IR 05000272/1995016
| ML18101A997 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 08/31/1995 |
| From: | Bores R, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18101A996 | List: |
| References | |
| 50-272-95-16, 50-311-95-16, NUDOCS 9509080177 | |
| Download: ML18101A997 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. *
Docket No License No /95-16; 50-311/95-16 50-272, 50-311 DPR-70, DPR-75 Licensee:
Public Service Electric and Gas Company P. o. Box 236 Hancocks Bridge, NJ 08038 *
Facility Name: Salem Nuclear Generating Station, Units 1 and 2 Inspection At:
Hancocks Bridge, New Jersey Inspection Conducted:
August 7 - 11, 1995 Inspector: Approved b~~.
R. Bo s, ie Faci ities Rad~Section ist Areas Reviewed:
Announced inspection of the radiation control program, including: audits and surveillances, radiation control operations, radiation instrumentation, dosimetry, and respiratory protectio Results:
The licensee's radiation control program elements generally were of very good quality. Minor areas for improvement.were identified in several area No safety concerns or violations of regulatory requirements were i dent ifi ed.
9509080177 9508'31 PDR ADOCK 05000272 Q
DETAILS INDIVIDUALS CONTACTED PRINCIPAL LICENSEE EMPLOYEES W. Billings, Radiological and Chemistry Support J. Foti, Operation Services, Radiation Protection Instruments C. Fricker, Salem Quality Assurance R. Gary, Hope Creek Radiation Protection Operations R. Granberg, Radiological and Chemistry Support T. DiGuiseppi, Emergency Preparedness/Radiological and Chemistry Support E. Lawrence, Salem Quality Assurance K. O'Hare, Salem Radiation Protection, As Low As Reasonably Achievable (ALARA)
E, Villar, Salem Licensing J. Wray, Radiological and Chemistry Support R. Yewdall, Radiological and Chemistry Support STATE OF NEW JERSEY D. Vann, Bureau of Nuclear Engineering NRC EMPLOYEES C. Marschall, Senior Resident Inspector The 'bov~ *individuals attended the inspection exit meeting on August 11, 199 The inspector also interviewed other*individuals during ~he inspectio.0 PURPOSE OF INSPECTION The purpose of this inspection was to review the radiation control program at the Salem Nuclear Generating Statio.0 AUDITS AND SURVEILLANCES LICENSEE AUDIT The latest licensee audit of the radiation protection program (Audit Report No.95-150) was conducted on June 5-23, 1995. This high quality technical audit identified the following strengths: self-assessment, radiation worker knowledge, management eff~ctiveness, ALARA briefings, and high radiation area key control. The audit also identified seven minor findings that were not safety significant. The audit team included four technical specialists from four outside utilitie.2 SURVEILLANCES The licensee implemented an internal self-assessment program of the radiation protection program beginning in 1995 as part of a station-wide effort to enhance the self-identification of weaknesses in each
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department are The inspector reviewed several individual self-assessment reports and reviewed the first and second quarter 1995 self-assessment summary reports. Several areas for improvement were identified and this program appeared to provide a focus for the departmen The in~pector viewed this as a very good surveillance progra The licensee also utilizes Radiological Occurrence Reports (RORs) that may be used by any station worker to report radiological event RORs require the investigation of radiological events, causal analysis, and determination of corrective action~ to prevent recurrenc The licensee includes personnel contaminations as RORs, and these compose most of the level "one" ROR Level "one" RORs are the least safety significant and level "three" RORs are the most safety significan As of August 7, 1995, the licensee had recorded 59 level "one" RORs, 15 level "two" RORs, and 6 level "three" RORs during 199 The inspector reviewed 15 of the level "two" and "three" RORs to determine the effectiveness of the licensee's radiological problem solving capability and the use of radiological events as feedback on program adequac Most of the RORs reviewed by the inspector were the result of low significance personnel errors, and corrective actions typically specified counselling of the individua Two of the RORs (95-036 and 95-051) involved the use of.the wrong RWP and not wearing proper dosimetry, respectively. The licensee provided very thorough investigations of these events, considered several causal aspects of the events and provided multiple corrective actipns that were tracked until closure. The inspector determined that the licensee demonstrated very effective radiological problem resolution capabilit.0 ORGANIZATION-CHANGES The licensee *has a stable radiation protection (RP) organizatio The previous Senior ALARA Supervisor has taken a leave of absence to work for the Institute of Nuclear Power Operations. A qualified ALARA Supervisor has been promoted to fill the senior supervisor positio During the current long-term plant shutdown, the RP organization has been expanded to include 93 contractor RP technicians providing around-the-clock coverag The radiation protection/ chemistry (RP/C) services group has been reorganized to include the emergency preparedness grou The radiation protection instrument calibration responsibility has been transferred to the measurement and test equipment (M & TE) grou The inspector determined that RP instrument selection and inventory levels were still controlled by the RP organizations of Salem and Hope Creek stations~ The above mentioned changes were determined not to have any deleterious affect on the radiation controls progra RP OPERATIONS AND ALARA During this inspection, Salem Units 1 and 2 were in an extended shutdown condition with some limited radiologically significant work in progress.
The inspector toured areas* of the station, observed some radiological work and attended several ALARA pre-job briefing *
The licensee had originally developed an ALARA goal of 220 person-rem for both Salem Units 1 and 2 for 1995. This estimate included the Salem Unit 1 refueling outage of 180 person-re The ALARA goal-to-date as of this inspection was 28.6 person-rem versus actual accumulated personnel exposures of 78.2 person-re The licensee indicated that the previous Salem Unit 2 refueling outage extended into 1995 due to extended workscope which resulted in 15.7 person-rem carryover into 199 In addition, Unit 1 experienced an unplanned forced outage in 1995 that resulted in another 15.7 person-rem that was not budgeted for 199 Due to the continued shutdown of Salem station, the licensee has begun developing a Unit 1 extended outage work schedul At the time of this inspection, the work planning for this extended outage had not been finalized and therefore, the ALARA exposure estimate could not be define The ALARA group was working with the maintenance and scheduling groups to obtain maintenance work plans as early as possible (generally one week in advance).
In spite of the limited advance notice, the ALARA group appeared to provide the requisite resources to limit exposures for the emergent work situation caused by the unplanned extended outage shutdown conditio The ALARA group added approximately 15 ALARA contract technicians and was in the process of procuring quantities of lead shielding to address the outage ALARA need The inspector participated in ALARA pre-job briefings of workers tasked with steam generator maintenance mobilization and with the residual heat removal heat exchanger end bell remoyal wor Both meetings demonstrated a good RP organization and work group rapport and appropriate discussions of the radiological hazards/controls and work evolution detail The inspector observed workers in the station and determined that very good RP technician oversight of jobs was being provided and that workers appeared to be conscientious in observing protective clothing dress requirements and other radiation work permit requirement Good RP support was also observed at the central radiological controlled area access point throughout the inspection perio The inspector determined that appropriate radiation protection coverage was being provided and that adequate ALARA exposure reduction efforts were being provided during the emergent work condition environment found during this inspectio.0 RADIATION INSTRUMENTATION The inspector reviewed the licensee's program for calibration and ensuring continued operability of portable radiation survey instruments and counting laboratory instruments with respect to regulatory requirement The licensee has established a new RP instrument calibration facility in the new Services Buildin The facility was designed and built with significant lead and concrete shielding to safely support riperation of
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calibration sources. The calibration facility was kept locked arid was appropriately posted. A rotating beacon was mounted outside the facility to indicate when a calibration source was exposed, however, the rotating beacon was not automatically activated when a source was
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exposed, but was operated manually by a wall switch located inside the facility. During this inspection the inspector observed two instances when a calibration source was expose During one instance, the calibration technician forgot to turn on the warning beacon and during the other instance the-beacon was turned on some time after the source was withdrawn from its shield. The facility contains three calibrators of which two contain protective interlocks to ensure the source is shielded when the area is accessible to personne Only one calibrator did not have automatic personnel access controls, and this calibrator was not capable of generating a high radiation area that would require lockin The licensee's portable gamma radiation survey instruments were calibrated with a 400-Curie cesium-137 source, housed in a Shepherd 89 calibration shield and with a 100-milliCurie cesium-137 source housed in a Shepherd 28 calibrator. Electronic pocket dosimeters were calibrated with a 3-Curie cesium-137 source housed in a Shepherd 81 calibrato Located in the basement of the security building was an additional calibration facility utilized for exposing TLDs for quality control purpose The security building calibration facility utilized a 20-Curie cesium-137 source housed in a Shepherd 81 calibrator. This ca li brat ion facility was properly secured and posted. At both calibrator locations, the inspector verified the current operation of each calibrator's safety interlock devices and noted that for the 400-Curie calibrator, the 20-Curie calibrator, and the 3-Curie calibrator, that they were designed to prevent access to personnel while the sources were expose The calibrator containing the 100-milliCurie cesium-137 source did not contain an interlock device and produced a dose rate field of approximately 400 mrem/hr at 30 centimeters from the exposed source. Although the licensee _had the required posting and control requirements in place fo*r the high radiation area generated by the 100-milliCurie source, the exposed source condition indication could be improved to ensure personnel inside the facility and those attempting to enter the facility during a source exposure condition would be appropriately warned of the immediate radiological hazar The licensee agreed that enhancements could be made and indicated plans to electrically couple the outside rotating beacon with the 100-milliCurie and the 3-Curie source position indicator circuits to cause the beacon to energize automatically*while the sources are expose The inspector reviewed the most recent calibration of each calibrator and found that each had been calibrated by a National Institute of Science and Technology {NIST)-traceable transfer standard using an electrometer with~n an *nnual time perio The annual calibration of each calibrator was detailed and incorporated appropriate correction factors for temperature and barometric pressure. The inspector reviewed the reproducibility of the various exposure geometries and determined
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that they were accurately defined for each calibrator. The calibration method of each calibrator except for one, consisted of repetitive measurements at differing source distances utilizing a transfer :
standar The 100-milliCurie calibrator was calibrated at only one distance from the source and approximately 30 other source distances were calculated assuming a point source geometr The inspector discussed with the licensee the limitations of assuming a simple point source geometry and the need for verification of this approac The licensee committed to revising the calibration methodology of the 100-milliCurie calibrator and provide transfer standard measurements at several distances as the basis of the calibration. This revised approach was found acceptable to the inspecto *
Calibration of portable radiation instrumentation was performed dn a semi-annual basis. Calibrations generally consisted of three points on each of the instrument scales with an acceptance criterion of +/-10%.
The calibration date and due date were recorded on stickers affixed to each instrum~nt and documented in a file for each instrument maintained in the M & TE instrument facility. The inspector sampled the instrument inventory and calibration records and determined that all of the instruments reviewed were found to be within the six-month calibration frequenc The ~P counting laboratory utilized high purity germanium (HPGe)
detectors, gas-flow proportional counters, thin-window Geiger-Mueller detectors and zinc sulfide scintillation detectors for the measurement of various media samples to determine the gamma isotopic content and gross beta and gross alpha activity. The inspector verified that the
'HPGe detectors had been properly calibrated within one year and that the other counting laboratory instrumentation had been calibrated within the past six month All calibration sources used were traceable to NIS The licensee utilizes daily soutce measurements to determine if counting instrumentation is still functioning properly between calibration Appropriate trending of the daily source measurements were maintained for each detector use The inspector observed indications of deteriorating performance for one of the HPGe detectors (No. 4) since August 2, 199 The daily source measurements indicated that this detector was positively biased greater than two standard deviations from the mean for several days and was approaching a positive bias of three standard deviations from the mea The inspector reviewed the licensee's actions to assess a deteriorating performance trend. The licensee has a contingency procedure, including a checklist, to verify detector operating characteristics and a followup source count acceptance criterion of +/-5% to allow for continued operation of the detector. The checklist had been utilized to monitor the detector's deteriorating performance, but the licensee had not yet discovered the cause of the noted performance tren Projecting from the daily performance trend, the detector could expect to fail outside of the positive 3 standard deviations within 2 or 3 day The procedure checklist did not provide instructions to increase the level of
- attention in order to correct the performance trend before failur The licensee agreed to review the procedure checklist and provide additional instructions as necessar The inspector determined that the RP instrument calibration program was sound and well implemented with only a few areas where enhancements were recommende.0 DOSIMETRY EXTERNAL EXPOSURE DOSIMETRY The inspector reviewed the licensee's external exposure dosimetry program with respect to regulatory requirement The licensee utilizes the vendor-supplied services of Teledyne Brown Engineering (hereafter referred to as Teledyne) for thermoluminescent dosimetry (TLD) and TLD processing services. The licensee utilized the Teledyne model P-300DS TLD which is currently National Voluntary Laboratory Accreditation Program (NVLAP) approved in all eight radiation categories of TLD testing. The accreditation remains effective until October 1, 199 The inspector requested from the licensee records of recent NVLAP TLD performance test results and NVLAP onsite assessment repor The licensee had not received *or reviewed the subject NVLAP evaluations that form the basis of continued NVLAP accreditation. The licensee contacted the vendor and provided the inspector with documentation of NVLAP fourth quarter 1994 performance test results and the onsite NVLAP assessor's inspection field notes dated April 28-29, 199 The TLD performance results were generally good, with results averaging within 60% of the NVLAP acceptance limits.* The NVLAP onsite inspection resulted in a few administrative quality control deficiencies, which were addressed by Teledyne as indicated in a May 23, 1994, letter to NVLA During the inspection, the inspector was apprised of a TLD performance problem that occurred during the fourth quarter of 199 In implementing a quality control (QC) blind spike TLD program with Teledyne, the licensee discovered that 30% of the spiked spare TLDs resulted in readings that were 25% low, with the other badges indicating accurate result The licensee indicated that historically, Teledyne processing of the licensee's QC TLD badges have been within -1% to +3%
bias. Teledyne's preliminary evaluation determined that the calibration factors or element correction factors (ECFs) for the affected TLDs had changed. Teledyne implemented corrective action to determine new ECFs for each TLD read to ensure correct readings were obtaine The fourth quarter 1994 personnel TLD badges were processed in January 1995 and each was provided with a new ECF calibration that was applied to each badg The inspector reviewed with the licensee the past QC badge results and Alnor electronic personnel dosimetry vs. TLD comparisons since the fall of 1993 when ECFs were previously determined for the TLD The inspector determined that the above discussed bias problem was strictly a 4th quarter 1994 TLD proble The licensee's QC spike program
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utilized a cesium-137 source to deliver a 200-400 mrem exposur The corresponding NVLAP acceptance criteria for category IV (high photon group) is 50% when summing the bias and the standard deviation value For tha fourth quarter 1994 QC badges, an average bias of -11.9% with a standard deviation of 13.4% was calculated by the licensee. This sums to 25.3%, a passing NVLAP grade. Therefore, the licensee did not consider the fourth quarter, 1994 TLD perfor.mance to be unacceptabl As a result of this inspection, the licensee has agreed to discuss the issue with other Teledyne TLD users on an informal basi The inspector's review of past personnel TLD and spiked TLD data and comparisons with electronic pocket dosimeter (EPD) data indicate that there were no significant exposure discrepancies caused by the TLD ECF changes that remain to be. addresse The licensee and Teledyne cooperated well to ensure the accuracy of the personnel exposure records were maintaine The cause of the TLD ECF changes and long-term corrective actions have not been determined as of this inspection perio The inspector considers the licensee's actions adequate, with no violations of regulatory requirements identifie Official record personnel dosimetry results were obtained from quarterly TLD processin During each calendar quarter, EPDs were used to provide real-time occupational exposure control in the plant. The inspector reviewed the licensee's program for calibration of EPD The inspector determined that the EPDs were calibrated appropriately and there were apprppriate administrative controls in place to ensure they are calibrated on a semi-annual basi The inspector reviewed dosimetry data that compared TLD results with EPD results for each quarter of 1994 and the first quarter of 199 The EPD results showed a-positive bias of between 4% and 12% when compared to TLD results during this time period. This is a good conservative relationship that helps prevent the occurrence of over-exposures while awaiting the quarterly TLD result The licensee also reviews individual EPD versus TLD data discrepancies of greater than 20% above a 300 mrem threshol Less than 1% of the badges have required a discrepancy investigation based on 1994 and first quarter 1995 dat The inspector determined that the licensee has a good external exposure dosimetry program that produces reliable results. The licensee has implemented a_good quality control spiked TLD program that provided effective warning of deteriorating TLD performance and the licensee successfully recovered from such an event that occurred during the fourth quarter of 199 The inspector discussed with the licensee closer ties with the vendor TLD service to include more timely review of NVLAP testing results and NVLAP inspection findings as well as ensuring long-term corrective actions associated with TLD processing problems are resolve The licensee representatives indicated that this area would be evaluate.2 INTERNAL 'EXPOSURE DOSIMETRY The licensee utilizes a single standup sodium-iodide whole body counter
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that provides for relatively quick whole body screening of workers to determine the presence of gamma-emitting radionuclide As was analyzed and discussed in a previous inspection report
, the standup sodium-iodide whole body counter was found to have questionable capability to accurately discriminate the radionuclides found at the Salem and Hope Creek Generating Stations~ At the conclusion of the previous inspection, the licensee had committed to restoring to service a high purity germanium detector whole body counter and maintaining an annual calibration to provide the capability of accurate internal exposure measuremen During this inspection, the licensee indicated that the high purity germanium whole body counter was not a servicable instrument and no contingency for providing investigational internal exposure measurements, as in response to a station emergency or due to planned internal exposures, had been develope The inspector reviewed results of whole body counts over the past five months and noted that there were only seven investigational whole body counts, all of which were well below exposure tracking level Historically, the radiation control programs of both Salem and Hope Creek have provided very good contamination. controls and controlled the generation of airborne radioactive area No precedent has been established that would suggest the need for an indepth internal exposure measurement and dose assessment progra The inspector indicated that establishment of such a capability at least on a contingency basis would be pruden The licensee agreed and committed to establish a memorandum of u~derstanding with another facility that can provide additional internal exposure dosimetry services in the event of a radiological event or plant emergency involving significant internal exposures. This will be reviewed in a future inspection (IFI 50-272,311/95-16-01). RESPIRATORY PROTECTION The inspector reviewed the licensee's respiratory protection program with respect to regulatory requir~ment Maintenance of all the respiratory protection equipment for Salem and Hope Creek Nuclear Generating Stations was performed at the Hope Creek Nuclear Generating Station. The inspector toured the Hope Creek respirator maintenance facility and determined that a good program was being implemente Sound respirator cleaning, surveying, repairing, inspecting, and storing procedures were being implemente One minor area of discrepancy was identified by t~e inspector. Respirator face pieces and high efficiency particulate air (HEPA} filters were tested for percent penetration using a corn oil aerosol/photometer test apparatu The licensee used an acceptance criteria of 0.1% penetration for this test. This was not compatible with the penetration acceptance criteria for the HEPA canisters (99.97% removal efficiency}. The licensee revised the applicable procedure to incorporate a more 1NRC Inspection No. 50-272/94-05; 50-311/94-05 conducted on February 14-18, 1994
- restrictive penetration acceptance criterion of 0.01%.
Air pressure regulators were calibrated annually as evidenced by calibration stickers affixed to each air regulato The inspector opened several respirators at random and inspected each for condition of use and reviewed maintenance records for eac All sampled respirators appeared to be in good condition and acceptable for issue. Maintenance records were available for each as require The inspector reviewed the respirators found in the facility and determined that there were National Institute for Occupational Safety and Health/ Mine Safety and Health Administration approvals for each type of respirator utilized. The inspector determined that the licensee's respirator maintenance program was of good quality with only one minor discrepancy noted with respect to particulate penetration acceptance criterio Respirator issuance was confined to the Salem RP access point to the radiologically controlled area. Only RP technicians were authorized to issue respirators to worker The procedure requires the RP technician to access the PREMS (local area network RP computer system) to review whether a medical examination, a respirator fit test, and respirator training have been provided for an individual within a one-year perio If the computer network indicated an individual was qualified, the RP technician would issue the respirator to the individua No discrepancies were noted by the inspector with respect to respirator issue and contro Respirator fit testing was provided by use of a dust-sensitive photometer that measured respirator efficiency during a multiple-step dynamic movement of the test individual, to ensure adequate.protection was afforded the individual by the respirator under normal work condition The inspector verified that the dust photometer had been calibrated by the manufacturer within one yea The inspector's review of the licensee's respiratory protection program found the program to be well developed and very well implemente No significant discrepancies were note.0 EXIT MEETING The inspector met with licensee representatives (denoted. in Section 1.0)
on.August 11, 1995. The inspector summarized the purpose, scope and findings of the inspectio The licensee acknowledged the inspection findings.