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{{Adams | |||
| number = ML20148D842 | |||
| issue date = 03/10/1988 | |||
| title = Insp Repts 50-324/88-09 & 50-325/88-09 on 880208-12. Violations Noted.Major Areas Inspected:Audits & Appraisals, Outage Planning & Preparation,Training & Qualification of New Personnel & Internal & External Exposure Programs | |||
| author name = Bassett C, Hosey C | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000324, 05000325 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-324-88-09, 50-324-88-9, 50-325-88-09, 50-325-88-9, NUDOCS 8803240349 | |||
| package number = ML20148D819 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 11 | |||
}} | |||
See also: [[see also::IR 05000324/1988009]] | |||
=Text= | |||
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UNITED STATES | |||
NUCLEAR REGULATORY COMMISSION | |||
o * REGION il | |||
i< [ 101 MARIETTA ST., N.W. | |||
,,,,, ATLANTA, GEORGIA 30323 | |||
MAR 161988 | |||
Report Nos.: 50-325/88-09,50-324/88-09 | |||
Licensee: Carolina Power and Light Company | |||
P. O. Box 1551 | |||
Raleigh, NC 27602 | |||
Docket Nos.: 50-325, 50-324 License Nos.: OPR-71, OPR-62 | |||
Facility Name: Brunswick | |||
Inspection Conducted: February 8-12, 1988 | |||
Inspector: la | |||
. H. Bbssett v Date Signed | |||
Accompanying Personnel: C. M. Hosey | |||
R. B. Shortridge | |||
Approvedby:.L bdw | |||
p.M.iHosey,SectionChief | |||
(ok | |||
Date' Signed | |||
, | |||
Division of Radiation Safety and Safeguards | |||
SUMMARY | |||
Scope: This routine, unannounced inspection was conducted in the areas of | |||
audits and appraisals, outage planning and preparation; training and | |||
qualification of new personnel; external exposure control; internal e'posure | |||
control; control of radioactive material, contamination, surveys and | |||
monitoring; maintaining exposures as low as reasonably achievabir.: (ALARA);and | |||
information notices followup. | |||
Results: Two violations were identified - (1) failure to maintain access to a | |||
high radiation area locked (see Paragraph 4.d.(2)); and (2) failure to fcilow | |||
procedures or to have adequate procedures (see Paragraphs 4.d.(3), 4.h.(1), | |||
4.h.(2)). | |||
8803240349 880316 4 | |||
DR ADOCK 0000 | |||
_- . . _ - .- - _ ._ . - _. . .. . . - . . . .. __ -_ | |||
_ .. . _ . . . . . .- . _ _ . . | |||
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REPORT DETAILS | |||
1. ~ Persons Contacted | |||
Licensee Employees | |||
C. Barnhill, Dosimetry Foreman, Environmental and Radiological Control | |||
*E. Bishop, Manager, Operations | |||
*C. Blackman, Superintendent, Operations | |||
*S. Callis, Onsite Licensing Engineer | |||
*A. Cheatham, Manager, Environmental and Radiological Control | |||
*E. Eckstein, Manager, Technical Support | |||
*K. Enzor, Director, Regulatory Compliance | |||
*R. Helme, Director, Onsite Nuclear Safety | |||
*J. Henderson, Supervisor, Environmental and Radiclogical Control | |||
*P. Howe, Vice President, Brunswick Nuclear Project | |||
*L. Jones, Director, Quality Assurance / Quality Control | |||
*J. O'Sullivan, Manager, Maintenance | |||
*R. Queener, Physical Engineer, Environmental and Radiological Control | |||
*J. Smith, Director, Administrative Support | |||
J. Terry, ALARA Coordinator, Environmental and Radiological Control | |||
*L. Tripp, Supervisor, Environmental and Radiological Control | |||
Other licensee employees contacted included construction craftsmen, | |||
, engineers, technicians, operators, mechanics, security office members, and | |||
i office personnel. ; | |||
NRC Resident inspector | |||
*W. Ruland | |||
* Attended exit interview | |||
2. Exit Interview | |||
The inspection scope and findings were summarized on February 12, 1988, | |||
with those persons indicated in Paragraph 1 above. The inspector | |||
described the areas inspected and discussed in detail the inspection | |||
findings listed below. The licensee acknowledged the inspection findings. | |||
However, licensee management stated that they might deny the violation for | |||
an inadequate procedure regarding reading of relf reading pocket | |||
dosimeters since the event was still under investigation. The licensee | |||
also stated that they considered that appropriate corrective actions had | |||
' | |||
been taken regarding the auxiliary operator displaying poor radiological | |||
work practices. The licensee did not identify as proprietary any of the | |||
material provided to or reviewed by the inspector during this inspection. 1 | |||
e | |||
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2 | |||
3. Licensee Action on Previous Enforcement Matters | |||
(Closed) Unresolved Item (325/87-39-03, 324/87-40-03), Poor radiological | |||
work practices exhibited by an auxiliary operator. See Paragraphs 4.d.2 | |||
and 3 of report details. | |||
4. Occupational Exposure During Extended Outages (83728) | |||
a. Audits and Appraisals (83722, 83724, 83725, 83726, 83728) | |||
The inspector reviewed audits of the radiation protection program | |||
performed in 1986 and 1987. The extent of audits, qualifications of | |||
auditors, and adequacy of the audits were assessed. During the | |||
review the inspector noted that of the ten monthly assessments | |||
performed by the corporate radiological protection group and reviewed | |||
by the inspector, none identified any radiological deficiencies or | |||
necessary corrective actions designed to improve the stations' | |||
radiation protection program. In late 1987 the corporate group | |||
, performing the audits / assessments function was disbanded and the | |||
auditors reassigned to other departments as a result of a corporate | |||
reorganization. The licensee stated that a new audit program was | |||
being developed and would be implemented as soon as possible. Audits | |||
or assessments performed by the new audit program will be reviewed | |||
during the next inspection. | |||
No violations or deviations were identified, | |||
b. Planning and Preparation (83724, 83725) | |||
Tne trasent health physics organization, staffing levels, and lines | |||
of authority as related to outage radiation protection activities | |||
were discussed with licensee representatives. The organizational | |||
responsibility and control of the contractor HP technicians used | |||
during the outage was also discussed. The licensee's HP organization | |||
consisted of a radiation protection manager, two supervisors, eight | |||
foremen, nine technical support personnel and sixty technicians. To | |||
provide additional job coverage required by the Unit 2 outage, the | |||
licensee increased the staff with eighty-three contract HP | |||
technicians. After training had been completed and verified, | |||
contractor HP technicians were integrated into the non-supervisory | |||
! positions, commensurate with the experience and qualifications. | |||
Licensee personnel maintained supervision over the HP contract | |||
technicians to assure compliance with established procedures and an | |||
acceptable quality of work was attained. Staffing levels for the | |||
outage appeared to be adequate. | |||
, | |||
No violations or deviations were identified. | |||
! | |||
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_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ______ _____ ___ _ _ _ _ _ _ _ _ _ | |||
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c. Training and Qualificahon (83723) | |||
(1) Technical Specification 6.3 required that each member of the HP | |||
staff meet or exceed the minimum qualifications of ANSI | |||
N18.1-1971. Paragraph 4.5.2 of ANSI N18.1 stated that | |||
technicians in responsible positions were to have a minimum of | |||
two years of working experience in their speciality. The | |||
licensee in practice requires that an individual have three | |||
years experie0ce to perfor.n the tasks assigned to junior | |||
technicians, teree to five years experience to perform as a | |||
technician and five or more years to be a senior technician. | |||
The inspector reviewed records of selected health physics | |||
technicians and noted that their qualifications and experience | |||
level appeared to be commensurate with their job assignments and | |||
responsibilities. | |||
< | |||
(2) Contractor Health Physics Technician Training and Qualification | |||
The 83 HP technicians contracted to augment the licensee's HP | |||
staff received 20 hours of classroom training in site | |||
radiological plant specifics in the areas of proceduras, | |||
instruments, basic health physics, problem solving and safety. | |||
To successfully complete the HP orientation, a contract | |||
individual must score 80 percent on an exanination to be | |||
classified a junior technician and eight-five percent to be | |||
classified as a senior technician. Prior to assignments of job | |||
coverage, the contractor technicians must satisfactorily | |||
demonstrate their knowledge and skills by performing the same | |||
tasks required of licensee technicians. The checkout of a | |||
contractor technician, in selected tasks, is monitored by a | |||
licensee-qualified instructor. Upon successful completion of | |||
the task, the instructor signs off the contractor technician's | |||
job perfornance on the same qualification-card required of | |||
licensee HP technicians. After completion of on the job | |||
iraining and qualification, the contractor technician is | |||
, | |||
assigned radiological job coverage responsibilities. | |||
No violations or deviations were identified, | |||
d. External Exposure Control and Dosimetry (83724) | |||
(1) Use of Dosimeters | |||
, | |||
10 CFR 20.202 requires eaC1 licensee to supply appropriate | |||
personnel monitoring devices to specific individuals and require | |||
the use of such equipment. During tours of Units 1 and 2 | |||
reactor building, the inspector observed the use of | |||
thennoluninescent dosimeters (TLDs) and self-reading pocket | |||
dosimeters (SRPDs). It was noted that workers typically placed | |||
, | |||
' | |||
their SRPDs inside their protective clothing. The inspector | |||
discussed with the licensee the potential for workers to | |||
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _______ _ _ _ | |||
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4 | |||
contaminate themselves if they reach inside their protective | |||
clothing to read their SRPD to monitor their exposure. The | |||
licensee stated they would review this matter and that' | |||
appropriate corrective actions would be taken. | |||
(2) Radiologically Controlled Areas | |||
Technical Specification 6.12.2 requires that each high radiation | |||
area, in which the intensity is greater than 1,000 mrem /hr, have | |||
locked doors to prevent unauthorized entry. | |||
The inspector- reviewed an unresolved item as reported in | |||
Inspection Report 87-39 and 87-40 dated December 29, 1987. The | |||
unresolved item concerned an event which occurred on November | |||
12, 1987, during which a NRC resident inspector accompanied an | |||
Auxiliary Operator (A0) making daily rounds of Unit 2 Reactor - | |||
- | |||
Building. The A0 was observed to unlock a chainlink door to | |||
access the Unit 2, 80 foot east fuel pool heat exchanger room, a | |||
high radiation area. The A0 left the area for a period of about | |||
5 minutes to dress out in protective clothing. During this | |||
period the high radiation area was unlocked and unattended, | |||
however, the inspector stood by the door and stated that no | |||
unauthorized entry was made by anyone into the area. A review | |||
of radiation surveys of the area taken on November 14, 1987, | |||
showed maximum general area radiation levels of 60-700 mrem /hr | |||
' | |||
with a.5,000 mrem /hr hot spot. No radiation readings were taken | |||
to determine the radiation levels in the accessible areas | |||
immediate adjacent to the hot spot. The inspector and licensee | |||
toured the area on February 11, 1988, and noted that the area | |||
adjacent to the hot spot could be accessed by an individual. | |||
The licensee controlled access to the fuel pool heat exchanger | |||
room as a high radiation area and required the door to the area | |||
to be locked. Failure to maintain access to a high radiation | |||
area locked was identified as an apparent violation of 1 | |||
10CFR20.203(c)(iii)(50-325,324/88-09-01). | |||
(3) Radiation Work Permits (RWPs) | |||
i Technical Specification 6.8.1 requires that written procedures | |||
I be established, implemented, and maintained covering the | |||
activities recomended in Appendix A, of Regulatory Guide 1.33 | |||
of November 1972. | |||
, | |||
Regulatory Guide 1.3?. Quality Assurance Program Requirements, | |||
I Appendix A. Section . A recomends that the licensee have | |||
l procedures for perfonw.,9 maintenance and Section G.5 recomends . | |||
procedures for personnel radiation monitoring and special work | |||
l | |||
permits. Section I.S.b recomends that factors be taken into | |||
l | |||
account in preparing detailed work procedures, including the | |||
. | |||
necessity for minimizing radiation exposure to workmen. | |||
l | |||
l | |||
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_ _ _ _ _ _ _ _ _ _ _ _ . _ _ | |||
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5 | |||
Technical Specification 6.11.1 requires that procedures for | |||
personnel radiation protection shall be prepared consistent with | |||
the requirements of 10 CFR Part 20 and shall be approved, | |||
maintained, and adhered to for all operations. | |||
Radiation Control and Protection Procedure, Volume Vill, | |||
Section 6.6.3 states that required items of protective clothing | |||
shall be worn by all personnel while in radiation controlled | |||
areas. | |||
On November 12, 1987, while the NPC resident inspector | |||
accompanied the A0 making daily rounds of the plant, the | |||
inspector observed the A0 violate protective clothing | |||
requirements on two occasions. The A0 entered the 80 foot Fuel | |||
Pool Heat Exchanger area and the mini-steam tunnel with a hard | |||
hat instead of a hood as required by RWP-1002, Revision 0, | |||
locally posted dress out requirements, and prior instructions | |||
from the duty health physics technician. | |||
Failure of the A0 to comply with RWP requirements in that he | |||
failed to wear the correct protective clcthing was identified as | |||
an apparent violation of Technical Specification 6.8.1 (325, | |||
324/88-09-02). | |||
The inspector reviewed general and special RWPs posted at the | |||
entrance to the radiologically controlled area to verify they | |||
complied with regulatory requirements and contained sufficient | |||
guidance, | |||
e. Internal Exposure Control (83725) | |||
(1) Intake Assessment | |||
10 CFR 20.103(a) establishes the limits for exposure of | |||
individuals to concentrations of radioactive materials in air in | |||
restricted areas. This section also requires that suitable | |||
measurements of concentrations of radioactive materials in air | |||
be performed to detect and evaluate the airborne radioactivity | |||
in restricted areas and that appropriate bioassays be performed | |||
to detect and assess intakes of radioactivity. | |||
The inspector reviewed selected results of general inplant air | |||
samples taken during the refueling outage and results of air | |||
samples taken to support work authorized by special radiation | |||
work permits. The inspector also reviewed the selected results | |||
of whole body counts. | |||
(2) Engineeririg Controls and Respirctory Protection | |||
10 CFR 20.103(b)(1) requires that the licensee use process or | |||
other engineering controls to the extent practicable to limit | |||
.. | |||
* | |||
.' | |||
" | |||
. | |||
~6 | |||
concentrations of radioactive materials in the air to levels | |||
below those which delineate an airborne radioactivity area as | |||
defined in 20.203(d)(1)(ii). | |||
During plant tours, the inspector'cbserved various engineering | |||
controls to limit the concentrations of airborne radioactive | |||
material. These included the use of temporary ventilation | |||
systems, containment enclosures, and air supplied respirators. | |||
The inspector discussed the use of respiratory equipment with | |||
the licensee to ensure that medical evaluations and fit testing | |||
were performed prior to respirator use. Selected records were | |||
reviewed to ensure that the required training and medical | |||
evaluations were documented. | |||
No violations or deviations were identified, | |||
f. Control of Radioactive Materials and Contamination, Surveys and | |||
Monitoring (83726) | |||
(1) Surveys | |||
The licensee was required by 10 CFR 20.201(b) and 20.401 to | |||
perform surveys and to maintain records of such surveys | |||
necessary to show compliance with regulatory limits. | |||
During plant tours, the inspector examined radiation levels and | |||
contamination survey results posted outside various areas | |||
including Units 1 and 2 drywells. The inspector performed | |||
independent surveys of selected areas using NRC equipment and | |||
compared them with licensee survey results. The inspector also | |||
examined licensee radiation protection instrumentation and | |||
verified that the calibration stickers were current. . | |||
(2) Caution Signs, Labels and Controls | |||
10 CFR 20,203(f) requires that each container of licensed | |||
radioactive material bear a durable, clearly visible label | |||
identifying the contents when quantities of radioactive material | |||
exceeded those specified in Appendix C. | |||
During plant tours the inspector verified that containers of | |||
radioactive material were properly labeled when required. | |||
(3) Area and Personnel Contamination | |||
The inspector reviewed records of skin contamination occurrence | |||
for 1987 and the current outage. The licensee had 420 skin | |||
and/or clothing contaminations in 1987 and 77 through the first | |||
5 weeks in 1988. | |||
_ _ _ . _ ._ _ _ _ _ _ _ _ - .. __ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ | |||
A d_ | |||
b | |||
. | |||
, | |||
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7 | |||
The licensee maintains approximately 625,000 square feet of the | |||
Unit 1 and Unit 2 reactor buildings and turbine building as a | |||
radiologically controlled area. Approximately 66,373 square | |||
feet or 9.4 percent is controlled as contaminated areas. | |||
No violations or deviations were identified. | |||
9 Program for Maintaining Exposures As Low As Reasonably Achievable | |||
(ALARA) (83728) | |||
10 CFR 20.1(c) states that persons engaged in activities under | |||
licenses issued by the NRC should make every reasonable effort to | |||
maintain radiation exposure ALARA. The recommended elements of an | |||
ALARA procram were contained in Regulatory Guides 8.8, Information | |||
Relevant to Ensuring that Occupational Radiation Exposure at Nuclear | |||
Power Stations will be ALARA, and 8.10, Operating Philosophy for | |||
Maintaining Occupational Radiation Exposures ALARA. | |||
ALARA Program | |||
The inspector discussed the ALARA Program with licensee | |||
representatives. During calendar year 1987 the collective exposure | |||
man-rem goal with 1 refueling outage was 1,209 man-rem and | |||
1,419 man-rem was expended. The 1988 man-rem goal is 1,530 with two | |||
scheduled outages. The first refueling outage goal is 852 man-rem. | |||
On February 12, 1988, the licensee had expended 476 of 479 projected | |||
man-rem for the first outage. The annual collective exposure goal | |||
was established at the station and was based on specific jobs and | |||
outage workscope. The inspector reviewed the planning for the | |||
refueling outage in progress and the outage report for the previous | |||
refueling outage in 1987. The job history / lessons learned section of | |||
the report contained substantive ALARA considerations to be used in | |||
minimizing radiation exposure for subsequent, similar or repeat | |||
operations. The planning document for the current outage did not ' | |||
appear to address, in the same level of detail, the ALARA | |||
considerations from the previous outage report. Consideration of | |||
lessons learned in outage planning will be reviewed during subsequent | |||
inspection. | |||
No violations or deviations were identified. | |||
h. Radiological Events Review | |||
(1) On January 3,1988, the licensee was transferring a startup | |||
range monitor dry tube via over head crane to a storage location | |||
in the spent fuel pool (SFP). Due to the length of the dry | |||
tubes and configuration of the path from the reactor vessel | |||
cavity to the spent fuel pool, the crane is required to be | |||
positioned at the far section of the SFP away from the reactor | |||
cavii.y(to | |||
canal cattleallow movement | |||
chute). Theofgripper | |||
the dryend | |||
tubeofthrough | |||
the drythe transfer | |||
tube is | |||
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8 | |||
normally lowered as far into the SFP as possible. The lower end | |||
of the dry tube is then raised, a bow in the tube rotating | |||
downward occurs, and the lower end of the dry tube is moved out | |||
of the cattle chute area and lowered to the SFP for storage. | |||
Normally the dry tube is maintained underwater to provide | |||
shielding during the operation for_ these highly irradiated | |||
components. During this event the crane hoist was correctly | |||
located.but a problem with the hydraulic cables on the gripper | |||
tool prevented lowering the dry tube to the correct location | |||
necessary to raise and rotate the other. end of the dry tube. | |||
With the upper end of the dry tube at a higher position than | |||
normal, the bottom of the dry tube was raised using a "J" hook | |||
tool. The dry tube bowed in an upward direction causing a | |||
highly irradiated section of the tube to break the water. When | |||
this occurred the area radiation monitor alarmed and the | |||
technician handling the J hook was instructed to drop the tube | |||
back into the water. The dry tube was out of the water for a | |||
maximum of 2 to 3 seconds. Radiation surveys on a similar dry | |||
tube read approximately 4,000 rem /hr on contact. The highest | |||
exposure to an individual involved in the event was 30 mrem. | |||
The inspector discussed the operation with the cognizant | |||
engineer and reviewed the SRM Dry Tube Removal Procedure, | |||
ENP-46. The procedure did not contain the necessary information | |||
and precautionary steps to prevent the dry tube removal from | |||
exposing personnel to high levels of radiation. The upper end | |||
of the dry. tube was in too high a position to ensure a downward | |||
rotation when the lower end was raised. The procedure step used | |||
to rotate the dry tube was broad in nature and allowed several | |||
actions to be performed simultaneously instead of several steps | |||
that are used in sequence. Failure of the procedure to include | |||
the necessary factors for minimizing radiation exposure to | |||
workmen was identified as an additional example of an apparent | |||
, | |||
' | |||
violation of Technical Specification 6.8.1 (50-325, | |||
324/88-09-02). | |||
(2) On January 23, 1988, a licensee individual entered the Unit 2 | |||
l | |||
drywell to prepare a weld on the feedwater nozzle for inservice | |||
l inspection. General arer, dose rates in the work area ranged | |||
' | |||
from 30 to 150 mrem /hr with contact readings on a shielded valve | |||
i | |||
penetration located in the work area from 300 to 1,200 mrem /hr. | |||
! | |||
Radiation Work Permit 88-1053 Attachment A, in part, required | |||
l that continuous coverage be provided by health physics during | |||
I the operation, that work should be planned to reduce stay-time | |||
l and generation of radwaste, and that work area dose rates be | |||
monitored often. After approximately 15 minutes in the drywell, | |||
the worker read his SRPD as suggested by Radiation Control and | |||
Protection Procedure, Volume VIII and noted 40 mrem. He began | |||
to prepare the weld surface by flapping with a grinder. After | |||
completing the weld prep which took approximately 1 hour the | |||
worker read his SRPD for a second time and noted that it was | |||
i | |||
! | |||
' | |||
- | |||
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9 | |||
offscale. The worker exited the drywell and reported to health | |||
physics. Processing of the workers TLD revealed that he | |||
received an exposure of 1,120 mrem for the quarter and 800 mrem | |||
during the entry on January 23. This exceeded the licensee's | |||
administrative limit of 1,000 mrem per quarter. An | |||
investigation by health physics of the event revealed that the | |||
same operation had previously been performed several times in | |||
the area resulting consistently in exposures of 20 to 50 mrems. | |||
Health physics personnel responsible for drywell coverage did | |||
not observe the worker during the weld prep operation as | |||
required by the RWP. Although the worker was aware of | |||
1,000 mrem /hr dose rates, he failed to read his SRPD. | |||
The inspector asked HP supervision and technicians what their | |||
understanding of continuous coverage meant. There were several | |||
interpretations that ranged from control point entry at the | |||
drywell constituted continuous coverage, to intermittent | |||
coverage (10 to 15 minute checks), to constant coverage during | |||
the entire job. In March 1986 HP management issued a memorandum | |||
to define continuous coverage but this allowed a HP technician | |||
the option of uninterrupted positive control (constant) or | |||
periodic surveillance intermittent consistent with the | |||
radiological hazard. The licensee stated that corrective action | |||
of strictly defining continuous HP technician coverage would be | |||
taken. | |||
Based on a review of radiological procedures and the radiation | |||
work permit requirements the inspector determined that the | |||
werker was not required by procedures or RWP to frequently read | |||
his SRPD while in radiation or high radiation areas. Radiation | |||
Control and Protection Procedure, Volume VIII, Section 6.6.2 is | |||
considered inadequate in that it failed to require that SRPD be | |||
read frequently when an individual is in a high radiation area | |||
to minimize exposure. Failure to have an adequate procedure was | |||
identified as an additional example of an apparent violation of | |||
, | |||
Technical Specification 6.8.1(50-325,324/88-09-02). | |||
l i . Radiological Controls for Drywell During Spent Fuel Movement | |||
l (Tl 2500/23) | |||
! | |||
l During a previous inspection, controls used during spent fuel | |||
movement were reviewed and appeared to be adequate. At that time the | |||
' | |||
licensee indicated that a new portable fuel-chute shield or "cattle | |||
l chute" was being fabricated and the various dimensions and amounts of | |||
I shielding were discussed. The inspector questioned the adequacy of | |||
! the shielding and the licensee indicated that further consideration | |||
would be given to the design and fabrication of the new chute. | |||
During this inspection, the inspector reviewed the specifications of | |||
l the new cattle chute and the radiological analyses of several | |||
! postulated fuel drop accidents performed after some design changes | |||
! | |||
l | |||
t | |||
' | |||
' | |||
. | |||
. | |||
4 | |||
10 | |||
and shielding modifications were made. The newly fabricated cattle | |||
chute now appears to be adequate, with six inches of lead shielding | |||
in the floor of the chute. If a fuel bundle were inadvertently : | |||
dropped in the chute, the highest calculated dose rate at one foot | |||
from the chute in the drywell would be 4.3 rem per hour. At 40 feet | |||
from the chute inside the drywell, or the area allowed to be occupied i | |||
during fuel transfer by procedure, the calculated dose rate would be | |||
35 millirem per hour. | |||
No violations or deviations were identified. | |||
, | |||
j. Information Notices (92717) | |||
The inspector determined that the following NRC Information Notices , | |||
had been received by the licensee, reviewed for applicability, * | |||
distributed to the appropriate personnel and that actions, as | |||
appropriate, were taken or scheduled: | |||
' | |||
IN 87-28, Air System Problems at U.S. Light Water Reactors | |||
IN 87-31, Blocking, Bracing, and Securing of Radioactive | |||
Materials Packages in Transportation ! | |||
4 | |||
4 IN 87-39, Control of Hot Particle Contamination at Nuclear Power i | |||
; Plants ! | |||
. | |||
I | |||
i | |||
e | |||
i | |||
. . | |||
' | |||
e | |||
i | |||
- | |||
. | |||
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}} |
Latest revision as of 09:50, 27 October 2020
ML20148D842 | |
Person / Time | |
---|---|
Site: | Brunswick |
Issue date: | 03/10/1988 |
From: | Bassett C, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20148D819 | List: |
References | |
50-324-88-09, 50-324-88-9, 50-325-88-09, 50-325-88-9, NUDOCS 8803240349 | |
Download: ML20148D842 (11) | |
See also: IR 05000324/1988009
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
o * REGION il
i< [ 101 MARIETTA ST., N.W.
,,,,, ATLANTA, GEORGIA 30323
MAR 161988
Report Nos.: 50-325/88-09,50-324/88-09
Licensee: Carolina Power and Light Company
P. O. Box 1551
Raleigh, NC 27602
Docket Nos.: 50-325, 50-324 License Nos.: OPR-71, OPR-62
Facility Name: Brunswick
Inspection Conducted: February 8-12, 1988
Inspector: la
. H. Bbssett v Date Signed
Accompanying Personnel: C. M. Hosey
R. B. Shortridge
Approvedby:.L bdw
p.M.iHosey,SectionChief
(ok
Date' Signed
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Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection was conducted in the areas of
audits and appraisals, outage planning and preparation; training and
qualification of new personnel; external exposure control; internal e'posure
control; control of radioactive material, contamination, surveys and
monitoring; maintaining exposures as low as reasonably achievabir.: (ALARA);and
information notices followup.
Results: Two violations were identified - (1) failure to maintain access to a
high radiation area locked (see Paragraph 4.d.(2)); and (2) failure to fcilow
procedures or to have adequate procedures (see Paragraphs 4.d.(3), 4.h.(1),
4.h.(2)).
8803240349 880316 4
DR ADOCK 0000
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REPORT DETAILS
1. ~ Persons Contacted
Licensee Employees
C. Barnhill, Dosimetry Foreman, Environmental and Radiological Control
- E. Bishop, Manager, Operations
- C. Blackman, Superintendent, Operations
- S. Callis, Onsite Licensing Engineer
- A. Cheatham, Manager, Environmental and Radiological Control
- E. Eckstein, Manager, Technical Support
- K. Enzor, Director, Regulatory Compliance
- R. Helme, Director, Onsite Nuclear Safety
- J. Henderson, Supervisor, Environmental and Radiclogical Control
- P. Howe, Vice President, Brunswick Nuclear Project
- L. Jones, Director, Quality Assurance / Quality Control
- J. O'Sullivan, Manager, Maintenance
- R. Queener, Physical Engineer, Environmental and Radiological Control
- J. Smith, Director, Administrative Support
J. Terry, ALARA Coordinator, Environmental and Radiological Control
- L. Tripp, Supervisor, Environmental and Radiological Control
Other licensee employees contacted included construction craftsmen,
, engineers, technicians, operators, mechanics, security office members, and
i office personnel. ;
NRC Resident inspector
- W. Ruland
- Attended exit interview
2. Exit Interview
The inspection scope and findings were summarized on February 12, 1988,
with those persons indicated in Paragraph 1 above. The inspector
described the areas inspected and discussed in detail the inspection
findings listed below. The licensee acknowledged the inspection findings.
However, licensee management stated that they might deny the violation for
an inadequate procedure regarding reading of relf reading pocket
dosimeters since the event was still under investigation. The licensee
also stated that they considered that appropriate corrective actions had
'
been taken regarding the auxiliary operator displaying poor radiological
work practices. The licensee did not identify as proprietary any of the
material provided to or reviewed by the inspector during this inspection. 1
e
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3. Licensee Action on Previous Enforcement Matters
(Closed) Unresolved Item (325/87-39-03, 324/87-40-03), Poor radiological
work practices exhibited by an auxiliary operator. See Paragraphs 4.d.2
and 3 of report details.
4. Occupational Exposure During Extended Outages (83728)
a. Audits and Appraisals (83722, 83724, 83725, 83726, 83728)
The inspector reviewed audits of the radiation protection program
performed in 1986 and 1987. The extent of audits, qualifications of
auditors, and adequacy of the audits were assessed. During the
review the inspector noted that of the ten monthly assessments
performed by the corporate radiological protection group and reviewed
by the inspector, none identified any radiological deficiencies or
necessary corrective actions designed to improve the stations'
radiation protection program. In late 1987 the corporate group
, performing the audits / assessments function was disbanded and the
auditors reassigned to other departments as a result of a corporate
reorganization. The licensee stated that a new audit program was
being developed and would be implemented as soon as possible. Audits
or assessments performed by the new audit program will be reviewed
during the next inspection.
No violations or deviations were identified,
b. Planning and Preparation (83724, 83725)
Tne trasent health physics organization, staffing levels, and lines
of authority as related to outage radiation protection activities
were discussed with licensee representatives. The organizational
responsibility and control of the contractor HP technicians used
during the outage was also discussed. The licensee's HP organization
consisted of a radiation protection manager, two supervisors, eight
foremen, nine technical support personnel and sixty technicians. To
provide additional job coverage required by the Unit 2 outage, the
licensee increased the staff with eighty-three contract HP
technicians. After training had been completed and verified,
contractor HP technicians were integrated into the non-supervisory
! positions, commensurate with the experience and qualifications.
Licensee personnel maintained supervision over the HP contract
technicians to assure compliance with established procedures and an
acceptable quality of work was attained. Staffing levels for the
outage appeared to be adequate.
,
No violations or deviations were identified.
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c. Training and Qualificahon (83723)
(1) Technical Specification 6.3 required that each member of the HP
staff meet or exceed the minimum qualifications of ANSI
N18.1-1971. Paragraph 4.5.2 of ANSI N18.1 stated that
technicians in responsible positions were to have a minimum of
two years of working experience in their speciality. The
licensee in practice requires that an individual have three
years experie0ce to perfor.n the tasks assigned to junior
technicians, teree to five years experience to perform as a
technician and five or more years to be a senior technician.
The inspector reviewed records of selected health physics
technicians and noted that their qualifications and experience
level appeared to be commensurate with their job assignments and
responsibilities.
<
(2) Contractor Health Physics Technician Training and Qualification
The 83 HP technicians contracted to augment the licensee's HP
staff received 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of classroom training in site
radiological plant specifics in the areas of proceduras,
instruments, basic health physics, problem solving and safety.
To successfully complete the HP orientation, a contract
individual must score 80 percent on an exanination to be
classified a junior technician and eight-five percent to be
classified as a senior technician. Prior to assignments of job
coverage, the contractor technicians must satisfactorily
demonstrate their knowledge and skills by performing the same
tasks required of licensee technicians. The checkout of a
contractor technician, in selected tasks, is monitored by a
licensee-qualified instructor. Upon successful completion of
the task, the instructor signs off the contractor technician's
job perfornance on the same qualification-card required of
licensee HP technicians. After completion of on the job
iraining and qualification, the contractor technician is
,
assigned radiological job coverage responsibilities.
No violations or deviations were identified,
d. External Exposure Control and Dosimetry (83724)
(1) Use of Dosimeters
,
10 CFR 20.202 requires eaC1 licensee to supply appropriate
personnel monitoring devices to specific individuals and require
the use of such equipment. During tours of Units 1 and 2
reactor building, the inspector observed the use of
thennoluninescent dosimeters (TLDs) and self-reading pocket
dosimeters (SRPDs). It was noted that workers typically placed
,
'
their SRPDs inside their protective clothing. The inspector
discussed with the licensee the potential for workers to
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contaminate themselves if they reach inside their protective
clothing to read their SRPD to monitor their exposure. The
licensee stated they would review this matter and that'
appropriate corrective actions would be taken.
(2) Radiologically Controlled Areas
Technical Specification 6.12.2 requires that each high radiation
area, in which the intensity is greater than 1,000 mrem /hr, have
locked doors to prevent unauthorized entry.
The inspector- reviewed an unresolved item as reported in
Inspection Report 87-39 and 87-40 dated December 29, 1987. The
unresolved item concerned an event which occurred on November
12, 1987, during which a NRC resident inspector accompanied an
Auxiliary Operator (A0) making daily rounds of Unit 2 Reactor -
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Building. The A0 was observed to unlock a chainlink door to
access the Unit 2, 80 foot east fuel pool heat exchanger room, a
high radiation area. The A0 left the area for a period of about
5 minutes to dress out in protective clothing. During this
period the high radiation area was unlocked and unattended,
however, the inspector stood by the door and stated that no
unauthorized entry was made by anyone into the area. A review
of radiation surveys of the area taken on November 14, 1987,
showed maximum general area radiation levels of 60-700 mrem /hr
'
with a.5,000 mrem /hr hot spot. No radiation readings were taken
to determine the radiation levels in the accessible areas
immediate adjacent to the hot spot. The inspector and licensee
toured the area on February 11, 1988, and noted that the area
adjacent to the hot spot could be accessed by an individual.
The licensee controlled access to the fuel pool heat exchanger
room as a high radiation area and required the door to the area
to be locked. Failure to maintain access to a high radiation
area locked was identified as an apparent violation of 1
10CFR20.203(c)(iii)(50-325,324/88-09-01).
(3) Radiation Work Permits (RWPs)
i Technical Specification 6.8.1 requires that written procedures
I be established, implemented, and maintained covering the
activities recomended in Appendix A, of Regulatory Guide 1.33
of November 1972.
,
Regulatory Guide 1.3?. Quality Assurance Program Requirements,
I Appendix A. Section . A recomends that the licensee have
l procedures for perfonw.,9 maintenance and Section G.5 recomends .
procedures for personnel radiation monitoring and special work
l
permits.Section I.S.b recomends that factors be taken into
l
account in preparing detailed work procedures, including the
.
necessity for minimizing radiation exposure to workmen.
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Technical Specification 6.11.1 requires that procedures for
personnel radiation protection shall be prepared consistent with
the requirements of 10 CFR Part 20 and shall be approved,
maintained, and adhered to for all operations.
Radiation Control and Protection Procedure, Volume Vill,
Section 6.6.3 states that required items of protective clothing
shall be worn by all personnel while in radiation controlled
areas.
On November 12, 1987, while the NPC resident inspector
accompanied the A0 making daily rounds of the plant, the
inspector observed the A0 violate protective clothing
requirements on two occasions. The A0 entered the 80 foot Fuel
Pool Heat Exchanger area and the mini-steam tunnel with a hard
hat instead of a hood as required by RWP-1002, Revision 0,
locally posted dress out requirements, and prior instructions
from the duty health physics technician.
Failure of the A0 to comply with RWP requirements in that he
failed to wear the correct protective clcthing was identified as
an apparent violation of Technical Specification 6.8.1 (325,
324/88-09-02).
The inspector reviewed general and special RWPs posted at the
entrance to the radiologically controlled area to verify they
complied with regulatory requirements and contained sufficient
guidance,
e. Internal Exposure Control (83725)
(1) Intake Assessment
10 CFR 20.103(a) establishes the limits for exposure of
individuals to concentrations of radioactive materials in air in
restricted areas. This section also requires that suitable
measurements of concentrations of radioactive materials in air
be performed to detect and evaluate the airborne radioactivity
in restricted areas and that appropriate bioassays be performed
to detect and assess intakes of radioactivity.
The inspector reviewed selected results of general inplant air
samples taken during the refueling outage and results of air
samples taken to support work authorized by special radiation
work permits. The inspector also reviewed the selected results
of whole body counts.
(2) Engineeririg Controls and Respirctory Protection
10 CFR 20.103(b)(1) requires that the licensee use process or
other engineering controls to the extent practicable to limit
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concentrations of radioactive materials in the air to levels
below those which delineate an airborne radioactivity area as
defined in 20.203(d)(1)(ii).
During plant tours, the inspector'cbserved various engineering
controls to limit the concentrations of airborne radioactive
material. These included the use of temporary ventilation
systems, containment enclosures, and air supplied respirators.
The inspector discussed the use of respiratory equipment with
the licensee to ensure that medical evaluations and fit testing
were performed prior to respirator use. Selected records were
reviewed to ensure that the required training and medical
evaluations were documented.
No violations or deviations were identified,
f. Control of Radioactive Materials and Contamination, Surveys and
Monitoring (83726)
(1) Surveys
The licensee was required by 10 CFR 20.201(b) and 20.401 to
perform surveys and to maintain records of such surveys
necessary to show compliance with regulatory limits.
During plant tours, the inspector examined radiation levels and
contamination survey results posted outside various areas
including Units 1 and 2 drywells. The inspector performed
independent surveys of selected areas using NRC equipment and
compared them with licensee survey results. The inspector also
examined licensee radiation protection instrumentation and
verified that the calibration stickers were current. .
(2) Caution Signs, Labels and Controls
10 CFR 20,203(f) requires that each container of licensed
radioactive material bear a durable, clearly visible label
identifying the contents when quantities of radioactive material
exceeded those specified in Appendix C.
During plant tours the inspector verified that containers of
radioactive material were properly labeled when required.
(3) Area and Personnel Contamination
The inspector reviewed records of skin contamination occurrence
for 1987 and the current outage. The licensee had 420 skin
and/or clothing contaminations in 1987 and 77 through the first
5 weeks in 1988.
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The licensee maintains approximately 625,000 square feet of the
Unit 1 and Unit 2 reactor buildings and turbine building as a
radiologically controlled area. Approximately 66,373 square
feet or 9.4 percent is controlled as contaminated areas.
No violations or deviations were identified.
9 Program for Maintaining Exposures As Low As Reasonably Achievable
(ALARA) (83728)
10 CFR 20.1(c) states that persons engaged in activities under
licenses issued by the NRC should make every reasonable effort to
maintain radiation exposure ALARA. The recommended elements of an
ALARA procram were contained in Regulatory Guides 8.8, Information
Relevant to Ensuring that Occupational Radiation Exposure at Nuclear
Power Stations will be ALARA, and 8.10, Operating Philosophy for
Maintaining Occupational Radiation Exposures ALARA.
ALARA Program
The inspector discussed the ALARA Program with licensee
representatives. During calendar year 1987 the collective exposure
man-rem goal with 1 refueling outage was 1,209 man-rem and
1,419 man-rem was expended. The 1988 man-rem goal is 1,530 with two
scheduled outages. The first refueling outage goal is 852 man-rem.
On February 12, 1988, the licensee had expended 476 of 479 projected
man-rem for the first outage. The annual collective exposure goal
was established at the station and was based on specific jobs and
outage workscope. The inspector reviewed the planning for the
refueling outage in progress and the outage report for the previous
refueling outage in 1987. The job history / lessons learned section of
the report contained substantive ALARA considerations to be used in
minimizing radiation exposure for subsequent, similar or repeat
operations. The planning document for the current outage did not '
appear to address, in the same level of detail, the ALARA
considerations from the previous outage report. Consideration of
lessons learned in outage planning will be reviewed during subsequent
inspection.
No violations or deviations were identified.
h. Radiological Events Review
(1) On January 3,1988, the licensee was transferring a startup
range monitor dry tube via over head crane to a storage location
in the spent fuel pool (SFP). Due to the length of the dry
tubes and configuration of the path from the reactor vessel
cavity to the spent fuel pool, the crane is required to be
positioned at the far section of the SFP away from the reactor
cavii.y(to
canal cattleallow movement
chute). Theofgripper
the dryend
tubeofthrough
the drythe transfer
tube is
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normally lowered as far into the SFP as possible. The lower end
of the dry tube is then raised, a bow in the tube rotating
downward occurs, and the lower end of the dry tube is moved out
of the cattle chute area and lowered to the SFP for storage.
Normally the dry tube is maintained underwater to provide
shielding during the operation for_ these highly irradiated
components. During this event the crane hoist was correctly
located.but a problem with the hydraulic cables on the gripper
tool prevented lowering the dry tube to the correct location
necessary to raise and rotate the other. end of the dry tube.
With the upper end of the dry tube at a higher position than
normal, the bottom of the dry tube was raised using a "J" hook
tool. The dry tube bowed in an upward direction causing a
highly irradiated section of the tube to break the water. When
this occurred the area radiation monitor alarmed and the
technician handling the J hook was instructed to drop the tube
back into the water. The dry tube was out of the water for a
maximum of 2 to 3 seconds. Radiation surveys on a similar dry
tube read approximately 4,000 rem /hr on contact. The highest
exposure to an individual involved in the event was 30 mrem.
The inspector discussed the operation with the cognizant
engineer and reviewed the SRM Dry Tube Removal Procedure,
ENP-46. The procedure did not contain the necessary information
and precautionary steps to prevent the dry tube removal from
exposing personnel to high levels of radiation. The upper end
of the dry. tube was in too high a position to ensure a downward
rotation when the lower end was raised. The procedure step used
to rotate the dry tube was broad in nature and allowed several
actions to be performed simultaneously instead of several steps
that are used in sequence. Failure of the procedure to include
the necessary factors for minimizing radiation exposure to
workmen was identified as an additional example of an apparent
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violation of Technical Specification 6.8.1 (50-325,
324/88-09-02).
(2) On January 23, 1988, a licensee individual entered the Unit 2
l
drywell to prepare a weld on the feedwater nozzle for inservice
l inspection. General arer, dose rates in the work area ranged
'
from 30 to 150 mrem /hr with contact readings on a shielded valve
i
penetration located in the work area from 300 to 1,200 mrem /hr.
!
Radiation Work Permit 88-1053 Attachment A, in part, required
l that continuous coverage be provided by health physics during
I the operation, that work should be planned to reduce stay-time
l and generation of radwaste, and that work area dose rates be
monitored often. After approximately 15 minutes in the drywell,
the worker read his SRPD as suggested by Radiation Control and
Protection Procedure, Volume VIII and noted 40 mrem. He began
to prepare the weld surface by flapping with a grinder. After
completing the weld prep which took approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the
worker read his SRPD for a second time and noted that it was
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offscale. The worker exited the drywell and reported to health
physics. Processing of the workers TLD revealed that he
received an exposure of 1,120 mrem for the quarter and 800 mrem
during the entry on January 23. This exceeded the licensee's
administrative limit of 1,000 mrem per quarter. An
investigation by health physics of the event revealed that the
same operation had previously been performed several times in
the area resulting consistently in exposures of 20 to 50 mrems.
Health physics personnel responsible for drywell coverage did
not observe the worker during the weld prep operation as
required by the RWP. Although the worker was aware of
1,000 mrem /hr dose rates, he failed to read his SRPD.
The inspector asked HP supervision and technicians what their
understanding of continuous coverage meant. There were several
interpretations that ranged from control point entry at the
drywell constituted continuous coverage, to intermittent
coverage (10 to 15 minute checks), to constant coverage during
the entire job. In March 1986 HP management issued a memorandum
to define continuous coverage but this allowed a HP technician
the option of uninterrupted positive control (constant) or
periodic surveillance intermittent consistent with the
radiological hazard. The licensee stated that corrective action
of strictly defining continuous HP technician coverage would be
taken.
Based on a review of radiological procedures and the radiation
work permit requirements the inspector determined that the
werker was not required by procedures or RWP to frequently read
his SRPD while in radiation or high radiation areas. Radiation
Control and Protection Procedure, Volume VIII, Section 6.6.2 is
considered inadequate in that it failed to require that SRPD be
read frequently when an individual is in a high radiation area
to minimize exposure. Failure to have an adequate procedure was
identified as an additional example of an apparent violation of
,
Technical Specification 6.8.1(50-325,324/88-09-02).
l i . Radiological Controls for Drywell During Spent Fuel Movement
l (Tl 2500/23)
!
l During a previous inspection, controls used during spent fuel
movement were reviewed and appeared to be adequate. At that time the
'
licensee indicated that a new portable fuel-chute shield or "cattle
l chute" was being fabricated and the various dimensions and amounts of
I shielding were discussed. The inspector questioned the adequacy of
! the shielding and the licensee indicated that further consideration
would be given to the design and fabrication of the new chute.
During this inspection, the inspector reviewed the specifications of
l the new cattle chute and the radiological analyses of several
! postulated fuel drop accidents performed after some design changes
!
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and shielding modifications were made. The newly fabricated cattle
chute now appears to be adequate, with six inches of lead shielding
in the floor of the chute. If a fuel bundle were inadvertently :
dropped in the chute, the highest calculated dose rate at one foot
from the chute in the drywell would be 4.3 rem per hour. At 40 feet
from the chute inside the drywell, or the area allowed to be occupied i
during fuel transfer by procedure, the calculated dose rate would be
35 millirem per hour.
No violations or deviations were identified.
,
j. Information Notices (92717)
The inspector determined that the following NRC Information Notices ,
had been received by the licensee, reviewed for applicability, *
distributed to the appropriate personnel and that actions, as
appropriate, were taken or scheduled:
'
IN 87-28, Air System Problems at U.S. Light Water Reactors
IN 87-31, Blocking, Bracing, and Securing of Radioactive
Materials Packages in Transportation !
4
4 IN 87-39, Control of Hot Particle Contamination at Nuclear Power i
- Plants !
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