ML20150D923
| ML20150D923 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 06/24/1988 |
| From: | Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20150D911 | List: |
| References | |
| 50-312-88-17, NUDOCS 8807140234 | |
| Download: ML20150D923 (10) | |
See also: IR 05000312/1988017
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-312/88-17
Docket No.
50-312
License No.
Licensee:
Sacramento Municipal Utility District
14440 Twin Cities Road
Herald, California 95638-9799
Facility Name: Rancho Seco Nuclear Generating Station
Inspection at Clay Station, California
Inspection Conducted:
June 6-10, 1988
Inspectors:
N
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6/)F/M
C. A. Hooker, Radiation Specialist
Da'te Signed
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Approved by:
O h Nib.
6/N
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G. P.
uh s, Chief
Date Slgned
Facilit s Radiological Protection Section
Summary:
Inspection on June 6-10, 1988 (Report No. 50-312/88-17)
Areas Inspected:
Routine unannounced inspection of licensee action on
previous inspection findings, control of radioactive materials and
contamination, ALARA, facilities and equipment, and review of licensee
reports.
Inspection procedures 30703, 92701, 92702, 83726, 83728, 83727, and
90713 were addressed.
Results:
In the areas inspected the licensee's program appeared adequate to
accomplish their safety objectives.
The licensees performance, overall,
appeared to be improving.
One apparent violation was identified in one area:
TS 6.9.2.1.2, failure to
submit a report (Paragraph 6).
8807140234 880624
ADOCK 05000312
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DETAILS
1.
Persons Contacted
a.
Licensee
- R. Croley, AGM, Technical and Administrative Services
- J.
Shelter, Director, Plant Support
- D. Keuter, Director, Nuclear Operations and Maintenance
- R.
Harris, Manager, Radiation Protection (RP)
- S. Crunk, Manager, Nuclear Licensing
- J. Reese, Superintendent, Radiological Health
S. Nico11s, Superintendent, Radiological Operations
R. Bowser, Superintendent, Radiological Technical Support
- R. Orthen, Supervisor, Health Physics / Chemistry Services (HPCS)
- H. Borter, Supervisor, Health Physics /ALARA
- G. Legner, Licensing Engineer
C. Podgurski, Supervisor, Respiratory Protection / Instruments
b.
NRC Resident Inspectors
- A. D'Angelo, Senior Resident Inspector
- P. Qualls, Resident Inspector
- Denotes individuals attending the exit interview on June 10, 1988.
In addition to the individuals noted above, the inspecto met and held
discussions with other members of the licensee's and contractor's staffs.
2.
Licensee Action on Previous Inspection Findings (92701 and 92702)
(Closed) Violation (50-312/87-22-01):
This violation involved the
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licensee's failure to provide ALARA training and ALARA inspections in
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accordance with facility procedures.
Based on review of training records
and ALARA surveillance reports and discussions with licensee
representatives, the inspector determined that effective corrective
actions had been implemented to prevent recurrence as stated in the
licensee's timely letter dated September 10, 1987.
Paragraph 4, below,
also discusses this matter.
The inspector had no further questions
regarding the licensee's corrective actions.
(Closed)' Follow-up (50-312/84-27-01):
This item involved the need to
review the licensee's program for operating their new low-level waste
storage facility.
Based on the observation described in Inspection
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Report No. 50-312/88-13, and review of the operating and waste handling
procedures for the facility, the inspector considered this matter closed.
(Closed) Follow-up (50-312/88-42-03):
This item involved a licensee
commitment to perform a system review and initiate a program to ensure
that valves on process and ef fluent monitors were properly labeled and
identified on "System Piping and Instrument Diagrams." During this
inspection, the inspector determined that actions regarding this
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commitment had been implemented and the licensee expected to have the valve
-labeling completed within the next two weeks.
The inspector had no further
questions regarding this matter.
(0 pen) Follew-up (50-312/87-42-02):
This item involved the need to
review the licensee's reevaluation of line losses due to plateout of-
particulates and iodine in their gaseous effluent monitoring systems.
During this inspection, the inspector reviewed a licensee memorandum,
Incorporation of Plateout Correction Factors Into the Particulate and
Iodine Effluent Samplina Proqrams, dated May 3,-1988, and attached
contracted evaluation report with the calculated plateout line losses and
correction factors for effluent monitors R15044,.R15045, and R15546A.
The evaluation was performed using the analytical methodology outline in
American Natior,a1 Standard 13.01-1969, Guide to Sampl'na Airborne
Radioactive Material in Nuclear Facilities.
The. report. summarized
correction factors for normal effluent and Post Accident Sampling System
(PASS) lines.
The licensee's application of.these new corrections factors
in their sample analysis program needs to be examined; therefore, this
matter remains open.
(Closed) Follow-up (50-312/88-01-01):
Inspection Report Nos.
50-312/88-01 and 50-312/88-13 documented previous inspection ef forts
regarding the licensee's reactor coolant system Post Accident Sampling
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System (PASS) performance.
Inspection Report No. 50-312/88-13 documented
the need to review the licensee's resolution of problems associated with
differences in sample flow rate and errors in total dissolved gas and PH
for PASS in-line analysis.
Based on discussicn with cognizant licensee
representatives and review of recent test data. it appeared that the
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licensee had adequately resolved the flow rate, pH and total gas
discrepancies.
The flow rate differences were due to a restricted flow
path from debris found in pressure control valve, PCV-71503.
The
licensee also determined that the sample flow rate had no apparent effect
on total gas results.
The errors in pH measurements were apparently due
to calibrations being performed under static conditions and sample
readings taken during system flow. Test data on May 7, 1988, under
static conditions indicated that the RCS PASS pH result (6.27) was in
close agreement with the RCS Hot Lab's measured pH valve (6.26).
With
respect to total gas, the licensee determined that the sequence of valve
operation had a dramatic effect on the total gas results. . The licensee
also determined, using distilled water, that apparent residual nitrogen
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in the Volume A dead legs added about 42 cc/kg total gas to each sample
run.
Correcting for the additional 42 cc/kg in the system and new valve
sequencing, 48 PASS sample runs averaged about 43 cc/kg which was in
close agreement of the RCS Hot Lab's average results (39 cc/kg).
The
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inspector had no further questions regarding the licensee's RCS PASS
performance.
Based on the observations in this area, the inspector
determined tha the licensee has successfully satisfied the requirements
of Criterion 10 of NUREG-0737,-Item II.B.3.
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3.
Control of Radioactive Materials and Contamination, Surveys and
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Monitoring (837261
The inspector reviewed the licensee's program to determine their
compliance with 10 CFR Part 20. Technical Specification (TS) requirements
and recommendations outlined in various industry standards.
Audits and Surveillances
Quality Assurance (QA) Audit Report, No.87-056,
Radiological Safety Program Audit, dated October 22, 1987, was examined.
The audit conducted on September 8-18, 3987, was performed by a QA
auditorg and two contract technical-specialist.
The audit covered the
licensee's respiratory protection, dosimetry and radiological controls
programs.
The radiological controls area of the audit included receipt
of radioactive materials, radiation work permits (RWPs), contamination
control, and radiological surveys.
The audit identified nine items that
required corrective action.
The audit findings were primarily
administrative in nature and did not represent a significant safety
problem.
The' inspector confirmed that corrective action taken appeared
appropriate.
Surveillance Report, No. 2P 88-1172, Hot Particle Program Activities,
dated May 19, 1988, was examined.
The Surveillance was conducted by HPCS
during March 16-24, 1988.
The surveillance involved observations in the
following areas:
Laundry Operations
RKPs
Routine Survey Operations
Detection of Contamination
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Training
Use of Protective Clothing
Access Control Operations
Decontamination Operations
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Personnel Monitoring
Administrative Controls
The surveillance report noted that the Hot Particle Control Program
(HPCP)-related activities were adequately performed to meet regulatory
and procedural requirements, with the exception of minor discrepancies
related to site specific procedures.
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Changes
The 'icensee had made major changes in their RP Program primarily due to
the implementation of their HPCP.
The inspector noted that the licensee
had generated naw procedures and revised old procedures to reflect
changes in their program.
The following selected procedures were
reviewed:
RSAP-1104, Hot Particle Control Program, a new administrative
procedure dated March 21, 1988, that establishes the detection,
control, and outline management responsibilities for the licensees
HPCP.
RP.305,
Radiation Protection Plan, dated February 10, 1983.
RP.305.4,
Radiation Work Permits, dated March 21, 1988.
RP.305.7,
Area Definitions, Posting, and Requirements, dated
May 23, 1988.
RP.305.9,
Contamination Limits and Control for Plant Surfaces,
dated May 23, 1988.
RP.305.9A, Removal of Tools and Equipment From Controlled Areas,
dated May 23, 1988.
RP.305.9C, Decontamination Procedures, dated May 23, 1988.
RP.305.90, Personnel and Clothing Decontamination and Reports,
dated March 21, 1988.
RP.305.9E, Hot Particle Controls, detad March 21, 1988.
RP.305.16, Receipt of Radioactive Material, dated March 21, 1988.
Based on review of the above procedures, the inspector determined that
the licensee had appropriately made changes to implement controls to
imirove performance in their RP program to ensure compliance with
regulatory requirements and incorporate applicable items from IE
Information Notices.
The inspector noted that the licensee was installing two new whole body
Personnel Contamination Monitors (PCMs) on the grade level of the
auxiliary building.
The new PCMs will be utilized by personnel who have
worked in contaminated areas prior to suiting up in their street clothes
and exiting the control point on the +40 ft. level.
The inspector also noted that the licensee's training programs in
Chemistry, RP, Electrical Maintenance, Electrical Technician, Instrument
and Control Technician, Mechanical Maintenance, and Technical Staff had
recently gained accreditation from the Institute of Nuclear Power
Operations.
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Surveys and Monitoring and Contamination Control
During facility tours the inspector observed proper use of friskers and
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PCMs by workers exiting the radiologically controlled areas (RCAs).
Personnel contamination reports examined from January 1-June 7, 1988,
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were adequately documented,' evaluated and included in personnel exposure
record files.
Monthly reports.of the details of personnel contamination
are sent to facility managers and supervisors.
Routine surveys examined
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from April 25-June 7, 1988,'of the RCAs and normally nonradioactive
contaminated areas outside of the power block were performed'and properly
reviewed according to licensee procedures.
Routine trending surveys of
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specific areas in the RCA were being taken as a result of-resumption of
power operations after a long shutdown period to evaluate changes in
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plant systems.
Routine surveys also included checks for the presence of
not particles.
Selected RWPs were examined.
Attached survey records indicated that
adequate detailed radiation and contamination surveys were taken prior
to, during, and following work activities in hot particle zones (HPZs).
Pr'or to working in HPZs, workers are briefed and RP Supervisors must
complete a Supervisor HPZ Checklist to ensure that:
1) the area is
properly posted; 2) initial surveys have been performed; 3) frequency of
personnel curveys have been specified; 4) an RWP field review has been
completed; and 5) workers have been briefed.
The licensee's procedures
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also require that a RP Supervisor be on site when work is being performed
in HPZs.
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On June 1, 1988, during cleaning out of the "A" Regenerate Holdup Tank
(RHUT) water was spilled onto the black topped area around the tank due
to an apparent hose connection problem.
Licensee survey records
indicatedthatwipesofasmallamountofogservedfreestandingliquidon
the block top measured about 400 dpm/100 cm .
Wipesoftheareayhere
liquid had soaked through the blacktop indicated < 200 dpm/100 cm .
Subsequent direct scans of the area indicated that readings of about 100
to 1800 cpm, localized to a small area.
During these scan surveys of the
general area around the "A" RHUT, the licensee identified a few
non-smearable localized areas that measured 200-400 cpm.
The licensee
suspected that the contamination in these areas were not from the June 1,
1988, spill but rather the result from some previous operation.
The
licensee was taking measures to remove the contaminated blacktop.
In
addition, the licensee informed the inspector that since they had
suspected that some of the contamination around the tank was from
previous operations, they were making plans to perform detailed surveys
of areas where previous work on contaminated equipment had been performed
in locations exterior of the power block.
Records of sealed source leak tests performed in June and December 1987
were examined.
Leak tests were performed in accordance with TS 4.15.1
and 4.15.2.
Leak test results inJicated no ret.ults greater than the
0.005uCi limit.
Records of annual physical inventories of sealed sources
were maintained in accordance with TS 6.10.i.
During facility tours, the inspector noted that radiation survey and
monitoring equipment had current calibration dates.
The inspector
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identified no problems when a new'RP Technician, hired to calibrate.and
repair survey and monitoring equipment, was questioned as to his
knowledge of the operations and safety controls involved with operating
the licensee's instrument calibration facility.
This individua'i also
appeared to ~have a' good background for the type of work he was
performing.
The inspector also noted that the licensee had recently
replaced their old 130 and 1.0 Ci Cs-137 TLD calibration well sources
with new 10 Ci and 700 mci Cs-137 sources.
During previous operations
with the old sources the licensee experienced exposure levels of 20 mR/hr
in the adjacent instrument repair portion of the facility.
With the new
lower activity sources the maximum exposure level is only 2.0 mR/hr, with
the sources exposed.
The inspector also noted that the licensee had
installed a new pneumatic time delayed system for exposing the well
-sources which allows the operator time to exit.the room before the
sources are exposed.
Previously, the well sources were moved by a hand
crank that allowed the sources to be exposed before the operator left the
room.
With the new lower activity sources and new pneumatic operating
system, the licensee has greatly reduced the exposure levels to personnel
operating the sources and those working adjacent to the calibration room.
Regarding new controls for olant areas, the licensee informed the
inspector that in the near future all entries and exits into the tank
farm area will be controlled through the main grade level RCA access
control point.
This will provide for more positive control over workers
and operators who have been in contaminated areas and at will, could exit
the RCA through the tank farm without performing a personnel survey under
the current system.
During facility tours, the inspector made independent radiation
measurements using an NRC R0-2 portable ion chamber, S/N 2691, due for
calibration on July 16, 1988.
The inspector noted that radiation and
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high radiation areas were posted as required by 10 CFR Part 20.
Licensee
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access controls for high radiatiin areas were observed to be consistent
with TS, Section 6.13, and licentee procedures.
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The licensee's performance in this area appeared to be improving and
seemed capable of meeting their safety objectives.
No violations or
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deviations were identified.
4.
ALARA (83728)
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The effectiveness of the licensee's implementation of their ALARA program
was examined.
Audits and Surveillance
QA Audit Report, No. 87-A-107, ALARA Program, dated February 18, 1988,
was examined.
The audit was conducted November 30-D ember 11, 1987, and
consisted ~4f two auditors, which included a contract specialist.
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scope of the audit included a comparison of procedural controls to
regulatory requirements, evaluation of procedural implementation, and
follow-up on findings from previous audits.
The audit identified two
findings and two observations.
The audit findings did not represent a
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significant safety problem and the inspector verified corrective actions
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taken appeared appropriate.
HPCS Surveillance Report, No. AM3.ATI, ALARA Training, dated February 1,
1988, was also examined.
The surveillance findings involved the need to
make improvements in updating ALARA training lesson plan material and
expound on areas specific to the ALARA program.
The inspector noted that
recent changes in the licensee ALARA training program have effectively
addressed the surveillance findings.
Program
The licensee had established a goal of 350 person-rem for 1987 and
expended 299.8 person-rem.
The licensee's goal for 1988 is 250
person-rem and as of June 10, 1988, the licensee had used about 40
person-rem.
The licensee's long shutdown time, which lowered their
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source term, has been a uajor contributor in exposure reduction.
Inspection Report No. 50-312/87-E2, described several weaknesses in the
licensee's implementation of their ALARA program.
During the inspection
the inspector noted that the licensee had made a number of changes to
improve program performance and ALARA planning.
As of December 16, 1987,
the licensee had conducted extensive training with revised lesson plans
and handouts for supervisors, engineering and design review staffs.
The
licensee has also scheduled continued quarterly-training in this area.
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The inspector noted that the licensee's Maintenance Administrative
Procedure, MAP-0006, Work Request Planning, Revision 3, dated April 26,
1988, had been extensively revised.
Among other revisions, the licensee
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had included RP and ALARA planning in the initial phases of processing
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work requests.
The licensee was in the process of approving and issuing
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a new ALARA Policy, ALARA Manual and ALARA Planning Guidelines
implementing procedures to strengthen their program.
The inspector examined several work packages of tasks performed from
March-May 1988.
The inspector noted pre and post ALARA reviews were
appropriately conducted.
ALARA work logs, while work was . in progress,
supportive survey data and copies of RWPs were also maintained in the
work packages for use as data base material.
The inspector also noted
that the licensee utilized a computerized photo retrieval system to
assist in scoping out certain aspects of proposed work.
Based on observations, discussions with licensee representatives, and
procedure and records review, the inspector concluded that the licer.dee
appeared to be effectively implementing their ALARA program.
Since the
last inspection in this area, the licensee's performance appeared to be
improving.
No violations or deviations were identified.
5.
Facilities and Equipment (83727)
During this inspection the inspector observed that.the licensee had
relocated their dosimetry office and whole body counting trailer to a
location outside of the protected area.
The licensee has also made plans
to have all of the General Employee Training Programs relocated outside
of the protected area.
These changes will enable the licensee to have
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personnel fully trained and badged prior to entering the protected areas.
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The inspector identified no problems while touring the dosimetry office.
The licensee's purchase of new equipment was discussed in paragraph 3
above.
No violation or deviations were identified.
6.
Licensee Reports (90713)
Radiological Environmental Operating Report
The licensees 1987 Radiological Environmental Operating Report, dated May
2, 1988, was reviewed in-office.
The report was in issued in accordance
with TS 6.9.2.2, and provided the data and analysis for radiological
environmental samples and measurements in accordance with the program
described in Section 3.22 of the TS.
Comparison with preoperational data
dnd previous environmental surveillance reports supports their conclusion
that dose pathways, from the environment to man, did not significantly
inpact on plant environs during 1987, while the plant was in cold
shutdown, and there was no health and safety significance from plant
releases to the environment.
Airborne radioactivity was well below
regulatory action levels.
No gamma activity was detected from plant
related corrosion or fission products.
Direct radiation level
measurements with TLDs were the same as observed in their 1986
environmental report.
Algae samples, which reflect liquid effluent
releases to the environment, decreased significantly from 1986, but still
showed some measurable activity.
Uptake of activity on animal vegetation
and aquatic fauna, from past plant releases, are still evident although
the concentration was decreased compared to previous years data. Water
samples remained comparable with samples taken during 1985 and 1986,
although no gamma activity was found in drinking or runoff water.
The report also included maps and results of the licensee's participation
in the EPA Cross-Check Program.
Land Use Census results showed that
changes during 1987 principally involved residents at distances beyond
the five mile radius of the plant.
During the on-site inspection, the HPCS supervisor informed the inspector
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that on June 2, 1988, during a surveillarce test, it was discovered that
their new site liquid effluent monthly composite sampler was not
operating due to the pump being turned off.
The licensee's initial
investigation of the matter had concluded that the pump had not beer
turned on since Amendment No. 98 to the TS become effective in March
1988.
The sampler was placed in operation on June 2,1988, shortly after
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found to be inoperable.
TS Table 3.22-1, Item 3.a requires the
collection and analysis of this sample monthly.
TS 3.22, Action, Item a.
states, in part, that with the Radiological Environmental Monitoring
Program not being conducted as specified in Table 3.22-1, the licensee
must prepare and submit to the Commission, in the Annual Radiological
Environmental Operating Report (AE0P), a description of ti.e reasons for
not conducting the program as required and plans for preventing
recurrence.
The Inspector was informed by the HPCS supervisor that the
required report would be submitted in their 1988 AEOP.
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Semiannual Radioactive Effluent Release Report (SRERP)
The licensee's SRERP fdr the periud of July 1, 1987, through December 31,
1987 dated February 23, 1988 was reviewed in office.
This timely report
was issued in accordance with TS 6.9.2.3 and included a summary of the
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quantities of radioactive liquid and gaseous effluents and solid waste
released as outlined in NRC Regulatory Guide 1.2.
.The report also
included the dose due to liquid and gaseous offluents.. Do to the
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licensee's extended shutdown time, the doses were well below the 10 CFR 50, Appendix I values.
The report included-changes to the Process
Control Program and Offsite Dose Calculation Manual.
No errors or
anomalies were identified.
Annual Exposure Reports
Based on review of TS required reports the inspector made the following
observations.
Technical Specification 6.9.2.1.2, Annual Exposure Report, states
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"The Annual Exposure Report shall be submitted to the Commission
within the first calendar quarter of each calendar year in
accordance with the guide contained in Regulatory Guide 1.16."
Appendix A of Regulatory Guide 1.16 provides a format for reporting.
personnel exposures greater than 100 mrem per year by work and job
functions.
Based on discussions with cognizant licensee representatives, on
June 7, 1988, the inspector was informed that the required report
had not been submitted.
The data for the report had been prepared
by the RP Department and provided to the HPCS Department for
ultimate reporting.
However, due to apparent procedure deficiencies
the report had not been submitted.
The licensee took action to have
this report submitted.
Failure to submit the report by March 31,
1988, was identified on apparent violation of TS 6.9.2.1.2(50-312/88-17).
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The licensee appeared to be maintaining their previous level of
performance in this area.
The licensee needs to identify and correct
weaknesses in procedures and improve on attention to detail.
One
apparent violation was identified.
7.
Exit Interview
The inspector met with licensee representatives, denoted in Paragraph 1,
at the conclusion of the inspection on June 10, 1988.
The scope and
findings of the inspection were summarized.
The licensee was informed that one apparent violation of TS 6.9.2.1.2, was
identified.
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