IR 05000272/1979007
| ML18081A430 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/23/1979 |
| From: | Stohr J, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18081A426 | List: |
| References | |
| 50-272-79-07, 50-272-79-7, NUDOCS 7910290099 | |
| Download: ML18081A430 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Report No. 79-07 Docket No. 50-272 Region I License No. DPR-70 Priority:
Licensee:
Public Service Electric & Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name:
Salem Nuclear Generating Station, Unit l Inspection at: Hancocks Bridge, New Jersey Inspection Inspector: *
Approved by:
n Specialist FF&MS Branch Category: C Inspection Summary:
Inspection'on February 6-9, 1979 (Report No. 50-272/79-07)
Areas Inspected:
Routine, unannounced inspection by one NRC regional based inspector of the Radiation Protection Program during operation The areas inspected included Radioactive Material Shipping, Licensee Audit, Personnel Training, Organization and Qualification of Personne In addition, the inspec-tor also reviewed the licensee corrective action to previously identified items of noncomplianc The inspection involved 28. hours on-site by one NRC inspecto Results:
Of the four areas inspected, two items of noncompliance were identified in the following areas (Infraction - Failure to ship radioactive material in accordance with 10 CFR 71, Detail 3)(Infraction - Failure to perform audits in accordance with written procedures in accordance with 10 CFR 50,Detail 4).
DETAILS Persons Contacted
- H. J. Midura, Manager, Salem
- J. M. Zupko, Jr., Chief Engineer, Salem
- L. K. Miller, Station Performance Engineer, Salem
- J. Gueller, Senior Performance Supervisor, HP-Chemistry, Salem
- M. F. Metcalf, QA Engineer, Resident Group
- W. T. Kittle, QA Engineer Resident Group
- E. Rozovsky, EPD Quality Assurange Engineer
- J. L. Stillman, Station Quality Assurance Engineer, Salem
- W. P. Grau, QA Staff Assistant D. Lyons, QA Specialist, Salem J. Herrick, Reactor Engineering, Salem
- denotes those personnel attending the inspector 1s exit interview on February 9, 197.
Previously Identified Items References:
(a) Notice of Violation, dated January 2, 1979 (IE Inspec-tion 272/78-30; 311/78-52)
(b)
Licensee 1 s Response Letter, dated January 23, 1979 (Closed) Infraction (272/78-30-01):
Failure to perform safety evaluation in accordance with 10 CFR 50.5 The licensee 1s response letter as identified in Reference (b) was reviewe This item (modification of l-WL79 and l-WL84},
has subsequently been examined and found not to be an unreviewed safety questio The licensee 1s safety evaluation is documented in SGS/M-SE-035, 11Waste Disposal Liquid System - Temporary Truck Connections.
11 Radioactiv.e Material Shipping During the course of this inspection, the inspector exam.ined certain radio-active material shipments for compliance with the following regul.ations:
10 CFR 71.3, 11Requirement for license, 11 states, 11 No licensee subject to the regulations in this part shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed material except as authorized in a general license or specific license issued by the Commission, or as exempted in this part.
10 CFR 71.12, 11General License for shipment in DOT specification container, in packages approved for use by another person, and in packages approved by foreign national competent authority, 11 Para-
~graph (b) states 11 {A general license is hereby issued to persons
_)
holding a general or specific... to deliver ricensea material~to~-----
a carrier for transport}... In a package for which a... certifi-cate of compliance has been issued by the Commission's Director of Nuclear Material Safety and Safeguards {NMSS}... provided that the person using a package pursuant to the general license provided by this paragraph:
(i) Has a copy of the specific license, certificate of compliance, or other approval authorizing use of the package and all docu-ments referred to in the lfcense, certificate, or other approval, as applicable; (ii) Complies with the terms and conditions of the license, certifi-cate, or other approval, as applicable, and the applicable requirements of this part; and, (iii) Prior to first use of the package submits in writing to the Director of Nuclear Material Safety and Safeguards or the Atomic Energy Commission, his name and license number, the name and license or certificate number of the person to whom the package approval has been issued, and the package identi-fication number specified in the package approva On December 13, 1978, the licensee shipped two fuel assemblies (containing unirradiated uranium dioxide with the uranium enriched in the isotope U-235) to Westinghouse Electric Corporation, Nuclear Fuel Division, Columbia, South Carolin The container used for this shipment was UAS/5450/B( )F, which was certified* by NMSS on September 19, 197 Contrary to the requirements of 10 CFR 71.1 (b) the licensee did not nave 1) a copy of the specific license, certificate of compliance or other approva 1 authori zi_ng use of the package, 2) copies of the documents referenced in such licenses, certificates or approval; and, 3) did not notify NMSS prior to the licensee's first use of the packag The two fuel assemblies (M-30 and L-59) contained fissile material in excess of the quantities specified in 10 CFR 71.9, 11Exemption for fissile material.
- The assemblies were first received by the licensee on the following dates under license number SNM-1831 issued to Public Service Electric and Gas Company of New Jersey for Salem II:
Assembly M-30 L-59 November 8, 1978 October 26, 1978 The shipments were signed for by the licensee's representatives who received them for Public Service Electric and Gas of New Jerse The licensee's Radioactive ~hipment and ~eceipt Form and General Stores Transfer ~nd Shipping Memorandum both indicate that fuel assemblies M-30 and L-59 were shipped by the licensee on December 13, 197 The inspector identified that failure to adhere to the requirements speci-fied in 10 CFR 71.12(b) constituted*, an item' of*noncompliance.- * (7*9.:.ff1~01)
It was further identified to the licensee that as of January 1, 1979, the licensee is prohibited from delivering licensed material to a carrier for transport or transporting licensed material, excepting no more than type A quantities as defined in l 0 CFR_ 71 * 7, 11 Exemption for no more than_ type A quantiti"es, 11 until such time that the licensee submits and has approved by the commission a description of the quality assurance program in accordance with 10 CFR 71.51, "Establishment and maintenance of a quality assurance program." The inspector indicated that the item would be reviewed in a subsequent inspectio (79-07-02)
Radiological Audits The inspector reviewed the licensee's audit program as it relates to radiation safety against the requirements presented in the following specifications:
10 CFR 50, Appendix B AP-17 OQI-5*:.
Licensing of Production and Utilization Facilities -
Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants Operational Quality Assurance Program
\\
Audits
... /
10 CFR 50, Appendix B, Specification XVIII, Audits, states:
11A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance
P~o.g~am_and_to_ciete_rm_ine_tb~e_eff_e_ctiveness of the i:irogra The audits shall be performed in accordance with the written procedures or check 9j lists by appropriately trained personnel not having direct responsibilities in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audite Follow-up action, including reaudit of deficient areas, shall be taken where indicated.
- AP-17, which implements the station quality assurance program in accordance with 10 CFR 50, Appendix B, states:
18.. Applicable elements of the Audit Subjects* {in the} quality assurance program shall be audited *at least annually or at least once within the life of*the*a*ctivity, l/thichever* is shorte "Frequency of Scheduled Audits, Organizations responsible for the operation, maintenance, control or administration of the Salem Station shall be subject to audit under this program not less frequently than that shown in Ref. 21 Ref. 219 Audit Schedule of AP-17 states that the Station Quality Assurance Engineer (SQAE) establishes and maintains audit schedules implemented by OQI-OQI-Section 4.0 - Audit Schedul The audit period used at the station is from August of each year to July of the following year. Audits are scheduled by the SQAE to be accomplished during this audit perio As required during the audit period special audits may be assigned, or the scheduled audit may be shifted on the schedule to be accomplished at another time during the audit period.
Additionally, the target date for completion of audits is
. given as 60 days from the time of initiatio A previous NRC Inspection Report (Report 50-272/78-18, dated June 12, 1978)
identified an item of noncompliance relating to the implementation of the licensee's procedure OQI-5, 11Audits.
Detail 2 of that report noted that audit subject "Radiation Safety and Chemistry, 11 then designated by the licensee as subject number E.2 was last completed April 28, 1977; and consequently was overdue from the annual requirement at the time of the findin In response (as further noted in Detail 2) the SQAE states that all overdue audits would be completed by the licensee by August, 197 *
The licensee's response letter (dated August 11, 1978) to the.item of non-compliance identified by NRC Report 50-272/78-18, stated, "All audits shown in our implementing documents will be completed prior to the end of the annual audit cycle.
The inspector noted on February 8, 1979, that the licensee's records indicated that an audit of "Radiation Safety and Chemistry" (.revised to Audit Sub-ject Number. N-1) was initiated on May 16, 197 From further review it was learned that, apart from indication on the record that the audit was initiated, no further action was taken (i.e., the:a.udit was never commenced).
From the review of this area, the inspector identified that 1) the licensee failed to complete the stated action described in the licensee's response letter (dated August 11. 1978) to Inspecti:on Report 50-272/78-18; 2) the licensee failed to perform audits in accordance with 10 CFR 50, Appendix B, in that the annual audit of "Radiation Safety and Chemistry" was not performed as specified by the implementing procedures AP-17 and OQI-The inspector identified that failure to perform an audit of 11Radi.ation Safety and Chemistry" within the periodicity specified by the implementing procedures of 10 CFR 50, Appendix B, constituted an item of noncomplianc (79-07-03}
.
Training The inspector reviewed the licensee's training of Health Physics Technicians against tne:requirements*specified in the followi:ng:
Technical Specification AP-24 Final Safety Analysis Report
. CFSAR) *:chapter 12 Technical Specification 6.4.1, states:
Training Radiological/Safety Program Conduct of Operations 11A retraining and replacement training program for the facility staff shall be maintained under the direction of the Chief Engineer and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI Nl8.l-1971 and Appendix A of 10 CFR Part 55.
The implementing procedure for this specification in regards to the Radi- **
ation Protection Department is AP-2 AP-24 states that the training of radiation protection personnel will be accomplished by Radiation Protection Instructions (RPI) and the response to FSAR Question 12.7; and that retraining will be accomplished in accordance with RPI.
- I*
FSAR Question 12.7 response is an in depth description of the licensee's intended personnel training program that was implemented for the startup of the Unit No. Contrary to the statements presented in AP-24, the inspector learned that there were no RPis prepared that dealt with the subject of training and retraining of Health Physics technician Further review of the training records of the station's nine staff techni-cians against the description of tr~ining specffied in the response to FSAR Question 12.7 indicated that, *
none of the technicians were subject to the complete training specified; four of the nine technicians met 80% of the spectfied training; five of nine technicians met between 10% and 50% of the specified trainin The inspector determined that there was not a formal training or retraining program in existence at the time of this inspection. It was noted, however, that the licensee had engaged the services of a contractor to provide Health Physics related training to the technician The inspector reviewed the training that was administered by the contractor and found that it appeared to meet the requirements of Techni:cal Specification 6.4. According to the Performance Supervisor, Health Physics.and Chemistry, upon completion of this training a formalized Health Physics technician training program will be developed for inclusion in the RPis on or about July l, 197 This item will remain unresolved pending. review of this area in a subsequent inspectio (79-07-04)
- Organization The inspector reviewed the organization and qualification of personnel against::the following requirements and guidance:
Technical Specification Fina 1 Sa.f ety Ana 1 ysi s Report *
. (FSAR) Chapter 1 Regulatory Gui de (RG) 8. 8..
Regulatory Guide (RG) Organization Organization and Responsibili:ty Information Relevant to Ensuring that Occupational Radiation Expo-sure. Wi 11 Be as Low as Reasonabl Achievab11 Personnel Sel~ttion and Trainin *
The inspector observed that the Performance Supervisor, Health Physics and Chemistry (designated as the Radiation Protection Manager (RPM) as defined in RG 1.8) is responsible for directing activities in the implementation of the h.ealth physics program and the performance of all chemical analyis
a-s-s1Jc-i-a-ted-w'i-t-h-pla-nt--eper--a-t-i-e-n,-aeeer-d-i-ng-to-~AR-,-Chapte~l2-.-2~ O~gantzatj on and Responsibility. This is in the line with the description of the RPM as presented in RG 8.8, which indicates, that to be effective, the RPM is to
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be independent of station divisions (such as operations, maintenance or technical support} whose prime responsibility is continuity or improvement of station operabilit It was noted that contrary to the guidance provided in RG 8.8 the following responsibilities have also been assigned to the RPM at Salem, in addition to his HP Chemistry functions: Operation and Performance of Make-up Demineralizer System Operation and Performance of the Water Chlorination System Operation and Performance of the Water Treatment Clarifier System Operation and Performance of Condensate Polishers Operation and Performance of Non-Rad Waste System Operation and Performance of Sewage Treatment Plant Observations by the inspector indicated that the RPM cannot devote his full time and attention to the area of Health Physics and Chemistry due to dilution of this primary responsibility with non-radiation protection related duties. Accordingly, his staff is also involved with other non-radiation protection activitie The inspector noted that since the RPM has an important safety function, it was possible the effectiveness of the Health Physics program could be diluted by adding on non-related, time consuming responsibilities which are mainly concerned with the station 1 s continuity and operabilit Though it has been observed that these other responsibilities given to the RPM do not appear to have compromised the effectiveness of the radiation protection program for single unit operation. the operation of the second unit would demand more time and attention"or.the,RPM and therefore have the po ten ti a 1 to compromise the * effecti venes*s -of the -progra The inspector indicated that this item would remain unresolved pendi_ng fur-ther review of this are (79-07-05)
9 *unresolved Items Unresolved items are matters about which more information is required
in-order-to-a-scerta-tn-whether-they-are-accepta-b-le-i-tems-,-items-or--------
noncomp l i ance, or deviation Unresolved items disclosed during the inspection are discussed in Details 5 and.
Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on February 9, 197 The inspector summarized the scope and findings of the inspection as noted in this report.