symbol and the words " Caution,
Radioactive Material," or " Danger, Radioactive Material." The
label must also provide sufficient information (such as
radionuclides present, an estimate of the quantity of
radioactivity, the date for which the activity is estimated,
radiation levels, the kinds of materials, and mass enrichment) to
permit individuals handling or using the containers, or working in
the vicinity of the containers, to take precautions to avoid or
minimize exposures.
Technical Specification (TS) 6.11 requires that procedures for
radiation protection shall be prepared consistent with the
requirements of 10 CFR Part 20 and shall be a9 proved, maintained,
and adhered to for all operations involving personnel radiation
exposure.
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RP Directive IV-2, Labeling and Marking of Containers, Rev. O,
dated January 1, 1993, step 5.6, requires that drums or containers
used inside the RCA for collecting contaminated items be labeled
as follows:
5.6.1 - At a minimum, place labels on the center section of
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the drums or containers at two locations 180 degrees apart.
5.6.2 - Use standard 2" wide yellow and magenta " Caution
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Radioactive Material" tape to encircle the top third of the
drum for radioactive containers.
During radiological tours of the Unit I containment, the inspector
conducted brief interviews with personnel regarding immediate work
area dose rates and radiological techniques observed at the job
site. No discrepancies were noted and all work observed was
performed with good radiological work practices.
Continuing with
the walkdown, the inspector noted that all vacuum cleaners in the
Unit I lower containment were not labeled as containing
radioactive material nor did they have any other markings other
than a station housekeeping tag.
Radiation levels taken around
the vacuums revealed levels comparable to containment background
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levels of 5 to 10 millirem per hour.
The vacuums were used as wet
vacuums to collect potentially radioactive water and discharge it
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to the floor drain system. One of the vacuums had a clamp loose
which held the top of the canister to the vacuum cleaner. body.
The inspector noted that only two clamps were used for this
purpose and discussed with the HP technician the potential for
inadvertent separation of the head of the vacuum from the body and
loss of contents in containment. The technician indicated that he
did not know of any problems like this occurring at the station.
Later this same issue was discussed with management and the
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inspector informed management that the failure to label containers
of radioactive material in accordance with requirements was a
violation of 10 CFR 20.1904(a) (VIO:
50-359/93-08-01).
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TS 6.8.1 requires that written procedures be established,
implemented, and maintained covering the activities referenced in,
among others, Appendix A of Regulatory Guide 1.33, Rev. 2, dated
February 1978.
Section 7.e.(4) of Appendix A requires RP
procedures for contamination control.
TS 6.8.2 requires that each procedure of TS 6.8.1 above, and
changes thereto, shall be reviewed and approved by a group
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manager, superintendent / manager, or one of their designated direct
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reports prior to implementation and shall be reviewed periodically
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as set forth in administrative procedures.
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K-Mac Services Procedure KM/D/0015/01, Contro; and Use of Vacuum
Cleaners in the RCA, dated March 25, 1991, contains pertinent and
applicable requirements that are accepted industry standards for
vacuum cleaners containing radioactive materials.
Upon requesting the licensee to provide requirements for using
vacuum cleaners for containing radioactive material, the inspector
was informed by HP that this responsibility had been turned over
to a vendor approximately 18 months prior. However, HP provided
the aforementioned vendor procedure KM/D/0015/01, Control and Use
of Vacuum Cleaners in the RCA and a vendor employee training
program task training and qualification standard titled, D0P
Testing of HEPA Filters for RCA Use Vacuums.
Both documents
contained accepted methods for controlling vacuum cleaners
containing radioactive materials.
For example, the aforementioned
K-Mac procedure contained, in part, the following elements:
All vacuum cleaners shall be identified by visible marking
to designate areas of use, i.e., contaminated and non-
contaminated.
Vacuum cleaners used in contaminated areas shall be emptied
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in a controlled environment under RP guidelines.
All canister vacuum cleaners shall be equipped with a
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locking device which prevents inadvertent opening of the
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Sleeve all vacuum cleaner hoses.
Seal between the head and body, hoses and extensions shall
be firmly connected to prevent accidental disconnection.
The inspector discussed .several problems observed with licensee
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HP, Maintenance, and Plant Management regarding vacuums. The
first being that requirements of the vendor procedure
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KM/D/0015/01, Control and Use of Vacuum Cleaners in the RCA, were
in several instances, not being met. The most safety significant
of the items was the fact that the vacuum cleaner heads were not
secured such that inadvertent opening was precluded.
Further
investigation showed that the licensee did not require any of the
various types of vacuum cleaners to have the head secured to the
body to prevent inadvertent opening. The primary concern is that
a vacuum cleaner is frequently handled and being lifted in the RCA
and the risk of loss of the radioactive contents is increased
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because of this.
The inspector also discussed that procedure KM/D/0015/01 did not
appear to be approved by the licensee.
Licensee HP
representatives indicated (1) that they did not consider the
vendor's procedure to be accepted plant procedure, (2) that they
had never experienced a vacuum separation problem, and (3) that
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economical considerations had also played a factor in not
formalizing the handling of vacuums. The inspector informed the
licensee that the failure to review and approve the procedure by
appropriate authority was a violation of TSs 6.8.1 and 6.8.2
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(VIO: 50-369,370/93-08-02).
Two violations were identified.
8.
Instrumentation (83750)
During tours of the plant, the inspector noted that friskers and
contamination monitors had up-to-date calibration stickers and had been
source-checked as required.
In addition, the licensee appeared to
possess an adequate number of survey instruments and related equipment
with only a small number out of service and in need of repair.
The licensee reviewed and discussed the licensee's increased usage of
DADS for all entries into the RCA. The inspector reviewed the issuance,
tracking, calibration and maintenance of the DADS as well as the
calibration system and the computerized DAD reader system. The licensee
maintained approximately 1600 DADS.with a certain fraction out of
service for calibration / maintenance at any given time. An issue was
also discussed regarding a problem identified by a major DAD vendor in
which certain hardware / software combinations caused double dose to be
reported. The licensee was aware of the problem and had taken
appropriate action. No problems were noted with the licensee's methods
or procedures.
No violations or deviations were identified.
9.
Program for Maintaining Exposures As low As Reasonably Achievable
(ALARA) (83750)
10 CFR 20.1101(b) requires that the licensee shall use, to the extent
practicable, procedures and engineering controls based upon sound
radiation protection principles to achieve occupational doses and doses
to members of the public that are as low as reasonably achievable
(ALARA).
During tours of the lower level of Unit 1 Containment Building, the
inspector noted that the entry to containment was posted as a high
radiation area.
But very few areas in the lower level would meet the
true definition of an area with dose rates greater than 100 millirem per
hour (mrem /hr) at 12 inches.
In addition, there were no signs
signifying radiation dose rates in dose-intensive areas.
The licensee
had posted hot spot areas and some heavily shielded components bore a
sign that read "significant dose contributor." However, dose rate signs
to inform the worker were not evident.
In discussions with the
inspector, licensee representatives indicated that the difficulty of
providing barriers in an ice condenser containment was too great
regarding radiation versus high radiation areas. The inspector
discussed with the licensee the potential dose reduction benefits of
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providing additional dose information for the worker in the way of dose
rate signs to better inform workers not only of dose rates in their
immediate work area, which all people when questioned responded
properly, but of increased dose rates in areas between 5 and
100 mrem /hr, and in areas to/from their job site.
The inspector reviewed the licensee's collective site dose. As of
May 19, 1993, the licensee had accumulated approximately 185 person-rem
for the year, well below the to-date projected dose of 227 person-rem.
The licensee's outage dose goal was 250 person-rem, which was
established after all of the outage job dose estimates were added to
give a total estimate of 277 person-rem for the outage.
Essentially all
of the dose accumulated thus far in 1993 was due to the outage, and a
Unit 2 outage is planned for later in the year.
The licensee's 1993
total collective dose goal was 502 person-rem.
Barring any unforeseen
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problems, it appeared that the licensee would end 1993 well within their
dose goal. No problems were noted with the licensee's dose estimating
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or tracking.
The inspector reviewed and discussed other ALARA-related topics and
initiatives. These included " soft shutdown," temporary and permanent
shielding, ALARA awareness training, ALARA planner training, and ALARA
procedures, in general. The ALARA group was allowed time as needed
(approximately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) at the beginning of an outage to maximize the
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effectiveness of using peroxide shock / lithium injection for soft
shutdown and crud removal.
Shielding packages were more " standardized"
for easier approval as well as installation / removal.
No problems were
noted with the licensee's procedures or methods and, overall, the
licensee appeared to be saving significant dose due to ALARA efforts.
No violations or deviations were identified.
10.
Followup on Inspector Followup Items (IFI) (92702)
(Closed) IFI:
50-369,370/92-17-01, Provide ALARA pre-job planning
familiarization training to newly assigned job planning personnel.
The inspector reviewed the licensee's actions taken in response to the
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IFI and found them to be adequate.
The licensee incorporated the ALARA
familiarization training into the Station ALARA Manual.
Department
supervisors, technicians, engineers and others who may be involved in
the ALARA aspects of job planning were required to receive the training.
In order to better communication and tracking, the ALARA training
program and implementation was added to the responsibilities of the
plant Training Department.
No additional concerns were noted by the
inspector and this item is considered closed.
11.
Exit Meeting (83750)
At the conclusion of the inspection on May 21, 1993, an exit meeting was
held with those licensee representatives denoted in Paragraph 1 of this
report. The inspector summarized the scope and findings of the
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inspection. The inspector discussed the two violations listed below and
identified and that one IFI was closed as discussed in Paragraph 10 of
this report. The inspector received no dissenting comments; however,
the Radiation Protection Manager did not feel that procedures were
needed for vacuum cleaners utilized for radioactive materials because no
problems had been experienced to date.
Item Number
Descrintion and Reference
50-369/93-08-01
VIO - Licensee failed to label
radioactive material containers in
Unit I containment (Paragraph 7.c).
50-369,370/93-08-02
VIO - Licensee failed to implement
safety significant requirement
regarding control of vacuum cleaners
and failed to have appropriate
authority approve procedure
(Paragraph 7.c).
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