ML20236E206

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Insp Rept 50-302/87-29 on 870928-1002.Violation Noted. Major Areas Inspected:Radiation Protection Activities, Including Organization & Mgt Controls,Training & Qualifications,Internal Exposure Control & ALARA Programs
ML20236E206
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/19/1987
From: Hosey C, Kuzo G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236E185 List:
References
50-302-87-29, IEB-78-07, IEIN-84-25, IEIN-87-028, IEIN-87-031, IEIN-87-039, NUDOCS 8710290116
Download: ML20236E206 (13)


See also: IR 05000302/1987029

Text

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Report No.i 50-30s/87-29:
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, Ocensee: . Florida. Power Corporation "

                                                                 c3201 34th Street, South

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                                       Facility Name:                      Crystal River 3
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                                       Docket'No,':'S01302i                                                                                                                       : License No':
                                                                                                                                                                                               .     DRP-72-                                   ,
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                                       Inspection' conducted: . I'eptember                S            28-October 2,.19'87,
                       L        IInspector:                                  Lt4M bo:                                                                                                     N'OiNM N                                   ,
7                                 ,                                  G. B. K           ot
                                                                                                g                                                                                            Date Signed-
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                                   ; Accompanying Personnel: . H.,Bermudez
                                    . Approved by: h                                  j'
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                                                                                               Sectihn Chief. .
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                                                                                                                                                                                           . Date ' Signed
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                                                                      . Division of Radiat on, Safety and Safeguards'                                                                                                                                  l
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                                                                                                             SUMMARY
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                                   ~. Scope: This routine,;u'nannounced inspection of' radiation protaction activities
                                  - 1nvolved' review 'of previously identified followup' items and enforcement
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                                       matters,.' organization 4 and management controls, training and qualifications,                                                                                                                                  !
                                       internal exposure control,' changes to facilities;and equipment, ALARA-(as low                                                                                                                                   i
                                       as' reasonably achievable) programs, and ' inspector followup of.IE' Notices and                                                                                                                                 j
                                       Bulletins.                                                                                                                                                                                                    q
                                       Results: One' violation was identified:. ' failure to maintain adequate records                                                                                                                               1
                                       to implement the approved ~ respiratory protection program.                                                                                                                                                       i
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                                                                                              REPORT DETAILS
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       1.                                    Persons Contacted
                                             Licensee Personnel:                                                                                        !

l l .P. F. McKee, Station Manager . *B. J. Hickle, Manager, Nuclear Plant Operations L *W. L. Rossfeld, Manager, Site Nuclear Compliance

                                     *S.                            L. Robinson, Superintendent, Nuclear Chemistry and Radiation Protection
                                     *R.                             E. Fuller, Senior Nuclear Licensing Engineer                           .,
                                     *D.                            T. Wilder, Manager, Radiation Protection                                        ,
                                     *S.                            Johnson, Manager, Site Nuclear Services
                                             G. R. Clymer, Manager, Nuclear Waste
                                      *D. A. Van Oesterwyk, Supervisor, Health Physics
                                     *R. J. Browning, Supervisor, Health Physics
                                             A. Kazemfar, Supervisor, Nuclear Support Services
                                     *P. D. Breedlove, Supervisor, Records Management
                                     *G,                            H. Calwell, Specialist, Nuclear Chemistry and Radiation Protecticn
                                     *M.                            S. Mann, Specialist, Nuclear Compliance
                                     *S. Horvath, ALARA Specialist
                                     *M.                            Jacobs, Area Public Information Coordinator                                        '
                                             W. P. Ellsberry, Supervisor, Nuclear Technical Training
                                            A. Auner, Supervisor, Nuclear Operations Training Control                                              *
                                             S. L. Lashbrook, Supervisor, Health Physics
                                             W. J. Lagger, Supervisor, Health Physics
                                            M. M. Siapno, Supervisor, Health Physics
                                             P. F. Ezzell, Specialist, Radiochemistry - Environmental
                                             E. M. Kiztarek, Specialist, ALARA
                                            A. F. Sanchez, Director, FPC Regional Medical
                                             Nuclear Regulatory Conmission
                                            T. Stetka, Senior Resident Inspector                                                            '
                                     * Attended exit interview                                                                              7,
      2.                                     ExitInterview(30703)
                                             The inspection scope and findings were summarized on October 2,1987, with                          (
                                             those persons indicated in Paragraph 1 above. Two inspector followup                                    ,
                                              items regarding identification of plant radionuclides contaminants and the
                                             subsequent TLD dosimetry responses (Paragraph 9), and quality control of
                                             the new whole body counting systems (Paragraph 6) were reviewed. One
                                             violation concerning the failure to maintain adequate records for
                                              implementation of the respiratory protection program was discussed in                             '
                                             detail (Paragraph b). In addition, poor personnel radiation protection
                                             practices observed during the inspection were sunmarized. The licensee
                                             acknowledged the inspection findings and took no exceptions.                      The licensee
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               did not identify as proprietary any of the material provided to or                     i
               reviewed by the inspector during this inspection.
            3. Licensee Action on Previous Enforcement Matters (92702)
               a..  (Closed) Violation (50-302/86-06-02) Failure to previde reasonable                ,
                    assurance for DAW scaling factors. The inspector reviewed and                     !
                    verified the implementation of- the corrective actions stated in
                    Florida Power Corporation:'s letter of December 5, 1986.
               b.   (Closed) Violation (50-302/87-09-01) Inadequate respiratory
                    protection procedures. The inspector reviewed and verified the                    t
                    implementation of the corrective actions stated in Florida Power
                    Corporation's letter of April 24, 1987.
               c.   (Closed) Violation (50-302/87-09-02) Inadequate whole boiy counts.
                    The inspector reviewed and verified the implementation af the
                    corrective actions stated in Florida Power Corporation's latter of
                    April 24.1987. Additional details regarding the licensee cerrective
                    actions in this issue are discussed in Paragraph 6.                               j
               d.   (Closed) Violation (50-302/87-09-04) Failure to survey vehicle tops,
                    inadeouate survey of empty package, incorrect labels on rad waste
                    package. The -inspector reviewed and verified the implementation of
                    the corrective actions stated in Florida Power Corporation's letter               !
                    of April 24, 1987.
            4. Management Controls'and Organization (83722)
               Technical Specification (TS) 6.2.2 details the organizational structure
               for the site staff.      The inspector discussed approved amendments to
               TS 6.2.2 regarding site organization as agreed to in a letter from NRC
               Division of Licensing to Florida Power Corporation, Manager, Nuclear                   ]
               Licensing and Fuel Management, dated May 8,1984.      The inspector reviewed
                                                                                                      '
               the current health physics organization, staffing levels and lines of
               authority as they relate to radiation protection activities for routine
               and outage conditions.     Responsibilities are adequatcly defined and no              3
               organizational changes which could affect the licensee's ability to
               maintain adequate routine protection activities were noted.      Permanent
               health physics (HP) staff included 4 assistant HP technicians,
               22 ANSI N18.1 qualified HP technicians, 4 Chief HP technicians and 4 HP
               Supervisors. In addition, 7 contract HP personnel are assigned to the                    ,
               radiation protection staff and an additional 13 contract individuals                   !
               detailed to other functional site groups have been delegated HP duties.                 !
               As of January 1,1988, staffing of HP technicians is expected to increase
               to approximately 25 ANSI qualified indi"iduals.
               During the present outage, the radiation protection HP staff reports to
               and coordinates activities with one of four Outage Shift Managers. The
               Outage Shift Manager position is directly responsible to the Outage
               Manager.   Approximately 70 ANSI qualified journeymen HP technicians and

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   i                  '15 juniorf technicians . have been assigned directly to . the radiation
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                       protection HP staff during the' outage.. Licensee representatives stated
                      1that staffing.is. expected- to be adequate to meet outage HP requirements.
          ,            No violations or deviations were identified.
                5.     Training' and Qualifications'(83723)
                       a'.     Training.
                               10'CFR 19.12 requires the licensee to instruct all . individuals           ;
                               working'in or frequenting any portion of the restricted area in the        ,
                              . health protection aspects - associated 'with exposure to -radioactive
                               material or. radiation, in precautions or procedures to minimize
                               exposures, and in the.purposec and functions of protective devices
                             . employed, applicable provisions of Commission regulations, individual ~
                             : responsibilities and the availability of radiation exposure data.
                               The inspector'discusred with licensce representatives /the role of the      >
                               facility's training staff- 4 addressing identified weaknesses in the
                             Lradiation safety program. 'The Inspector referred to the recent
                               findings of contaminated equipment outside the radiation..' control area
                             :(RCA) and to reactor- operators wearing protective equipment.while^
                               unqualified.to do so.
                               Licensee- representatives -indicated that . the training program is-
                               continually updated to instruct personnel in areas where- weaknesses
                               have been identified. . Cognizant personnel .showed the inspector the      ,
                             . portion of the training outline in which procedures for the release        i
                               of; equipment from the RCA were emphasized. Students were instructed'      ,
                               that any material being taken ~out of the RCA must be checked by HP        '
                             . personnel for radioactivity to prevent contaminated iteins such as-        l
                               tools from leaving the RCA.
                             . Licensee representatives also indicated that all reactor operators
                               above apprentice level who were physically capable of wearing              ,
                               respiratory protection equipment would be trained in the use of the
                               Clifton. Precision Breathing Apparatus by October 2,1987, The
                               inspector obtained a copy of the Plant Operations Shift Schedule for
                               the week of September 28' - October 4,1987. By discussions and
                               review of training records, the inspector verified that all
                               medically-qualified reactor operators above apprentice level
                              . scheduled to work during the aforementioned week were qualified in
                               the use of the proper respiratory equipment.
                               Training of personnel as it related to radiological control for
                               specific jobs was evaluated during tours of the plant site.         In
                               general, plant personnel were observed to be following good practices
                               necessary to prevent or minimize the spread of radioactive
                               Xntaminanta to personnel or throughout the plant.        However, the

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        following poor radiation protection practices were observed during
        plant tours and discussed with licensee management in detail.
        1.     Unzippered protective clothing. Several instances of personnel
              working in containment or around its entrances were observed
               having partially opened or improperly fastened protective
               clothing. The inspector noted that licensee supervisors took.
               prompt appropriate action when these issues were -identified
               during their routine tours of work areas.
        ii. Conducting a contamination survey by reacning across a rope
               barrier specifying an area where respiratory protection was
               required. While conducting wipes for the routine contamination
               survey in containment, a HP technician sampled a filter housing
              behind a. partially dislodged roughing filter by reaching across
              a rope barrier posted as respiratory equipment required. The
               inspector noted that the technician was not wearing respiratory
              equipment.and that movement of the dislodged filter potentially
              could have resulted in airborne contamination and the subsequent
              spread of radioactive material to nearby areas. Discussion with
               the technician indicated that for general surveys specific
               sample locations were not detailed and the smear was being
              collected to evaluate the housing contamination prior to taking
              corrective actions for the dislodged filter,
        iii. Poorly marked contaminated material at the edge of a temporary
              RCA.    On October 1,1987, the inspector noted poorly marked
              contaminated material at the edge of a temporary RCA located     ;
              near the equipment hatch of the reactor building. The inspector
              noted that the labels were not highly visible and thus, the      l
              contaminated equipment easily could have been pushed outside of
              the RCA and then treated as non-contaminated items.
        iv.   Changes to Radiation Work Permit (RWP) respiratory protection
              requirements. The inspector discussed RWP R87-416, Determ Power
              Cables and N Cables, dated September 28, 1987, with workers and
              cognizant HP supervisors.       During observation of work in
              progress, the inspector noted that contrary to the RWP which
              specified only air purifying respiratory equipment, all workers
              were wearing air supplied systems. One worker believed that the
              RWP indicated the use of either air purifying or air supplied
              equipment. Furthermore, he stated that the HP technicians and
              supervisors were knowledgeable of and assured that workers         !
              complied with the RWF requirements. HP supervisors stated that
              air supplied equipment could be utilized, in that current          i
              radiation protection procedures allowed them to upgrade
              protective equipment. Further inspection disclosed that details
                                                                                 '
              for. upgrading RWP protective equipment for RWP work was not
              addressed in current procedures.       Licensee representatives
              stated that this issue would be evaluated and addressed in
              procedures in a timely manner.
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                        .No violations'or deviations'were. identified..
                                                                                                        I'
                    b..   Qualification Records
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   *~                     .10CFR0.103(c)(2)requiresthatthe.licenseemaintainandimplement
                        ' a t respiratory' protection program that includes determination by a
                        ~p hysician L prior to ' initial 'use of respirators that' the' individual
                          user. is ' physically able .to use respiratory equipment.
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                          The inspector reviewed the Respirator Issue and Return Log for               !
                          September 29, 1987, and randomly reviewed ' selected -individuals'
                          training. and qualification records. The records. reviewed included,-
                          qualification dates - for the. following. requirements: green badge
                          training, yellow badge- training, dressout and ifrisk, initial whole       '!
                          body. count, ' respirator training, respirators medical examination and
                          mask fit test.
                          The. inspector 1noted that training and _ qualification records of one
                          individual did not ' include' any' information regarding his medical
                          qualifications.: . When the inspector inquired about the finding, the
                          Nuclear Operator ' . Training ' Information System ~ (NOTIS) operator         <
                          indicat'ed that the~ individual's medical. qualifications had been           ,
                          deleted. . Originally, the individual was examined and determined to       l
                          be physically capable 'of wearing respirators, however, upon' further
                          review of the ' individual's medical history, the member of the medical
                                                                          '
                          staff felt it necessary to prevent. thel individual- from wea-ing
                         . respirators until some additional issues were resolved. The NOTIS
                          operator was contacted.by telephone by the medical staff and asked to
                          delete the individual's medical qualifications from his records. The         ,
                          change was then entered in the 'NOTIS master data base.
                                                                                                        '
                                                                                          Cognizant
                          personnel stated that the NOTIS database is used to generate a list
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   y'                     which technicians at the respirator. issue counter utilized to verify
                          personnel qualifications prior. to issuing respiratory protective
                          equipment. .Further review indicated that the. changes in the master
                        ~ NOTIS data base were not reflected in the respiratory technician's           !
                          list.    . Preliminary investigation indicated a problem in the              f
                          licensee's computer software.       In addition, discussions with licensee   ,
                          representatives indicated that quality control checks of the software          '
                          had-not been conducted prior to its use.                                     ,
                          Licensee representatives stated that the individual in question
                          indicated that he wore the respirator on September 29, 1987, for the
                        .first time, and that he was unaware he was medically unqualified to
                          wear it. The norida Power Corporatica Regional Medical Director
                          indicated that apparently. there had been mis-communications within          l
                                                                                                       '
                          members of the medical staff. he re-examined the individual in
                          question and reviewed his medical history on September 30, 1987, and         i

a ' determined that the individual was physically qualified to wear

                          respirators.
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                                 Plant Procedure RSP-101, " Basic Radiological Safety Inforrrnion and   ,
                                                                                                        '
                                 Instructions' to Workers," Section 2.4.4, Rev. 7, November lo,1986,
                                 states that qualification in CR-3's Respiratory Protection Program
                                 must be obtained prior to using any respiratory protective equipment
                                 for the purpose of preventing the inhalation or ingestion of
                                          ~
                                 radioactive material.
                                 Plant Procedure RSP-500, " Health Physics Respiratory Qualification
                                 Program," Section 2.4.16, Rev. 0, #nuary 17,1987, states that each
                                 functional area should forward lis s of individual's completion
                                 requirements as often as necessary to keep the Nuclear Operator
                                 Training Information System database current.
                                . Failure to have adequate controls to maintain and impleunt the
                                 respiratory protection program in order to prevent unauthorized use
                                 of respiratory protection equipment was identified as an apparent
                                 violation of 10 CFR 20.103(c)(2) (50-302/87-29-01).
              6.-          Internal Exposure Control (83725)
                           10 CFR 20,201(b requires each licensee to make or cause to be made such      j
                           surveys as (1) )necessary for the licensee to comply with regulations in
                           this part and (2) are reasonable under the circumstances to evaluate the
                           extent of radiation hazards that may be present.
                           a.    Whole Body Counting (WBC) Analyses
                                 10CFR20.103(a)(3) requires for purposes of compliance with
                                 requirements of this section, that the licensee use measurements of
                                 concentrations of radioactive materials in air for determining and     i
                                 evaluating airborne radioactivity in restricted areas and in           i
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                                 addition, as appropriate, use measurements of radioactivity in th
                                 body, measurements of radioactivity excreted 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.                                                   j
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                                 The licensee conducts entrance, termination, annual and special whole
                                 body counts (WBC) of personnel who could be exposed to airborne
                                 radioactive material. A previous inspection report (IE Report No.
                                 50-302/87-09) detailed inadequacies with the licensee's WBC analysis
                                 program.     Corrective actions regarding this issue . included the
                                 acquisition of new WBC analysis systems. The inspector reviewed and
                                 discussed with cognizant licensee representatives changes to the WBC
                                 analysis program. Two new WBC analpis systems, a Canberra Model
                                 2250 Fastscan Model using 2,4x4x16 inch sodium iodide detectors and a
                                 Canberra 2280 Accuscan II Model using 2 high efficiency germanium
                                 detectors, have been purchased. Cu rently, the Fastscan system is
                                 calibrated and in operation.     Initial setup and calibration for the
                                 Accuscan system had not been complete at the time of the inspection.
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                Prior 'to installation of. the new equipment, WBC ' analyses were
                conducted at the Emergency Offsite Facility (E0F) located                 1
                approximately 10 miles from the plant site.- The new Fastcan system       j
                is located onsite at the 95 foot elevation of the control complex-         t
                building in close. proximity to the RCA access area.         Licensee      '
                representatives stated that the Accuscan system also may be installed:     L
                onsite in an administration building (Rusty' Building) located within
                the protected area. The onsite location is expected to improve and         i
                facilitate WBC analyses during routine and non-routine events.
                The inspector discussed potential radiation contamination or high          I
                background radiation problems for the Fastscan system.      The system is
                located in close proximity to the portable instrument calibration
                laboratory on the 95 foot elevation of the control conglex building-
                and potentially could receive direct radiatkn exposure from sources
                used in normal calibration activities. Licensee representatives            i
                stated that careful review of WBC data with the radioactive sources
                                                                                           '
                unshielded in the instrument calibration laboratory disclosed no           !
                significant impact on WBC analyses.       In addition, potential high      l
                background radiation resulting from noble gas problems which may           ;
                occur in the nearby. auxiliary building were discussed. Ventilation        +
                airflow to the Fastcan WBC facility is not shared with the auxiliary
                building and thus background activity from high noble gas                  ;
                concentrations transferred to the WBC from the auxiliary building was      t
                not an anticipated problem. Furthermore, routine background analysis       l
                would provide an indication of any noble gas problems.                     l
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                The inspector discussed the ' quality control program for the WBC          l
                analysis program with cognizant licensee representatives.          The
                following procedures concerning the WBC program were discussed:
                -
                       HPP-320, Whole Body Counting System Operation, Rev. 3, July 1,
                       1987
                -      HPP-322, Whole Body Counting System Calibration, Rev. 2, June 8,    ;
                       1987                                                                j
                The inspector noted that the procedures did not provide detailed           j
                guidance regarding the identification and quentification, and
                notification responsibilities to operating technicians regarding           t
                unidentified energy peaks during WBC analyses.        The inspector
                reviewed QC data from July 7 through October 1,1987, for the
                Fastscan system. All background and analytical performance criteria        i
                were within established licensee acceptance criteria.        Review of
                                                                                           '

j procedures and discussion of the system software with licensee i

                representatives, indicated that the acceptance criteria for QC
                performance measurements were not based on standard statistical or
                vendor methodology.       From review and comparison of licensee WBC
                minimum detectable activities with the lower limits of detection
                calculated for specific radionuclides the inspector determined that a
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                systematic verification of the vendor software programs had not been

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                                     conducted.'   Licensee representatives agreed to evaluate analytical
                                     and QC areas' of the WBC program.     The inspector informed licensee
                                     representatives that these issues regarding the WBC analysis program
                                                                        item (IFI) and would be reviewed
                                     would
                                     during abe  an inspector
                                               subsequent     . followup (50-302/87-29-02).
                                                          inspection
                                     No violations or deviations were identified.
                          b.         MPC-hour Assignments
                                     10 CFR 20.103(b) requires that when it is impractical to apply
                                     process or . engineering controls to limit concentrations of
                                     radioactive materials in air below 25% of the concentrations
                                     specified in Appendix B, Table 1, Column 1, other precautionary.
                                     measures should be used to maintain the intake of radioactive
                                     materials by any individual within seven consecutive days as far
                                     below 40 MPC-hours as is reasonably achievable.
                                     The inspector discussed with licensee representatives their method of-
                                     MPC-hour' tracking for personnel issued respiratory protection
                                     equipment for work in the reactor building during the period of
                                     September 29-October 1,1987.      Health physics technicians stated that
                                     the reactor building had been purged and general area airborne
                                     concentrations were well below 25% MPC, and therefore, MPC-hour
                                     tracking was not necessary. They stated that the purpose of wearing       i
                                     the respiratory protection equipment was to prevent facial                !
                                     contamination and to prevent -any . intakes during work in highly .
                                     contaminated areas were the potential for creating airborne areas
                                     existed. The inspector independently reviewed several RWPs for work
                                     in the reactor building and their associated air sample results. The
                                     inspector also verified that health physics coverage was required for.
                                     work in highly contaminated areas and observed the use of breathing
                                     zone air samplers where the potential for creating airborne areas
                                     existed.
                                     No violations or deviations were identified.
                  7.      Facilities and Equipment (83727)
                          The inspector discussed changes to equipment and facilities and toured
                          selected facilities with licensee representatives,
                          a.         Whole Body Counting Systems.      Whole body counting equipment and
                                     facility changes are discussed in Paragraph 6.                           ;
                          b.         Portable Instrunent Calibration Laboratory

o The licensee has relocated the portable instrument calibration L laboratory from the turbine deck to an area adjacent to the RCA L control point on the 95 foot elevation. The new facility provides l added space for routine calibration activities and instrument ! L

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             storage.     Furthermore, licensee representatives indicated that the

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             location allows for increased use and improved tracking of the
             portable radiation monitoring instruments.
             The effect of using calibration' sources in close proximity to the
             present .WBC system and the RCA exit. PCM-18 portal monitors was
             discussed.     From discussion with HP technicians and review of
             selected records, the licensee had not experienced any false portal
             monitor alarms or high background counts for the WBC system as a
             result of operation of the calibration facility.
             No violations or deviations were identified.
          c. Wet Laundry
             The licensee has relocated the wet laundry from the 95 foot elevation
             adjacent to the RCA exit point in the auxiliary building to the 119
             foot elevation near the hot machine shop. This change has resulted-
             in a decrease in background radiation in the RCA access and exit
             areas with no negative impact noted for the new location. Licensee
             HP. management representatives have proposed the purchase of.and have
             initiated ' review of specifications for laundry monitoring equipment
             to be utilized for the laundry facilities.
             No violations or deviations were identified,
          d. Material Frisking /Decon Service Room
             The licensee has established a new RCA frisking /decon area and
             service room on the 119 foot elevation outside the auxiliary building
             near the hot machine shop. The facility has been operational since      !
             August 1987, and allows trisking of potentially contaminated material
             in a low background area, approximately 40-50 counts per minute
             (CPM).    In addition, licensee management indicated that procurement
             of tool monitoring equipment has been initiated and will be utilized
             in this frisking area.
                                                                                     .
             The inspector reviewed the most recent radiation safety incident
             reports (RSIR) (June through September 1987) regarding the finding of
             contaminated material outside of the RCA. Review of the records and
             discussion with licensee representatives indicated that the materials
             most recently found were items released prior to establishment of the   .
             new control point. Originally, frisking of material was conducted in
                                                                                      '
             areas with higher radiation backgrcund and resulted in the release of
             contaminated materials to uncontrolled areas.            Licensee
             representatives indicated that the frisking of potentially
             contaminated materials and their subsequent release from this new low    '
             background control point should prevent the recurrence of finding
             contaminated material outside of the RCA. Furthermore, licensee
             management indicated that following the present outage work, a
             detailed radiation survey of all areas of the site would be conducted
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                    to evaluate the effect-of the new frisking facility on the control of
                    radioactive contaminated material.                                     s
                                                                                          1
                    No violations or deviations were identified.
        8.-  Maintaining Exposure ALARA (83728)                                            l
                                                                                           l
              10 CFR 20.1(c) speci'ies that licensees should implement programs to make
             every reasonable effort to maintain radiation exposures as low as
              reasonably achievable (ALARA).     The recommended elements of an ALARA
            . Program. are contained in Regulatory Guide 8.8, "Information Relevant to
              Ensuring that Occupational Exposures at Nuclear Power Station will be        i
             ALARA," and Regulatory Guide 8.10, " Operating Philosophy for Maintaining
             Occupational Exposures ALARA."
             The inspector discussed with licensee representatives the facility's ALARA.
              Programs, in relation to the outage in progress. Licensee representatives
              indicated 291 person-rem were expected to be directly attributable to        ,
             outage activities out of an estimated collective radiation dose of
             350 person-rem for 1987.    The 291 person-rem estimate for the outage was
             based on plant history, work comparisons and lessons learned and did not
             allow for any unscheduled / unanticipated work.
             .S]ecial duties associated with the outage include the use of members from
              t1e facility's ALARA staff to perform walk-throughs to check for good        i
             ALARA practices such as contamination control and the effective use of        ,
              time, distance and shielding.       It was indicated that the total
             contaminated square footage within the Radiation Control Area (RCA) was
             not expected to change significantly after the outage ends.                   ]
                                                                                           ;
             The inspector observed the evaluations of a job associated with the
              removal of surveillance capsules from a shielded cask. The inspector
             attended pre-job briefings in which the specifics of the job were
             discussed.      These included the source description, expected contact       l
              (7 R/hr) and three-foot (150 mR/hr) radiation levels, radiation detection
              instruments to be used, steps to be followed, personnel responsibilities,
             and a contigency plan in the event that unanticipated radiation levels        ,
                                                                                           '
             were encountered.
             The inspector reviewed selected details of the entire job.        Training
              records of selected individuals involved in the job were verified in that
              their radiation worker training qualifications were current.    Calibration
             of instruments utilized were current. Highest accumulated individual
             exposure for this job was 4 millirems, as measured by pocket dosimeter.
             The inspector attended several daily planning meetings in which
              representatives of the groups involved in outage work discussed the status
             of their respective activities.      Emphasis was placed on general safety,
             especially on RWP compliance and on the proper use of dosimetry and
             protective clothing. Supervisors were asked to question their workers on
             the content of the (RWP) on which they were working. They were also asked
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             to verify that their _ workers did not change . protective clothing items    1
             unless approved by Health Physics and the RWP was changed to reflect such
             approval. .
                                                                                           t
             No violations or deviations were identified.
         9.  InspectorFollowupItems(IFI)(92701)
                                                                                           l
             (Closed) IFI (50-302/87-09-03) This IFI ' dealt with the results of the TLD   L
             response study and the licensee actions to resolve suspected inaccuracies     q
             in a new vendor TLD system. The NRC and the licensee conducted an               !
             independent dosimeter performance study of the vendor TLD system. Results        l
             obtained from the study indicated an overall under-response to gamma and
             mixed beta-gamma doses. The licensee conducted additional independent
             performance studies, which also indicated nonconservative results. The          ;
             licensee terminated the vendor's services in August.1987, and reinstituted    j
             a contract with a TLD vendor utilized prior to January 1986. Quality            l
             control results for this previous vendor appeared adequate.
                                                                                             .
             The licensee reviewed the dose records of the employees who received the
             highest doses during the period (February 1986-August _1987) in which the
             vendor's services were suspect. The inspector verified that in the            ,d
             worst-case scenario, where persons receiving the highest orginally           1
             reported exposures were increased by the greatest positive tolerance'(bias      i
             dno standard deviation Cdlculated from known exposures during the studies,    '
             approximately 27%), no doses in excess of regulatory requirements would
             have occurred.
             Licensee representatives indicated that they crc presently scheduled to
             perform beta energy studies in several areas of the plant where
             significant beta fields were present.     The inspector stated that detailed
             beta energy studies were relevant to an adequate TLD and instrument              ,
             calibration program. The inspector informed licensee management that          4
             results of the beta energy studies and subsequent radionuclides energy        1
             calibration programs for the facility dosimetry program will be considered      j
             anInspectorFollowupItem(50-302/87-29-03).                                       i
         10. IE Bulletin (IEB) Followup (92703)
             (Closed) IEB (78-80-07) Protection Afforded by Airline Respirator and
             Supplied Air Hood
             On June 12, 1978, NRC issued IE Bulletin No. 78-07 which indicated that
             protection provided by airline supplied air respirators operated in the
             demand mode was much less than originally estimated.       Licensees were
             required to perform a review of the plant respiratory protection program
             and outline actions to be taken to assure protection of personnel using
             airline supplied air respirators operating in the demand mode. The               l
             licensee's response dated June 16, 1978, was reviewed and actions taken          -
             were adequate. An additional evaluation of the bulletin as it applied to
             the present respiratory protection program was conducted and documented in
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                                a. response dated May 26 F1987, (The response noted that.curren't licensee-
                                procedures use ;the appropriate protection factors ' as specified .in
                                                                                                                  ,
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                                                                                             '
                              -10LCFR 20,-Appendix' A..
>.                                                  ..
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                    - 11. . IEInformationNotices-(92717).                                                   <
                                                                                                                     j
                                The~ inspector determined that the following NRC.Information. Notices:(IEN)I
                                                                                  E
                                                                                                                      1
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                                had been received.by ihe licensee, reviewed for applicability, distributed
                                                                                                    ~
                                                                                                                           l
                             ;-to appropriate' personnel and.that actions, as' appropriate,-were taken or-           1
                                schedul ed. ..
                                                                                                                     <l
                             .' a .'   .IEN 84-75: Calibration . Problems - Eberline Instrument' Model 61128'
                                        Analog Teletectors.
                              ~ b.     'IEN 87-28:: . Air Systems Problems at U. S. L'ght Water Reacters.                  ;
                                                                                                                           I
                                c.     'IEN:87-31: Blocking, Bracing,' and l Securing of Radioactive Materials.            ;
,
                                         Package in Transportation.-                                                 q
  ,.                                                                                                                 .4
                                d;       IEN 87-39: - Control of Hot! Farticle -Contamination at Nuclear Power.      O     '
                                         P1 ants.
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