ML20153C125
| ML20153C125 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/19/1988 |
| From: | Hosey C, Weddington R NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20153C116 | List: |
| References | |
| 50-327-88-31, 50-328-88-31, IEIN-88-008, IEIN-88-8, NUDOCS 8808310239 | |
| Download: ML20153C125 (15) | |
See also: IR 05000327/1988031
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.Wi
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ATLANTA, GEORGI A 30323
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AU6 0 51988
Report Nos.:
50-327/88-31 and 50-328'88-31
Licensee: Tennessee Valley Authority
6N38 A Lookout Place
~1101 Market Street
Chattanooga, TN 3740? 2801
Docket Nos.: 50-327 and 50-328
License Nos.:
OPR-77 and DPF.-79
Facility Name:
Sequoyah 1 and 2
Inspection C nducted: June 6-10, 1988
Inspector:
M
7//7/@
R. E. WeddingTo~n
j
Date Signed
Accompanying Personnel t
C. H. Bassett
Approved by:
%
7 /7[h
C. M. Ho'sey, Sectipn Chief
Date Signed
Division of RadiatMon Safety and Safeguards
SUMMARY
Scope:
This was a routine, announced inspection in the areas of training and
qualifications, external exposure control, internal exposure control, control
of radioactive material and surveys, solid wastes, transportation, followup on
previous open items and NRC Information Notices, allegation followur
1d Units 1
and 2 Operaticoa' Readiness.
Results: The licensee's radiation protection program is adequate for routine
operations as well as the upcoming refueling outage of Unit 2.
The radiation
protection program is also adequate to support the startup of Unit 1.
Within
the areas inspected, the following violation was identified - failure to adhere
to or establish procedures for performing breathing zone air samples and for
exposure control during steam generator work, Paragraphs 3 and 4.
Three inspector identified items were identified concerning:
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hot particle control training fur employees, Paragraph 2.
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licensee development of hot particle control procedures. Paragraph 5.
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licensee action to improve coordination for insulation removal and
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replacement in radiological areas, Paragraph 8.
8808310239 880805
ADOCK 05000327
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
' *J. Flood, Health Physicist, Corporate Staff
- 0. Hickman, Manager, Radiation Protection Group
S. Holdefer, Supervisor, Radiological Control Technic,.. nection
- J. Kurtz, Quality Assurance Specialist
- J. LaFoint, Deputy Site Director
- S. Layendeeker, Health Physicist, Corporate Staff
J. Leamon, ALARA Engineer, ALARA Section
M. Littleton, Manager, Radiological Control Field Operations
J. Osborne, Supervisor, ALARA/ Health Physics Section
- M. Palmer, Superviscr, Radiation Health Section
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- R. Prince, Superintendent, Site Radiological Control
- T. Ritter, Engineering Assurance Engineer
- H. Rogers, Supervisor, Plant Operation Review Staff
- V. Shanks, Supervisor, Water and Waste Processing Group
- S. Smith, Plant Manager
- S. Spencer, Nuclear Engineer, Licansing
J. Steigelman, Supervisor, Radiological Surveillance Section
- L. Strickland, Supervisor, PLwer Operations Training Center
- J. Vincelli, Radiological Assessor
- K. Walker, Quality Evalaator, Site Quality Assurance
Other licensee employees contacted included engineers, technicians,
security office members, and office personnel.
Nuclear Regulatory Commission
- K. Jenison, Senior Resident Inspector
G. Humphrey, Resident Inspector
- Attended exit interview
2.
Training and Qualifications (83723)
a.
General Employee Training (GET)
The licensee is reouired b,10 CFR 19.12 to provide basic radiation
safety training for workers.
Regulatory Guides 8.13, Instruction
Concerning Prenatal Radiation Exposure, 8.27, Radiation Protection
Training for Personnel at Light-Water-Cooled Nuclear Power Plants;
and 8.29, Instruction Concerning Risks from Occupational Radiation
Exposure, provide an outline of the topics that should be included in
such training / retraining programs.
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The inspector and licensee representatives discussed recent
developments in the training program and current topics of interest
to the industry.
It was noted that one current topic of
significance, that of hot particles and hot particle control, was not
covered in GET or continuing training.
The licensee indicated that
the subject of hot particles and their control was being reviewed and
would likely be included in future GET and continuing training
courses.
The inspector informed the licensea that this issue would
be reviewed during a subsequent inspection. (50-527, 528/88-31-01)
No violations or deviations were identified.
b.
Radiation Control (Rad Con) Technician Training
The inspector and licensee representatives discussed the revisions'
that have been made to the Rad Con technician training program. The
entire program was revised and rewritten to provide more
comprehensive training for every technician.
The new program now
requires each Rad Con technician trainee to complete every section of
the training course which includes instruction in the basics of
health
physics,
dosimetry,
respiratory
protection
and
instrumentation.
The program also provides detailed performance
verification sheets or sign-off sheets that sp0cifically outline what
is required for job performance verification,
This also provides a
standardized criteria for supervisors to evaluate performance and
give a sign-off for completion of a task.
Once qualified, a
technician is able to function in any ra11ation control job at the
facility.
The licensee also indicated that the Institute for Nuclear Power
Operations (INPO) had recently performed an accreditation inspection
of the program and that they expected to be formally informed of
their program accreditation shortly.
No violations or deviations were identified,
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c.
Advanced Radiation Workers
The licensee's Advanced Radiation Worker program was also discussed.
It was noted that people with this type of training will not provide
their own radiological control job coverage but will have expanded
instruction of rad con principles and the instrumentation used.
Such
topics as glove bag and glove box usage, suppl'ed air usage,
contamination control, expanded coverage of biological effects of
radiation and the capabilities and limit. Lions of the instruments
used in radiation control will be covered.
A pilot program which
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w'.ll consist of one week of training for those managers and
supervisors inter !sted, is sc'.iduled to begin in July.
No violations or deviations dere identified.
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3.
External Exposure Control (83724)
a.
High Radiation Area Access Control
The inspector reviewed licensee procedure HPSIL-31, Radeon Personnel
Responsibilities During . Activities of Significant Radiological
Concern, Revision 2, May 23, 1988.
During a previous health physics
inspection (Inspection Report Nos. 50-327, ' 328/88-04) it wa's noted
that the procedure had been changed tc- require the Radiological
Controls Shift Supervisor (RCSS) to initial the radiation work permit
or timesheets for entries into areas greater than 1 rem / hour to
signify that appropriate controls were in place and that personnel
understood their responsibilities.
It. was noted that the RCSS
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sometimes makes or accompanies such high radiation area. entries and
che procedure did not clarify if the RCSS could approve his own entry
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or if a higher level of approval was required.
During this
inspection, licensee representatives stated that HPSIL-31 had been
changed to require approval by another RCSS or higher level
supervisor for entries made by the RCSS. The inspector reviewed the
procedure change that had been made and noted that in addition to
high radiation area entries, the section that _ contained the change
also discussed work involving wearing of self contained t.'reathing
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apparatuses, entries into airborne radioactivity areas and work
involving estimated worker doses in excess of 500 millirem. .It was
unclear if the new requirement in regard to the RCSS applied to just
high rar:iation area entries or to the other situations as well,
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Licensee representatives stated that the change had been intended to
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apply only to high radiation area entries and that the procedure
would be revised to provide clarification.
No violations or deviations were identified.
b.
Startup Surveys
Prior to the Unit 2 startup, the licensee had established and
published in an internal memorandum of March 16, 1988, a list of
areas that had the potential of becoming high radiation areas after
startup.
Shiftly surveys were required of these area. The inspector
reviewed baseline and startup radiation surveys performed in the
auxiliary building during May 1988, and performed independent
radiation surveys during the inspection.
Licensee postings were
consistent with licensee survey results and those of the inspector.
No violations or deviations were identified,
c.
Beta Radiation Exposure Control
Technical Specification 6.11 requires that procedures for personnel
radiation protection shall be prepared consistent with the
requirements of 10 CFR Part 20 and shall be approved, maintained and
adhered to for all operations involving personnel radiation exposure.
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10 CFR 20 201(b) requires that each licensee shall make or cause to
be made such surveys as (1) may be necessary for the licensee to-
comply with 10 CFR Part 20, and (2) are reasonable under the
circumstances to evaluate the extent of radiation hazards that may be
present.
The inspector reviewed records of surveys performed by the licensee
on June 7, 1988, during and following the removal of the manway
covers and diaphragm from the number two steam generator in Unit 1.
The surveys indicated the beta radiation levels just inside the
manway (opening were significantly higher than the gamma radiation
levels approximately 17 Rem / hour beta and 1 Rem / hour gama).
The inspector discussed beta radiation exposure control with licensee
representatives, who stated they assumed from past experience that
beta radiation exposure was not a problem during steam generator work
and that this fact was confirmed when the worker's thermoluminscent
dosimeters (TLDs) were read.
The inspector was also shown
documentation of three beta radiation studies that had been performed
by the licensee which concerned beta correction factors for portable
survey ins"ruments, the change in beta correction factors when
instrunnnte
! covered in plastic and the beta radiation attenuation
capability
the licensee's protective clothing.
The licensee
stated that
..ey had not performed attenuation studies with various
samples of clothing and eye protection to be worn by workers prior to
allowing access to the steam generator in order to evaluate the
adequacy of prescribed protective clothing and in order to assess the
need for other control measures such as beta radiation stay times.
Such evaluations are typically performed within the industry each
time a steam generator is accessed due to the potential for changing
radiological conditions.
The licensee had no procedure which
required these types of beta exposure control evaluations prior to
allowing access to the steam generator.
The licensee showed the inspector the four highest TLD dose values
from the multiple badge sets worn by workers during the steam
generator preparatory work. The records did not show any lens of the
eye dose greater than the whole body dose.
The licensee then performed an attenuation survey on the diaphragm
plate that had been removed from the Unit i number four steam
generator.
The survey indicated that the intensity of the beta
radiation field from the diaphragm was reduced from between sixty to
seventy-eight percent depending on the type of protective clothing
sample being used as a shield for the survey instrument.
The inspector stated that failure to have a procedure for performing
beta radiation exposure control evaluations prior to steam generator
work was an apparent violation of Technical Specification 6.11
(50-327/328/88-31-02).
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d.
Steam Generator Exposure Control
The inspector discussed with licensee representative the method used
to control worker doses for steam generator work.
The licensee
stated that when workers reported to the . control point at the
containment access, their stay time was computed by radiological
control personnel based on the individual's remaining dose available
of their administrative dose limit and highest contact beta-gamma
dose rates in the work area.
The stay time was phoned to the
radiological control technician at the steam generator access and was
told verbally to the worker.
The licensee showed the inspector an
in.ormal section notebook that contained guidelines for the
technicians to use in computing and administering stay times.
The inspector discussed with licensee representatives the need for
establishing in procedures the steam generator exposure control
guidelines and for providing documentation of the basis for the
calculated stay time, what the_ stay times were, the workers actual
time in the exposure area and exposure received.
Failure of the
licensee to have a procedure for computing, administering and
documenting work area stay times is an additional example of an
apparent
violation
of
(50-327/328/88-31-02).
4.
Internal Exposure Control and ,\\ssessment (83725)
a.
Uptake Investigation
10 CFR 20.103(a) requires the licensee to use measurements of
radioactivity in the body, measurements of radioactivity excreted
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from the body, or any combination of such measurements as may be
necessary for timely detection and assessment of individual intakes
of radioactivity by exposed individuals.
The inspector reviewed the licensee's investigation of an apparent
internal exposure of an employee to radioactive material that
occurred June 6, 1988.
During the afternoon of June 6, a contract
worker entered a tent that had been constructed in support of steam
generator work in Unit 1 containment. The steam generator (S/G) had
not been opened and the worker was to conr act some conduit / tubing in
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preparation for removing the S/G diaphragm and other associated work.
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After connecting the tubing and completing the assigned work, the
individual left the tent area, proceeded to the step off pad of the
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contaminated area, removed his protective clothing (PCs) and exited
containment.
As he was performing a personal contamination survey,
the individual noted contamination on his face varying from 300 to
600 counts per minute (cpm).
Rad Con technicians responded to the
scene and took nasal smears which showed contamination levels of
1,200 disintegrations per minute (dpm).
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Because of the facial contamination .and the results of the nasal
smears, the individual was given an initial whole body count (WBC) in
the licensee's stand-up whole body counter. The results indicated up
to nine percent (9%) of a Maximum Permissible Organ Burden (MP0B) of
Cobalt-60-(Co-60) in the lower torso before the individual showered.
Following a shower, the individual was given another WBC using the
licensee's chair whole. body counter which showed 3% MP0B of Co-60 in
the lower torso.
Two other people who had been working in the tent
area were'also given WBCs and they were determined to have MP0Bs of
from 2-3% of Co-60 in the lower torso as well.
The licensee
calculated a Maximum Permissible Concentration-hour (MPC-hr) exposure
of 0.5 MPC-hrs based on an uptake of 17 nanocurie? of Co-60.
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inspector reviewed the licensee's exposure calcula? ions and noted
that they appeared to be adequate.
The licensee determined that the uptake occurred as a result of the
worker handling some items that had been placed inside the tent in
sealed bags in preparation for the steam generator work.
The bags
had been opened at some point although the worker was told not to
open the bags and indicated that he had not done so. The Radiation
Work Permit (RWP) the individual was signed in on also had
instructions that did not permit opening any bags or handling any
contaminated items.
The items in the bags were contaminated to
12,000 dpm/100 cm2 with contact radiation levels of 50 millirem per
hour (mram/hr) beta and 30 mrem /hr gamma. The tent was not posted as
an airborne radioactivity area and Rad Con did not provide coverage
for the work since the tent was newly installed and had not yet been
used for radiological work; therefore, no air samples were taken
inside the tent during the time of the incident.
Following the incident, the licentee posted the tent as an airborne
radioactivity area and informed the oncoming crew of the problem.
Other individuals, who had been working in the same general area on
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the same RWP, were also given WBCs but no positive results were
reported.
The licensee was still evaluating further action with
regard to the individual involved.
The inspector determined the
licensees actions in this matter were adequate.
No violation or deviations were identified,
b.
Air Sampling
10CFR20.103(a)(3) requires the licensee to perform suitable
measurements of the concentrations of radioactive materials in air
for detecting and evaluating airborne radioactivity in restricted
area.
Technical Specification 6.11 requires that procedures for personnel
radiation protection shall be prepared consistent with the
requirements of 10 CFR Part 20 and shall be appr~ved, maintained and
adhered to for all operations involving personnel radiation exposure.
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Licensee Prr are, HPSIL-5, Airborne Radioactivity Surveys, Revision
30, dated April 1,1988, requires that air samples be placed as close
as pcssible to the breathing zone of a worker and that this distance
should be no greater than one or two feet.
The procedure also
requires that air samplers be kept off the floor while taking an air
sample.
During tours cf the facility.of June 6,1988, the inspector observed
a contractor Rao Con technician performing job coverage for work in
the Unit 2 Containment Purge Filter Bank Room on the 690 foot
elevation.
The inspector noted that an individual, dressed in
personal PCs but not wearing any respiratory protective device, was
working inside the filter bank room opening and inspecting the
charcoal filter drawers while the Rad Con technician was taking
both a gaseous and a particulate air sample at the entrance to the-
area.
This area had a potential for airborne radioactivity during
unit operation and a warning to that effect was stenciled on the door
to the area.
The pump drawing air for the gaseous air sample was
attached to some of the equipment just inside the entrance to the
filter bank area while the particulate air sampler was setting on the
floor just inside the entrance and greater than six feet from the
worker.
Failure to perform air sampling in accordance with written procedures
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was identified as an additional example of an apparent violation of
Technical Specification 6.11 (50-327,328/88-31-02).
c.
Whole Body Counting Facility
The inspector reviewed the changes that had been made in the whole
body counting facility.
The whole bcdy chair counter had been moved
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from a small area near the lunch room to a much larger room.
This
facilitated not only operation of the chair counter, but acquisition,
installation and operation of a stand-up counter as well.- The chair
became operational March
11, 1988.
Dosimetry Section personnel
completed orientation on the fastscan system in March and became
fully qualified in May.
The fastscan was placed in full operation
May 9, 1988, and is being used as a screening device. When positive
results are noted on a fastscan WBC, the chair counter is used to
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ascertain a more accurate analysis of the nuclides present.
The
fastscan can perform a whole body count in 60 seconds and has a
nuclide library as specified in ANSI Standard N343-1978.
The
fastscan system recomputes the Minimum Detectable Activity (MDA) for
each count which is typically less than five percent of MP0B for
isotopes in the library.
No violations or deviations were identified.
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d.
Identification of Respirators
During tours of the facility, the inspector observed that respiratory
protection devices are now tagged with a unique identification number -
made up of initials and letters indicating mask type, size and serial
number.
This identification number was reflected on mask issuance:
records.
The use of the identification numbers was specified in the
following licensee procedures:
RPSIL-3, Selection, Issue, and Use of Respiratory Protection Devices,
Revision 1, May 17, 1988.
RPSIL-3, Cleaning / Sanitizing, Maintenance, Inspection
Storage, and
Inventory of Respiratory Protection Devices, Revision 1, May 24,
1988.
No violations or deviations were identified.
5.
Control of Radioactive Materials and Contamination, Surveys and Monitoring
(83726)
a.
Hot Particle Program
(1) Procedures
The inspector reviewed the following licensee procedures:
HPSIL-2, Contamination Surveys, Rev.19, dated April 15,
1988.
HPSIL-10, Personnel Decontamination and Confiscation of
Contaminated Articles, Rev,14, dated May 23, 1988.
HPSIL-39, Protective Clothing laundry Handling and
Shipments, Rev. 3, dated April 15, 1988.
DOS-3, Calculation of Skin Dose from Direct Contamination
Survey Measurements, Rev. 2, dated February 22, 1988.
The procedures included a definition of hot particles, survey
techniques to be used when hot particles are suspected, action
levels for skin dose calculations and whole body counts, and
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instructions on laundry monitoring techniques.
The inspector
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noted that the laundry handling procedure did not specify
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whether or not the returned laundry should be surveyed on the
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cutside of the garment, on the inside of the garment or both.
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The licensee indicated that instructions had been issued to
survey the laundry on both the inside and outside but that the
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instructions had not been included in a procedure.
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The inspector also noted that there were no procedures outlining
the specific identification of hot particle contamination areas
and detailing the extra precautions required for their control.
Also, there were no provisions to have personnel working -in such
areas monitor themselves periodically to ensure that no hot
particle contamination was present and to prevent the extra skin
dose that results.
The licensee acknowledged thatino such
procedures had been prepared but indicated that they would
continue to improve their program by initiating such procedures.-
The inspector informed licensee. representatives that this issue
would be reviewed during a subsequent inspection.
(50-327,328/88-31-03)
(2) Hot Particle Investigation
Since instituting their hot particle program on March 7, 1988,
the licensee had experienced 73 hot particle occurences/
contamination events.
From those that were determined to be
skin contaminations, the highest dose to the skin was calculated
to be 1.777 rem.
A qualitative analysis of the particles has
shown that they are all mixtures of fission and/or activation
products.
To date there have been no single isotope hot
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particles identified.
The inspector reviewed the licensee's ongoing investigation of
the hot particle contamination event that resulted in the
1.777 rem exposure to the skin. The event was documented in the
Hot Particle Occurrence Log and Personnel Contamination Report
- 88-58.
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During the af ternoon of April 30, 1988, an individual was
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inspecting and repairing mirror insulation inside the Unit 2
reactor cavity.
After working in the cavity for approximately
two hours, the worker left the area and proceeded to the
entrance / exit of the contaminated area where he removed the PCs
he had been wearing and exited the area.
While performing a
whole body frisk, the worker detected contamination on his back.
Upon further investigation by the Rad Con technicians who
responded to help with the problem, it was determined that the
contamination was located on the person's sweatshirt and not on
the skin.
It was also determined that the contamination was a
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hot particle which read 8,000 cpm while holding a frisker probe
on the outside of the sweatshirt and 33,000 cpm while holding
the probe on the inside of the sweatshirt.
The licensee performed skin dose calculations using
0.181 microcuries as the total activity of the particle and 2.18
hours as the time of exposure.
The resultant skin dose was
calculated to be 1.633 rad beta and 0.144 rem gamma.
The
inspector reviewed the licensee's methodology for performing the
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calculations and determined that the dose assigned was
conservative.
No violations or deviations were identified.
b.
Surveys
10 CFR 20.201(b) requires each licensee to make or cause to be made
such surveys as (1) may be necessary for the licensee to comply with
the regulations and (2) are reasonable under the circumstances to
evaluate the extent of radiation hazards that may be present.
During tours of the facility, the inspector observed Rad Con
technicians surveying items at the "green tag" table.
These items,
after being surveyed and found clean, were to be released for
unrestricted use.
It was noted that the quantity of material taken
into the Radiation Control Area (RCA), which was then required to be
surveyed out, had decreased from that observed during past
inspections.
The inspector discussed with licensee representatives other steps
that have been or are being taken to further reduce the amount of
material taken into the RCA.
Storage areas inside the RCA are being
developed for scaffolding and other items of equipment routinely used
in that area.
A work area or calibration area is also being sought
inside the RCA to eliminate the need to transport items across the
barrier to receive the proper maintenance and/or calibration.
No violations or deviations were identified.
6.
Solid Waste (84722)
The inspector discussed with licensee representative the current staffing
within the Water and Waste Processing Group.
Two personnel were
temporarily reassigned from the corporate radioactive waste section to
provide technical support for the site personnel. Based on interviews and
comments from other onsite personnel, the corporate assistance had proven
beneficial in improving the group's effectiveness.
The licensee had recently sampled three of their waste streams (dry active
waste, radwaste demineralizer and contaminated oil) and had forwarded the
samples to an offsite laboratory for analysis so that new 10 CFR Part 61
waste classification scaling factors could be determined for these waste
streams.
Following unit startup and establishment of equilibrium
radioactivity with the system, the remaining site waste streams will be
sampled.
The inspector reviewed the results of an audit performed during the period
January 19-22, 1987, by the TVA Procurement Quality Assurance Branch at
the laboratory which analyzed the licensee's 10 CFR Part 61 waste stream
samples.
The audit determined the vendors quality plan was not being
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adequately implemented.
A summary of the more significant audit findings
follows:
Logs for strontium and transuranic analysis did not indicate
personnel performing tests.
Some analysis were performed by
laboratory technicians that were not qualified for the specific
analysis.
Intralaboratory analysis program does not comply with . vendor
requirements in that data from actual samples is not reviewed in an
acceptable fashion for reasonableness and consistency of laboratory
results.
No interlaboratory analysis program had been established.
Verification and approval of computer programs was not in accordance
with vendor procedures.
The licensee suspended analysis work at the vendor lab because these
findings reflected negatively on the labs ability to provide accurate
results.
Licensee representatives stated that the problems noted at the laboratory
had been resolved.
The inspector discussed with licensee representatives the status of the
new radioactive waste building.
The licensee was having difficulty
placing the bale compactor into operation due to poor compression factors.
No violations or deviations were identified.
7.
Transporation (86721)
The inspector discussed the licensee's transportation of radioactive
materials program with licensee representatives and reviewed selected
records maintained by the licensee of radioactive materials shipments.
There had been no transportation incidents within the past year.
The inspector noted that a teletector survey meter (maximum scale of
1000 Rem per hour) had been used to perform the shipping survey on a
package of 10 CFR Part 61 samples being sent to an offsite laboratory.
The shipment was classed as a Limited Quantity shipment which required,
pursuant to 49 CFR 173.421(b), that the dose rates on the external surface
of the package not exceed 0.5 mrem /hr.
The documents indicated that the
package dose rates were 0.4 mrem /hr. The inspector observed that it may
be more appropriate to select survey instruments with range midpoints
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closer to the limit being applied toward the measurement.
No violations or deviations were identified.
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8.
Followup on Allegations (99014)
a.
Statement of Concern
Allegation No. OSP-88-A-0037.
It was alleged that primary piping
insulation was being taken off and put back on repeatedly for
different purposes rather than consolidating the maintenance and
inspections.
Licensee management had agreed with the alleger last-
year to establish the position of an insulation coordinator to plan
this type of work to minimize the radiation dose to the insulators.
However, there is ctill no coordinator and the alleger has heard that
the licensee no longer-intends to get one. The problem is continuing
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worse than ever. Poor planning of work had caused workers to be sent
into radiation areas to perform work, only to then find out the work
could not be performed or had been simultaneously assigned to another
work group.
b.
Discussion
The inspector discussed this concern with licensee representatives.
The inspector reviewed exposure records of the personnel involved and
reviewed an ALARA suggestion that had been prepared by an individual
on the subject.
The exposure records indicated the following:
During the period January 1 to June 7,1988, the 24 mechanical
maintenance insulators received a total dose of 2.457 man-rem.
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During this same period, the 25 modifications section insulators
received a total dose of 10.247 man-rem.
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The highest individual dose for the year in the mechanical
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maintenance insulator section was 278 millirem.
The highest
individual dose for the ye 'r in the modifications insulator
section was 908 millirem.
Yhe alleger had a total dose which
was substantially less than the highest dose received.
Of the 137 designated sections at the site, 38 had total doses
for the year in excess of one man-rem.
The nodifications
section insulators had the lith highest dose and the mechanical
maintenance insulator section had the 26th highest dose.
The total station dose for the year was 354.014 man-rem.
The
total dose for the insulators was 12.704 man-rem or 3.6 present
of the total station dose.
None of the licensee representatives interviewed disputed the
allegation that there was an apparent coordination problem with
insulation removal and replacement and that improvement could be made
in this area.
However, the magnitude of the dose to the work groups
suggested that this problem was not a significant contributor to
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cumulative station dose.
The licensee stated that they would ask
their newly formed Work Control Group to review ' this area to
determine what actions would be appropriate.
,
c.
Finding
There was acknowledged coordination problem with insulation removal
and replacement.
However, worker doses were being maintained well
within NRC limits and compared favorably with other work groups at
the station.
The licensee's referral of this problem to the Work
Control Group appears to be responsive to the problem.
Whether or
not an individual is designated as- an insulation coordinator would
be at the licensee's discretion.
d.
Conclusion
The allegation was substantiated.
Actions taken by the licensee's
Work Control Group to minimize the work coordination problem in
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radiation areas will be reviewed during a future inspection
(50-327/328/88-31-04).
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No violations or deviations were identified.
9.
Action on Previous inspection Findings (92701)
6.
(Closed)
IFI
(50-327/328/88-04-02),
Evaluation of Improved
Reliability of Digital Alarming Dosimeters (DADS).
A previous inspection identified that the DADS used by the licensee
as the dose warning device required by Technical Specification 6.12.1
for personnel entering high radiation areas experienced high rates of
failure on the three times a week source check. The licensee was to
evaluate means of improving the reliability of the instruments and
increasing their source check frequency.
The inspector reviewed licensee procedure ISIL-1, Radiological
Control Instrument Inventory and Response Criteria, Revision 1,
May 27, 1988.
The procedure now requires that the DADS be response
checked prior to each issue.
The inspector toured the area where
DADS were source checked in the radiological controls field office.
The licensee used a Sheppard calibrator containing a 400 Curie
Cesium-137 source for the response check. The instrument alarms were
set to a radiation source strength of 200 millirem / hour and
100 millirem integrated dose.
After source check, the instruments
were taken to the equipment issue window at the controlled area
access.
Through discussion with licensee representatives the
inspector determined the licensee was no longer experiencing a high
failure rate on the more frequent instrument response checks.
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b.
(Closed) IFI (50-327/328/88-04-04), Provide Revised ALARA Preplan
Exposure Estimates When Work Scope Changes.
The licensee now required that exposure estimates be revised when
work scope changes.
The inspector reviewed selected records nf work
plans issued.during 1988 and discussed the new program with licensee
representatives. Approximately eighty percent of the preplanned jobs
have had revisions processed to the original exposure estimate. The
inspector determined the licensees actions were appropriate.
10. NRC Information Notice.(IN) (92717)
The inspector determined that the following information notice had been
received by the licensee, reviewed for applicability, distributed to
appropriate personnel and that action, as appropriate, was taken or
scheduled:
IN 88-08: Chemical Reactions with Radioactive Waste Solidification Agents
11. Units 1 and 2 Operational Readiness
Licensee readiness to support Unit 2 restart in the areas of inplant
health physics and radwaste had been favorably assessed during inspection
50-327/328/88-04.
This inspection did not reveal any new issues that
would adversely impact on Unit 1 startup or on the upcoming refueling
outage.
12.
Exit Interview
The inspection scope and results were summarized on June 10, 1988, with
those persons indicated in Paragraph 1.
The inspector described the areas
inspected and discussed in detail the inspection . findings listed above.
The licensee did not identify as proprietary any. of the material provided'
to or reviewed by the inspectors during this inspection.
Dissenting
comments were not received from the licensee.
Item Number
Description and Reference
338,339/88-31-01
Violation - Failure to adhere to or establish
procedures, Paragraphs 3 and 4.
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