Text

Insp Repts 50-327/87-56 & 50-328/87-56 on 870817-21. Violations Noted.Major Areas Inspected:Mgt Controls, Training,Internal Exposure Control,External Exposure Control & Followup on IE Info Notices
	ML20235U715
Person / Time
Site:	Sequoyah
Issue date:	09/04/1987
From:	Hosey C, Weddington R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20235U703	List: ML20235U700; ML20235U704; ML20235U715;
References
	50-327-87-56, 50-328-87-56, IEIN-86-023, IEIN-86-23, IEIN-87-003, IEIN-87-007, IEIN-87-031, IEIN-87-3, IEIN-87-31, IEIN-87-7, NUDOCS 8710140215
	Download: ML20235U715 (13)
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UNITED STATES -

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jo . NUCLEAR REGULATORY COMMISSION

REGION 11

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1 101 MARIETTA STREET, N.W.

i. ? r: ATLANTA, GEORGt A 20323

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Q* * " * / OCT 0 2198T

Report Nos.:- 50-327/87-56 and 50-328/87-56

Licensee: Tennessee Valley Authority

6N 3BA Lookout Place

1101 Market Street-

Chattanooga, TN 37402-2801

Docket Nos.::.50-327 and 50-328 License Nos.: DPR-77 and DPR-29

Facility Name: Sequoyah 1 and 2

Inspection Conducted: August 17-21, 1987 _

Inspector: SlrwO hp NdM NN

4A R. E. edding n Date Signed

Accompanying-Personnl: M. T. Lauer

Approved by: atty bb d t

9 8,.dtJn N@

b C. i. yqsey, AeTtion Chief .

Date Signed

Division of RWdiation Safety and Safeguards

SUMMARY

-Scope: This was a routine, announced inspection in the areas of management

controls, training, internal exposure control, external exposure control,

control of radioactive material, facilities and equipment, ALARA, solid wastes,

transportation, followup on previous inspector identified items, followup on '

allegations and followup on IE Information Notices.

Results: Three violations were identified: (1) failure to control a high

radiation area, (2) failure to perform a 10 CFR 50.59 review for' a change in

the radioactive waste system and (3) failure to obtein. review and' approval for

a change in waste solidification procedures.

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8710140215 871002

PDR ADOCK 05000327

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,< REPORT DETAILS

1. Persons Contacted ;

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f.icensee Employees

L. M. Nobles, Plant Manager

P. R. Prince, Site Radiological Control Supervisor

R. h. Buchholz, Office of Nuclear Power Site Representative

A. M. Qualls, Assistant to the Plant Manager ;

L. !.. Jackson, Assistant to the Plant Manager

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T. J. Arney, Quality Assurance Manager

F. W. Reimann, Radiological Assessor

J. Sullivsn, Supervisor, Plant Operations Review Staff

E. R. Ennis, Assistant to the Plant Manager

W. S. Kilbure, Assistant to the Maintenance Superintendent

J. M. Qualls, Radwaste Manager

M. Littleton, R0diological Field Operations Manager

0. E. Hickman, Jc., Radiation Protection Manager i

V. Faust, Health Physicist, Corporate Staff

L. J. Politte, Health Physicist, Corporate Staff

S. Harrison, Radiation Health Shift Supervisor

T. E. Cribbe, Licensing Engineer

G. B. Kirk, Compliance Licensing Manager

J. Osborne, Manager of ALARA

J. A. Leamon, ALARA Engineer

M. Palmer, Radiation Health Manager ;

E. Parris, Radiological Outage Supervisor

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W. Wil'liams, Chemistry Supervisor

L. Strickland, Supervisor, Power Operations Training Center

Other licensee employees included technicians, security force members, and

office personnel, j

Nuc1 car Regulatory Commission !

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K. A. Jenison, Senior Resident Inspector

P. E. Harmon, Resident Inspector

D. Loveless, Resident Inspector

Attended exit interivew

2. Exit Interview

The inspection scope and findings were summarized on August 21, 1987, with

those persons indicated in Paragraph 1 above. The following issues were

discussed in detail: (1) an apparent violation for failure to control a

high radiation area involving a radioactive waste liner (Paragraph 6),

(2) an apparent violation for failure to perform a 10 CFR 50.59 review for

a change in the radioactive waste system (Paragraph 10); and (3) an apparent

violation for failure to obtain review and approval for a change in waste

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l solidification procedures (Paragraph 10). The licensee acknowledged the

L ' inspection fir, dings and took no exceptions. The licensee did not

identify as propriety any of the materials provided to or reviewe', by the

inspectors during this inspection.

3. Organization and Management Controls (83722)

Technical Specification (TS) 6.2 describes the licensee's radiation

protection organization. The inspector reviewed -the organization and

staffing of the licensee's radcon and radwaste groups. Within the radcon

group, the position of Radiological Protection Manager and Radiological

Field Operation Manager had been recently filled. The only remaining

vacancies within the radcon group were five technicians, two engineers and

two administrative personnel. The inspection determined that these

shortages were minor and did not affect the effectiveness of the radcon

program. There had been no staff changes in the radwaste group.

No violations or deviations were identified.

4. Training and Qualifications (83723)

TS 6.3.1 requires each member of the facility staff to meet or exceed the

minimum qualifications of ANSI N18.1-1971. Paragraph 4.3.1 of

ANSI N18.1-1971 states that a supervisor is required to have a minimum of

four years experience in the craft or discipline he is to supervise. The

inspector compared the experience levels of two new supervisors in the

radcon group with the qualification requirements and discussed their

qualification with licensee represer ^ - tives. The inspector determined

that the supervisors met the qualifie in requirements.

Paragraph 4.5.2 of ANSI N.18.1-1987 states that technicians in responsible 1

positiens shall have a minimum of two years of working experience in their

speciality and one year of related technical training in addition to their

experience.

The inspector discussed with licensee representatives the health physics ,

technician qualification program administered through the licensee's Power )

Operations Training Center (P0TC). Personnel received an initial four

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months of clessroom instruction at the POTC, followed by a twenty month l

on-the-job training (0JT) program. The OJT program was structured around

completion of various performance verification sheets in such areas as .

radiological surveys and radiation work permits (RWP). !

No violations or deviations were identified.

5. Internal Exposure Control (83725) .

10CFR 20.103(c)(2) provides that the licensee may make allowance for use

of respiratory protective equipment in estimating exposures of individuals

to concentrations of radioactive material in air provided that the

licensee maintains and implements a respiratory protection program that

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includes, as a minimum, written procedures regarding selection, fitting

and maintenance of respirators, and testing of respirators for operability 1

immediately prior to each use and written procedures regarding supervision )

and training of personnel and issuance records.

The inspector discussed with licensee representatives their respiratory

protection training program. The respirator qualification training and

testing was combined with general employee training (GET). Licensee 1

representatives stated that they were in the process of seperating i

respiratory protection training from GET. 1

The inspector toured the licensee's respirator repair and issue station.

and discussed its operation with licensee personnel. The inspector

examined the licensee's respirator issuance log and noted that respirators

were not uniquely identified by a serial number or other means which would 1

permit establishment of maintenance and wear histories of masks and 1

investigation of possible defects as a cause of worker internal exposures.

Licensee representatives stated such a system was being con:;1dered. ,

No violations or deviations were identified.

6. External Exposure Control (83724)

The inspector discussed with licensee representatives the staffing within

the dosimetry section. The section had recently lost three of the ten

technicians assigned to the section. As a result the licensee had to

reduce their round the clock manning of the dosimetry office to operating

hours of 6:00 a.m. to 11:00 p.m. Dosimetry personnel would have to be

called to the site to process dosimetry or perform a whole body count if

an urgent need arose during the period in which the dosimetry office was

not manned. Licensee representatives stated that this arrangement had not

caused any problems to date, but if additional staffing was needed, they

could be obtained from contractors or TVA's Watts Bar facility. As a long

term solution, the licensee was in the process of changing their radcon

and dosimetry technician training and qualification programs to facilitate

exchange of personnel between the two groups. Currently, a radcon

technincian would have to complete the entire two year training program to

become a qualified dosimetry technician.

No violations or deviations were identified.

b. Licensee Event Report (LER) SQR0-50-327/87026

The subject LER repo-ted a violation of the licensee's technical

specification requirements for high radiation area control which occurred

.on May 26, 1987. Technical Specification 6.2.2 required that each high

radiation area in which the intensity of radiation is greater than

1000 millirem / hour shall be barricaded and conspicuously posted as a high

radiation area and locked doors shall be provided to prevent unauthorized

entry into the area.

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The licensee had experienced problems during solidification of a )

radioactive waste liner in the Auxiliary Building railroad access bay in i

which the liner contents had overflowed the cask and hardened. The 4

li:ensee prepared radiation work permit (RWP) 87-0563-0004 to move the

liner by crane up to the refueling floor and across to the cask

decontamination room where the excess solidified material was to be

chipped away so that the lid could be placed on the cask. The radiation

level around the cask was 1200 molirem/ hour at 18 inches from the side of i

.the cask. The RWP required that : adcon provide continous coverage of the I

work. ).

On the day of the event, a radcon technician was sent to the radwaste area {

to assist the normally assigned radcon technician. The radwaste radcon l

technician signed the RWP for the liner work, but then left the area to I

perform routine radiological-surveys. The radcon technician that had been J

assigned to assist apparently had not been briefed that he was to cover j

any specific job, but he was standing nearby when the work group began j

preparations to rig out the liner. Although the technician had not signed !

the RWP, the work group apparently thought this technician was providing i

their coverage. A second radcon technician from the ALARA section was

also present in the area to take photographs of the job. As the cask was

being raised out of the railroad bay, the ALARA technician asked the other

radcon technician about the provisions that had been made to provide high

radiation area controls on the refueling floor and in the cask

decontamination room and was apparently told that no controls were in

place. The ALARA technician then went up two flight of stairs to the

refueling floor to catch up with the liner and provide the necessary

controls, but upon reaching the refueling floor, the technician observed

the cask being lowered into the decontamination room and a person was in

the room guiding the liner into place. Since the personnel access door to

the decontamination room was on the same elevation as the railroad access

bay, the ALARA technician headed back down the stairs and met the

temporily assigned radcon technician. It was decided that the radcon i

technician would go to the decontamination room to provide coverage and )

that the ALARA technician would phone the radcon field office to alert 1

them to the problem. While the ALARA technician was on the phone in the

railroad access bay, the technician that had left to cover the j

decontamination room came through the door. The technician stated that he i

left the room unlocked because he did not have a key. The ALARA i

technician then left to guard the access to the cask decontamination room 1

until it could be properly posted and locked. Licensee investigation )

indicated that the highest exposure received by the people involved in i

this event was 20 millirem.

A similiar event occurred on November 4,1986 (LER SQR0 50-327/86052) and

was discussed in Inspection Report Nos. 50-327/87-03 and 50-328/87-03. At

that time, it was determined that the licensee had met the criteria of

10CFR Part 2, Appendix C.V.A for not issuing a Notice of Violation. For

the most recent event, it was determined that the licensee had not met the

self identification criteria in that the violation could reasonably be

expected to have been prevented by the licensee's corrective action for

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the previous violation. Failure to provide high radiation area ontrols

for the movement of the radwaste liner on May 26, 1987, was identified as

an apparent violation of Technician Specification 6.12.2 (50-327/87-56-01

and50-328/87-56-01).

c. Radiation Work Permits (RWPs)

The licensee had implemented a system of standing RWPs for r60etitive work

that.did not involve entry into containment, a high radiat!on area or an

airborne radioactivity area. The inspector reviewed selected standing

RWPs and determined that the controls were appropriate for the type of

work described.

The inspector observed work performed under RWP 87-2202-006 to remove a

transversing incore probe (TIP) from its storage location inside the shield

wall and transfer it using a shielded transport pig to a storage cask in

the radwaste building. The highest dose rate on the TIP was measured to

be 700 millirem / hour.

No violations or deviations were identified.

7. Control of Radioactive Materials and Contamination, Surveys, and

Monitoring (83726)

a. Surveys

The licensee had established a portion of the control building

between the control room and the refueling floor as a regulated area

(i.e. radiologically controlled area) during the time that cable and

conduit were being installed in the overhead and wired to various

cabinets in the area. This change of boundaries allowed the licensee

to bring materials into the area from the controlled area without

being first surveyed for contamination. At the completion of the

work, the licensee performed a radiological survey on July 21, 1987,

to release the area as a controlled area. The inspector reviewed the

documentation of the survey results and discussed the survey with

licensee representatives. The inspector determined that the cables

inside of the conduits and cabinets were potentially contaminated and

that they had not been accessible for survey when the release survey

had been performed. The inspector stated that a person who might

subsequently work in this area and gain access to the cables could

unknowingly become contaminated. The licensee acknowledged the

comment and stated that they would evaluate placing warning signs in

the area or other means to preclude an inadvertent contamination

event in the area.

No violations or deviations were identified.

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b. Byproduct Material Control

Technical Specification 3.7.10 requires that each sealed. source

containing radioactive material either in excess of 100 microcuries

of beta and/or gamma emitting material or five microcuries of alpha j

emitting material shall be free of greater than or equal to !

0.005 microcuries of removable contamination.

Technical Specification 4.7.10.1 requires that sealed sources in use i

be tested for leakage at least once per six months.

.. Technical Specifications 6.10.1.g and h require that the licensee i

maintain records of sealed source leak checks and results of the

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annual physical inventory of all sealed source material of record.

The inspector discussed the results of the licensee's most recent j

inventory and leak check of sealed sources. The inventory was still

in progress during the inspection. The licensee used 10 CFR 30, ,

Schedule B as a guide for the sources that they maintained on their ]

inventory even though there was no NRC requirement that they do so. {

As a result the licensee had approximately 250 sources under control, 1

only nine of which were required to be controlled by the technical l

specification (greater than 5 microcurier alpha or 100 microcuries

beta / gamma). Licensee representatives stated that they had found

eight. sources that were not listed on their inventory, the largest of

which contained two microcuries of radioactivity. Most of these

sources were found in a van that had been transferred from another

TVA facility and inside inplant radiation monitors. The only other

findings was that a one microcurie Co-60 source could not be found

and was believed to have been sent to radwaste. The inspector i

determined these discrepancies were minor in nature and not

indicative of any programmatic problem. No discrepancies were

identified in regard to the nine sources requiring accountability by

the Technical Specification. 1

No violations or deviations were identified.

8. Facilities and Equipment (83727)

The inspector discussed facility changes with licensee representatives.

The licensee had disestablished their contaminated laundry and was sending

protective clothing to a licensed offsite vendor for processing. The ;

licensee had not yet made a decision on building a new laundry.

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The inspector toured the radwaste building that was under construction and

was expected to be in operation by the end of the year. The building I

featured a new combination shredder and compactor. Licensee ALARA l

personnel had recently been active in reviewing the layout of facilities !

and equipment within the building.

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The inspector toured the Condensate Demineralized Waste Evaporator (CDWE)

Building. The CL'WE was shutdown for maintenance which included biannual ;

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equipment inspection and eddy current tests. The floor was also being

- repoured so that it would slope toward the floor drains in the areas. The

. inspector also obsarved that extensive decontamination and cleanup work

had been peformed in the area.

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No violations or deviations were identified.

9. Maintaining Occupational Exposures ALARA (83728)

10 CFR 20.1(c) specifies that licensee should implement programs to

maintain workers' exposures ALARA. Other recommended elements of an ALARA

program were contained in Regulatory Guides 8.8 and 8.10.

The inspector discussed with licensee representatives recent changes that

they had made in their ALARA program. The licensee had established an

ALARA Review Committee composed of management and- supervisory personnel

from Radcon, Operations, Electrical Maintenance, Mechanical Maintenance,

Instrument Maintenance and Modifications. The inspector reviewed the

minutes of the ALARA review Committee meeting that had been held since the

first meeting in February 1987. The inspector also reviewed the ALARA

suggestions that had been received in 1987. The licensee had already

received 50 suggestions in 1987, whereas they had only received 14 in

1986. The increase was attributed to implementation of an ALARA

suggestion incentives program at the first of the year. The inspector

observed that many of the suggestions were meaningful. The licensee was

responsive to all suggestions and provided feedback to the person writing

the. suggestion.

The licensee had in place a program to minimize the area controlled as

contaminated and high radiation areas. The licensee had reduced the size

- of these controlled areas by approximately one half since the first of the

year to 6500 square feet of high radiation area and 11,348 square feet of

contaminated area. These areas represented less than ten percent of the

area of the plant.

The licensee's exposure goal for calendar year 1987 was 600 man-rem and

they had expended 293 man rem through July 31. The plant radwaste goal

was 23,400 cubic feet, and as of the inspection, they had disposed of

9,086 cubic feet.

No violations or deviations were identified. :

10. SolidWastes(84722)

a. 10 CFR Part 61

10 CFR 20.311(d)(1) requires that licensees prepare all radioactive

wastes so that the waste is classified according to 10 CFR 61.55 and

meets the waste characteristics requirements in 10 CFR 61.56.

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The.. inspector discussed with licensee representatives their plans for- i

waste stream sampling 'and analysis. .Since the units have been

shutdown, the licensee had not : sampled any waste stream, - but

continued to use the waste stream analytical data from when-the units .

were last operated. This was conservative due to decay and had been

previously' determined to be satisfactory. .The licensee planned to

, perform their next sampling after. the waste streams had reached. j

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equilibrium in activity after startup.

No violations or deviations were identified.

~b. Waste Solidification

, (1) Background

The licensee solidified radioactive waste under a process

control program (PCP) to meet the waste stability requirements ;

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of 10 CFR 61.56 and certain disposal site criteria. . The

licensee used a vendor, Chem-Nuclear Systems, Inc., to perform

the solidification services.

During May 1987, . problems were experienced during the

solidification of two liners containing CDWE bottoms. The

contents of the liners started a rising process after quantities

of the vendor stabilization, solidification and defoaming agents

were added to the. waste bottoms in the liner. The mixture

slowly flowed through the liner fill head and out the fill head

inpsection plate, leaving a solidified mass outside the confines

of the liner. The excess material was successfully chipped away

by the licensee and the liners were shipped to the disposal site

without incident.

Licensee investigation into the event revealed that the swelling

in the waste liners was caused by an exothermic reaction between

chemical -contaminants in the waste and vendor

stabilization / solidification agents causing the waste to exceed a

temperature of 240'F. This temperature was above the boiling

point of the mixture and this, in addition to the gases released I

during reaction, caused the swelling of the contents of.the !

liner.

The licensee and vendor representatives were still investigating i

this problem at the conclusion of the inspection, but several ;

interim measures had been taken to preclude future liner }

overflows. These measures included reducing the amount of waste

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introduced into a liner and restrictions on the use of a laundry

detergent (Turco 4324 NP) which was found to be especially

reactive with the vendor agents and was concentrated in the

waste as a residue from the processing of the laundry and hot

shower drain tank through the CDWE. 4

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(2) Waste Stream Processes

10 CFR 50.59(b)(1) requires that the licensee shall maintain

records of changes in the facility and of changes in procedures

made pursuant to this section, to the extent that these changes

constitute changes in the facility as described in the safety

analysis report or to the extent that they constitute changes in

procedures as described in the safety analysis report. These

records must include a written safety evaluation which provides

the bases of the determination that the change does not involve

an unreviewed safety question. l

The inspector discussed witt. i1censee representatives the

circumstances which led to the introduction of the laundry

detergent that was reactive with the solidification agents into

the CDWE waste stream. The Final Safety Analysis Report (FSAR), l

Chapter 11.2 described the laundry and hot shower drain tank as !

being normally sampled and discharged as an effluent, with

provisions for processing the liquid through the CDWE if the

sample result was above the discharge limit. Licensee

representatives stated that in May 1987, they had changed the

process for this waste stream by sending all the laundry and hot )

shower waste water through the CDWE first and then sampling to

determine if it was releasable. The change was made for ALARA

reasons to reduce the total activity in liquid effluents, but

the effect of this change was to cause higher quantities and

concentrations of laundry contaminants to appear in the CDWE

bottoms since previously only a minor amount of this waste was

processed through the CDWE. Licensee representatives stated

that no 10 CFR 50.59 review had been performed for this change

in the radioactive waste process. Failure to perform a Safety

review for the change in the manner in which the laundry and hot ,

shower drain tank was processed was identified as an apparent

violation of 10 CFR 50.59(b)(1) (50-327/87-56-02 and

50-328/87-56-02).

(3) Waste Processing Procedures

Technician Specification 6.8.2 requires that changes to

Radioactive Waste Processing Procedures shall be reviewed by the.

Plant Operations Review Committee (PORC) and approved by the

Plant Superintendent prior to implementation.

The inspector discussed with licensee representatives and

reviewed documentation of an event on May 20, 1987, which

occurred during the solidification of one of the waste liners.

It was noted that the temperature of the mixture was increasing

above the maximum temperature given in the PCP. An air line was

connected to the liner in an attempt to dissipate the excessive

heat. When the air was turned on, back pressure in the line

broke it away from the liner and liquid from the liner was

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sprayed on' t' o a vendor technician. The technician was

contaminated .to 45,000 disintegrations' per.. minute (dpm) on his

right arm, 5000' dpm on his face and 400 dpm in tho: nostrils; L A

subsequentf whole ' body count did not indicate any internally.

deposited activity. . The licensee did not: obtain a procedure-

~c hange.for connection of the air hose to the liner. Failure to

a .obtain prior review and approval for the change to; the Radiation

Waste _ Processing Procedure was. identified as ' an . apparent

violation of Technical-Specification 6.8.2-(50-327/87-56-03'and

50-328/87-56-03).

L il .- Transportation (86721)

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'10 CFR 71.5 requires - each licensee who transports licensed material

outside of the confines of its plant or- other place of use, or who

delivers licensed material to a-.. carrier for transport, shall comply with

the ' applicable requirements of the regulations appropriate to the mode cf

transport of the Departnert of Transportation in 49 CFR 170 through 189.

The inspector reviewed selected records _ of shipments perforned dcring

1987, and verified that they had been performed consistent with 49 CFR

j requirements.

No violations or deviations were identified.

12. ~Fo11cwupron Previous Inspector Identified Items (92701)

.(Closed) IFI'(50-327/328/83-28-02). Faulty Magnehelic gauge on

hood No.' I-L-231 in the Hot Sample Room. The inspector toured the Hot

Sample Room with licensee representatives and was shown-that the guages

were operable. The inspector also discussed calibration of the gauges

with instrument maintenance personnel. The inspector had no further

questions.

13. Followup on Allegations (99014) j

a. Allegation (Case No. RIl-87-A-0019)

The alleger was involvea in a contamination event on October 12, i

1983, in which his wrist became contaminated to 150,000 dpm 5,aile !

doing decontamination work. He has since developed medical 1

difficulties which he believes may have been caused by the 1

contamination. None of his doctors would tell him whether or not the j

contamination incident caused his illness. i

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b. Discussion

This allegation was sent to the licensee for resciution. The

licensee's investigation and findings were docurrented in their

Employee Concern Program Investigation Report [CP-87-SQ-253-01. The

report stated that a contamination event did occur en October 12,

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1983, involving the alleger. The alleger was decontaminating a

handrail lifting rig in a contamination zone on Elevation 734 under

RWP 83-0-00361. The contamination levels in the area were

20,000 dpm/100 cm2 The alleger did not find any contamination when

he surveyed himself with a frisker upon leaving the area, but the

portal monitor alarined as he was exitNg the Auxiliary Building.

Contamination levels of 20,000 dpm on the right forearm and

150,000 dpm on the right pants pocket were found. The alleger was

successfully decontamination by health physics. No whole body count

was performed since there was no facial contamination. The licensee

determined that the event was likely caused by transferal of residual

contamination from his protective clothing as a result of sweating.

The allegur's exposures during the calendar quarter in which the

event occurred was 193 millirem to the whole body, skin of the whole

body and the extremities. A dose calculation indicated that the

maximum dose to the skin of the forearm was 21 mrtm, which is

considered an extremity exposure. The licensee concluded that the

contamination event and resulting exposures to his forearm could not

have caused the allegers medical complaints,

c. Findings

The inspector reviewed and discussed the licensee's investigation

report with licensee representatives. The inspector reviewed the

methodology for the exposure calculation that had been performed.

The licensee's skin dose assessment procedure provided two forumlas

to use depending on whether the contamination was measured with a

frisker (i.e., portable GM survey instrument with a pancake probe) or

some other instrunent. The 21 millirem dose was calculated using the

formula for an instrument other than a frisker and the dose was

averaged over an area of 100 cm2 The inspector questioned the

selection of formulas since skin contamination was typically measured

with a frisker. The type of instrument used was not documented. Use

of the frisker formula would have given an exposure estimate of

136 millirem. Following the inspection, a health physicist from TVA's

Radiological Health Branch contacted the inspector and acknowledged

that at the time the calculations were rade he was unfamiliar with

how contamination events were routinely handled in the field and it

would have been more appropriate to use the other formula, in this

case however, the choice of formulas was not significant in that j

exposures calculated by both techniques were well within flRC limits.

The inspector performed an independent exposure calculation using

techniques acceptable to the NRC (reference IE Information Notice

No. 86-23: Excess Skin Exposures Du ! to Contamination With Hot

l Particles) and concluded that the exposure was likely approximately

1,000 millirem. The inspector determined that the licensee's smaller !

estimate was due in part to their averaging the dose over an area

greater than one square centimeter (i.e. 100 cm2), which is not

appropriate. The exposure would have been therefore approximately ,

2100 millirem using the licensee's formula. !

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The Inspictor also questioned when ~ the exposure assessment was

performed and was' informed it was made after the allegation had been.

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.sent :to' the licensee and that no assessment had been made:in 1983

when the ever,t occurred.- Only recently has the need for calculating:

skin dose from contamination' events been recognized by the industry.

During" the time period in question, few if any -licensee ~ performed

such dose assessments. The inspector stated that the investigation

report may be misleading in that it does not indicate when the

exposure assessment-was made nor explain why no' assessment was made-

when the' event' occurred. Licensee representatives acknowledged that.

. portions of the report' needed clarification.

Conclusion

The. allegation was partially substantiated in that the al. leger was-

involved -in a contamination event in 1983. Although discrepancies were

noted in the exposure assessment, the potentially higher exposure was

still well within the NRC quarterly exposure limit of 18.75 rem to the.

extremities.

No violations or deviations were identified.

14. Followup on IE Information Notices (IENS) (92717)

The inspector determined that the following information notices had been

received by the licensee, reviewed for applicability, distributed to

appropriate personnel and that action, as appropriate, was taken or

. scheduled.

IEN 87-03: Segregation of Hazardous and Low-Level Radioactive Wastes

IEN 87-07: Quality Control of Onsite Dewatering / Solidification' Operations

by Outside Contractors

IEN 87-31: Blocking, Bracing, and Securing of Radioactive Materials -

Packages in Transportation.

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ML20235U715

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