IR 05000272/1994017
| ML18100B248 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek, 05000351  |
| Issue date: | 07/29/1994 |
| From: | Bores R, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18100B247 | List: |
| References | |
| 50-272-94-17, 50-311-94-17, 50-354-94-16, NUDOCS 9408090130 | |
| Download: ML18100B248 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No /94-17; 50-311194-17; 50-354/94-16 Docket Nos. 50-272: 50-311: 50-354 License Nos. DPR-70. DPR-75. NPF-57 Licensee:
Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge. New Jersey 08038 Facility Name:
Salem Nuclear Generating Station. Units 1 and 2 and Hope Creek Nuclear Generating Station Inspection At: Hancock's Bridge. New Jersey Inspection Conducted: June 27 - July 1. 1994 Inspector:
Approved by:
R~
date Facilities Radiation Protection Section Areas Reviewed: The inspection was an unannounced review of the radiological controls program with respect to the revised 10 CFR Part 20 regulations. Areas reviewed included:
station radiological control procedures and applicable training program Results: The licensee's radiation protection procedures were generally well written, but a few discrepancies were noted by the inspector. The revised 10 CFR Part 20 requirements were well integrated into the radiation protection program, with no discrepancies with the regulations noted. The radiation protection training program had also been thoroughly revised and was of good qualit ~DR408090130 940729 Q
ADOCK 05000272 PDR
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- DETAILS 1. 0 Individuals Contacted Licensee Personnel
- R. Dolan, Radiation Protection and Chemistry Services
- R. Gary, Hope Creek Senior Radiation Protection Supervisor - Operations
- E. Lawrence, Quality Assurance Audits
- C. Manges, Hope Creek Licensing Engineer
- M. Prystupa, Hope Creek Radiation Protection Manager
- D. Ruyter, Salem Senior Radiation Protection Supervisor
- M. Simpson, Senior Staff Engineer, Radiation Protection and Chemistry Services
- J. Trejo, Radiation Protection and Chemistry Services Manager
- E. Villar, Salem Licensing Engineer
- A. Wesolek, Nuclear Training Center Representative
- J. Wray, Salem Principal Radiation Protection Engineer USNRC Personnel
- T. Fish, Resident Inspector
- Denotes those individuals attending the exit meeting on July 1, 1994.
Other personnel were also contacted and interviewed during the course of the inspectio. 0 Radiation Protection Program Annual Review The inspector reviewed the licensee's program for review and oversight of the radiation protection program with respect to the revised 10 CFR 20.1101 ( c).
The licensee follows the Technical Specification requirement for biennial audits of the radiation protection program and the radwaste program and performs these audits on alternating years. This is in agreement with the Nuclear Reactor Regulation (NRR)
interpretation that allows 2 or 3 years to completely review the radiation protection program of a nuclear power plant (NUREG/CR 6204). No safety concerns or violations were identifie.0 Radiation Protection Program Procedure Review The inspector examined approximately 60 station radiation protection procedures, which included general station procedures, radiation protection administrative-level procedures, and health physics (HP) implementing procedures. The inspector reviewed several procedure discrepancies with the applicable. licensee personnel. The following are the results of this revie *
In general, the revised 10 CFR Part 20 requirements were found throughout all levels of the applicable station procedures. The inspector noted that the station administrative exposure limits were established at 80 % of the NRC regulatory limit The licensee has opted to restrict the use of planned special exposures, subject to Vice President - Nuclear Operations approval. The licensee has opted to record any committed effective dose equivalent (CEDE) of 50 mrem or greater, which is significantly lower than the regulatory requirement of 500 mrem. Also, the licensee has imposed a lifetime dose administrative limit of two rem per year after 17 years of age. There currently is no lifetime exposure limit contained in the NRC regulation Approximately 80 station radiation protection procedures were revised as a result of the 10 CFR 20 revision. The procedure changes were completed by the end of 1993, with a personnel training effort provided in paralle The inspector noted that the licensee's procedures met the intent of the regulations and were more restrictive than the regulations where differences existed. No concerns were identified by the inspecto.1 Radiation Protection Procedures Common to Both Salem and Hope Creek Stations The following implementation criteria conventions were adopte NC.NA-AP.ZZ-0007(Q), Rev. 2, "ALARA Program" In addition to the conventional external exposure criteria thresholds requiring ALARA review, the licensee has included an internal exposure threshold of 200 DAC-hours of collective exposure and.L 20 DAC-hours per individual. The licensee's criteria are well below the NRC regulatory requirement that states that internal exposure monitoring is required if an individual is expected to receive 2.. 200 DAC-hours per yea NC.NA-AP.ZZ-0024(Q), Rev. 3, "Radiation Protection Program" The licensee has limited TLD dosimetry issue to those radiation workers that are expected to receive 2.. 400 mrem per year or require access to a high radiation area. Previously, all radiation workers were issued dosimetry at the station. Alarming pocket dosimeters continue to be issued to all personnel entering the radiological controlled areas (RCAs) of both Salem and Hope Creek Stations to ensure the 400 mrem administrative exposure monitoring threshold is not exceeded for personnel not issued TLDs. The posting requirement for airborne radioactivity area was defined in the procedure as 2.. 0.1 DAC, which is more conservative than the regulatory requirement. The licensee has set an administrative internal exposure limit of 200 DAC-hours for both stations. This requires radiation protection manager approval and an internal monitoring program to be established for the specified individual(s) if the administrative limit is to be exceeded. (The regulatory limit is 2,000 DAC-hours.)
Radiation Protection and Chemistry Services (RP/CS) Technical Basis Document No. 1, Rev. 2, "Personnel Monitoring Requirements" The licensee takes credit for safety glasses which are required to be worn in the RCA, and equates the lens of the eye dose equivalent to the deep dose equivalent. The licensee concludes that the alarming pocket dosimeter measures the resulting external personnel exposur RP/CS Technical Basis Document No. 2, Rev. 1, "Internal Dose Assessment" The licensee has adopted a policy of recording.L 0.5 DAC-hours per entry to any posted airborne area. To ensure internal exposure is monitored, any accumulation of L. 10 DAC-hours in any seven consecutive days requires a whole body count and subsequent measurement evaluatio RP/CS Technical Basis Document No. 3, Rev. 1, "Exposure Control" The licensee has reprogrammed the Personnel Radiation Exposure Management System (PREMS)
software to lock out any worker who is not issued a TLD from entering the RCA on an RWP that allows access to a high radiation area. In addition, the plant high radiation area postings have been changed to indicated that TLDs are required for entry into these area RP/CS Technical Basis Document No. 4, Rev. 1, "Dosimetry Records and Reports" The licensee has added the requirement to issue annual exposure reports to all monitored workers in accordance with 10 CPR 19.13 and 10 CPR 20.220 RP/CS Technical Basis Document No. 5, Rev. 1, "ALARA" The licensee's ALARA policy has been enlarged to encompass internal exposures. An ALARA evaluation is required for any task dose estimate of L. 50 mrem to an individual or mrem collective dose estimate from internal exposure source RP/CS Technical Basis Document No. 9, "Planned Special Exposures" The licensee has decided that planned special exposures should not be needed and has not developed a tracking program for their use. If needed, a procedure and a tracking system would need to be develope NC.RP-Tl.ZZ-0304(Q), Rev. 0, "Dosimetry Action Reports" Other procedures are listed below that were reviewed that were of good quality and had no significant changes or discrepancie NC.NA-AP.ZZ-0029(Q), Rev. 2, "Radioactive Material Control Program" NC.NA-AP.ZZ-0030(Q), Rev. 1, "Commitment Management" NC.NA-AP.ZZ-0045(Q), Rev. 2, "Respiratory Protection Program" NC.NA-AP.ZZ-0058(Q), Rev. 1, "Corrective Action Program" M12-AP-1, Rev. 3, "Radiation Protection/ Chemistry Services Organization and Administration"
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RP/CS Technical Basis Document No. 6, "Restricted, Controlled and Unrestricted Areas" RP/CS Technical Basis Document No. 7, "Review of the Radiation Protection Program" RP/CS Technical Basis Document No. 8, Rev. 1, "Air Sampling Program" 3. 2 Salem Radiation Protection Procedures The following specific procedure discrepancies were note SC.RP-TI.ZZ-0209(Q), Rev. O, "Release of Items from the RCA" The licensee has listed appropriate unrestricted release criteria for surface contaminated objects, however, the procedure does not provide guidance for surveying volumetric materials (e.g., soil, oil, or scabbled concrete) at the environmental lower limits of detection specified in station Technical Specifications. The licensee stated that the procedure would be revised to include this guidanc SC.RP-TI.ZZ-0302(Q), Rev. S, "Visitor Processing I Special Dosimetry Issue and Monitoring" Attachment 1, "Guideline for Visitor RCA Access Orientation", Step 9, states that visitors will be sent records of their respective exposures in cases where their exposures reach 25 % of 10 CFR 20 dose limits or if the visitors submit written requests for their exposures. The regulations (10 CFR 20.1502) require exposure monitoring and reporting when an individual is expected to reach 10% of the 10 CFR 20 dose limits. The licensee stated that the subject procedure would be revised accordingl SC.RP-Tl.ZZ-1001(Q), Rev. 3, "Radiological Occurrence Investigations" Attachment 1 provides descriptions of radiological occurrences segregated into three severity levels. Under the description for level 2 events the procedure states that unexpected but verified internal exposures of > 10 MPC-hours in a single entry constitutes a level 2 radiological occurrence. The licensee stated that this would be changed to indicate > 10 DAC-hours in a single entr The following implementation criteria conventions were adopte SC.RP-TI.ZZ-0201(Q), Rev. 1, "Access Control Point Management" The licensee records skin dose calculations resulting in L.. 125 mrem and all internal exposures resulting in L.. 0.5DAC-hour SC.RP-TI.ZZ-0203(Q), Rev. 1, "Locked High Radiation Area Key Control System" The licensee describes the controls for very high radiation area entry, which includes RPM approval.
SC.RP-TI.ZZ-0206(Q), Rev. 2, "DAC Hour Accountability" Any RCA entry resulting in L. 0.5 DAC-hours will be entered into the PREMS database and if L 10 DAC-hours are accrued by an individual during seven consecutive days, the PREMS computer will flag the individual as requiring a whole body count. The whole body count measurement and evaluation will provide the threshold for internal exposure monitorin SC.RP-TI.ZZ-0401(Q), Rev. 2, "Non-Routine Bioassays" This procedure restricts RCA access to individuals who have accrued L 400 mrem CEDE during a calendar year until an internal dose monitoring plan can be established by the Radiation Protection Enginee The following procedure comments are offered for consideration and evaluation and represent areas of less safety significanc SC.RP-TI.ZZ-0601(Q), Rev. 3, "Air Sampling" This procedure describes a breathing zone sample as collected generally 4-6 feet above the floor and within 2-3 feet of the worker. There is no guidance given as to when a lapel air sample should be obtained versus a fixed area air sample. This guidance may be necessary when the licensee elects to allow individuals to obtain airborne radiological intakes in the interest of overall lower exposures (Total Effective Dose Equivalents) and yet fails to obtain adequate surveys of the airborne intakes. The Radiation Protection Engineer (RPE) agreed to review and evaluate the need for additional procedural guidanc SC.RP-TI.ZZ-0702(Q), Rev. 0, "Use and Control of Temporary Lead Shielding" This comprehensive procedure contains some excellent details for placement of temporary lead shielding. One aspect of the procedure suggests prevention of an unposted or uncontrolled high radiation area that could be caused by the unauthorized movement of shielding material. The procedure in Sections 3.2, 5.6.1.B, and 5.7.4, refers to locking the shielding in place if the preshielded condition is L. 10 rem/hour at 30 centimeters. Since the Technical Specification requirement for locking high radiation areas is set at L. 1 rem/hour, the procedure does not prevent the accidental exposure of sources L 1 rem/hour but less than 10 rem/hour for removal of in-place shielding. The licensee stated that this area would be reevaluate Other procedures are listed below that were reviewed and were of good quality with no discrepancies note SC.RP-TI.ZZ-0105(Q), Rev. 0, "Radiation Protection Shift Duties and Responsibilities" SC.RP-PQ.ZZ-0169(Q), Rev. O, "Supervisor Qualification Process" SC.RP-TI.ZZ-0202(Q), Rev. 2, "Radiation Work Permits" SC.RP-TI.ZZ-0204(Q), Rev. 1, "Posting of Radiation Signs and Barriers"
SC.RP-TI.ZZ-0205(Q), Rev. 2, "Decontamination of Personnel and Skin Dose Assessment" SC.RP-TI.ZZ-0208(Q), Rev. 1, "Discrete Radioactive Particle Skin Dose Assessment" SC.RP-TI.ZZ-0402(Q), Rev. 1, "Use, Inspection and Control of Respiratory Protection Devices" SC.RP-TI.ZZ-0602(Q), Rev. 2, "Radiation and Contamination Surveys" SC.RP-TI.ZZ-0702(Q), Rev. 2, "ALARA Program Implementation" SC.RP-TI.ZZ-0804(Q), Rev. 1, "Labelling and Control of Radioactive Material" SC.RP-TI.ZZ-0808(Q), Rev. O, "Discrete Particle Exposure and Contamination Control" SC.RC-RC.ZZ-0502(Q), Rev. 0, "Routine Operation of Radiation Protection/
Chemistry Counting Facility" SC.RC-RC.ZZ-OSOl(Q), Rev. O, "Count Room Daily Equipment Quality Control" The inspector determined that the licensee had good quality procedures in place to effectively implement the revised 10 CFR 2. 3 Hope Creek Radiation Protection Procedures The following specific procedure discrepancies were note HC.RP-TI.ZZ-0204(Q), Rev. 4, "Posting of Radiological Signs and Barriers" Preceding Section 5.1 of this procedure is a "Note" that states that the words
"Danger" and "Caution" may be used interchangeably on area postings with the exception of very high radiation areas that shall say "Grave Danger". This is in contradiction with 10 CFR 20.1902 that specifies only the term "Caution" to be used in posting radiation areas. The RPM agreed to revise the procedure accordingl HC.RP-TI.ZZ-0804(Q), Rev. 4, "Labelling and Control of Radioactive Material" The licensee has listed appropriate unrestricted release criteria for surface contaminated objects, however, the procedure does not provide guidance for surveying volumetric materials (e.g., soil, oil, or scabbled concrete) at the environmental lower limits of detection as specified in station Technical Specifications. The licensee stated that the procedure would be revised to include this guidanc HC.RP-TI.ZZ-0808(Q), Rev. 3, "Discrete Radioactive Particle Exposure and Contamination Control" Minor misquoting of the RPM's title was noted. Sections 2.1.1 and 2.1.2 should say RPM not RPE. The RPM stated that this would be correcte The following implementation criteria conventions were adopte HP.RP-TI.ZZ-0206(Q), Rev. 1, "DAC-Hour Accountability" This procedure specifies the internal exposure recording threshold of.L 0.5 DAC-hours per individual entr HC.RP-TI.ZZ-0401(Q), Rev. 2, "Non-Routine Bioassays". This procedure specifies the conditions that should result in a bioassay measurement, such as.L 10 DAC-hours per seven consecutive days, and provides direction to restrict personnel who have accrued.L 200 DAC-hours from additional contaminated area acces HC.RP-TI.ZZ-0702(Q), Rev. 4, "ALARA Reviews and Documentation" This procedure has been modified to include ALARA reviews of tasks estimated to result in.L 200 DAC-hours in collective internal exposure or.L 20 DAC-hours per individual. A total effective dose equivalent ALARA evaluation methodology is provided to determine the lowest combined total dose from internal and external source The following procedure comments are offered for consideration and evaluation and represent areas of less safety significanc HC.RP-TI.ZZ-0601(Q), Rev. 1, "Airborne Radioactivity Sampling" This procedure describes a breathing zone sample as collected generally 4-6 feet above the floor and within 2-3 feet of the worker. There is no guidance given as to when a lapel air sample should be obtained versus a fixed area air sample. This guidance may be necessary when the licensee elects to allow individuals to obtain airborne radiological intakes in the interest of overall lower exposures (Total Effective Dose Equivalents) and yet fails to obtain adequate surveys of the airborne intakes. The Radiation Protection Engineer (RPE) agreed to review and evaluate the need for additional procedural guidanc HC.RP-TI.ZZ-0701(Q), Rev. 2, "Use and Control of Temporary Shielding" This comprehensive procedure contains some excellent details for placement of temporary lead shielding. One aspect of the procedure suggests prevention of an unposted or uncontrolled high radiation area that could be caused by the unauthorized movement of shielding material. The procedure in Section 5.8.3, refers to locking the shielding in place if the preshielded condition is.L 10 rem/hour at 30 centimeters. Since the Technical Specification requirement for locking high radiation areas is set at.L 1 rem/hour, the procedure does not prevent the accidental exposure of sources.L 1 rem/hour but less than 10 rem/hour by removal of in-place shielding. The licensee stated that this area would be re-evaluate Other procedures are listed below that were reviewed and were of good quality with no discrepancie HC.RC-TI.ZZ-0007(Q), Rev. 3, "Gamma Spectroscopy Analysis"
HC.RP-TI.XX-OOOl(Q), Rev. 10, "Primary Containment (Drywell) Entries" HC.RP-TI.XX-0004(Q), Rev. 6, "TIP Room Entries" HC.RP-TI.ZZ-OOll(Q), Rev. 6, "Respirator Selection, Issue and Accountability" HC.RP-TI.ZZ-0102(Q), Rev. 2, "Information Management" HC.RP-TI.ZZ-01-3(Q), Rev. 4, "Qualification Process" HC.RP-TI.ZZ-0201(Q), Rev. 4, "Access Control Point Management" HC.RP-TI.ZZ-0202(Q), Rev. 7, "Radiation Work Permits" HC.RP-TI.ZZ-0203(Q), Rev. 5, "Radiation Protection Key Control System" HC.RP-TI.ZZ-0205(Q), Rev. 6, "Decontamination of Personnel and Skin Dose Assessment" HC.RP-TI.ZZ-0301(Q), Rev. 5, "Personnel Dose Monitoring" HC.RP-TI.ZZ-0303(Q), Rev. 2, "Administrative Dose Control System" HC.RP-TI.ZZ-0502(Q), Rev. 6, "Routine Operations of Radiation Protection Gross Counting Facility" HC.RP-TI.ZZ-0602(Q), Rev. 7, "Radiation and Contamination Surveys" The inspector determined that the licensee had good quality procedures in place to effectively implement the revised 10 CFR 2.0 Radiation Protection Training Review The inspector examined the radiation worker training and HP technician training to ensure the appropriate 10 CFR Parts 19 and 20, as well as, applicable HP procedure content were provide The inspector examined HP technician 10 CFR Part 20 training lesson plans and the radiation worker training lesson plan. The inspector reviewed training attendance sheets and conducted interviews with various members of the training staf The licensee has made significant revisions to the appropriate radiation protection training lessons plans and this training has been provided to the radiation protection staff and general radiation workers. The station radiation protection procedures were not approved until late in 1993, and although the revised 10 CFR 20 regulations became effective in 1994, the training department began educating the licensee's workforce, beginning in 1991 and has done an effective job in training the workforce in the revised 10 CFR 20 regulations by January 199 In 1991, the licensee provided an eight-hour course on the revised 10 CFR 20 regulations to the HP technicians at both Hope Creek and Salem stations. In 1992, a one-hour course describing changes in station radiological posting practices due to the revised regulations was provided to the HP technicians. In 1993, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of-revised 10 CFR 20 training was provided to members of both Hope Creek and Salem HP departments that included 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> of classroom and seven hours of procedure training. The inspector determined that the Salem HP procedure training was
conducted from 15 newly revised procedures and the Hope Creek HP procedure training was conducted from 13 newly revised procedures and 9 revised procedure drafts. The inspector determined that Salem HP staff training was conducted between December 8, 1993 and January 12, 1994 with a total of 49 personnel in attendanc Completion of training was provided by live participation in a "Jeopardy" game show question and answer format with no documented testing results. Similarly, the Hope Creek HP staff training was conducted between November 16, 1993 and January 12, 1994 with a total of 47 personnel in attendance. Again, no test results were produced. The lesson plan material was comprehensive and accurate with no discrepancies note The general radiation worker training was revised on December 20, 1993 and was developed from the Institute for Nuclear Power Operations "Guidelines for General Employee Trainjng", dated November 1993. In general the licensee lesson plan contained training in the revised 10 CFR 20 regulations and included the station administrative limits, but had not incorporated many of the station program implementation details that the radiation worker might encounter in the plant. For example, on page 38 of the Radiation Worker Lesson Plan No. 202-12, the licensee defined an airborne radioactivity area as > 1 DAC or > 12 DAC-hours per week, which is correct according to the revised regulations. However, both Salem and Hope Creek stations have further defined an airborne radioactivity area in the procedures as > 0.1 DAC. The training department agreed to revise this training to match the radiation protection program definition. Further review of this training should be made with respect to the station radiation protection procedures to ensure the workers are provided with current and accurate training in the applicable parts of the radiation protection program at Artificial Islan The licensee emphasized the revised regulations by developing and providing a color brochure entitled, "The New 10 CFR 20, Overview of the Revision and its Impact on the PSE & G Nuclear Department, " to each radiation worker prior to the implementation of the revised regulations. This brochure was an excellent training aide, providing the necessary information in layman's terms and in an entertaining contex In general, the licensee has provided very good quality training in the revised 10 CFR 20 regulations to the workforce at this nuclear power plant sit. 0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1. 0) on July 1, 1994. The inspector summarized the purpose, scope and findings of the inspectio The licensee acknowledged the inspection findings.