ML20058A494
| ML20058A494 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/08/1993 |
| From: | Bores R, Joseph Nick NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A482 | List: |
| References | |
| 50-289-93-23, NUDOCS 9312010101 | |
| Download: ML20058A494 (10) | |
See also: IR 05000289/1993023
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
Report No.
10.-289/93-23
Docket No.
50-289
License No.
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Licensee:
GPU Nuclear Corporation
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Middletown. Pennsvivania 17057-0191
Facility Name:
Three Mile Island Nuclear Station
Inspection At:
Middletown. Pennsylvania
Inspection Period:
October 4 - 8.1993
Inspector:
O.
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88 0 D
J. Nick,/ Radiation Specialist
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Facilities Radiation Protection Section, DRSS
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Approved by:
///08/93
R. BorefChief
Date
Facilities Radiation Protection Section, DRSS
Areas Inspected: Radiological controls during a planned shutdown of plant operations for n: fueling
and maintenance. Program elements reviewed included organization and staffing levels, staff
qualifications and training, external exposure control, internal exposure control, radiological
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surveys, radiation protection logs and records, and ALARA planning.
Results:
The radiological controls program was generally very effective in protecting the safety
of workers in radiological areas. Areas toured in the facility were well maintained and exhibited
good housekeeping. The mdiation protection group was staffed by qualified individuals with
documented tmining and qualifications. Improvement was noted in beta dose mte surveys for entries
into the reactor building during power opemtions. Weakness was noted in control of High Radiation
Areas and documentation of contractor health physics technicians' qualifications. One violation was
identified regarding access control of high radiation areas and is described in Section 3.0 of this
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report. Another non-cited violation involving controls to a locked high radiation area was identified
by the licensee and is described in Section 11.1 of this report.
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9312010101 931112
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ADOCK 05000289
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DETAILS
- 1.0
Individuals Contacted
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1.1
Licensee Personnel
- G. Broughton, Director, TMI Unit 1
- D Etheridge, Manager, Radiological Engineering
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- E. Hammond, NSCC
- E. Houser, Radiological Controls Training
- G. Keuhn, Director Radiological Controls / Occupational Safety
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- A. Miller, Acting Manager, TMI Licensing
B. Parfitt, Radiological Engineer
A. Paynter, Radiological Controls Field Operations Manager
L. Poppenwimer, Engineering Associate
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- W. Potts, Radiological Controls / Occupational Safety Director
P. Velez, Radiological Controls Field Operations Manager
- S. Williams, NSCC
1.2
NRC Personnel
D. Beaulieu, Resident Inspector
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1.3
Other Personnel
- R. Janati, Nuclear Engineer, Pennsylvania DER /BRP
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- Denotes those present during the exit meeting
2.0
Puroose
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The purpose of this announced inspection was to assess the licensee's implementation of
radiological controls during an outage period.
Program elements reviewed included'
organization and staffing levels, staff qualifications and training, external exposure control,
internal exposure control, radiological surveys, radiation protection logs and records,~and
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.ALARA planning.
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3.0
Facility Tours
The inspector toured many of the radiologically controlled areas (RCAs) of the facility
including the reactor building, the spent fuel pool area, the turbine building, and radwaste
processing. Most areas were generally well posted and exhibited good housekeeping. Some
minor discrepan'cies in postings were identified to the licensee's radiological controls staff.
These discrepancies were resolved and were verified by the inspector during subsequent
tours.
High Radiation Area (HRA) postings and barriers were checked throughout the facility. All'
areas were posted as requin:d by NRC regulations.
Most areas were appropriately
barricaded and all areas were locked as required. However, the inspector expressed concern
regarding control of high radiation areas. One area was identified by the inspector as having
inappropriate controls to prevent inadvertent entry into the HKA. The area observed was
a ladder leading to a platfonn approximately 10 feet above the floor where dose rates
exceeded 100 millirem per hour during fuel tnmsfer opemtions. The ladder was posted with
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a HRA sign hanging from one nmg of the ladder. There was no barricade at the bottom of
the ladder or on the platfonn at the top of the ladder. The inspector was concerned that
workers could inadvertently enter the HRA without noticing the posting hanging behind the
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ladder.
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The licensee took prompt initial corrective action that included downgrading the area to a
mdiation area since the fuel transfer operations had been completed, removing the HRA
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posting from the ladder, and writing a memo to all radiological controls staff members on
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the correct method for access control of any HRA reached by a ladder. Additionally, the
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licensee's plant staff requested additional training on this issue for health physics technicians
by the licensee's training staff.
Other examples of improper control of HRAs were observed by the inspector during
subsequent tours of the licensee's facility. Seveml HRA postings and barriers in the reactor
building were moved or repositioned by workers and not placed back in their original
positions. The areas were marked by a step-off pad on the floor and a swing ann gate with
an HRA posting. The inspector observed that two swing ann gates were propped open
against a wall or railing with the posting facing the away and not visible to someone entering
the HRA. In another instance, the entire swing ann gate was moved about five feet away
and to the side of the step-of' pad so that it did not barricade the entrance to the HRA.
Work was being performed ir the MRA, but the inspector did not observe any personnel
enter the HRA during the time period that the barriers were out of place. The licensee stated
that radiological area workers may ha ve moved the swing ann gates to facilitate the removal
of equipment or scaffolding from th, HRA.
After identification by the inspector, the siansee rearranged the swing ann gates so that
workers could not prop them open. Other barriers were moved to facilitate entry and exit
while still controlling access to the HRA. The licensee also briefed radiological area
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workers on the importance of the barriers and the requirement to contact the radiological
controls staff if a barrier needed to be moved or left open for an extended period of time.
The inspector was concerned that the initial radiological worker training given to the workers
did not stress the importance of the HRA controls. For many contmc* ors, this training was
given four to six weeks prior to the period of this inspection.
In the aggregate, these examples of improper control of HRAs are an apparent violation of
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the licensee's Technical Specifications that require each HRA to be barricaded and
conspicuously posted (50-289/93-23-01).
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4.0
Organization and Staffing
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The most significant change to the licensee's organization since the last inspection was the
replacement of the Radiological Controls / Occupational Safety Director. The director had
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oversight of the managers of Radiological Engineering, Unit 1 Radiological Controls Field
Opemtions, Unit 2 Radiological Controls Field Operations, and Occupational Safety. The
previous director was transferred to another facility and the new director assumed the duties
in early 1993. A review of the new director's resume' and qualifications revealed that the
individual is well qualified based on documented training and experience.
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The licensee had augmented the pennanent staff of 14 technicians with approximately 44
technicians for radiological controls during the plant refueling outage. The temporary staff
was comprised of 34 senior technicians,10 junior technicians, and additional technicians for
dosimetry or other specialty areas. Additional technicians were reassigned from their nonnal
mdiological control duties at Unit 2 to help during the' outage period _ at Unit 1.
The
inspector concluded that the staffing levels were adequate for the scope of work perfonned
during the refueling outage.
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The licensee maintained nine supervisors to direct the activities of the pennanent- and
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contractor health physics technicians during the plant outage. The General Radiological
Controls Supervisor (GRCS) staff included seven pennanently assigned personnel and
personnel on temporary assignment from the training staff. These tmining staff individuals
were required to work a minimum three days per calendar quarter as GRCS to maintain their
plant knowledge. The individuals also maintained the same qualification requirements as
pennanently assigned GRCS staff. The licensee stated that this policy kept the instmetors
infonned about changing plant processes and gave the training staff additional credibility with
their students who were mainly plant Radiological Controls Technicians. Additionally, one
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GRCS from Unit 2 was used on a part time basis during the outage. The inspector found
the supervisory oversight of radiological control activities very good.
The Radiological Engineering staff assisted the GRCS staff during the outage by providing
assistance in dose calculations, ALARA reviews, and other technical areas. The staff was
placed on shifts to provide assistance at all times.
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5.0
Training and Oualifications
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The inspector reviewed a mndom. selection of the tmining and qualification records for-
contractor health physics technicians. As per the licensee's procedures, all technicians were
required to pass a screening examination, attend approximately two weeks of procedures-
training, read required reference materials, and pass a qualifications examination prior to
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perfonning health physics duties. Senior health physics technicians were required to obtain
an 80% grade to pass the qualifications examination, while junior technicians were required
to obtain a 75% gmde. Specific on the job training (OJT) was required for the areas to
which the technicians were assigned and a qualification record was signed by an approved
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OJT instmetor/ evaluator.
All contractor technicians were qualified for the duties they were assigned as per the training
documentation. Approximately thirty technicians' training and qualifications records were
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reviewed. Training attendance sheets, test results, and evaluator's signatures for task.
qualifications were reviewed. Most records were completed and documented as required by
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the licensee's procedures. Two contractor technicians' qualification cards were not found
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in the training files. In subsequent discussions with the employees, the licensee staff
detennined that the documentation was not completed but the individuals were qualified.
The licensee completed these records during the period of this inspection. The licensee did
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not have a process to ensure that all qualification documentation was completed and placed
in the training files. It was not clear to the inspector, nor to licensee personnel, who had
the responsibility to ensure that the qualification records -were completed before the
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technicians perfonned their new job duties. This was identified as a minor weakness in the
tmining and qualification process.
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6.0
External Exposure Control
The inspector observed workers in the RCA wearing their assigned self-reading dosimeter
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(SRD) and the whole body thennoluminescent dosimeter (TLD) with the correct body
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placement. The licensee had an onsite laboratory to process whole body TLDs. This
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allowed a good response time for obtaining official personnel dose from TLD results. The
licensee's procedures required the issuance of at least one alanning SRD to a work pany
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when individuals entered an HRA. The inspector observed all individuals in the HRAs with
an alanning SRD assigned to their work party. -One work pany was observed by the
inspector as they removed scaffolding from the "D ring" enclosures around the steam
genemtors, pressurizer and reactor coolant pumps'. The workers were on several different
elevations forming a line to pass the materials fmm one location to another. The work group
consisted of approximately seven workers. The worker located next to an area of higher
radiation dose rates or " hot spot" was wearing the alanning SRD. ' The inspector found this
practice acceptable because the alanning SRD was used to indicate to the workers when they
had reached a maximum stay time based on accumulated radiation dose. In this case, the
alann would sound when the dose was accumulated by the worker in the higher dose rate '
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area and the dose to the other workers would be lower. This method could fail if the worker
with the alarming SRD for the work pany was not in the highest dose rate area, or if a'
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worker left the work group. However, the workers were generally aware of areas of higher
dose rates and each worker was monitored by an individual SRD and TLD.
The inspector reviewed records of extremity and multiple whole body TLD assignments and
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dose totals. The licensee's procedure required the issuance of extremity TLDs to workers -
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when the extremity dose was expected to be four times higher than the whole body dose and
the total dose was expected to exceed 1000 millirem. The licensee's procedures contained
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the requirement for issue of multiple whole body TLDs whenever a single TLD could not
be used to adequately assess the dose to the whole body. This would include circumstances
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where dose rates were non-unifonn or the dose to any part of the whole body- was
significantly higher than dose to the nonnal monitoring location (i.e. upper torso). The
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licensee had assigned multiple whole body TLDs for specific jobs that had non-unifonn dose
rates to different pans of the workers' bodies. The extremity and multiple whole body TLDs
were assigned to approximately 200 workers and the dose assignments were well under the
regulatory limits. The highest extremity dose assignment to an individual was 1295 millirem
for the calendar quarter, although some TLDs were still not processed. The NRC regulatory
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limit for dose to the extremities is 18,750 millirem per calendar quaner.
The licensee's procedure required calculations for dose assignmem from skin contamination
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or from discrete radioactive particles found on the workers' skin or clothir,g. The inspector
reviewed selec'ed records of events when contamination was found on workers during the -
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frisking process. The licensee had perfonned the calculations for skin dose assignment for
the records selected. The highest skin dose assessment reviewed by' the inspector involved
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a discrete radioactive particle on a worker's earlobe. The panicle was comprised of
radioactive isotopes cobalt-60 and manganese-54. The licensee assigned a skin dose of 2240
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millirem to the worker for less than a hour of estimated exposure.
This skin dose
assignment is below the NRC regulatory skin of whole body dose limit of 7500 millirem per
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calendar quader. Other incidents of radioactive contamination and skin dose assignments.
were very well documented.
7.0
Intemal Exposure Control
The control of internal exposure control was inspected through a review of air sample -
results, internal dose assignments, the presence of air sampling instruments in the work
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locations, and the use of respimtors or other engineering controls. Estimated internal dose
was assigned to workers based on the results of air samples in the work areas. Air sample .
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results were calculated in Maximum Pennissible Concentrations (MPCs) and multiplied by-
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the time spent by the worker in the area to obtain MPC-hours. After an individual had
accumulated greater than 2 MPC-hours in any one-day period, the individual was contacted
for a bioassay detennination. The dose calculatcJ from the bicassay replaced the estimated
dose assigned from the air sample results. The inspector reviewed the results of several
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bioassays to verify the dose assignments. The dose assignments from the air sample were
conservative, and most individuals were not assigned any significant dose from the bioassay
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detennination. The highest internal dose assigmnent for the outage period was 22.5 MPC-
hours and the NRC regulatory limit is 520 MPC-hours per calendar quarter.
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The inspector observed air sampling equipment in the work place when it was appropriate.
Air filtmtion and air handling units were also placed in many areas 'to provide better
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breathing air in potentially contaminated areas. The inspector did not observe work in any.
areas that required ventilation or filtration without the units. The licensee had attempted to
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restrict the use of respirators when possible due to ALARA dose concerns. ' The radiation
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protection staff believed that in many circumstances the individuals would receive ~ ore
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whole body exposure when wearing respirators than when perfonning the same job without.
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wearing respirators, and the historical data on some jobs had shown very little internal dose
potential. The licensee stated that respirator usage had decreased from 6% during the last '
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plant refueling outage to 3% during the current outage period without a significant increase
in internal dose assignments. Overall, the inspector concluded that the licensee provided
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adequate control of internal exposure to the workers.
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8.0
Radiation Surveys
The inspector reviewed selected radiological survey documentation for various areas of the
licensee's radiologically controlled areas (RCAs). The survey records were completed by
fully qualified technicians and reviewed by supervision. Current dose rate and contamination
- results ~were used to generate Radiation Work Pennits (RWPs) for the survey. areas.
Radiation survey records and RWPs were posted on the walls at the entrances to the RCA.
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The selected records were completed according to the licensee's procedure requirements.
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The inspector found that the documentation of radiation surveys was adequate.
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9.0
Radiation Protection Locs and Records
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Radiation protection logs kept at the access control points were reviewed by the inspector.
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The logs contained general infonnation such as personnel assigned to particularjobs and job -
specific updates. The radiation protection logs contained useful and accumte infonnation.
In addition, the GRCS staff maintained an electronic log that could be viewed from various
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locations on the licensee's mainframe computer. This log contained general radiological
controls updates, supervisory waivers, recent mdiological events, and other items ofinterest.
The licensee stated that the electronic log was a useful tool for management awareness of
radiological events and updates.
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Air sample records were maintained in a log including personnel assigned to the airborne
mdioactivity area, work start and end times, volume for air samples, work area of the
sample, the technician's name who perfonned the air sample, and a summary of air sample-
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results.
The inspector found good attention to detail with all entries completed by
technicians and verified by a GRCS.
10.0 ALARA Plannine
The licensee's Radiological Controls program contained several components to maintain
personnel radiation exposure As Low As Reasonably Achievable (ALARA). The licensee
held monthly Radiation Awareness Meetings where Radiological Controls staff members
presented ALARA and other radiological infonnation to department representatives. The
depanment representatives took this infonnation back to their respective Apanments for
distribution.
The GRCS staff and the Radiological Engineering staff prepared ALARA reviews of jobs
and tasks perfonned in the RCA. ALARA reviews for major tasks and jobs were assigned
to one of the Radiological Engineering staff members. Job supervisors and job planners
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were also included in ALARA reviews. The licensee's staff had prepared and issued over
30 ALARA reviews for the refueling outage period.
The licensee distributed Monthly Status Reports and exposure track.ing repons to keep the
licensee's staff aware of personnel exposure to workers on each job and ovemil personnel
exposure totals. The reports also included perfonnance summaries, highest individual
radiation doses, numbers of Awareness Repons and Radiological Investigative Repons,
numbers of positive whole body counts, numbers of skin and clothing contaminations, total
square feet of contaminated and airborne radioactivity areas, and a summary of audit / action
items. ALARA goals were co'mpared to actual personnel exposures and displayed in graphs
and charts. The ALARA reports stated the total estimated personnel exposure slightly above
the target goal for data current through 10/3/93. The total accumulated exposure for the
outage period was 133.090 person-rem, which was below the overall outage goal of 175
person-rem. The highest individual accumulated dose for a calendar quaner was 1072
millirem during the period of the outage. The inspector found the reports to be good quality
with valuable infonnation to the staff and radiological area workers.
I1.0
Other Items
11.1
Failure to Maintain a Locked Hich Radiation Area
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The licensee generated a Radiological Investigative Repon (RIR) to document an incident
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when a locked HRA was left unlocked and unguarded. The incident happened on September
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27, 1993 when a Radiological Controls Technician (RCT) left the steam generator upper
enclosure without placing the padlock on the steam generator manway shield. Instead of
locking the manway shield, the RCT put the padlock on one of the two enclosure doors
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leading to the genemtor. This left the second door to the enclosure and the manway
unlocked. The area was not positively controlled for a period of approximately two hours
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until another RCT found the mistake and controlled access to the area. The licensee stated
that there were no unauthorized entrie.s to the enclosure during this short period of time
because the second door was taped shut and the tape did not appear disturbed.
The licensee took immediate actions to correct the situation including controlling the area and
notifying supervision. The licensee also initiated an investigation to detennine the root cause
of the event and prepare recommendations for long - term corrective actions.
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investigation perfonned by the licensee's staff concluded that the root cause of this incident
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was inadequate awareness by the RCT. The technician had perfonned this task before
without any problems and was not concentrating in this circumstance. The recommendations
for long tenn corrective actions included making the enclosure door hasp unable to accept
the padlock, briefing all RCTs on the correct locations for locking the steam generator
barriers, and securing the second entmnce to the enclosure to minimize the severity of a
similar occurrence.
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Since the dose rates inside the steam generator were potentially greater than 1000_ millirem
per hour, this was an apparent violation of the licensee's Technical Specifications 6.12.1.b
that requires any area accessible to personnel with dose rates greater than 1000 millirem per
hour to be locked or guarded to prevent unauthorized entry. This violation will not be
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subject to enforcement action because the licensee's effons in identifying the violation and
effective corrective actions meet the criteria specified in Section VII.B. of the NRC '
Enforcement Policy,10CFR2, Appendix C.
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11.2 Beta Dose Rate Surveys in the Reactor Building
The licensee's method for monitoring beta dose for reactor building entries with the reactor
at power was a concern in a previous NRC inspection (50-289/92-02). The inspector had
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expressed concern because the TLD used for reactor building power entries was not capable
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of detecting beta radiation energies. The licensee had responded that they calculated the
assigned dose from noble gases and performed dose rate surveys for beta contamination
during reactor building entries at power. However, the frequency (i.e. annual) of the dose
rate surveys from beta contamination was detennined to be inadequate. The licensee had
committed to perfonn the beta dose rate surveys quanerly and when specific work was
scheduled; this commitment was documented in NRC Inspection Repon number 50-289/92-
21. During the period of this inspection, the inspector attempted to verify that the licensee
had changed their procedures to incorporate these commitments. The licensee had revised
the procedure for monitoring beta dose rates in the reactor building in February 1993.
The inspector verified that the licensee had perfonned quarterly and job specific beta
contamination surveys for work in the reactor building during 1993. The licensee had also
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perfonned beta dose calculations for personnel exposed to noble gas in reactor building
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entries during 1993. The licensee's revised procedure also committed to perfonning a
calculation for dose assignment to personnel from beta contamination if the beta
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contamination survey was positive. The inspector identified at least one positive beta
contamination survey, but the licensee could not pmvide a beta dose calculation for personnel
who entered the area with beta contamination. The licensee was not certain of the corrective
action for this item of concem. Since the beta dose rates were very low, the inspector will
review this item in future inspections.
12.0
Exit Meetine
A meeting was held with licensee representatives at the end of the inspection period on
October 8,1993. The purpose and scope of the inspection were reviewed and the findings
of the inspection were discussed. The licensee acknowledged the inspectors findings.
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