ML20244C235

Insp Rept 50-440/89-16 on 890502-0602.Violations Noted Re Inadequate Surveys & Failure to Use Dosimetry in High Radiation Area.Major Areas Inspected:Allegations of Possible Overexposure.Overexposure Probably Did Not Occur

ML20244C235
Person / Time
Site:	Perry
Issue date:	06/05/1989
From:	Greger L, Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20244C228	List: ML20244C225 ML20244C235
References
50-440-89-16, NUDOCS 8906140171
Download: ML20244C235 (11)

See also: IR 05000440/1989016

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION III

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l Report No. 50-440/89016(DRSS)

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Docket No. 50-440 License No. NPF-58

Licensee: Cleveland Electric Illuminating Company

Post Office Box 5000

l- Cleveland, OH 44101

l Facility Name: Perry Nuclear Power Plant, Unit 1

Inspection At: Perry Site, Perry, Ohio

Inspection Conducted: Hay 2 through June 2, 1989

Inspectors: M. A. Kunowski M . M. k 8~

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R. J. Caniano $pY b [//@

Reviewed By:

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M. Schumacher, Chief #***/h[. /

Radiological Controls Date

and Che stry Section

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Approved By: L. Ro/bertGreger,Chif

Reactor Programs 9 ranch Date

Inspection Summary

Inspection on May 2 through June 2, 1989 (Report No. 50-440/89016(DRSS))

Areas Inspected: Special, announced inspection to review allegations of

a possible overexposure.

Results: The inspectors' review of this event indicated that an overexposure

probably did not occur; however: a potential for one appears to have existed.

The radiation field intensity was not known at the time of entry. Also,

the worker exited the area without completing his work assignment because he

noted an unexpected SRD reading. The inspectors identified several radiological

control weaknesses attendant to the event, including inadequate surveys in

support of an RWP and a lack of aggressiveness and curiosity by the radiation

protection technicians covering the drywell during the incident. Four

allegations related to the incident were unsubstantiated; two allegations

were substantiated (Sections 2 and 3). Four apparent violations of regulatory

requirements were identified, including (1) inadequate surveys, (2) failure to

document a survey, (3) failure to follow radiological control procedures for

installation of shielding and for initiating a radiological occurrence report,

and (4) failure to use appropriate dosimetry in a high radiation area.

(Sections 2 and 3).

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DETAILS

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1. Persons Contacted 1

• R. R. Bowers, Corporate Health Physicist

• W. E. Coleman, Manager, Operations Quality Section

+G. R. Dunn, Lead Engineer, Licensing and Compliance Section, Perry

Plant Technical Department (PPTD) 1

• M. W. Gmyrek, Manager, Perry Plant Operations Department j

+*H. L. Hegrat, Operations Engineer, Licensing and Compliance Section

J. V. Ivery, Superintendent, R. J. Frazier

• S. F. Kensicki, Director, PPTD

• R. A. Newkirk, Manager, Licensing and Compliance Section i

R. W. Parsons, Superintendent, R. J. Frazier 1

C. Reiter, Health Physics Supervisor, PPTD {

T. E. Shega, System Engineer, PPTD

• L. L. VanDerHorst, Plant Health Physicist, PPTD

+*F. C. Whittaker, Lead Health Physics Supervisor, PPTD

• S. J. Wojton, Manager, Radiation Protection Section, PPTD

The inspectors also contacted other licensee employees, including

technicians, workmen, and supervisors.

• G. F. O'Dwyer, NRC Resident Inspector

• Denotes those present at the exit meeting on May 10, 1989.

+ Denotes those present at the exit telephone meeting on June 5, 1989.

2. Allegation Followup

(Closed) Allegation (AMS No. RIII-89-A-0054) l

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a. Allegation Concern No. 1: A worker may have been overexposed during

a job.

An allegation concerning a possible overexposure was received

in the Region III office on April 10, 1989; subsequent telephone

conversations with the alleger were held on April 27. May 11, and

May 31, 1989. The alleger stated that on March 24, 1989, a worker

may have been overexposed when he was allowed to work in an unexpectedly

high radiation field near a hotspot that was later determined to be

12 R/hr on contact. Several concerns were expressed by the alleger,

namely, that the worker was blamed for the exposure, that the RPM

may have been covering up the exposure, that the Radiation Work

Permit (RWP) for the job was not properly written, that the hotspot

in the pipe should have been shielded, and that the worker had not

been issued proper dosimetry for the job.

These allegations were reviewed by Region III inspectors during a

special onsite inspection on May 2-3, and May 8-10, 1989 and in

subsequent telephone discussions with licensee representatives 1

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through June 2, 1989. The inspection consisted of record and

procedure review, job site observations, and interviews of workers

.and licensee technical _and management personnel.

Discussion: On March 24,1989, at 6:45 p.m. , the worker, who is a

pipefitter, and his foreman entered the drywell on RWP 890335 to

provide support for inservice inspection (ISI) work. Attached

to the RWP.were several survey maps for various-locations in the

drywell, including the general areas in which the men had to go.

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The men stated they notified the radiation protection technicians

(RPTs) at-the drywell access control desk before entry, as required

by.the RWP, and were told of the radiological conditions in the

areas in which they had to work, as shown on the survey maps.

The individuals then entered the drywell and first went to the

reactor water cleanup (RWCU) system on the 583' elevation. After

approximately 30 minutes, the men left this area and went to the

630' elevation to scope another job, removal of pipe supports

(snubbers and pipe clamps) on the low pressure coolant injection

(LPCI) line. The supports are located about 2' upstream of a LPCI

line check valve in an approximately 3.5' x 5' x 6' pit, adjacent

to, but below, the 630' elevation walkway. This pit is normally

not accessible from the walkway, being enclosed by jet shielding;

however, some of the jet shielding had been removed on March 22,

1989, allowing access to it.

Within the pit, the foreman recorded some preliminary data and

explained to the worker what had to be done for the job. The men

left the area after approximately 15 minutes (at about 8:00 p.m.)

and returned to the drywell exit. As they left the drywell, they

told the RPTs that they had received approximately 30 mrem, an

unexpected amount, on their SRDs during their short time at the LPCI

job site. The RPTs attributed this exposure to the time the workers

spent at the RWCU job, where the general area dose rates ranged from

100-150 mrem / hour, and not the LPCI job,'where general area dose

rates supposedly ranged from 5-18 mrem / hour, according to the posted

survey, dated May 16, 1989, taken before the jet shielding was removed.

No records were found which showed that a survey of the pit area was

conducted after removal of the jet shielding on March 22 and the

initial pit entry by the workers on March 24.

The RPT who was named in the allegation stated that after the men

left he surveyed the pit and identified a 2.5 R/ hour (contact)

hotspot on the LPCI pipe about 3' downstream of the snubbers, and

also measured general area dose rates of 80-100 mR/ hour. These

general area levels were about a factor of ten higher than those

measured during the survey of March 16, 1989, which was being used

to allow entry under the RWP. However, the March 16, 1989, survey

was done with the jet shielding in place and, therefore, did not

properly characterize the radiological conditions in the pit. The

licensee's use of an inappropriate survey to govern RWP entry is an

apparent violation of 10 CFR 20.201(b), which requires the licensee

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.to make surveys that are necessary and reasonable to evaluate the

extent of radiation hazards that may be present

(No. 440/89016-01a).

In addition, the inspectors determined that the survey identifying

the 2.5 R/ hour hotspot was not documented, an apparent violation of

the 10 CFR 20.401(b), which requires the licensee to maintain records

of surveys required by 10 CFR 20.201(b) (No. 440/89016-02).

At 11:45 p.m., the foreman and the worker returned to the drywell,

with a second worker. The RPT stated he informed them of the survey

results including the hotspot. (However, the worker and the foreman

stated to the inspectors that they were not informed of any hotspot.

The foreman stated that he and the RPT went to the work area, where

the RPT explained that he had surveyed the area earlier in the day

and that dose rates along the bottom of the pipe were 80 mR/ hour

and indicated that general area dose rates were lower. The worker

stated that the survey results that were relayed to him were general

area dose rates were 30-40 mR/ hour.)

The worker stated he began the job, assisted by the second worker,

who did not enter the pit, but stayed on the 630' walkway to get

tools as needed. Meanwhile, the foreman, with the agreernent of

the RPT, obtained lead shielding and gave it to the workers, who

" hung" it on the pipe near the snubbers. However, it appears that

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the lead shielding was not placed around the pipe elbow, the spot

identified by the RPT as the hot spot,-but on a horizontal section

of the pipe near the snubbers.

They continued working until the first worker read his low-range

SRD, and observed what he thought was movement of the SR0 hairline.

(Both workers stated to the inspectors that the worker read the SRD

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because of.his apprehension about the radiation hazards in the area

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and not because of such instructions by the RPT.) The workers

immediately left the area and went to the drywell exit where they

informed the named RPT of the behavior of the SRD. The worker

estimated that he had been in the pit for 35 to 40 minutes before he

left.

The RWP record shows 210 mR total dose based on the worker's

low range SRD; the RPT stated that the worker's high-range SRD

read 50 mR. The RPT also stated that he told the worker that the

discrepancy may be due to a faulty low-range SRD. (It was later

ascribed by health physics management to differences in location ,'

of the two dosimeters with respect to the hotspot.)

The RPT stated that sometime later he resurveyed the pit with a

different meter and found that the intensity of the hotspot had

increased to 3.5 R/ hour and the general area dose rates had

increased to 300-400 mR/ hour. The technician then returned to the

drywell exit and informed the workers of the survey results. (The  !

workers claim that when the technician returned, he apologized to

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f them saying, in effect, that the meter he used for the previous

survey must have been defective, and that there was a hotspot in the

elbow of the pipe and general area dose rates were 300-400 mR/ hour.

The workers then left the drywell, at about 12:30 a.m. , on March 25,

1989.

Another foreman (the general foreman) stated to the inspectors

that after hearing of the hotspot, he borrowed a Bicron Model

Tech 50 G-M survey meter from the RPTs at the drywell control

desk and surveyed the elbow. He stated that he measured 5 R/ hour

on contact with the elbow (5 R/ hour is the highest value obtainable

-with this model survey meter.)

According to the technician, after he informed the workers of the

survey results he informed his supervisor of the apparent change

in the radiological conditions in the pit. Subsequently, no further

entries were allowed, pending an ALARA review. The RPT documented

his survey approximately 30 minutes later, at 1:00 a.m. There

is no record of the survey by the general foreman.

During his next shift (on Saturday night, March 25th), the RPT-

stated that he again surveyed the work area in the pit and determined

that the hotspot was now reading 12 R/ hour and the general area dose

rate was 1 R/ hour. For this survey, the RPT climbed down into the

pit, whereas, for the two previous surveys, he-did not enter the pit,

but just reached in with his meter from the walkway. An inspection

of the work area by an NRC inspector indicated that because of the

narrow, partially obstructed opening to the area, and the position

of the 12" LPCI pipe in the pit, an adequate survey of the work area

could not have been made from the walkway with the type of survey

meter uscd by the technician. Performing the two surveys of the

pit frow the walkway is another instance of an apparent violation

of 10 CFR 20.201(b), which requires the licensee to make surveys

that are reasonable to evaluate the extent of radiation hazards

that may be present (No. 440/89016-01b).

On his next shift, (Saturday-Sunday, March 25-26), the worker

discussed the incident with an HP supervisor who took the worker's

TLD for processing, and began an investigation to determine if an

overexposure had occurred. Later, the worker discussed the incident

with the HP supervisor responsible for external dosimetry on

nightshift. This supervisor apparently tried to allay some of the

worker's concerns, and provided, at the worker's request, a

preliminary dose estimate that ranged from 210 mrem to 7000 mrem.

The 210 mrem value was the worker's recorded dose for the job

according to the low-range SRD and the 7000 mrem value was a

worst-case estimate assuming the worker was in contact with a

3.5 R/ hour hotspot for the entire 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> he spent in the drywell.

The supervisor then refined the estimate by assuming 20% of the time

was spent in transit to and from the work area, and explained to

the worker that even this simple assumption would change the upper

estimate from 7 rem to 4.76 rem. (The supervisor stated in a memo

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dated March 26, 1989, that he later realized that he miscalculated

the value, noting that 80% of 7 rem is 5.6 rem, not 4.76 rem.) After

discussing this estimate and general information on the effects of

radiation, the supervisor and the worker then discussed other

details of the job.

During the remainder of the week, the plant HP staff.made a more

formal evaluation of the potential doses to the worker and the

foreman. The evaluation used personal dosimetry results, a detailed

. survey of the work area, and times and distances obtained from a

reenactment of the job in the dose reconstruction. The reenactment

was performed in the pit using an HP supervisor of similar height

as a surrogate for the worker. The reconstruction for the worker

assumed:

(1) The head 12 inches from the hotspot for 26.5 minutes in a field

of 500 mR/hr;

(2) The head 9 inches from the hotspot for 26.5 minutes in a field

of 1000 mR/hr; and

(3) The head 3 inches from the hotspot for two minutes in a field

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of 3500 mR/hr.

(According to licensee representatives, distances referenced for the

dose rates were measured from the pipe to the center of the detector

which is located approximately 1 1/2 inches from the base of the

survey meter.)

The resulting dose estimate to the head of the worker was 780 mrem

for his two entries into the pit. A similar but more detailed

scenario was used to estimate 346 millirems for the foreman's

entries (17 minutes) into the pit. The corporate health physicist

made. independent dose estimates based on the worker's dosimeter

readings and allowing for attenuation through the body but using the

same dose rate-time scenario. He obtained 750 and 860 mrem for the

worker's high and low range dosimeters, respectively, which are not

significantly different from the 780 mrem estimated by the station

staff.

The reconstruction was necessitated by the absence of dosimetry on

the portion of the total body (the head or top of the back) nearest

the hotspot. The reconstruction for the foreman appears better

because it was based on his detailed written description of his

actions and assumes a short period in contact with the pipe. The

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reconstruction for the worker assumed no contact time despite the

worker's assertion that he leaned against the pipe (although not

necessarily the hot spot). An NRC inspector who entered the pit

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noted that it was neither difficult nor awkward to place his head

l on the LPCI pipe. The worker told NRC representatives that he was

j not sure of time or positions with reference to the hotspot.

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While the licensee's dose estimate of 780 mrem for the worker may

be a reasonably good estimate of his actual dose, there is an

uncertainty associated with this estimate due to the worker's stated

lack of specific recollection of his body movements in the pit.

However, because the worker did not recall having his head in

contact with the pipe for a significant length of time, it does not

appear that even under conservatively assumed conditions, he could

have received a dose in excess of regulatory limits.

Finding: This allegation could not be substantiated. It appears,

based on the results of this inspection, that no overexposure

occurred although the worker's dose may have been underestimated

by assuming that no time was spent in direct contact with the

hotspot. However, a potential for an overexposure did exist and

an overexposure may have occurred if the worker had not left the

work area when he did and/or if the hotspot radiation levels had

been higher. Two apparent violations of NRC requirements were

identified.

b. Allegation Concern No. 2: The RPM told the worker that the exposure

was the worker's fault.

Discussion: The RPM denied making a statement of this nature to the

worker. The RPM stated to the inspectors that while discussing the

incident with the worker and hearing comments from the worker

concerning how many times he questioned the RPTs about the dose

rates in the area that he (the RPM) did tell the worker that if he

was not satisfied with the answers he was getting from the techs

that he should have pursued the matter at a higher level, as allowed

and encouraged by station policy.

Findings: The RPM made a statement that could be interpreted as

ascribing fault to the worker; however, the RPM denied that was the

intention. The allegation was not substantiated. No violations of

NRC requirements were identified.

c. Allegation Concern No. 3: The alleger stated that he was concerned

that the RPM may be covering up the alleged overexposure because the

RPM would not allow the worker to see or copy any of the records

pertaining to the incident, and because of the RPM's statement that

he (the RPM) "never had anyone burned out at Perry" and that he

would evaluate the dose and "it will probably be under 1000 mR."

This concern was reinforced by the fact that another HP supervisor

had earlier given him an exposure estimate of 4.78 rem (The

licensee's memo of March 26, 1989 refers to this estimate as

4.76 rem. See Allegation Ccncern No. 1.)

Discussion: The RPM stated to the inspectors that the worker

requested to review or receive copies of some records but that

he declined because the evaluation was not yet complete. The RPM

stated that the worker was told that copies could be requested after

completion of the evaluation. On May 2, 1989, the RPM told the

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inspectors that the evaluation had been completed but no request

from the worker had been received. He further stated that he had

no reason:to deny the worker's request and, in fact, had responded

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to a similar request from the foreman for his records. He added

l that such detailed records are not normally given to workers.

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The RPM told the inspectors that he did not remember making the

' statement that he "never had anyone burned out at Perry," but stated

-that he did tell the worker that it was not Perry's policy to " burn

out" workers; but rather it was Perry's policy to minimize dose to

the individual and to groups of workers, and to equally distribute

dose as much as possible. He also stated that his forecast of under

1000 mR was based on his knowledge of the tentative results of the

evaluation then in progress, which was much more plausible than the

crude.4.76 rem estimate made before detailed measurements were taken

in the pit.

Findings: The inspectors could not substantiate the allegation

that the RPM was concealing information from the worker regarding

the worker's exposure. The RPM acknowledged that records of the

incomplete evaluation were not given to the worker but stated that

the worker was told he could request a copy of the evaluation when

completed. No violations of NRC requirements were identified.

d. Allegation Concern No. 4: The Radiation Work Permit (RWP) for the

job on which the alleged overexposure occurred was not properly

written.

Discussion: TheallegerstatedthathewastoldbytheALARA

Coordinator (name unknown) that the HP department ' screwed up the

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RWP." The inspectors interviewed the members of the ALARA staff,

including the dayshift and nightshift ALARA Coordinators, and

several ALARA Specialists. The nightshift ALARA Coordinator

remembered being questioned by an individual unknown to him about

the incident but stated that he did not remember making such a

statement about the RWP to the individual, and probably would not

have made such a statement. RWP No. 890335, written March 1, 1989,

covered in-service inspection and support work which included snubber

removal in the pit. The RWP covered such work, throughout the

drywell. It specified that HP be notified before the start of work

so that area conditions may be established and also required either

HP coverage or a dose rate meter to enter a high radiation area

(HRA). The entire drywell was posted as an HRA with control over

entry exercised at the HP desk at its entrance where the RWP sign-in

sheets are kept. In this case, area conditions were established not

from a survey at the time of entry on March 24, but from the record

of.a survey made on March 16, as noted in the discussion under

Allegation Concern No. 1, this survey was inadequate because it did

not accurately depict conditions in the pit at the time of entry.

Finding: The RWP, although very generally written, was adequate to

prevent this occurrence had it been followed; therefore the

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allegation was unsubstantiated. However, overall radiological

control was vitiated due to inadequate surveys to establish

radiological conditions, as described under Allegation Concern

No. 1.

e. Allegation Concern No. 5: A pipe with a hotspot should have been

shielded during the work in the area.

Discuss.ig : _ Station practice is to shield or flush hotspots before

allowing work to proceed and if not practical, then to use other

means to limit worker exposure such as restricting staytime or using

alarming dosimeters. The opportunity to use such controls before

work in the pit began on March 24 was missed due to the inadequate

survey previously discussed. Also, the controls were not imposed

before worker reentry following discovery of the 2.5 R/hr hotspot.

Shielding was hung by the workers after reentry, at about 11:45 p.m.

i However, it was not hung in accordance with Perry Administrative

Procedure PAP-0122, " Selection and Use of Temporary Shielding,"

which requires completion of a request form PPNP No. 6623 and

an estimate by the ALARA Coordinator of the person-rem that would

be incurred if the shielding were not installed. Failure to

follow this procedure is an apparent violction of Technical

Specification 6.11.1 which requires adherence to procedures for

personnel radiation protection (Violation 440/89016-3a).

Finding: This allegation is substantiated. Although licensee

procedures were vague on this point, good ALARA practice would have

dictated shielding the hotspot before work began in the pit; that

it was not hung then is an apparent result of the inadequate survey.

When it was hung, it was done so improperly. _0ne apparent violation

was identified.

f. Allegation Concern No. 6: Dosimetry should have been placed on the

worker's head while working near the hotspot.

Discussion: Based on discussions with the worker and the foreman, a

reenactment of the job, and survey information, it is apparent that

a steep dose gradient existed in the work area, and that the highest

dose during the job would have been to the head and upper back,

not the chest where the dosimetry was placed. The dosimeters

near the chest would have been subject to shielding from the worker's

body, whereas a dosimeter on the head or upper back would not.

Therefore, the dose recorded by the dosimeter near or on the chest

would be inaccurate. So too would the dose determined by

back-calculation from the dosimeter because of uncertainties in

position of the chest with respect to the source and because of

the varying shielding effect as the worker moved around in the

work area. 10 CFR 20.202(a)(3) requires each licensee to supply

appropriate personnel monitoring equipment to each individual

who enters a high radiation area. In apparent violation of this

requirement, the licensee did not supply appropriate personnel

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l monitoring equipment to the two workers who entered the pit, a high

radiation area, in that dosimetry was not placed on the part of

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the whole body subject to the highest dose (No. 440/89016-04).

Findings: The allegation was substantiated. One apparent violation

of NRC requirements was identified.

3. Licensee Performance

This event revealed weaknesses in the licensee's radiological controls;

most notable was the failure to adequately survey to determine

radiological conditions attendant upon entry to the work area. This was

significant because the controlling RWP was generally written, leaving

radiological details to be determined by site-specific surveys. An

adequate survey taken at entry should have resulted in identification of

elevated radiation levels, an ALARA review, better worker instructions,

and issuance of proper dosimetry such that the incident would have been

avoided. An inadequate survey tends to undermine the RWP system of

controls.

A related and perhaps more fundamental weakness was the apparent lack of

curiosity by the radiation protection group covering the drywell work on

March 24-25, 1989, when the exiting workers first expressed concern about

their SRD readings and again after the 2.5 R/ hour hotspot was identified.

Opportunities to avoid an incident were again lost due to lack of

aggressive response by the radiation protection group.

Lack of aggressiveness also appeared to be a weakness in the licensee's

followup investigation of the event. Problems identified by the

inspectors included the following.

• The licensee did not begin an investigation of this event until

the worker sought out an HP supervisor on the worker's next shift

(Saturday-Sunday, March 25-26) with complaints concerning the

event. The foreman was not interviewed until two days after the

incident (on Monday, March 27,1989), when he alto sought out an

HP supervisor.

• The licensee's investigation was too narrowly focused and did not

include other relevant documents such as the work order covering

the worker and his foreman and the HP drywell logbook until their

relevance was pointed out by the inspectors. Both of these records

indicated that other workers involved in snubber related work had

entered the same general area; however, subsequent licensee review

of these entries indicated they were not in close proximity to the

hotspot.

• The licensee had in place two procedures for conducting and

documenting a thorough review which had not been invoked at the

time of the inspection. Perry Administrative Procedure, PAP-0124,

" Radiological Occurrence Reporting," should have been implemented

by initiation of a Radiological Occurrence Report (ROR) shortly

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after the event. This procedure (Section 5.1) defines a

radiological occurrence as "an event which results in or could

result in a violation of the intent of Perry radiological

procedures, practices, or policies; or personnel radiation exposures i

in excess of administrative guides and 10 CFR 20 limits," The I

procedure also states (Section 3.4) " Individuals are responsible

for reporting radiological occurrences in a timely manner." Contrary

to this requirement, and thus in apparent violation of Technical

Specification 6.11.1, no ROR was initiated for this incident

although it violated the intent of Perry radiological procedures,

practices, and policies on ALARA and external exposure control

(No.440/89016-03b).

An example of an apparent violation of NRC requirements was identified.

4. Exit Interview

An exit interview was conducted with licensee representatives (Section 1)

on May 10, 1989, to discuss the tentative findings and possible

enforcement options. The inspector stated that although the event may

not have resulted in an overexposure, a significant potential did exist

for one. The inspector also identified several apparent violations

including inadequate evaluation, failure to document a survey,

unauthorized shielding placement, and failure to initiate an ROR. The

licensee stated that a condition report (which has a higher threshold than

an ROR) was being initiated. The licensee did not identify any material

reviewed by the inspectors as proprietary.

A telephone conversation was held with the licensee representatives

(denoted in Section 1) on June 5. 1989, to discuss the inspection

findings including apparent violations. The following matters were

specifically addressed:

a. NRC determination that an overexposure apparently did not occur,

but that there may have been a substantial potential for one,

b. Other specific allegation findings.

c. Apparent violations for inadequate surveys (Section 2.a), for failure

to document a survey (Section 2.a), for installation of temporary

shielding and for failure to initiate a radiological occurrence

.

report both contrary

to use appropriate to procedure

dosimetry (Sections

in a high 2.e

radiation and 3)(, and failureSection 2

area

d. Weaknesses in radiological controls related to the incident and in

the licensee's followup.

e. Confirmed the receipt of the list of topics to be specifically

addressed at the Enforcement Conference, and the time, dtte, and

location of the Enforcement Conference.

11

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