IR 05000293/1985022

Insp Rept 50-293/85-22 on 850819-23.No Violation Noted.Major Areas Inspected:Implementation of Radiological Improvement Program Commitments,Previously Identified Items & Review of Unmonitored Releases

ML20133F463
Person / Time
Site:	Pilgrim
Issue date:	10/02/1985
From:	Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133F455	List: IR 05000293/1985022 ML20133F451
References
50-293-85-22, NUDOCS 8510110047
Download: ML20133F463 (25)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-22 Docket N License N OPR-35 Priority --

Category C Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: August 19-23, 1985 Inspectors: . _ . MT. N d lo Ii l 95 R. L. Nimitz enior Ra'diation Specialist date Approved by: NC<~ 3 0 '7- 6 W. Pa' scia C CEief date i BWR Radiation Safety Section l

Inspection Summary: Inspection on August 19-23,1985 (Report No. 50-293/85-13)

Areas Inspected: Routine, announced inspection of the following: licensee

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implementation of Radiological Improvement Program (RIP) commitments; previously identified items; review of several unmonitored releases; and preparation for diving in the fuel storage poo The inspection involved 35 inspection hours onsite by one region based inspecto Results: No violation were identified. The licensee was satisfactorily l implementing his RIP Commitments. The licensee took satisfactory corrective l action for the unmonitored releases. Additional attention to the area of radiological controls preparation and planning for fuel pool work is needed.

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DETAILS 1.0 Individuals Contacted I

1.1 Boston Edison Company (BECo)

• A. L. Oxsen, Vice Pesident-Nuclear Operations

*W. H. Deacon, Assistant to the Senior Vice President-Nuclear

• D. E. Mastrangelo, Chief Operating Engineer

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• A. R. Trudeau, Chief Radiological Engineer l *E. T. Graham, Compliance Management Group Leader

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• J. Smallwood, Senior Chemical Engineer (Acting Chief Chemical Engineer)

• L. Dooley, Training Supervisor

• J. McCann, Watch Engineer

• D. Tepper, Human Relations l

• T. Sowdon, Radiological Controls

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• J. Crowder, Compliance l 1.2 Contractors

• H. Smith, Hydro-Nuclear In * Denotes attendance at the NRC/ Licensee exit meeting on May 24, 1985.

l The inspector also contacted other licensee personne .0 Purpose of Inspection

! The purpose of this routine, announced. radiological controls inspection was to review the following programs elements:

• Previous findings,

• Radiological Improvement Program,

• Transfer of sewage to town of Plymouth,

• Overflow of sewage onsite,

Apparent unmonitored airborne radioactivity release path from " hot" machine shop, and

• Radiological controls for diving.

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3.0 Licensee Action On Previous Findings 3.1 (Closed) Follow-up Item (50-293/85-13-01) Licensee to establish guidance / action levels to be used as criteria to identify

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potentially contaminated normally uncontaminated systems. The licensee established acceptable guidance / action levels to be used as criteria to identify potentially contaminated /normally uncontaminated system. Appropriate personnel were trained in the new criteria. However, the inspector noted that the station air.

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systems were not identified as systems to be sanpled as potentially contaminated systems and to which the new criteria applie Licensee representatives indicated the matter would be reviewed and appropriate action taken. The area will be reviewed during a subsequent inspection (50-293/85-22-01)

3.2 (Closed) Follow-up Item (50-203/85-13-02) Licensee to establish guidance for operations personnel as to what actions to take if a normally clean system was identified as contaminated. The licensee issued a memorandum to Nuclear Watch Engineers on May 28,1985,(AD 85-132). The memorandum provides adequate guidance as to the responsibilities of the operations personnel. This matter is close .3 (Closed) Violation (50-293/85-13-04) Licensee personnel did not adhere to station procedures. The inspector reviewed this matter with respect to the corrective and preventive action documented in the licensee's August 15, 1985, letter (85-152) to NRC Region The licensee satisfactorily implemented the short term corrective actions documented in his letter. The implementation of the licensee's long term corrective action will be reviewed during a subsequent inspectio (50-293/85-22-02) Note: The licensee provided additional long term corrective actions to preclude recurrence. These corrective actions are documented in NRC Region I's September 17, 1985, letter to the licensee (Reference Inspection Report 50-293/85-13).

3.4 (Closed) Deviation (50-293/85-07-03) Licensee did not adhere to guidance contained in IE Bulletin 80-1 The inspector reviewed this matter with respect to the corrective and preventive action documented in the licensee's August 15, 1985, letter (85-152) to NRC Region I. The licensee satisfactorily implemented the short term corrective and preventive actions documented in his lette The licensee has established a plan to evaluate facility design with respect to the criteria contained in IE Bulletin 80-1 The licensee anticipates completion of the evaluation and implementation of final long term corrective actions by January 198 The implementation of the licensee's long term corrective actions will be reviewed during a subsequent inspection (50-293/85-22-03).

4.0 Implementation of Licensee Commitments Presented to NRC in the Radiological Improvement Program 4.1 General The inspector reviewed the implementation of' Radiological Improvement Program commitments presented to the NR The review was with respect to criteria and/or information contained in the following documents:

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Order Modifying Licensee, Notice of Violation, and Notice of Deviation (NRC Inspection No. 50-293/84-25 and 50-293/84-29),

dated November 29, 1984,

Letter (W. D. Harrington, Senior Vice President-Nuclear, Boston Edison, to T. E. Murley, Regional Administrator, NRC Region I),

dated February 28, 1985, (BECo Ltr No.85-042),

Licensee Completed Regulatory Requirement Analysis Forms (various) relative to Radiological Improvement Plan (RIP)

Milestones,

Licensee Radiological Activity Assessment Reports (RAAR)

(various),and

Radiological Oversight Committee (ROC) Meeting Minutes (various). s The purpose of this review was to determine if,

the licensee met the commitments (i.e. milestones) specified in the Radiological Improvement Program (RIP);

the material or actions taken/ generated by the licensee satisfactorily met the commitments made to NRC in the RIP;

the material or actions taken/ generated were properly implemente The following aspects of RIP implementation were noted and verified implemented:

a tracking program was in ' place to identify milestones due;

adequate management controls were in place to monitor implementation of milestones and initiate proper action when milestones were identified as potentially not being met;

adequate review was performed of the material or actions taken/ generated to determine its adequacy prior to its acceptance and implementatio Also, on August 20, 1985, the inspector attended and observed a Radiological Oversight Committee (ROC) meeting. Inspector observations at this meeting indicated the committee was functioning consistent with the Committee Charter presented in the licensee's February 28, 1985, letter (85-042) to NRC Region _

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4.2 Findings The inspector reviewed a total of 67 commitments that were to have been completed by the licensee by July 31, 1985. The commitments reviewed and the status of them are identified in the attachment to this repor The review indicated the licensee satisfactorily completed his committed action on 57 of the commitment Several commitments were left open due to the need for additional licensee action or NRC review. These are identified in the attachment to the repor Within the scope of the review, the following position attributes l were noted:

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The licensee's Senior Vice President-Nuclear is closely monitoring implementation of the Radiological Improvement Progra *

Radiological Oversight Committee members are touring the facility once per week. Findings identified during the tours are brought up and discussed at the ROC meetings Action is initiated to resolve problems identified.

t Within the scope of the review, the following matter requiring licensee attention was identified:

A member of the ROC has been selected as a member of the site Radiological Controls Organization. This individual is now no longer independent of that group. Consequently this individual's membership on the ROC is not in conformance with the specifications of the ROC Charter. The licensee is aware of this matter and is reviewing it. The licensee's action on the matter will be reviewed during a subsequent inspectio (50-293/85-22-04)

Conclusion Based on the above review, the licensee is adequately monitoring implementation of the RIP improvement items and is meeting commitments provided to NRC Region I 5.0 Unplanned Release General The inspector reviewed the circumstances, licensee evaluation, and licensee corrective actions associated with the following events:

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Discharge of unmonitored potentially radioactive gaseous effluents from the " Hot Machine Shop",

Transfer of unsampled station sewage to the Town of Plymouth, and

• .0verflow of sewage from the site holding / collection tank to various areas within the protected are The following matters associated with these events was reviewed:

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proper notification, where required, was made,

appropriate immediate corrective actions were taken (as necessary) to limit effluent release,

appropriate short term corrective action was taken to preclude recurrenc *

appropriate long term corrective actions were taken to preclude recurrence, and

• the licensee properly quantified the amount of radioactive material released offsit The review was with respect to criteria contained in the following:

10 CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors",

• 10 CFR 20.403, " Notification of Incidents",

• 10 CFR 20.106, " Radioactivity in Effluents to Unrestricted Areas",

• 10 CFR 20.103, " Exposure of Individuals to Concentration of Radioactive Material in Air in Restricted Areas",

The evaluation of the licensee's performance in this area was based on discussion with cognizant licensee personnel and review of applicable licensee records.

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5.2 Release from HOT Machine Shop Documents Reviewed

• Radiological Occurrence Report 85-7-30-683, dated July 30, 1985

- PNPS Failure and Malfunction Report, dated August 12, 1985

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Engineering Service Request (ESR)85-363, dated July 30, 1985

• Miscellaneous Radioactive Contamination Surveys of various fan rooms, duct work, air exhaust and intake locations dated July-August 1985

- PNPS Maintenance Request, dated August 7, 1985 General On July 30, 1985, a contamination survey of the "Old Maintenance Office" floor area identified low level floor contamination (1000-2000 disintegration per minute per 100 centimeters squared

[dpm/100 cm 2 ]). An investigation as to the source of the contamina-tion indicated it apparently was emanating from exhaust duct work in the area. Further investigation indicated the local exhaust duct work tied into exhaust duct work from the " Hot" Machine Shop. This former duct work eventually exhausted its contents to the atmosphere outside the Turbine building. (See Figure 1)

As a result of this identification, the licensee determined that an apparent unmonitored release path from the " Hot" Machine Shop may have existed for some period of time. The licensee performed the following action when the floor contamination was identified:

• On July 30, 1985, a Radiological Occurrence Report was written to document the even * On July 30, 1985, an Engineering Service Request was written to request engineering evaluation and corrective actions for the even * On or about July 30, 1985, a determination was made that Fan VEX-107 was inoperable and had in fact been tagged out of service since December 2, 198 * On or about July. 30, 1985, a determination was made that a

"backdraft damper" down stream of VEX-107 was found to be failed open. Note: This allowed contaminated air to be " blown back" into other duct work (i.e. Maintenance Area).

• On August 7, 1985, the back draft damper was repaired and fan VEX-107 was inspected, found to be operable, and placed in service. Note: Radiation Protection Personnel were unaware of the restarting of this fa * On August 8, 1985, Radiation Protection personnel identified that the fan was placed back in operation and requested it be tagged ou j

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• The NRC resident was notified on August 8, 1985, of the unmonitored release pathwa *

A Failure and Malfunction Report was initiated on August 12, 198 *

On or about August 12, 1985, the license initiated comprehensive surveys of all openings of all process buildings that could represent an unmonitored release pathway to the atmospher Surveys of plant exhaust and intake ducts of various rooms was l also initiated. All surveys were completed about August 12, 198 !

Note: No other contaminated exhausts or intakes to or from the atmosphere was identified. An intake near the control room corridor (23' elevation) indicated some low level contaminatio ~

On or about August 12, 1985, the licensee performed calculations to determine the. quantity of material that could have been -

released and an estimated off site dose resulting from this release. Because the effluent release point was unmonitored, the licensee estimated the release based on contamination levels identified in the exhaust plenum and on the exhaust louver Inspector Evaluation (Hot Machine Shop Release)

The inspector review of this matter indicated the followir.g:

• The licensee initiated timely action to: identify the source of the unexplained floor contamination; control any further release of material to non-contaminated areas; secure the source of release to the environment; identify any other potential unmonitored release points; estimate the quantities of material release * The plenum and louvers from which air from the Hot Machine Shop was ultimately exhausted to the environment exhibited low levels of contamination. No significant source term was identified based on the extent of contamination presen *

The licensee estimated that about 50 millicuries of a mixture of cobalt-60 and cesium-137 may have been released. The licensee's estimates (using various particle sizes) ranged from 2x10 5 millicuries to about 3.2 curies. However, the licensee's evaluation did not provide sufficient information to demonstrate whether he had or had not complied with the average offsite concentration values of 10 CFR 20.106 or, 2) complied with the average onsite concentration values of 10 CFR 20.103.

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The cause of the unmonitored release path was due to insuffic-Tent review when this area of the station was converted to a

" Hot" machine sho *

Licensee Procedure 3.02, " Preparation, Review Verification, Approval and Revision of Design Documents for Plant Design Changes", dated December 10, 1984, provides guidance for review of design changes by radiological control personnel. However, inspector review of this procedure indicated the procedure does not appear to clearly show how a similar event could not occu i.e., (Conversion of a normally clean room to a contaminated area and subsequent offsite release.)

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Based on the above review, the following matters are unresolved and will be reviewed during a future inspection: (50-203/85-22-05)

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licensee evaluation of offsite releases with respect to 10 CFR 20.106, a

licensee evaluation of onsite releases with respect to 10 CFR 20.103,

licensee close-out of applicable Radiological Occurrence Reports and Failure and Malfunction Reports,

licensee completion of a safety evaluation for further operation of

" Hot Shop" exhaust ventilation (including need to monitor this release point),

a source of contamination of duct work in Control Room Corridor and HP Count Room, a design change methodology to preclude recurrence, and

update of Final Safety Analysis Report to reflect actual conditions of " Hot Shop" are As a result of the above and the problems associated with the sewage system, the licensee has initiated a review of the facility with respect to IB Bulletin 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored/ Uncontrolled Release to the Environment". This evaluation is scheduled for completion in January 198 .3 Sewage Disposal To Town Documents Reviewed

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Radiological Occurrences Report 85-4-3-205, dated May 4, 1985

Licensee memorandum NMSD 85-312, dated July 5,1985,

" Investigation of PNPS Septic Pumping Chamber"

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Various station effluent sample analysis results including:

-main gate pumping station-south septic tanks-radioactive waste sanitary sump-leaching field at Pilgrim Station parking lot-sar.itation trucks-radioactive waste septic tank-radioactive waste oil separator a Various sample analysis results of samples from:

-Plymouth sanitary landfill-Baxter's grit machine-Baxter's aeration trough-nite soil settling trough-landfill drying pit General-On May 3, 1985, a drain in the licensee's " Hot Machine Shop" (23'

elevation) was identified as apparently backing up. A Radiological Occurrence Report was written at that time. Since this drain was plugged and located in a contaminated area, an investigation was initiated to determine the ultimate disposal point of the drain. The

, licensee's investigation indicated that liquid in the drain may be directed to the Main Sewage Pumping Station. Since the effluent from this pumping station is directed to an onsite leaching field and the pumping station effluent is periodically pumped out and sent to the Plymouth Sesage Disposal facility, the Main Pumping Station potentially represented an unmonitored effluent release path. The sewage flow path is shown in Figure 2. The licensee notified the resident inspector of this finding on May 10, 1985. This matter was reviewed in part during inspection 50-293/85-13. (Conducted May 20-24, 1985). At that time it was determined that the licensee had failed to implement a noncontaminated system sampling program

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consistent with the requirements of IE Bulletin 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored/

Uncontrolled Release to the Environment." The NRC took enforcement action on this matter at that time. The licensee initiated a comprehensive review of the facility design with respect to IE Bulletin 80-10 in order to identify other problems in this are The licensee took the following actions when the backed up drain was identified:

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A Radiological Occurrence Report (ROR) (No. 85-4-3-205) was written on April 3,1985 (date identified).

A review of the apparent back up was conducted shortly there-after. Because the drain is plugged, no further action was taken to examine the drain. It was believed the water was remaining on top the plu *

On or about April 8-10, 1985, a Radiological Assessor, perform-ing a tour, identified bubbles coming up from the drain. This was indication of water entering the drain. New drain plugs were installe * On or about April 8-10, 1985, a review was initiated to determine the flow path of the drain. This included dye checks of drains to determine their flow path * On or about April 8-10, 1985, or shortly thereafter, a decision was made to halt shipment of sewage to the Town of Plymout Security personnel were notified not to allow sewage trucks on sit *

On April 15-20, 1985, action was initiated to pump out the main sewage holdup tank *

On May 6,1985, a sample of effluent from the main sewage holdup tank was collected, analyzed and found to be contaminate * On May 10, 1985, Town of Plymouth sewage collection truck entered the site, and pumped out sewage. The truck was stopped before leaving the site, a sample of its contents was collected, analyzed and found not to be radioactiv * During the period April 8 - May 10, 1985, action was taken to isolate all potential radioactive inputs to the sewage collec-tion system. All identified inputs were rerouted to radwast (e.g. Hot Machine Shop floor drains, Radwaste Oil Separator)

• During late April 1985, and May 1985, the licensee initiated sampling of all collection tanks and sump of the sewage collec-tive system, sampled the site leaching field and sampled collection / holding areas of the Plymouth Sewage Treatment Facility / Landfil The environmental sampling and analysis program was performed by the Yankee Atomic Electric Company Environmental Laboratory. No measurable radioactivity was identified offsit r -__

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-Inspector Evaluation (Sewage To Town)

The inspector review of this matter indicated the following:

• The licensee initiated timely action to: identify the final release point of the Hot Machine Shop drains; prevent release of the material offsite; isolate the contaminated inputs into the sewage system; sample and analyze the hold-up and disposal points of the sewage; take long term corrective action to review facility design to identify any further unmonitored release point *

Concentrations of radioactive material identified in final onsite storage transfer tanks (i.e. Main Sewage Pumping Station)

were at concentrations of less than 10% of offsite average allowable concentration value *

No releases in excess of 10 CFR 20.106 or 10 CFR 20.303 was identifie *

The licensee initiated a routine sampling and analyses program for sewage to be transferred offsit * The licensee included the Plymouth landfill in his environmental monitoring progra This matter is close .4 Sewage to Bay Documents Reviewed

Letter - W. D. Harrington (BECO) to T. E. Landry (EPA), dated August 5, 1985,

• Miscellaneous overflow sample analysis results dated July 30,198 General On July 30, 1985, the licensee's Sanitory Sewage System malfunctioned causing an estimated 100 gallons of untreated sewage to flow into storm drains. The drains discharge to Cape Cod Bay via the discharge canal. The licensee investigated the cause and determined it to be inoperable level instrumentation on the sewage tank at the main

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sewage pumping' station. The level instrumentation malfunctioned causing their breaker to tri Since this breaker'also powered the

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. pumps, the pumps became inoperable. The licensee issued an Engineer-ing Design Service Request- to modify the power supplies to the level i- instrumentation and pump I Inspector Evaluation

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The inspector review of the matter indicated the following:

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The licensee initiated timely action to prevent additional waste from entering the bay. This included blocking off the

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storm drains and repairing the malfunctio *

The licensee sampled all sources of waste discharging to the storm drains. No radioactivity in excess of background was identified.

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• The licensee initiated a design change request to correct the cause of the even *

No releases in excess of 10 CFR 20.106 or 10 CFR 20.203 occurre This matter is close .0 Fuel Pool Modification (Radiological Controls)

The inspector met with licensee site Radiological Controls personnel to discuss licensee planning and preparation for. the planned increase in storage capacity of the Spent Fuel Pool. The licensee will use divers

.during underwater wor The following matters were discussed

a planning and preparation,

* establishment and approval of procedures (as necessary) for

-diving operations

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-emergency response (e.g. loss of breathing air, loss of pool water,

damage of diving equipment and suits)

-exposure control including source checking radiation survey instrumentation

• pool decontamination,

• radioactive source control (e.g. encore instrumentation),

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• water clarity,.

• control of diver approach to spent fuel, I *

dose mapping of pool including gamma and neutron radiation,

• ~ personnel dosimetry and its calibration (whole body, skin, and i

extremity),

use of multiple survey instrumentation, its calibration and periodic verification of operability, I' -*

use of survey' meters and alarming dosimeters during underwater work,

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contamination control including control of possible point sources 3 '(e g. small chips),

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control and verification of movement of spent fuel,

bioassays of diving personnel,

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training and qualification of personnel on applicable procedures,

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• - applicable NRC quidance in this area (e.g. IE Information Notice N , " Overexposure of. Diver in Pressurized Water Reactor (PWR)

Refueling Cavity"),

i a breathing air quality for divers,

previous diving operations at reactor facilities in NRC Region I,

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- The discussion with licensee Radiological Controls personnel indicated no

significant planning and preparation for the upcoming diving work had occurred. The inspector indicated the licensee's efforts in the area will be reviewed during a subsequent inspection. (50-293/85-22-06).

7.0 The inspector met with licensee representatives (denoted in Section 1 of this report) on August 23, 1985. The inspector summarized the purpose scope and findings of this inspection.

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At no time during this inspection did the inspector provide written

- material to the licensee.

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ATTACHMENT Status of Boston Edison Company's Radiological Improvement Program (RIP)

Commitment to be Completed after April 30, 1985, and before July 31, 198 COMMITMENT STATUS NRC COMMENT .2.4(a)-1 Perform a task Complete The licensees performed a analyses for all position (See NRC comment) comprehensive task within the Radiological analysis for the organiza Group's organizatio tion in place before (July 31, 1985) August 26, 198 However, on this date the licensee reorganized his Radiologi-cal Controls Organizatio This organization was to be completed by June 30, 1985, but was deferred (See RIP Item 1.m.2).

Consequently it is not certain whether a task analyses has been per-formed for all positions in the newly established organization. This matter remains Ope (50-293/85-22-07) .2.4.c-1 Complete Complete None Technician rotation policy evaluatio (July 31, 1985) .1.4-1 Improve the Open The following matters qualification process remain open:

of radiological controls personne * definition of minimum (July 31, 1985) radiological controls experience for each position in the organization

• identification of issuance of training policy-1-

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ATTACHMENT

~ COMMITMENT STATUS NRC COMMENT

• procedure T-20 check list for personnel qualifications does not match procedure Licensee action on these will be reviewed during a subsequent inspectio (50-293/85-22-08)

. .2.b-1 Develop supervisory Complete None training material ~(June 30, 1985 .2.7-1 Develop and Open Prccedure developed does

. implement a program not ensure radiological to ensure personnel controls personnel were are trained in- be trained in procedures procedure revision prior to implementing (May 31, 1985) the procedure ( watch health physics technicians) Licensee action on this matter will be reviewed during a subsequent inspectio (50-293/85-22-09) .1.1-3 Implement the Open The revised program has a revised Radiological limited discussion of the Protection portion o Radiological Occurrence the General Employee Report and a limited dis-training progra cussion of the major (July 31, 1985) feature of the Radiological Control Group structure and key individuals. The licensee's action on this matter will be teviewed during a subsequent inspectio (50-293/85-22-10) .1.2-1 Revise General -Complete (See NRC Comment on RIP Employee Training Progra Item 3.1.1-3)

(June 30, 1985)

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ATTACHMENT COMMITMENT STATUS NRC COMMENT .1.3-1 Request INPO Complete None Evaluation of General Employee Training (GET)

Progra (July 31, 1985) .1.4-1 Licensee to request Complete None Certification of GET Progra (July 31, 1985)

1 .1.5-1 Develop pretest Complete None and refresher update training for the aw GET Progra (July 31, 1985)

-1 .3-1 Develop a booklet Complete None for personnel in GET (reference).

(July 31,1985)

1 .1.2.c-1 Compare and Complete License revised and issued evaluate the use of procedures to incorporate wrist badges and finger finding rings to monitor extremity exposur (July 31, 1985)

1 .1.3-1 Evaluate significant Complete None skin contamination relative to skin exposur (July 30, 1985)

1 .1.3-2 Develop guidance Open Procedure issued provides for assigning skin exposur limited guidance relative (July 31, 1985) to assigning skin exposure at skin contamination levels less than 350,000 dpm/100 cm2 ,

(50-293/85-22-11)

1 .2-2 Review applicable Complete None procedures to determine the need for a policy for exposure of female (July 31, 1985)

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ATTACHMENT COMMITMENT STATUS NRC COMMENT 16. '4.3-1 Review physical- Open The licensee's review did controls for high radiation not address high radiation area area key controls. This (June 30, 1985) matter remains ope (50-293/85-22-12)

17, 5.1.1-2 Evaluate and modify Complete None testing program for breath-ing air syste (May 31, 1985)

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1 .1.3-1 Prepare and Complete None Implement.a procedure for training technician to inspect and repair respirator (June 30, 1985)

1 .1.3-2 Develop a training Complete None program to train technicians to inspect and repair respirator (July 31, 1985)

2 .1.4 Prepare a checklist Complete None and visual aids for inspect-ing and repairing respirator (July 31, 1985)

.2 .2.la-1 Evaluate use of Complete Comprehensive evaluation alarming CAMS during work performed. Findings where there is a potential indicate deficiencies in for changes in airborne real-time airborne particulate and iodine radioactivity monitoring concentratio progra (June 30, 1985)

22 _5.2.4-1 Develop non- Open Licensee review indicated radiological respiratory a need for a non-radio-

_ protection equipment logical respiratory controls and equipmen protection program. No (June 30, 1985) date provided for program establishmen (50-293/85-22-13)

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ATTACHMENT COMMITMENT STATUS NRC COMMENT 2 .3-2 Revise Purchase Complete None specification for SCBA compressor part (June 30, 1985)

2 .2.la-2 Order calibration Complete None sources for whole body counter. (May 31, 1985)

2 .2.Ib-1 Develop preocedure Complete Licensee effort was for whole body counter (BWC) comprehensiv configurations and uses of phantom (June 30, 1985)

2 .2.lb-2 Validate configura- Open Licensee obtaining tion benchmarks for WBC sources and performing configurations (on going) validatio . 6.2.1c-2 Correct errors and Complete Comprehensive inconsistances in WBC librar review performe (May 31, 1985)

2 .2.lf-1 Develop and approve Complete None a program for evaluating and trending internal depositio . 6.2.1h-1 Develop method for Complete None investigation, documentation, and records maintenance of abnormal internal exposure (July 31, 1985)

30. 6.2.11 Develop a procedure Complete None that contains the approved methods and calculation for determining intak (July 31, 1985)

31, 6.2.1R-1 Evaluate WBC spare Complete None parts and equipmen (July 31, 1985)

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ATTACHMENT COMMITMENT . STATUS NRC COMMENT 3 .2.1.1 Review software Complete None program and jobstreams of WBC for accuracy and completenes (July 31, 1985)

3 .2.1.m Evaluate CAMS for Complete None the need to add iodine monitoring capabilit (June 30, 1985)

3 .1.2-2 Complete a walkdown Complete Walkdown comprehensive of the station to identify and remove unnecesary posting and labeling. (June 30, 1985)

3 .1.7 Require-that Open On going responsibile Health Physics supervisors assure that

.RWPs have adequate and current survey (On going)

3 .1.11-1 Complete review of Complete None ARMS in the Radwaste Truck-lock. (June 30,1985)

3 .2.1-10,1 Obtain and review Complete None information on RWP programs at other-power reactor (June 30, 1985)

3 .2.1-10,2 Approve plan for Open Approval not identifie improving the RWP program at (50-293/85-22-14)

Pilgrim Statio (July 31, 1985)

3 .3.3-2 Prepare plan and Open No plan and schedule schedule for modification provide of the Main Control Poin (50-293/85-22-15)

(May 31, 1985)

40, 7.3.4-3 Develop plans and Complete None schedules for further mimimization of access control point (June 30, 1985)

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ATTACHMENT COMMITMENT STATUS NRC COMMENT

.4 .1.1-1 Develop policy Complete None concerning radioactive waste. (July 31,1985)

~4 .1.3-2 Recommend enclosures Complete None for radwaste. (May 31,1985)

4 .1.4-2 Shield current Complete None radwaste storage area (May 31, 1985)

4 .1.4-3 Evaluate consolidation Complete None of radwaste storage area (June 30, 1985)

-4 .1.1-1 Revise NOP 83RC-1 Complete None address in the area of ALAR .(July _31,1985)

4 .1.1-2 Evaluate and revise, Complete None as appropriate, the formal statement of ALARA Polic (July 31,1985)

4 .1.2-1 Provide shielded Complete None storage areas for the storage of high level radioactive material (May 31, 1985)

4 .1.3-2 Initiate Pilot Complete None Program for housekeepin (May 31,--1985)

4 .1.4-1 Review current Complete None practices, procedures, and facilities for issuance and control of Health Physics instrumentatio (June 30, 1935)

5 .1.6-1 Evaluate storage Complete None

, needs of Radiological Control Group's instruments and calibration equipmen (May 31, 1985)

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l ATTACHMENT i COMMITMENT STATUS NRC COMMENT 5 .1.6-2 Order storage Complete None equipment for instruments and calibration equipmen (June 30, 1985)

52 .- 10.2.la-1 Evaluate WBC and Complete None its software. (July 31,1985)

53.- 10.2.lc Determine the need Complete None for upgraded software for the WBC. (July 31, 1985)

5 .2.1.d Review the program Complete None

~for rotating technicians used to operate the WB (July 31,.1985)

5 .2.2.a-1 Receive vendor Complete None recommendations for WBC spare parts. (May 31,1985)

56.- 10.2.la-2 Order WBC spare Complete None parts. (June 30,1985)

5 .2.2.c-1 Approve revised Complete None procedures for analysis of charcoal cartridge (June 30, 1985 5 .2.2.c-2 Order sources for Complete None GE (L1) syste (June 30, 1985)

5 .2.5.a-2 Approve procedures Complete None to calibrate the calibration sources. (June 30,1985)

6 .2.5.a-3 Initiate calibra- Complete None tion of source (June 31, 1985)

6 .2.6-1 Evaluate the need to Complete None obtain additional instrument-ation. (June 30,1985)

..

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ATTACHMENT COMMITMENT STATUS NRC COMMENT 6 .2.8-1 Establish a method Complete None and frequency for checking HEPA filter unit for break-through. (May 31,1985)

6 .3.2-1 Review and recommend Complete None standardization of health physics posting and labelin (July 31, 1985)

6 .3.3-1 Review the need for Complete None lower radiation levels on protective clothing and document recommendation (July 31, 1985)

6 .3.4-1 Evaluate the Complete None personnel decontamination supplies available to the Radiological Controls Group and make materials availabe (July 31, 1985)

6 .3.5-1 Discuss Complete Licensee to review 10.3.5-2 Use of substitution adequacy of substitution material with stores personnel program in November, 198 and develop additional action as required. (May 31,1985)

No commitments in Section 11, Procedure . 12.1.1-8,1 Draft a radioactive Complete None 12.2.1-5,1 and contaminated material control progra (July 31, 1985)

No commitments in Section 13, Management Oversigh . 14.1 Review the current Open * Licensee identified corrective action system need for additional and expanded it to include procedures to implement a followup evaluation of progro significant item (July 31, 1985) * The program does not include a timely review of radio-logical controls significant item (50-293/85-22-16)

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