IR 05000293/1980005
| ML20009B143 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/22/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Andognini G BOSTON EDISON CO. |
| Shared Package | |
| ML20009B132 | List: |
| References | |
| NUDOCS 8107140856 | |
| Preceding documents: |
|
| Download: ML20009B143 (6) | |
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JUL 221980 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. G. Carl Andognini Manager, Nuclear Operations Department 800 Boylston Street Boston, Massachusetts 01299 Gentlemen:
Subject: Health Physics Appraisal The NRC has identified a need for licensees to strengthen the health physics programs at nuclear power plants and has undertaken a significant effort to assure that action is taken in this regard. As a first step in this effort, the Office of Inspection and Enforcement is conducting special team appraisals of
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the health physics programs, including the health physics aspects of radioactive waste management and onsite emergency preparedness at all operating power reactor sites. The objectives of these appraisals are to evaluate the overall adequacy and effectiveness of the total health physics program at each site and to identify areas of weakness that need to be strengthened. We will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements but also for effecting improvements in NRC requirements and guidance.
This effort was
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identified to you in a letter dated January 22, 1980, from Mr. Victor Stello, Jr., Director, NRC Office of Inspection and Enforcement.
During the period of January 28 - February 8,1980, the NRC conducted the special appraisal of the health physics program at the Pilgrim Nuclear Power Station. Areas examined during this appraisal are described in the enclosed report (50-293/80-05). Within these areas, the appraisal team reviewed selected procedures and representative records, observed work practices, and interviewed personnel.
It is requested that you carefully review the findings of this report for consideration in effecting improvements to your health physics program.
The findings of the appraisal at Pilgrim indicate that although your overall health physics program is adequate for present operations, several significant
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weaknesses exist. These include the following:
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lack of technical proficiency among the staff assigned to health physics
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lack of an established health physics training and retraining program
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8107140856 800s14 gDRADOCK 05000293 PDR
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Boston Edison Company M/C Nuclear JUL 231980
an inadequate internal exposure control program
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inadequate facilities for maintenance / storage of respiratory protection
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equipent, radiation monitoring instrument calibration, internal dosimetry and radwaste storage several deficiencies associated with the ability to organize and mobilize
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personnel, particularly, in health physics, in the event of an emergency.
These findings are discussed in more detail in Appendix A. "Significant Appraisal Findings." We recognize that an explicit regulatory requirement pertaining to each significant weakness identified in Appendix A may not currently exist.
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However, to determine whether adequate protection will be provided for the health and safety of workers and the public, you are requested to submit a written statement within twenty (20) days of your receipt of this letter, describing your corrective action for each significant weakness identified in Appendix A including:
(1) steps which have been taken; (2) steps which will be taken; and (3) a schedule for completion of action.
This request is maue pursuant to Section 50.54(f) of Part 50. Title 10, Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities do not appear to have been conducted in full compliance with NRC requirements as set forth in the Notice of Violation enclosed herewith as Appendix B.
The items of noncompliance in Appendix B have been categorized into the levels of severity as described in our Criteria for Enforcement Action dated December 13, 1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations, requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including): (1)correctivestepswhich have been taken by you and the results achieved; (2 corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
You should be aware that the next step in the "RC effort to strengthen health physics programs at nuclear power plants will be the imposition of a requirement by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop, submit to the NRC for approval, and implement a Radiation Protection Plan.
Each licensee will be expected to include in the Radiation Protection Plan sufficient measures to provide lasting corrective action for significant weaknesses identified during the special appraisal of the current health physics program.
Guidance for the development of this plan will incorporate pertinent findings from all
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special appraisals and will be issued by NRR in the fall of this year.
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Boston Edison Company M/C Nuclear JUL 321980
In accordance with Sectic 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the.NRC's Public Document Room.
If this material contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such infonnation from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses the items which will be considered by the Commission as listed with specificity (4) of Section 2.790.
The information sought to be withheld Subparagraph (B)
shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, this letter and the enclosures will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
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AW B ce H. Grier
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irector
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Enclosures:
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Appendix A, Significant Appraisal Findings 2.
Appendix B, Notice of Violation 3.
Office of Inspection and Enforcement Inspection Report No. 50-293/80-05 cc w/encls:
P. L McGuire, Pilgrim Station Manager
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APPENDIX A SIGNIFICANT' APPRAISAL FINDINGS A.
Internal Exposure Control Program The overall program for internal exposure control was found to be inadequate and not effective due to:
lack of confidence in the direct measurement activities (whole body
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counter). There was a lack of technical oversight for this operation and weakness in personnel training and qualifications of those indi-viduals assigned to operate and calibrate the whole body counter.
lack of procedures to provide for proper collection, handling and
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analysis of indirect bioassay samples; together with a lack of pro-cedures establishing biological models and calculational techniques necessary to evaluate monitoring data in tenns of dose assessment and compliance with intake limitations set forth in 10 CFR 20.103.
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failure to ensure consideration of engineering controls for airborne
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radioactivity areas or to evaluate and document the practicability of applying process or engineering controls in airborne radioactivity areas. Excessively high loose radioactive contamination levels existed in many areas of the plant and a program to reduce and main-tain significantly lower levels was not implemented.
lack of adequate facilities for cleaning, inspecting and maintaining
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respiratory protection equipment.
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lack of adequate training for contractor health physics technicians in
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the operation of the respirator fitting booth.
lack of in-plant surveillance to insure proper usage of respiratory
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equipment.
failure to have a technically knowledgeable individual assigned re-
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sponsibity for maintaining cognizance of developments in respiratory protection use and equipment and evaluation of the effectiveness of the respiratory protection program.
Additional concerns relating to the internal exposure control program are documented in Appendix B, " Notice of Violation" and are identified as items of noncomplianc '
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Appendix A
B.
Personnel Selection and Training Program A program for training / retraining members of the health physics staff at Pilgrim is essentially non-existent.
The level of fonnal training and education of most of the staff and the contractor personnel is limited.
Appraisal findings established that:
there is no fonnal training / retraining prograra that exists for members
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of the plant health physics staff. A check sheet (qualification) is used to document that personnel have received new hire orientation and some on-the-job orientation.
there is no established retraining program in radiation safety for
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general emricyees.
there was minimal effort to determine the qualifications of the con-
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tractor supplied health physics personnel. The program in place consisted of only a screening process.
The training provided these individuals is lacking and the qualifications of many of the con-tractor health physics technicians used during the refueling outage were questionable.
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Emergency Preparedness The present equipment configuration for emergency environmental monit-
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oring in conjunction with existing proceduros are inadequate since there is an inability to detect, measure and project radiation levels and radionuclide concentrations in air equivalent to the lower limits of the Protective Action Guides.
The present procedure for declark t at emergency is based s_o'ely on r
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the results of the rapid proter.cd i'es survey.
The survey method is inadequate and dependence n.c ;
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" uracceptable.
Several emergency plan impicment.ng 'orocedures have become outdated
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due to changes in personnel and facilit,ias and have not been updated.
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The current emergency plan training program as written in the Pilgrim
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Station Training Manual is not being implemented. The 1979 radiation emergency plan training was not perfonned in accoidance with the training manual program.
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Appendix A
The state of readiness of emergency equipment, i.e., items missing and
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out of calibration, appeared to indicate some maintenance problems.
There was a lack of a clear assignment of emergency duties and respon-
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sibilities for radiation protection and emergency repair / corrective i
actions.
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