ML20057G202
| ML20057G202 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/12/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20057G200 | List: |
| References | |
| 50-382-93-30, NUDOCS 9310210019 | |
| Download: ML20057G202 (12) | |
See also: IR 05000382/1993030
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-382/93-30
Operating license:
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Licensee:
Entergy Operations, Inc.
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P.O. Box B
Killona, Louisiana 70066
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Facility Name: Waterford Steam Electric Station, Unit-3
Inspection At:
Taft, Louisiana
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inspection Conducted:
September 13-17, 1993
Inspectors:
L. T. Ricketson, P.E., Senior Radiation Specialist
Facilities Inspection Programs Section
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D. Blair Spitzberg, Ph.D., Emergency Preparedness Analyst
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Facilities Inspection Programs Section
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Approved:
Date
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B. Kurray,
- hief', Facgl
ties Inspection
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Programs Section
Inspection Summar_y
Areas Inspected:
Routine, announced inspection of areas related to the
radiation protection program including audits and appraisals, program changes,
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training and qualifications, external exposure controls, internal exposure.
controls, and controls of radioactive materials and contamination.
Results:
Comprehensive quality assurance audits were performed by qualified
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personnel.
The timeliness of the radiation protection organization's
responses to audit findings had improved and the responses appropriately
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addressed the technical issues (Section 2.1).
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The radiation protection organization had low turnover (Section 2.2).
A good training program had been established for supervisors and
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professionals within the radiation protection group'(Section 2.3).
Excellent exposure control programs were implemented (Section 2.4).
9310210019 931015
ADOCK 05000302
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Two NRC identified violations (one cited and one non-cited) were noted
inolving skin contamination controls and inventory of radioactive
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sources (Section 2.6)
Several weaknesses were identified regarding radiation protection
implementirig procedures and technical reviews of survey instruments
(Section 2.6).
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During plant tours, good programs were observed concerning control of-
radioactive materials, contamination control, and surveys (Section 2.6).
Summar_y of Inspection Findings:
A noncited violation was identified (Section 2.6.1).
Violation 382/9330-01 was identified (Section 2.6.2).
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Violation 382/9322-01 was closed (Section 3).
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Licensee Event Report 382/92-015 was closed (Section 4).
Attachment:
Persons Contacted and Exit Meeting
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DETAILS
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1 PLANT STATUS
During the inspection, the plant was operating at 100 percent power.
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2 OCCUPATION RADIATION EXPOSURE CONTROL (83750)
The licensee's program was inspected to determine compliance with Technical
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Specification 6.8 and the requirements of 10 CFR Part 20, and. agreement with
the commitments of Chapter 12 of the Final Safety Analysis Report.
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2.1 Audits and Appraisals
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The inspectors reviewed the following Quality Assurance audits:
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SA-93-018B.1, " External and Internal Exposure Control and Dosimetry,"
performed June 30 through August 31, 1993.
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SA-92-018C.1, " Instruments, Process, and Area Monitor," performed
August 3 through August 31, 1992.
SA-93-024.1, "Radwaste Processing and Shipping" performed March 5
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through April 7, 1993.
The inspectors reviewed responses to the audit findings and determined that
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they were made promptly and were technically correct.
On previous
inspections, the inspectors had noted that responses were not timely.
The audit teams included personnel with health physics experience.
Some of
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the audit teams included personnel with technical expertise from the corporate
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office.
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At the time of the inspection, a special team was assessing the licensee's
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readiness to implement the new 10 CFR Part 20. The team was composed of
corporate personnel and technical experts from other power reactor sites.
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The inspectors also reviewed condition reports which were used to document
problems related to the radiation protection program. The condition reporting
system worked well to ensure that events were documented and reviewed and that
corrective actions were taken to prevent recurrence.
As an example, the
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inspectors noted that a Condition Report (93-81) was initiated promptly
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following the inspectors' observations on the licensee's heat stress program
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during NRC Inspection 50-382/93-22.
The condition reporting process resulted
in the identification of a possible plant-wide problem, and the root cause
analysis identified that supervisors were unaware of the meaning of part of
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the procedural guidance.
Part of the corrective action was to revise the
implementing procedure (UNT-007-019) to clarify its guidance and provide
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additional training to the first-line supervisors.
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To eliminate similar systems and possible confusion, the licensee discontinued
the use of quality notices as corrective action documents.
2.2 Changes
There were no substantive changes in the licensee's organizational structure,
equipment, or facilities.
Turnover in the radiation protection department was,
very low.
There was a new manager of Technical Services.
A new program involving portable radiation instrument calibration was
implemented.
The calibration of selected instruments was performed by
corporate personnel at a different power reactor site.
2.3 Training and Qualifications of Personnel
The inspectors determined that the licensee maintained a continuing, technical
training program for radiation protection supervisors and professional staff.
The training consisted of professional meeting attendance, vendor training, or
visitation of other power reactor sites by the professional staff members.
2.4
External Exposure Control
The inspectors observed that workers in the radiological controlled area wore
personnel dosimetry properly.
Individuals observed working in high radiation
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areas wore alarming dosimeters, as required by technical specifications.
The inspectors determined that the licensee's accreditation by the National
Voluntary Laboratory Accreditation Program (NVLAP) expires October 1, 1993,
and the licensee was unable to schedule a re-accreditation visit until
October 5-7, 1993.
The inspectors reviewed the licensee's dosimetry quality assurance / quality
control program and determined that the licensee participates in a program
with six other dosimetry users in which one member, on a rotating basis,
irradiates thermoluminescent dosimeters and provides them to the others for
processing and analysis of the results.
The licensee also received
thermoluminescent dosimeters from the University of Michigan on a quarterly
basis.
The dosimeters were exposed to radiation in one of the eight
categories sent and to the licensee for processing and analysis.
The
licensee's results agree closely with the reference values.
The inspectors interviewed workers to determine their knowledge of radiation
work permit requirements and reviewed computerized radiological controlled
area access records and determined that the individuals were working in
accordance with the proper radiation work permits.
On tours of the radiological controlled area, the inspectors reviewed area
posting and performed independent radiation measurements.
The inspectors did
not identify additional areas requiring posting or control.
The inspectors
noted that radiation survey results were posted at the entrance to rooms.
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This information was current and easy to read and understand; however, the
date the information was obtained was not included. Actual survey records
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included all necessary information.
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During 1992, the licensee recorded a total of 205.5 person-rems (as measured
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by thermoluminescent dosimeters). At the time of the inspection, the licensee
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had recorded approximately 11.76 person-rems (thermoluminescent dosimeter and
pocket ion chamber totals) for 1993.
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2.5 Jnternal Exposure Contrcl
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The inspectors determined that the licensee maintained a goed tracking system
for maximum permissible concentration hours.
No enrker had exceeded
regulatory limits.
Respirator use for the past year was low; however, the licensee maintained,
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ready for issue, a suitable quantity of respirators.
The licensee used a cascade system.for filling self contained breathing
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apparatus air tanks. The inspectors confirmed that the licensee had
certification that the air quality met grade D standards, as defined by
American National Standard Institute (ANSI)/CGA G-7.1.
The licensee also'
performed periodic testing of the bottled air and air from the breathing air
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system to confirm that it met the required standards.
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The licensee performed daily air sampling in several rooms in the radiological
controlled area. These areas were included with daily survey assignments.
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Particulate, iodine, and noble gas stack monitors were used to identify
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potential airborne problems in general areas of the radiological controlled
area.
Portable continuous air monitors were available for use on each level
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of the auxiliary building.
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Technicians were knowledgeable of whole body counting and calibration
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procedures. There were no uptakes by individuals in excess of investigational
limits.
Tritium urinalysis was performed onsite for divers working during the last
refueling outage.
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2.6 Control of Radioactive Materials and Contamination. Surveys. and
Monitoring
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2 6.1 Control of Materials
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The inspectors reviewed the radioactive source inventory records and
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determined that the licensee was delinquent in the performance of inventories
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of radioactive sources.
Technical Procedure UNT-005-021, " Radioactive
Material and Radioactive Source Purchase, Receiving, Surveying, Opening, and
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Disposal," states in Step 10.5.3, "All sources will be inventoried each six
months and documented on HP-RM-4, source inventory (Attachment 12.4)."
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Through a records review, the inspectors identified many sources which were
not inventoried ir, accordance with procedural guidance.
Examples are listed
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below:
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Source Control
No.
Inventory dates
0041079
5-21-92
3-11-93
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0191181
5-21-92
3-11-93
0190284
6-18-92
3-11-93
0300284
6-18-92
3-11-93
0181079
12-07-92
0041080
12-07-92
0261181
12-07-92
0110182
12-07-92
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The failure to inventory the sources on six-month intervals (plus or minus 25
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percent) was identified as a violation of Technical Specification 6.8 which
requires that the licensee maintain and follow procedures listed in Appendix A
of Regulatory Guide 1.33, including radiation protection procedures. After
the identification of this item by the inspectors, the licensee initiated
Condition Report 93-152 and proposed corrective action to prevent recurrence.
Because of the low safety significance and because the licensee presented-the
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inspectors with proposed corrective actions to prevent recurrence before the
end of the inspection, the NRC has elected to exercise discretion, in
accordance with Section VII (B)(1) of 10 CFR Part 2, Appendix C and not to
issue a Notice of Violation regarding this matter.
2.6.2
Control of Contamination
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During tours of the radiological controlled area, the inspectors observed
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three face shields lying in the containment spray header isolation valve area.
The area was controlled as a contaminated area.
Another face shield was noted
in a contaminated area on the upper level of the fue.1 handling building.
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inspectors discussed with licensee representatives the possibility of face
shields left in this manner being reused, resulting in facial contamination.
The inspectors reviewed reports of skin contamination events occurring in 1992
and 1993 and identified inconsistencies in the implementatior, of Procedure
HP-002-704, " Personnel Decontamination."
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The inspectors noted two cases of identified facial contamination, on
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September 25,1992 (Report 92-49), and on July 29, 1993 (Report 93-8), in
which no followup nasal smears were obtained.
Procedure HP-002-704, Step
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10.1.2.3. A, requires, in part, that for cases of skin contamination of the
facial area, that nasal wipes of each nostril be taken using cotton-tipped
swabs.
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In two other cases of skin contamination, surveys were not documented, and
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perhaps not performed, to verify that decontamination had been completed to
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levels below the acceptance criteria. Procedure HP-002-704, Step 10.1.2.6,
states, in part, that skin contamination is considered no longer present as
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evidenced by <100 cpm / probe area by direct frisk. When this limit can be met,
then the individual can be released. Final . surveys conducted of individuals
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with skin contamination on February 19, 1992 (Report 92-2), and July 29, 1993
(Report 93-8), reported the residual contamination following decontamination
as "<1000 cpm."
Therefore, these individuals may have been released before
the acceptance level for decontamination was met.
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The dates and times that resurveys were conducted following decontamination of
individuals were not denoted.on July 23,1993 (Report 93-9), and on
February 17, 1992 (Report 92-1).
Procedure HP-002-704, Step 10.3.3.6
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requires, in part, that part 2 of the Skin Decontamination Report be completed
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by denoting the date/ time the affected area was resurveyed after attempting
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decontamination.
Technical Specification 6.8.1 requires that written procedures be established,
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implemented, and maintained covering activities referenced in Appendix A,
(including contamination control and bioassay program) of Regulatory Guide
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1.33, Revision 2.
The failure to implement Procedure HP-002-704 is considered
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a violation of Technical Specification 6.8.1 (382/9330-01).
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Procedure HP-002-704 contained minor inconsistencies.
For example, Step 9,
the " Acceptance Criteria," consisted of the following statement:
Individual's skin / clothing contamination has been found to be less than
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100 counts per minute per probe area (above background) when measured on
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contact (less than 1/2 inch from surface) with a count rate meter and
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thin-window GM probe (e.g. Ludlum 177 with HP-210 probe or equivalent)
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is considered to be non-contaminate [d] .
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Step 10.1.2.6 of the procedure also lists this criteria, but adds, "or being
cleared by a TCH or a PCM-1."
The preceding does not appear in the general
acceptance criteria statement.
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The inspectors noted that no procedural guidance was available for nasal smear
acquisition and assay or for nasal smear action levels. Followup information
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of special whole body count results following skin contamination events was
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generally not recorded on the skin decontamination reports.
There was no
mechanism to actually ensure or verify that whole body counts were performed;
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however, the inspectors did not identify an example in which an individual was
instructed to get a whole body count and failed to do so.
The proposed corrective actions listed on the personnel contamination reports
often included a statement that the protective measures neededEto be
increased; however, few cases identified a root cause to be that protective
measures were not adequate, initially. Therefore, any trending performed by
the licensee of root causes would not have identified possible weaknesses in
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the establishment of protective measures, such as during the radiation work
permit preparation process.
The licensee reported 145 skin contamination events in 1992, a year which
included a refueling outage.
Through the time of the inspection, there had
been only 10 skin contaminations in 1993.
2.6.3
Surveying and Monitoring
On tours of the radiological controlled area, the inspector observed radiation
protection technicians performing surveys, collecting contamination samples,
analyzing the samples, and documenting the results of the surveys. All
actions conformed to good health physics practices.
The inspectors noted that survey maps were posted outside of each room in the
radiological controlled area.
The information was easy to read and
understand.
The date of the survey was not included; however, actual survey
records contained all necessary information.
Three area radiation monitors were inoperable.
None were required by
technical specification.
Calibration and repair of the monitors were the
responsibility of the instruments and controls group.
The inspectors determined that radiation protection counting and analyzing
equipment was properly calibrated.
A sufficient number of calibrated portable survey instruments were available.
Instruments observed by the inspectors had been response tested properly
before being used.
The inspectors observed radiation protection technicians
response test selected (beta sensitive) personnel contamination monitors, tool
monitors, and the (gamma sensitive) portal monitors.
Selected calibration
records were reviewed by the inspectors to confirm that calibration dates
listed on the instruments were correct.
When one neutron survey instrument (HP-DS-023) was returned to the
manufacturer for calibration on May 28, 1993, the "as found" calibration
readings were only 10 percent of the expected values.
Instrument
manufacturer's representatives then identified that this was caused by an
internal switch being improperly positioned.
The previous calibration date of
the instrument was July 30, 1992. The six-month period of use, therefore,
extended to approximately January 31, 1993.
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The license, at first, stated on September 16, 1993, that the instrument was
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not used for containment entries or determining stay times during its period
of use. The statement was based on a technical review performed after the
May 28, 1993, calibration results were known. When asked by the inspectors to
verify this, using the instrument response test records, the licensee
determined that the instrument had, in fact, been used on four occasions.
Because of this, the licensee determined that the original technical review -
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was inadequate and initiated a Condition Report (93-154) to document the
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situation.
Because of the lateness of these events in the inspection, the
licensee was not able to confirm this information and relay it to the
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inspector until after the exit meeting.
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The licensee's subsequent investigation revealed that the instrument was used
for reactor containment building entries on August 14 and 15,1992. Readings
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obtained with the instrument were in the normal range expected, based on
historical data. The instrument was used again on January 13 and 20, 1993 to
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perform radiation surveys in another part of the plant. Licensee
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representatives stated that the readings obtained during these measurements
were suspect, M hindsight, because of the number of significant figures to
the right of the decimal on the survey instrument's digital display (as
documented on survey records). Licensee personnel theorized that someone may
have tampered with the instrument during the period August 15, 1992 to
January 13, 1993.
Licensee representatives stated that no unexpected neutron
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exposures were recorded by personnel dosimetry during those activities in
which the survey instrument was used.
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The event demonstrated weaknesses in procedural guidance. The first example
involved the licensee's Technical Procedure HP-002-371, " Instrument
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Source / Response Check," Revision 3.
Section 10.5 of the procedure provided
guidance for response testing, specific to the neutron instrument. Step
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10.5.1.4 stated:
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"During normal operations, the noted response should be approximately
5 mR/hr.
Since this is a response check, there is no definitive range
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for the instrument response.
Therefore, responses that are questionable
should be brought to the attention of a Health Physics supervisor."
On January 13 and 20, 1993, the technicians using the neutron instrument
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recorded measurements of 0.6 mrem /h and 0.62 mrem /h, respectively, in the area
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where response tests are performed, yet did not consider these values to be
" questionable." This pointed to a lack of clear guidance provided by the
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procedure or inadequate training of the technicians in the use of the
procedure.
During a telephone conversation with one of the inspectors on
September 29, 1993, a licensee representative stated that a review of the
instrument response test records showed that readings of 1.8 to 4.9 mrem /h
were typically obtained with the instrument during response testing. He also
stated that part of the corrective action, proposed in the draft Condition
Report 93-154, will include the revision of Technical Procedure HP-002-371,
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" Instrument Source / Response Check," to provide clearer guidance to the
radiation protection technicians with regard to what constitutes a " definitive
range for instrument response" and what situations could indicate a problem.
The inspectors also observed that there was also a weakness in the licensee's
technical review program which did not identify that the instrument was used
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and did not, itself, initiate corrective actions or initiate another
corrective action document. The weakness may be the result of a another
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example of poor procedural guidance. Step 6.5.5 of Administrative Procedure
HP-001-210, " Health Physics Instrument Control," Revision 7, states:
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An instrument technical review using attachment 7.R c6-11 be performed
whenever an instrument calibration "As Found" ', .. of tolerance by
>20%.
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However, licensee representatives stated that discussions with radiation
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protection staff members indicated that they had a poor understanding of the
goal of a technical review. Attachment 7.8 of the procedure asks only for the
facts of what happened to the instrument.
It does not provide instructions to
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the user which might prompt him/her to ascertain the reasons for a problem or
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the possible consequences.
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3 CONCLUSIONS
Comprehensive quality assurance audits were performed by qualified personnel.
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The timeliness of the radiation protection organization's responses to audit
findings had improved and the responses appropriately addressed the technical
issues.
The radiation protection organization had stable staffing with very little
turnover.
A good training program had been established for supervisors and professionals
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within the radiation protection group.
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Excellent exposure control programs were implemented.
While generally good, programs for control of radioactive materials, control
of contamination, and surveying were sometimes handicapped by inadequate
procedural guidance.
In other cases, there was simply a failure to implement
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the procedures. Two violations were identified by the inspectors.
Specific
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problems were identified with radioactive source inventories, handling of
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contaminated personnel, and performance of survey instrument technical
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reviews.
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4 FOLLOWUP DN CORRECTIVE ACTIONS FOR VIOLATIONS (92702)
(Closed) Violation 382/9322-01 - Failure to Submit Waste Streams Samples for
Offsite Analysis
In addition to the chemical volume control system filter sample identified by
the inspector, the licensee identified that the Boron Management System waste
stream sample had not been submitted for offsite analysis. As corrective
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action, the licensee counseled the radwaste foreman in charge of the program
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in the sampling requirements set forth in Radwaste Procedure RW-002-110. The
procedure was then revised to clarify its requirements.
5 ONSITE REVIEW OF LICENSEE EVENT REPORTS (92700)
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(Closed) Licensee Event Report 92-015 - Desian Error Results in Radiation
Levels Hicher Than Previously Assumed
A discussion of this item was documented in NRC Inspection Report
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50-382/92-26.
The licensee's design engineering group discovered that the
radiation levels in the reactor auxiliary building wing areas, following a
recirculation actuation signal, would be significantly higher than originally
calculated. This was caused by the failura of the original calculations to
take into account the recirculation of highly contaminated coolant from the
sump through the containment spray and high pressure safety injection systems.
There is a 10-inch containment spray line and two 3-inch high pressure safety
injection lines in the wing area. The exposure rate calculations, based on
final safety analysis report source terms, showed exposure rates too high to
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allow valve operation while maintaining operator exposure to less than 5 rem.
Corrective actions taken by the licensee included the placement of shielding
blankets around the Containment Spray and Safety Injection system lines in the
-4 reactor auxiliary building wing area; the revision of calculations for the
NUREG-0737 post-accident shielding study; review of calculations to determine
equipment qualification dose requirements; and consideration of changes to
eliminate the need for personnel to enter the -4 reactor auxiliary building
wing area to close valves after a loss of coolant accident. Other long-term
corrective actions will include the replacement of the temporary shielding
with permanent shielding.
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ATTACHMENT I
1 PERSONS CONTACTED
1.1 Licensee Personnel
- J. Houghtaling, Technical Services Manager
- D. L. Hoel, Health Physics Supervisor
P. M. Kelly, Health Physics Supervisor
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R. C. McLendon, Health Physics Supervisor
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- D. A. Landeche, Lead Supervisor, Radiation Protection Support
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- L. W. Laughlin, Licensing Manager
- D. F. Packer, General Manager, Plant Operations
- J. A. Ridgel, Radiation Protection Superintendent
- R. I. Sebring, Senior Health Physics Technician
- C. J. Thomas, Licensing Engineer
1.2 NRC Personnel
- J. Dixon-Herrity, Resident Inspector
- Denotes personnel that attended the exit meeting.
In addition to the
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personnel listed, the inspector contacted other personnel during this
inspection period.
2 EXIT MEETING
An exit meeting was conducted on September 17, 1993.
During this meeting, the
inspector reviewed the scope and findings of the report. The licensee did not
identify as proprietary, any information provided to, or reviewed by the
inspector.
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