ML20235U715
| ML20235U715 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/04/1987 |
| From: | Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235U703 | List: |
| References | |
| 50-327-87-56, 50-328-87-56, IEIN-86-023, IEIN-86-23, IEIN-87-003, IEIN-87-007, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8710140215 | |
| Download: ML20235U715 (13) | |
See also: IR 05000327/1987056
Text
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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.W.
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ATLANTA, GEORGt A 20323
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OCT 0 2198T
Report Nos.:- 50-327/87-56 and 50-328/87-56
Licensee: Tennessee Valley Authority
6N 3BA Lookout Place
1101 Market Street-
Chattanooga, TN 37402-2801
Docket Nos.::.50-327 and 50-328
License Nos.:
Facility Name:
Sequoyah 1 and 2
Inspection Conducted: August 17-21, 1987
_
Inspector:
SlrwO hp
NdM NN
4A R. E.
edding n
Date Signed
Accompanying-Personnl:
M. T. Lauer
Approved by:
atty bb d
9 8,.dtJn N@
t
b C. i. yqsey, AeTtion Chief
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Date Signed
Division of RWdiation Safety and Safeguards
SUMMARY
-Scope:
This was a routine, announced inspection in the areas of management
controls, training, internal exposure control, external exposure control,
control of radioactive material, facilities and equipment, ALARA, solid wastes,
transportation, followup on previous inspector identified items, followup on
allegations and followup on IE Information Notices.
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Results: Three violations were identified:
(1) failure to control a high
radiation area, (2) failure to perform a 10 CFR 50.59 review for' a change in
the radioactive waste system and (3) failure to obtein. review and' approval for
a change in waste solidification procedures.
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8710140215 871002
ADOCK 05000327
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REPORT DETAILS
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Persons Contacted
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f.icensee Employees
- L. M. Nobles, Plant Manager
- P. R. Prince, Site Radiological Control Supervisor
- R. h. Buchholz, Office of Nuclear Power Site Representative
- A. M. Qualls, Assistant to the Plant Manager
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- L. !.. Jackson, Assistant to the Plant Manager
- T. J. Arney, Quality Assurance Manager
- F. W. Reimann, Radiological Assessor
- J. Sullivsn, Supervisor, Plant Operations Review Staff
- E. R. Ennis, Assistant to the Plant Manager
- W. S. Kilbure, Assistant to the Maintenance Superintendent
- J. M. Qualls, Radwaste Manager
- M. Littleton, R0diological Field Operations Manager
- 0. E. Hickman, Jc., Radiation Protection Manager
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- V. Faust, Health Physicist, Corporate Staff
- L. J. Politte, Health Physicist, Corporate Staff
- S. Harrison, Radiation Health Shift Supervisor
- T. E. Cribbe, Licensing Engineer
- G. B. Kirk, Compliance Licensing Manager
J. Osborne, Manager of ALARA
J. A. Leamon, ALARA Engineer
M. Palmer, Radiation Health Manager
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E. Parris, Radiological Outage Supervisor
W. Wil'liams, Chemistry Supervisor
L. Strickland, Supervisor, Power Operations Training Center
Other licensee employees included technicians, security force members, and
office personnel,
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Nuc1 car Regulatory Commission
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K. A. Jenison, Senior Resident Inspector
- P. E. Harmon, Resident Inspector
D. Loveless, Resident Inspector
- Attended exit interivew
2.
Exit Interview
The inspection scope and findings were summarized on August 21, 1987, with
those persons indicated in Paragraph 1 above.
The following issues were
discussed in detail:
(1) an apparent violation for failure to control a
high radiation area involving a radioactive waste liner (Paragraph 6),
(2) an apparent violation for failure to perform a 10 CFR 50.59 review for
a change in the radioactive waste system (Paragraph 10); and (3) an apparent
violation for failure to obtain review and approval for a change in waste
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solidification procedures (Paragraph 10).
The licensee acknowledged the
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' inspection fir, dings and took no exceptions.
The licensee did not
identify as propriety any of the materials provided to or reviewe', by the
inspectors during this inspection.
3.
Organization and Management Controls (83722)
Technical Specification (TS) 6.2 describes the licensee's radiation
protection organization.
The inspector reviewed -the organization and
staffing of the licensee's radcon and radwaste groups. Within the radcon
group, the position of Radiological Protection Manager and Radiological
Field Operation Manager had been recently filled.
The only remaining
vacancies within the radcon group were five technicians, two engineers and
two administrative personnel.
The inspection determined that these
shortages were minor and did not affect the effectiveness of the radcon
program. There had been no staff changes in the radwaste group.
No violations or deviations were identified.
4.
Training and Qualifications (83723)
TS 6.3.1 requires each member of the facility staff to meet or exceed the
minimum qualifications of ANSI N18.1-1971.
Paragraph 4.3.1 of
ANSI N18.1-1971 states that a supervisor is required to have a minimum of
four years experience in the craft or discipline he is to supervise. The
inspector compared the experience levels of two new supervisors in the
radcon group with the qualification requirements and discussed their
qualification with licensee represer ^ - tives.
The inspector determined
that the supervisors met the qualifie in requirements.
Paragraph 4.5.2 of ANSI N.18.1-1987 states that technicians in responsible
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positiens shall have a minimum of two years of working experience in their
speciality and one year of related technical training in addition to their
experience.
The inspector discussed with licensee representatives the health physics
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technician qualification program administered through the licensee's Power
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Operations Training Center (P0TC).
Personnel received an initial four
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months of clessroom instruction at the POTC, followed by a twenty month
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on-the-job training (0JT) program.
The OJT program was structured around
completion of various performance verification sheets in such areas as
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radiological surveys and radiation work permits (RWP).
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No violations or deviations were identified.
5.
Internal Exposure Control (83725)
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10CFR 20.103(c)(2) provides that the licensee may make allowance for use
of respiratory protective equipment in estimating exposures of individuals
to concentrations of radioactive material in air provided that the
licensee maintains and implements a respiratory protection program that
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includes, as a minimum, written procedures regarding selection, fitting
and maintenance of respirators, and testing of respirators for operability
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immediately prior to each use and written procedures regarding supervision
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and training of personnel and issuance records.
The inspector discussed with licensee representatives their respiratory
protection training program.
The respirator qualification training and
testing was combined with general employee training (GET).
Licensee
representatives stated that they were in the process of seperating
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respiratory protection training from GET.
The inspector toured the licensee's respirator repair and issue station.
and discussed its operation with licensee personnel.
The inspector
examined the licensee's respirator issuance log and noted that respirators
were not uniquely identified by a serial number or other means which would
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permit establishment of maintenance and wear histories of masks and
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investigation of possible defects as a cause of worker internal exposures.
Licensee representatives stated such a system was being con:;1dered.
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No violations or deviations were identified.
6.
External Exposure Control (83724)
The inspector discussed with licensee representatives the staffing within
the dosimetry section.
The section had recently lost three of the ten
technicians assigned to the section.
As a result the licensee had to
reduce their round the clock manning of the dosimetry office to operating
hours of 6:00 a.m. to 11:00 p.m.
Dosimetry personnel would have to be
called to the site to process dosimetry or perform a whole body count if
an urgent need arose during the period in which the dosimetry office was
not manned.
Licensee representatives stated that this arrangement had not
caused any problems to date, but if additional staffing was needed, they
could be obtained from contractors or TVA's Watts Bar facility.
As a long
term solution, the licensee was in the process of changing their radcon
and dosimetry technician training and qualification programs to facilitate
exchange of personnel between the two groups.
Currently, a radcon
technincian would have to complete the entire two year training program to
become a qualified dosimetry technician.
No violations or deviations were identified.
b.
Licensee Event Report (LER) SQR0-50-327/87026
The subject LER repo-ted a violation of the licensee's technical
specification requirements for high radiation area control which occurred
.on May 26, 1987.
Technical Specification 6.2.2 required that each high
radiation area in which the intensity of radiation is greater than
1000 millirem / hour shall be barricaded and conspicuously posted as a high
radiation area and locked doors shall be provided to prevent unauthorized
entry into the area.
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The licensee had experienced problems during solidification of a
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radioactive waste liner in the Auxiliary Building railroad access bay in
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which the liner contents had overflowed the cask and hardened.
The
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li:ensee prepared radiation work permit (RWP) 87-0563-0004 to move the
liner by crane up to the refueling floor and across to the cask
decontamination room where the excess solidified material was to be
chipped away so that the lid could be placed on the cask.
The radiation
level around the cask was 1200 molirem/ hour at 18 inches from the side of
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.the cask.
The RWP required that : adcon provide continous coverage of the
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work.
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On the day of the event, a radcon technician was sent to the radwaste area
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to assist the normally assigned radcon technician.
The radwaste radcon
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technician signed the RWP for the liner work, but then left the area to
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perform routine radiological-surveys.
The radcon technician that had been
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assigned to assist apparently had not been briefed that he was to cover
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any specific job, but he was standing nearby when the work group began
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preparations to rig out the liner. Although the technician had not signed
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the RWP, the work group apparently thought this technician was providing
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their coverage.
A second radcon technician from the ALARA section was
also present in the area to take photographs of the job. As the cask was
being raised out of the railroad bay, the ALARA technician asked the other
radcon technician about the provisions that had been made to provide high
radiation area controls on the refueling floor and in the cask
decontamination room and was apparently told that no controls were in
place.
The ALARA technician then went up two flight of stairs to the
refueling floor to catch up with the liner and provide the necessary
controls, but upon reaching the refueling floor, the technician observed
the cask being lowered into the decontamination room and a person was in
the room guiding the liner into place.
Since the personnel access door to
the decontamination room was on the same elevation as the railroad access
bay, the ALARA technician headed back down the stairs and met the
temporily assigned radcon technician.
It was decided that the radcon
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technician would go to the decontamination room to provide coverage and
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that the ALARA technician would phone the radcon field office to alert
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them to the problem.
While the ALARA technician was on the phone in the
railroad access bay, the technician that had left to cover the
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decontamination room came through the door. The technician stated that he
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left the room unlocked because he did not have a key.
The ALARA
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technician then left to guard the access to the cask decontamination room
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until it could be properly posted and locked.
Licensee investigation
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indicated that the highest exposure received by the people involved in
this event was 20 millirem.
A similiar event occurred on November 4,1986 (LER SQR0 50-327/86052) and
was discussed in Inspection Report Nos. 50-327/87-03 and 50-328/87-03.
At
that time, it was determined that the licensee had met the criteria of
10CFR Part 2, Appendix C.V.A for not issuing a Notice of Violation.
For
the most recent event, it was determined that the licensee had not met the
self identification criteria in that the violation could reasonably be
expected to have been prevented by the licensee's corrective action for
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the previous violation.
Failure to provide high radiation area
ontrols
for the movement of the radwaste liner on May 26, 1987, was identified as
an apparent violation of Technician Specification 6.12.2 (50-327/87-56-01
and50-328/87-56-01).
c.
Radiation Work Permits (RWPs)
The licensee had implemented a system of standing RWPs for r60etitive work
that.did not involve entry into containment, a high radiat!on area or an
airborne radioactivity area.
The inspector reviewed selected standing
RWPs and determined that the controls were appropriate for the type of
work described.
The inspector observed work performed under RWP 87-2202-006 to remove a
transversing incore probe (TIP) from its storage location inside the shield
wall and transfer it using a shielded transport pig to a storage cask in
the radwaste building.
The highest dose rate on the TIP was measured to
be 700 millirem / hour.
No violations or deviations were identified.
7.
Control of Radioactive Materials and Contamination, Surveys, and
Monitoring (83726)
a.
Surveys
The licensee had established a portion of the control building
between the control room and the refueling floor as a regulated area
(i.e. radiologically controlled area) during the time that cable and
conduit were being installed in the overhead and wired to various
cabinets in the area. This change of boundaries allowed the licensee
to bring materials into the area from the controlled area without
being first surveyed for contamination.
At the completion of the
work, the licensee performed a radiological survey on July 21, 1987,
to release the area as a controlled area. The inspector reviewed the
documentation of the survey results and discussed the survey with
licensee representatives.
The inspector determined that the cables
inside of the conduits and cabinets were potentially contaminated and
that they had not been accessible for survey when the release survey
had been performed.
The inspector stated that a person who might
subsequently work in this area and gain access to the cables could
unknowingly become contaminated.
The licensee acknowledged the
comment and stated that they would evaluate placing warning signs in
the area or other means to preclude an inadvertent contamination
event in the area.
No violations or deviations were identified.
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b.
Byproduct Material Control
Technical Specification 3.7.10 requires that each sealed. source
containing radioactive material either in excess of 100 microcuries
of beta and/or gamma emitting material or five microcuries of alpha
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emitting material shall be free of greater than or equal to
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0.005 microcuries of removable contamination.
Technical Specification 4.7.10.1 requires that sealed sources in use
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be tested for leakage at least once per six months.
.. Technical Specifications 6.10.1.g and h require that the licensee
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maintain records of sealed source leak checks and results of the
annual physical inventory of all sealed source material of record.
The inspector discussed the results of the licensee's most recent
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inventory and leak check of sealed sources.
The inventory was still
in progress during the inspection.
The licensee used 10 CFR 30,
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Schedule B as a guide for the sources that they maintained on their
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inventory even though there was no NRC requirement that they do so.
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As a result the licensee had approximately 250 sources under control,
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only nine of which were required to be controlled by the technical
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specification (greater than 5 microcurier alpha or 100 microcuries
beta / gamma).
Licensee representatives stated that they had found
eight. sources that were not listed on their inventory, the largest of
which contained two microcuries of radioactivity.
Most of these
sources were found in a van that had been transferred from another
TVA facility and inside inplant radiation monitors.
The only other
findings was that a one microcurie Co-60 source could not be found
and was believed to have been sent to radwaste.
The inspector
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determined these discrepancies were minor in nature and not
indicative of any programmatic problem.
No discrepancies were
identified in regard to the nine sources requiring accountability by
the Technical Specification.
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No violations or deviations were identified.
8.
Facilities and Equipment (83727)
The inspector discussed facility changes with licensee representatives.
The licensee had disestablished their contaminated laundry and was sending
protective clothing to a licensed offsite vendor for processing.
The
licensee had not yet made a decision on building a new laundry.
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The inspector toured the radwaste building that was under construction and
was expected to be in operation by the end of the year.
The building
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featured a new combination shredder and compactor.
Licensee ALARA
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personnel had recently been active in reviewing the layout of facilities
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and equipment within the building.
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The inspector toured the Condensate Demineralized Waste Evaporator (CDWE)
Building.
The CL'WE was shutdown for maintenance which included biannual
equipment inspection and eddy current tests.
The floor was also being
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- repoured so that it would slope toward the floor drains in the areas. The
. inspector also obsarved that extensive decontamination and cleanup work
had been peformed in the area.
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No violations or deviations were identified.
9.
Maintaining Occupational Exposures ALARA (83728)
10 CFR 20.1(c) specifies that licensee should implement programs to
maintain workers' exposures ALARA. Other recommended elements of an ALARA
program were contained in Regulatory Guides 8.8 and 8.10.
The inspector discussed with licensee representatives recent changes that
they had made in their ALARA program.
The licensee had established an
ALARA Review Committee composed of management and- supervisory personnel
from Radcon, Operations, Electrical Maintenance, Mechanical Maintenance,
Instrument Maintenance and Modifications.
The inspector reviewed the
minutes of the ALARA review Committee meeting that had been held since the
first meeting in February 1987.
The inspector also reviewed the ALARA
suggestions that had been received in 1987.
The licensee had already
received 50 suggestions in 1987, whereas they had only received 14 in
1986.
The increase was attributed to implementation of an ALARA
suggestion incentives program at the first of the year.
The inspector
observed that many of the suggestions were meaningful.
The licensee was
responsive to all suggestions and provided feedback to the person writing
the. suggestion.
The licensee had in place a program to minimize the area controlled as
contaminated and high radiation areas.
The licensee had reduced the size
- of these controlled areas by approximately one half since the first of the
year to 6500 square feet of high radiation area and 11,348 square feet of
contaminated area.
These areas represented less than ten percent of the
area of the plant.
The licensee's exposure goal for calendar year 1987 was 600 man-rem and
they had expended 293 man rem through July 31.
The plant radwaste goal
was 23,400 cubic feet, and as of the inspection, they had disposed of
9,086 cubic feet.
No violations or deviations were identified.
10.
SolidWastes(84722)
a.
10 CFR 20.311(d)(1) requires that licensees prepare all radioactive
wastes so that the waste is classified according to 10 CFR 61.55 and
meets the waste characteristics requirements in 10 CFR 61.56.
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The.. inspector discussed with licensee representatives their plans for-
waste stream sampling 'and analysis.
.Since the units have been
shutdown, the licensee had not : sampled any waste stream, - but
continued to use the waste stream analytical data from when-the units .
were last operated.
This was conservative due to decay and had been
previously' determined to be satisfactory. .The licensee planned to
perform their next sampling after. the waste streams had reached.
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equilibrium in activity after startup.
No violations or deviations were identified.
~b.
Waste Solidification
(1) Background
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The licensee solidified radioactive waste under a process
control program (PCP) to meet the waste stability requirements
of 10 CFR 61.56 and certain disposal site criteria. .
The
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licensee used a vendor, Chem-Nuclear Systems, Inc., to perform
the solidification services.
During May 1987, . problems were experienced during the
solidification of two liners containing CDWE bottoms.
The
contents of the liners started a rising process after quantities
of the vendor stabilization, solidification and defoaming agents
were added to the. waste bottoms in the liner.
The mixture
slowly flowed through the liner fill head and out the fill head
inpsection plate, leaving a solidified mass outside the confines
of the liner. The excess material was successfully chipped away
by the licensee and the liners were shipped to the disposal site
without incident.
Licensee investigation into the event revealed that the swelling
in the waste liners was caused by an exothermic reaction between
chemical -contaminants
in
the
waste
and
vendor
stabilization / solidification agents causing the waste to exceed a
temperature of 240'F.
This temperature was above the boiling
point of the mixture and this, in addition to the gases released
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during reaction, caused the swelling of the contents of.the
liner.
The licensee and vendor representatives were still investigating
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this problem at the conclusion of the inspection, but several
interim measures had been taken to preclude future liner
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overflows.
These measures included reducing the amount of waste
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introduced into a liner and restrictions on the use of a laundry
detergent (Turco 4324 NP) which was found to be especially
reactive with the vendor agents and was concentrated in the
waste as a residue from the processing of the laundry and hot
shower drain tank through the CDWE.
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(2) Waste Stream Processes
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10 CFR 50.59(b)(1) requires that the licensee shall maintain
records of changes in the facility and of changes in procedures
made pursuant to this section, to the extent that these changes
constitute changes in the facility as described in the safety
analysis report or to the extent that they constitute changes in
procedures as described in the safety analysis report.
These
records must include a written safety evaluation which provides
the bases of the determination that the change does not involve
an unreviewed safety question.
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The inspector discussed witt. i1censee representatives the
circumstances which led to the introduction of the laundry
detergent that was reactive with the solidification agents into
the CDWE waste stream.
The Final Safety Analysis Report (FSAR),
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Chapter 11.2 described the laundry and hot shower drain tank as
being normally sampled and discharged as an effluent, with
provisions for processing the liquid through the CDWE if the
sample result was above the discharge limit.
Licensee
representatives stated that in May 1987, they had changed the
process for this waste stream by sending all the laundry and hot
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shower waste water through the CDWE first and then sampling to
determine if it was releasable.
The change was made for ALARA
reasons to reduce the total activity in liquid effluents, but
the effect of this change was to cause higher quantities and
concentrations of laundry contaminants to appear in the CDWE
bottoms since previously only a minor amount of this waste was
processed through the CDWE.
Licensee representatives stated
that no 10 CFR 50.59 review had been performed for this change
in the radioactive waste process.
Failure to perform a Safety
review for the change in the manner in which the laundry and hot
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shower drain tank was processed was identified as an apparent
violation
of
(50-327/87-56-02
and
50-328/87-56-02).
(3) Waste Processing Procedures
Technician Specification 6.8.2 requires that changes to
Radioactive Waste Processing Procedures shall be reviewed by the.
Plant Operations Review Committee (PORC) and approved by the
Plant Superintendent prior to implementation.
The inspector discussed with licensee representatives and
reviewed documentation of an event on May 20, 1987, which
occurred during the solidification of one of the waste liners.
It was noted that the temperature of the mixture was increasing
above the maximum temperature given in the PCP. An air line was
connected to the liner in an attempt to dissipate the excessive
heat.
When the air was turned on, back pressure in the line
broke it away from the liner and liquid from the liner was
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sprayed on' t' o a vendor technician.
The technician was
contaminated .to 45,000 disintegrations' per.. minute (dpm) on his
right arm, 5000' dpm on his face and 400 dpm in tho: nostrils; L A
- subsequentf whole ' body count did not indicate any internally.
deposited activity. . The licensee did not: obtain a procedure-
~ hange.for connection of the air hose to the liner.
Failure to
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.obtain prior review and approval for the change to; the Radiation
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Waste _ Processing Procedure was. identified as ' an . apparent
violation of Technical-Specification 6.8.2-(50-327/87-56-03'and
50-328/87-56-03).
L il .- Transportation (86721)
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'10 CFR 71.5 requires - each licensee who transports licensed material
outside of the confines of its plant or- other place of use, or who
delivers licensed material to a-.. carrier for transport, shall comply with
the ' applicable requirements of the regulations appropriate to the mode cf
transport of the Departnert of Transportation in 49 CFR 170 through 189.
The inspector reviewed selected records _ of shipments perforned dcring
1987, and verified that they had been performed consistent with 49 CFR
requirements.
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No violations or deviations were identified.
12. ~Fo11cwupron Previous Inspector Identified Items (92701)
.(Closed) IFI'(50-327/328/83-28-02).
Faulty Magnehelic gauge on
hood No.' I-L-231 in the Hot Sample Room.
The inspector toured the Hot
Sample Room with licensee representatives and was shown-that the guages
were operable.
The inspector also discussed calibration of the gauges
with instrument maintenance personnel.
The inspector had no further
questions.
13.
Followup on Allegations (99014)
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a.
Allegation (Case No. RIl-87-A-0019)
The alleger was involvea in a contamination event on October 12,
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1983, in which his wrist became contaminated to 150,000 dpm 5,aile
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doing decontamination work.
He has since developed medical
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difficulties which he believes may have been caused by the
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contamination.
None of his doctors would tell him whether or not the
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contamination incident caused his illness.
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Discussion
This allegation was sent to the licensee for resciution.
The
licensee's investigation and findings were docurrented in their
Employee Concern Program Investigation Report [CP-87-SQ-253-01.
The
report stated that a contamination event did occur en October 12,
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1983, involving the alleger.
The alleger was decontaminating a
handrail lifting rig in a contamination zone on Elevation 734 under
RWP 83-0-00361.
The contamination levels in the area were
20,000 dpm/100 cm2
The alleger did not find any contamination when
he surveyed himself with a frisker upon leaving the area, but the
portal monitor alarined as he was exitNg the Auxiliary Building.
Contamination levels of 20,000 dpm on the right forearm and
150,000 dpm on the right pants pocket were found.
The alleger was
successfully decontamination by health physics.
No whole body count
was performed since there was no facial contamination. The licensee
determined that the event was likely caused by transferal of residual
contamination from his protective clothing as a result of sweating.
The allegur's exposures during the calendar quarter in which the
event occurred was 193 millirem to the whole body, skin of the whole
body and the extremities.
A dose calculation indicated that the
maximum dose to the skin of the forearm was 21 mrtm, which is
considered an extremity exposure.
The licensee concluded that the
contamination event and resulting exposures to his forearm could not
have caused the allegers medical complaints,
c.
Findings
The inspector reviewed and discussed the licensee's investigation
report with licensee representatives.
The inspector reviewed the
methodology for the exposure calculation that had been performed.
The licensee's skin dose assessment procedure provided two forumlas
to use depending on whether the contamination was measured with a
frisker (i.e., portable GM survey instrument with a pancake probe) or
some other instrunent. The 21 millirem dose was calculated using the
formula for an instrument other than a frisker and the dose was
averaged over an area of 100 cm2
The inspector questioned the
selection of formulas since skin contamination was typically measured
with a frisker. The type of instrument used was not documented. Use
of the frisker formula would have given an exposure estimate of
136 millirem.
Following the inspection, a health physicist from TVA's
Radiological Health Branch contacted the inspector and acknowledged
that at the time the calculations were rade he was unfamiliar with
how contamination events were routinely handled in the field and it
would have been more appropriate to use the other formula,
in this
case however, the choice of formulas was not significant in that
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exposures calculated by both techniques were well within flRC limits.
The inspector performed an independent exposure calculation using
techniques acceptable to the NRC (reference IE Information Notice No. 86-23:
Excess Skin Exposures Du ! to Contamination With Hot
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Particles) and concluded that the exposure was likely approximately
1,000 millirem.
The inspector determined that the licensee's smaller
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estimate was due in part to their averaging the dose over an area
greater than one square centimeter (i.e. 100 cm2), which is not
appropriate.
The exposure would have been therefore approximately
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2100 millirem using the licensee's formula.
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The Inspictor also questioned when ~ the exposure assessment was
performed and was' informed it was made after the allegation had been.
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.sent :to' the licensee and that no assessment had been made:in 1983
when the ever,t occurred.- Only recently has the need for calculating:
skin dose from contamination' events been recognized by the industry.
During" the time period in question, few if any -licensee ~ performed
such dose assessments.
The inspector stated that the investigation
report may be misleading in that it does not indicate when the
exposure assessment-was made nor explain why no' assessment was made-
when the' event' occurred.
Licensee representatives acknowledged that.
. portions of the report' needed clarification.
Conclusion
The. allegation was partially substantiated in that the al. leger was-
involved -in a contamination event in 1983.
Although discrepancies were
noted in the exposure assessment, the potentially higher exposure was
still well within the NRC quarterly exposure limit of 18.75 rem to the.
extremities.
No violations or deviations were identified.
14.
Followup on IE Information Notices (IENS) (92717)
The inspector determined that the following information notices had been
received by the licensee, reviewed for applicability, distributed to
appropriate personnel and that action, as appropriate, was taken or
. scheduled.
IEN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes
IEN 87-07: Quality Control of Onsite Dewatering / Solidification' Operations
by Outside Contractors
IEN 87-31:
Blocking, Bracing, and Securing of Radioactive Materials -
Packages in Transportation.
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