IR 05000293/1982014

IE Insp Rept 50-293/82-14 on 820517-21.No Noncompliance Noted.Major Areas Inspected:Radiation Protection Program, Including Transportation & Radwaste Mgt

ML20062C398
Person / Time
Site:	Pilgrim
Issue date:	07/09/1982
From:	Dan Collins, Greenman E, Wray J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062C387	List: IR 05000293/1982014 ML20062C381
References
50-293-82-14, NUDOCS 8208050243
Download: ML20062C398 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /82-14 Docket No 50-293 License No. DPR-35 Priority -

Category C Licensee: Boston Edison Company M/C Nuclear 8_00 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: May 17-21, 1982 Inspectors: ^^

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D. J. Collins, R diation Specialist date g*

~-:=f $~ $~ S J. R. Wra9, Radiation Speciali date Approved:

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7" [* 88 E. G. Greenman,' Chief, Facilities date Radiation Protection Section ( Inspection Summary:

l Inspection on May 17-21, 1982 (Repcrt No. 50-29'/82-14)

Areas Inspected: Routine, unannounced safety inspection of the Radiation l

Protection Program by two region-based inspectors (62 hours7.175926e-4 days <br />0.0172 hours <br />1.025132e-4 weeks <br />2.3591e-5 months <br />), including:

licensee action on previous inspection findings; transportation and Radiocctive l Waste Managemen Results: No violations were identified. One unresolved ited was identified (Personnel monitoring in High Radiation areas, Detail 5). Twenty-three outstanding items were closed (Detail 2).

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8208050243 820721 DR ADOCK 05000293 PDR

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DETAILS 1. Persons Contacted i 1.1 Boston Edison Company, Pilgrim Nuclear Power Station

• J. Armstrong, Deputy Nuclear Operations Manager

• R. J. Cook, Nuclear Training

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• R. J. DeLoach, Quality Control Operations Manager L. Dooley, Supervisor, H.P. Records B. E. Eldridge, Senior Radiological Engineer J. Kane, ALARA Engineer

• Kuhn, Technical Staff, Radiological Group R. H. Oliveria, Waste Management Coordinator R. L. Schuler, Senior Radiological Engineer A. R. Trudeau, Chief Radiological Engineer G. G. Whitney, Plant Engineer E. J. Ziemianski, Management Services Group Leader 1.2 NRC

• J. R. Johnson, Senior Resident Inspector t H. Eichenholtz, Resident Inspector 1 1.3 Other persons, contractors and technicians, were contacte *Present at exit interview.

) 2. Outstanding Items:

2.1 (Closed) Unresolved Item (77-21-10): Evaluation of licensee's dosimetry capability. The inspector noted that the dosimetry program

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was evaluated extensively during the 1980 Health Physics Appraisal (Report 80-05). The evaluation of discrepancies between TLD and

, pocket ionization chambers is discussed in procedure 6.2-011, " Lost, j Damaged or Off-scale Dosimeter or TLD Investigation;" the actions for evaluation include supervisory determination .2 (Closed) Infraction (77-31-01): Exposure of an individual in excess of 3 Rem in a calendar quarter. The inspector determined that the corrective actions indicated in the licensee response dated April 4, 1978 to USNRC were as stated and adequate.

I 2.3 (Closed) Inspector Follow Item (77-31-05). Failure to instruct personnel in accordance with 10 CFR 19.12 " Instructions to Workers."

The inspector verified that the corrective actions were adequate and as described in licensee r3sponse to USNRC dated Apri! 4, 1978.

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2.4 (Closed) Inspector Follow Item (78-BU-07): Protection offered by Air-Line Respirators and Supplied-Air Hoods. The inspector reviewed licensee letter to Region I dated July 31, 1978 (BECo No.78-144)

i and further, noted that the appropriate provisions have been incorporated into the Respiratorv Protection Program and Health Physics procedure .5 (Closed) Iaspector Follow Item (78-20-01): Review licensee's action to acquire better air sample capabilit The inspector determined that Health Physics now has two GeLi detector systems within the department. The systems permit adequate turn-around time for air sample analysis during routine operations and outage .6 (Closed) Inspector Follow Item (78-20-02): Review licensee corrective actions in respiratory precectio The Health Physics Appraisal report (50-293/80-05) and a follow up inspection (50-293/81-21)

contain in-depth reviews of the licensee's program and progress towards implementation of an acceptable respiratory protection progra .7 (Closed) Infraction (78-20-03): Failure to follow Health Physics procedure 6.7-103, " Maintenance, Cleaning, Disinfection, Decontamination, and Storage of Respirators". The inspector determined that the corrective action indicated in licensee's letter to Region I dated September 6, 1978 (BECo No.78-164) was adequate and as describe The licensee has since discontinued re-use of respiratory protection filter device .8 (Closed) Inspector Follow Item (79-CI-15): Bursting of high pressure

! hose and malfunction of relief valve and "0"-ring in certain self-I contained breathing apparatus. The licensee had no units of the affected manufacturer, therefore no additional action was require .9 (Closed) Unresolved Item (79-JS-05): Radwaste shipment discrepancy reports: Shipper's Radioactive Shipment Record (RSR) No. 79-41 and 79-42. The inspector reviewed the RSR's and identified no violation or deviatio .10 (Closed) Unresolved Item (79-02-01): Sampling for reactor coolant conductivity with steaming rates greater than 100,000 pounds per hour. The inspector determined that Technical Specification 4.6.B. had been changed by Amendment 42 on May 20, 1980 to allow calibration of the conductivity cell with a reference bridg .11 (Open) Inspector Follow Item (79-19-01): Review Training audits in area of radwaste training to be done by licensee in mid-198 Licensee audit open item is still activ Licensee representative stated a formal training program was finalized by June 1,198 Implementation of portions of the program is expected by October 1, 1982. This item remains open. A Deviation was also identified in Region I Inspection Report No. 50-293/82-06 related to training prograns in this are ___ - __

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2.12 (Closed) Inspector Follow Item (80-05-01): Failure to establish formal Health Physics personnel training / retraining program. The inspector determined that a program had been established. It was evaluated during NRC Region I Inspection 50-293/81-2 .13 (Closed) Inspector Follow Item (80-05-02): Failure to have station app.oved dosimetry procedure for operating TLD system. The inspector verified the implementation of a station procedure for the TLD syste .14 (Closed) Inspector Follow Item (80-05-03) Failure to have QA program for vendor dosimetry. The inspector verified the use and acceptability of three QA operations which permit verifications of the TLD system reliability: A vendor technician, qualified on the system, reads a third chip on each TLD card to verify similarity of exposure recorded as a result of BEco technician operation of the system. No BECo person has the capability to cause this chip to be rea Discrepancies are investigated; evaluations are made, Vendor QA supplies cards exposed to known doses, which are included in each run. Vendor programming compares and reports the values; discrepancies are evaluate BECo has contracted with another vendor to expose TLD cards and report the values to BECo. These cards are inserted in each run of the syste The vendor dosimetry system processes these cards blind. Discrepancies are investigated and evaluate .15 (Closed) Inspector Follow Item (80-05-05): Failure to control high radiation areas. The inspector reviewed postings and made measurements of radiation dose rate No violations were found. High radiation area signs were attached semi permanently to fixed object .16 (Closed) Inspector Follow Item (80-05-06) Review to determine high radiation area Technical Specification has been changed. The inspector verified that Technical Specification 6.13 had been changed to the Standard Technical Specification by means of Amendment 45, September 1, 198 .17(Gosed) Inspector Follow Item (80-05-07): Failure to have a complete bioassay program. The bioassay program was reviewed during inspection 50-293/81-21. Inspection report detail 6.a.1 and 2 showed a program implementation date of January 1,1982. The licensee indicated on July 7,1982, that the program was able to demonstrate compliance using ICRP-2 methodology in accordance with IE Information Notice 82-18, " Assessment of Intakes of Radioactive Material by Workers".

The incorporation of ICRP-2 methodology will be examined in a future inspectio _ . .. . .

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2.18 (Closed) Infraction (80-05-08): Failure to prevent recurrence of 40 MPC-br exposures per 10 CFR 20.103(b)(2). The inspector determined that procedure 6.2-010 " Radiological Incident Investigation" contained guidance for evaluation of measures to preclude recurrence following identification of an exposure in excess of 40 MPC-hour .19 (Closed) Infraction (80-05-09): Failure to survey as required by 10 CFR 20.201(b) to meet requirements of 20.103 (b)(2). The inspector determined that MPC-hours were being assigned based on times and air samples while the individuals were wearing respiratory protection devices.

! 2.20 (Closed) Infraction (80-05'10): Technical Specification 6.11 procedure for 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> MPC control measures not written in accordance with 10 CFR 20. The inspector reviewed training records of Health Physics personnel and determined that training had been accomplished, as stated by licensee during inspection 50-293/81-2 .21 (Closed) Inspector Follow Item (80-05-13) Establish use of clearance tags for tools, etc., leaving controlled areas. The inspector

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determined that procedure 6.1-207, " Release of Material from Potentially

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Contaminated Areas of the Plant," provides adequate guidance to personnel to prevent the release of contaminated material for unrestric-ted us .22 (Closed) Inspector Follow Item (80-05-15): Develop surveillance program to maintain contamination levels ALARA. The inspector determined that the surveillance program of uncontaminated areas, while not mandated by procedure, provided for detection of contamination in uncontrolled areas of the plant. Frequent surveys of' controlled areas and use of step-off pads control the spread of contamination within the controlled are .23 (Closed) Infraction (80-05-18): Failure to meet 10 CFR 50, Appendix B, Criterion V regarding housekeeping. The inspector verified the corrective actions indicated by BECo letter 81-93 dated May 11, 1981. The actions were as stated. The inspector noted the general housekeeping within various areas of the plant during tours. Extensive cleanup, painting, and good housekeeping practices were evident.

2.24 (Closed) Infraction (80-29-01): High radiation door from Radwaste to Condenser Bay not locke The inspector verified the corrective actions taken as described in BECo letter no. 81-17 dated February 5, 1981 to Region .25 (Closed) Inspector Follow Item (81-04-03): Review whole body counts of workers who shoveled spent resin. The inspector reviewed the whole body counts of all the individuals involved, and noted that no uptake indicated more than 2.15% Maximum Permissable Body Burden of any isotope identifie _ - _ .

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3. Transportation 3.1 The inspector selectively reviewed radioactive shipment records for 1982. The following was verified:

3. Current applicable recipient licenses were on fil . Applicable certificates of compliance for all containers ased were availabl . Shipments were properly classified as LS .2 Of approximately 68 curies shipped, about 63 curies were depleted resin, contained in 14 of 119 shipments. The balance consisted of LSA trash, laundry, and equipment shipped to other licensee .3 The inspector observed the loading and dispatch of an LSA box shipment, briefing instructions to the sole use vehicle operator, and reviewed the shipping vehicle papers. No violations were identifie . Standby Gas Treatment (SBGT) Testing Technical Specification (TS) 4.7.8 specifies the frequency and acceptance criteria for SBGT and Control Room Filter system tests (DOP for HEPA filters and efficiency of removal of methyl iodide for charcoal).

4.1 The inspector reviewed records indicating adequate testing performed for SBGT on February 24 and March 17, 1982 (HEPA and charcoal). The inspector reviewed a safety evaluation performed in accordance with 10 CFR 50.59 to operate with one charcoal filter removed from each train. The safety evaluation appeared adequat The testing indicated adequate performanc .2 The inspector verified the adequacy of the testing of the Control Room Filter system on December 18, 1980 and October 2, 198 .3 The testing met the requirements of T.S. 4. . Staffing The Pilgrim Radiological Group organization is shown on Attachment The staffing appears adequate for routine' operations and capable of handling off-normal situation . High Radiation Area Control 6.1 Technical Specification 6.13 lists alternative control measures for access to High Radiation Areas between 100 mR/hr and 1000 mR/hr (Whole Body Exposure). Procedures 6.1-012 (Access Control for High

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Radiation Areas) and 6.1-022 (Radiation Work Permit) do not appear to fully implement the requirements of 6.13.1.c in that positive control of activities within a High Radiation Area is not specifie .2 This item is unresolved and will be reviewed in a future inspection to determine acceptability (82-14-01).

7. Bioassay Program

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The licensee's bioassay program will be examined with respect to the incorporation of ICRP-2 methodology in a subsequent

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inspection (82-14-02).

8. Exit Interview On May 21, 1982, an exit interview was held with the individuals denoted in Detail 1. A summary of the inspection findings was presente Licensee management stated that procedure 6.1-022 (Radiation Work Permit) would be revised to require management determination and attention to high radiation area survey frequency in areas subject to radiation level changes. This revision was to be implemented by May 24,1982.

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Pilgrim Nuclear Power Station l

Nuclear Operations Manager 3=

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$ l Chief Radiological Engineer l

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HEALTH PHYSICS WASTE F NAGEMENT

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l Senior Engineer l l Senior Engineer l I HEALTH PHYSICS RECORDS ALLRA 1 -

i Waste l l Supervisor l jSupervisor] l Supervisor l l Engineer ] Mgmt i i_ i l Alara I Clerk

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BEco Contractor' Chemistry BECo Contractor ALARA Shiel d/Decon Waste Q nagementj HP HP HP Health Health Technician)

NPA's

Co-ordinator l l Ttchnicians Technicians Technicians Physics Physics 1 I

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Clerks Clerks

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BECo , Contractor NPA's NPA's

• Assigned on Rotating Basis from Health Physics Technician

• • Assigned from Waste Management Nuclear Plant Attendants (NPA's)