IR 05000272/1991032
| ML18096A447 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/15/1992 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A446 | List: |
| References | |
| 50-272-91-32, 50-311-91-33, NUDOCS 9201280037 | |
| Download: ML18096A447 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No /91-32 50-311/91-33 Docket Nos. 50-272 50-311 License Nos. DPR-70 DPR-75 Licensee:
Public Service Electric and Gas Company P.O. Box 236 Hancocks Brid£e. New Jersey Facility Name:
Salem Nuclear Generatin£ Station. Units 1 and 2 Inspection At:
Hancocks Bridge. New Jersey Inspection Conducted:
December 16-20. 1991 Approved by: a_v~
W. Pasciak, Chief, Facilities Radiation Protection Section Inspection Summary:
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date Areas Inspected: This inspection was a routine, unannounced Radiological Controls Inspection during the Unit 2 refueling outage. The following areas were reviewed: actions on previous inspection findings, including questions related to control room habitability; radiological control.s organization and staffing; personnel qualifications and training; external and internal exposure controls; ALARA; and radioactive material and contamination control Results : Information provided by the licensee relative to control room habitability was evaluated, compensatory actions were implemented by the licensee to assure that the storage of ammonia near the control room would not affect control room habitability, and a commitment to provide a safety evaluation of this matter by February 28, 1992, was 9201280037 920116 PDR_
ADOCK 05000272 G
obtained. The licensee implemented effective radiological controls for the Unit 2 outage,and the ALARA staff provided aggressive oversight of on-going activitie Within the scope of this inspection no violations were identified.
DETAILS Individuals Contacted
- C. Vondra, General Manager, Salem Operations
- E. H. Villar, Licensing Engineer
- P. O'Donnel, Salem Operation Engineer
- J. Wray, Radiation Protection Engineer, Salem
- M. Prystupa, Radiation Protection Engineer, Hope Creek
- W. Schuitz, Manager-Station QA, Salem
- D. Parks, Principa_l Training Supervisor
- M. Shedlock, Maintenance Manager, Salem
- M. Morroni, Technical Manager, Salem
- C. Conner, Senior In-service Inspection Supervisor, Site Services T. Cellmer, Radiation Protection/Chemistry Manager B. Preston, Manager, Salem Projects
. B. O'Grady, Outage Manger-Salem Unit 2 A. Pasricha, Supervisor, Chemistry and Process Group J. Bailey, Nuclear Er1gineering Services Manager B. Bovankovich, Senior Project Engineer R. Brown, Principal Engineer-Nuclear Licensing C. Rokes, Staff Licensing Engineer Others
- E. Krufka, Salem Site Representative, Atlantic Electric
- P. Duca, Salem Site Representative, Delmarva Power 1. 3 NRC Personnel
- S. Pindale, NRC Resident Inspector, Salem Station
- P. Patniak, NRC Reactor Inspector, NRC Region I The inspector also contacted other licensee and contractor individuals during the course of this inspection
- Denotes those individuals attending the exit meeting on*
December 20, 199 **
- Purpose and Scope of Inspection This inspection was a routine, unannounced Radiological Controls Inspection during the Unit 2 refueling outage. The following are.as were reviewed:
the licensee's actions on previous findings; organization and staffing; training and qualifications; external and internal exposure controls; ALARA; radioactive materials and contamination control; Status of Previously Identified Items (Closed) Unresolved Item (50-272/91-08-01)
The inspector noted that the licensee did not appear to have in place a well defined qualification, training and retraining program for radiation protection supervisor The requirements for qualification were subjective, i.e., various topics are discussed with the Radiation Protection Engineer (RPE) and upon completion of each discussion the appropriate area is signed off on a qualification card by the RPE. The licensee's management informed the inspector that the program for supervisory personnel was in an evolving status and that the need for better definition of the program had been identified. The licensee was in the process of establishing an enhanced program in this are The inspector's review of this matter during the current inspection indicated that th licensee established Procedure SC.RP-PQ.ZZ-0169(Q), Supervisor Qualification Process, to describe the minimum and desired experience and qualification for supervisory positions in the Radiation Protection Department. The procedure also delineates the department specific training to assume the responsibility of a supervisor outside of that provided by the licensee's general supervisor training program. This item is closed. Implementation of the program will be reviewed during future routine inspection.2 (Open) Unresolved Item (50-272/91~25-02)
The licensee's Updated Final Safety Analysis Report (UFSAR) did not discuss ammonia impact on control room habitability. In addition, it was not apparent that the licensee addressed on site storage of ammonia in its July 1, 1980, response to NUREG 0737 item III.D.3.4.
In response to the first observation, the licensee made commitments as follows:
The licensee will provide the results of the preliminary safety assessment of on site storage of ammonia on control room habitabilit The licensee will provide a summary of other toxic chemicals not previously evaluated but stored on site, that could potentially affect control room habitability and a discussion as to the planned actions relative to the identified toxic chemicals and their potential impact on control room habitabilit The final safety evaluation for the control room habitability, relative to ammonia storage, would be completed by December 31, 199 The UFSAR would be updated with the new information relative to ammonia impact on control room habitability by the end of July 199 The inspector's review of this matter indicated that the licensee subsequently provided letters dated November 6, 1991, and November 27, 1991, relative to the above commitment The preliminary safety assessment of ammonia storage on control room haqitability was provided in the licensee's November 6, 1991, letter. The letter indicated that no significant habitability problems, relative to ammonia, were present. A computer model (EPA CHARM) used by an off site vendor (Vendor A) concluded that no apparent significant impact on control room habitability was presen The licensee's November 27, 1991, letter identified other chemicals that have the potential to impact control room habitability and indicated that the chemicals would be evaluated. These chemicals were 35 weight % hydrazine stored in a 300 gallon vessel on elevation 120 of the Unit 1 Turbine Building and 50 weight % sodium hydroxide stored at: elevation 88 of the Unit 1 Turbine Building (2 tanks of 4,000 ga1lons each), elevation 88 of the Unit 2 Turbine Building (2 ta11ks of 2,250 ga11ons each), the non-Radwaste Building (1 tank of 5,000 gallons), the vicinity of the Hope Creek Cooling tower (1 tank of 21, 154 gallons), and the 54 elevation of the Hope Creek Turbine Building (2 tanks of 1,600 gallons each).. The licensee's personnel indicated that based on preliminary analysis, no apparent control. room habitability problems were present relative to the storage of the hydrazine and sodium hydroxide.
The inspector met with cognizant licensee representatives during the inspection and discussed the current status of the safety evaluations. During discussions with the licensee's personnel on December 18, 1991, the inspector was informed that a computer evaluation by a second vendor (Vendor B), using a second computer model (NUREG-570 VAPOR) and conservative assumptions, indicated that the ammonia could possibly impact control room habitability and that time limit/concentration guidelines of Regulatory Guide 1. 78, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During A Postulated Hazardous Chemical Release, could possibly be exceeded. The licensee indicated that the 100 parts per million (ppm) anhydrous ammonia concentration value, presented in the regulatory guide, would be exceeded earlier than the recommended 2 minute time period
- identified in the regulatory guid The licensee stressed that the results were preliminary and that conservative assumptions were used for the evaluatio~1. The licensee also indicated that an evaluation by the initial vendor (Vendor A) indicated no potential impact on control room habitability by ammonia. As a result of the new information, the licensee took the following actions:
A temperature* versus volume curve was generated. The temperature/volume curve was important because of the low boiling point* of ammonia. The licensee could control the volume relative to temperature to prevent any significant impact on control room habitability. Use of this curve is expected by the licensee to preclude adverse impact on control room habitabilit Temperature monitors were placed on the ammonia storage tank to monitor tank temperatures. The temperatures are monitored twice a shif The licensee initiated an incident report and made a one hour notification to the NRC in accordance with 10 CFR 50. 7 The licensee subsequently provided a December 30, 1991, letter to the NRC which discussed the status of the habitability reviews and provided the following:
A request for an extension to the end of February 1992 to complete the final safety evaluation for the control room habitability review, relative to ammoni A commitment to complete the evaluation of control room habitability, relative to the other chemicals identified, and update the UFSAR by the end of July 199 The inspector indicated that this unresolved item remains ope ** *
Organization and Staffing The inspector reviewed the organization and staffing of the on site Radiation Protection Group with respect to criteria contained in the following:
Technical Specification 6.2, Organization; Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be ~s Low As Is Reasonably Achievabl The inspector also reviewed general supervisory and management oversight of radfological significant work task The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, review of on-going work and review of documentatio Within the scope of this review, no violations were identified. The following positive observations were made by the inspector:
The licensee issued a Unit 2 Sixth Refueling Outage Radiation Pro'tection Organization which included descriptions of the responsibilities of key personne The licensee re-organized the ALARA organization to provide for enhanced oversight of outage activities from an ALARA perspectiv The licensee assigned dedicated crews and supervisors to oversee major radiologically significant work activities (e.g., Steam Generator work activities).
The licensee used radiation protection personnel from the Hope Creek station to augment the Salem radiation protection staf Daily, weekly and monthly radiological controls performance data was provided to station managemen The licensee assigned an individual to perform assessments of radiological controls for the outage. Weekly assessment summary reports were provided to radiological controls managemen The inspector's review identified_ significant improvement in supervisory oversight, from a radiological controls perspective, of outage activities as compared to the Unit 1 outage. Overall supervisory oversight was considered. very good. The inspector noted good inter-and intra departmental communication.0 Training and Qualifications The inspector reviewed the qualifications and training of selected members of the Radiological Controls Organization with respect to criteria contained in the following:
Technical Specification 6. 3, Facility Staff Qualification; ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel; Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposure at Nuclear Power Stations will be As Low As Is Reasonably Achievabl The inspector's review in this area focused on the qualification and training of contractor radiological controls personnel hired to augment the radiological controls organization during the outage. The inspector also reviewed the training and qualification of radiation worker The evaluation of the licensee's performance in this area was based on revie.w of resumes and training records and discussions with cognizant personne Within the scope of this review, no violations were identified. The following matters
- were identified:
radiation workers were trained and qualified in accordanc.e with training program requirement The licensee established a defined radiation protection contractor training document which identified required training for contractor radiation protection technicians.. The contractor personnel were qualified in accordance with the documen The following area for improvement was brought to the licensee's attention:
Although, the licensee'*s training program did provide training on the radiological hazards associated with incore instrumentation, the program provided limited training on the radiological hazards of other plant system ** *
The following additional matter was brought to the licensee's attention:
The licensee's training program allows for management to exempt contractor radiation protection personnel who have been away from the site for less than a year from comprehensive procedure training and the completion of required exams on procedure knowledge. These personnel are however required to review applicable procedure changes since last leaving the station. No verification of procedure knowledge was required. The inspector noted that ANSI N-18.1, 1971, Section 5.5, Retraining* and Replacement Training, specifies that means should be provided in the training programs for appropriate evaluation of its effectiveness. It was unclear what means were being used to evaluate the effectiveness of the procedure change training. The licensee indicated.this matter would be reviewe There appeared to be limited guidance that provided consistent criteria for evaluation of perso11nel resumes relative to applicable experiei1ce. The licensee indicated this matter would be reviewe External and Internal Exposure Controls The inspector toured the radiologically controlled areas of the plant and independently reviewed the following elements of the licensee's external and internal exposure control program:
posting, barricading and access control, as appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas; High Radiation Area access point key control; personnel adherence to radiation protection procedures, radiation work permits, and good radiological control practices; use of personnel contamination control devices; use of dosimetry devices; *
use of respiratory protection equipment; adequacy of airborne radioactivity sampling and analysis to plan for and support ongoing work; timeliness of analysis of airborne radioactivity samples including supervisory review of sample results; installation, use and periodic opei*abilily verification of engineering controls to minimize airborne radioactivity; records and reports of personnel exposure; adequacy of radiological surveys to support pre-planning of work and on-going work; adequacy of supply, maintenance, calibration, and performance checks of survey instruments; and hot particle controls.
The review was with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Protection Against Radiatio The inspector independently reviewed on-going work activities and performed independent radiation surveys to verify radiological survey information and evaluate *
the adequacy of radiological controls. Work activities reviewed included Unit 2 steam generator work activities, reactor coolant pump maintenance, safety injection
. system valve work, and loading of irradiated hardware into shipping casks for off-site disposa Within the scope of this review, rio apparent violations were identified. The licensee implemented effective radiological controls for the work activities reviewed. Th following positive observations were made:
Very good use of television cameras to monitor on-going steam generator work activities was noted. In addition to cameras located inside the Unit 2 containment at the steam generator control points, the licensee had television screens located. in the ALARA office area outside the RC The licensee proininently posted signs at the entrance to the Auxiliary Buildings and the Unit 2 Reactor Containment warning personnel of retracted irradiated flux thimbles and the prohibition of personnel entry below the reactor vesse *
A large electronic sign was placed at the entrance to the RCA to notify personnel of proper location to wear dosimetr The licensee required pre-briefings to be held to discuss significant up-coming radiological work activities, including work sub-task The inspector also reviewed the licensee's on-going efforts to address dosimetry program findings identified during an audit conducted by a representative of the National Voluntary Laboratory Accreditation Program (NVLAP). The inspector's review indicated the following:
The licensee augmented the Radiatioi1 Protection Services Group with well qualified technical consultants to assist in resolving out-standing issue The licensee enhanced the quality assurance of the dosimetry processing. A
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recent test of personnel dosimetry relative to ANSI Nl3.11 testing criteria, indicated overall good performance of the licensee's dosimetry processing capabilities.
The licensee was maintaining a tracking document of all on-going actions and due dates for open issue The obser_vations indicated very good licensee efforts on the audit finding.0 ALARA The inspector reviewed selected aspects of the licensee's ALARA Program. The review was with respect to criteria contained in the following:
10 CFR 20.1, Purpose; Regulatory Guide 8. 8, Information Relevant to Ensuring that Occupational Radiation Exposure at.Nuclear Power Stations will he As Low As Is Reasonably Achievable; Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As is Reasonably Achievable; NUREG/CR-3254, Licensee programs for Maintaining Occupational Exposure to Radiation As Low As Is Reasonably Achievable; NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Stations; Study on High Dose Jobs, Radwaste Handling and-ALARA Incentive Within the scope of this review, no violations were identified. Licensee planning and preparation for major work tasks, e.g., steam generators, appeared excellen The following positive observations were made by the inspectors:
The licensee assigned supervisory personnel to oversee significant radiological work activities. Inspector review of on-going work activities indicated effective direct oversight of activities by ALA RA supervisory personne The licensee initiated use of a new type of shielding material (coated lead sheets). The shielding was effectively used to reduce general area and work area radiation dose rate The licensee provided extensive posting of low dose wait. areas in the Unit 2 Reactor Containmen.* *
Control of Radioactive Materials and Contamination The inspector toured the station periodically during the inspection and reviewed the licensee's controls for radioactive material and contamination. The following matters were reviewed:
posting, labelling, and control of radioactive and contaminated materials; personnel use of contamination control devices The evaluation of the licensee's performance in this area was based on review of on-going work activities, discussions with personnel and review of documentatio The following positive observation was made:
The licensee's station exhibits about 5 % contaminated floor space. The low percentage indicates very good licensee efforts to minimize contaminated floor spac The licensee was maintaining excellent contamination controls of steam generator work activities. There were very few personnel contaminations. The licensee contained eddy current machines in specially designed contamination control glove boxes. The boxes served to control contamination at its source and greatly minimized gross contamination of steam generator work platforms and the potential of personnel exposures to hot particle The following matter was brought to the licensee's attention:
The licensee controls the removal of material and equipment from known contaminated areas within the radiological controlled area (RCA) by appropriate surveys and bagging of equipment as necessary. - Personnel exiting known contaminated areas are required to perform personnel frisking at the closest frisking station. Consequently, when equipment is removed from the RCA that was not in a known contaminated area, the licensee performs limited frisking of the equipment or material at the RCA boundary because of -the controls implemented at the contaminated area boundaries located inside the RCA. Inspector discussions with personnel noted instances of equipment found outside the RCA with slight internal contaminatio The inspector noted that the licensee initiated a nuclear department incident report on December 16, 1991 to document identification of copper tubing with internal contamination found at an electrician's desk outside the RCA. At the time of the inspection, the licensee was evaluating the findin The licensee suspended release of all material from the RCA which could not be verified as internally non-contaminated even though it had come from an apparent clean (non-contaminated) area within the RC The inspector noted that in light of these findings, there was an apparent need to re-evaluate the practice of performing limited frisking at RCA boundarie The inspector indicated that the circumstances surrounding the removal of the contaminated tubing from the RCA and the effectiveness of the licensee's contamination control practices at the RCA boundary was _an unresolved item (50-272/91-32-01).
9.0 Plant Tours The inspector toured the radiological controlled areas of the facility periodically during the inspection. The following matters were discussed with licensee personnel:
During tours of the piping penetration area (78' elevation Unit 2 Auxiliary Building) on December 16, 1991, the inspector was almost sprayed with hot sparks from overhead cutting work. The fire watch for the area had his back turned and was vacuuming the floor. No warning signs or fire curtains were present. The matter was brought to the attention of safety personnel who informed station staff at outage n:ieetings regarding proper control of hot wor.0 Exit Meeting The inspector met with licensee representatives denoted in section 1 of this report on March 8, 1991. The inspector summarized the purpose, scope, and findings of the inspection. No written material was provided to the licensee.