ML20153E508
| ML20153E508 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/16/1988 |
| From: | Hooker C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20153E393 | List: |
| References | |
| 50-312-88-24, NUDOCS 8809060336 | |
| Download: ML20153E508 (11) | |
See also: IR 05000312/1988024
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U. S. NOCLEAR REGULATORY COMISSION
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REGEON V
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Report 6.
50-312/88-24
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Docket No.
50-312
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License No.
OPR-54
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Licensee:
Sar.ramer.+. Municipal Utility District
14440 Twin Cities Road
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Herald, California 95638-9799
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Facility Name: Rt'choSecoNuclearGeneratingStktion
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Inspection at: Clay Station, California
Inspection Conducted.
July 19-22, 1988, and subsequent telsphnna
con ~versation on July 25, 19P8.
Inspector:
N'
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9F
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r. A. Hooker, Radhtion Specialist
Date $igned
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Approved by:
b.h Ot
- d// 6/W .
G. P.
uh s. Chief
Date Signed
Emerge
Preparedness and Radiological
Protection Branch
Summary:
Inspection on July 19-22. 1988 and telephone conversation un July 25. 198S
(Recort No. 50-312/88-24)
Areas Inspected:
Routine unannounced inspection of licensee act?on on
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prestous inspection findings and Licensee Event Reports (LERs), external
exposure control, ano internal exposure contro'. Inspect!on Procedures 30703,
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92700, 92701, 92702, 83724 and 83775 were addiessed.
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Results:
In the areas inspected the licensee's program appearet', adequate to
accomplish its sh ety objectives.
The licensee replaced thier contract
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Radiation Protectin M Pger with a District employee with qualifications
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equivalent to those out ' eri in Regulatory Guide 1.8 (paragraph 3).
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One apparent violatio.; was
ntifiec
nne area:
TS 6.11., failure to
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follow procedures (para
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OETAILS
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1.
Persons Contacted
Licensee
- B. G. Croley, Ass?stant General Manager (AGM), Technical Services
D. Keuter, AGM, Nuclear Power Production
- J. Vinquist, Director, Nuclear Quality
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- M. Bua, Manager, Radiation Protection (RPM)
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- R. Harris, Assistant RPM
- W. . Keeper, Manager, Nuclear Operations (MNO)
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- S. Crunk, Manager, Licensing
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- L. Houghtby, Manager, Nuclear Security
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- P. -Turner, Manager, Plant Performanca
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- P. Lavely, Manager Environmental Monitoring and Emergency
Preparedness (EM&EP)
- G. Cranston, Manager, Nuclear Engineering
- J. Reese, Superintendent, Radiological Health (SRH)
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- G. Legner, licensing Engineer
- G.~Podgursk), Supervisor, Respiratory Frotection/ Instruments (SRP&I)
D. Gardiner, Superintendent, Radwaste (SRW)
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NRC Resident 2nspectors
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- A. D'Angelo, Senior Resident Inspector
- P. Qualls, Resident Inspector
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- Denotes individuals attending the exit interview on July 22, 1988.
In addition to the individuals noted abovo, the inspector met and held
discussions with ott.e members of the licensee's and contractor's staffs.
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2.
Licensee Action on krevious Inspection Findings and LERs (92700. 92701
and 92702
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(Closed) Violation (50-312/88-13-01):
This violation involved the
,licensee's failure to maintain documentation attesting that a shipping
container was a Department of Transportat'on 7A package as required by 49
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CfR 173.415(a).
Based on a discussion with the SRW and review of revised
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procedure PP.309.I.1, Determination of the Requirements for
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Shipinent of Radluactive (Nonwaste', Material Of f site, th~. inspector
determined tb
effective corrective actions had been is.iemented to
prevent recurrence as stated in the licensee's timely le v er dated June
6, 1988.
The inspector had no further questions regarding the licensee's
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corrective act.ons.
(Closed) Violation (50-312/88-13-02):
This violation involved the
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licensee s failure to obtain wr4tten certification that a recipient was
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authorized to receive the byproduct material transferred to them by the
licensee.
Bared on a discussion with the SPW and review of revised
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procedure RP.309.I.1, the inspector determined that effective corrective
actions had been implemented to prevent recurrence as stated in the licensee's
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letter dated June 6, 1988.
The inspector had no further questions
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regarding this matter.
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(Clo gd) Follow-up (50-312/87-22-04):
This item involved the need to
revie.e the licensee's evaluation tr accurately measure beta radiation
with their Panasonic Thermoluminescent Dosimeters (TLD).
The SRH
informed the inspector that the Panosonic TLDs, when used, are only used
to backup their pocket ion chamber (PIC) results under certain
conditions.
The SRH also informed the inspector that if and when it was
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determined that a need to use the Panasonic TLD for measuring beta
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exposures existed, they would ensure calibration data results met
industry standards. The licensee utilizes a contract vendor supplied TLD
service that is certified under ti.o National Voluntary Laboratory
Accreditation Program (NVLAP) for their legal record and compliance with
the requirements of 10 CFR Part 20.
The inspector had no further
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questions regarding this matter.
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(Closed) r-llow-up (50-312/87-26-01):
This item involved the need to
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review the licensee's evaluation of changes in the A and B Regenerate
Holdup Tank's cleanup system.
Based on review of the licensec's letter
No. GCA 87-916, Radioactive liquid Effluent Systems D_escription
S_upplement, dated January 7, 1988, and administrative controls
(splashguards for flanges and valves) added to procedure A-29
Waste Water Disposal System the inspector censiders this matter closed.
(Closeo) Follow-up (50-312/85-28-08):
Inspection Report Nos,
50-312/85-28, 86-11 and 88-01 document previous inspection efforts
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regarding problems and licensee actions associated with a containment
building purge flow rete measuring device.
Based on discuctions with
licensee representatives and review of Preliminary Change Description No.
4264, for relocating this device during the licenska's 1989 refueling
outage, the inspector considered this matter closed.
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(C'losed) LER (50-312/88-04-201:
The inspector determined that corrective
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actions as stated in the licensee's timely LER No.88-004,
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Incperative Radiation Moisitors Due to an Inadequate Surveillance
Procedure . dated March 29, 1988, had been effectively implementcd to
prevent
scurrence.
The inspector also noted ttie.t as a result of the
licensee's corrective actions, they identified deficiencies in other
surveillance procedures and were taking appropriate action to resolve
these findings.
The inspector had ne further questions regarding this
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matter.
3.
External Exposure Control
The inspector examined the licensee's external exposure control program
to determine :he licensee's compliance with 10 CFR Fart 20, Technical
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$pecifications (TS), licensee procedures, and recommendations outlined in
various industry standards.
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Audits
Quality Assurance (QA) audits and Health Physics / Chemistry Services
(HP/CS) surveillances of this area were discussed in Inspection Report
No. 50-312/88-17, paragraph 3.
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Coanges
Changes in the licensee's program due to implementation of the Hot
Particle Control Program and new equipment were described in Inspection
Report No. 50-312/88-17.
During this inspection (50-312/88-24), the licentee had appointed a new
permanent RPM effective July 22, 1988.
Technical Specification, Section 6.3, Facility Staff Qualifications, states in part, that the RPM shall
meet or exceed the qualifications of Regulatory Guide (RG) 1.8, September
1975
Based on an interview with the new RPM, the inspector determined
that this individual's qualifications were equ!voient to those outline in
RG 1.8, Personnel Selection and Training, dated September 1975.
This
individual has a BA in Chemistry approximately five years of nuclear
power supervisory experience in chemistry and radiation protection
training, about seven years of experience as an instructor in chemistry
and radiation protection, and about eight years at the technician level.
However, the inspector also noted that this individual had very little
experience in management of day to day inplant RP activities.
Program Implementation
Inspection findings associated with the licensee's failure to control
licensed material to ensure workers were not exposed in excess of
regulatory limits were described in Inspection Feport Nos. 50-312/88-07,
08 and 20.
This inspection (50-312/88-24) did nat include a review of
those matters.
The inspector reviewed the following licensee procedures:
RP.305, Radiation Protection Plan
RSAP-1104, Hot Particle Control Program
AP.305-1, Restricted and Controlled Area Access Requirements
including Maximum Permissible Exposures, TLD Issue,
Multiple Badging and Exposure Record.
RP.305.4, Radiation Work Permits
RP.305.10. Initial Reactor Building Entry Guivalines
RP.305.37, Noble Gas Clouds Dsse Determination
AP.311, Portable Health Physics Instrumentation
EPIP-5550, Emergency Facilitits, Equipment and Supplies
Selected Procedures in the licensee's Dosimetry Manual.
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Based on review of the above procedures and facility tours the inspector
made the following observations:
On July 20, 1988, the inspector, accompanied by the SRH and SRP&I ,
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inspected the contents of the licensee's onsite emergency radiation
protection equipment lockers:
RP1 - Control Room /TSC Hallway
RP2 - Warehouse "A" Locker Room
RP3 - Auxiliary Buildina Hallway (orace level)
The inspector noted that tl.e lockers were equipped with the quantity
and type of radiation survey instruments and PICS as specified in
procedure EPIP-5660.
The inspector also noted that the survey
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instruments and PICS had current calibration dates.
Problems
associated with survey instrument calibrations in offsite response
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kits were discussed in Inspection Report No. 50-312/88-25.
Status
of equipment associated with internal exposure control is discussed
in paragraph 4 below.
The inspector also observeo that the alternate Operations Support
Center (OSC), in the "A" warehouse, contained unlocked lockers
filled with a large number of uncalibrated portable battery operated
air samplers and portable radiation survey instruments.
The
inspector was informed that the instruments and samplers were
maintained by the Emergency Preparedness Department and, when
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needed, were calibrated and used as replacements for those in
offsite locations when their calibration had expired.
The inspector
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also noted that the was no posting or other controls to indicate
that the uncalibrated air samplers and survey instruments in the OSC
should not be used.
The inspector expressed a concern to the
licensee that there were r.o controls to prevent the inadvertent use
of this equipment if the OSC was manned during an emergency. At the
exit reeting on July 22, 1988, the EM & EP manager informed the
inspector that the uncalibrated enuipment would be removed from the
OSC and administratively controlled, for non use, in another
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location.
On July 20, 1988, during a tour of the auxiliary buildir.g
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radiologically controlled areas (RCAs), accompanied by the SRP&I,
the inspector observed an individual who had just exited a
contaminated work area in the grade level decon room.
The inspector
also noted that the individual, dressed in swimming trunks, did not
have any personnel monitoring devices or security badge on his
person.
The inspec(or questioned the individual concerning the
whereabouts of his dosimetry devices and security badge.
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individuul presente( a PIC he had placed at the step off pad when
exiting the contaminated work area; however, he could not present a
TLD or security badge.
The individual informed the inspector that
he had apparently left his TLD and security badge in the change room
locker (prade level), along with his street clothes, when changing
icAc pt rtretive clothing PCs.
The individual also informed the
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inspectoe that he had been in the contaminated work area for about
20 minuteT to take airflow measurements of the air supply for the
decon room.
The inspector, along with the SRP&I, informed a RP Technician who
was stationed outside of the decon room of this matter.
The RP
Technician escorted the individual to a nearby whole body personnel
contamination monitor (PCM) for a body frisk, change room to get his
TLD and security badge, and subsequently to the RCA access control
point on the 40 ft, level.
During further questioning of this
individual, prior to his exit from the RCA, he informed the
inspector that he was aware that the radiation work permit (RWP) No.
88-021A, he had signed in on, required him to wear his TLD at all
times when in the RCA.
The individual also stated that he was also
aware of the requirements for wearing his TLD and security badge
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through General Employee Training (GET) when he started to work
Rancho Seco in January 1988.
As a result of this incident the licensee immediately performed a
survey of the contaminated area in the decon room.
The licensee's
survey results indicated that the radiation levels were 5 1.0 mR/hr
2
and the maximum contamination level was 1000 dpm/100 cm .
The
individual's PIC indicated that no measurable radiation was received
and no personnel contamination was detected when the individual used
the PCMs on the grade and +40 ft exit area. The licensee also
initiated an Abnormal Dorimetry Report and investigation of this
incident.
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The licensee's Radiation Control Manual procedure RP.305 Article 2,
Responsibilities of Workers, states, in part, "An example of
responsibilities of all radiation workers follows: .. 3.
Wear
TLD/ film badges where required by procedure, RWP or Radiation
Protection Personnel...."
Procedure RP 305.4 Section 6.6.2 states "It is the responsibility of
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all porsonnel using an RWP to familiarize themselves with the
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radiological conditions listed, protective clothing, dosimetry
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required, and any special instructions.
Each ?WP use
will complete
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Enclosure 8.2 with their Printed Name, Signature, Date, and Badge
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No. Once per work period, and read the RWP upon each entry.
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individual's completion of these items constitutes acknowledgement
of the conditions and requirements as listed on the RWP.
The inspector noted that on July 20, 1988, this individual had
signed Enclosure 8.2 for RWP No. 88-021A, prior to entering the RCA.
The inspector also noted that RWP No. 88-021A required a TLD badge
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for all workers entering the RCA under this RWP.
The failure of
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this individual to wear his TLD badge while working in the der <
room was identified as ar apparent violation of TS 6.11
(50-312/88-24-01).
The inspector examired records associated with containment entries at
reactor power on May 4, 1988, for maintenance and inspection, and June
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22, 1988, for neutron energy spectrum studies performed by the contract
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vendor who supplies the licensee's TLDs.
The records examined indicated
that the licensee corducted adequate preplanning prior to the entries,
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and ALARA considerations and RWPs were appropriately scoped.
Determination of air activity and air quality, use of respiratory
protection equipment, surveys, use of personnel dosimetry, and safety
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precautions taken were performed in accordance with licensee procedures.
The inspector identified no problems during this examination.
With respect to the Itcensee's short maintenance and inspection outage
scheduled in August 1988, the inspector noted that the RP Department was
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in the process of contracting for additional RP and Dosimetry Technicians
to augment their current staff.
The inspector toured an area where th1
licensee had been conducting training with a newly built reactor coolant
pump (RCP) mockup for expected RCP work during the outage.
The inspector
noted that the licensee had taken extra measures to simulate working
conditions, including heating the area to evaluate heat stress on
workers.
Personnel monitoring was based on monthly vendor processed TLDs and
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updated licensee PIC data.
The licensee inputs the monthly TLD data into
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a computer based system to keep track of each workers accumulated
exposure.
In addition to normal badging, supplementary TL0s and PICS
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were used to monitor whole body exposures in non uniform radiation fields
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and extremity monitoring as required.
Neutron exposures were determined
by survey data and stay time.
On June 22, 1988, neutron energy
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evaluations were performed by the licensee's TLD vendor for possible
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future use in neutron dosimetry.
Licensee processed Panasonic TLDs were
used in special cases to backup PICS. Weekly exposure updates from TLD
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and accumulated PIC data showing exposure used for the week, quarter to
date, and year to date were sent to department supervisors, and the OSC
and TSC.
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Exposure records for selected individuals were examined.
The inspector
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verified that forms NRC-4 and NRC-5 or equivalent were maintained as
required by 10 CFR Part 20.
The inspector noted that personnel folders
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also contained a computer listing of dates of workers last GET, medical
examinations, respiratory test, whole body count (WBC) and date of
termination. With respect to termination reports, the inspector made the
following observations:
On July 21, 1988, the inspector noted that the licensee had stored,
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in a cabinet, personnel files for 11 workers who terminated in May
1988.
Notes in the files indicated that they had be m reviewed by
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the t'osimetry office during the July 11-13, 1988 period, and were being
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held for the SHS's review and resolution of minor administrative
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discrepancies before they could be processed.
The vendor TLD report for these terminated workers was dated June 9,
1988.
According to the Dosimetry Supervisor (05) the reports were
normally received at the SRH's office within two weeks of the report
date.
The SRH reviews the reports before they are sent Y.o the
dosimetry office.
Since the licensee did not have an administrative
system such as logging in or stamping the reports, the licensee
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could not provide evidence of the exact date of receipt while the
inspector was on site.
On July 22, 1988, prior to the exit interview, the inspector
discussed the 30 day reporting requirements outlined in 10 CFR 20.408(b) with the 05 and RPM.
The inspector also informed the DS
and RPM that the NRC normally perceived that a workers exposure was
determined when the TLD results were received by the licensee.
The
RPM informed the inspector that the subject termination reports
would be processed by July 23, 1988.
The apparent lack of administrative controls to ensure that
termination reports were processed in a timely manner, and the 30
day reporting requisements of 10 CFR 20.408(b) were also discussed
at the exit interview on July 22, 1988.
The inspector's concerns
were acknowledged by the ifcensee.
During a telephone conversation with the SRH on July 25, 1988, the
inspector was informed that the licensee had received the vendor TLD
results on June 20, 1988, and computer inputs, to determine the
workers exposures, were not corpleted until a few days later.
The
SRH also informed the inspector that their procedures would be
revised to include administrative controls to ensure that
termination reports were processed in a more timely manner. The
inspector will examine the licensee's actions regarding this matter
in a subsequent inspection (50-312/88-24-02).
The inspector noted that exposures from evaluations due to personnel
contaminations or lost dosimetry devices were appropriately added to an
individual's exposure record,
No individual, excluding the individual
described in Inspection Report Nos. 50-312/88-07, 08 and 20, had exceeded
the 10 CFR 20.101(a) or 20.101(b) limits.
The inspector reviewed the circumstances involving an incident that
occurred on July 12, 1988, at about 0228 hours0.00264 days <br />0.0633 hours <br />3.769841e-4 weeks <br />8.6754e-5 months <br />, which resulted in five
workers being contaminated with radioactive noble gases.
The incident
was due to the flushing of raw reactor coolant (RC) from the letdown
system to a floor drain on the minus 20 ft. level, which emptied into a
sump on the minus 40 ft. level.
The RC degassed when it entered the sump
and created a noble gas cloud that contaminated workers on both levels.
The licensen determined that the causes of the incident was the failure
to recognize that the letdown system contained raw RC due to their long
shutdown time, little experience in flushing RC systems during reactor
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operations, no established procedures, and several other weaknesses that
contributed to the incident.
The licensee calculated that the effluent
release that resulted from the noble gases released was about 2.4% of the
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TS 3.18.1 limit.
The maximum personnel exposure due to noble gas was 30
mrem.
The WBCs of the five workers indicated no detectable radionuclides
other than noble gases.
The inspector outermined that the licensee had
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properly evaluated this incident, determined root causes, and were taking
appropriate corrective actions to prevent recurrence.
At the exit
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meeting on July 22, 198R, the MNO informed the inspector that detailed
procedures were being developed for flushing operations.
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During facility tours, the inspector made independent radiation
measurements using an NRC PO-2 portable ion chamber, S/N 2694, due for
calibration on August 10, 1988.
The inspector noted that radiation and
high radiation areas were posted as required by 10 CFR Part 20.
Licensee
access controls for high radiation areas were observed to be consistent
with TS, Section 6.13, and licensee procedures.
The licensee appeared to be maintaining their previous level of
performance in this area and appeared capable of accomplishing their
safety goals.
However, it appeared that the licensee naads to improve on
worker awareness of the requirements for working in RCAs, and provide
more management oversight and attention to detail for processing
termination reports and flushing of systems containing RC water.
One
apparent violation was identified in this area which appeared to be an
isolated occurrence.
4.
Internal Exposure Control
The inspector examined the licensee's internal exposure control program
to determine compliance with 10 CFR Part 20 TS, licensee procedures, and
recommendations outlined in various industry standards.
Audits
QA audits and HP/CS surveillances of this area were discussed in
Inspection Report No. 50-312/88-17, paragraph 3.
Chances
The appointment of a new RPM was discussed in paragraph 3 above. With
respect to other changes, during the fourth quarter of 1987, the licensee
replaced their old bed WBC with a new ilelgeson "Quicky" and bed counter.
Both of these units were located in a portable trailer near the dosimetry
office, at the new location, outside of the Plant protected area.
Quality control checks and calibrations of the WBCs were performed in
accordance with licensee's procedures.
Program Implementation
Based on review of air sample data for containment entries during reactor
power operation on May 4 and June 22, 1988, selected RWPs and discussions
with the SRH, the inspector determined that there were nu airborne
exposures to workers that exceeded the 40 MPC-hour control measure that
would require an evaluation pursuant to 10 CFR 20.103(b)(2).
Examination
of WBCs of selected workers indicated no intakes of radioactive materials
that would require internal dose evaluations.
Action points for the
"Quicky" counter were established and, if exceeded, required a count in
the bed counter for a more detailed assessment of internal exposures.
The following procedures in the licensee's Respir.irory Protection Manual
were reviewed:
RP.314 Article 1, Radiological Respiratory Protection Program
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AP.114 I-1, Use of MSA Ultra Filter Full Facepiece Respirator
AP.314 II-2, Use of MSA Custom 4500 Air Mask SCBA
AP.314-2, MSA Constant Flow Air Line Respirator
AP.314 IV-1, Respirator Inspections. Maintenance. Cleaning and
Storage
AP.314 V-I, Training For Use and Maintenance of Respiratory
Protection Equipment
Based on review of the above procedures, discussions with licensee
representatives, and observations during the inspection, the inspector
determined that the licensee's program was consistent with,10 CFR 20.103, RG 8.15, Acceptable Programs for Respiratory Protcetion, and
NUREG 0041, Manual of Respiratory Protection Against Airborne
Radioactive Materials.
The inspector noted that personnel who performed tests and repairs on
respiratory protection equipment, had been trained and certified by the
vendor who supplies the licensee's equipment.
Records of quarterly breathing air system radioactivity and air quality
checks examined, indicated no problems with the licensee's breathing air
system.
The licensee also performed the same analysis prior to each use
of the breathing air system which was supported by the service air
system.
The licensee maintained a separate system for filling SCBA air
tanks.
The inspector toured areas where the licensee maintained
respiratory equipment for normal and emergency use.
The following
observations were made:
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On July 20, 1988, the inspector noted two SCBA Units in the MAKO air
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compressor shed that had yellow sticky note paper denoting that
their pressure gauges were broken.
The note papers had been
attached to the faces of the gauges on these two units that were
stored in a borizontal position with several filled units.
Due to
the heat in this area, the glue on the note paper had become
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ineffective and were just resting on the face of the gauges.
The
inspector expressed a concern to the licensee that note paper was
being used instead of a more permanent type of tag
This was also
discussed at the exit meeting on July 21, 1988.
The inspector's
observations were acknowledged by the licensee.
On July 20, 1988, the inspector noted that the low volume portable
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air samplers in Emergency Lockers RPI, RP2 and RP3 were due for
calibration on July 18, 1988, as indicated on attached calibration
tags.
In addition, locker RPI also contained a "HI-Vol" portable
air sampler that indicated that calibration was due July 1, 1988.
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As indicated on the calibration tags and according to the SRH, these
samplers were calibrated quarterly.
Lased on review of procetures in the licensee's Radiation Detection
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Instrutsonts Manual, the inspector noted that no reference was n.ade
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to the calibration frequency for portable air samplers.
The
inspector Tiso noted that the licensee's computer listing, of
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instruments due for calibration by July 30, 1988, listed the
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"HI-Vol" sampler as being due on July 1,1988; however, the low
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volume samplers were not on the list presented to the inspector.
The licensee took immediate steps to have the samplers calibrated on
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July 20, 1988.
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The inspector discussed the apparent weakness in the licensee's
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program regarding the failure to specify the policy for tt.e
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calibration frequencies of portable air samplers, and the failure to
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list the low volume sampler in the emergency lockers with the SRH.
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These matters were also discussed at the exit meeting on ,1uly 22,
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1988.
The inspectors observations were acknowledged by tne
licensee.
The inspector was informed by the SRH that the licensee's
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procedures were beir,g revised to clarify the policy with respect to
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instrument calibration frequencies, and a review to ensure all
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instruments were on the licensee's listing of instruments due for
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calibration.
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The inspectcr noted that respiratory equipment, availaH e for
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emergency use, appeared to be well maintained and in the quantities
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specifled in the licensees procedures.
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Problems associated with responsibilities for inventories of
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emergency equipment were described in Inspection Report No.
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50-312/88-25.
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The licensee seemed to be maintaining their previous letol of performance
in this area and their program appea.ed adequate to accomplish its safety
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objectives.
No violations or deviations were identified.
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5.
Exit Interview
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The inspector met with the licensee representatives, denoted in paragraph
1, at the conclusion of the inspection on July 22, 1988.
The scope and
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findings of the inspection were summarized.
During the interview, the
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RPM reviewed the actions taken to assure that the workers terminatioli
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reports would be immediately processed.
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The licensee was informed of the appar nt violation discussed in
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paragraph 3 above.
The inspector also informed the licensee that the
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matter regarding timeliness of processing tertaination reports would be
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given further in office review, and the licensee needed to established a
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firm date as to when the TLD results had been received onsite.
The SRH
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stated that he would investigate the matter and inform the inspecter of
his findings by telephone (paragraph 3).
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