IR 05000272/1992005
| ML18096A687 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 05/06/1992 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A686 | List: |
| References | |
| 50-272-92-05, 50-272-92-5, 50-311-92-05, 50-311-92-5, 50-354-92-05, 50-354-92-5, NUDOCS 9205150158 | |
| Download: ML18096A687 (19) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-272/92-05 50-311/92-05 50-354/92-05 Docket Nos. 50-272 50-311 50-354 License Nos. DRP-70 DPR-75 NPF-57 Licensee:
Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge. New Jersey Facility Names:
Salem Nuclear Generating Station. Units 1 and 2 Hope Creek Nuclear Generating Station Inspection At:
Hancocks Bridge. New Jersey Inspection Conducted:
March 30 - April 3. 1992 April 13 - 16. 1992 Inspector:
Approved by:
Areas Inspected:
R. L. Nimitz, CHP, Senior Radiation Specialist
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W. Pasciak, Chief Facilities Radiation Protection Section 5 lthL date This inspection was a routine inspection of the radiation protection programs at the Salem and Hope Creek Generating Stations. Areas reviewed were organization and staffing, training and qualifications, audits, ALARA, routine radiological controls, ventilation systems (Hope Creek only), radioactive material and contamination controls, and previous finding Findings The licensee was implementing, overall, a very good radiological controls program. There was a need to review the effectiveness of controls for release of potentially contaminated material from the radiological controlled areas. An unresolved item associated with audits of personnel qualifications was identified. No safety concerns or violations of regulatory requirements were identifie PDR ADOCK 05000272 G
- . DETAILS Individuals Contacted Public Service Electric and Gas Company The following individuals attended the April 3, 1992, exit meeting at the Hope Creek Station:
J. J. Hagan, General Manager, Hope Creek Operations
. R. Hovey, Manager - Operations J. Clancey, Radiation Protection/Chemistry - Manager M. Prystupa, Radiation Protection Engineer - Hope Creek J. Ray, Radiation Protector Engineer - Salem B. Hall, Technical Manager - Hope Creek M. Cirelly, License Engineer - Hope Creek E. Karpe, Senior Radiation Protection Supervisor ALARA J. Molner, Senior Radiation Protection/Chemistry Supervisor - Support D. Parks, Principal Training Supervisor K. Maza, Chemistry Supervisor The following individuals attended the April 16, 1992, exit meeting at the Salem Station:
C. Vondra, General Manager, Salem J. Wray, Radiation Protection Engineer, Salem K. O'Hare, Supervisor ALARA E. Katzman, Radiation Protection/Chemistry Services Engineer W. Schultz, Manager, Station QA, Salem E. Villar, Station Licensing Representative P. Benni, Principal Engineer, QA T. Cellmer, Radiation Protection/ Chemistry Manager, Salem V. Polizzi, Operations Manager, Salem Others M. Sesok, Atlantic Electric Site Representative (Attended the exit meeting on April 3, 1992.) NRC T. Johnson, Senior Resident Inspector, Salem/ Hope Creek Stations (Attended the April 16, 1992, exit meeting.)
2. 0 Areas Reviewed The following areas were reviewed during the inspection:
organization and staffing training and qualification audits and assessments ALARA external exposure control internal exposure controls radioactive material and contamination control 3. 0 Licensee Action on Previous Inspection Findings (Open) Unresolved Item (50-272/91-32-01)
The NRC will review the circumstances and licensee corrective actions (as appropriate)
associated with the December 16, 1991, discovery of contaminated tubing outside the radiological controlled area (RCA). The individual with the tubing (an I&C technician)
was asked by the licensee where he had obtained the tubing and was informed that it was brought into the RCA from a box under his desk and used for work on a non-contaminated system. The licensee checked the box and found an additional piece of tubing with contamination levels of about 10,000 pm/100 cm squared.
. The original piece that the technician was attempting to bring out of the RCA measured about 15,000 disintegrations per minute (pm)/100 centimeters (cm) squared. Both pieces were returned to the RCA. The licensee believed the tubing may have been released some time earlier but was identified as contaminated following the implementation of more rigorous. frisking of material leaving the RCAs. Time limitations precluded the inspector from completing the review of this matter. However, the inspector did note the following history of contamination control weaknesses:
May 1990:. A contaminated shoe was released from the Salem Statio June 1990-.Five contaminated tools were found in the B Building July 1991-A contaminated test gauge was released from the Hope Creek RC December 1991-Contaminated tubing was found outside the Salem RC February 1992-A contaminated pipe wrench was found outside the Salem RC After identification, all of the above material was returned to the radiological controlled are *
In light of the above non-all inclusive list, there appears to be a need to review, from a combined Hope Creek/Salem station point of view, the effectiveness of contamination controls at the stations' RCA boundaries. The above item remains open pending further NRC review of contamination control.2 (Open) Unresolved Item (50-272 & 311/92-28-01; 50-354/91-21-01)
NRC to review the licensee's actions to address dosimetry program weaknesses identified via an outside audit of the program by National Voluntary Laboratory Program (NVLAP)
assessment personne The inspector's review indicated that the licensee initiated commendable actions to resolve the finding The licensee initiated the following actions:
The licensee enhanced quality assurance of the dosimetry processin The enhancements include daily and monthly trending of reader sensitivity correction factors. The licensee also uses special dosimeters to provide real time quality assurance of processin The licensee has trained all personnel in applicable procedures including new procedures and procedure revisions. The licensee has developed a procedure upgrade schedul The licensee has been performing laboratory inter-comparisons and blind testin The licensee anticipates completion of the procedure upgrade program by the end of the year and completion of development of a permanent dosimetry organization by June 1992. This matter remains ope.0 Organization and Staffing General The inspector reviewed the organization and staffing of the on-site radiation protection organizations. The review was with respect to criteria contained in applicable Technical Specifications and licensee administrative document The inspector evaluated licensee performance in this area by review of applicable documentation, discussions with cognizant individuals, and independent observation of on-going work activities throughout the stations.
5 Hope Creek (Findings)
The inspector found that the organization was essentially fully staffed and generally well defined. The organization and staffing provided effective support of station activitie The following observation was made:
Station Administrative Procedures provided descriptions of responsibilities, accountabilities and qualifications. Authorities are identified in implementing procedures. In reviewing the responsibilities in the area of radwaste shipping, the inspector noted that there was a memorandum of agreement regarding inter-transfer of waste between the Salem and Hope Creek Stations. However, the job description for the Radiation Protection Supervisor-Radioactive Material appeared to need updating to reflect actual responsibilities for final disposition of waste from the stations. It was not clear which individual (either from the Sale Station or Hope Creek Station) was responsible for final release of packaged waste from the station. The licensee indicated this matter would be reviewe No violations were identifie. 3 Salem (Findings)
The inspector determined that the organization was well defined and well staffed. The licensee enhanced the organization to support outage activities and established supplemental documents to define responsibilities of radiation protection personnel during the outage. The organization provided effective support for outage work with minimal use of overtim No violations were identifie.0 Training and Qualification General The inspector reviewed the training and qualification of radiological controls personnel at the stations. The inspector also reviewed the training of radiation workers. The review was with respect to applicable Technical Specification requirements, licensee administrative documents, and 10 CFR 19, Instructions to Worker The evaluation of the licensee's performance in this area was based on discussions with personnel, review of training records and qualification documents and review of resumes to verify experience. The inspector also observed personnel performance in the field.
6 Hope Creek The inspector's review of the training and qualification of selected radiological controls personnel and radiation workers indicated that the individuals were appropriately trained and qualified. Radiation workers who had worn respiratory protective equipment had received appropriate training. The following observations were made:
The inspector noted that the licensee has recently embarked on a program to provide for enhanced developmental opportunities for those supervisors who had been in their positions for several years. The opportunity involved rotation of supervisors to other supervisor positions. The action was initiated in the summer of 1991 with actual position changes occurring in September 1991. The inspector noted that the licensee provided several months for the individuals to. transition to the new position. Specialty training, as appropriate, was provided for individuals moving into a new area (e.g., system training), individuals were required to complete a qualification card, and the licensee performed an evaluation of personnel qualifications relative to applicable requirement Departmental directives were updated to reflect responsibilities and assigned individuals. It was noted however, that procedures did not identify needed procedure training for supervisors moving into the new position The inspector noted that the licensee has initiated a new type of training called integrated training which involves radiation protection personnel and maintenance personnel planning for and performing a work activity together at a stator water cooling mock-up at the Salem Training Center. The work activity was performed in a realistic manner and monitored and video taped. The class was critique Radiation survey and monitoring equipment, which can be adjusted to indicate apparent radiation and contamination levels, are used during the training. The training was considered a very good initiative. This training was also given to Salem personnel (radiation protection and maintenance).
The licensee rotates radiation protection technicians from shift work every three months and assigns them to a different area for about six month The inspector's review found that all technicians are trained in all applicable procedures and that the technicians are informed of procedures changes for the new are The following matter was brought to the licensee's attention:
The licensee notifies personnel of important matters (e.g., procedure changes and industry events) via three required reading logs. The logs are the health and safety log, the required reading log, and the night order log. Personnel also receive operations event training on recent industry events and procedure training at the Salem training cente *
The inspect~r reviewed the administrative controls for the required reading logs and noted that the licensee's procedures require that individuals sign acknowledgement sheets to indicate reading of the required reading material. The inspector noted that all individuals were not reviewing assigned reading in a timely fashion. For example, a new departmental directive entitled Radiological Free Release of Bulk Liquids and Free Flowing Solids from Hope Creek, HC.RC-DD.ZZ-0018, Revision 0, was issued for required reading on February 2, 199 The directive provided requirements for minimum sensitivity for counting of free flowing solids to be released off-site to ensure the solids were free of by-product (radioactive) materia The inspector noted that Department Directive HC.RC-DD.ZZ-0004, Dissemination of Health & Safety Information of Interest to Radiation Protection/Chemistry Personnel, requires, in Attachment 1, that department directives be reviewed as soon as possible (ASAP) during the shift. It also indicates that Radiation Protection/Chemistry supervision shall periodically review signature sheets to assure entries have been read in a timely manne The inspector's review of the signature sheet for the above Departmental Directive, issued on February 2, 1992, indicated that as of about 2 months after issuance of the directive, 7 individuals had not signed off indicating they had read and understood the Department Directiv The inspector indicated that the failure to read the required reading material within the specified period was a violation of Technical Specification 6.11 which requires that radiation protection procedures be adhered to. The inspector noted that this matter had minor safety significance since the chemistry group personnel, who had all reviewed and signed the signature sheet for the new directive, were principally responsible for implementing it. In addition, the licensee immediately initiated action to require all appropriate personnel to read and acknowledge by signature understanding of the directive. Also, the licensee initiated a supervisor sign-off to ensure supervisors periodically reviewed the required reading and ensured all personnel had signed off appropriate documentation. In light of the above this was considered a non-cited violation in accordance with the criteria specified in 10 CPR Part 2, Appendix B,Section V. The inspector sat through presentation of reactor core isolation system training provided to radiation protection personnel. The instructor covered radiological aspects of the system. However, the training manual used did not include any of the information provided. The licensee was reviewing the need for enhanced system trainin *
- Salem (Findings)
The inspector reviewed the training and qualification of selected contractor radiation personnel hired to augment the staff during the refueling outage. The review indicated the contractors had received appropriate training and were properly qualifie The inspector also determined selected radiation workers had received proper trainin The following matter was brought to the licensee's attention:
The inspector made an entry onto the 21/23 steam generator platforms to observe initial preparations for steam generator work activities. The inspector questioned the radiation protection technician covering the radiological work activity and determined that the individual was a Hope Creek technician on loan to the Salem station for the outage. Although the technician appeared to be providing effective control, subsequent questioning indicated the individual had not received any training on Salem specific radiation protection procedure Although some procedures were generic and applied to both Salem and Hope Creek, training had not been provided on specific procedures. The licensee subsequently removed this individual and three others from job coverage pending review of applicable procedures.
Subsequent inspector review indicated the licensee had recognized this matter and was developing a list of procedures for review. The inspector considered it a weakness to allow this individual to cover work activities without review of applicable procedures, particularly if the procedures are different from Hope Creek specific procedures which were routinely used by the technician. The inspector indicated this matter should be reviewed from a generic basis to ensure that individuals in other disciplines receive appropriate specific training when on loan to the other station. This matter is considered unresolved (50-272/92-05-01; 50-311/92-05-01; 50-354/92-05-01).
No violations were identifie.0 Audits and Assessments General The inspector reviewed the audits and assessments performed at the Hope Creek and Salem Stations. The review was with respect to applicable criteria contained in Technical Specifications and licensee procedures.
The evaluation of *the licensee's performance in this area was based on review of documentation, review of auditor qualification records and discussions with cognizant individuals. In particular, the inspector reviewed Audit No.91-150, Site Radiation Protection (performed August 12-September 4, 1991), and various QA surveillances performed at each statio.3 Hope Creek (Findings):
The licensee was considered to be performing good audits and surveillances of the radiation protection progra The licensee performed scheduled and unscheduled surveillances of the radiation protection program, including during back shifts using detailed checklists. The QA audits contained a mixture of documentation review and performance based observations. In addition, supervisor tours were routinely performe Self-identified (e.g., radiological occurrence reports) and audit identified concerns were resolved in an appropriate manner.
No violations were identifie.4 Salem (Findings)
The licensee performed appropriate audits of the radiation protection progra A radiological assessor was used to provide independent oversight of on-going work activities during the current refueling outage. There was very good supervisory oversight of on-going work activitie The inspector noted that there was limited QA surveillance of on-going outage work activities. This was brought to the licensee's attention as an area for improvemen No violations were identifie.5 Audits of Qualifications The inspector noted that Hope Creek Technical Specification 6.5.2.4.3, Audits, requires that audits of facility activities be performed under the cognizance of the Off-site Safety
- Review (OSR) Committee and shall encompass the performance, training, and qualifications of the entire facility staff at least once per 12 months. The inspector's review of Audit No.91-040, Training, conducted January 28-February 15, 1991, indicated that the audit contained little indication of audit of personnel qualification Also, inspector discussions with cognizant QA personnel, relative to this matter, indicated that personnel qualifications were not routinely audited by the corporate QA grou According to the QA personnel, the qualification of personnel relative to the requirements of Technical Specification 6.3, Unit Staff Qualifications, were not routinely audited. The inspector did note that the on-site QA surveillance groups did review the qualifications of certain groups. It was unclear if the licensee was implementing the audit requirements of Technical Specification 6.5.2.4.3. This matter was considered unresolved and applied to both the Hope Creek and Salem Stations (50-272/92-05-02; 50-311/92-05-02; 50-354/92-05-02).
The licensee initiated action to review this matter, provide for a base line qualification audit, and coordinate audits of personnel qualifications at the site. The inspector's review did not identify any individual who did not meet at least minimum qualification requirement. 0 ALARA Efforts General The inspector_ reviewed selected aspects of the licensee's ALARA Program. In particular the inspector. reviewed efforts by the licensee to plan for the March 1992 mid-cycle outage at Hope Creek and the refueling outage at Salem Unit 1. The review was with respect to criteria contained in the following:
Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achievable Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable NUREG/CR4254, Occupational Dose Reduction and ALARA at Nuclear Power Plants; Study on High-Dose Jobs, Radwaste Handling and ALARA Incentive The evaluation of the licensee's performance was based on discussions with cognizant personnel, independent inspector observations during tours of the stations, observations of on-going work activities, and review of documentatio.2 Hope Creek (Findings)
The inspector's review indicated the licensee was making very good efforts to reduce occupational radiation exposure. The following observations were made:
On March 30, 1992, the licensee used a robot (Miser) to search for leaks in the area of the A Steam Jet Air Ejector. The robot entered an area that exhibited radiation dose rates up to about 5,000 mR/hr. The robot was equipped with video recording which allowed its observations to be tape recorded for later viewing. The use of the robot precluded entry into the area by personne The licensee implemented a number of enhancements to the loading of radwaste shipping containers. The enhancements were expected to provide for savings of about 5 person-rem per yea During the previous refueling outage, the licensee directed the discharge of under water vacuum cleaners into the fuel pool clean-up syste This precluded handling of highly radioactive filters from a _self-contained filter system resulting in an annual radiation exposure savings of about 2 person-re The following additional observations were made:
The licensee has been on the third cycle of zinc (.1 ppb) injection. The zinc injection has shown favorable results, according to the licensee, in maintaining radiation levels on primary system piping lo The licensee replaced seals on the Reactor Water Clean-up Pumps with a new desig As a result, only one seal was replaced in the last 17 month Previously an average of 5-8 seals were replaced in about the same time fram This has resulted in significant exposure savings since seal replacement averaged about 2 person-rem/sea The licensee was initiating a program to remove excess iron (currently 5-10 ppb)
from feed water by use of a special resin. The licensee was trying to achieve less than 2 ppb in feed wate During the up-coming refueling outage, the licensee will inspect and look for large quantities of crud to remove it. This will be removed during the up-coming outage. Following the outage, the licensee will initiate hydrogen water chemistr The licensee has instituted a "soft shutdown" to cool down in order to quickly by-pass the zinc solubility region. This minimizes release of zinc to the primary syste *
- The licensee was actively flushing hot spots, was tracking hot spots, and installed blank flanges for flushin The licensee generated an exposure goal for the mid cycle outage (March 1992)
(12 person-rem) and sustained 11.026 person-rem. No intake of airborne material or unplanned external exposure occurred during the outage. During the outage the licensee developed passes to control access to the drywell. The shift manager or outage manager authorized entrie This served to reduce unnecessary personnel traffic in the drywell and associated personnel exposur The inspector reviewed ALARA aspects during review of on-going work. The following weakness was identified:
An individual was observed at about 3:00 p.m. on March 30, 1992, double bagging miscellaneous radwaste articles at the Hope Creek compactor area (102'
elevation radwaste).
The individual was performing this activity in an area measuring about 15 mR/h The individual could have moved to a lower radiation dose rate are Salem (Findings)
The inspector's review indicated that the licensee was performing excellent planning and preparation for the Unit 1 refueling outage. Of particular note was the licensee's efforts to plan for steam generator work activitie The following matters were brought to the licensee's attention:
Low dose rate wait areas were not posted in the Unit 1 penetration are Personnel were observed holding conversations in elevated radiation level.0 Rad Material Control General The inspector reviewed the control of radwaste, contaminated material, and contamination. The following areas were reviewed:
personnel frisking practices proper contamination control work techniques posting and labeling (as appropriate) of contaminated and radioactive material efforts to reduce the volume of contaminated trash including steps to minimize introduction of unnecessary material into potentially contaminated areas adequacy of contamination surveys to support planning for and support of on-going wor ' Hope Creek (Findings)
Overall control of radioactive and contaminated material and contamination appeared to be goo * The following matters were noted:
Evidence of ingestion of food stuff in the radiological controlled area was identified. A candy wrapper was found in the compactor area. A gum wrapper was found in the hot machine sho *
Stantions used to demarcate contaminated areas were placed inconsistently. Some were inside the contaminated boundary while others were outside or over* the boundarie.3 Salem (Findings)
Overall control of radioactive and contaminated material and contamination appeared to be good. However, additional details are provided in Section 3 of this report relative to review of an event associated with contaminated material found outside the radiological controlled are. 0 Routine Radiological Controls General The inspector reviewed the implementation, adequacy and effectiveness of the radiological controls programs. The inspector toured selected portions of the radiological controlled areas of the Salem and Hope Creek Stations and reviewed the following elements of the license's radiological controls 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 dosimetry devices airborne radioactivity sampling and controls contamination controls installation, use and periodic operability verification of engineering controls to minimize airborne radioactivity
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performance and adequacy of radiological surveys to support pre-planning of work and on-going work hot particle controls implementation of radiation work permit The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, review of on-going work activities and review of vanous document.2 Hope Creek (Findings)
The inspector's review of radiological work activities performed during the March 1992 mid-cycle outage indicated that overall, effective radiological controls were implemented for the work activities performed. The work activities reviewed included replacement of a reactor recirculation pump sea There were no unplanned internal or external radiation exposure The following matter was brought to the licensee's attention:
The inspector's review of the High Radiation Area Key Loan Log Book on March 31, 1992 identified the following:
On March 28, 1992, on six (6) occasions, the shift radiation protection technician did not sign the log book indicating that radiation protection keys had been returned. Two of the keys were sub-masters (CC and CB)
which allowed entry into various areas greater than 1000 mR/hr in the turbine buildin On March 29, 1992, on two (2) occasions, the shift radiation protection technician did not sign the log book indicating that keys had been properly returne On March 30, 1992, on two (2) occasions, the shift radiation protection technician did not sign the log book indicating that the keys had been properly returne The licensee's procedure HC.RP-TI.ZZ-0203(Q), Revision 1, Radiation Protection Key Control, requires that the shift radiation protection technician sign the High Radiation Area Key Loan Log to indicate that the keys were returned to the key locke The inspector noted that failure to adhere to radiation protection procedure HC.RP-Tl.ZZ-0203(Q) and sign back in two sub-master High Radiation Area access control keys on March 28, 1992 was a violation of Technical Specification 6.11 which requires that radiation protection procedures be adhered t The inspector noted that the failure to sign keys back in involved only *one individual who was informed of this matter. The inspector noted that the.licensee also notified all appropriate personnel of the need to properly sign keys back i The licensee also developed a supervisor review sheet that requires supervisors to review key status. Lastly, the inspector noted that although the keys were not signed back in, they were audited at the end of each shift and determined to be present. In light of the above, and in accordance with the criteria of 10 CFR Part 2, Appendix B, Section V. A, this matter is a non-cited violatio The inspector's review of radiation survey documentation indicated that the survey documentation was unclear as to whether certain measurements were actually made. The inspector noted certain surveys indicated "No beta". The inspector asked what this meant and was informed that beta measurements were made but no beta radiation was detected. Other individuals indicated that no measurements were made. This was considered a survey documentation weakness which the licensee indicated would be reviewe. 3 Salem (Findings)
The inspector independently reviewed initial on-going work activities associated with the Unit 1 outage. Work activities reviewed included: removal of the reactor vessel head, retraction from the reactor vessel of irradiated highly radioactive flux thimbles, removal of insulation from the pressurizer, underwater diving activities associated with testing the fuel up-ender in the Unit 1 spent fuel pool, replacement of service water piping in the penetration areas of the Unit 1 Auxiliary Building, and work activities associated with set-up of steam generator work control..
The inspector's review identified overall, very good radiological controls and supervisor and management oversight of the work activities. Radiation protection technicians were providing an appropriate level of control, airborne radioactivity control measures were effectively used, and High Radiation Areas were properly controlle The following matters were brought to the licensee's attention:
The inspector's review of dosimetry records for Unit 1 radiation workers indicated that some records appeared to be incomplete or inaccurate (e.g.,
unsigned NRC Form 4, incorrect work dates, incorrect identification of female as a male, unverified data, and apparent incorrect logging in computer of record completion). The licensee initiated an immediate review of this matter. The accuracy of the information and the licensee's conformance with approved procedures was considered an unresolved item (50-272/92-05-03; 50-311/92-05-03; 50-354/92-05-03).
The licensee performed an immediate sampling of other worker dosimetry records and did not identify any widespread programmatic problems. The licensee also determined no administrative exposure limits were exceede The inspector reviewed initial entry of a diver into the Unit 1 spent fuel pool at about 11:00 a.m. on April 15, 1992. The entry was controlled by procedure SC.RP-TI.ZZ-llOl(Q), Revision 0, Radiological Controls for Diving Operation Section 5.1.3 of the procedure states in part:
"Perform the following pre-dive radiological surveillances:
A. Perform a detailed radiation survey of the transition and work areas using two independent instruments (TLDs may be considered one type of instrument);"
The inspector's review indicated that the licensee performed two independent radiation surveys at the principal work areas near the up-ender. However, the inspector's review indicated that two independent instruments were not used to survey the transition area in the southwest comer of the Unit 1 spent fuel. The transition area involved the area where the diver dropped to the spent fuel pool floor from the pool surface along the wall of the spent fuel pool and worked on an underwater vacuum cleaning system prior to moving to the up-ender area to check the up-ende The inspector indicated that failure to adhere to the radiation protection procedures and perform the second independent radiation survey in the transition area was a violation of Technical Specification 6.11 which requires the procedures be adhered t The inspector noted however, that the radiation protection technician had performed an initial survey. of the transition area using one meter and shortly thereafter verified that the meter used was functioning properly by re-checking radiation dose rates at the up-ender area which had previously been surveyed by two independent survey method In addition the diver was equipped with a hand-held underwater survey meter. Since the licensee informed all personnel of the need to adhere to procedures and the area entered was surveyed by an instrument that was re-checked for operability, and in accordance with the criteria contained in 10 CFR Part 2, Appendix B, Section A., this matter was considered a non-cited violation. Subsequent inspector review indicated that the worker, based on pocket dosimeter readings, sustained about 50 millirem exposur.0 Ventilation System Testin The inspector reviewed the surveillance testing of the Hope Creek Technical Support Center ventilation system. The inspector also performed an independent walk-down of the Hope Creek Control Room emergency ventilation system. The review was with respect to criteria contained in applicable Technical Specifications and surveillance testing procedure The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, independent walk-down of the ventilation systems and review of documentatio The inspector reviewed surveillance test data for the Technical Support Center Emergency Ventilation system. The following data were reviewe visual inspection results in-place leak test data laboratory test data for charcoal flow and pressure drop information
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The following observations were made:
The control room emergency ventilation system uses portions of the normal ventilation system during the emergency mode. The inspector found two loose chocks on one access door down stream of A VH-403-(Normal Supply). The inspector also found one chock unlocked. The licensee personnel opened the access door and found a damaged door gaske The freon injection test connection/tubing was left in place in the control room emergency ventilation system upstream of AVH-400. The inspector's review of the last freon test indicated the test rig had been remove A bolt was missing from the charcoal addition portal on the Technical Support Center (TSC) ventilation syste The flexible collar (expansion joint) for connection of duct work to the TSC fan had a small hole in it. Also, the downstream collar was deterioratin One chock was open in the access door downstream of the TSC charcoal be Although the inspector's review indicated that the observations did not indicate a potential for introduction of contaminated air (under accident conditions) to be introduced downstream of filter systems, the observations indicated the need for addition oversight of the condition of these systems. The licensee initiated work orders to correct the observation _ Tb_e_ recent_lab_o~t_gry_ te_stiQg p(_c:Qai:cocµ for t!i~ T_SC v~n!il(l_tion _system showed low penetration (.048%). However, acceptance criteria used (10%) was-base((
on a 2" charcoal bed instead of criteria for a 4" bed ( <.175 % ). The TSC charcoal beds are 4". The licensee initiated a review of this matter and indicated the acceptance criteria would be reviewe. 0 Plant Tours The following observations were made during tours of the station:
During tours of the Unit 1 Containment on April 14, 1992, the inspector noted that three out of the four access/egress doors to the steam generator loop areas were padlock closed. Subsequent inspector reviews indicated that the door latches on the three doors were broken and that the remaining door provided unimpaired egress. The inspector noted that the padlocks could preclude timely egress from the loop areas in an emergency situation. The licensee immediately initiated action to repair the doors. The doors were repaired in a timely fashio During tours of the Unit 1 annulus areas on April 14, 1992, the inspector observed personnel working in the overhead on service water piping on the lower elevation of containment to not be using safety belts. A licensee safety assessor had also observed other parties and initiated action to correct the situatio The access ladder to the upper elevations of tlie pressurizer in Unit 1 containment required personnel to access the pressurizer via steeping across an opening to a platform. This was brought to the licensee's attention who indicated that they were aware of the matter and were reviewing i.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1. 0) on March 3, 1992, at the Hope Creek Station and on April 16, 1992, at the Salem Station. The inspector summarized the purpose, scope and findings of the inspection at each station (respectively). No written material was provided to the licensee.