IR 05000272/1986029
| ML18092B360 | |
| Person / Time | |
|---|---|
| Site: | Salem |
| Issue date: | 11/13/1986 |
| From: | Dan Collins, Dragoun T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18092B359 | List: |
| References | |
| 50-272-86-29, 50-311-86-30, NUDOCS 8611240240 | |
| Download: ML18092B360 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272 Docket No /86-29 Report No /86-30 DPR-70 License No DPR-75 Category c
Licensee:
Public Service Electric and Gas Company Facility Name: Salem Nuclear Generating Station Units 1 & 2 Inspection at: Hancock's Bridge, New Jersey Inspection Conducted: September 29 - October 3, 1986 Inspectors:
Approved by:
Radiation Specialist M. M. Shanbaky, Chief, Protection Section Specialist Radiation llw-1.2 ;qJ?C, date /
Inspection Summary: Inspection conducted on September 29-0ctober 3, 1986 (Combined Inspection Reports 50-272/86-29 and 50-311/86-30)
Areas Inspected: Routine safety inspection of the Radiation Protection pro-gram including:
External dosimetry; New Inprocessing Facilities; Internal exposure controls; Routine Radiological Surveys; Organization and Staffing; ALARA Program; Fuel pool diving preparations; Inplant respiratory protect-ion; High Radiation Area Control and, action on previously identified item Results: Within the scope of this review, no violations were identified.
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8611240240 861114 PDR ADOCK 05000272 G
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DETAILS 1.0 Persoris Contacted The below licensee personnel were contacted during this inspectio Other persons were also interviewed or provided informatio Bergendahl, D., Engineer, Radiation Protection Services, Bioassay
- Britz, W., Manager, Radiation Protection Services
- Katsch, J., Principal Engineer, Radiation Protection Services Miller, L., Assistant General Manager
- Mohler, D., Radiation Protection Engineer Nicks, J., Engineer, Radiation Protection Services, Dosimetry
- Patwell, R., Licensing Engineer Perkins, D., Quality Assurance Ruyter, D., Respiratory Protection Supervisor Simpson, S., Senior Radiation Protection Supervisor
- Trejo, J., Radiation Protection/Chemistry Manager
- Zupko, J., General Manager, Salem Generating Station
- Attended the Exit Interview on October 3, 1986 2.0 External Dosimetry The inspector reviewed the external dosimetry program against the require-ments of 10 CFR 19.13, 11 Notifications and Reports to Individuals, 11 10 CFR 20.101, 11 Radiation Dose Standards for Individuals in Restricted Areas, 11 10 CFR 20.102, 11 Determination of Prior Dose, 11 10 CFR 20.202, 11 Personnel Moni-toring,11 10 CFR 20.401,, 11 Records, 11 and 10 CFR 20.407, 11 Personnel Monitor-ing Reports. 11 The inspector also reviewed the program with respect to the recommendations in American National Standards Institute (ANSI) Nl3.ll-1983, 11 Cri teri a for Testing Personne 1 Dosimetry Performance; 11 ANSI N1,
11 Performance of Personnel Thermoluminescent Dosimetry Systems; ANSI Nl3.6-1966 (R-1972), American National Standard Practice for Occupa-tional Radiation Exposure Record Systems. 11 The inspector reviewed these procedures for adequacy and consistancy with the above:
M12-AP-4, Rev. 1, Radiation Protection Services Dosimetry Activities M12-DOP-1 thru 8, Departmental Dosimetry Operating Procedures M12-DOI-101 thru 803, Departmental Dosimetry Operating Instruction The inspector determined that there were minor discrepancies within these procedure DOP-3, "Dosimetry processing and Test Plan 11 and 11DOI-301, TLD vs Self-reading Dosimeter Comparison Discrepancy Reporting 11, did not have the same percentage difference requirement in that DOP-3 indicates that a difference of 20% when above 100 mrem will be referred for investigation
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while DOI-301 states that the computer should be programmed to print out a list of differences that exceed 25%. DOP-3 is a higher tier procedure than is DOI-30 While the procedures provide that dosimetry shall be exchanged on a month-ly frequency, effective with the third calendar quarter of 1986, the lic-ensee exchanged personnel TLDs on a quarterly basis. Personnel TLDs as-signed for wear as of July 1, 1986 were worn until September 30, 1986. The dosimetry supervisor was unable to provide the inspector with an analysis of the effects expected on personnel exposures due to the chang This matter will be reviewed again in a future inspectio The inspector determined that an NRC Form 4 is required to be completed by an individual prior to that individual performing work which may result in exceeding station administrative limits. Individuals who exceeded the station administrative limits were properly extended. The licensee makes a diligent effort to determine the previous history of individuals seeking access to the radiologically controlled area Termination letters are sent to individuals departing the station, and if returned are kept in the individual 1 s record. Notifications to NRC are filed in the individual 1 s recor Within the scope of this review, no violations were identifie.0 New Inprocessing Facilities The Radiation Protection Services group is a corporate level support func-tion providing dosimetry, respiratory protection equipment fit testing and whole body counting services to both the Salem and Hope Creek site This group also provides instrumentation repair and calibration services; and ALARA engineering services. The facilities which are used in these support activities are housed in the lower level of the main access point building. The area is considered inside the protected area and access is thru security gates on the main level. The licensee is pursuing methods to provide external access so as to ease the inprocessing of new personnel without security badge The inspector determined that the space as allocated was sufficient to handle the projected flows of people requiring these service However, the inspector noted that instrumentation calibration and repair; anti-contamination clothing laundry; and respirator maintainence, inspection and repair facilities all remain in temporary unit Within the scope of this review no violations were observe.
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4 Internal Exposure Controls The inspector reviewed the internal exposure control program against criteria contained in 10 CFR 20.103, ANSI Nl3.l-1969(R-1982), and ANSI N343-1978. The licensee uses these procedures within the Radiation Pro-tection Services group: M12-AP-8 Radiation Protection Services Radio-bioassay Program; and, Ml2-BOP-1 thru 3, Departmental Operating Proce-dure The licensee uses a standup rapid whole body counter and has plans to expand the bioassay program with the addition of a scanning uni In preparation for the outage, the licensee contracted a second whole body counting unit in a va The inplant unit and the van unit are similarly configured. The licensee has calibrated its unit appropriately, and main-tains documentation as well as the computer files. The operators are trained and qualified through a formal progra A computer is used to analyze the body count data and to run diagnostic checks of the hardware and software to verify proper operation. Investigative levels are set by procedures and investigations are performed. A program exists to relate bioassay results to intake quantities. The licensee evaluates skin con-taminations and possible uptakes. The licensee uses a contractor labora-tory for more advanced bioassay, including tritium and fecal analyse The inspector determined that the program meets the regulatory require-ment.0 Routine Radiation Surveys The scheduling and control of routine radiation surveys was reviewed with respect to the requirements of 10 CFR 20.201 survey The licensee 1 s program is described in the following documents:
Station Procedure RP4.001, 11 Routine and Zone Radiation Protection Survey Schedul es 11 Rev II Station Procedure RP4.019, 11 Performance of Radiological Surveys 11 Rev
Radiation Protection Guideline RPG 4.1, 11 Radiation Protection Survey Schedul es 11 Rev. I R.P. Tech Good Practices Guidelines at Salem Station The status of the licensees program was determined from a review of se-lected documents and interviews with the Radiation Protection Manager, Senior R.P. Operations Supervisor, and the Technical Superviso Within the scope of the limited review no violations were observe.0
The various in-plant and site areas are identified by approximately 150 maps and are surveyed for dose rates, surface contamination and airborne contaminatio R.P. Operations Supervisors assign responsibility for surveys to ANSI qualified R.P. technicians and provide written guidance on proper selection of survey instruments and documentation of reading Survey results are reviewed by supervision to ensure completeness and to evaluate radiological condition The scheduling of the routine surveys appears to be thorough and well controlle The licensee has resolved the weaknesses identified in this area during inspection 50-272/85-21 and 50-311/85-23 in October 198 The licensee advised that a new program will be instituted during the up-coming outage to resurvey all vehicles and equipment exiting through the site 11 vehicle gate".
This survey will supplement the unconditional re-lease survey done earlier but will use extremely sensitive micro-R meters in a method similar to walk through portal monitors used by personnel exiting the sit This final check will increase the control of radio-active materia Organization and Staffing The inspector reviewed the qualifications of the recently appointed Rad-iation Protection Engineer with respect to the criteria contained in Technical Specification 6.2 and Reg Guide The individual was found to be fully qualifie This position had been vacant for several months and was recently fille The licensee stated that a proposed technical specification change will be submitted by October 3, 1986 that will affect Section 6.0 Administrative control The inspector reviewed the draft change and noted the following highlights:
the position of Radiation Protection Manager is added along with the exapnded radiation protection staff to the chart of the station organizatio the Radiation Protection Manager will become a permanent member of the SORC committee Draft job description are available for the new supervisory positions as well as for the staff of the corporate Radiation Protection Services grou The assignment of responsibility and authorities was generally clea Although all positions of the expanded RP department are filled, the var-ious policies, procedures, and job descriptions have not been formalize The licensee progress on the matter will be reviewed in a future inspect-io '*
Prior to the last outage the licensee introduced a screening exam for contractor HP technician The exam was designed to verify knowledge of basic regulatory requirement For this upcoming outage approximately 20%
of the ANSI-qualified technicians failed and were not hire This screen-ing appears to be effective in ensuring that technicians are indeed qual-ifie.0 ALARA The licensees efforts to improve ALARA performance was determined from:
Discussion with the Radiation Protection Manager Review of SORC meeting minutes for July, August and September 1986 Observation of a Salem Station ALARA Committee meeting on October 1, 1986 Review of the Zeke II computer program used to locate valves and discussions with HP technicians regarding use of this program Within the scope of this review, no violations were observe The 1986 ALARA goal for both units has been increased to 725 man-rem due to ex-panded work scope planned for the Unit 2 outag However, the licensee has made program improvements as follows:
The policy requiring ALARA reviews of all Design Change Packages (DCP)
in conjunction with corporate Radiation Protection Service has been reinforced by SORC action in rejecting incomplete DCP 1 A computer program called 11Zeke !1 11 gives the exact physical location of all valves in containmen This is expected to reduce time spent by HP technicians conducting job surveys and workmen performing rout-ine valve maintenance in radiation area A high level task force has reviewed world-wide ALARA performance and has proposed funding twenty-one major short term and long term act-ions for the plant to reduce exposure ALARA targets continue to be included in contract specifications to vendors with fixed dollar value penalties and incentives associated with the goal For instance, the refueling contract with Westing-house allows a total of 42 man-Rem for reactor disassembly, fuel shuffle and reassembl Equipment improvements include specially designed scaffolding, new reactor head seal design, use of wireless headsets by cavity work crews, and improved head stand shieldin The inspector concluded that management commitment to ALARA remains ex-cel len.0 Fuel Pool Diving The inspector evaluated the licensee's preparation for underwater diving during the upcoming outage with respect to the recommendations of Infor-mation Notices and the requirements of 10 CFR 19.12, and 10 CFR Part 2 The licensee procedure (1.031 Diving Package Review) calls for appropriate controls on surveys, visibility of the diver, dosimetry provided for the operation, pool conditions, prejob briefings and, bioassay determination The inspector had no further question.0 Inplant Respiratory Protection The inspector reviewed selected portions of the inplant program for res-piratory protectio The licensee has taken the proper response actions with respect to Information Notice 86-46 on cleaning, 86-24 on air cylin-der The licensee procedures for respiratory cleaning and repair make extensive use of vendor reference Respiratory protection equipment is maintained by radiation protection technicians assigned for an extended tim Training is provided by the Training Departmen Air samples for self-contained breathing bottles are obtained once per month when the compressor unit is used to fill bottles, and analyzed by an offsite con-tractor for Grade D quality conformanc The inspector noted that not enough air was drawn in the sampler for an odor determinatio Licensee representatives stated that a tank of air would be selected and breathed down to make the determination for each compressor ru Within the scope of this review no violations were identifie.0 High Radiation Area Controls The inspector reviewed the implementation of controls on high radiation areas and locked high radiation areas with respect to the requirements of Technical Specification 6.1 The licensee routinely locks high radiation areas with unique keys, which are controlled by an authorized individua These keys are retained in a lockset at the Radiation Protection Control Poin The shift technician and radiation protection supervision control access to the key which can release the lockse Locked High Radiation Areas are those where an exposure of 1000 mrem to the whole body could be received in an hour by an individua The keys to these areas are secured in a double lockset, requiring the use of two keys to release them for us The Reactor Building Sumps are specially controlled Locked High Radiation Areas which require the use of up to six keys to use, including the Rad-iation Protection Engineer, the Manager of Radiation Protection, the Operations Shift Superviso The inspector toured the plant and determined that the implementation of these controls was appropriat The inspector had no further question..
11.0 Licensee Action on Previously Identified Items CLOSED - Inspector Follow Item (50-272/86-13-03 and 50-311/86-13-03)
Provide schedule for revision of Radiation Protection Procedures.As re-vised on September 30, 1986 the licensee has prepared a schedule for initiation/revision, review, approval and training of plant staff in Rad-iation Protection procedures. This schedule ends in August 1988, but the majority of the work is scheduled to be completed before the scheduled Unit 1 outage in September-November 198.0 Exit Interview The inspector conducted an exit interview on October 3, 1986 at which the scope of the inspection and the inspector 1 s findings were presented. At no time during the in~pection did the inspector provide written material to the licensee.