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Text

IR 05000424-08-005 & 05000425 on 01/20/09 for Vogtle Electric Generating Plant
	ML090430143
Person / Time
Site:	Vogtle
Issue date:	02/12/2009
From:	Scott Shaeffer; NRC/RGN-II/DRP/RPB2
To:	Tynan T; Southern Nuclear Operating Co
Shared Package
ML090430130	List: IR 05000424/2008005; ML090430143;
References
	IR-08-005
	Download: ML090430143 (17)
	v • d • e

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

SAM NUNN ATLANTA FEDERAL CENTER

61 FORSYTH STREET, SW, SUITE 23T85

ATLANTA, GEORGIA 30303-8931

February 12, 2009

Mr. Tom E. Tynan

Vice President

Southern Nuclear Operating Company, Inc.

Vogtle Electric Generating Plant

7821 River Road

Waynesboro, GA 30830

SUBJECT: ERRATA LETTER - VOGTLE ELECTRIC GENERATING PLANT - NRC

INSPECTION REPORT 05000424/2008005 AND 05000425/2008005

Dear Mr. Tynan:

By letter dated January 20, 2009, we transmitted the results of the routine baseline inspections

for the fourth quarter of 2008 (ML090200064). This report is being revised to provide additional

information typically provided regarding radiation dose rates as discussed on pages 17 and 18

of the report. This revision does not change the inspection results. Please replace pages 17

through 22 of the report transmitted on January 20, 2009, with the enclosed revision.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

I regret any inconvenience this omission may have caused. Please contact me at (404) 562-

4521 if you have any questions.

Sincerely,

/RA/

Scott M. Shaeffer, Chief

Reactor Projects Branch 2

Division of Reactor Projects

Docket Nos.: 50-424, 50-425

License Nos.: NPF-68, NPF-81

Enclosures: 1. Revised Pages

2. Removed Pages

cc w/encl: (See next page)

_________________________ XG SUNSI REVIEW COMPLETE

OFFICE RII:DRP RII:DRP RII:DRS RII:DRS

SIGNATURE CWR1 SMS BRB1 AND

NAME CRapp SShaeffer BBonser ANielson

DATE 02/11/2009 02/11/2009 02/11/2009 02/11/2009 2/ /2009 2/ /2009

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO

SNC 2

cc w/encl: Mr. N. Holcomb

Angela Thornhill Commissioner

Managing Attorney and Compliance Officer Department of Natural Resources

Southern Nuclear Operating Company, Inc. Electronic Mail Distribution

Electronic Mail Distribution

Dr. Carol Couch

N. J. Stringfellow Director

Manager Environmental Protection

Licensing Department of Natural Resources

Southern Nuclear Operating Company, Inc. Electronic Mail Distribution

Electronic Mail Distribution

Cynthia Sanders

Jeffrey T. Gasser Program Manager

Executive Vice President Radioactive Materials Program

Southern Nuclear Operating Company, Inc. Department of Natural Resources

Electronic Mail Distribution Electronic Mail Distribution

L. Mike Stinson Jim Sommerville

Vice President (Acting) Chief

Fleet Operations Support Environmental Protection Division

Southern Nuclear Operating Company, Inc. Department of Natural Resources

Electronic Mail Distribution Electronic Mail Distribution

Michael A. MacFarlane Mr. Steven M. Jackson

Southern Nuclear Operating Company, Inc. Senior Engineer - Power Supply

40 Inverness Center Parkway Municipal Electric Authority of Georgia

P.O. Box 1295 Electronic Mail Distribution

Birmingham, AL 35201-1295

Mr. Reece McAlister

David H. Jones Executive Secretary

Vice President Georgia Public Service Commission

Engineering Electronic Mail Distribution

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution Office of the Attorney General

Electronic Mail Distribution

Bob Masse

Resident Manager Office of the County Commissioner

Vogtle Electric Generating Plant Burke County Commission

Oglethorpe Power Corporation Electronic Mail Distribution

Electronic Mail Distribution

Arthur H. Domby, Esq.

Moanica Caston Troutman Sanders

Vice President and General Counsel Electronic Mail Distribution

Southern Nuclear Operating Company, Inc.

Electronic Mail Distribution (cc w/encl contd - See next page)

Laurence Bergen

Oglethorpe Power Corporation

Electronic Mail Distribution

SNC 3

cc w/encl contd:

Director

Consumers' Utility Counsel Division

Govenor's Office of Consumer Affairs

2 M. L. King, Jr. Drive

Plaza Level East; Suite 356

Atlanta, GA 30334-4600

Senior Resident Inspector

Southern Nuclear Operating Company, Inc.

Vogtle Electric Generating Plant

U.S. NRC

7821 River Road

Waynesboro, GA 30830

Susan E. Jenkins

Director, Division of Waste Management

Bureau of Land and Waste Management

S.C. Department of Health and

Environmental Control

Electronic Mail Distribution

SNC 4

Letter to Tom E. Tynan from Scott M. Shaeffer dated February 12, 2009

SUBJECT: ERRATA LETTER - VOGTLE ELECTRIC GENERATING PLANT - NRC

INSPECTION REPORT 05000424/2008005 AND 05000425/2008005

Distribution w/encl:

C. Evans, RII EICS (Part 72 Only)

L. Slack, RII EICS (Linda Slack)

OE Mail (email address if applicable)

RIDSNRRDIRS

PUBLIC

R. Martin, NRR (PM: HAT, SUM)

17

Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee

procedures. Documents reviewed are listed in the report Attachment. The inspectors

completed 21 of the required line-item samples described in Inspection Procedure (IP)

71121.01.

Problem Identification and Resolution. The inspectors reviewed corrective action

program (CAP) documents associated with access control to radiologically significant

areas. This included review of selected CRs related to radworker and HPT

performance. The inspectors evaluated the licensees ability to identify, characterize,

prioritize, and resolve the identified issues in accordance with procedure NMP-GM-002.

The inspectors also evaluated the scope of the licensees internal audit program and

reviewed recent assessment results. Documents reviewed are listed in the Attachment.

b. Findings

Introduction: Two examples of a Green, self-revealing, non-cited violation (NCV) of TS 5.7.1, High Radiation Area, were identified for unauthorized entries into HRAs.

Inadequate communication between workers and HP resulted in licensee personnel

breaching HRA boundaries without prior knowledge of the radiological condition.

Description: On May 9, 2007, a Shift Operator (SO) performed a visual inspection in the

Unit 2 Residual Heat Removal Pump Room A. This room contained both a Radiation

Area (RA) and a posted and barricaded HRA. The SO contacted HP prior to entering

the room, but failed to communicate that entry into the HRA might be required. As a

result, HP briefed the SO on current radiological conditions outside the rope barricade

and not on conditions inside the HRA. The assigned RWP did not allow entry into HRAs

without first obtaining a briefing on the HRA radiological conditions. Typically, this

inspection does not require the SO to pass the HRA boundary, however insulation

obstructed the SOs view from outside the HRA. Without knowledge of dose rates in the

HRA, the SO proceeded past the HRA boundary and subsequently received an ED dose

rate alarm. Dose rates inside the area were as high as 160 mrem/hr.

On August 16, 2007, two Facilities personnel entered the Unit 2 Fuel Handling Building

room 2-FHB-A-01 to perform cleaning duties and replace light bulbs. This area

contained a Contaminated Area (CA), RA, and a posted and barricaded HRA. Prior to

starting work, the personnel were briefed by HP on radiological conditions in the CA and

RA, but not on dose rates in the HRA. There was no clear understanding between the

two groups that a HRA entry would be required. The assigned RWP did not allow entry

into HRAs without first obtaining a briefing on the HRA conditions. Without knowledge of

dose rates in the HRA, one worker proceeded past the HRA boundary in room 2-FHB-A-

01 to continue the housekeeping activities and received an ED dose rate alarm. Dose

rates in the area were as high as 238 mrem/hr at 30cm.

Analysis: The inspectors determined that the unauthorized entries into HRAs were

performance deficiencies. This finding is greater than minor because it is associated

with the Occupational Radiation Safety Cornerstone attribute of Human Performance

and adversely affects the cornerstone objective of ensuring adequate protection of

worker health and safety from exposure to radiation from radioactive material during

routine civilian nuclear reactor operation. Workers who enter HRAs without prior

knowledge of current radiological conditions could receive unintended occupational

exposures. The finding was evaluated using the Occupational Radiation Safety SDP

Enclosure 1

18

and determined to be of very low safety significance (Green). The finding was not

related to ALARA planning, nor did it involve an overexposure or substantial potential for

overexposure, and the ability to assess dose was not compromised. This finding

involved the cross-cutting aspect of Human Performance, Work Practices H.4.a]

because the HRA events were a direct result of poor communications during pre-job

briefings and a willingness on the part of licensee personnel to proceed in the face of

uncertainty.

Enforcement: TS 5.7.1, High Radiation Area, requires individuals entering HRAs to

meet one or more of the following criteria: 1) carry a survey meter; 2) wear an ED and be

made aware of radiological conditions in the area; or 3) be escorted by a HP technician.

Contrary to the above, on May 9, 2007, and on August 16, 2007, plant personnel

entered HRAs without a survey meter, without being aware of radiological conditions in

the area, or without HP technician escort. Because the violation is of very low safety

significance and has been entered into the licensees CAP (CR 2007105476 and CR

2007108830), this violation is being treated as an NCV, consistent with Section VI.A of

the NRC Enforcement Policy: NCV 05000424/425, 2008005-01, Unauthorized Entries

Into High Radiation Areas.

2OS2 ALARA Planning and Controls

a. Inspection Scope

The inspectors reviewed ALARA program guidance and its implementation for ongoing

2R13 job tasks. The inspectors evaluated the accuracy of ALARA work planning and

dose budgeting, observed implementation of ALARA initiatives and radiation controls for

selected jobs in-progress, assessed the effectiveness of source-term reduction efforts,

and reviewed historical dose information.

ALARA planning documents and procedural guidance were reviewed and projected

dose estimates were compared to actual dose expenditures for the following high dose

jobs: scaffolding installation/removal, reactor vessel head work, steam generator

maintenance activities, motor operated valve (MOV) testing and maintenance, and

installation of the external neutron monitoring system inside containment. Differences

between budgeted dose and actual exposure received were discussed with cognizant

ALARA staff. Changes to dose budgets relative to changes in radiation source term

and/or job scope were also discussed. The inspectors attended pre-job briefings and

evaluated the communication of ALARA goals, RWP requirements, and industry

lessons-learned to job crew personnel.

The inspectors made direct field or closed-circuit-video observations of outage job tasks

involving work inside Unit 2 containment. For the selected tasks, the inspectors

evaluated radworker and HPT job performance, individual and collective dose

expenditure versus percentage of job completion, surveys of the work areas,

appropriateness of RWP requirements, and adequacy of implemented administrative

and physical controls.

Implementation and effectiveness of selected program initiatives with respect to source-

term reduction were evaluated. Chemistry program ALARA initiatives and their effect on

containment and auxiliary building dose rate trends were reviewed.

Enclosure 1

19

Plant exposure history for 2005 through 2008 year-too-date, and data reported to the

NRC pursuant to 10 CFR 20.2206 were reviewed, as were established goals for

reducing collective exposure during the current 2R13 outage. The inspectors reviewed

procedural guidance for dosimetry issuance and exposure tracking. The inspectors also

examined dose records of declared pregnant workers to evaluate assignment of

gestation dose.

ALARA program activities and their implementation were reviewed against 10 CFR Part

20, and approved licensee procedures. In addition, licensee performance was evaluated

against guidance contained in Regulatory Guide (RG) 8.8, Information Relevant to

Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As

Low As Reasonably Achievable, and RG 8.13, Instruction Concerning Prenatal

Radiation Exposure. Documents reviewed are listed in of the Attachment. The

inspectors completed 20 samples of specified line-items in IP 71121.02 to close the

procedure.

Problem Identification and Resolution. The inspectors reviewed selected CR and Action

Item (AI) data in the area of exposure control. The inspectors evaluated the licensees

ability to identify, characterize, prioritize, and resolve the identified issues in accordance

with NMP-GM-002. The inspectors also evaluated the scope of the licensees internal

audit program and reviewed recent assessment results. Documents reviewed are listed

in the Attachment.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

a. Inspection Scope

Groundwater Monitoring. The inspectors discussed current and future programs for

onsite groundwater monitoring with chemistry specialists and corporate staff, including

number and placement of monitoring wells and identification of plant systems with the

greatest potential for contaminated leakage. The inspectors also reviewed procedural

guidance for identifying and assessing onsite spills and leaks of contaminated fluids. In

addition, the inspectors reviewed records of historical and recent contaminated spills

retained for decommissioning purposes as required by 10 CFR Part 50.75(g).

The licensee has installed a number of onsite groundwater monitoring wells; optimally

located to detect contamination based on recent hydrological studies. The sample

results from these wells were included in the Annual Radiological Environmental

Monitoring Program Report. For the period reviewed, all monitoring well results were

below reporting limits (20,000 pCi/L for drinking water and 30,000 pCi/L for non-drinking

water).

b. Findings

No findings of significance were identified.

Enclosure 1

20

2PS2 Radioactive Material Processing and Transportation

a. Inspection Scope

Waste Processing and Characterization During inspector walk-downs, accessible

sections of the liquid and solid radwaste processing systems were assessed for material

condition and conformance with system design diagrams. Inspected equipment included

floor drain tanks; resin transfer piping; resin and filter packaging components; and

abandoned evaporator equipment. The inspectors discussed component function,

processing system changes, and radwaste program implementation with licensee staff.

The 2007 Effluent Report and radionuclide characterizations from 2007 - 2008 for each

major waste stream were reviewed and discussed with radwaste staff. For primary

filters and Dry Active Waste (DAW) the inspectors evaluated analyses for hard-to-detect

nuclides, reviewed the use of scaling factors, and examined comparison results between

licensee waste stream characterizations and outside laboratory data. Waste stream

mixing and concentration averaging methodology for spent resin and primary filters were

evaluated and discussed with radwaste operators. The inspectors also reviewed the

licensees procedural guidance for monitoring changes in waste stream isotopic

mixtures.

Radwaste processing activities and equipment configuration were reviewed for

compliance with the licensees Process Control Program and UFSAR, Chapter 11.

Waste stream characterization analyses were reviewed against regulations detailed in

10 CFR Part 20, 10 CFR Part 61, and guidance provided in the Branch Technical

Position on Waste Classification and Waste Form. Reviewed documents are listed in

Section 2PS2 of the report Attachment.

Transportation The inspectors directly observed preparation activities for a shipment of

contaminated laundry. The inspectors noted package markings and placarding,

observed dose rate measurements, and interviewed shipping technicians regarding

Department of Transportation (DOT) regulations.

Five shipping records were reviewed for consistency with licensee procedures and

compliance with NRC and DOT regulations. The inspectors reviewed emergency

response information, DOT shipping package classification, radiation survey results, and

evaluated whether licensees in receiving were authorized to accept the packages.

Procedures for opening and closing Type B shipping casks were compared to Certificate

of Compliance requirements. In addition, training records for selected individuals

currently qualified to facilitate the shipment of radioactive material were reviewed.

Transportation program implementation was reviewed against regulations detailed in 10

CFR Part 20, 10 CFR Part 71, 49 CFR Parts 172-178; as well as the guidance provided

in NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and

Surface Contaminated Objects. Training activities were assessed against 49 CFR Part

172 Subpart H. Documents reviewed are listed in the Attachment. The inspectors

completed 6 of 6 samples as required by IP 71122.02.

Problem Identification and Resolution Selected CRs in the area of radwaste processing

and transportation were reviewed in detail and discussed with licensee personnel. The

Enclosure 1

21

inspectors assessed the licensees ability to characterize, prioritize, and resolve the

identified issues in accordance with licensee procedure NMP-GM-002. The inspectors

also evaluated the scope of the licensees internal audit program and reviewed recent

assessment results. Licensee CAP documents reviewed are listed in Section 2PS2 of

the report Attachment.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator (PI) Verification

a. Inspection Scope

The inspectors sampled licensee submittals for the listed PIs during the period from

July 1, 2007 through June 30, 2008, for Unit 1 and Unit 2. The inspectors verified the

licensees basis in reporting each data element using the PI definitions and guidance

contained in procedure 00163-C, NRC Performance Indicator and Monthly Operating

Report Preparation and Submittal, and Nuclear Energy Institute document NEI 99-02,

Regulatory Assessment Indicator Guideline.

Cornerstone: Mitigating Systems

C Mitigating Systems Performance Index (MSPI), Cooling Water Systems

C MSPI, Emergency AC Power Systems

C Safety System Functional Failures

The inspectors reviewed Unit 1 and Unit 2 operator log entries, the Vogtle Electric

Generating Plant Unit 1 and Unit 2 NRC Mitigating System Performance Index Basis

Document, the monthly operating reports and monthly PI summary reports to verify that

the licensee had accurately submitted the PI data.

Cornerstone: Occupational Radiation Safety

Occupational Exposure Control Effectiveness

The inspectors reviewed PI data collected from January 1, 2007, through September 30,

2008. For the reviewed period, the inspectors assessed CAP records to determine

whether HRA, VHRA, or unplanned exposures, resulting in TS or 10 CFR 20 non-

conformances, had occurred during the review period. In addition, the inspectors

reviewed selected personnel contamination event data, internal dose assessment

results, and ED alarms for cumulative doses and/or dose rates exceeding established

set-points. Documents reviewed are listed in the Attachment.

Cornerstone: Public Radiation Safety

Radiological Control Effluent Release Occurrences

The inspectors reviewed the PI results for the period of January 1, 2007, through

September 30, 2008. For the assessment period, the inspectors reviewed cumulative

and projected doses to the public, out-of-service effluent radiation monitors and

compensatory sampling data. The inspectors also reviewed licensee procedural

Enclosure 1

22

guidance for collecting and documenting PI data. Documents reviewed are listed in the

Attachment.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Daily Condition Report Review. As required by Inspection Procedure 71152,

Identification and Resolution of Problems, and in order to help identify repetitive

equipment failures or specific human performance issues for follow-up, the inspectors

performed a daily screening of items entered into the licensees corrective action

program. This review was accomplished by either attending daily screening meetings

that briefly discussed major CRs, or accessing the licensees computerized corrective

action database and reviewing each CR that was initiated.

.2 Focused Review

a. Inspection Scope

The inspectors performed a detailed review of the work-around lists for Unit 1 and 2 that

were in effect on October 28. The inspectors reviewed the licensees list to determine

whether any items would adversely affect the operators ability to implement abnormal or

emergency operating procedures. The inspectors reviewed proposed corrective actions

and schedule for each item on the work-around list. The inspectors reviewed the

compensatory actions and cumulative effects on plant operation. The inspectors verified

each item was being dispositioned in accordance with plant procedure 10025-C, Work

Around Program. Documents reviewed are listed in the Attachment.

b. Findings and Observations

No findings of significance were identified.

Enclosure 1

17

Section 12; TS Sections 5.4 and 5.7; 10 CFR Parts 19 and 20; and approved licensee

procedures. Documents reviewed are listed in the report Attachment. The inspectors

completed 21 of the required line-item samples described in Inspection Procedure (IP)

71121.01.

Problem Identification and Resolution The inspectors reviewed corrective action

program (CAP) documents associated with access control to radiologically significant

areas. This included review of selected CRs related to radworker and HPT

performance. The inspectors evaluated the licensees ability to identify, characterize,

prioritize, and resolve the identified issues in accordance with procedure NMP-GM-002.

The inspectors also evaluated the scope of the licensees internal audit program and

reviewed recent assessment results. Documents reviewed are listed in the Attachment.

b. Findings

Introduction. Two examples of a Green, self-revealing, non-cited violation (NCV) of TS 5.7.1, High Radiation Area, was identified for unauthorized entries into HRAs.

Inadequate communication between workers and HP resulted in licensee personnel

breaching HRA boundaries without prior knowledge of the radiological condition.

Description On May 9, 2007, a Shift Operator (SO) performed a visual inspection in the

Unit 2 Residual Heat Removal Pump Room A. This room contained both a Radiation

Area (RA) and a posted and barricaded HRA. The SO contacted HP prior to entering

the room, but failed to communicate that entry into the HRA might be required. As a

result, HP briefed the SO on current RA radiological conditions. The assigned RWP did

not allow entry into HRAs without first obtaining a briefing on the HRA radiological

conditions. Typically, this inspection does not require the SO to pass the HRA boundary;

however, insulation obstructed the SOs view from outside the HRA. Without knowledge

of dose rates in the HRA, the SO proceeded past the HRA boundary and subsequently

received an ED dose rate alarm.

On August 16, 2007, two Facilities personnel entered the Unit 2 Fuel Handling Building

room 2-FHB-A-01 to perform cleaning duties and replace light bulbs. This area

contained a Contaminated Area (CA), RA, and a posted and barricaded HRA. Prior to

starting work, the personnel were briefed by HP on radiological conditions in the CA and

RA. There was no clear understanding between the two groups that a HRA entry would

be required. The assigned RWP did not allow entry into HRAs without first obtaining a

briefing on the HRA conditions. Without knowledge of dose rates in the HRA, one

worker proceeded past the HRA boundary in room 2-FHB-A-01 to continue the

housekeeping activities and received an ED dose rate alarm.

Analysis The inspectors determined that the unauthorized entries into HRAs were

performance deficiencies. This finding is greater than minor because it is associated

with the Occupational Radiation Safety Cornerstone attribute of Human Performance

and adversely affects the cornerstone objective in that workers who enter HRAs without

prior knowledge of current radiological conditions could receive unintended occupational

exposures. The finding was evaluated using the Occupational Radiation Safety SDP

and determined to be of very low safety significance (Green). The finding was not

related to ALARA planning, nor did it involve an overexposure or substantial potential for

overexposure, and the ability to assess dose was not compromised. This finding

involved the cross-cutting aspect of Human Performance, Work Practices H.4.a]

Enclosure 2

18

because the HRA events were a direct result of poor communications during pre-job

briefings and a willingness on the part of licensee personnel to proceed in the face of

uncertainty.

Enforcement TS 5.7.1, High Radiation Area, requires individuals entering HRAs to meet

one or more of the following criteria: 1) carry a survey meter; 2) wear an ED and be

made aware of radiological conditions in the area; or 3) be escorted by a HP technician.

Contrary to the above, on May 9, 2007, and on August 16, 2007, plant personnel

entered HRAs without a survey meter, without being aware of radiological conditions in

the area, or without HP technician escort. Because the violation is of very low safety

significance and has been entered into the licensees CAP (CR 2007105476 and CR

2007108830), this violation is being treated as an NCV, consistent with Section VI.A of

the NRC Enforcement Policy: NCV 05000424/425, 2008005-01, Unauthorized Entries

Into High Radiation Areas.

2OS2 ALARA Planning and Controls

a. Inspection Scope

The inspectors reviewed ALARA program guidance and its implementation for ongoing

2R13 job tasks. The inspectors evaluated the accuracy of ALARA work planning and

dose budgeting, observed implementation of ALARA initiatives and radiation controls for

selected jobs in-progress, assessed the effectiveness of source-term reduction efforts,

and reviewed historical dose information.

ALARA planning documents and procedural guidance were reviewed and projected

dose estimates were compared to actual dose expenditures for the following high dose

jobs: scaffolding installation/removal, reactor vessel head work, steam generator

maintenance activities, motor operated valve (MOV) testing and maintenance, and

installation of the external neutron monitoring system inside containment. Differences

between budgeted dose and actual exposure received were discussed with cognizant

ALARA staff. Changes to dose budgets relative to changes in radiation source term

and/or job scope were also discussed. The inspectors attended pre-job briefings and

evaluated the communication of ALARA goals, RWP requirements, and industry

lessons-learned to job crew personnel.

The inspectors made direct field or closed-circuit-video observations of outage job tasks

involving work inside Unit 2 containment. For the selected tasks, the inspectors

evaluated radworker and HPT job performance, individual and collective dose

expenditure versus percentage of job completion, surveys of the work areas,

appropriateness of RWP requirements, and adequacy of implemented administrative

and physical controls.

Implementation and effectiveness of selected program initiatives with respect to source-

term reduction were evaluated. Chemistry program ALARA initiatives and their effect on

containment and auxiliary building dose rate trends were reviewed.

Plant exposure history for 2005 through 2008 year-too-date, and data reported to the

NRC pursuant to 10 CFR 20.2206 were reviewed, as were established goals for

reducing collective exposure during the current 2R13 outage. The inspectors reviewed

procedural guidance for dosimetry issuance and exposure tracking. The inspectors also

Enclosure 2

19

examined dose records of declared pregnant workers to evaluate assignment of

gestation dose.

ALARA program activities and their implementation were reviewed against 10 CFR Part

20, and approved licensee procedures. In addition, licensee performance was evaluated

against guidance contained in Regulatory Guide (RG) 8.8, Information Relevant to

Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As

Low As Reasonably Achievable, and RG 8.13, Instruction Concerning Prenatal

Radiation Exposure. Documents reviewed are listed in of the Attachment. The

inspectors completed 20 samples of specified line-items in IP 71121.02 to close the

procedure.

Problem Identification and Resolution. The inspectors reviewed selected CR and Action

Item (AI) data in the area of exposure control. The inspectors evaluated the licensees

ability to identify, characterize, prioritize, and resolve the identified issues in accordance

with NMP-GM-002. The inspectors also evaluated the scope of the licensees internal

audit program and reviewed recent assessment results. Documents reviewed are listed

in the Attachment.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

c. Inspection Scope