IR 05000272/1981030
| ML18086B392 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/11/1982 |
| From: | Knapp P, Mcbride H, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18086B391 | List: |
| References | |
| 50-272-81-30, NUDOCS 8204020448 | |
| Download: ML18086B392 (13) | |
Text
Report N Docket N U.S. NUCLEAR REGULATORY COMMISSION 50-272/81-30 50-272 Region I License N DPR-70 Priority Category c
Licensee:
Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101
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Facility Name:
Salem Nuclear Generating Station, Unit l Inspection at:
Hancocks Bridge, New Jersey Inspection conducted:
November 23-25, 1981 Inspectors: y, -~-
~r: Plumlee, Radiation Specialist J; (If /?"/--
date signed
~cYc_
3 /11 le:A date signed Approved by:
igned Inspection Summary:
Inspection on November 23-25, 1981 (Report No. 50-272/81-30)
Areas Inspected:
Routine, unannounced inspection of preparations for radiation protection during refueling including:
Procedures, advanced planning and preparations, training, exposure control, respiratory protection program, posting, radioactive and contaminated material control, surveys, independent measurements, and outstanding items from previous inspection The inspection involved 48 inspector-hours on site by two NRC regional based inspector Results:
No items of noncompliance were identified.
a2o4o2o448-a2o:f15 PDR ADOCK 05000272 G
DETAILS Persons Contacted W. Britz, Corporate Health Physicist
- A. Darelius, Quality Assurance Engineer
- J. Driscoll, Chief Engineer
- J. Jackson, Reactor Engineer H. Midura, General Manager, Salem Operations
- J. O'Connor, Radiation Protection Senior Supervisor A. Oguruk, Technical Supervisor
- J. Stillman, Station Quality Assurance Engineer
- denotes presence at the exit interview conducted Novemb~r 25, 198 Licensee Action on Previously Identified Items (Closed) Inspector follow item (80-28-01):
Review the adequacy of the licensee bioassay procedures to identify any significant uptake of alpha or pure beta activit No alpha activity is evident in the sample analyses and survey record The ratio of readily detectable gamma activities, such as Co-58, co~60, Cs-134, Cs-137, and I-131, to pure beta emitters other than tritium is greater than 500 to one. The action levels to initiate whole body counts are based on access to the controlled area, work in highly contaminated areas, exposures to airborne radioactive materials, and contamination of an individual's skin, face, or nos Exposure to tritium is identified by air sampling and liquid waste analyse No risk of unidentified uptakes of radioactive materials was eviden (Closed)
Inspector follow item (80-28-02):
Review the evaluation by the licensee of skin exposures to two individual The licensee letter dated August 21, 1981, contained the revised results of exposure estimates for the skin, eyes, and various organs of the two individuals involve Review of the method of analysis did not identify any discrepancie No overexposures were identifie No problems with the licensee evaluations were identifie (Closed)
Items of noncompliance (80-28-03, -04, -05):
Failures to survey to assure compliance with 10 CFR 20.103 (a)(l) and (b)(l) and 10 CFR 20.10 The inspector verified the completion of the corrective actions stated in the licensee letter dated March 13, 1981, applicable to the fuel transfer tube entry on October 4, 198 The inspector also reviewed recent entries into airborne radioactive materials areas. No problems were identifie (Closed)
Item of noncompliance (80-28-06):
Failure to tag a door to restrict entry to an area with radiation levels in excess of 100 rem/hr.,
which resulted in three individuals entering the area. The inspector verified the completion of the corrective actions stated in the licensee letter dated March 13, 1981, applicable to the entry into the area under the in-core detector seal table on October 10, 198 ~~----------------------** -,
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(Closed)
Items of noncompliance (80-28-07, -09):
Failures to inform workers of the hazards and the precautions necessary on entering the fuel transfer tube on October 4, 1980, and the area under the in-core detector seal table on October 10, 198 The inspector verified the completion of the corrective actions stated in the licensee letter dated March 13, 198 (Closed)
Item of noncompliance (80-28-08):
Failure to control the entries into the fuel transfer tube by issuance of a radiation exposure permit required by Sections 6.11 and 6.13 of the Technical Specifications, and the implementing procedure The inspector verified the completion of the corrective actions stated in the licensee letter dated March 13, 198 (Closed)
Inspector follow ite~ (80-28-10):
Review of the control of the exposures of individuals whose Form NRC-4 information is incomplete. The licensee procedural administrative limits on exposures are below the limits prescribed by 10 CFR 20.lOl(a) and (b) and these limits are printed by the computer with the dosimetry update The computer printout flags any individual approaching the administrative limit, requiring a review and either an increased limit or appropriate control to prevent exceeding the administrative limi The controls appeared to be effective.
(Closed)
Inspector follow item (80-28-11):
Review the adequacy of contract employee resume The inspector reviewed ten resumes provided by contract health physics technician These were specific as to dates of previous employment and job assignment No examples were found of the licensee allowing credit for experience without an adequate basis in the resum (Closed)
Item of noncompliance (80-28-12):
Failure to require a health physics qualified individual to accompany the entries, or to carry the required survey equipment, during the entries into the fuel transfer tub The inspector verified the completion of the corrective action described in the licensee letter dated March 13, 198 (Closed)
exposure facility No items Inspector follow item (80-28-13):
permits (REP) and sign-in sheet and observed the records and work of noncompliance were identifie Review the use of radiation The inspector toured the practices during this inspectio The inspector reviewed with the licensee an apparent example of a contractor employee entering the Hot Machine Shop on January 13, 1981, without signing in on the REP, documented in a letter dated August 3, 1981, to the worke The licensee 1 s corrective action to prevent any recurrence appeared to be effective.
(Closed)
Inspector follow item (81-20-01):
Review of the completion of commitments to implement a formal health physics training progra The inspector verified that the Personnel Training Manual was revised by
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September 1, 1981, and that the administrative procedure on training was being revise All of the elements of a formal training program were evident in the apprentice training program being conducted by the Training Departmen Retraining of health physics technicians was conducted without some of the elements of a formal progra As an example, no documented periodic verification of their continuing proficiency was maintained other than routine performance review There was no official retraining program outlin The licensee has contracted with a con~ultant to review and formulate a program by March 1982 that should include the retraining of these individual.
Radiation Protection Procedures The inspector toured the facility to review the licensee's procedural control of radiation work pursuant to the requirements of Technical Specifications Section 6.8, 11 Procedures, 11 and 6.11, 11 Radiation Protection Program, 11 during preparations for the outag The radiation protection procedures were reviewed during inspections 50-272/81-20 and 50-272/80-03, and the subsequent changes have been reviewed. No procedural changes were made or planned as part of the refueling outage preparations.
Review of the status of the maintenance and modification procedures showed the planning engineer was initiating the procedures for jobs not previously performed at this sit The ALARA team was reviewing each job to identify any means of reducing the exposures to personne The review and authorization of procedures for the outage, and the draft outage procedure plan, appeared to comply with the licensee's administrative procedures and the technical specification No violations were identifie.
Advance Planning and Preparation for the Outage Increased Health Physics Staff Technical Specification Section 6.3.l requries that each member of the facility staff meet the minimum qualifications of ANSI Nl8.l-1971 for comparable positions, except for the Radiation Protection Senior Supervisor who must meet or exceed the qualifications of Regulatory Guide 1.8, September 197 The licensee letter dated September 24, 1981 documented the Radiation Protection Senior Supervisor's credential Review by the inspector did not identify any discrepancies.
The Radiation Protection Senior Supervisor stated that, as of November 24, 1981, he headed a department of about 105 personne This included seven supervisors and technical assistants; about 60 personnel required for routine two-unit operation (radiation protection technicians, chemists, clerks, etc.); 30 personnel required at the time for non-routine jobs; and 8 personnel to prepare for the coming outag About 40 of the 150 were PSEG employees, including a few who were in full-time apprentice training, and more than 60 were contractor personne The licensee plans to hire about 35 additional senior contract health physics technicians and 25 junior level technicians and clerks for the outag The inspector verified by review of 14 contractor personnel files including resumes, training records, and job assignments that the assignments were consistent with the individual 1 s experience and trainin No violations were identifie Radiation Protection-Related Staff A licensee representative stated that an 18-man crew from Hydro-Nuclear Services was on site to perform housekeeping, collection of trash and contaminated materials, waste packaging, and area decontaminatio More will be hired during the outag A four-man crew was contracted to operate a leased portable (trailer-mounted) protective clothing laundry facility during the outag Three Chem-Nuclear Services employees were processing water through a demineralizer purification syste The licensee plans to train PSEG employees on this jo No violations were identifie Special training and equipment Personnel to be assigned to the jobs listed below were either to be specifically instructed and trained, or were previously experienced on these assignment Procedures, training, shielding and equipment were being provided that would permit the completion of the following jobs with adequate control of personnel exposures to radiation:
Post-LOCA sampling equipment installation Reactor water level sensor installation Hydro-lancing of steam generator tube sheets Reactor cooling pump seal repairs
In-core detector thimble replacement Reactor cavity decontamination Inservice inspection of steam generator tubes, piping and nozzles, and reactor vessel welds The licensee will provide enclosures and ventilating systems for steam generator work, grinding, and decontamination jobs involving potential airborne contaminatio No violations were identifie Supplies and Equipment The inspector toured the facility to observe the availability and use of survey instruments, protective clothing, respirators, shielding, decontamination materials, and special equipmen No survey instruments or friskers were identified as inoperative or overdue for calibratio Based on the inspector's review of service records, there were no lengthy delays in return of instruments to service when due for calibration or repai The licensee maintains a routine restock procedure to assure an adequate stock of consumable materials required during outage A trailer mounted laundry for protective clothing was contracted for use during the outag Typically, the day's collection of discarded protective clothing will be laundered and available for reuse by the next da The inspector noted there was dedicated space for cleaning and storing respirators, and trained personnel were provided on this jo No shortage was observed in items such as protective clothing, respirators, shielding, barricades, and sign The inspector observed that two separate personnel access control points into Unit 1 were to be maintained during the outag No violations were identifie.
Training Training Program The inspector reviewed the training program to verify compliance with the requirements of Section 6.4 of the Technical Specifications, Section 5.5 of ANSI N18.l-1971, and 10 CFR 19.12, and to determine consistency with Regulatory Guide 8.27 and NUREG 0761 (draft),
Section.
!
The inspector examined the licensee's procedures for radiation protection training of the following categories of personnel:
Contract radiation protection technicians (CRPT)
Permanent radiation protection technicians (PRPT)
Radiation workers Respirator users The licensee had provided the following training to the groups of individuals shown:
Type of Group Training All Employees General Indoctrination Radiation Workers Radiation Worker New PSEG Apprentice &
Employees Phase II Tech-nical Assistants Contractor Contract RPTs Employees Duration (Hours)
8 1000
Frequency Annual Annual Once
- Each Outage Evaluation Method Written Examination Written Examination &
Proficiency Demonstration Written Examinations, On the Job Training, et Written Examinations &
Proficiency Demonstration Status com-pared with Procedural Requirements Complies Complies Complies Complies Respirator Users Respirator User J
Annually Written Complies Examinations &
Fit Test
..
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The training program is managed by the Training Director and the Radiation Protection Supervisor Day-to-day supervision is provided by the training staff and the Radiation Protection Supervisor The work of the organization is carried out by a full time training staff and, during outages, senior radiation protection level contract personne The inspector verified licensee compliance with the training program related procedures by interviews and by a review of the following training procedures and materials, including worker tests and records of other evaluation methods:
Personnel Training Manual Basic Nuclear Apprentice Assistant Lesson Plan Outline Administrative Procedure No. 24, Radiological Protection Program Administrative Procedure No. 14, Station Training Program Procedure RP-2, Training:
2.001 New Employee General Indoctrination 2.002 Technician Training 2.003 Respiratory Protection Training & Fit Test With the exception of retraining of radiation protection technicians, the main elements of a formal program were in place, i.e., there were course outlines, lesson plans, examinations, and schedule The licensee had rescinded the portion of procedure RP-2 concerned with retraining of the PSE&G radiation protection technicians and there were no current retraining schedules, examinations, or training records assuring that two of these individuals were maintaining proficiency in the fundamentals of their job The licensee committed to develop a formal training/retraining program by March 1982, (see paragraph 2, item 81-20-01). Escorted Individuals The inspector verified that untrained individuals such as short term visitors and arrivals who had not yet attended training were instructed to stay with the escort and follow his instructions. The untrained individuals were specifically instructed to comply with emergency signals and public address system announcements and warnings; and to observe posted information and signs, barriers, and local alarms.
I
- -- General Employee Indoctrination Review of general employee indoctrination, provided to comply with 10 CFR 19.12, indicated that experienced instructors were provided, a program outline was followed, and procedure no. RP-2, Training, was availabl This procedure formalized the examinations, passing score, and record No violations were identifie.
Exposure Control Dosimetry Programs The licensee 1 s personnel monitoring program was examined against the requirements of 10 CFR 20.101, 20.102, 20.401, and 20.408 and within the framework of the following generally accepted codes, standards, publications and examples of good practice:
Inspection and Enforcement Information Notice 81-26, Personnel Neutron Dosimeters at LWR 1 s Regulatory Guide 8.4, Direct Reading and Indirect Reading Pocket Dosimeters Regulatory Guide 8.7, Occupational Radiation Exposure Records Systems ANSI/ANS N13.ll, Draft American National Standard Criteria For Testing Personnel Dosimetry The licensee expects to issue dosimetry badges containing thermolum-inescent dosimeters (TLDs) to several hundred contract workers during the outag The TLDs are evaluated on site at least monthly and as necessary to meet procedural requirements. The TLD badges and self-reader dosimeters are picked up on entering an area requiring personnel dosimetr The dosimeters are zeroed by the control point monitor or the user when picked up; read out by the user; and the results are recorded on the REP sign in/out sheet on leaving the controlled are All visitors wear the dosimetry described above on entering areas normally requiring personnel dosimetr Exceptional unique provisions may be made infrequently, an example being escorted groups of short term visitor Up to 500 contract personnel may be on site during a 24-hr. period wearing visitors badges.
Extremity dosimetry is provided where the head, hand, foot or various parts of the body may receive nonuniform exposures to radiatio *
The outage is not expected to involve neutron dosimetr Facilities and equipment used to support this program and, the routine quality control checks and calibration, are as follows:
Computer record system, including keyboards, display tubes, a printer, etc. (daily operability check)
TLD reader (checked daily/calibrated monthly)
Self Reader Dosimeters (calibrated semiannually)
Survey and air sampling instruments (checked daily/calibrated quarterly or semiannually)
Gamma Radiation Calibration Facility The external personnel dosimetry program is managed by a Technical Assistant with ten years of radiation protection experienc The personnel monitoring program organization prepares and issues the following reports and documents:
Daily updates incorporating TLD and daily self-reader dosimeter results Termination reports & estimates Summary information for reports pursuant to the require ments of 10 CFR 20.407 No violations were identifie Procedural Control of Exposures The. inspector verified compliance with the requirements of 10 CFR 19.13, 20.102, 20. 401, and 20. 408 by rev.i ew of 14 completed Forms NRC-4, equivalent Forms NRC-5, termination reports, and administrative exposure limit authorization On November 25, 1981, the inspector reviewed several pages of the daily computer printout of dosimetry information, averaging about 40 names per pag Except for a minor discrepancy between two licensee copies of the termination report to one individual, no problems were identifie The licensee committed to correct this discrepancy. The discrepancy had no potential to cause any overexposure in this particular example.
No violations were identifie *
11 Air Monitoring The inspector verified compliance with a portion of the requirements of 10 CFR 20.103 by review of the procedural provisions and recent records applicable to air sampling, airborne radioactive materials areas, and access control The inspector reviewed records of recent entries into containment and verified that records were maintained of exposures to airborne radioactive materials, and also skin exposure due to noble gase No violations were identifie.
Review of Respiratory Protection Programs Adherence to internal exposure limits The inspector reviewed the 14 respiratory protection procedures to verify compliance with 10 CFR 20.103 and Regulatory Guide 8.15, Acceptab 1 e Programs for Respiratory Protectio These. procedures covered respirator training, fit testing, cleaning and disinfecting,'
use, inspection and repair, and quality assuranc The procedures appeared to assure compliance with the above requirement In addition, the selection of equipment appeared adequate to meet the requirement During the review of personnel folders (see paragraph 4.a and 6.b)
the inspector verified that records were maintained of physician's determinations of fitness to wear respirator Observation of working conditions during the inspection, and review of records of work permits, air samples, contamination surveys, nasal swipes, skin contamination, and whole body counts did not identify any exposures to airborne radioactive materials in excess of 10 CFR 20.103 limit No violations were identifie Air monitoring The inspector reviewed the licensee's procedures and records of air monitoring to verify compliance with 10 CFR 20.103 and 10 CFR 20.203(d). *
The inspector toured the facility to verify proper posting of airborne radioactive materials area No violations were identified.
- 12 Bi oassay Program The inspector reviewed the bioassay program maintained pursuant to 10 CFR 20.201 to assure compliance with 10 CFR 20.10 The licensee whole body counting program requires radiation workers to be counted at least annually, or an evaluation to be made if counting is impract-icable; and in the case of temporary employment, on arrival and on departur A worker's concerns that he had no whole body count on arrival or departure were reviewed by the inspecto No exposures to airborne radioactive materials were identified and the worker was notified that no whole body count was require The inspector verified the licensee procedures and equipment were adequate to identify nanocurie quantities of typical reactor activation and fission product gamma activities, and the ratio of such activities to pure beta emitters was greater than 500 to one. (See paragraph 2, item 80-28-01)
No violations were identifie Temporary Engineering Controls The inspector verified that exposures to airborne radioactive materials were controlled by decontamination of surfaces, use of plastic covers and tents to prevent spread of contamination, and use of controlled ventilation systems to prevent exposures to unacceptable concentrations of airborne radioactive materials. No omissions were identified of the use of such controls on contaminated job No violations were identifie Licensee Evaluations of Controls The inspector noted that the records of the licensee evaluations of controls appeared to verify the selection of acceptable equipment, the use of authorized protection factors, the application of preventive measures, and the evaluation of internal exposure *
No violations were identifie Respiratory Protection Training and Respirator Fitting and Testing The inspector verified during the review of personnel files (see paragraphs 4.a and 6.b) that the medical check, fitting, and training of personnel using respirators was documented and the procedures, described above, appeared to be fully implemente *
No violations were identifie Respirator Cleaning and Maintenance In order to verify adherence to the above procedures, the inspector observed the collection process for used respirators, and respirator cleaning and maintenanc The inspector also observed that each user tested the respirator fit each time the respirator was donne No violations were identifie.
Posting and Control of Radiation Areas, Airborne Radioactivity Areas, and Contaminated Areas In'order to verify compliance with the requirements of 10 CFR 20.203, Caution signs, labels, signals and controls, the inspector toured the facility to observe posted radiological and survey information, barriers and enclosure The inspector also surveyed the outdoor radioactive waste storage area fence and barrier ropes, and trailers being loaded with material to be transporte No violations were identifie.
Radioactive and Contaminated Material Control The inspector observed the licensee 1s management of used protective clothing, contaminated trash, and radioactive wast The inspector verified container labels, transport information and shipping document It was noted that the applicable procedures appeared to be fully implemented and the exposure of personnel to radiation emanating from radioactive waste was reasonably limited by barriers, isolation and shieldin No violations were identifie.
Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspectio The inspector reviewed the inspection findings.