IR 05000272/1987023
| ML18093A354 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Salem |
| Issue date: | 09/02/1987 |
| From: | Dragoun T, Gresick J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A353 | List: |
| References | |
| 50-272-87-23, 50-311-87-24, GL-82-12, NUDOCS 8709140174 | |
| Download: ML18093A354 (7) | |
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Report No Docket No U. S. NUCLEAR REGULATORY COMMISSION REGION I.
50-272/87'.'"23 50-311/87-24 50-272 50-311 License Nos. DPR-70 and DPR-75 Priority Licensee:
Public Service Electric & Gas Company 80.Park Place Newark, New Jersey 07101 Category C
Facility Name:
Salem Nuclear Generating Station, Units 1 & 2 Inspection At:
Hancocks Bridge,'New Jersey
. Inspection ~onduited: July 27-31, 1987 Inspectors:
T Approved by:
'Cf ate date Inspection Summary: Ins ection Conducted on Jul 27-31, 1987 Re ort No /87-23 and 50-311/87-24 *
Areas Inspected: Routine, announced inspection of the licensee's radiation protection program, including: organization and staffing, training and quali-fication of HP/Chem technicians; control of overtime; hot particle program; radiological occurrence report system; planning and preparation for th~
upcoming Unit 1 outage; and the management meeting summary of July 29, 198 Results: No violations were identified *
8709140174 870908 PDR ADOCK 05000272 G
- DETAILS Persons Contacted 1.1 Licensee Personnel
- S. Miltenberger, Vice President, P.S.E.& +* J. Zupko, General Manager, Salem Station
+ D. Perkins, Manager, Station Quality Assurance
- J. Trejo, RP/Chem Manager, Salem 1 & 2
+* D. Mohler, Radiation Protection Engineer, Salem 1 & 2
+* T. Cellmer, Radiation Protection Engineer, Hope Creek
- J. Clancy, Principal Health Physicist, RPS, P.S.E.& * J. Kotsch, Principal Health Physicist, RPS, P.S.E.& * J. Molner, Sr. Radiation Protection Supervisor, Operations (H~C.)
- J. Wray, Sr. Radiation Protection Supervisor, RMC (H.C.)
+* G. Reggio, Station Licensing Engineer, Salem L. Fry, Station Planning Manager, Salem
- D. Schultz, Engineer, Licensing & Regul~tions, P.S.E *. & D. Parks, Training Supervisor, Radiation Protection NRC Personnel
- G. Rivenbark, Project Manager - NRG, for Hope Creek
- R. Bellamy, Chief, Emergency Preparedness & Radiation Protection Branch, RI
- P. Swetland, Chief, Reactor Projects Section 2, RI
+* T. Kenny; Senior Resident Inspector, Salem 1 & 2
- R. Borchardt, Senior Resident Inspector, Hope Creek
+* K. Halvey-Gibson, Resident Inspector, Salem 1 & 2
- M. Shanbaky, Chief, Facilities Radiation Protection Section, RI
- R. Nimitz, Senior Radiation Specialist
- denotes attendance at the management meeting at the Salem-Hope Creek Site on July 29, 1987
+ denotes attendance at the exit interview conducted on July 31, 1987 2.0 Purpose The purpose of this routine inspection was to review the following elements of the radiation protection program:
Status of Previously Identified Items Organization and Staffing Training and Qualification of Health Physics/Chemistry Technicians Control of Overtime for Technicians Hot Particle Program
r-
Radiological Occurrence Report System Planning and Preparation for the Upcoming Unit I Outage Management Meeting on July 29, 1987 3.0 Status of Previously Identified Items 3.1 (Closed) Followup Item (272/85-05-01)
Review adequacy of computer program for determing skin dos Draft procedure RP 205 provides a simple calculation for dose delivered by generalized contamination on the ski.2 (Closed) Followup Item (272/85-21-02 and 311/85-23-02)
Ensure that radiation protection guideline procedures are consistent with SORC instructions. Procedure RP101, "Preparation and Control of Procedures," effective on May 15, 1987, ensures that a 11 proce-dures meet administrative requirement.3 (Closed) Followup Item (272/87-05-01 and 311/87-07-01)
Issue new functional job descriptions for new HP/Chem organizatio Procedure RP104, "Organization and Administration," effective on May 1, 1987, provides detailed job description.4 (Closed) Followup Item (272/87-05-02 and 311/87-07-02)
Clarify posting and labeling requirements for contaminated equipment stored in the RC Responsibility for this has been assigned to Senior Supervisor7Radioactive Material Control. *A tour of storage areas verified that posting requirements are being me.0 Organization and Staffing The licensee's organization and staffing of the RP department was re-viewed with respect to criteria contained in:
Technical Specification 6.2, "Organization,"
Technical Specification 6.3, "Facility Staff Qualifications,"
ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel,"
ANSI N18.7, "Administrative Controls for Nuclear Power Plants,"
NUREG/CP-1280, "Power Plant Staffing,"
NUREG-0761, "Radiation Protection Plans for Nuclear Power Reactor Licensees," *
Request for Amendment Facility Operating Licenses DPR-70 and DPR-75 dated October 6, 1986, and Station Procedure RP 104 "Organization and Administration,"
effective May 1, 198 The licensee's performance relative to these criteria was determined from interviews with various RP supervisor Within the scope of this review, no violations were observe **
The major reorganization of the department is complete and all key positions are filled with one exception in the chemistry are Two new functions have been created that report to the Radiation Protection Manager: Count Room and Support. These groups consolidate the certain activities common to both radiation protection and chemistry program The relationships between the groups and detailed position descriptions for each supervisor are found in procedure RP10 This reorganization culminates a significant licensee effort that began in early 1987, and reported in inspection 87-0 Significantly improved performance is anticipated, particularly in the chemistry progra.0 Training and Qualifications of HP/Chem Technicians The licensee's program for the training and qualification of HP/Chemistry technicians was reviewed with respect to criteria contained in:
10 CFR 19.12 and 20.206, Technical Specification 6.4, 11Training,
Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants,"
ANSI N18.1 - 1971, "Selection and Training of Nuclear Power Plant Personnel," an ANSI/ANS - 3.1 - 1981, "American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants.
The licensee's performance with.respect to the above criteria was de-termined by:
review of current qualification cards for selected HP technicians, review of modularized training approach and qualification statements-for Health Physics/Chemistry technicians, and discussions with licensee personne Within the scope of this review, no violations were identified. The licensee maintained complete records of training and qualifications for Health Physics technicians to assure that the appropriate training had been provided for key radiation protection task The licensee is in the process of revising their current training program to upgrade and modularize the training and qualification program, and qualify technicians in Health Physics tasks and Chemistry tasks concur-rentl Under the new plan, personnel will receive classroom training to perform certain elementary Health Physics and Chemistry tasks and then receive in-plant qualification and experience in these tasks before going on to additional classroom training and more responsible task Above an undetermined 11elementary 11 level, technicians will receive specialized and advanced training in either Chemistry or Health Physic..
Although the modularized approach to training and qualification was still in development stages, the inspector noted that the following information was not yet available for review:
At the time of the inspection, the length of time required to gain work experience in the Health Physics tasks and Chemistry tasks was not specified. Certain tasks identified in the combined HP/Chem training modules included surveys, posting, and barricading of high radiation areas, and sample acquisition, analysis, and comparison with technical specification parameters. Some of these tasks are required.to be performed by an ANSI-qualified technician (i.e., 2 years experience for ANSI N18.1 Standards and 3 years experience for ANSI/ANS 3.1-1981-standards.)
An in-plant qualification system and a requalification system had not been established to ensure the appropriately qualified techni-.
cian was assigned to perform a tas Through discussions with the licensee, the inspector determined that.*
the first line supervisory position would have the responsibility of ensuring that techs assigned for a task were properly *qualified for that task. However, no position description identified that respon-sibilit The licensee acknowledged that these toncerns would be considered in the development of the new HP/Chem technician training and qualification progra This area will receive on-going reviews in future inspection.0 Control of Overtime for Health Physics Technicians This area was reviewed with respect to criteria contained in NUREG-0737, item I.Ail.3 and NRC Generic Letter No. 82-12, "Nuclear Power Plant Staff Working Hours.
The licensee's performance related to the above criteria was determined from a review of licensee procedures, memos, and records of overtime for HP technicians, and discussions with licensee personne Within the scope of this review, no violations were identified. The licensee had established routine work schedules for normal operation (40 hour/5 day weeks), and the upcoming outage (9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> per day/6 days per week).
Additionally, administrative limits were established to limit overtime to no more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in seven consecutive days and no more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, as specified in Generic Letter 82-1.0 Hot Particle Control Program Due to increasing industry incidents with hot particles, the licensee had begun to evaluate their programs with respect to control of this particu-lar type of contamination. At the time of the inspection, the licensee provided the inspector with a "Fuel Flea Control Instructions" sheet, used as an attachment to radiation work pennits for plant areas where these particular hot particles may be encountere The check-off sheet included additional contamination control requirements, including maislin wipes, tape for "hot particle" removal, additional surveys, whole body frisking, and segregation of trash. The licensee has also begun to re-evaluate the laundering of protective clothing to minimize this form of cross-contamination and the potential for personnel exposur.0 Radiological Occurrence Report System The inspector reviewed the licensee's system for identifying, tracking, and trending abnormal plant incidents involving radiological controls by review of two radiological occurrence reports (ROR 87-249 and ROR 87-170), and discussions with licensee personne The licensee had a well-documented and well-implemented system in place for identifying, tracking and trending various radiological incidents, and had established a "severity of incident" level syste ROR 87-249 was identified as a level 2 incident, and involved supervisory review and re-evaluation of new worker training in radiological concern ROR 87-170 described the circumstances, attempted decontamination efforts, and subsequent skin dose evaluation of a "fuel flea" contamination even This incident was categorized as a level 3 incident, and was reviewed by the corporate Health Physics grou The licensee trends all incidents on a quarterly basis to identify progranvnatic weaknesses within their radiological controls progra The inspector noted that all evaluations and reports were timely and thorough and constituted an effective base for self-identification and correction of otherwise citable violation.0 Planning and Preparation for the Upcoming Unit I Outage The licensee's next major outage activity, scheduled for Unit 1 in early October 1987, includes the seventh refueling outage and 10 year Inservice Inspection (10 year ISi). Inspector review of the planning and prepara-tion for this outage included discussions with various licensee personnel and review of outage planning documentatio The licensee established a station planning group to identify plant projects and outage activities and coordinate the work packages with the appropriate plant groups. Initial ALARA reviews are perfonned by the
corporate Radiation Protection Services (RPS) grou Early in the outage planning stage, plant Health Physics personnel were involved with the work evaluation planning, and primary (or lead) technicians were assigned to follow and cover specific work packages through the outag The licensee anticipates a person-rem expenditure of approximately 460 rem for the.Unit 1 outag The inspector stated that this person-rem goal appeared hig The licensee was unable to provide the inspector with a break-down of each work package and its associated estimated dos The inspector noted that a contractor Health Physics technician ~mpany had not yet been secure The inspector discussed this with lic~~see management who stated that they had changed the scope of the contract*
which postponed the process of hiring a contractor compan The-licepsee assured the inspector that Health Physics technicians would be hired,and appropriately trained in a timely manner prior to the commencement of the outag "-
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10.0 Management Meeting on July 29, 1987
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During this inspection, NRC Region I management and inspectors met with licensee management to discuss the site standardization of the Radiation Protection Progra The licensee requested the meeting to discuss the reasoning behind the move to standardize programs, and to request the NRC's cooperation by ensuring consistency in the inspection process by assigning only one Radiation Specialist inspector for Hope Creek and Sale NRC management representatives stated that the NRC would support the licensee's efforts to standardize the Radiation Protection Program at the Salem and Hope Creek sites. However, NRC management also stated that assigning only one inspector to monitor radiation protection activities at both Salem and Hope Creek was not considered an effective way to
- assure compliance with regulatory and licensee requirements and Radiation Protection Program quality. However, the licensee was given relief from undocumented verbal commitments made to various inspectors in the pas The licensee had stated that certain earlier "commitments" were viewed as a hinderance to the standardization effor. 0. Ex it I nterv*i ew The inspector met with the licensee denoted in section 1.1 at the conclu-sion of the inspection on July 31, 198 The scope and findings of the inspection were discussed at that time.