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| {{Adams
| | #REDIRECT [[IR 05000313/1990032]] |
| | number = ML20058G854
| |
| | issue date = 11/05/1990
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| | title = Insp Repts 50-313/90-32 & 50-368/90-32 on 900924-28.Major Areas Inspected:Select Portions of Occupational Radiation Protection,Transportation & Solid Radwaste Programs
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| | author name = Baer R, Murray B, Ricketson L
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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| | addressee name =
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| | addressee affiliation =
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| | docket = 05000313, 05000368
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| | license number =
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| | contact person =
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| | document report number = 50-313-90-32, 50-368-90-32, NUDOCS 9011140076
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| | package number = ML20058G851
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| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
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| | page count = 13
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| }}
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| See also: [[see also::IR 05000313/1990032]]
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| | |
| =Text=
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| {{#Wiki_filter:i -s
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| ,
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| e *
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| APPENDIX
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| U.S. NUCLEAR REGULATORY COMMISSION-
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| REGION IV
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| NRC Inspection Report: 50-313/90-32. ' Operating Licenses: ORP-51-
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| 50-368/90-32
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| ~
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| NP F-6
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| Dockets: 50-313 ..
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| 50-368
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| Licensee: Entergy Operations, Inc. (E01)
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| P.O. Box 551
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| Little Rock, Arkansas 72203
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| Facility Name: Arkansas Nuclear One (ANO) Units 1 and 2
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| Inspection At: AND Site, Russellville, Arkansas
| |
| Inspection Conducted: September 24-28, 1990
| |
| Inspectors: O
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| .
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| R.'E. Baer, Senior Reactor Health Physicist
| |
| #b N
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| Date.
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| Radiological Protection-and Emergency
| |
| Preparedness Section
| |
| A rM"
| |
| 'C T. RJcKe s'odtSenior Radiation. Specialist
| |
| Nhl90
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| Date
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| Radio ogi Protection and Emergency
| |
| Pre _ ness Section -
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| Approved: //[4
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| B'.
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| 0 //#l/'/44
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| Rur~ ray, ChT6f, Radiological Protection
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| // h k/6
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| Date /
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| Y
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| andEmergencyPrep3ednessSection
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| Inspection Summary
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| -
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| ,
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| Inspection Conducted September 24-28, 1990 (Report 50-313/90-32: 50-368/90-32)
| |
| Areas Inspected: Routine, announced inspection of select portions of the
| |
| occupational
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| programs.
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| radiation protection, transportation, and solid radioactive waste
| |
| Results: The dosimetry system was state of the art; however, an evaluation was
| |
| still in progress to determine if the thermoluminescent dosimeter chips and the
| |
| dose algorithm were appropriate. Elements of the internal exposure control '
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| 9011140076 9011os
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| QDR ADOCK 05000313 i
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| PDC "
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| _ - _ - _ _ _ - _ _ - - _ - - _ - - - - - - - - - - -
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| .
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| 1 i
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| .
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| *
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| -
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| . .
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| .g.. \
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| program were in place and it appeared to be functioning adequately. The
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| program for reporting infractions related to radiological work conditions
| |
| needed to be revamped in order to be effective as a tool for correcting
| |
| -
| |
| problems. Other radiological controls appeared to be adequate. The licensee-
| |
| has maintained a technically qualified organization. A new radiation
| |
| protection manager was recently selected. An adequate radiation
| |
| protection / general employee training program had been implemented.
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| Some problems were noted concerning timely submittal of Design Change Packages
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| to the ALARA group.
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| The licensee had performed comprehensive audits in the area inspected.
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| A well managed transportation and solid radwaste program had been implemented.
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| ,
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| .i
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| h
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| 1
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| 1
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| .
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| l % %
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| ,- *
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| .
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| -
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| ..
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| +8
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| '
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| -3 '
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| DETAILS
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| 1. Persons Contacted
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| ANO
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| *J. W- Yelverton, Director Operations
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| *D. W. Akins, Superintendent, Health Physics (HP)
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| H. N. Bishop, Radwaste Supervisor
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| *D. Boyd, Licensing Specialist
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| '
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| *0. Cypret, Senior HP Specialist
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| *J. J. Fisicaro, Manager, Licensing ANO-
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| *R. E. Green, Dosimetry Supervisor
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| W. L. Hada, HP Operations Supervisor-
| |
| *R. J. King, Supervisor, Licensing
| |
| *W. C. McKelvy, Superintendent, Nuclear Chemistry
| |
| *D. J. Moss, Radiation Protection /Radwaste Manager
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| *T. W. Nickels, Superintendent, Radwaste
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| *G. D. Provencher, Manager, Quality Assurance (QA)-
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| S. P. Robinson, Supervisor, ALARA
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| T. M. Rolniak, Lead Trainer, HP
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| *R. A. Sessoms, Plant Manager, Central
| |
| D. J. Wagner, Acting Supervisor, QA-
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| J. R. Waid, Supervisor, Technical Support Training
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| Others
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| f *C, Warren, Senior Resident Inspector,-NRC-
| |
| *K. Weaver, Resident Office Assistant, NRC .'
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| * Denotes those individuals present at the exit meeting conducted on
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| September 28, 1990.
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| The inspectors also interviewed several other licensee and contractor
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| employees, including HP, chemistry, QA, and training personnel.
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| 2. Action on Previous Inspection Findings >
| |
| (Closed)OpenItem(313/8936-01;368/8936-01): Classification'of
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| Placement of Personnel Monitorirg Devices for External Exposure - This
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| item was discussed in NRC Inspection Report 50-313/89-36; 50-368/89-36 and
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| 50-313/90-04; 50-368/90-04 and involved the monitoring of the lower leg as
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| an extremity. As reported previously, the licensee revised
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| Procedure 1000.031 to reflect the lower leg'to be included as part of the
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| whole body, but had not corrected Section 8.26 of Procedure 1642.006.to
| |
| reflect the change. The 'aspectors verified that this procedure had been
| |
| ,
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| revised to reflect the change. 4
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| !
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| . _. . . ._.. . __
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| ,
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| o
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| i . ,
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| '
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| . .
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| -4-
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| l
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| (Closed)UnresolvedItem(313/8947-02;-368/8947-02): This item was
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| discussed in NRC Inspection Report 50-313/89-47; 50-368/89-47 and involved
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| the observation of the portal monitor alarms by the~ security officers at '
| |
| the secondary guard station. The inspectors observed individuals as they
| |
| passed through the portal monitors and noted that:it appeared that the ,
| |
| number of security personnel and the attention they gave to the portal *
| |
| monitor responses had increased since the previous observation and it
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| appeared adequate to prevent personnel from leaving the site unmonitored.
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| . .
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| . .;
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| ''
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| (Closed) Violation (313/9004-03; 368/9004-03): . Unauthorized Transfer of
| |
| Byproduct Material - This. violation was discussed in NRC Inspection
| |
| Report 50-313/90-04; 50-368/90-04 and involved the transfer of radioactive
| |
| '
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| materials without possession of a current copy of the transferee's
| |
| license. The licensee had obtained an updated copy =of the transferee's-
| |
| licensee. The licensee made changes to station procedures requiring that'
| |
| verification be made thct the transferee's license is on file and current-
| |
| prior to any shipment of radioactive material made to them.
| |
| 3. Organization and Management Controls
| |
| The inspectors reviewed the licensee's onsite RP organization, staffing,
| |
| and assignment of responsibilities to determine agreement with the '
| |
| commitments in Chapters 12 and 13.of the Units 1 and 2 Updated Safety
| |
| Analysis Reports (USARs), and compliance with the requirements in
| |
| Section 6 of the Units 1 and 2 Technical Specifications (TSs).
| |
| The inspectors determined there had been no change.to the reporting chain
| |
| for the radiation protection /radwaste manager and organizational
| |
| responsibilities remained as described in NRC Inspection
| |
| Report 50-313/90-04; 50-368/90-04. In preparation-for the
| |
| maintenance / refueling outage scheduled for. Unit 1, the licensee had
| |
| contracted for 98 senior and 29 junior HP. technicians, 34 clerks and ;
| |
| 44 decontamination personnel. The 34 clerks would provide additional ;
| |
| support for both the dosimetry group and at access' control points. The '
| |
| licensee was experiencing difficulty filling all the HP technician- ;
| |
| positions. These problems were related to the. lack of availability of
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| personnel due to the large number of outages scheduled within the' industry
| |
| and the greater than normal number of technicians who did not pass the
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| ,
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| v
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| qualifications examination administered by the licensee. The licensee -
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| stated that work scheduled would be deferred if they did not have HP
| |
| technicians available to effectively monitor.the work. y
| |
| No violations or deviations were identified.
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| l 4. Training and Qualifications
| |
| l The inspectors reviewed the licensee's training and qualification program
| |
| for general employees, HP personnel, and contractor HP technicians,
| |
| including adequacy of training and quality of training, qualification
| |
| requirements, new employees, and audits and surveillances to determine
| |
| agreement with commitments in Chapters 12.5 and 13.2 of Units 1 and 2
| |
| i
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| - __ - _ _ _ _ _ _ .
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| Y v .
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| ,
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| . .
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| U
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| t -5'
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| ;
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| .
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| l
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| USARs, compliance with the requirements in Sections 6.3 and 6.4 of Units 1: .
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| and 2 TSs, and 10 CFR Part 19.12, NRC Bulletin 79-19; and the i
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| recommendations of RGs 8.8, 8.10, 8.13, 8.27, and'8.29; and
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| -
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| ANSI /ANS 3.1-1978. -
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| l
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| The inspectors reviewed the . licensee's radiation. worker training programs ;
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| for permanent plant employees, visitors', and contractors. -The licensee's -
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| general employee training and radiation worker training appeared to
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| satisfy the requirements of 10 CFR Part 19.12; and the guidance in ,
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| RGs 8.13, 8.27, and 8.29.
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| The inspectors reviewed the licensee''s. training program for HP personne1' I
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| and radwaste operators, The licensee's training program was being' (
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| 1mplemented in accordance with station procedures and met the commitments
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| made in response to. IE Bulletin 79-19 for training of radwaste personnel
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| involved in the transfer, packaging, and transport of low-level
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| radioactive waste materials.
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| The inspectors reviewed selected resumes of incoming contract HP
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| technicians and determined that they met. qualification requirements. The
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| inspectors noted that the licensee had written criteria for evaluating the
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| individual's previous experience (Procedure 1012.002, " Contract HP
| |
| Technician Selection") The inspectors noted that the licensee required
| |
| individuals to have: a high school diploma or equivalent, at least 1 year
| |
| of technical training, and at least 2 years (4000 hours in..a minimum of 80
| |
| weeks) of varied radiological pro;ection experience at a commercial
| |
| nuclear power station (or equivalant). The procedure allowed 1 year
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| (2000 hours in a minimum of-40 weeks) of power station experience to be>
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| substituted for technical experience if the individual had at least.
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| 6000 hours experience. The inspectors also noted that the maximum credit
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| allowed for decontamination experience was raised from 500 hours to
| |
| 1000 hours, and the maximum total credit allowable for decontamination,
| |
| contaminated laundry, respiratory protection', dosimetry, and radioactive- ;
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| waste handling experience was raised from 1000 hours to:1500 hours, in the
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| latest revision of Procedure 1012.002. -
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| The licensee is committed to have an individual:as radiation protection i
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| manager (RPM) that meets the requirements of RG 1.8.- 1975. RG 1.8 states i
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| that the RPM should have.a bachelors degree or the equivalent and at least:
| |
| 5 years of professional experience in applied radiation protection. At-
| |
| least 3 years of this professional experience should be in applied
| |
| radiation protection work in a nuclear facility dealing with radiological
| |
| problems similar to those encountered in nuclear power stations,
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| preferably in an actual nuclear power station.
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| The inspectors reviewed the qualifications of the new individual assigned - :
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| to the position of radiation protection /radwaste manager. The individual
| |
| has a degree in nuclear engineering and approximately 71/2 years 3
| |
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| -s s
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| .
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| *
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| . .
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| -6-
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| professional experience at a Naval shipyard and 4 1/2 years as an
| |
| evaluator for radiological protection programs at various nuclear
| |
| facilities. The later period included a long term assignment (2-3 months)'
| |
| at a nuclear power station during a refueling outage.
| |
| The inspectors discussed with the licensee the limited experience of the
| |
| new RPM with the actual supervision of a power reactor associated HP'
| |
| program. The licensee submitted a letter dated October 12, 1990, to NRC.
| |
| stating that the RPM would receive-technical support assistance from the.
| |
| former corporate HP-(also former AN0_ RPM). This assistance will-be
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| provided for a minimum of 6 months at which time an evaluation will be
| |
| made for the need of continued support.
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| No violations or deviations were identified.
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| 5. 0A program
| |
| The inspectors reviewed the QA surveillance and audit programs regarding
| |
| RP, training, and radioactive waste transportation activities to determine.
| |
| agreement with commitments in Chapter 17 of the Units 1 and 2-USARs and
| |
| compliance with the requirements in Section 6.5.2.8'of the_ Units 1 and 2
| |
| TSs.
| |
| The inspectors reviewed QA manuals, audit procedures, audit checklists,
| |
| audits, and surveillance reports conducted during the period January 1,_
| |
| 1990, to September 26, 1990, in the above areas. The inspectors also
| |
| reviewed audit findings, corrective action tracking and . responses to -
| |
| findings, and auditors' qualifications. The specific audits and
| |
| surveillances reviewed are listed below:
| |
| QAP-3-90 Quality Assurance Program Audit - Health Physics, March 12 -
| |
| through May 7, 1990
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| QAP-4-90 Quality Assurance Audit - Trai_ning (Revised), April 11
| |
| through May 25, 1990
| |
| 90-112 Quality Assurance Surveillance - HP Job Coverage (Weekend,
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| Unit 2 Power Entry), September 10, 1990
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| 90-002 Quality Assurance Surveillance - Unit 1 Radiological,
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| Contamination and Hot Particle. Surveys, January 5, 1990
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| 90-018 Quality Assurance Surveillance - Radiological Controls and-
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| Housekeeping, Units 1 and~2 Auxiliary Building, January 31, 1990
| |
| 90-023 Quality Assurance Surveillance - Radioactive. Source Control,
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| February 9, 1990
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| 90-062 Quality Assurance Surveillance - HP Radiation Surveys,-May 2,
| |
| 1990
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| !
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| '" 6-
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| .
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| *
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| .. .
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| \
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| -7-
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| The QA audits and surveillances appeared To be a comprehensive evaluation: ,
| |
| of the programs reviewed. Deficiencies that were noted had been resolved <
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| '
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| in a timely manner.
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| '
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| No violations or deficiencies were' identified, s
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| 6. External Exposure Control l
| |
| The inspector reviewed theLlicensee's external control-program to .
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| [
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| determine compliance with Unit 1 TS 6.10, Unit =2 TS 6.11; the requirements 1
| |
| of 10 CFR Parts 19,13, 20.101, 20.102, 20.105, 20.202,.and 20.401; and the ,
| |
| commitments.of. Chapter 12 of the USAR.
| |
| The inspectors reviewed the licen_see's facilities for processing new _
| |
| radiation workers and verified that the licensee obtained individuals'
| |
| previous exposure histories and verified completion of radiation worker
| |
| training prior to issuing dosimetry. ,
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| The inspectors noted that the licensee used state of the art, i
| |
| four-element, thermoluminescent dosimeters-(TLDs). .The licensee _had ;
| |
| received accreditation from the National Voluntary Laboratory i
| |
| Accreditation Program in all categories. The accreditation. extends until
| |
| January 1, 1991. The inspectors reviewed the dosimetry processing area
| |
| and the licensee's quality assurance techniques and determined that they ,
| |
| were adequate. The licensee also conducted a_ quarterly quality assurance- !
| |
| verification with the assistance of a vendor. ' Licensee representatives -
| |
| stated that they have approximately 18,000 TLDs, which appeared to be a
| |
| sufficient supply for-the upcoming outage. The inspectors:also reviewed ;
| |
| l the licensee's use of multiple TLD packets and extremity monitoring during i
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| '
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| special jobs. [
| |
| The licensee's representatives stated that a contractor was performing an
| |
| evaluation to determine the adequacy, in certain site-specific
| |
| environments, of the TLD chip currently in use. For example, licensee
| |
| representatives had noted in the past.that neutron. doses measured by TLDs
| |
| ,_ differed from that predicted from instrument measurements by as much as a
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| l
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| '
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| factor of 10. The licensee stated that if the TLDs are found to be !
| |
| appropriate, adjustments to the dose. algorithm will be made, if not,- J
| |
| different TLDs will be used and perhaps another. evaluation of.the. spectrum -r
| |
| of neutron energies will be performed, o
| |
| The inspector discussed technician qualifications with the licensee's
| |
| representatives and determined that the dosimetry technician in charge of
| |
| processing TLDs had recently completed an offsite training course in
| |
| dosimetry. .;
| |
| The inspectors observed a technician performing:a calibration of '
| |
| self-reading dosimeters (SRDs) and verified that the licensee had . .
| |
| .
| |
| implemented a program of comparison of the exposure recorded by the TLDs:
| |
| and the SRDs.
| |
| | |
| ._ _. . __ _ - _ _ - _
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| t-
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| i_ o , a
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| . >
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| .. .
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| .g.-
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| i
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| L
| |
| Licensee representatives stated that they are preparing to initiate th'e -
| |
| use of electronic, alarming dosimeters for individuals entering high
| |
| radiation areas and would perhaps, in the future,'use them for all people l
| |
| entering the radtalogical controlled area (RCA).-
| |
| (
| |
| No violations or deviations were identified. j
| |
| 7. Internal Exposure Control ,
| |
| The inspector reviewed the licensee's program for control of internal :
| |
| radiation exposure to determine compliance with Unit 1 TS:6.10, Unit 2 TS;
| |
| the requirements of 10 CFR Parts 20.103, 20.201, and 20.401; and agreement ,
| |
| with the commitments in Chapter 12 of the USAR and:the recommendations of
| |
| '
| |
| RG 8.15, NUREG-0041, Industry Standards _ ANSI Z88.2-1980 and ANSI /GCA
| |
| G-7.1-1989.
| |
| The inspectors reviewed the whole body counting facilities and noted that-
| |
| the licensee had shortened counting time on the'two bed-type whole body
| |
| counters and were thus able to process more people per time period and yet
| |
| maintain adequate sensitivity. The licensee added a third whole body
| |
| counter, a standup unit, which was located inside the protected area,
| |
| making it more convenient for investigational use than the others which
| |
| were located in the training center.
| |
| The licensee was required by.procedu're to analyze positive whole body.
| |
| counts at least quarterly to identify trends which indicated practices-
| |
| contributing unnecessary exposure,.-The inspectors confirmed that the
| |
| licensee had implemented a procedure to calculate airborne: radioactivity
| |
| concentration using whole body counting results.
| |
| The inspectors reviewed policy statements requiring the 'use of enginee' ring
| |
| controls whenever possible to lessen the possibility of internal exposure
| |
| and reviewed records of air sampling data.. The inspectors also observed
| |
| that the licensee used an adequate number of_ continuous air monitors in
| |
| i various locations throughout the facility.
| |
| !
| |
| The inspectors reviewed portions of the respiratory protection program
| |
| including: fitting, selection, issuance,. return, testing, and
| |
| maintenance. ,
| |
| I
| |
| L The inspectors observed the respirator fitting area and noted the use of
| |
| I tabletop fit testing devices. Issuance was from the HP-desk at the
| |
| radiological controlled area entrance. The inspectors' reviewed records of
| |
| respirator issue and confirmed that individuals receiving respirators were
| |
| qualified and that they received respirators of the proper size and type.
| |
| Issue procedures called for individuals'to present a laminated' respiratory
| |
| qualification card listing the dates of respiratory protection-training;
| |
| (differentiating between that for purified, air devices, supplied air, and
| |
| self-contained breathing apparatus), physical examination, fit testing-
| |
| and respirator size. The inspectors observed that it was-possible,
| |
| under certain circumstances,-for unqualified-individuals to alter the- ,
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| r
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| ]
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| | |
| . , - . - _ _ - . - .
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| \. < ,
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| -
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| t . -p
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| .. *
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| -9-
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| l cards and thus appear to have completed the required qualifications. HP
| |
| ; representatives stated that individuals had begun to present unlaminated
| |
| l cards at the issue point and HP was initiating new issuance procedures.
| |
| ; utilizing a computer printout listing the status of respiratory protection :
| |
| : qualifications of all personnel. The inspectors reviewed the information '
| |
| '
| |
| available on the radiation exposure management (REM)= system and noted that.
| |
| !
| |
| it did not differentiate between the different types of respiratory. '
| |
| protection training and hence, could not be used as an issuance tool.-
| |
| The inspectors determined that the licensee had adequate' facilities for
| |
| decontaminating, cleaning, inspection,. testing, and maintenance-of, ,
| |
| respiratory protection equipment and verified that respirators ready to be
| |
| issued had been inspected within the previous 30. days. -The inspector also
| |
| noted that the licensee had programs for the testing of:used respirator
| |
| cartridges and portable, filtered ventilation units.
| |
| Licenses representatives informed the inspectors of one instanco in which-
| |
| a unique fitting used on the breathing air system was removed and another
| |
| -
| |
| fitting was installed. The licensee representatives believed that the
| |
| fitting was replaced by employees of a contractor and were'considering
| |
| methods of preventing recurrences.
| |
| .
| |
| No violations or deviations were identified.
| |
| 8. Control of Radioactive Material and Contamination, Surveys, and Monitoring
| |
| The inspectors reviewed the licensee's program for surveying / monitoring
| |
| and controlling radioactive materials to determine' compliance-with Unit 1
| |
| [ TS 6.10, Unit 2 TS 6.11; the requirements of 10 CFR Parts 19.12, 20.201,
| |
| l 20,203, 20.205, 20.207, 20.301, and 20.401; and'with'the commitments in
| |
| Chapter 12 of the USAR.
| |
| y
| |
| The inspectors reviewed the access control procedures at containment
| |
| I
| |
| access to Unit 1 (designated as CA-1)-and observed the alternate access
| |
| -
| |
| facilities (CA-3), under construction, which will_be used during the
| |
| outage. Qualifications of individuals entering the RCA were automatically
| |
| verified by computer prior to entry.
| |
| l The inspectors noted that the egress area from the personnel hatch at
| |
| I
| |
| containment had been changed to allow more room for the> removal of
| |
| .
| |
| protective clothing by personnel as they exited.
| |
| ,
| |
| ! The inspectors reviewed survey procedures, by HP personnel, of itema prior
| |
| I to their release from the RCA and noted that tool monitors were in use for
| |
| checking items such as hard hats for contamination.
| |
| The inspectors reviewed selected radiation work permits (RWPs) and
| |
| determined that RWPs for work to be performed up through approximately the
| |
| first week of the outage had been: completed. There was no' specific method '
| |
| .
| |
| to ensure that RWPs were revised if radiological work conditions changed
| |
| :
| |
| !
| |
| | |
| 1 *
| |
| ,
| |
| *
| |
| , .
| |
| -10-
| |
| i
| |
| .
| |
| .
| |
| . . . .
| |
| :
| |
| during the course of the job other than feedback from the HP tech covering i
| |
| the work (or work area =if full coverage was not provided). Licensee i
| |
| representatives pointed out that RWPs were good only for two weeks and
| |
| survey information was reviewed before renewal.
| |
| The inspectors reviewed radiological safety infraction / condition (RSIC)
| |
| reports and noted that, in some cases, occurrences taking place as early
| |
| as April 1990 had apparently not been investigated andLresolved. In some -l
| |
| cases, items had been referred to specific individuals for action, but due i
| |
| dates had not been met and apparently action had yet to be taken. The
| |
| individual in charge of maintaining the RSIC reports also stated that he
| |
| sometimes did not receive copies of the reports and had no wa; ef 1
| |
| determining at what stage of completion the items were. Licensee i
| |
| representatives acknowledged the problems with the RSIC reports'and stated'
| |
| that they were considering ways of improving.the process. j
| |
| The inspectors reviewed radiological' survey data and determined that the-
| |
| licensee had implemented an adequate program of routine' surveys. The-
| |
| survey frequency was determined by the radiological protection manager.
| |
| In accordance with the licensee's procedures, at least 10 percent of the i
| |
| contamination surveys were counted for alpha contamination.
| |
| 1
| |
| '
| |
| The inspector confirmed that portable radiation survey instruments were
| |
| response checked daily. Licensee representatives estimated that between 1
| |
| 85 to 95 percent of the portable urvey instruments were operable and . ;
| |
| available for use. The inspectors confirmed that it appeared an adequate '
| |
| supply was available. The inspectors also reviewed the instrument
| |
| calibration facility, interviewed personnel,yand reviewed selected:
| |
| calibration procedures. The instrument and controls (I&C) department
| |
| performs the calibration of portable survey ~ instruments, portable air ,
| |
| samplers, personnel contamination monitors, portal" monitors, tool !
| |
| monitors, continuous air monitors, and particulate-iodine-noble gas l
| |
| monitors. Calibration of such-items as radiation and process monitors ~are i
| |
| performed by the unit I&C personnel. Another staff member has recently i
| |
| been added to the calibration staff, which is not HP-specific, bringing
| |
| the total to three.
| |
| No violations or deviations were identified.
| |
| 9. Maintaining Occupational Radiation Exposures ALARA
| |
| The inspectors reviewed the licensee's program for maintaining
| |
| occupational radiation exposures ALARA to-determine agreement with the
| |
| commitments in the Units 1 and 2 USARs; compliance with the requirements
| |
| of 10 CFR Parts 20.1(c); and agreement with the recommendations of
| |
| RGs 8.8, 8.10, 8.27, and Information Notice (IN) 83-59, 84-61, 86-44,
| |
| 86-107, and 87-39.
| |
| j
| |
| The licensee's ALARA program is well defined-in Administrative
| |
| Procedure 1000.033 and Section 1612.000 of the plants' operating
| |
| procedures. The HP group ALARA supervisor is responsible for site ALARA
| |
| i
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| s. .
| |
| | |
| s ,
| |
| ,
| |
| . .
| |
| -11-
| |
| activit;es. During normal plant operations the ALARA supervisor is
| |
| assisted by three senior HP technicians and five planning and scheduling
| |
| coordinators. The licensee had planned to supplement the ALARA staff with
| |
| four senior HP contract technicians during the-maintenance / refueling
| |
| outage on Unit l'.
| |
| The licensee has a hot spot tracking system and has attempted _to reduce
| |
| the radiation intensity at several locations. During September 1990, of
| |
| the 5 flushes made, 3 of the 32 hot spots in Unit I were reduced
| |
| significantly, from 1000 to 150 millirem.per hour (mrem /hr)'. The licensee
| |
| had more success in Unit 2 where 7 of the 16 hot spots were reduced.:from
| |
| 2000 to 6 mrem /hr. The intensity of the highest hot spot in Unit 1 is-
| |
| 40,000 mrem /hr at contact and 1600 mrem /hr in Unit 2.- The licensee has
| |
| plans to reduce additional hot spots during the Unit'l
| |
| maintenance / refueling outage.
| |
| .
| |
| '
| |
| The inspectors had determined that the licensee had_ completed the-
| |
| " surrogate tour", which is a laser video dicc system film to assist .the
| |
| ALARA group. The licensee expects to save person rem by reducing the time
| |
| required to locate exact work areas and identifying areas of; higher
| |
| exposure levels to work crews prior to their entry into the area.
| |
| The inspectors discussed the lack of a centralized briefing' room for work
| |
| -
| |
| crews where prejob and postjob reviews could be conducted. The licensee
| |
| had a small room in the alternate access facility "CA-3," adjacent to the
| |
| reactor building equipment hatch, set aside for prejob briefings. This
| |
| area did not appear adequate for all-ALARA briefings.
| |
| The inspectors discussed with licensee representatives the lack of work
| |
| packages for design changes that had been received from the engineering
| |
| department. Only 70 of the 80 design change packages had been received
| |
| and the outage was scheduled to- start in 3 days. The lack of timely
| |
| submittal of design change package prevents-adequate ALARA evaluations
| |
| regarding worker and HP support,-shleiding requirements, and estimated-
| |
| person-rem exposure for the jobs.
| |
| The licensee had made several improvements to the ALARA program since the
| |
| ~
| |
| last NRC inspection. Job history files had received more attention and
| |
| had been entered-into the, computer base. The licensee had contracted'for-
| |
| 12 remote television cameras, 10-with audio capability, for the outage.
| |
| These cameras will be placed within the reactor building and the master
| |
| console will be located-in the CA-3 access facility. The licensee had
| |
| also purchased alarming dosimeters for use by personnel in high radiation i
| |
| areas.
| |
| -
| |
| No violations of deviations were identified.
| |
| | |
| '
| |
| ,
| |
| . 0
| |
| -12- l
| |
| 10. Transportation Activities
| |
| *
| |
| The inspectors reviewed the licensee's radioactive material transportation
| |
| program to determine agreement with the commitments _made in response to
| |
| NRC Bulletin 79-19, ins 79-21, 80-32, 83-10, 84-14, 84-50, 85-46, and-
| |
| 87-31; and compliance with the requirements of 10 CFR Parts 20, 30, and .
| |
| 71; and 49 CFR Parts 171 through 189.
| |
| The inspectors reviewed all records of radioactive material shipments made i
| |
| from January 1 through September 24, 1990,'for completeness of shipment
| |
| records. The inspectors determined that the. licensee's procedures had
| |
| been appropriately updated to incorporate the revisions to NRC and.
| |
| Department of Transportation (DOT) regulations, changes to burial site
| |
| acceptance criteria, and applicable items from ins.
| |
| 'I
| |
| The inspectors reviewed the licensee's procurement of DOT and NRC
| |
| certified packages. The inspectors noted that the licensee normally ships
| |
| low specific activity waste in steel boxes as strong-tight containers or
| |
| in steel containers inside an NRC certified package. The inspectors
| |
| determined that the licenses maintains current documents on manufacture
| |
| design, use, maintenance, testing,' and NRC certificate of compliance for
| |
| all packages the licensee is' registered to use.
| |
| The inspectors verified that the licensee had established procedures and
| |
| checklists for the preparation of radioactive material and_ waste
| |
| shipments. These procedures included requiring-a visual inspection of the
| |
| packages prior to use or loading the package, instructions for closing and'
| |
| sealing the packages, the package's identification and weight, labeling-
| |
| requirements for the appropriate type of package, and determining the
| |
| curie content, radiation and contamination limits for packages. The ,
| |
| licensee routinely uses quality control hold or checkpoints during l
| |
| preparation of the package. '
| |
| ,
| |
| The inspectors determined by discussions with licensee representatives
| |
| that none of the ANO radiation material or waste shipments had been
| |
| involved in an accident or incident.
| |
| No violations or deviations were identified.
| |
| 11. Solid Radioactive Waste Management -
| |
| The inspectors reviewed the licensee's program for processing, control,
| |
| and onsite storage of solid radioactive waste for agreement with the-
| |
| commitments in Chapter 11'.4 of Units 1 and 2 USARs; compliance.with the
| |
| requirements in Unit 1 TS 4.29.4 and Unit 2 TS 3.11.4, 10.CFR' .i
| |
| Parts 20.301, 20.311, 61.55, and 61.56; and the recommendations of NRC "
| |
| branch technical position papers on low level radioactive waste (LLRW)
| |
| ,
| |
| classification and waste form characterization and ins 87-03 and 87-07. l
| |
| l
| |
| l
| |
| l
| |
| l l
| |
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| |
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| |
| #
| |
| The inspectors reviewed the licensee's computerized program for management
| |
| of waste processing and packaging activities. The licensee's computer-
| |
| .
| |
| program included the latest revisions to 49 CFR requirements regarding-
| |
| reportable quantities and emergency response:information. .The licensee-
| |
| stated the computer program vendor supplies, updated programs when the '
| |
| regulatory requirements are changed. The licensee performs-annual
| |
| evaluations of waste streams, samples are sent:to a qualified vendor's
| |
| laboratory for analysis and. development of isotopic correlation factors. !
| |
| The licensee's LLRW characterization and classi_fication program is well
| |
| documented in accordance with station procedures.
| |
| 4
| |
| The licensee ships dry active waste,.compactable and noncompactable- l
| |
| radwaste, to a vendor for additional.. segregation, incineration, and super '
| |
| compaction. This process has reduced:the total volume of~LLRW being
| |
| delivered to the burial site, >
| |
| !
| |
| The inspector noted during tours of the licensee's facilities that LLRW
| |
| was being stored outside, unprotected, by the old radwaste building. This
| |
| _
| |
| included 24 boxes low level contaminated soil, drums of. concrete rubble,
| |
| solidified oil,-and spent resins. The licensee was storing new unused
| |
| boxes inside the radwaste building. The licensee stated they would
| |
| reevaluate the outside storage of LLRW.
| |
| No violations or deviations were identified, t
| |
| 12. Exit Meeting
| |
| The inspectors met with the senior resident inspector and licensee
| |
| representatives identified in paragraph 1 of this report at the conclusion 4
| |
| of the inspection on September 28, 1990. The inspector summarized the
| |
| scope of the inspection and discussed the inspection findings as presented
| |
| in this report. The licensee did not identify.as proprietary any of the
| |
| materials provided to, or reviewed by, the inspectors during the ,
| |
| inspection. 1
| |
| l
| |
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| |
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| |
| }}
| |