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IE Health Physics Appraisal Rept 50-272/80-03.Noncompliance Noted:Inordinate Reliance on Contracted Personnel,Lack of Technical Proficiency Among Staff & Weaknesses in Emergency Plan Procedures
	ML18085A345
Person / Time
Site:	Salem
Issue date:	05/16/1980
From:	Donaldson D, Greger R, Hosey C, Galen Smith, Jason White; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML18085A339	List: IR 05000272/1980003; ML18085A338; ML18085A340; ML18085A341; ML18085A342; ML18085A343;
References
	50-272-80-03, 50-272-80-3, NUDOCS 8012080195
	Download: ML18085A345 (74)
	v • d • e

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Report N Docket N.

License N OPR-70

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U.S. NUCLEAR. REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Health Physics Appraisal Program Priority ------

.Category Licensee; Public Service Electric and Gas Company (PSE&G)

80 Park Place Newark., New Jersey 07101 i=aciHty Name:

Salem Nuclear Generating Station, Unit *1 (SNGS)

c

Appraisal at:

New Jersey; PSE&G Corporate Offices in

. Appraisal 1980 I

Team Members: NRC (Team

'aaesfgned NRC date signed r,tf,4 NRC date signed Batte1le s-fa/p date signed Battelle datesigned date signed date signed

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Approved by:

and date signeo sfaft6 date'signed so 12 oso/95,

CONTENTS Summary Radiation Protection Organization 1.1 Description 1.2 'scope of Responsibilities 1.3 Staffing Personnel Selection Qualification and Training 2.1 Selection Criteria.2 Qualification Criteria 2.3 Training Program 2. General Radiation Protection 2. Contractor Training - Health Physics Personnel Exposure Control and ALARA Implementation 3.1 External Exposure Control 3.1.1. Dosimetry Program 3.1.2 Quality Assurance 3.1.3 Exposure Review 3.1.4 Barri!:;!rs 3.1.4.1 Administrative 3.1.4.2 Physical 3.2 Internal Exposure Controls 3.2.1 Dosimetry Program 3.2.2 Quality Assurance 3.2.3 Exposure Review

ii 3.2.4 Barriers 3.2.4.1 Administrative

3.2.4.2 Physical 3.3 Surveillance Program 3.3.1 Scope

. 3.3.2 Instrument Availability 3.4 Radioactive Waste Management 3.4.1 Liquid 3.4.2 Gaseous 3.4.3 Solid Facilities and Equipment 4.1 Facilities 4.1.1 Radiation Protection 4.1.2 Chemistry 4.1.3 Radioactive Waste 4.2 Equipment 4.2.1 Protective 4.2.2 Instrumentation Emergency Plan Administration Organizational Control of Emergencies 6.1 Onsite Organization 6.2 Augmentation Emergency Plan Training

iii 8. 0 Emergency Faci 1 i ti es and Equipment *

8.1 Emergency Kits and Emergency Survey Instrumentation 8.2.Fixed Facilities and Instrumentation 8.3 Emergency Communication Equipment 8.4 Emergency Operations Center 8.5 Medical Treatment Facilities 8.6 Decontamination Facilities 8.7 Protective Facilities and Equipment 8.8 Damage Control and Corrective Action 8. 9 Reserve Supplies and Equipment.

8. 10 Expanded Support Facilities 9. 0 Procedures for Implementation of Emergency Pl an 9.1 Format 9.2 Implementing Instructions 9.3 Implementing Procedures 9.4 Supplementary Procedures 10.0 Management Oversigh ANNEX A ANNEX B ANNEX C ANNEXES Exit Meeting and Licensee Commitments Persons Contacted Documents Reviewed

SUMMARY The Health Physics Program at Salem Nuclear Generating Station (SNGS) is cur~

rently in a state of transition. The existfog program is deficient in several areas, particularly in re.gards to an inordinate reliance on contracted heal th physics services, lack of a comprehensive training program to assure proficiency in health physics technicians, lack of a viable alternate to the Ra.diation Protection Manager, as well as failure to fully implement NRC directives as specified in NUREG-0578, 11TMI Lessons Learned... Short Term Recommendations.

The deficiencies noted have a bearing on the licensee's ability to effectively manage the increased responsibility accompanying the operation of a second uni The licensee has.initiated several actions designed to upgrade the performance of the Radiation Protection Program and to resolve the discrepancies noted by this appraisa Some long-term corrections that effect his performance will be factored into Labor-Mana.gement negotiations that are currently underwa The portion of the health physics audit covering emergency plannfog involved five general areas:

Emergency Faci 1 i ti es and Equipment Emergency Plan Implementfog Procedures Organizational Control of Emergencies Management Controls for Maintaining Response Readiness The results of the audit indicate that the station staff and contractors have identified many shortcomings in the existing program and have developed con-ceptual solutions to resolve these shortcoming Little has been done, however, to carry these changes to implementatio Of particular concern is that even the most critical *shortcomings were not being vigorously attacke This 11wait and see 11 posture has understandably and predictably evolved due to the far reaching actions of the NRC Task Force on Emergency Plannin Despite this, there are areas in the emergency planning program which must constantly be attended to and a wait-and-see attitude is inappropriate, particularly at an operating facilit In light of these considerations, there are three general areas of the current emergency planning program which necessitate immediate attention to ensure that a response of reasonable effectiveness would result iri the event of a serious emergency at the Salem Nuclear Generating Station. These areas are: the emergency *organization; training; and procedure Major organizational changes in the program are being considered and plans are expected to be developed to better prepare the program to deal with the radio-logical hazards that are prevalent in normal operation as well as off-normal and emergency condition *

RADIATION PROTECTION (HEALTH PHYSICS) ORGANIZATION 1.1 Description The present organization in place at the Salem Nuclear Generating Station is depicted in Figure 1. This is an* amendment to the organi-zational structure shown in the current Technical Specifications (Figure 2). A request for amendment of the Technical Specification was filed on January 28, 1980 to split the duties previously assigned to the Senior Performance Supervisor - Chemistry/Health Pbysics (HP), between two individuals, i.e., Senior Performance Supervisor - Radiation Pro-tection and Senior Performance Supervisor-Chemistr The former is the designated Radiation Protection Manager (RPM) for the facilit This action was completed in response to a previous inspection finding (IE Report 272/79-07) which noted that.the Senior Performance Supervisor -

Chemistry/HP could not adequately devote his attention to radiation protection matters due to his involvement in other production related activities; and as a result the licensee's evaluation of the Radiation Protection Program in the wake of the Three Mile Island experienc In the organizational structure depicted in Figure 1, the Health Physics (HP) activity is under the managerial control of the Station Performance Engineer who is also the prime responsible manager of the Instrument and Control (I&C), and Chemistry (Chem) organizations. It was noted that there is a di_stinct similarity between the Station Performance structure and responsibilities at the Salem plant, and eight fossil. fuel plants also

operated by PSE& The Salem Station Performance Engineer is responsible for the following activities:

1)

Unit Performance Testing; 2)

Routine Station Reports; 3)

Plant* Water Chemistry;

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4)

Demineralized Water Plant Operation; 5)

Control of Environmental Releases; 6)

Calibration and Maintenance of All Instruments and Controls; and 7)

Radiation Protection The Radiation Protection aspect of the Performance Department respon-sibility is essentially an appendix to what would normally be under the management of the Performance Engineer at any of PSE&G's conven-tional ~tations, and, in the case of Salem, appears to be regarded as adjunctive to the operation of the station; i.e., an activity that is appended to, but not an essential part of the station's operation.

Figure 1 Amend~d organization depicted in Technical Spe~ification change:*ls mitte January 28, 1980 i:*...

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M~nas., *

Sal em "Generating Station Sr. Performance Supv. - Instrumen-tation and Control

Instrument Supervisors Technicians Sta ti on Performance Engineer Sr. Performance Sup Chemistry Technical Supervisors Technicians Nuclear Technical 1 Assistants Sr. Performance Sup Radiation Protec-tion Technical Supervisors Technicians Nuclear I

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Figure 2 Organization as depicted Manag*er Salem Generating Station Sta ti on Performan e Engineer

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Specification

sr. Performance Supv.~Instrumenta tion and Control Sr. Performance Supv, Chemistry and Heal th Physics Instrument Supervisors Technicians Technic'al Assistants Technical Supervisors Technicians Nuclear

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1.2 Scope of Responsibilities and Authorities Observations during this period of review indicated that the Senior Performance Supervisor-Radiation Protection provided adequate direct contact and oversight of the Radiation Protection functio The in-dividual was aware of the general status of the program and the status of in-plant activities affecting the progra Information feedback, although not a formalized system, appeared ade-quate enough for the progra*m to functio The Radiation Protection Program's authority, management reporting chain, and scope of respons.ibil ities are documented in the Station Administrative Procedure, AP-24, "Radiological Safety Program", Revision This document does not, however, des.cribe the current program being implemente The Radiation Protection Program within the last six months has been in a transitory stage primarily due to the correc-tion of deficiencies identified in internal audits by the Station Quality Assurance group, and appraisal by management of the Performance Department. Major problem areas identified included:

(1) inability of the current organizational structure to efficiently provide job experience and training (sufficient to meet the requirements of ANSI-N18. L-1971, "Selection and Training of Nuclear Power Plant Personnel") to personnel intended to fill technician level positions in the radiation protection group as well as chemistry and I&C; (2)

lack of a formal comprehensive training program to assure adequate technical proficiency in techni&ian specialty areas, i.e., radia-tion protection; chemistry and I&C;

(3)

administrative difficulties in the Performance Department in providing effective management oversight for the specialty areas of Chemisty, I&C, and Radiation Protection due to the diverse nature and specialization required in each program; (.4)

inherent program inflexibility, particularly in the Radiation Protection area, due to technician job specifications and func-tional descriptions contained in the current union/management agreement that fail to recognize specialization attributes for technician The recognition of these weaknesses by the Performance Department has resulted in the initiation of changes in many program areas, parti-cularly, procedure development and revisions to emergency planning, personnel training, organizational structure, and nianpower allocatio.1

Due to these changes already underway, AP-24 is being revised to re-flect station po.. licy, organization and responsibilities regarding Radiation Safety. Other implementing documents which are also under-going revision are the Performance Department Manual (a delineation of administrative functions, policies, responsibilities and instructions)

and the Radiation Protection Manual (detailed description of the Radi-ation Safety program).

Procedures for direct radiation protection implem~ntation are contained in the Radiation Protection Instructions, and are also being subjected to further development and revisio The. adequacy of these efforts is contingent upon support and approval

. of PSE&G corporate management which, up to this time, has not been expresse From the foregoing observations it was concluded that, at the station level, there has been a recognition of the program deficiencies af-fecting the area of radiation protection, and the development and imple.mentation of plans for resolving these deficiencie The ability of the organization as it stands at the present time is questionable in regard to its technical competence and capabilit Twenty-four hour shift coverage is maintained by both contractor and station personnel. A Technician - Nuclear (TN) is supposedly given the responsibility for health physics coverage on the backshift Conceptually this appears adequate, however, in actuality TNs have no direct involvement in normal in-plant health physics activitie On the backshift the TN usually works in the Chemistry function or in the counting room, and is generally not current with the radiological status of the plant rir jobs in-progress. These activities are left to the contractors. Contrary to the licensee 1 s intentions, it is generally the contractors, not the TN that pro vi des backs hi ft hea 1th physics cover*

ag In terms of functi.ona 1 responsibility, contractors provide the entire range of technical and administrative support for the Radiation Pro-t~ction program, including the management of solid radioactive waste, HP techniCian training, *procedure *development, emergency planning, and administrative and clerical suppor In addition the entire in-plant operational health physics activity (responsible for radiological surveys, direct coverage of personnel performing work in the radio-logically controlled area, and the determination and identification of the radiological status of the controlled area) is supervised and

.performed by contractor *

The same is true for Radiation Exposure Permit (REP) planning. Contractor personnel are responsible for planning and evaluating the radiation protection techniques used to perform work in radiologically controlled areas, including ALARA consideration *

Contractors also provide all personnel required for whole body counting and portable instrumentation calibration and maintenanc The direct involvement of PSE&G 1 s personnel in the radiation protection pr_ogram (accepting direct management from the Senior Performance Supervisor) is limited to dosimetry, records maintenance, operation of counting equipment, and the respiratory protection progra Even in these areas, contractors provide up to 50% of the manpower requirement From the interviews with several licensee personnel, the Radiation Protection Group conceptionally does have adequate authority tq con-trol activities on-site. However, the Radiation Protection Group is not currently recognized in the site emergency plan and does not have clearly defined responsibilities for such an even If an emergency had occurred during this assessment, the group would make an effort to align itself in the recognized emergency organization on a 11ad hoc

basi Certainly its e*ffectiveness would be compromised as confusion regarding responsibilities and reporting chain would likely occu This particular item is further discussed in Section 6.0, Organi-zational Control Of Emergencie The Senior Performance Supervisor - Radiation Protection reports to the Station Performance Engineer, Performance Department (Figure 1).

While Instrument and Control, and Chemistry are well-suited to alignment with the Performance Department responsibilities because of the pro-duction-oriented aspeGt of those activities, the same is not true of Radiation Protectio By its nature, it is safety-related and respon-sible to both management and employees, and is a very specialized area with a scope and responsibility much diverse from the other activities in the Performance Departmen As such, it should be independent from production division The proposed reorganization of the Performance Department recognizes this management problem but does not provide adequate resolution. It is recommended that this area be evaluated and revised as necessary to assure that the Radiation Protection group is independent of organ-izations that have direct production responsibilitie.3 Staffing Figure 3 represents a staff commitment of approximately 55 peopl Tho.ugh a major improvement over the previous structure, particularly in the recognition of the need for specialized management of crucial aspects of the program; the need for technical and administration support, and for manpower resources sufficient for a two unit opera-tion; it is not a true reflection of the PSE&G management team 1s commitment to the Radiation Protection aspects of the stations operation.

~S-_P~ Service Employee

\\ :.actor Employee

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Technical Sup Records 1-PS I

Dosimetry &

Records

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13-PS 3-CON Whole Body Counting I-l-CON Counting Room I-2-PS (~*.

Figure 3 '..

ed Radiation Protection Organization Sr, Perfor~ance Sup Radiation Protection

________ J_=_es _____ ~--

Radwas te Co-ordinator l

l Rad Waste Assistant l-CON Training

Administra.:..

Co-ordinator tive Assis CON 3-CON Procedures Co-ordinato ~

1-CON Technical Sup Radiation Exposure P.lanni ng l-CON I

Technicians 2-CON Technical Su Equipment l-PS Respiratory Protection i-2-PS 1-CON nstruments 2-CON Co.nsumab l es 1-CON

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I Technical Sup Operations

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l-CON

Technician

.*Crew l..

4-CON Technkian Crew 2

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4-CON Technician

.Crew i-..._

4-CON Technicia Crew 4 lo-4-CON Technician Crew 5

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3-CON

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The actual. PSE&G commitment of personnel resources to the radiation protection organization includes one Senior Performance Supervisor -

Radiation Protection; two Technical Supervisors, four qualified Techni-cians - Nuclear.(TN),"and about five Technical Assistants (TAs) who are not dedicated to any particular activity in the Performance De-partmen TNs rotate assignment b.etween Chemistry and Radi~tion Protection; and the TAs rotate assignment between I&C, Chemistry and Radiation Protectio The result is about twelve people to support an anticipated two unit operatio The rest of the personnel are contrac-tor supplied radiation protection personne Of a staff of approximately 55 people, 80% are contractors. This inordinately heavy reliance on contractor personnel for normal ope-rations would obviously carry over to off-normal or emergency condi-tions where contractors would provide the primary manpower resourc Contractor personnel are used normally to supplement.or augment the existing radiation protection staff in off-normal situations, e.g.,

outage* In the case of Salem, contract personnel essentially are the radiation protection staf While *contractor personnel may be as technically qualified and capable as PSE&G's own personnel, inordinate reliance on personnel who may not be familiar with the stations design, characteristics and procedures, and who are subject to continual turn-over (the majority of contract technicians are at Salem for only six months) is undesirabl Addi-tionally, though contractor personnel are responsible for the most s*ubstantive elements of the program, they are not subjected.to any specialized training or retraining to maintain proficiency in the health physics specialty (See Section 2.0, Personnel, Selection, Qualification and Training).

There appears to be adequate numbers. of personnel {predominately con-tractors) in the Radiation Protection organization to maintain normal operations for a single unit facility. *Operation of additional units may require additional staffin At this time, essentially all of the technical and managerial expertise in the area of radiation protection is vested in one individual avail-able on-site, the Senior Performance Supervisor - Radiation Protectio There is no planned back-up capability for this individua In the case of prolonged absence, his responsibilities would fall to signifi-cantly less qualified individuals who would be unable to effectively administer this area.

' 6 Alternate personnel, outside of the Radiation Protection organization, that the licensee might consider, are not being developed in any manner to assure that they are current with the program's status, the radiological plant status, or the administrative functioning of the organizatio *

In response to this concern, the licensee has committed to developing an individual to act as alternate for the RPM in his absenc To this end, the Corporate Health Physicist will be the interim back-up to the RPM, with an established plan to maintain a sufficient knowledge of the program and the plant's status to enable him to function effect-ively if require *

2.0 Personnel Selection, ~ualification and Training 2.1 Selection Criteria The only selection criteria formally applied are specified in ANSI-*

Nl8.1-1971, "Selection and Training of Nuclear Power Plant Personnel."

In the case of technicians, it is this selection criterion (2 years of related experience) that is applied to both PSE&G and RSI to select perso.nnel for" responsible positions. However, currently this selection criterion, i.e., a person having 2 years previous experience in the Health Physics specialty is also generally presumed to be qualified as a Health Physics technicia *

This is particularly true in the case of contractor personnel who are not subjected to any training or retraining in their specialty as in plant specific areas such as plant system.2 Qualification Criteria The only formal standard applied to the qualification of personnel i ANSI-N18.l-1971, "Selection and *Training of Nuclear Power Plant Per-sonnel."

Due to the licensee's method of developing personnel, parti-cularly technicians, the required application of this standard has led to the current situation of inordinate reliance on contractor.personne The current program attempts to qualify and train technicians so that they are capable of performing activities in Instrument and Control, Chemistry and Health Physic The development of proficiency in Hea.lth Physics technicians is further confounded by continuously rotating the personnel among all three specialties as in the case of Technical Assistants, and among the Chemistry and Health Physics specialties as in the case of Techni~ians-Nuclear. The result of this attempt to cross-train technicians is that personnel are not afforded sufficient time and experience to appreciate and develop the technical skills necessary to perform in a responsible position. This has led to the inability to promote within the organization (because of a lack of personnel meetfog the minimum selection criteria), and has there-fore forced the licensee to seek the required technician support for its Radiation Protection Program from contract organization As previously mentioned, contractor personnel provfde as much as 80% of the program requirement The licensee's failure to develop and implement a technician retraining program to assure that the technicians* skill and level of knowledge is maintained satisfactorily also contributes to overall lack of tech-nical proficiency of personnel.* Though some type of retraining has

been performed, it was done w.ithout reviewable lesson plans, form-alized procedures, or training documentatio Currently, another retraining session is being performed, but again lesson plans, training procedures and traini_ng documentation have yet to be develope.3 Training 2. 3. 1 Genera.l Radiation Protection The licensee 1s general radiation protection training for all employees and radiation *workers was reviewe All employees receive a lecture training session on radiation protection, along with lectures on the

station 1s emergency plan and security system, as part of the General Employee Indoctrination. This indoctrination lasts one day for those completely unfamiliar with station procedures and radiation protection principle For experienced personnel, some portions may be deleted with permission of the Senior Performance Supervisor-Radiation Pro-tection; however passing of qualifying tests may still be require For those to be designated as radiation workers with unescorted access to the controlled area, a two-day course entitled Radiation Protection-

! is required with a passing grade on the final tes After review of the current lesson plan and course handout for the radiation protection po~tion of the General Employee Indoctrination.

and after receiving an abbreviated version on entering the plant, this training was foun*d to be adequate for i ndi vi duals not working in, or just occasionally frequenting, the controlled area The Radiation Protection-I training was reviewed by attendance at *the second of the two-day lecture series, review of the course handout, and an interview with station employees chosen from the security force, who had recently (November 1979) taken the course and had no previous radiation worker experience. This course appeared adequate as initial training for an inexperienced radiation worker. Several weaknesses were noted, however:

1)

The origins of the radioactive materials in the plant operations are not well explained (i~e., fission products from fuel; activa-tion products from primary systems).

2)

Some outdated or inaccurate information on plant procedures was presented (i.e., old REP/EREP procedures and exposure card pro-cedures were presented).

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3)

The distinction between dose rate and accumulated dose was weakly presente It was made specific for reading dosimeters, but not as a general principl *

. 4)

The requirement of 10 CFR 19.12 that workers "shall be instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licensees or unnecessary exposure to radiation or radioactive material" was not addresse.3.2 Contractor Training - Health Physics Personnel From interviews with representatives from the Health Physics contractor organization (RSI) and the licensee's representatives it was learned that contracted Health Physics technicians are not subjected to any type of formalized training in their specialty or in plant system Additionally, a review of the contract organization records indicated that the average length of time that contract personnel are at Salem is about six month This affords the individual little time to become familiar with the facility and results in a near constant turn-over of personne The result is that the majority of the elements in the SALEM HP program is being implemented by personnel who are not formally trained (or retrained) in HP and who have limited experience and familiarization with the facility. The licensee exercises very little control over the quality of contractor personnel except for those who are placed in responsible positions (for which only 2 years of previous experience is required).

3.0 Exposure Control and ALARA Implementation 3.1 External Exposure Control 3.1.1 Dosimetry Pr.ogram

The 1 icensee uses an in-house Harshaw thermo luminescent dosimeter (TLD) system in conjunction with direct-reading pocket dosimeters to evaluate external exposure.. The TLD system includes a. twci chip LiF-700 TLD badge; a Harshaw model 2271 automated personnel. monitoring TLD system,. consisting of a dosimeter identifier, card loader, card reader, Sr-90 calibrator; a model 20008 Automatic Integrating Picoammeter; a teletype; and Univac 1110 compute *

The TLD badge contains two LiF-700 chip One chip has a cadmium shield and is used to evaluate exposure from gamma rays, and the second chip is essentially unshielded and is used to evaluate exposure from gamma rays and beta particles. Beta dose equivalent is deter-mined by subtracting the response of the shielded chip from the re-sponse of the unshielded chip (the licensee equates roentgen and rem).

Extremity exposure is evaluated through the use of special TLDs, as outlined in Health Procedure PD-15.3.021, "Special Personnel Monitor-ing.11 Neutron exposure is determined with a Landauer 11neutrak 11 syste Portable neutr:.().n. instrumentation includi.ng the PNR-4 11 rem ball 11 and AN/PDR-70 11snoopy 11 are also available to assist in neutron exposure evaluatio The routine dosimetry program is inadequate in the area of control of pocket dosimeter Dosfmetry procedures* do not exist to ensure control of these dosimeter Such procedures are a necessity since approximately 400 pocket dosimeters were lost or damaged during the licensee's last out.ag Additionally, procedures delineating the dosimetry program during emergency conditions do not exist. Considerations with respect to backup systems, alternate offsite facilities, and logistics should be made and the results incorporated into the procedures prepared for these area.1.2 Quality Assurance The Quality Assurance (QA) program that the licensee conducts on the Harshaw TLD badge is adequat It is noted that external exposure is being slightly overestimated due to no correction for fading of the TLO chips being made by the licensee. (The auditors noted that the pre-heat cycle which the licensee possesses and intends to use will minimize this overestimate.)

QA procedures do not exist for the recently adopted 11neutrak 11 neutron TLD syste Such procedures should include a review frequency as well as appropriate acceptance criteria. Suitable acceptance criteria exist in ANSI Nl3.ll, 11Criteria for Testing Personnel Dosimetry Performance 11, not only for neutron irradiation but a.lso for beta and gamma irradiation (independently and in mixed fields). The licensee

. does not appear to be considering the guidance which is available in Regulatory Guide 8.14, "Personnel Neutron Dosimeters.

It is recognized that the licensee participated in the University of Michigan intercalibration study; participation in intercalibrati'on studies should continu However, records indicating the results of the licensee's participation were not available for review at the site, but were instead located at the corporate office From inter-views with management who were responsible for the station 1s program, it was apparent that the results of these tests, and the licensee's own performance were not made available to them, and therefore they were unaware of the capabilities of their dosimetry progra.1.3 Exposure Review External exposure is measured in two ways simul~aneously: 1) daily, by self-reading pocket dosimeter, and.2) biweekly, by TL Exposure information from both systems is placed on the Univac 1110 computer in the program file entitled, 11Personnel Radiation Exposure Monitoring System" (PREMS).

Several programs have been written to store exposure information* in a variety of ways, which allows for cross-reference capabilit External exposure information is disseminated on a daily basis in the form of computer printouts. The printouts are distributed to appro-priate department heads, and a listi.ng of all personnel is maintained by the health physics grou Exposure review is thus performed not only by the respective department heads but also by health physic Exposure information is being compiled on each RWP issued, which allows an evaluation of exposure expended versus job function. This information can be used to supplement and strengthen the licensee's ALARA progra Heal th Physics procedures PD-15. 1. 012, 11 Past Opera ti on Debriefing,

and PD-15.3.014, 11Alert System for Personnel Exposure Control, 11 describe additional exposure review programs and their implementation.

3.1.4 Barriers 3.1.4.1 Administrative Station administrative control limits on external exposure are con-tained in AP-24, 11 Radiol_ogical Safety Progra The control 1 imi t is 100 mrem per week under normaloperating conditions. A blanket exten-sion of a 11 pl.ant personne 1 to 300 mrem per week was made by p 1 ant *

management in order to accommodate the last outag As of the time of the appraisal, some four weeks after the end of the outage, the extension

- had not been withdraw However, personnel exposures in this period usually were less than 100 mrem/per wee The licensee's representative indicated that this ~dministrative limit was under review to determine if the limit could be rese The weakness of the administrative control program is also manifested in the lack of any health physics representation on the station's outage planning grou Such representation is necessary so that radiation work *can be planned ahead to assure conformance with admin-istrative controls and the reduction of exposures to levels as low as reasonably achievable. Steps should be taken immediately to secure and maintain health physics representation on this important grou.1.4.2 Physical The auditor reviewed the licensee's posting and control of radiation areas, 'high radiation areas, radioactive material areas, and the l abe 11 i n*g of radioact.i ve materi a 1 during tours of the p 1 an CFR 20.203(f) requires that each container of licensed material bear a durable, clearly visible label identifying the radioactive contents and providing sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof to take pre.cautions to avoid or minimize exposures. During a tour of the plant; numerous yellow bags of radioactive material were found stored in various areas of the unit one auxiliary buildin The highest radiation level on the bags that were surveyed by the auditor was 4 mR/hr on contact with the ba The material was not labelled as radioactive material and did not meet any of the exemptions presented in 10 CFR 20.203(f)(3). Although licensee representatives stated that yellow bags were used only ior radioactive material, during a tour of the plant one licensee representative pointed out some clean material that was in a yell ow ba Station Procedure AP-24 states that yell ow bags shall only be use*d for radioactive materia The explanation provided was there were no other bags available so yellow bags were used for clean and radioactive materia The auditor stated that

failure to label containers of radioactive material with a clearly visible label identifying the radioactive contents and providing the additional information required was in noncompliance with 10 CFR 20.203(f). (272/80-03-01)

10 CFR 20.203(a)(2) states that the licensee may provide on or near radiological warning signs additional information which may be appro-priate in aiding individuals to minimize exposure to radiatioD or to radioactive materia During tours of the plant~ the auditor noted that the licensee does not have radiation/contamination levels posted

on or near radiological warning signs. A licensee representative stated that the station relies on the briefing of the worker prior to beginning work each day to make him aware of the radiological hazards in the work are However, discussions with station workers indicate that briefings are not given for entries made on Extended Radiation Exposure Permits (EREP).

Access to radiation, high radiation and con-tamination areas are permitted for entries covered by an ERE During one day, 80% of the entries into the Auxiliary Building were made using an ERE Although licensee representatives stated that workers should receive a briefing prior to the first entry of the day, no system is established at the REP desk to ensure that a worker has received the required briefin.2 Internal Exposure Controls

3.2.1 Dosimetry Program

The dosimetry program for assessing internal exposures consists of whole body counting and urinalysis. The licensee is currently using a shadow shield whole-body counter supplied and administered by a contractor. The licensee intends to purchase a chair-type counter equipped with three sodium iodide (Na!) detectors and assume control of the whole-body counting program from the contractor when the new system becomes functiona Appropriate procedures for using the new system and evaluating the results obtained are still being develope Plant procedures governing whole-body counting are deficient in that they fail to require who.le-body counts for n*ew hires and persons ter-minating work at the statio In the event an individual sustains an intake* of radioactive material at this facility, data (i.e. incoming baseline and termination whole-body counts) would be necessary to evaluate the intake and determine if in fact the exposure had occurred at this facility. Therefore, entrance and exit whole-body counts are necessary to evaluate any internal deposition of radioactive material and the resultant dose, particularly for those individuals frequenting the controlled areas of the facilit The licensee's urinalysis program exhibited similar shortcoming Plant procedures do not spedfy criteria for collection methods, ana-lysis of results, or action levels. This, as well as other site-specific information, are vital to the establishment of an adequate urinalysis p~ogra *

Provisions for operation of the exposure control system in off-normal or emergency conditions are deficient in that procedures detailing the off-normal operation of the system have not been established. These procedures should be developed in sufficient detail to ensure that adequate exposure control services and staff are available during emergencies. Such factors as alternate sites, movement of exposure control equipment, augmentatfon by off-site agencies, special controls, personnel accountability, and other changes necessitated by changed and unusual conditions should be considere Further discussion of this area is conta.inined in Section 6.0, 110rganizational Control of Emergencies, 11 and Section 9.0, 11Emergency Plan Implementing Procedures.

In discussing the evaluation of the dosimetry program with licensee personnel the auditor stressed the need to consider the requirements and.recommendations of ANSI N343, 11American National Standard for Internal Dosimetry for Mixed Fission and Activation Products, 11 in establishing an adequate internal dosimetry progra.2.2 Quality Assurance A calibration of the whole-body counting system performed by con-tractor personnel was observed. The co.ntractor procedures were found to be adequate to ensure that an acceptable calibration is performed and included the use of NBS-traceable sources and phantom The requirements and recommendations of ANSI N343 with respect to cali-bration are being me In addition to calibrations as noted above, daily checks of system performance are made and are adequate to ensure the maintenance of the whole-body counting syste.2.3 Exposure Review Procedures for review of internal exposure do not exis As currently practiced, exposure review is performed initially by the contractor technicians in charge of the whole-body counting syste Bioassay results are forwarded to the.records section for inclusion in the individual 1 s fil Health Physics procedure PD-15.11.009, 11Bioassay Program

, should be amended to include a formal exposure review syste (272/80-03-02)

.

3.2.4 Barriers The auditors reviewed the licensee measures to control and/or reduce internal exposure In this regard administrative and physical bar-riers were considere *

3.2.4.1 Administrative The 1 icensee.' s posting and control of airborne radioactivity and contamination areas *and general housekeeping during plant tours was reviewe During these tours, it was noted that the licensee did not have contamination levels posted on or near warning signs to aid individuals in minimizing exposure as required by 10 CFR 20.203{a).

A licensee representative stated that reliance is placed on the brief-ing of a.worker *prior to the beginning of work each day to make him aware of the radiological hazards in the work area. Discussions with station workers, however, indicated that such briefings are not given to workers who make entries on Extended Radiation Exposure Permits

{EREPs), even though access to contaminated areas are permitted by an ERE It was determined that there was no system established at the REP desk to ensure that workers receive the required briefin During the tours of the Unit 1 auxiliary building, it was also noted that general housekeeping was poo As an example, anti-contamination clothing, tools and equipment, polyethelene bags and paper were scat-tered abou It appeared that the space behind the Boric Acid Evaporator Pond was being used as a trash receptable. It was noted that poor housekeeping will compound the problem of contamination/control and may even be a potential fire hazar.2.4.2 Physical By review of records, observations, and discussions with licensee representatives, the auditor evaluated the licensee's respiratory protection program including air sampling, engineering controls, MPC-hour controls, medical qu~lification, traini~g, mairitenance and issue controls for respirator The licensee currently uses respiratory protective equipment to limit the inhalation of airborne radioactive material, however, they do not take credit for the use of such equipment when estimating exposures of individuals. Credit is not taken for respiratory protection devices because the respiratory protection program does not meet the require-ments for an acceptable program specified in 10 CFR 20.103(c) and Regulatory Guide 8.1 *

Although the licensee committed to having an acceptable respiratory protection program that met the requirements of Regulatory Guide 8.15 prior to the *1ast Unit 1 refueling outage, action on this commitment still has not been complete The records used to identify workers qualified to wear respirators contain errors and are incomplete *.

In reviewing the licensee's respiratory protection procedures, it was noted that 10 out of 25 written procedures are in various stages of preparation or review and the training received by workers requires considerable upgrading to be effective. Licensee management attention was directed to this area, with a recommendation to complete program imp 1 ementa tion *.

Specific deficiencies in the licensee's respiratory protection program were identified during the appraisal. Most of the deficiencies identified were attributable to a lack of a review of day-to-day operations of the program by the individual assigned responsibility for respiratory protec.tion and included failure of the individual assigned responsibility for the program to assume responsibility for the total respiratory protection progra The following deficiencies were noted:

On February 4, 1980, two contract health physics technicians were issued self-contained breathing apparatus (SCBA) for entry into Unit 1 containmen Upon review of the respiratory protection status sheet, which indicates the qualifications of individuals to wear respirators, the inspector noted that one of the individuals was not medically qualified to wear a respirato The daily computer listout of radiation exposure information also indicated the individual was not fully qualified to wear a respirato Although a copy of the technicians medical qualification was not in the licensee's files, a copy was obtained from the on-site coordinator for the contracto The auditor stated that the technician issuing the respirators must be able to rely on the status sheet or ~omputer listou Individuals who are not fully qualified should not be issued respirator To ensure that the issue records (status sheet/computer listout) are accurate, the 1 icensee should conduct a record-by-record verification of data and should institute appropriate quality control checks and supervisory reviews of changes to the lis An auditor survey of several respirators that had been cleaned and inspected and temporarily stored in the respirator maintenance room was mad The radioactive contamination levels on all respirators surveyed were less than the limits specified in station procedure PD-15.6.003, 11Respiratory Protective Equipment Cleaning and Disinfection

During this review, it was noted that the respirator inspection tags for the surveyed respirators had not been signed indicating the respirators had been inspected and found ready-for-issue. A licensee representative stated that to 11 get around 11 the requirement in station procedure PD-15.1.009, Res.piratory Protective Equipment Quality Assurance, to reinspect on a monthly basis all respirators awaiting reissue, respirators are cleaned, disinfected, surveyed and inspected, however, the inspection tag is not signe As respirators are needed, they are reinspe~ted and th~ inspection tag signe It was noted during the review of this area that no more than four respirators

17.

were observed to be in the issue room in a ready-for-issue statu In the event of an emergency requiring *res pi ra tory protection, an

~de*quate number of ready-for-issue respirators would not be immediately available. Respirators in thestorage bins should be inspected and made ready-for-issue. It was also noted tha respirators temporarily stored in the bins in the respiratory maintenance area were stacked four or five hig The auditor stated that NUREG 0041, Section 9.3 recommends that respirator be stored so.that they are not damaged by adjacent equipment or twi$ted out of their normal configuration. A licensee repre-

. sentative stated that the storage of respirators would be changed to fol low the recommendations of NUREG 004 The auditor observed a technician prepare the sodium chloride quantitative fit test booth for use and underwent a fit tes The auditor ascertained that technicians were temporarily as-signed to perform fit tests as a collateral duty and that the records were being filed without an independent review of the test results by the individual responsible for the respiratory protection program or another technically qualified individua The auditor stated that the test *results should be reviewed by a technically competent individual for accuracy and adherence to procedures, and s_i gned by the reviewer before fi 1 in The auditor attended the respiratory protection phase of the radiation protection training (RP-1) received by new employees and visitors on January 30, 198 The training received did not cover the basic material recommended in NUREG 0041, nor did it cover the material required by Station Procedure PD-15.2.003,

"Respiratory Protection Training and Fit Testing.

During the presentation on January 30, approximately twenty minutes were devoted to respiratory protection trainin The following areas were not discussed during the training: construction, operating principles and limitations of the respirator and selection of the respirator which is the proper type for a particular purpose, reasons for usi_ng respirators and explanations of why more positive controls are not used, procedures for insuri_ng that the respirator is in proper working condition, checking respirator for adequacy of fit, practical (field) training in donning a respirator, and wearing it to develop confidence in ability to use the device properl *

In discussions with the auditor, licensee representatives stated that a detailed 9utline for respiratory protection had been provided to the station training group when they assumed respon-sibility. for that phase of the radiation protection trainin However, due to time restrictions, the amount of material covered was reduce The auditor stated that the respiratory protection training should be revised to include all the training recommended in chapter 8 ofNUREG 004 The auditor also noted that the instructor presenting the training was unable to answer specific technical questions from the audience concerning the progra The instructor should have a thorough knowledge of the *respir-atory protection program at the station. This could be obtained

.by having the instructors attend the training courses for health physici technicians in such areas as;. selection and use of respirators, maintenance, quantitative fit test, et The licensee does not presently have onsite combination charcoal/high efficiency filter cartridges for use with the Norton respirator to minimize the exposure of individuals to radioactive Iodine in the event of an acciden A licensee representative stated that the combination cartridges will be procure (272/80-03-03)

l

3.3 Surveillance Program The auditor reviewed selected records of radiation, contamination, and airborne radioactivity surveys performed between July 1979 and February 1980, discussed the survey results with licensee representatives, observed technicians performing various surveys and performed inde-pendent surveys of area The detai 1 and *frequency of surveys performed by the licensee appeared to be adequat However, the following defi ci enci es were noted:

No continuous air monitors with an alarm function were located on the 55' elevation or the 64' elevations of the Unit 1 aoxiliary building. A licensee representative stated that the station does

. not ha.ve enough continuous air samplers to locate samplers on the*

55' elevation and the 64' elevatio High airborne radioactivity detected in samples taken January 21, 1980, on the 64' elevation in the hallways outside the gas stripper pump room, would indicate a need to have continuous iamplers on this level as well as the 55' elevation. A review of the latest instrument and equipment inventory revealed that 9 air monitors were on hand and only five were in service, indicating a lack of available equipmen The auditor accompanied and observed a technician as he performed a routine loose surface contamination survey in the hallways of the auxiliary building, counted the smears and documented the survey. The auditor noted that the technician used 20% as the efficiency of the RM-14 count rate meter with HP-210 prob When questioned concerning the use of this efficiency, the technician stated that the efficiency of the instrument was 10-20%, however, he was instructed to use 20% to be conservativ The inspector checked the efficiency of four different RM-14/HP-210 instruments utilizing the 2 inch Cobalt-60 check source (S-104) that is used for calibration of the BC-4 counte The efficiency of the instruments were 15-16% when th~ source was held one quarter to one half inch away from the detector. This is the distance that several technicians stated was the smear-to-detector distance they used for evaluating smear The use of an efficiency of 20%

would result in a 33% *error in the non-conservative direction for smears evaluated using the RM-14/HP-210 instrumen The auditor stated that the actual efficiency of each RM-14/HP-210 instrument should be determined and that value used or an arbitrary efficiency that is conservative should be selected (e.g., 10%).

It was also noted that the RM-14/HP-210 instruments in the counting room are not response checked periodically to verify that they are functioning properl These instruments should be response checked prior to use and at least daily while in continual use in accordance with the guidelines established in ANSI N323-197. 20 The auditor reviewed the licensee methods for controlling work in radiologically controlled area The station implemented a new radiation exposure permit (REP) procedure (Station Procedure PD-15. 1.013) during this appraisal effort. Although the procedure is new, most workers and radiation protection personnel are at least familiar with how the system works. The following specific discre-pancies were noted in the control of work using the REP system:

The procedure requires that a copy of surveys (radiation and contamination) must be in the REP/EREP folder for review b¥ the worke It further requires that the survey be less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months old. Several entries were made on REP's on February 5, 1980, for which the survey in file was more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ol More current surveys were later found after the discrepancy was brought to the attention of the license Station Procedure PD-15.1.013 requires that workers obtain an authorization to work on a particular REP from their supervisor and to present this authorization to the REP desk prior to entering the restricted are A review of REP's on February 5, 1980, revealed that workers had signed in on a REP, however, the authorization slip was not in the REP fil The station procedure requires a prework and a post-work ALARA review of each REP issue Observations by the inspector and a review of completed REP's indicates that only a perfunctory review is performe Numerous REP's in file had the prework, post work or both sections blan The auditor stated that the individual assigned the responsibility in the radiation protection group for the review and issue of EREP's and REP's is devoting an excessive amount of his time performing administra-tive tasks, such as fili_ng routine Sl!rveys; task which could be performed by a clerk, rather than a health physic technicia A licensee representative stated that very rarely does the group which will perform the work meet with the REP reviewer and discuss the work to be performed and the necessary radiological controls which will be require The auditor stated that pre-REP discussions should be held as well as prework and post work briefings to be attended by the individual who will perform the work and the HP technicians who will provide radiation protection coverage for the wor During a discussion of station procedures with a licensee representa-tive the representative stated that maintenance and operations proce-dures do not routinely receive health physics review prior to issuanc The auditor commented that all procedures involvi_ng work on radioactively contaminated systems, handling of radioactive material or work in radiation areas should be reviewed by the radiation protection staff as far in advance of the work as possible. This review is necessary

to insure that adequate consideration is given to health physics aspects of the work, including staffing, availability of health phy-sics equipment and supplies," temporary shielding, engineering controls to minimize airborne radioactivity and to keep exposures ALAR Radiological survey records, from 1978 and 1979 which are permanent records that Technical Specifications require to be retained for the

life of the pl ant; are being stored in cardboard boxes in the REP roo A licensee represeritative said the station was in the process of microfilming.the records *. The auditor stated that survey records should b~ promptly delivered to document control for.retention and/or microfilming or they should be stored in fire-resistant cabinet The auditor observed personnel frisking themselves and using the portal monitors. There appears to be no consistency in how much of the individual's body is frisked, nor how much time is necessary to ensure that the contamination levels are below the limits established by the statio Some individuals frisked the entire body in 10-20 seconds, others frisked their hands and feet and still others frisked only their hand The auditor noted that RP-1 Training Course handout states the individual should frisk his entire bod The licensee should post signs at the exit to the controlled area, stating what parts of the body should be frisked and how long a satisfactory frisk.

should tak The licensee should also station a member of the health physics staff at the exit point periodically to observe personnel frisking practices as a method of ensuring that proper frisking practices are being use The auditor also noted that at shift change the control point for entry into the auxiliary building is so crowded that contaminated tools and equipment could be removed from the auxiliary building without detectio The auditor stated that the flow of traffic into and out of the auxiliary building should be S-2parated and exiting personnel kept under surveillance. *

At the request of the auditor, a licensee representative checked the alarm set point of RM-14/HP-210 personnel friskers at the control poin The alarm for one instrument was set at 300 cpm over back-ground and the other instrument was set at 400 cpm over backgroun Licensee representatives stated that the alarm set point should be 200 cpm over backgroun The auditor stated that*the equivalent count rate over background for 1000 dpm should be determined and this value used for the set point. Signs should also be placed on the instrument stating that the alarm set" points are not to be changed except by qualified radiation protection personne The response of the.friskers should be checked with a check source in accordance with the procedure specified in ANSI N323-1978 and the alarm set point verified prior to the first use and at least daily when in continuous us.4 Radioactive Waste Management 3.4.1 Liquid The licensee's installed liquid processing system consists of tanks and equipment for collecti_ng, transferring, treati_ng, monitoring, and

releasing radioactive liquids. Boric acid and radwaste evaporators are installed for processing the liquid waste before discharge to the Delaware River or reuse iri the plan Inleakage of brackish river water rendered the radwaste evaporator inoperable in 197 Since that time, mixed bed portable demineralizers (contractor provided)

have been used to process the liquid radwast The licensee was cited for failure to conduct a review, as required by 10 CFR 50.59, for use of the portable demineralizers in lieu of the installed radwaste. evap-orator during a previous inspection. A replacement radwaste evaporator is expected to be inplace and operational by the end of 198 According to licensee personnel, the primary water storage tank con-tinues to experience oxygen absorption problems which render the water undesirable for use in the primary syste Consequently, the deminer-al ized water tank is used as a source of makeup water instead of the primary water storage tan Demineralized water storage tank water typically contains* 0.05 ppm oxygen as compared with 0.5 ppm oxygen in primary water storage tank wate As a result of the oxygen problem, radwaste water is routinely discharged to the river after being processed through either the portable demineralizer or the boric acid evaporato Radioactive liquid releases are made on a batch basis, normally from the CVCS monitor tanks or the waste holdup monitor tan The installed waste monitor tanks are not normally used because of their small volum Liquid releases are quantified on the basis of pre-release and post-re-.

lease (composite) analyses. *A liquid release permit is used to provide*

management control over radioactive release In addition to providing authorization and documentation for the release, the release permit is used to determine the allowable release rate and the liquid effluent monitor setpoint. The auditors reviewed selected release permits for calendar year 197 No significant discrepancies were identifie Neither the technical specification limits nor the design objectives have been exceeded for liquid releases. This conclusion is based on a review of semiannual effluent report data, discussions with licensee personnel, and a selective review of 1979 discharge permit No signi-ficant discrepancies from the technical specification surveillance requirements were identifie The composite surveillance analyses are performed by a contract laboratory, which was audited by the license Steam generator blowdown liquid is also monitored and sampled for radio-activit No significant activity has been found in the blowdown re-lease At pr~sent, steam generator blowdown is released to the river after neutralization treatmen According to licensee personnel, a modification to route steam generator blowdown back to the condenser for reuse has been initiate The annual curie quantities of radioactive liquids releases for 1977, 1978 and 1979 were approximately 60%, 80% and 90%, respectively, of

('...

'*.. '

the five curie design object1v Liquid releases will increase with plant age unless further processing or reuse of radioactive liquids occur This matter was discussed at the exit intervie Although the volume and activity of liquid radioactive releases are not atypical for operating PWRs, a s.ignificant number of PWRs find it possible to operate with annual liquid releases totaling approximately 10% of the 1i censee 1 s annual re 1 eases..

Liquid radwaste system and eves tankage consists of about 300, 000 ga 11 ons storage capacity tn shielded tank Available storage capacity at a particular time is dependent upon plant operations, but typically totals about 200, 000 ga 11 ons, with the remaining 100, 000 ga 11 ons occupi.ed by liquids being collected/processe The completion of Salem Unit 2 will essentially double the available storage and processing capacitfe Planned cross connects between the two units will allow flexibility in operation of the system *

3.4.2 Gaseous

....

The licensee 1 s installed gaseous processing system consists of tanks and equipment for collecting, transferring, storing, monitoring, and release airborne radioactive waste Available treatment consists of storage in one of four waste gas decay tanks (WGDT) at up to 110 ps before release through the plant vent.. The major potential *sources of gaseous wastes are containment purges, WGDT releases, auxiliary r~*'1,fuel handling building ventilation releases, and air ejector re-r\\

)s. All of these potential release pathways exit the plant through 01.~/vent which is continuously monitored for noble gases and continu-ously sampled for particulates and iodine A second monitor consist1ng

of noble gas, iodine, and particulate channels, is normally aligned to the sample.containment atmosphere but is realigned to sample the plant vent during WGOT releases anq containment purges and in emergency situations requi.ring offsite dose predictions. Waste gas decay tank releases have been the major contributor to gaseous effluents to dat No detectable activity has been found to date in air ejector release No significant problems affecting operation of the gaseous waste equipment were note Airborne relases have been low, less than 10% of the annual design objectives, since startu Containment purge and waste gas decay tank releases are quantified based on pre-release analyses. A gaseous releas*e permit is used to provide management control over the releases. The trip setpoints for the WGDT effluent monitor is determined on the release permi The approximately 30 WDGT release permits covering the last 10 months of 1979 and 11 containment purge release permits covering the first 6 months of 1979 were selectively reviewe No significant discrepan-cies were noted. It was noted, however, that 20 of the 32 WGDT 1s

released were heldup for less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months between isolation and releas Only 2 of the 32 WGDT's released were heldup for more than 7 ciays between isolation and release. According to the Salem FSAR, the gaseous waste system is designed to provide a 45 day holdup in the WGDT's before releas *

Normal gaseous release quantification is based on containment purge and WGDT pre-release grab samples, weekly grab samples of plant vent releases, and continuous plant vent iodine and particulate sample As noted previously, in certain elevated release situations, the con-tainment monitor (gas, iodine, and particulate channels) is realigned*

to sample the plant vent. Procedures exist for quantifying noble gas and iodine releases from the plant vent using this monito However, discussions with two control room operators and two shift supervisors revea:led that the criteria for shifting the containment monitor to the plant vent were nbt well u~derstood nor readily available in plant procedures. This item was discussed at the exit interview. The ope-rating characteristics of these monitors are discussed in more detail *

in section 4.2.2 of this repor Other problems noted were:

(1) The licensee does not systematically review the plant vent noble gas monitor recorder for quantification of anomalous releases during the periods between weekly grab. sample (2) The vent fo*r the steam generator blowdown atmosphere flash tank is located in close proximity to the outside ladder leading to the plant vent iodine and particulate sample On occasion, the sampler is not safely accessible due to ice formation (from flash tank vent moisture) on the ladde (3) Licensee procedure PDV3.8.016 - Gaseous Radwaste Release Calculations (Rev. 2), contains an erroneous formula which had been routinely used for calculating total activity in WGDT releases on the gaseous release permit The erroneous formual under-estimates gaseous, iodine, and parti.culate release quantities by about 20%.

The error did not affect release rate (or concentration) calcu-*

lations and has not significantly affected the licensee's compliance with T/S release limits. The licensee's semiannual effluent reports were also not affected by the error since separate calculations are performed for these report (4) The gas analyzer has been plagued with repetitive moisture problems resulting in only 50% to 75% opera-bility during 197 (5) Procedures had not been developed for collect-ing and handling gaseous samples under accident condition Plant vent grab samples are collected at the particulate and iodine sampler (194 foot elevation on outside of containment) and also at the containment monitor when it is aligned to the plant ven Comparative data for the two sample locations was not available *

Containment samples for purge calculations are collected by making a containment entr The containment.monitor samples the same general area in containment {130') but is not used by chemistry personnel who take the grab sample Licensee personnel stated that the grab samples were preferred because of a belief that they are more repre-sentative of the containment atmosphere t*han the installed monitor and because of difficulties in physically obtaining samples using the containment monito The chemistry procedure for collection of *

containment air>' samples {PD 3~5.061) refers to the use of the contain-ment monitor and does not include procedures for collecting grab samples within containmen The licensee did not have comparative date of sample results by the two method According to health physics personnel, containment atmosphere samples are collected on a daily basis using the containment monitor sample lineu.4.3 Solid This area was previously reviewed in Inspection Report No. 50-272/

79-31, dated January 21, 1980, and was therefore not subject to review during this appraisal effor *

4.0 Health Physics Facilities and Equipment 4.1 Facilities 4.1.l Radiation Protection Management's failure to adequately integrate the radiation protection function into the initial planning process is demonstrated.in that the station received an operating license on August 13, 1976, it was not until mid-1979 that in-plant space and facilities were made available to the Radiation Protection grou Up to that time, the entire group (including suppbrting equipment, instruments, the dosimetry system, management personnel, etc.) occupied a trailer located outside of the Unit 1 Turbine Building, and remote from the

areas (i.e., Auxiliary Buildings and Reactor Buildings) which required their attention. This item was initially identified in IE Report 311/78-13 and in IE Report 311/78-52. Since that time, space and facilities had been made available in the vicinity of the control point for most of the group's personnel and equipmen The Senior Performance Supervisor - Radiation Protection and the su_pporti ng administrative and technical staff, however, are still located in a trailer facility. According to a licensee representative, the remainder of the Radiation Protection group will be assigned space in another building currently under constructio.1.1.1 Analytical Laboratories The licensee's analytical laboratories for Units 1 and 2 are located in the Auxiliary Building and consistof a.. counting room, chemistry laboratory, and sampling roo The counting room is located on the Unit 2 side of the Auxiliary Buildin The Senior Performance Engineer for Chemistry indicated that the room has increased shielding and its own air suppl Alpha and beta counting capability is provided by a low-background, thin-window, gas-flow, proportional counter with automatic planchet handling (Beckman Model:

Wide Beta II). Beta calibration is per-formed with an appropriate commerical Sr-90 source, and the frequency of calibration and background determination are adequat Tritium counting capability is provided by a* Packard TRI-CARB Liquid Scintillation Spectrometer. Operation of the spectrometer was not observed during the site visi Gamma spectrum analysis capability consists of three shielded Ge(Li)

detectors. Two-detectors are connected to a.Canberra Scorpio MCA/Com-puter Syste The third detector is connected to a Canberra 8100 Series MC Both systems are capable of automatically counting, analyzing, and printing isotopic identification and concentrations

of liquid or gas samples in µCi/ml or µCi/cc in several specific geometrie Daily calibration checks are made with *a mixed gamma standard (NBS traceable), and recalibration is performed if the calculated_ sample standard deviation is in excess of 0.3 The counting room had adequate storage space, be*nch space, sinks, and desk or writing area The fume hood is inoperative and will remain so until the Unit 2 ventilation system is functionin Liquid, gas, and dried liquid samples are carefully wrapped in plastic to prevent the area from becoming contaminated~ All equipment seemed well maintained and* in working order, and the lab was well organize *

The chemistry laboratory is located at the 1oo~foot level of the Unit 1 side of the Auxiliary Buildin Nonradiological chemistry is performed in*most of the room, with one end (with two fume hoods)

used for radioactive sample operation Airflow through the two fume hoods seemed minimal; however, it was not checked with a velomete No labels indicating the last airflow check or the proper sash level (opening) for 100 cfm were see A dumb waiter to bring samples from the sampling room.above is located conveniently next to the fume hoods; the dumb waiter was inoperative during this inspection.

4.1.1.2 Change Rooms Change rooms with lockers and benches were located conveniently near the control point and decon area. A restroom adjoined the locker area; however, convenient, separate women 1s lockers and restrooms were not availabl.1.1.3 Decontamination Area *

The room designated for personnel decontamination was conveniently located near the control point. It contained four large sinks and

. two shower stalls. Respirator equipment decon and small tool decon were routinely performed at the same sink The posted procedures and the use of multiple sinks seems adequate for cleaning the respira-tors; however, during times of peak use by personnel or decon of larger quantities of contamimition, some cross-contamination could occu The use of this area for purposes other than personnel decontamination should be discouraged. *

One shower head was missing and one sink was cracke There was no dedicated frisker in the roo Personnel decon could be performed, but the design capability of the room was not available.

4.1. 2 Chemistry 4.1.2.1 Sampling Areas - Coolant The sample room is located on the 110-ft level directly above the chemistry lab on the Unit 1 side of the Auxiliary Buildin Liquid samples from several sources in the containments and the Auxiliary Building are drawn into this roo The sample lines terminate inside the fume.hood over the sinks, with the final valves located inside the fume hoo One fume hood contains the sample lines from Unit 1 while across the room is a second fume hood for lines from

Unit Valve position lights and activating switches are located next to each sampling hoo Area* radiation monitor R6A is located oh the wall next to the Unit 1 sampling hood.. The sampling hoods are conveniently next to the dumb waiter down to the chemistry la No labels indicating hood airflow checks or sash levels were observe The equipment in the liquid sample room is adequate for routine low-level samples; however, the functioning of equipment (e.g., the fume hoods) is not adequately assured by routine checks, and shielding for nonroutine samples is not presen *

Capabilities for sampling the reactor coolant do not now meet the criteria of NUREG-057 The sampling lines are not shielded to protect the technician from high exposures during sampling of high-acti-vity coolan Valve manipulation for the final sampling must be done by hand at the valve in the sample sink. Gaseous release from the coolant water can be adequately captured by the hood over the sink. With the existing recirculating procedures before sampling, the sample is representative of the reactor primary coolant syste The licensee's response to the lessons learned inquiries was given

in a letter of January 1, 1980,. to the Commissio The letter indicated that a design and operational review of the containment atmosphere and reactor coolant sampling system had been performed and that this review indicated that modifications to the atmosphere and reactor coolant sampling systems were neede When the auditor asked for comments on these modifications from the Senior Performance Engineer for Chemistry, he indicated that he had not seen this letter of response which, he said, came from the corporate office in Newark, His initial reaction on reading the proposed ~edifications was that they would not work for the coolant samples because:

1)

the exposure in the sampling room from the coolant in the lines would be too high after sampling, 2)

the high exposure rate would preclude the use of the Unit 2 sampling sink, which is across the room, and

29\\

3)

the sampling sink drains run into the sampling room floor (i.e.,

the chemistry lab ceiling) and would (could?) raise the exposure level in the chemistry la The Senior Performance Engineer for Chemistry did not have the source terms or documentation of the design review, which he said were from corporate in Newar He had no further documentation of the revie He did produce a handwritten, draft procedure for using multiple sample takersto obtain a post-accident coolant sample with the current equipment.* He also indicated that the. procedures for sampling and analyzing very highly radioactive samples in a post-accident situation had been discussed among his staff but were n.ot documente In

discussing these proce.dures, he indicated that his current method of obtaining a containment atmosphere sample would be to use the existing containment air sampling lines to get a grab sample; however, the response letter of January 1, 1980, indicates that the electrical penetration room where containment air sampling lines are located

"becomes inaccessible during an accident due to radiation streaming thro.ugh the surrounding penetrati an In an attempt to determine the current procedures for sampling reactor coolant, the auditor followed a plant Technican Helper assigned to the chemistry section during a routine sample ru Salem Procedure PD-3~5.001, "Sampling of the Reactor Coolant" was successfully followed w.ith one significan*t exceptio Under 11 Precau.tions, 11 one item noted that Salem Procedure PD-15.7.008, "Handling and Tagging of Samples,

should be observe This procedure primarily concerns measurement of the exposure field on contact and at 1 foot from the freshly drawn sampl The use of a high-range survey meter is prescribed, along with instructions to be followed if the sample reading is too hig In addition, proper tagging procedures are give The Technician Helper did not carry *a survey meter, check the exposure rate, or tag the sample container with the proper radiation symbol and exposure rate level (When the sample was measured by the auditor, the contact level was less than 1 mrem/hr, as would be expected in a normal sample).

When asked about the apparent lack of safeguards against an unknown hot sample, the Technician Helper responded that he was following the procedures he had been taught and that if the Opera-tions Department indicated trouble he would call his supervisor or if the area alarm sounded he would leave and find hel When asked whether he had received instructions or had had discussions with his supervisors on the immediate steps to take for a post-accident sample, he said he had no The apparent 1 ack of*.communication between the corporate generators of the lessons learned response and the plant senior performance engineer for chemistry indicates that the effort to precluding another TMI-2 response to an accident has not been successful up to this tim The

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concern of the NRC for this situation, and immediate, simple steps to reduce unnecessary exposures to post-accident samples have apparently not been well communicate Time did not permit an examination of the corporate review documentation for the proposed engineering modifica-tion.1.3 Radioactive Waste 4.1.3. l Ventilation Systems Technical Specification 4.7.7. l requires, in part, that the Unit 1 auxiliary building exhaust air filtration system should be demon-strated OPERABLE, at leas.t once per 18 months by satisfactorily com-pleting in-place filter testing with the system operating at a system flow rate of 21,400 cfm + 10%.

During a review of the most recent in-

- place test of the auxiliary building exhaust ventilation performed in July 1979, the auditor noted that the test results indicated that ventilation system Number 13 had a flow rate of 31,293 cfm during the in~place test. A licensee representative stated that the test results had just been received and a thorough review had not been performe _He further stated that he thought the flow rate value recorded on the

.data sheet was in error, since the flow rate had b.een within specifica-tions on previous tests, however, he would contact the vendor and confirm the fl ow rat The auditor state_d that failure to perform the in-place test with the system operating within the sp~cified flow rate would be in noncompliance with Technical Specification 4.7. The auditor stated this item would remain unresolved (272/80-03-04)

pending further review during future inspection The auditor discussed with licensee representatives the extensive painting which has taken place in the auxiliary building within the past few weeks and the impact of painting on the ventilation system filter The licensee representative states that the auxiliary building ventilation would be retested as soon as the schedule could be worked out with the vendor who performs the tes During a tour of the auxiliary building, the auditor observed that one of the roughing pre-filters in exhaust ventilation system #11 had been destroye Differential pressure across the roughing filter bank was zer Discussions with licensee representativ~ revealed that new filters had been ordered, but not yet receive *

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4.2 Equipment 4.2.1 Protective This area is discussed in section 3.2..2.2 Instrumentation 4.2.2.1 Portable The auditor observed a variety of health physics instruments and equipment (portable survey instruments, portal monitors, personnel*

friskers, pocket dosimeters, air samplers) in use, observed the cali-bration of instruments, checked calibration stickers, performed bat-tery checks for selected portable instruments, and selectively examined calibration records for survey instruments in us The auditor discus-sed the radiation survey instrument calibration program with contract instrument technicians who perform the calibrations, with the techni-cal supervisor responsible for instrument calibration and with technicians who use the instruments as well as licensee managemen The number and nature of the findings discussed below indicates a need for more direct management involvement in the instrument calibration progra The instrument calibration program has been turned over to a contractor, with little, if any, technical review of their work by the license The licensee does not assure that a tecDnically sound calibration program is in place and does not require an aggressive monitoring of this program by the responsible individua The cali-bration program should meet or exceed the recommendations of ANSI N323-1978~ Radiation Protection Instrumentation Test and Calibratio Without radiation detection instruments that are calibrated by quali-fied technicians, using approved procedures, and sources that are d.irectly traceable to' National Standards, the credibility of this p.ortion of the sta.tion 1s health physics program is questionabl Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented and maintained covering the acti-vities recommended in Appendix 11A 11 of Regulatory Guide 1.33, Rev. 2, February 197 Regulatory Guide 1.33, 'Appendix A, Section 8.b(l)(aa)

states that specific procedures for surveillance test, inspections and calibrations should be written for area, portable and airborne radia-tion monitor instrumentatio *

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Station Procedure PD-15.9.004, "Calibration of the Radiation Monitor, Model, RM-14

, Rev. 0, Paragraph A.I.7 states, "Place a beta-gamma standardization source against or directly under the prob The indicated count rate should be 10-20% of the indicated standard dpm for pancake detector When questioned concerning what type of source was used for checking the RM-14 1s, a technician who calibrates the instruments stated that this section of the procedure was not performed and that the calibration of the RM-14 was only an electronic calibration using a pulse generato Station Procedure PD-15.9.009, "Calibration of Eberline Portable Neu-tron Rem Counter, 11 PNR-4, Rev. 0, Paragraph A. I. 2-5 states, 11Pl ace instrument in a 4 mrem/hr, 40 mrem/hr, 400 mrem/hr and 4 rem/hr neu-tron field and check readin If correct reading within 10% are not obtained in all fields, proceed to section II.

Licensee representa-tives stated that this part of the procedure is not being followed, because the output from the neutron source is not know The auditor stated that the output of the neutron source could be determined by measuring the output with an instrument that has been calibrated offsite. After this had been accomplished, the source could be used to check the response of the neutron survey instruments in accordance with the procedur The auditor stated that failure to follow the

procedures for the calibration of instruments was in noncompliance (272/80-03-05) with Technical Specification 6. The auditor observed the calibration of a staplex high volume air sample When the auditor asked to see the procedure that was being used, the technician stated that the procedure was still being writte It should also be noted that the licensee could not produce a calibration certificate for the Alnore thermo-anemometer used to determine the flow rate for the staplex. A licensee representative stated that the anemometer had been compared to a 11 calibrated 11 instrument by the instrument calibration contractor, hQwever, no results were available for revie The calibration certificate for the 11 calibrated 11 anemo-meter used as the reference was also not availabl The auditor stated that failure to have a written procedure for deter-mining the flow of the staplex air sampler is another example of noncompliance (272/80-03-06) with Technical Specification 6. Technical Specification 6.8.2 states in part that each procedure and administrative policy of 6.8.1, and changes thereto shall be reviewed by the SORC and approved by the Station Manager prior to implementation.

Station Procedure PD-15.9.002, "Background and Efficiency Determination on BC-4 and SCA-4 Counting Instruments, 11 has been rewritten and the new procedure used to determine the efficiency of the counters on February 1, 1980, without first having the procedure reviewed by SORC and approved by the Station Manage The temporary change*provisions of Technical Specification 6.8.3 are not applicabl The auditor observed a technician attempting to perform a daily source count and background count on the BC-4 counter using the data sheets in the procedure without having a copy of the procedure available for referenc The technician stated that he had not received any training on the proce-dur The source count was outside the 3 sigma control band (high side) that had been establishe The co~rective action was to change the source-to-detector distance until the count rate fell within the required band; no. records were available to indicate the source-to-detecto.r distance used for initial calibratio The BC-4 counter is used to evaluate particulate air sample During the calibration of a Teletector high range survey instrument, the auditor noted that the Station Procedure PD-15.9.011, "Calibration of Teletector 6112 11 being used by the technician had pencil changes made to paragraph A.I.7 and The technician stated that these changes had been made to correct errors in the procedur A review of the master copy of the station procedure revealed that the procedure had not been officially change Th~ auditor stated that failure to have the changes to Station* Procedures PD-15.9.002 and PD-15.9.011 reviewed by the SORC and approved by the station manager prior to implementation was in noncompliance (272/80-03-07) with Technica Specification 6. The station uses a Cobalt-60 source (No. S-140) for calibrating the BC-4 beta counte The station could not locate any documentation to indicate that this source is traceable to a National Standar The auditor stated that failure to have a certification for the source documenting relatability to a National Standard would make any analysis performed on the BC-4 suspec The auditor stated that relatability of the source to a National Standard should be promptly establishe The auditor observed that portable health physics instruments were being checked prior to use by holding the instrument near a radiation source and observing that the instrument responded to radiation (instrument read greater that some value).

The RM-14 friskers were considered satisfactory if the alarm sounded when the alarm setpoint was full scale and the HP-210 probe was brought near a sourc The auditor stated that neither instance insures that the instrument is functioning properl The response is checked on only one scale and just because the reading is above a present point does not necessarily mean the instrument ii functioning properl The auditor stated that the procedure described in ANSI N323-1978, should be used for response

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checking instruments. This procedure requi.res.that the instrument be exposed to a check source immediately *following calibration in a constant and reproducible manne Reference *readings should be ob-tained on each scale normally use If the instrument response to the check source on subsequent response checks differs.frorri the reference reading by more than 20%, the-instrument should be removed from service and recalibrated *.

. The station's health physics instruments and equipment are being

_calibrated and*maintained by an outside contracto By observations and qiscussions with the contract technicians and station personnel, the auditor determined that the records generated by the contractor are not reviewed by station personnel for accuracy arid adherence to procedure The auditor stated that calibration re.cords should be reviewed by a technically competent individual, preferably the technf-cal supervisor responsible for this area, and signed by the individual before the records are file *

4.2.2.2 Fixed Area Radiation Monitors The Salem ~tation has a conventional area radiation monitoring system consisting of fixed G-M detectors with local and remote (control room)

di-splays and alarms. There are approximately 18 area monitors and all but 3 of which have remote readout and alarm function The control room alarm has a reflash functio Ranges are limited to 10 R/hr except for one of the five containment monitors and one auxiliary building monitor (mechanical penetration area) which have an upper range of 1000 R/h The containment monitors are not designed to op'.'"

erate in a major LOCA environmen In response to an *October 30, 1979, letter from the NRC (NRR), the licensee agreed to install two area monitors in containment by January 1, 198 These monitors are to be capable of withstanding required accident environmental condi-tions and to have ~n increased range.*

The licensee performs functional.testing and calibrations of the area monitor The calibrations are performed in accordance with approved, written procedures which specify two point solid source calibration checks of the detectors, and an electronic calibration of the monito The functional checks are primarily electronic, but do include a detector response check with installed check sources. Although some maintenance problems have been encountered with the area monitors, sufficient spares are available from Salem, Unit 2 to minimize downtim An equipment cha_nge on Unit 2 resulted in the additional spare monitor In addition to the area monitors, approximately nine G-M monitors are installed in proximity to filters in various radioactive system No evidence of a licensee evaluation of area monitor adequacy under accident conditions was foun The variability of accident scenarios appears to make a good case for a system of portable area monitors with readout in~ central location (control room).

Although, according

.to licensee personnel, Salem, Unit 2 will have such.a system, there are no present plans to backfit Unit 1 with a similar syste.2. Effluent and Process Radiation Monitors A system of approximately 24 monitorfog channels consisting of gas (G-M), iodine (scintillation)~ pa~ticulate (scintillation), and gross 1 iquid (scintillation) detectors monitors. radiation levels in various plant operating systems. Monitor readouts. and alarms are provided in the contro.l roo The control room alarm has a reflash functfo The monitor ranges are lEl cpm to.1E6 cpm (a range of lEl to 1E4 can be selected at the monitoring system cabinets, but not on the control room indicators).

Two monitors are used for monitoring airborne radioactive effluent The plant vent monitor (R-16), which consists of four inline G-M tubes, routinely monitors the plant's gaseous release During WGDT releases, containment purges, and in certain emergency situations, a combination gas, iodine, and particulate monitor (RllA, 12A, 128) is aligned to ~he plant ven According to licensee personnel, an ad-ditional monitor consisting of gas, iodine, and particulate channel will be installed and dedicated to monitoring the plant vent continu-ousl Neither the installed nob 1 e gas monitors, Rl2A and Rl6, nor the planned additional gas monitor possess the monitoring range speci-fied in the October 30, 1979 letter from NRR to the licensee (Lessons Learned Task Force, Short Term Recommendations).

In response to the October 30, 1979 letter, the licensee agreed to modify the plant vent gas monitor to provide the specified detection range (1E~7 µCi/cc to

1E5 µCi/cc) by January 1, 198 The.licensee had not, however, com-pleted the actions specified for completion by January 1, 1980, re-garding noble gas monitorin The licensee did not address *the January 1, 1980,' requirements for noble gas or radi oi odi ne and particulate effluent monitoring in their response, although requested to do so in the October 30, 1979 letter. At the time of this inspection, the licensee's noble gas monitor was capable of monitoring releases up to about µCi/cc, which is several orders of magnitude less than the NRR reques The two installed gas monitors (R16 and R12A) were calibrated with Xe-133 and Kr-85 gases during preoperational testing. The R16 setpoints were verified by the auditors to correspond (conservatively) to the quarterly average technical specification release rate (warning) and the instantane.ous technical specification release rate (alarm) based on

- - - .:: 36 the preoperational Xe-133 calibratio Use of the Xe-133 calibration data results in a conservative quantification for Kr~85 and typical release mixture The quarterly calibrations of Rl6 and Rl2A performed subsequent to the preoperational fluid calibrations have utilized two solid calibration sources that were cross calibrated during the fluid calibrations. Monthly functional tests include an electronic check in addition to the use of a check source for detector respons Although the licensee has no current provisions to do so, it would be prudent to repeat fluid calibrations of these monitors at certain.interval It would likewise be prudent to use more than two solid sources per calibration and to define an acceptable response to the functional test check source. These items were discussed at the exit intervie It was determined that licensee procedures existed for the calibrations and functional testing of the process and area monitor However, these procedures were not examined in detail during this inspection.

. The surveillance testing was noted to have been conducted within the technical specification interval No significant discrepancies were identified regarding administration of the calibration and functional testi_ng surveil 1 ance program *

5.0 Administration of Emergency Planning The Assistant to the Manager is assigned overall responsibility for the station emergency plan and implementing procedures.and reports directly to the *station Manager and acts with his authority in all matters involving emergency planning and maintaining a state of constant readines He has

an assistant who devotes approximately 50% of his time to emergency plan-ning function Acting as the Emergency Planning Coordinator, the Assis-tant to the Manager delegates the actual performance of certain readiness functions to senior supervisors in the line organization while retaining full authority to dea 1 directly with the res pons.i b 1 e supervisors in the organization irrespective of the formal chain of comman The Emergency Preparedness Coordinator maintains overall control of various emergency planning readiness function records, e.g. drills, training, equipment inventories, etc. thereby enabling him to keep day-to~day track of the readiness posture and the performance of required readiness function Discussions indicated that the Assistant to the Manager and his assistant receive adequate support from both Corporate and site personnel in the performance of tbeir emergency planning function In addition to the licensee employed individuals-involved in emergency planning activities, two contractors have been retained to provide planning and procedure development suppor One contractor is part-time in the sense that his activities are only partially devoted to the Sale~ sit The other is full-time, working in the radiation protection grou Com-munication between the various individuals involved in emergency planning appears good and a number of areas for upgrading have been identifie For those problem areas identified, conceptural approaches for resolution have been develope Despite this, there.has been little actual effort toward implementation of these conceptural changes. This reluctance to implement appears to have resulted from the development of a 11wait-and-see 11 attitude precipated by the ongoing review and upgrading of the emergency plan by the NRC Emergency Planning Task Force. This a,ttitude has had an adverse impact on the emergency organi.zation configuration, training, and the emergency*

plan implementi.ng procedures. Based upon the results of this audit and upon discussions with the Assistant to the Manager, this attitude seems to have lessened and action will be taken to implement and correct immediate short term difficulties that would hamper an effective response to a seri-ous eme.rgency at the Salem Generating Statio Generally, the management control of emergency planning at the Salem site is adequat It provides a unified approach where the ultimate authority and responsibility for the readiness posture of the facility is vested in a single individual who exerts centralized control over all readiness func-ti~n This situation appears to have a positive impact upon the state-of-the-art nature of the licensee's procedures, facilities, equipment and overall response postur t.38...

6.0 Organizational Control of Emergencies 6.1 Onsite Organization The licensee 1s emergency organization is somewhat general in the assignment of functional r~sponsibilities. Organizational elements described are: Senior Shift Supervisor; the Emergency Duty Officer; the Manager of Salem Generating Station; the Emergency Radiation Survey*Teams; Fire Brigade-and First Aid Team; and Personnel Accountabi-lity Tea To evaluate the adequacy of the licensee 1 s emergency organization fr.om a radiation protection standpoint, it was necessary to take an overview of the entire emergency organization as currently structured to determine what radiation protection functions were

covered, by whom they were-covered and which functions were not covere As described in the emergency plan and reflected in the implementation procedures, the licensee's onsite emergency organiza-tion is as represented in figure From* discussions with various 1ndividuals at the management level and in the radiation protection group, it was noted there has not been a specific delineation of authority and responsibility for several key individuals and groups of the emergency organizatio The role and authority *of the Station Manager during an emergency is one such exampl In accordance with the Salem Generating Station Emergency Plan the Emergency Duty Officer (EDO) directs, coordinates, and controls implementation of the emergency pla Presently there are five EDOs all of whom are SRO licensed. The Station Manager no longer has an SRO license and is therefore not included in the five man EDO poo There are provisions for emergency coordinator called the EDO at the Salem site onsite at all time During any emergency the Senior Sh.ift Supervisor initially assumes this duty until relieved by the assigned EDO of the da All senior shift supervisors are EDO qualified and have (as do all EDOs) the authority and responsibility to initiate any emergency actions within the provisions of the emergency p)an including the exchange of information with offsite authorities responsible for coordinating offsite emergency measure It was not clear in the Salem plan and procedures or through discus-sions with EDOs of the exact scope of the authority and responsibility vested in the emergency coordinator particularly in the area of plant operatio Procedurally, the EDO's functions, authorities and responsibilities exclude his involvement in operations aspects related to an emergenc The Shift Supervisor appears to be permitted to act independently from.other elements of the emergency organization and independently from the ED Under accident conditions the operating crew appears to have final authority over any operational-re-lated matter This is reflected in the nature of the training and the procedures of the emergency pla I I

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With the EDO having no clear-cut authority over the actions which the operations crew may wish to take, an apparent lack of a unified

command and control of the emergency organization exists. There is a potential for conflict with the actions, decisions, capabilities, and resources of that portion of the emergency organization under the control of the EDO as well as competion for the manpower resource ; Since the operational aspects of an emergency can heavily impact

. upon the radiological, e.g. operational decisions.and activities can.

directly.affect the radiological consequences of the*event for which the emergency organization has been created to comba This competition and vying for emergency resources occurs when the operation's group has need of the skills of and support from other elements of the

emergency organization, particularly in the areas of radiation protection, chemistry and radwast The ex.isting emergency organization does not include or delineate an organizational structure to support continuity of radiation protection functions during emergencies. Within the radiation protection area, the organization is limited to a general statement,_ 11radiation teams.

11 Procedures do reflect some limited support in this area, primarily in the area of team coverag Such aspects' as personnel dosi.metry, site access controls, dose assessment, ALARA considerations, chemistry, etc. are not included and are not addessed in the existing organizatio Discussions with licensee management and radiation protection personnel indicated that considerations for continuity of radiation protection functions during emergencies has been considere A conceptural organization has been developed and is currently under review for possible implementatio The auditor reviewed this conceptural org~nization and noted that it provided adequate coverage of the af.orement i oned area *

Generally the licensee's existing emergency organization is consti-tuted in such a manner that during a serious emergency it would be necessary for ad hoc organizations to be created to combat radiation protection problems and interface the operational and radiation pro-tection aspects and resource Further review of the licensee's emergency organization indicated

that the interface between corporate and private contractor support groups are not clearly delineated. ihe chains of command and com-munication and authority were not clearly specifie For example, the licensee's emergency environmental monitoring program would be ad.ministered by an individual from the Corporate headquarter This is not reflected in the current organization nor have*detailed provisions for interfacing this organization been included in the site organization description. The licensee had al so i denti fi ed this problem area and had developed a conceptural approach ;to resolving this organizational discrepanc. '-;., *~

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6.. 2 Augmentation of Onsite Emergency Organization As. discussed pr*evi ously, certain of the Corporate management, admi n-

.. * istrative and technical. support personnel who would augment the

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plant staff are not clearly specified in the emergency organization,

- - particularly in the areas of environs monitoring, logistic~l support

. for emergency personnel, technical support for planning reentry and recovery operations, for the release of information to news media, and coordination with. governmental authoritie The scope of the

_accident against which the present plan is designed has not resulted in the development of prOlisions for supplementing the health physics staff under accident condition Consequently, such provisions for additional health physics support would have to be made on an ad hoc basi Certain of the contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency organization are discussed in the implementing proc~dures themselve In some instances, however, the authorities, responsibi-lities and limits on the action of the Corporate and contractor*

support groups are not clearly specified in the procec(ures governing

their activitie Generally the licensee's emergency organization is w~ak in four general areas:

(1) in the delineation of authorities and responsibilities for key individuals within the licensee's emergency organization, in particular, the Station Manager and the Emergency ou*ty Office (2) in the area of i.ntercoordination of the operational aspects with other elements of the emerg~ncy organ.izati o (3) inadequate description of the radiation protection organization during emergencies to ensure that radiation protection functions continue with some.degree of c.ontinuity commensurate with the emergency situatio (4) the interface, authorities and responsibilities of Corporate and contractor groups who may support the licensee 1s emergency response are also not clearly defined and interfaced with the licensee 1 s emergency organizatio The licensee had identified these shortcomings *and had already ;initiated conceptural plans to correct these organizational gaps and weaknesses in the emergency organization. These concepts are presently under*.

review with final resolution expected in.the near futur.0 Training Emergency plan training at the Salem site is* deficient in several areas..

While the categories of emergency personnel and the frequency at which they

are.trained are specified, the scope and nature of the training to be pro-vided are not specified. The exact scope and nature of the actual training is left to the discretion of the assfgned instructor, and there are no pro-visions to evaluate the ability of each individual to perform their emer-gency duties* once the training has been complete In this regard, there *

are no training objectives. clearly stating the cond-itions, tasks and stand-ards of performance that would apply in making an evaluation and a deter-mination that a particular individual is qualified to perform his assigned emergency functio *

In pursuing the scope and content of the. various training sessions conducted for emergency personnel, the auditor noted that there are no approved formal lesson plans for each category of emergency training for use by the instruc-tor. It was also noted that for each category of training required~ the individual who will be responsible for conducting the training was not spe-cified. Training of individuals for the site emergency organization occurs at. a routine frequency about once every 12 month In discussions with licensee management and persons involved in administering the emergency planning program, the auditor determined that there were no formal provi-sions for retraining or,iraining members of the emergency organization in changes to procedures and equipment which might occur* in the period of time between the scheduled training sessions one year apar Through interviews of emergency team personnel and licensee management, the auditor determined that training programs consist almost entirely of 1ecture-type classroom instruction. Occasionally there have been an oppor-tunity for attendees to gai.n practical experience in the use of equipment and procedures which they may be expectec:i to use, but, in general, this is not included in the training progra *

42 8.0 The Emergency Facilities and Equipment ~ergency Kits and Emergency Survey Instrumentation The licensee maintains pr.epositi.oned emergency-supplies and survey instrumentation at various specified locations throughout the facili-ty. ihe kits and equipment were located as specified fn the plan and procedures and inventories were correct. A review of available port-able survey instrumentation indicated that their ranges, types and numbers were adequate to meet *anticipated emergency needs. Instrumen-tation available for individuals or teams re-entering the facility provide the capability to detect and measure radiation fields up to 1000 R/hr. The station has no radiation survey instruments with ranges greater than.1000 R/h The inspector stated that the station should consider acquiring instruments with ranges up to 10,000 R/hr to be used in the event of an acciden Instruments with ranges greater than 1,000 R/hr were needed immediately following the accident at Three Mile Island, but were not availabl A licensee representa-tive stated that the station would review the need for such instrument Emergency environmental sampling and sample counting equipment provide

a capability to detect and measure radioiodine concentrations in air with a sensitivity of at least 5 E~oa uCi/cc under field condition The counting instrument used is the Stabilized Assay Meter (SAM) II in conjunction with the RD22 sodium iodide detecto The air sampler used is the Radeco H809V with variable flaw capability. * Charcoal car-tridges are presently used as the collection medium, but to counteract the. adverse effects of noble gases, the licensee has ordered silver zeolite to replace the charcoa Operability checks and inventories are routinely performed at a quar-terly frequency an.all emergency i.nstrumentatian, supplies and equip-ment described in the emergency plan and implementing procedure The conduct of emergency equipment inventories and checks is governed by Procedure No. EPII-10, Conducting an Inventory of Emergency Equip-men The inventories. and checks being performed appeared adequate to maintain emergency supplies and equipment in a constant state of readines While there is no formal policy for maintaining state-of-the-art sur-vey ins.trumentation, constant revieti( and attention are given to *the configuration of emergency instrumentation. The responsibility for this review is assigned to a single individual in the licensee 1 s radia-tion protection organizatio A portion of this individual 1 !? normal duties involve maintaining inventories, reorder levels and stackage of all supplies and equipment used in the radiation protection program at the sit *

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.....,,,..,, The licensee maintains an onsite capability to fill self_;contained breathing devices.. A mobile, diesel powered, skid-mounted air c;om-pressor is available for this purpose,.-and could be moved if the areas which it is located should exhibit.high airborne or direct levels of ~adiation. The licensee has also made backup provisions with a local fire department in this respect for filling breathing device.2 Fixed Facilities and Instrumentation for Radiological Accident Assessment S.2.1 *Area and.PrOCi;!SS Radiation Monitors During the audit, the area and process radiation monitoring systems of both Unit 1 and Unit 2 were rev.iewed for operability. It was noted that Monitors for assessing the release of radioactive materials to the environment under accident conditions do not have sufficient ope-rating ranges to adequately assess the releases which may occur under a serious accident condition.. The licensee recognized this several years ago and developed a contingency procedure to be used under acci-dent conditions where assessment instrumentation should happen to be offscale or out of servic **

The* numbers and locations of area radiation monitors appear adequate to assess accident conditions affecting internal areas of the plan These* monitors could, however, be affected by elevated background radiation or be inaccessible during a serious emergenc Procedures related to the use of area and process radiation monitor readings under accident conditions are limite Area monitors are primarily used for accident detection and classificatio Specific review of area monitoring data prior to the conduct of emergency ope-rations requiring entry/reentry in,to the facility is not clearly spe-cified in the procedures governing the conduct of these types of ope-ration Process radiation monitors are used to assess releases and project accident consequence Procedures relating to the use of certain process radiation monitors for projecting such radiological conse-quences appear clear and easy to follo Under the present organiza-tional configuration, readings from the area and process radiation monitoring systems are readily available to the individuals of the emergency organization who would be required to use the information to assess the acciden All radiation monitors, area and process, are maintained on a routine schedule, with daily operational checks performed on all monitor A review of these checks indicate they are adequate *

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8.2.2 Meteorological Instrumentation Readouts of station meteorology are available in each control roo During the audit, the operability of this equipment was reviewed and the system. appeared to be operating prope.rly. the system is not pro-

vided with.vital or redundant power, but there are backup provisions for obtaining representative, real-time meteorological information dur.ing an e*mergency if the onsite instrumeritation should become inope-rabl The Greater Wilmington Airport" Weather Station is used for this purpos *

8.3 Emergency Conununicatfon Equipment The communications equipment specified in the licensee's Emergency Plan and Procedures were. availabl There are specified alarms throughout the facility which have specific meaning These alarms are: the fire alarm, the radiation alert alarm, the containment eva~

cuati*on alarm, the fuel handling building evacuation alarm, and the cardox evacuation alarm covering the emergency diesel generator rooms and switchgear.room Each of these alarms are tested on a.weekly basis in accordance with approved operator surveillance procedure During the audit, an apparent problem was noted with the containment and fuel handling building evacuation alarm Workers interviewed reported that electrical arc welding operations cause ~purious acti-vation of the containment and fuel handling building evacuation alarms~

Apparently, during outages these false alarms become such a frequent occurrence, that*the alarms are ignored altogethe Further discus-sions with workers who have experienced this situation indicated that during periods when welding operations are being performed there are no backup-alarm provisions made available in the co_ntainment or fuel handl i.ng bui 1 ding to indicate that. an e,vacuati on of. the area(s) is neede Voice communications devices and equipment consist of portable radios, fixed base station radios, a NAWAS telephone line, a direct line to the New Jersey State Police and a direct line to the Lower Alloways Creek Township Municipal Buildin Each of these three direct-line systems are routinely checked for operability and immediately repaired if such checks indicate that they are inoperabl The licensee does not have provisions for tape recording telephone and radio communications originating from or going to the emergency coordination center and control roo The recording method relies on manual transcription of messages on data forms and pape *-In addition to the licensee installed communication systems and device two NRC telephone nets are in strategic locations throughout the facilit ***.':

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One net is the off premises extensio*n (OPX), used for rapid notifica-tion of the NRC in the event of an emergency and for the subsequent passage of operational data_,

A second 1 i ne, the SS4 or heal th phy-sics net, is used for the passage o'f health physics and environmental monitoring data to the NR *

Generally, the onsite and offsite communications systems appear ade-quate to support the performance of vital functions in transmitting and receiving information throughout the course of an emergenc A particularly good communications.aspect is the interface of radi communications between the State :of New Jersey teams that may be responding to the incident and the licensee's emergency coordination center and environmental monitoring team Through the direct line to Lower Alloways Creek Township and telephone and radio communica-tions to the State, the licensee has an onsite cooununications capa-bility to assure contact with offsite authorities responsible for implementing protective measures in the environ.-4 Emergency Operation Centers The licensee has provisions for a principal and an alternate emergency coordination center from which the direction, evaluation and coordina-tion of all licensee activities relating to the emergency will be per-forme The primary emergency coordination center is located in the Shift Supervisor 1 s office and the alternate at the Lower Alloways Creek Township Municipal Buildin The location of the primary emergency coordination center is _such that access to the facility may be pre-cluded during a serious emergency in which internal areas of the plant are affected by higher than normal radiation level The room itself is somewhat small, having only one door to the main corridor between the Unit 1 and Unit 2 control rooms and one door into the Unit l con-trol roo The alternate emergency coordination center at the Lower Alloways Creek Township Municipal Building is also similarly smal Review of these centers indicated that they were equipped as stated in the plan and proce,dures and that generally the scope, range and nature of equipment available would be adequate for the licensee to respond to an emergenc.5 Medical Treatment Facilities The licensee maintains onsite provisions and facilities for the treat-ment of individuals who may be injured and contaminated. Originally the licensee had two such facilities: one located near the controlled area and one located in the Administration Buildin Several months ago, the licensee converted the controlled area first aid room into a health physi.cs counting roo Consequently, all persons who may be injured or contaminated must be transported to the Administration Building first aid are. I I

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The first aid room in the administrative. area is maintained under lock

. and ke There are, howev.er, provisions for rapid dispatch of a key to the facility to permit immediate access. The facility is easil accessible to a stretcher being ca.rried by two individuals and was equipped with first aid equipment and supplies adequate to perform personnel decontamination with the exception that there was not an

* operable calibrated personnel contamination survey instrument main-tai ned in the facility for immediate us Communications were avail-able from the first aid f aci 1 i ty and procedures for treatment and decontamination of individualS were availabl Discussions with licensee personnel indicate that the controlled area first aid room was eliminated without total evaluation from the stand*

point of a 10 CFR 50.59 revie The availability of a single first aid and decontamination treatment area in the Administration Building appears inadequate since it necessitates the transport of a potentially contaminated victim through clean areas of the plan.6 Decontamination Facilities There were minimal provisions for decontamination in close proximity to the onsite medical facility discussed abov Thes.e provisions consist of a body* tray for wash down of an individual, large.carboys for the collection of potentially contaminated water, cotton swabs and various other decontamination supplie A source of water was available from a deep sink located in the facility. There were pro-visions for the disposal of solid and liquid waste at the firs~ aid/

decontamination facilit Other provisions for decontamination at the Salem site are the showers normally used by individuals who work in the controlled are There were no provisions for offsite decon-tamination of personnel or vehicles/equipment from the station that may have to be* evacuated in the event of an emergenc.7 Protective Facilities and Equipment Assembly areas are designated and located within the facilit These areas, however, have not been selected based upon a review of the fea-tures to ensure adequacy with respect to their capacity to accomodate the number of persons expected for shielding, ventilation, supplies of equipment, (e.g. decontamination supplies, respiratory protection, protective clothing, portable lighting and communications equipment).

Personnel are not routinely assembled or evacuated from the site in the event of a serious emergency at the facilit Rather, personnel instructed to "stand fast 11 upon hearing a radiation alarm until directed to report to their assigned assembly area such as the cafeteri Indi-viduals remain at their accountability stations until a decision is made that evacuation is necessary or pruden Each of the assembly areas is to be staffed by radiation protection personnel to monitor

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area radiation levels and report to the emergency coordination center.*

Unde.r conditions of a* plant*, site or general emergency it is possible

that these assembly areas could become untenable and that personnel should b,e evacuated from the si.te upon declaration of such emergencie Consequent1y,* the auditors have determined that assembly areas located withi-n the facility are inadequate due to 'their diverse locations, the need for coverage by numerous health physics personnel and the potential for increa~ed radiation levels both direct and airborne and

_resulting exposure/contamination of individuals in these locations.

. 8.8 Damage Control, Corrective Action and Maintenance Equipment and Supplies for Use During Emergencies The 1 i censee does not mai ntai.n reserves of equipment for damage con-trol, corrective actions, and/or emergency maintenance of equipmen Rather, the emergency plan relies upon the availability of the rou~

tine stocks of instrumentation and equipmen.9 Reserve.Emergency Supplies and Eq.uipment For a serious emergency, the licensee would rely on the normal inven-tory of supplies, (e.g., survey instruments, dosimetry for the envi-ronmental radiation monitoring program, protective clothing and equip-ment, and other instruments and equipment) to support emergency opera-tions and supplement the emergency reserve The licensee is in the process of establishing formal controls to ensure that minimum stock levels of routine operational equipment will always be availabl Part of the controls to be implemented will include periodic verifica~

tion of stock and the establishment of automatic reorder levels when stocks of various items have reached the reorder poin SolO Expanded Support Facilities

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The licensee's plan and facilities does not designate or consider work facilities or resources available for an expected increase in the num-ber of radiation protection personnel that may be expected under a serious accident conditio Such provisions would have to be arranged on an 11ad hoc 11 basi.0

~ergency Plan Implementing Procedures 9.1 General Content and Format The licensee has developed 22 procedures that may be used to implement the emergency plan during an actual emergency. * These procedures were reviewed to ascertain the adequacy of the general content and forma In this regard the auditors noted that the procedures do not clearly specify the individual or organizational element having the responsi-bility and authority for performing the tasks covered by the particular

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procedure Within the procedures, emergency action levels and pro-tective action guides were clearly specified as were the emergency actions or protective actions to be implemente The procedures were weak in spedfying the actions to be performed by Headquarters, contractor, private organization, and local services *

support. They did not include such aspects as the requirements* for coordination with other elements of the licensee's emergency organi-zation, procedures for site access, precautions to be. observed and limits to the authorities responsibilities and actions of these gro~ps.

. Generally t~e action steps in the licensee's emergency plan implement-ing procedures were clearly dfsplayed in a step-by-step sequential fashio They generally described and highlighted prerequisites and conditions that should exist before the specified actions of the pro-cedure are to be performed and highlighted precautions to be observed during performance of the action The procedures did, however, exhibit an obvious deficiency in the area of providing guidance to users regarding when they are permitted to exercise judgement in the implementation of specific actions, in the interpretation of *emergency action level, in the application of protective action guides or in making recommendations relating theret For example, procedures governing accountability did not address act ion.1eve1 s under which assembly areas should be evacuate This decisi-0n is esse~tially left to the judgement of the emergency coordinato Such action l~vels were not specified, nor were guide lines provided for the emergency coordinator to use in making such judgement Procedural steps which require other functions or jobs to be performed, or which are supplemented by other procedures already in existence but are not part of the emergency plan implementing procedures, con-tain references to the specific procedures that are applicabl Gene-rally these references appear in the body of the procedure at the point*

where implementation of the other function or procedures is to be per-formed or considere There are signoff sheets, check lists and data sheets to document that the actions described in the procedures have been completed~ A review of these sheets, however, indicated some inadequacies in their form and conten These inadequacies are discussed further in a subsequent sectio In reviewing the emergency response scheme the auditor discussed and reviewed the plant emergency operating procedures to ascertain whether these procedures contained a step in the immediate action section to require evaluation of the emergency conditions relat1ve to the emer-gency action levels contained in the emergency plan implementing instruction The auditors noted that emergency operating procedures do not reference emergency plan implementing instructions or contained*

instructions for classifying the situation and 1mplementing appropriate implementing instructions of the emergency pla Consequently, the interface between the.emergency operating procedures and the emergency

plan *implementation procedures is not clear, making implementation of

the plan at the appropriate level difficult and cumbersome in the ini-tial stage *

9.2 Implementing Instructions There *is a separate procedure for each class of emergency specified in the licensee 1s emergency pla The classification system presents a graded response, with each implementing instruction clearly specify-ing the emergency action levels and preplanned response actions required to be considereo or implemented in response*to each class of emergenc Many of the emergency action levels are based on readily available information available to operators in the control roo However, the usefulness of these action levels is reduced since, as previously men-tioned, the interface between the emergency operating procedures and the emergency plan implementing procedures is wea Each of the procedures governing a particular class of emergency gene-rally orchestrates the 1mplementation of other more specific procedures that have been developed to implement or support the ~mergency pla Implementing instructions for each emergency class indicate however, they are not written from the viewpoint of and for use by the emergency coordinator such that the emergency coordinator 1s duties, responsibi-lities and actions are clearly specified. These procedures imply that all action statements are to be performed by the emergency coordinator himself rather than stating the necessity for directing that such actions be performed by the appropriate emergency organizational e*le-men In this _sense the implementing instructions are weak in that the emergency coordinator 1s specific duties are not clearly specified as action statements but rather are more implie.3 Implementing Procedures In addition to a review of the, implementing instructions for each class of emergency, the auditor also reviewed specific implementing procedures that would be followed and used by specific functional elements and individuals within the emergency organizatio Each of the particular areas of interest are discussed individually belo.3. 1 Notifications Generally, the sequence of notification to alert or mobilize the onsite emergency organization,and supporting agencies was described

for each class of emergency listed in the implementing instruction Important notifications that are immediate in nature and the respon-sibility of the emergency coordinator or shift operating crew are incorporated into the steps of the implementing instruction The specific person (by title or function) responsible for making these immediate notificati.ons, however, is not specifie Action* levels are specified for notification of the site emergency organization, local services support and for participating local, state and federal governmental agencies who support the licensee's response progra Notification procedures and provisions were some-what weak in that they do not specify action levels for notification of the corporate, contractor, or private agency support relied upon to support the site respons Preplanned messages, announcements and alarms are used for initial notifications. Initial notifications to the State of New Jersey are made through a dedicated phone to the New Jersey State Polic Noti-fications to the State of Delaware are made through the NAWAS tele-phone lin Notifications to Lower Alloways Creek Township govern-mental officjals are made through a direct-line telephon Notifica-tion of onsite personnel at the time of the emergency is accomplished through the use of a series of separate. and distinct alarms and announcements over the station pag On backshifts or during other periods of minimal staffing, telephone is used to contact members of the site emergency organizatio The licensee's emergency duty offi-cer is accessible 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day by beeper or hard-wired telephon As mentioned previously, there are preplanned messages included for initial notification In some cases, the content of the applicable message is included in the relevant procedur In other instances,*

the content of the message is not... Notification procedures contain 1 i stings of a 11. persons and agencies who are included in the response schem Additionally, the means to be used to make such contacts are also specifie Where telephone is to be used, telephone numbers are listed, and there is an authenications scheme for initial notifications to the State of New Jerse.3.2 Offsite Radiological Surveys The methods, equipment, arid the preplanned survey points for emergency offsite radiological surveys are clearly specified in the procedures governing the activities of the offsite radiological survey team While the procedure contains a f-""~m for team members to record qata and information gathered during offsite surveys, the form did not con-tain certain specific elements of information that may be needed to properly assess environm~ntal condition Noted omissions on data sheets were: the date and time the survey is performed, the name(s)

of the individuals who perform the survey, the instrument used (to

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include type and serial number), the mode in which the instrument was used, (e.g., window open or window closed), the duration of any meter readings, air sampler flow rates, background radiation levels at the t.ime of air sample counting~ and sample count tim The auditors also noted that there were neither provisions for label-i.ng each environmental sample for later identification, nor a descrip-tion of how c~llected data (to include the original data sheets) are

. to be provided to the organizational element responsible for emergency radiolo~ical assessment function A central coll~ction point* has not been established for the return of envi~onmental samples collected by the offsite survey team The primary means of communication for offsite teams is portable radi Backup means, should radio failure occur, are not specified in the plan, nor have such provisions been considere The auditor also noted that while the licensee does have one van available, the provisions for transportation of the team was not clearly specifie This would be of particular importance in the event two or more offsite teams would be neede.3.3 Onsite (Out of Plant) Radiological Surveys The auditors noted that there are no specific procedures for the per-formance of onsite out-of-plant radiological survey *

9.3.4 In-plant Radiological Surveys A review of the entire emergency plan and implementing procedures indicated that the provisions for in-plant radiological surveys during emergencies have not been specified *

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9~3.5 Personnel Monitoring and Decontamination Procedures available for personnel monitoring and decontamination do not clearly specify the provisions for monitoring all individuals leaving restricted areas or areas known or suspected to be contami-nate (e.g., at the in-plant assembly points or offsite should the site be evacuated).

There are no provisions for recording the names of individuals who are surveyed, the extent of any contamination found, the instrument to be used for the survey effort and the results of any decontamination efforts. Discussions indicated that the contami-nation levels that normally require decontamination are 1000 counts above backgrtiund, however, such levels are not specified in the per-sonnel monitoring and decontamination procedures nor are considera-tions for high background discusse I I

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Additionally, personnel survey procedures do not include or reference decontamination procedures for various levels and types of contamina-tio Discussions with licensee personnel indicat~ that routine ope-rational decontamination procedures would be used, however, these pro-cedures were not readily available at assembly areas o.r offsite where such decontamination may have to be performe Additionally the audi-tor noted that action levels were not clearly specified which would require fu~ther assessment of a contaminated individual's dose, nor

.was there a designated element of the emergency organization respon-sible for performing the followup assessmen As in the case of offsite survey data, the means for providing col-lected personnel monitoring data and information to the individual or organizational element responsible for the radiation protection pro-gram during emergencies was not describe This is primarily due to the fact that the licensee's emergency organization does not include provisions or assignment of responsibility for the continued perfor-mance of environmental health physics functions as dosimetry, decon-tamination, dose assessment, etc. This is discussed further in a sub-sequent sectio.3.6 Evacuation of Onsit~ Area The licensee's emergency plan implementing procedures do not clearly specify action levels that wi 11 require evacuation of particular areas, building$, or the sit This is a judgement call left to the discre-tion of the Emergency Coordinato As mentioned previously, the implementing instructions do not contain guidance for the Emergency Coordinator's use in making ~uch judgement During a tour of the licensee's facility, the auditor noted that eva-cuation routes were not marked either through posted arrows, signs, floor markings 9r other readily vi~ible means and that evacuation to a predesignated assembly area relies solely upon an individual's familiarity with the plan Additionally, procedures covering evacua-tion of onsite or in-plant areas do not specify the particular loca-tions of the assembly areas and the criteria for their us There

are no provisions for concise oral announcements over the facility public address system or other provisions to describe the immediate actions of nonessential personne These actions are covered in site specific trainin Procedures dictate that upon the sounding of a radiation alarm, all individuals remain at their location until given instructions from the control roo Announcement~ or instructions are prepared on an ad hoc basis depending upon conditions existing at the tim.3.7 Personnel Accountability The licensee's provisions for personnel accountability during emergen-cies involve procedures in two areas, the emergency plan and securit (

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5_3 Emergency plan implementing procedure EP I-13, Personnel Accountabi-lity, is general in nature.-

The specifics of how accountability is to be accomplished are covered in security procedure and "post orders.

The auditor held a discussion with security personnel at the Salem site to ascertain the exact method by.which accountability is accom-plishe As a result of these discussions, the auditor determined ttiat the actual accountability procedures for individuals were in the form of "post orders." Post orders are not approved station proce-dure A book c6ntaining a current fisting of individuals who.are badged at the *salem site and a post order for accountability is located.at each assembly poin These post orders are not approved procedures in the sense of regular security procedures but are gene-rated by the security department and placed at the assembly areas in*

the aforementioned book The overall responsibility for accountabi-lity is assigned to the security force at the Salem sit However, during discussions with security individuals it became apparent that the security force does not conduct accountability at all accountabi-lity station location The normal procedure is for a security guard to report to the cafeteria where he conducts the accountabilit At other locations where assembly has taken place that is in the control room, in the monitoring room, any individual who happens to be aware that the "post orde~' book and list of personnel are located there, performs accountability-and reports to_ the Emergency Directo A review of records of emergency drills conducted in September 20 and September 26, 1979 indicate that accountability times range from approximately 45 minutes to one hour and a ha 1 In the former dri 11,

the first accountability was complete within 45 minutes, with final accountability within 70 minute On the subsequent drill, the account-ability still had not been completed by the time the drill had termi-nate Further discussions with licensee personnel indicate that a key card access system, which has.. been recently installed, wi 11 be used to assist in accountability efforts in future revisions of accountability procedure The auditor noted that accountability procedures do not contain pro-visions for continuous accountability of individuals who may be required to enter the site or be on site after the initial accountabi-lity has been complete Discussions with security and licensee man-agement personnel indictated that continuous accountability provisions will be included in a subsequent revision to the emergency plan imple-menting procedure *

9.3.8 Assessment Actions The system for gathering information and data upon which to base deci-sions to escalate, deesca.late, take corrective actions or recommend

protective actions to onsite and offsite individuals consists of efflu-ent monitors, area and process monitors, and offsite environmental

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surveys performed by emergency team personne Applicable procedures identify the sources of information needed or expected to be available from area and process radiation monitor readings, meteorological instru-*

ments and offsite radiation surveys.. There are provis.ions for ini-tially assessing ciffsite radiological consequences in the event plant effluent monitors are offscale or inoperabl The radiological assess-ment procedures are deficient, however, in describing similar infor-mation from in-plant radiation survey teams, plant chemistry and plant operating parameters..

The action levels and protective action guides to be used by assess-ment personnel as a basis for considering or initiating emergency measures or for terminating or mitigating the actual. or projected consequences of an emergency are limited primarily to action levels and protective actions applicable to offsite areas.* Procedures are noticeably weak in specifying action levels and protective action guides to be used by assessment personnel for considering or initiat-ing onsite and in-plant emergency measure Assessment _procedures contained a means for rapidly projecting expo-sures and exposure rates to the whole body and thyroid of individuals*

located in the environs*of the plant. These projections can be made*

initially based upon installed control room instrumentation with veri-fication and subsequent additional information and projections made based upon environmental surveys performed by emergency team member Procedures contain provisions for immediate notification of state and local agencies in the event an initial radiological assessment action indicates an actual or potential exposure to the whole body or thyroid of persons in the environs in excess of limits of the protective action guides established by the State of New Jerse While there are no clear provisions for trend analysis of all assessment data, there are provisions for continuous update of assessment information to offsite agencies who are responsible for implementing assessment and protec-tive actions in behalf of the general populatio Procedures relating to the assessment of offsite radiological conse-quences are limited to radiation data from survey teams and do not address the actual or intended use of the environmental monitoring program and the incorporation of environmental TLDs, soil, vegetation, water and animal feed sample This aspect is discussed further in the following paragrap.3.9 Radiological and Environmental Monitoring Program The licensee has developed conceptual provisions for a radiation environmental monitoring program to be implemented during emergen-cie This program, however, has not been formalize The assign-ment of duties for the direction of the program and for the collec-tion and evaluation of data under*emergency conditions are incomplet *'

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As such, the licensee does not have a management cqordinated struc-ture for a total emergency environmental monitoring progra The licensee appears capable of conducting an initial emergency moni-toring program, i.e.. air samples and direct radiation readings in the environs by emergency teams, but it does not appear that an expanded emergency* environmental monitoring program could efficiently be imple-mented on an emergency basi Discussion with licensee personnel

responsible for emergency planning indicate that corporate personnel are involved and would support the expanded environmental monitoring progra A.future revision of the emergency plan and implementing procedures will specify those individuals who will be responsible for the total radiation environmental monitoring program in support of emergency operation *

9.3.10 Onsite First Aid Rescue.

Procedures covering onsite first aid and rescue specify the methods for receiving, recovering, transporting and handling injured persons who may also be contaminated.* The interface and action ievels for using the offsite medical treatment facilities are also clearly speci-fie *

9.3.11 Security During Emergencies General discussion with security personnel indicate that the security measures to be p 1 aced into effect during emergencies have not be fully develope The licensee has prepared and submitted a Security Contingency Plan in accordance with the requirements of Appendix C to 10 CFR 7 The auditor reviewed the applicable portion of this pian related to operations during emergencie The licensee indicated that when the plan is implemented considerations for security during emer-gencies as well. as for compensatory security measures should the secu-rity checkpoint or other security equipment not be available due to evacuation of the facility or radiological conditions would be included in the procedure.3. 12 Radiation Protection During Emergencies The auditor reviewed the licensee 1s general provisions for radiation protection during normal operations and held discussions with licensee personnel to ascertafo the nature of the radiation protection program under emergency condition The inspector noted that the emergency plan and implementing procedures contained little information regarding radiation protection during emergencies~ Information was limited to emergency risk doses for equipment and lifesaving activitie In this regard, the auditor held discussions with radiation protection manage-

. ment to determine whether all or part of the procedures and plans for routine operations would continue during emergencie Based upon these

56 discussions, the auditor determined that this area had not been clearly thought out *and integrated into the emergency response schem From

- reviewing routine radiation protection procedures, the auditor noted that these procedures did not clearly reflect their applicability during emergency situation The licensee had given.some preliminary thought to approaching the problem of continuity. of radiation protection during emergencies and had developed an organizational concept that would be implemented to

administer the program under emergency conditions. Within this pro-gram and conceptural development, such areas as personnel dosimetry, exposure records, positive access controls, instructions to emergency workers (1 i censee as well as contractor), dose assessment, and provi-sions for preventing reexposure of individuals or limiting exposures through ALARA review of emergency operations, had all been considere Since this aspect of the emergency operation has not been clearly defined either organizationally or procedurally, if a serious accident were to occur at the Salem Nuclear Generating Station, emergency ope-rations could be severely hampered or restricted until ad hoc emergency radiation protection control measures could be established and imple-mente.3. 13 Recovery Procedure EP I-20, 11 Recovery Operations, 11 provides very broad.guidance tc the Emergency Director in considering and implementing a recovery mode of operatio The auditor noted, however, that the organizational authority is not clearly specified for declaring that recovery phase

. is to be entered~ Additionally, there are no action levels or guid-ance for evaluating plant operating conditions as well as in-plant and out-of-plant radiological conditions in making a decision to de-escalate from an emergency to a recovery operation phas While the recovery procedure does provide for notifying the control room that recovery to be entered, it does not provide for prior coordina-tion with or notification to the remainder of the licensee 1 s emergency organization or supporting federal, state, local and corporate organi-zations and group.3. 14 Firefighting Procedures governing firefighting at the Salem site contain a descrip-tion of the responsibilities and action levels for offsite firefight-ing suppor Procedures also include instructions for monitoring the exposure to radiation of any offsite personnel, site access procedures, and the command and control aspects under which the offsite agency wi 11 functio \\

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9.i 15 Repair and Corrective Actions The licensee's emergency plan implementing procedures do not contain clear provisions for the conduct of repair or corrective actions.*

that may be needed during an emergency situation. While the proce-dures.discuss reentry in a general.sense, specific procedures governing repair* teams or other teams who may be directei:i to perform a mainte-nance operation to mitigate or terminate consequences of the event are not specifie *

Thi-s is discussed further in the section on the emergency organizatio.4 Supplementary Procedures The licensee has developed several supplementary procedures designed to ensure a state of continued readiness at the Salem facilit These procedures include provisions for: inventory, operational check and calibration of emergency equipment, facilities and supplies; training; the conduct of drills; provisions *for review, revision and update of the emergency plan and implementing procedures; and for conducting periodic audits of the emergency plan and its implementatio Each of these generic areas are discussed separatel.4. l Inventory Operational Check and Calibration of Emergency Equipment, Facilities and Supplies The procedure governing the aforementioned operations contain an inventory 1 i sting and 1 ocat ion of a 11 equipment he 1 d in reserve for use during emergencie The inventory and check of emergency equip-ment is accomplished at a quarterly frequency and the responsibility for performing the emergency equipment readiness checks and for cor-recting any noted deficiencies is.clearly delineated. The auditor reviewed the most recent inventory conducted on this emergency equipment and noted that all equipment had been inventoried and was properly maintaine.4.2 Drills Drills at the Salem site are administered by the emergency planning coordinator in accordance with procedure EP II-Prior to each drill a scenerio is develope As part of the drill, observer comments are documented for subsequent evaluation and discussion during a critiqu Comments are then consolidated and responsibility is assigned for corrective actio The licensee has a mechanism for management control which assigns the responsibility for corrective actions and a completion dat In reviewing the documentation and evaluation of observer comments from two past drills conducted in September 1979 the auditor noted that several of the comments made by observers appeared substantive but were not subsequently trans-posed from comment sheets for action or evaluatio Discussion with

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licensee management indicated that during the critique, a number of these observations were resolved (apparently to the satisfaction of the observers), thereby negating the necessity for subsequent review and corrective a*ctio The auditor noted that thi.s was not clear from available qocumentation and that several of the observer comments appeared to be significan The Septe~ber 20 and 27, 197~ drills noted 12 drill deficiencie At*the time of this audit, nine of the deficiencies remained open, two had been closed with no action, and one was closed by a discussion with personnel involve The auditor.observed that this discussion took place some 10 weeks after the drill, giving the auditor cause for concern over the excessive amount of time which had intervened between the identification of a problem area a~d its ultimate reso-lutio Of the 12 identified drill deficiencies, six items had a January 15, 1980 completion date, consequently, many of these items*

had passed completion date with no indication of actio In this regard, the auditor has identified a need for increased management control in the area of documentation, followup, and timely resolution of dri 11 identified improvement area *

In discussin~ the drill concept with licensee management, the auditor learned that there were no provisions in the licensee's procedures for a backshift dri11* and that no backshift drills have been conducte The licensee stated, however, that such considerations would be made in the futur.4.3.Review, Revision and Update Procedures governing the review, revision and update of the emergency plan and implementing procedures provide for updating and review of telephone numbers on a six month basi All procedures which implement the emergency P.lan are reviewed at least once each calendar year to incorporate changes resulting from dri 11 s or changes in the f aci 1 i ty itself or the facility environ The responsibility for the review is specified a~d assigned to the Assistant to the Manager who also functions as the Emergency Planning Coordinato A review of the licensee 1s current plan and procedures indicate that they had been reviewed and updated as require Additional review indicates that changes have been distributed in accordance with the approved distri-bution list and that procedure distribution was correc.4.4 Audit The Salem Nuclear Generating Station has prov1s1ons for auditing the emergency plans and implementing procedures on a routine basi The Nuclear Review Board conducts an annual audi Observation of an emergency drill is included as part of this audit and comments of the audit team in addition to those of the observers that are normally required by the drill procedure are evaluated for corrective actio *

.. 5_9 10.0 Management Oversight There is a formal audit program administered by the Station Quality Assurance Departmen The program is described in AP-17, Operational Quality Assurance Program.* Implementing procedure OI-5, Audits, provides for an annual audit of the Radiation Protection activit The last audit performed in this area, 79-3-Nl-13, Radiation Control, was on August 31, 1979, ahd identified many problem areas within the Radiation Protection Program:

These included: *

(a) deficiences in the revision and review of Radiation Protection Instructions; (b)

an inadequate portable instrumentation accountability program; (c) a lack of equipment to support the respirator protection program; (d) the failure to provide for a Radioactive Waste Management progralJ1 and assign responsibility for the program; (e) a failure to implement a system to assure that revisions of procedures are brought to the attention of department personnel; (f) failure to acceptably document instrument calibrations; and (g) failure to develop Radiation Protection instructions regarding HP trai ni.n Three other audits were also reviewed:

79-3-J.l-8, Waste Management, dated March 1, 1979 79-3-C.2-10, Appendix 11 8 11 Technical Specifications, dated June 30, 1979 79-3-C.2-15, Appendix 118 11 Technical Specifications, dated September 30, 1979 The audit findings appear to have been one of the primary motivators in the general upgrading of the Radiation Protection Progra Each audit item has been asigned to an appropriate management individual for correction and is subjected to followu The major weakness noted in the audit program is that none of the auditors-are specialists in matters pertaining to Radiation Protec-tio While the auditors are qualified, trained and able to verify

adherence to procedures, they are generally not able to ascertain the technical accuracy of the procedure and must rely on the Radiation Protecti9n grou It was noted that there has not been a peer review of the Radiation Protection program since the plant was made operational

in 197 *

It is recommended that such an independent peer review be scheduled in the current audit plan to ascertain the technical adequacy of the progra Contracted Services The contracted service, RSI, provides the majority of the staffing and is given the predominent responsibility in most normal, off-normal and emergency situations. The only evaluation of contractor personnel is a review of resume's performed by the Senior Supervisor - Radiation Protectio No selection or qualification criteria are used except for classifying the technicians capable of performing in a responsible position in accordance with ANSI-N1 No formal training in the HP specialty is required or provided by either the contractor or the licensee, and unless the individual was and had previous training, the only other training to which the person is subjected is on-the-job. This item is further discussed in Section 2.0, PERSONNEL SELECTION, QUALIFICATION AND TRAININ *

References:

(a)

ANNEX A EXIT MEETING AND LICENSEE COMMITMENTS Letter from F. P. Librizzi, General Manager, Electric Pro-duction, to B. H. Grier, Director, NRC Region I (Phila-delphia), dated March 7, 1980. Subject: Health Physici~t Availabilit (b)

Letter from F. P. Librizzi, General Manager, Electric Production, tb B. H. Grier, Director, NRC Region I (Phila-delphia), dated March 24, 1980. Subject: Radiation Pro-tection Program, Salem Generating Statio (c)

Letter from E. H. Crosby, General Manager, Rad Services, Inc., to H. M. Midura, Salem Station Manager, dated March 21, 198 On February 26, 1980 a meeting was held at the NRC Region I (Philadelphia)

Office between Mr. F. P. Librizzi, Vice President, Electric Production, PSE&G (with principal members of his staff), and Mr. J. M. Allan, Deputy Director, NRC Region I (with other members of that office).

.

The purposes of the meeti_ng was to summarize the findings of the appraisal, to highlight particular concerns and to solicit commitments from the licensee regarding improvements in the Radiation Protection Progra To this end the following commitments were made:

Item of Concern Lack of a viable alternate to the RPM to act in his absenc Licensee Action Reference (a) provides the licensees commitment to estab-lish the Corporate Health Physicist as an alternate to the RPM on an interim bases until a qualified alternate was acquired as a member of the station's staf In further clarifications of this interim action, the licensee agreed to establish methods to keep the Health Physicist current on the Radiation Protection Pro-gram and radiological status of the facility (including communica-tions with the RPM and onsite reviews).

Item of Concern*

Inordinate reliance on contracted health physics personne Lack of stabilization of contractor work force particularly supervisory personne Lack of any training prov1s1on for contracted health physics personne Lack of an established retraining program for PSE&G and contractrir personnel in the Radiation Pro-tection grou Lack of any description of the overall training system an associated documentation requiremen Licensee Action Reference (b) provides the licen-see's commitment to develop a plan along with an implementing schedule to reduce dependence on contracted personnel by July 1, 198 Reference (b) provides the licen-see's commitment to stabilize contracted supervisory personnel in accordance with a new agree-ment negotiated with the con-

. tractor's organization as docu-mented in Reference (c).

Reference (a) provides a licen-see's commitment to establish a traini.ng program for all con-tracted health physics personne Such a program was implemented on March 1, 198 Reference (a) provides the licen-see's commitment to provide an annual retraining (requalifica-tion) program for all radiation protection personne Reference (a) provides the licen-see's commitment to revise the Stations Performance Department Manual by March 14, 198 *

ANNEX 13-.

PERSONS CONTACTED Principal Licensae Parsonnel F. Librizzi, Vice-President, Electric Production, PSE&G H. Midura, Station Manager H. Heller, Manager, N~clear Generation, PSE&G J. Zupko, Chief Engineer R. Silverio, Assistant to the Manager L. Miller, Station Performance Engineer N. Millis, Health Physicist, PSE&G R. Swetnam, Senior Performance Engineer - Health Physics J. Ge 11 er, Senior Performance E_ngi neer - Chemistry Other Persons Contacted E. Nielsen, Administrative Assistant, RSI R. Shult, Procedure Coordinator, RSI W. Schwenn, HP Instructor, RSI W. Hunkele, Technical Supervisor, Salem P. Greenbaum, Technical Supervisor, RSI D. Godlewske, Technical Supervisor, Salem F. Huwe, Techni ca 1 Supervisor, RS I E. Surmacz, Rad Waste Assistant, RSI In addition, other personnel (technicians, operators and contractors) were interviewed by the auditors of the performance of this appraisal *

*---

ANNEX *c'

DOCUMENTS REVIEWED Title V, Code of Federal Regulations, Chapter 1 NUREG-0578, TMI Lessons Learnec;i Task Force Status *Report and Short-Term Recommendations Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Requirements {Opera~

tions), February 1978

Regulatory Guide 8.14, Personnel Neutron Dosimeters ANSI N-13.11, Criteria for Testing Personnel Dosimetry Performance ANSI 18.1-1971, "Selection and Training of Nuclear Power Plant Personnel" ANSI N323-1978, Radiation Protection Instrumentation Test and Calibration ANSI N324, Performance of Thermoluminescence Dosimetry Systems ANSI-N-343, Internal Dosimetry for Mixed Fission and Activation Products Technical Specifications 50-272 Station Performance Department Manual Statton Radiation Protection Manual Station Administrative Procedure AP-17, Operational Quality Assurance Program Implementi.ng Procedure OI-5, Audits Audit 79-3-Nl-13, Radiation.Control, dated August 31, 179 Audit 79-3-J.1-8, Waste Management, dated March 1, 1979 Audit 79-3-C.2-10, Appendix 118 11 Technical Specifications, dated June 30, 1979 Audit 79-3-C.2-15, Appendix 118 11 Technical Specifications, dated September 30, 1979.

Station Administrative Procedure AP-24, Radiological Safety Program Station Procedure PD-3.5.001, Sampling of the Reactor Coolant

Station Procedure PD-3. 5. 061, Sampling the Containment Atmosphere Station Proced1,1re PD-3.8.016, Gaseous Radwaste Release Calculations, Rev. 2 Sta ti on Procedure P D-15. 1. 010, Radiation Signs and Barriers Station Procedure PD-15.1.012, Post Operation Debriefing Station Procedure PD-15.1.013, Radiation Exposure Permit/Extended Radiation Exposure Permit Station Procedure PD-15.2.001, New Station Employee Indoctrination Station Procedure PD-15.2.012, TN Retraining Station Procedure PD-15. 2. 013, TN Training Requirements Station Procedure PD-15. 2.002, Visitor and Contractor Indoctrination Station Procedure PD-15.3.002, PSE&G Personnel Registration and TLD Issue Station Procedure PD-15.3.003, Contractor Registration and Dosimetry Station Procedure PD-15.3.004, Self Reading Pocket Dosimeter Reading and Rezero Station Procedure PD-15.3.006, TLD Exposure Determination Station Procedure PD-15.3.007, Periodic TLD Card Exchange Station Procedure PD-15.3.012, Response Check onQTLD Material Station Procedure PD-15.3.014, Alert System for Personnel Exposure Control Station Procedure PD-15.3.017, TLD Termination Station Procedure PD-15.3.019, Lost-Damaged Offscale Dosimeter or TLD Station Procedure PD-15.3.020, Report of Over-Exposure to Ionizing Radiation Station Procedure PD-15.3.021, Special Personnel Monitoring Station Procedure PD-15.6.008, Use of Portable Shielding Station Procedure PD-15.7.008, Handling and Tagging of Samples Station Procedure PD-15.9.002, Background and Efficiency Determination on BC-4 and SCA-4 Counting Instruments

Station Procedure PD-15.9.004, Calibration of the Radiation Monitor, Model RM-14 Station Procedure PD-15.9.009, Calibration of Eberline Portable Neutron Rem Center, PNR-4 Station Procedure PD-15.9.011, Calibration of. Teletector 6112 Station Procedure PD-15.9.023, Calibration of Snoopy NP-2 Neutron Meter Station Procedure PD-15.11.009, Bioassay Program Salem Generati_ng Station Emergency Plan.

Emergency Procedure EP-I-20, Recovery Operations Emergency Procedure EP-II-1, Conducting Emergency Pl an Ori 11 s

v t e Inspection Report - Salem - 1980003
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1980 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 10(0) 11(0) 12(0) 13(0) 14(0) 15(0) 16(0) 17(0) 18(0) 19(0) 20(0) 21(0) 22(0) 23(0) 24(0) 25(0) 26(0) 27(0) 28(0) 29(0) 30(0) 31(0) 32(0) 33(0) 34(0) 11(0) 15(0) Security Operator Exams Emergency Planning Other

IR 05000272/1980003

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