BECO-87-011, Responds to NRC Re Insp Rept 50-293/86-19.Actions Taken in Response to Inspector Followup Items Detailed in Encl.All Commitments Made Have Associated Completion & Target Dates & Assigned Personnel

Responds to NRC Re Insp Rept 50-293/86-19.Actions Taken in Response to Inspector Followup Items Detailed in Encl.All Commitments Made Have Associated Completion & Target Dates & Assigned Personnel

ML20212R496
Person / Time
Site:	Pilgrim
Issue date:	01/22/1987
From:	Lydon J BOSTON EDISON CO.
To:	Martin T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
BECO-87-011, BECO-87-11, NUDOCS 8702020682
Download: ML20212R496 (15)

Text

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BOSTONEDISON Executive of fices 800 Boylston Street Boston, Massachusetts 02199 James M. Lydon Chief Operating Officer January 22,1987 BECo Ltr. #87- 011 k

U.S. Nuclear Regulatory Commission Attention: Document Control Desk Hashington, DC 20555 Mr. Thomas T. Martin Director, Division of Radiation Safety \

USNRC 1 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293

Subject:

NRC Inspection Report No. 50-293/86-19

Dear Mr. Martin:

This letter is in response to your letter dated December 15, 1986 transmitting NRC Inspection Report No. 50-293/86-19.

Boston Edison was pleased to have the opportunity during this inspection to demonstrate its progress in the area of Radiological Protection improvements at Pilgrim.

He agree with the findings of the inspection team and are taking actions to improve and strengthen each specific and programmatic area. Boston Edison management will continue to place an emphasis on enhancing the communication interface between the Radiological Section and other station groups. Boston Edison management will also continue to refine the Pilgrim Station goals and performance monitoring programs in order to more explicitly define performance expectations, responsibility and accountability.

Actions in response to each specific item identified as an Inspector Follow Item in the subject inspection report are detailed in the attachment to this letter. All commitments made have an associated plan for completion, have been assigned to persons with primary responsibility for commitment implementation, and have been assigned target dates for completion, in accordance with our NRC Commitment Control Program.

8702020682 8701 P ama Osm g2 q,

Mr. Thomas T. Martin Page 2 Please do not hesitate to contact me directly should there be any questions regarding these matters.

Very truly yours, James M. Lydon xc: Dr. M. McBride EM/la Attachment

ATTACHMENT RESPONSE TO INSPECTION REPORT 50-293/86-19 Item 50-293/86-19-01 The documentation of management oversight and control of the radiation protection program has improved. Radiation protection Program procedures and staffing has been upgraded. However, the following significant program weaknesses were brought to the licensee's attention as areas needing improvement:

NRC:

Communications and working relationships between the Radiation Protection Section and other station sections, particularly the Operations Section, needs improvement. This continues to degrade morale with potential impact on operational and radiological safety.

The licensee is acutely aware of this problem and is taking steps to address it.

BOSTON EDISON RESPONSE:

The issue of communications and working relationships among the Radiological Section and other station groups is a matter of acute concern to all management at PNPS. In an effort to improve this relationship we have and will continue to stress the need for frequent, complete and candid information exchange and open discussion of information between all groups.

Recent initiatives have been taken by the operations department to improve the interface with the Radiological Section. The Radiological Section Manager believes that communications have improved as a result of this cooperative effort.

He will stress the need for consistency in conservatively applying both Health Physics and ALARA requirements while being helpful and supportive of efforts to operate and maintain the plant. Since some of the friction appears to result from a belief that adherence to Health Physics requirements is solely l the interest and responsibility of the Radiological Section, each section i manager and the Station Manager are making a positive and aggressive effort to l instill in all employees recognition that each individual is personally l responsible for adherence to good radiological practices. All levels of I management are making efforts to dispell the perception that Health Physics personnel are " policemen" and are encouraging that they be viewed as members of the work team with special skills to enhance work safety. All levels of management have notified their personnel that adherence to good radiological practices is of paramount importance to every section manager not only the radiological section.

l '

NRC:

i The station and section goals program needs upgrading. The current l performance monitoring program does not stress accountability when goals are not achieved. Also, some important parameters do not have accompanying goals. For example, of six radiological controls parameters included in the performance monitoring report, only two have accompanying goals. In addition, of twenty-four parameters tracked in the monthly Radiological Occurrence Report summary, none have accompanying goals. Also some important parameters are not provided to senior management as a performance indicator (e.g. total station area contaminated).

Page 1 of 13

BECO:

To stress accountability, annual personnel performance reivews will contain an assessment of an individual's performance in the area of ALARA.

The performance monitoring program has recently been expanded to include many more parameters and goals where appropriate. Of the six existing radiological parameters, goals will be estabitshed where appropriate. For example goals would not establish for total number of RHPs since this is contingent upon the ,

amount of work being performed. However, goals have been established for total number of RORs.

The information provided to management has been expanded to include items like the amount and degree of contaminated area in the station.

NRC:

Aggressive management action is needed to substantially reduce the number of Radiological Occurrences at the station. Recurrent problems continue to be identified by the Radiological Occurrence Report Program.

BECO:

Increased emphasis and management attention is being directed toward worker compilance with radiological requirements which will reduce the number of ROR's.

NRC:

The Licensee has completed a review of the Radiation Protection Plan and Radioactive Material Control Plan to ensure that appropriate implementing procedures are in place. Some procedural deficiencies were identified. The licensee should ensure all necessary procedures to implement the plans are established and implemented on a timely basis.

BECO:

As part of our Backlog Project we have assigned tasks to review safety evaluations related to onsite storage to ensure that the bases for all procedures have been accurately reflected in the procedures. The principal procedure has been modified to require review of temporary storage areas by fire protection personnel. Although considerable progress has been made in the upgrade of vital procedures, the Radiological Section intends to continue to revise and improve all procedures to ensure compliance and consistency with the Radiation Protection Plan and Radioactive Material Control Plan as part of the Backlog Project.

NRC:

A RIP audit was conducted by the Radiological Oversight Committee and by a contractor. Appropriate milestones should be established for completion of corrective actions for weaknesses identified in both assessments.

BECO:

Each item identified in the RIP implementation audit conducted by our contractor has been scheduled and assigned for action and resolution. Many of these items have already been completed. The remainder are currently scheduled to be completed during the current outage.

Page 2 of 13

' Item 50-293/86-19-02 Although the organization was found to be upgraded, the following items for improvement were identified:

NRC:

The current Radiation Protection Organization is not consistent with that depicted in Technical Specifications. The Technical Specifications should be updated to: 1) depict the correct organization and 2) clearly identify the Regulatory Guide 1.8 qualified Radiation Protection Manager (or equivalent title).

6 BECO:

A proposed Technical Specification change has been prepared which will depict the current Radiation Protection Organization and designate the PNPS position corresponding to the position of Radiation Protection Manager as defined in Reg. Guide 1.8.

NRC:

Olscussions with cognizant radiation protection personnel indicate that during outage conditions, the section directly reports to the Outage Manager and administratively reports to the Station Manager. This arrangement is not provided for or described in Technical Specifications.

BECO:

1 Boston Edison Licensing Group is evaluating the need to change the Technical Specifications.

NRC:

The Radiation Protection Plan does not describe functional responsibilities for all Radiation Protection Supervisors. The Plan serves as the primary program description document and should be updated to reflect radiation protection supervisor responsibilities.

BECO:

The Radiation Protection Plan will be revised to describe the functional responsibilities of all Radiation Protection Supervisors during the current outage.

NRC:

Responsibilities in the area of radioactive and contaminated material handling need upgrading and distribution to all station sections involved with radioactive material handling, processing and storing. Consideration should be given to establishing a radioactive waste handling, processing and shipping group.

BECO:

The procedure on Radioactive Material Control has been distributed as required reading to all station groups.

A consolidated Radioactive Waste Group has been authorized and is in the process of being staffed. This group will be responsible for all waste generation, processing, packaging and shipping activities.

Page 3 of 13

NRC:

An individual with experience in internal dosimetry should be obtained.

Otherwise the individual supervising the internal dosimetry program should be provided additional training. The current individuals supervising this area have limited experience in internal dosimetry.

BECO:

The newly hired Senior Supervising Engineer, Dosimetry and Respiratory Protection reported to work on 12-29-86. This individual has experience in internal dosimetry and will have available to her the services of a Certified Health Physicist with substantial training and experience in internal dostmetry. Additionally, an internal dosimetry course is being administered to approximately 20 members of the Radiological Section.

NRC:

The Senior Radiological Engineer - ALARA position is vacant. This position should be filled in a timely manner by a qua11 fled individual.

BECO:

He are currently searching for and interviewing candidates for the position of Senior ALARA Engineer. Every reasonable effort will be made to hire a qualified individual as expeditiously as possible.

E:

Personnel are being moved to other positions in the radiation protection technical support area. Movement of personnel in this area should be finalized in a timely manner in order to stabilize and provide consistent oversight of technical support functional area responsibilities.

BECO:

We are in the process of optimizing the assignment of personnel in order to focus management oversight and technical competence in those areas which require the greatest improvement. We will make every reasonable effort to formalize these adjustments promptly. He believe that the present organization is adequate to meet the needs of PNPS for the foreseeable future and we expect to stabilize its structure within the next 2 months.

Item 50-293/86-19 Licensee personnel indicated that the following matters would be reviewed:

E:

i The inspector noted that the board used for posting of notices to workers (as required by 10CFR 19.11) at the main control point was not in a location conspicuous to individuals entering the controlled area using the access route

! from the Administration building. The licensee stated that the board had been recently moved during facility modifications and would be relocated to a more conspicuous location.

' BECO:

i l The board used for posting of notices to workers at the main control point has i been relocated. It is now located in the New Administration Building, i immediately next to the doorway providing access to the controlled area.

Page 4 of 13 l

NRC:

Inspector noted discrepancies between the qualification requirements specified

, in the training manual and those in the individual position descriptions. The position description for the chief radiological engineer is not consistent with the qualification description in the training manual. Also, an apprentice radiation protection technician is not described in the training manual.

BECO:

The qualification listed in the individual position descriptions are generally more stingent and more recent than those in the training manual. The training manual will be updated as part of the Backlog Project.

N,RQ:

The training manual, section 3.5.4, describes the qualification prerequisites for entry level. Paragraph 3.5.4.1 states that all HP technicians hired into the Boston Edison Company will meet the ANSI N18.1 requirements. The description as to what Boston Edison considers adequate to meet the training and experience requirements is not consistent with ANSI N18.1.

BECO:

The training manual.Section 3.5.4, will be revised if necessary to reflect the description of training and experience requirements of ANSI N18.1 by 4/1/86.

Item'50-293/86-19-04 The following program weaknesses were discussed with licensee's management for appropriate action:

NRC:

Communication between the RP group and operations and maintenance groups is vital for the proper operation of a RWP control system. The frequent use of Priority "A" RWPs, the large number of RWPs requested and approved that do not get worked, and the failure to notify the RP group when work is complete, indicated communication problems and a lack of a strong management oversight to ensure efficient and safe conduct of radiological operations.

BECO:

As previously stated in response to Item 50-293/86-19-01, communications and working relationships among the Radiation Protection Section and other station groups is a matter of acute concern. In an effort to improve the efficiency of the RWP system, we will continue to stress the need for frequent, complete and candid exchange of perceived problems and possible solutions. RWP usage rates are now trended and lists of those persons not using RWPs, once issued, is presented to station management for remedial action.

Station management is strongly committed to a work management system, incorporating the RWP process in work planning and performance. Full implementation of this system is expected to achieve among other objectives, an increase in the efficiency of implementation of the RWP system.

Page 5 of 13

Itea 50-293/86-19-05 Licensee personnel indicated the following matter would be reviewed:

NRC:

Review of the 1986 RORs indicated a recurring problem with maintaining LHRA access points locked. The gate to the RWCU pump room found unlocked in this inspection had been previously found unlocked and unguarded by an NRC inspector this year. Repeat occurrences of the N.W. gate on the 51' level of the Turbine Building being found unlatched were also noted. These occurrences indicate that the licensee's systems for diagnosing a root cause, necessary for proper corrective action, needs improving. In discussions with RP supervision the licensee indicated they would investigate whether they had a generic problem with the LHRA mechantsms.

BECO:

4 The recurring issue of unlocked high radiation area doors will be corrected by

1) improving the system for identifying individual (s) by name who have possession of high radiation keys and 2) employing disciplinary action (s) where necessary to increase individuals' appreciation for the importance of key control and locked high radiation area doors. These actions are presently in progress. We have also instituted the practice of auditing LHRA every four hours to ensure that all areas are properly controlled.

NRC:

During the review of the keys controlled by the operations group, the inspector interviewed one watch engineer / shift supervisor, a senior reactor operator and the technical assistant involved in LHRA key issuance. The watch engineer interviewed displayed a lack of knowledge of the control and issuance procedures of the keys administratively under his control. A review of the key issuance log did not indicate that any key was issued to unauthorized personnel.

BECO:

A recent policy has been issued by the Operations Section Manager to clarify the Watch Engineers' responsibilities in the matter of high radiation area key control.

NRC:

Controlling procedure 6.1-012 does not reflect the requirements for entry into high radiation areas specified in TS 6.13.1. This procedure leads the reader to believe that continuously indicating radiation monitoring devices are only l required for entrance into areas of greater than 10,000mR/hr contrary to the TS (which require them in areas of 100 mR/hr or greater). Although these requirements are listed in the RWP issuance procedure (No. 6.1-022) referenced in 6.1-012, this may lead to some confusion with plant personnel. During GET

! for initial access to the plant, the NRC inspectors were told by the instructor that having a continuously indicating monitor was in fact not required unless entering an area of greater than 10,000 mR/hr.

I BECO:

Both the procedure in question and the GET course will be corrected to accurately reflect Technical Specification Requirements.

Page 6 of 13

itel 50-293/86-19-06 The following matters and concerns were discussed with the licensee during the inspection and the licensee indicated that they are being addressed:

NRC:

Completion of dosimetry procedure revisions and implementation.

Complete development and implementation of the new dosimetry training program.

Completion of personnel dosimetry staffing (2 additional staff members).

Complete resolution of outstanding technical issues as discussed above.

Complete arrangement to perform offsite irradiation of TLD dosimeters for use in QA/QC.

BECO:

All of the five items are scheduled to be completed prior to 3/31/87.

Item 50-293/86-19-07 The licensee indicated the following matters would be reviewed:

NRC:

The licensee had established a procedure for in vitro monitoring for internal exposure controls. However, specific instructions for obtaining fecal samples, and the appropriate analyses for certain isotopes such as transuranics had not been developed at the time of the inspection.

BECO:

Necessary procedures for in vitro monitoring are scheduled to be developed and implemented during the current outage. These procedures will provide the necessary detail.

NRC:

The establishment of procedures for comparison of air sample results, whole body count data and respiratory protection would be considered.

BECO:

i Procedures for comparison of air sample results and whole body count data are being prepared and are scheduled to be implemented during the current outage.

NRC:

The appropriate guides and standards for determination of intake of radioactive material have not been referenced in procedures.

BECO:

The appropriate references have been incorporated into the procedure.

Page 7 of 13

Ite7 50-293/86-19-08 NRC:

The routine plant radiation, contamination and airborne radioactivity surveillance program is adequate. However, the program procedures do not provide guidance for modifying the program as a result of changes to the radiological environment (e.g. modification of surveillance program following leaking fuel or high coolant activity).

BECO:

The procedures are scheduled to be improved to provide guidance for modifying the program when warranted by extraordinary situations by 2-15-87.

Item 50-293/86-19-09 The ALARA program contains the following weaknesses:

NRC:

Need for improving inter- and intra- departmental working relationships and communication.

BECO:

Boston Edison management is continuing to provide emphasis on inter- and intra-departmental working relationships and communication through various initiatives. Examples of these initiatives are:

1.) The recent restructuring of daily morning inter-departmental meetings.

2.) The recent designation of the Station Manager as chairman of the ALARA Committee.

NRC:

Lack of effective meetings by the ALARA Oversight Committee, and too few meetings by the ALARA Committee.

BECO:

Improvement in the effectiveness of the meetings of the ALARA Committee is evolutionary in nature and is expected to increase as more meetings are held i

and meeting agenda more clearly defined. The recent designation of the l Station Manager as chairman of the ALARA Committee and future consolidation I with the ALARA Oversight Committee is expected to both improve the I effectiveness of this committee and improve inter-departmental communications and effectiveness of the ALARA program. Monthly meetings of the ALARA Committee are planned for the future.

NRC:

Need for challenging section goals and additional initiatives for dose reduction, and vigorous program followup and implementation to achieve these goals.

Page 8 of 13 l

i l

,q - ,.- - -- - - - - , -

1ECO:

Challenging exposure goals for the various station organization sections have been established by the Radiation Protection organization working closely with the individual sections. Progress toward these exposure goals is tracked by the Radiation Protection organization and reported to the various sections and BECo management.

NRC:

Need for complete development and/or implementation of procedures.

BECO:

Progress toward development and implementation of procedures is continuing, as before, with the highest priority <

Item 50-293/86-19-10 The reviews of this area indicated the licensee has substantially improved his oversight and control of radioactive and contaminated material. Instances of improper storage, spillage or identification of unexpected contamination of normally non-contaminated areas are addressed via the radiological occurrence report system. Despite these improvements, weaknesses in some aspects of the program were identified. The licensee indicated the following matters would be reviewed:

NRC:

An unapproved, unreviewed instruction is being used by maintenance personnel to provide guidance for decontamination and storage of contaminated tools.

Licensee personnel indicated the instruction will be reviewed and its information will be incorporated into the Radioactive and Contaminated Material Control Program.

BECO:

The Maintenance Section plans to formalize the instructions used for tool control and decontamination.

MC:

The current radioactive and contaminated material storage program does not contain adequate provisions to ensure that the types and quantities of material stored comply with the limitations imposed by applicable safety evaluations. Licensee personnel indicated that provisions would be included in applicable procedures to ensure that the types and quantitles of material stored are within applicable safety evaluations.

Page 9 of 13

. a BECO:

Applicable safety evaluations will be reviewed to determine what limits on the quantitles of stored radioactive material is appropriate for each permanent storage area of the plant. Existing procedures will be modified to require that estimates of the total activity of each. component will be made to insure compliance with storage limits. Limits and components will be considered which present a safety hazard due to accidental fire or similar circumstances. This review and applicable procedure changes is scheduled to be completed during the current outage.

NRC:

It is not apparent that procedures for establishment of new radioactive and contaminated material storage areas provide for all applicable safety reviews (e.g. seismic loading, fire protection) prior to establishment of the area.

Licensee personnel indicated the procedures for establishment of new storage locations would be reviewed to ensure that all applicable reviews are performed consistent with NRC guidance (e.g. Generic Letter 81-38).

BECO:

The requirement for a fire protection review has already been incorporated into the applicable procedures. The need for review for seismic or floor loading concerns will be evaluated. This evaluation is scheduled to be completed during the current outage.

NRC:

All procedures for receipt of radioactive material did not ensure that appropriate surveys required by 10 CFR 20 would be performed within the time constraints specified therein. Licensee personnel indicated security procedures would be revised to ensure radiation protection personnel are notified of receipt of radioactive material in a timely fashion to allow them to perform package surveys within 10CFR20 time constraints.

BECO:

Security procedure 2.01 is now being revised to require timely notification of a Health Physics Supervisor whenever radioactive material arrives at any gate. -

NRC:

Procedures for release of material offsite do not discuss loose or fixed alpha contamination, surveys of inaccessible areas, types of alternative surveys for "non-routine" material released (e.g. soll) off. site; or lower limits of detection for this non-routine material.

Page 10 of 13 l

i l

'"BECO:

i This procedure has been modified to address these concerns. The issue of de-minimus measurements as they apoly to the release of " clean" or

" contaminated" material such as dirt has not yet been resolved.

NRC:

Procedures for " direct frisk" of material do not take into consideration mixtures of beta-gamma nuclides and counting efficiencies to be realized for variations in mixtures.

BECO:

Our procedures have already been modified to specify that any activity of any and all nuclides that result in greater than 100 cpm above background is unacceptable for release.

NRC:

Procedures for counting alpha contamination smears do not address self-absorption corrections.

BECO:

We have developed a basis for an alpha self absorption factor of 1.5 and are including the factor in the appropriate procedures. These procedures are scheduled to be revised during the current outage.

Item 50-293/86-19-11 The following were considered minimally acceptable. However, the licensee indicated that they will be re;iewed for possible improvement:

NRC:

Adequacy of the activities of the well and open calibrators to cover the full range of instrument calibrations.

BECO:

We have ordered a new high range calibrator to permit calibration of the upper ranges of all instruments. He expect del.tvery of this unit within the next 3 months.

NRC:

Adequacy of the method of using the well calibrator to calibrate instruments considering scattered radiation.

BECO:

The accuracy of the existing calibrator will be determined by using an NBS traceable device.

Based on the results of this determination we will evaluate the need for a free air calibrator. He expect to complete this evaluation by 1-31-87.

Page 11 of 13

'NRC:

Adequacy of the calibration facility, or room, to house higher activity sources if the current sources are upgraded.

BECO:

The adequacy of the temporary calibration facility to house high activity sources will also be determined by 2-28-87.

Item 50-293/86-19-12 The following areas were considered minimally acceptable. However, the licensee indicated that they will be reviewed for possible improvement:

NRC:

Improvements in current QA/QC practices.

BECO:

He are presently reviewing current QA/QC practices as part of the Backlog Project.

NRC:

Improvements in supervisory review of counting laboratory data, particularly daily QA data.

BECO:

Supervisory review of counting laboratory data has been improved and will continue to receive close attention.

NRC:

Need for additional counting equipment.

BECO:

With the help of an INPO assistance visit we have determined the need for additional counting equipment. He are currently soliciting proposals for a low background alpha - beta counting system. No additional equipment is presently anticipated.

NRC:

Development of a technical bases manual or document to record the technical bases for certain practices, such as for example the choice of quality control chart limits, methods of calculating LLD or MDA, specification of the conditions under which the LLD and MDA are used, and so on.

BECO:

All of this information will be incorporated into existing procedures.

Revision of these procedures is expected to be performed during the current outage.

Page 12 of 13

" Item 50-293/86-19-13 The following program areas which need improvements were discussed with licensee personnel. The licensee indicated these would be reviewed:

NRC:

The licensee currently only has one size mask for respiratory protection.

Therefore, there will be some individuals who will not fit properly in the standard respirator facepiece. The licensee is considering purchase of additional respirator facepiece sizes to accommodate personnel with large or small faces to ensure proper respirator fit. Personnel who cannot be fit are not permitted to wear respirators.

BECO:

l' The final evaluation on the practicability and effectiveness of using different size respirators will be completed by 1/31/87.

NRC:

Respirators were stored more than two respirators high, and respirator head straps were pulled over the faceplete visor for storage. These two practices have been found to potentially deform the sealing surfaces of the respirator faceplece. The licensee stated that these two practices will be discontinued and respirator training will be revised to instruct workers on donning of respirators without pulling headstraps over the facepiece.

BECO:

The practice of stacking respirator more than two high and pulling head straps over the facepiece has been discontinued. Respirator training will be revised to instruct workers on donning of respirators without pulling head harness straps over the facepiece by 1/31/87.

Page 13 of 13

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