IR 05000293/1986002
| ML20154N187 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/07/1986 |
| From: | Kronenberg J, Mcfadden J, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154N173 | List: |
| References | |
| 50-293-86-02, 50-293-86-2, NUDOCS 8603170227 | |
| Download: ML20154N187 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-293/86-02 Docket No.
50-293 License No.
OPR-63 Priority
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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: January 13-17, 1986 Inspectors:
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R. L. Nimitz, Senior Radiation Specialist date
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J. R. McFadden, Radiation Specialist date
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. L. Kronenber, Reactor Engineer date Approved by:
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M.'M. Shanbaky, Facilities Radiation
' da'te Protection Sectic EPRPB, DRSS Inspection Summary:
Inspection on January 13-17, 1986 (Report No. 50-293/86-02).
Areas Inspected:
Routine, announced inspection of the following:
implementation of improvement items identified in the Radiological Improvement Program; radiological controls for f uel pool re-racking and removal of the radwaste concentrator; and calibration and testing of area radiation monitors.
The inspection involved 117 inspector-hours onsite by two region based inspec-tors and one NRC Headquarters based Reactor Engineer.
Results: The Radiological Improvement Program was being satisfactorily imple-mented. Three violations were identified by the licensee during review of concentrator work. The licensee took corrective action for these.
8603170227 860310 DR ADOCK O
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DETAILS 1.0 Individuals Contacted 1.1 Boston Edison
- W. D. Harrington, Senior Vice President Nuclear
- A. L. Orsen, Vice President, Nuclear Operations
- C. J. Mathis, Station Manager
- W. Deacon, Assistant to Senior Vice President Nuclear
- T. Sowdon, Radiological Section Head 1.2 USNRC M. McBride, Senior Resident Inspector
- denotes those individuals attending the exit meeting on January 17, 1986.
The inspector also contacted other personnel (licensee and contractor).
2.0 Purpose of Inspection The purpose of the routine, announced radiological controls inspection was to review the following program elements:
Licensee action on previous inspection findings
Implementation of the Radiological Improvement Program
Radiological Controls for re-racking of the spent fuel pool
Radiological Controls for Removal of the Radwaste Concentrator
Area Radiation Monitor (ARM) Testing and Calibration
3.0 Licensee Action on Previous Findings 3.1 (Closed) Follow-up Itera (50-293/85-07-02)
Licensee's close-out information for radiological occurrence reports (RORs) does not provide a description of 1) wist corrective action was +he basis for closure of the ROR or 2) what action was taken to prevent recurrence.
Inspector review of this inspection also iden-tified numerous closeo RORs witnout a clear description of the basis for closure. The licensee acknowledged this and indicated the matter is being reviewed. Meetings were held with various licensee person-nel to determine the extent and adequacy of corrective action taken
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for these RORs.
No apparent violations were identified.
The licen-see's action on this matter will be reviewed in conjunction with Radiological Improvement Plan Item No. 14.1-1 (NRC' Follow-up Item 50-293/85-22-16).
3.2 (0 pen) Follow-up Item (50-293/85-13-05)
Licensee to include check-off list in radioactive waste shipping procedures to address verification of cask seal change-out. The licensee revised applicable procedures; however the revision does not ensure cask seal change-out at specific intervals and in accord-ance with the Certificate of Compliance requirements.
3.3 (0 pen) Follow-up Item (50-293/85-13-07)
-NRC to review approved Radiological Controls Organization.
The licensee established and approved a long term Radiological Controls Organization.
The licensee described: group functional responsi-bilities; individual responsibilities; and organization responsi-bilities. A defined organization chart was established. The organization and responsibilities were not formally incorporated into any station approved procedures.
Ir addition, Radiological Control Organization interfaces with other
.ation groups and shared respon-sibilities were not described. The above matters remain open.
Licensee representative indicated these matters would be reviewed.
3.4 (Closed) Follow-up Item (50-243/85-13-08)
Licensee to correct dose conversion factor contained in procedure
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No. 6.2-111.
The licensee revised and reissued procedure 6.2-111 as PNPS SI-RP.2001.
The licensee corrected the factor in the revision.
3.5 (0 pen) Follow-up ltem (50-293/85-13-11)
NRC to review status of Traversing Incore Probe (TIP) and Radwaste Are: Radiation Monitors.
The licensee determined an area monitor is not neede; in the Radwaste Segregation area. The licensee's Radio-logical Oversight Committee is currently reviewing the area radiation
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monitors in the TIP area.
3.6 (Closed) Follow-up Item (50-293/85-13-12)
Licensee to include videotape segment discussing procedure adherence into General Employee Training Program. The inspector selectively reviewed the tapes. The tape included discussion of the need to adhere to procedure.
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3.7 (Closed) Follow-up Item (50-243/85-22-01)
Licensee to establish sampling and analysis program to detect radio-active contamination of the normally noncontaminated service air system.
The licensee has established and is implementing a sampling and analysis program for the service air system.
3.8 (Closed) Follow-up (50-293/85-22-02)
Licensee to implement long term corrective action to improve pro-cedure adherence. The licensee established Outage Management Group Instruction No. 11.
This instruction describes the methodology to be used to improve intergroup communication and interface.
However, the instruction does not provide clear guidance as to when inter-group meetings should be held. This matter will be reviewed during a subsequent inspection (50-293/86-02-01).
3.9 (0 pen) Follow-up Item (50-293/85-22-03)
Licensee to review facility design with respect to concerns identi-fied in IE Bulletin 80-10 " Contamination of Nonradioactive system and Resulting Potential for Unmonitored/ Uncontrolled Release to the Environment.
The licensee had scheduled the review of his facility design to be completed in January 1986.
The licensee has taken interim actions to address the bulletin concerns. The licensee's facility review is not yet completed but is planned for completion in January 1986.
3.10 (Closed) Follow-up Item (50-293/85-22-04)
Licensee to review and resolve status of a Radiological Oversight Committee member no longer independent of station organization.
The licensee replaced the individual with an appropriately qualified individual independent of the station organization.
3.11 (Closed) Follow-up Item (50-293/85-22-06)
NRC to review licensee radiological controls for fuel pool work. The fuel pool work was reviewed during this inspection (See Section 5.1 of this report.) and inspection 50-293/85-32.
3.12 (Closed) Follow-up Item (50-293/85-22-07)
Licensee to ensure position responsibilities for positions of the new, long term Radiological Controls Organization were based on appro-priate task analyses.
Inspector review indicated task analyses were performed for all appropriate positions in the organization and that position responsibilities were based on the analyse _ _ _
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3.13 (0 pen) Follow-up Item (50-293/85-22-09)
Licensee to develop and implement a program to ensure that personnel are trained in new procedures.
Licensee established program pro-cedure.
Procedure does not ensure that personnel will be trained in safety significant procedure changes and new procedures in a timely manner.
The licensee is reviewing the matter.
3.14 (Closed) Follow-up Item (50-293/85-22-14)
Licensee to approve RWP improvement plan. The plan was reviewed and approved by licensee Radiological Controls Management. The plan, with some revisions, was implemented.
3.15 (Closed) Follow-up Item (50-293/85-22-15)
Licensee to prepare plan and schedule for modification of the Main Control Point. The licensee has prepared a plan and schedule for modification of the Main Control Point.
The implementation of the schedule will be reviewed during subsequent inspections.
3.16 (0 pen) Follow-up Item (50-293/85-32-23)
Establish Final RWP program. See item No. 13 (RIP Item 7.2.1-10)
contained in the attachment to this report.
3.17 (Closed) Follow-up Item (50-293/85-32-25)
Consolidate radwaste storage areas.
The licensee consolidated radwaste storage areas and defined acceptable locations for storage.
3.15 (Closed) Follow-up Item (50-293/85-32-26)
Provide enclosures for Radwaste.
Licensee provided enclosures for Radwaste.
3.19 (0 pen) Follow-up Item (50-293/85-32-27)
Shield consolidated radwaste storage locations.
Licensee shielded consolidated storage areas. However, procedures do not provide
" trigger levels" requiring shielding of radwaste storage areas.
3.20 (Closed) Follow-up Item (50-293/85-32-28)
Licensee to approve the ALARA Section of the Radiation Protection Plan.
The licensee's station manager approved the entire plan.
The plan includes the subject ALARA Section.
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4.0 Implementation of Licensee Commitments Presented to NRC in the Radiological Improvement Program (RIP)
4.1 General The inspector reviewed the implementation of Radiological Improvement Program commitments presented to the NRC. The review was with respect to criteria and/or information contained in tne following documents:
Order Modifying Licensee, Notice of Violation, and Notice of
Deviation (NRC Inspection No. 50-293/84-25 and 50-293/84-29),
i 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),
i Licensee Completed Regulatory Requirement Analysis Forms
(various) relative to Radiological Improvement Plan (RIP)
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Milestones, Licensee Radiological Activity Assessment Reports (RAAR)
(various),
Radiological Oversight Committee (ROC) Meeting Minutes a
(various),
NRC Inspection Report Na. 50-293/85-13, dated July 16, 1985,
and NRC Inspection Report No. 50-293/85-22, dated October 7, 1985.
- NRC Inspection Report No. 50-293/85-32, dated December 31, 1985.
- The purpose of this review was to determine if:
the licensee met the commitments (i.e. milestones) specified a
in the Radiological Improvement Program (RIP);
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the material or actions taken/ generated by the licensee
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satisfactorily met the commitments made to NRC in the RIP; and the material or actions taken/ generated were properly
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implemented.
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The following aspects of RIP implementation were noted and verified
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implemented:
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a tracking program was in place to identify milestones due;
adequate management controls were in place to monitor
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implementation of milestones and initiate proper action when milestones were identified as potentially not being met; review was performed of the material or actions taken/ generated
to determine its adequacy prior to its acceptance and
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implementation.
4.2 Findings The inspector reviewed a total of 33 commitments that were to have been completed by the licensee by December 31, 1985. The commitments reviewed are identified in the attachment to this report.
The review indicated the licensee satisfactorily completed his action on 21 of the commitments. Several commitments were left open due to the need for additional licensee action or NRC review. These are identified in the attachment to this report.
Based on the above review, the licensee is monitoring implementation of the RIP improvement items, and is meeting commitments provided to NRC Region I.
Within the scope of this review, the following was noted:
The licensee's Senior Vice President-Nuclear is monitoring
implementation o' the Radiological Improvement Program.
Radiological Oversight Committee members are touring the fact-
lity every two weeks.
Findings identified during the tours are brought up and discussed at the ROC meetings. Action is ini-tiated to resolve problems identified.
A Radiological Assessor is touring the plant daily.
Identified
deficiencies are reviewed and brought to the attention of the appropriate group for resolution.
The licensee has taken action to address procedure adequacy
concerns identified during previous NRC inspections of this area.
The licensee has taken action to 1) improve the technical adequacy of radiological controls procedures 2) stress attention to detail and 3) improve the overall quality of radiological controls procedures. The licensee is reviewing and revising (as appropriate), thirty-five previously established procedures to identify areas for improvemen e
5.0 Radiological Controls The inspector reviewed the implementation, adequacy, and effectiveness of Radiological Controls for the installation of high density fuel racks in the fuel pool and removal of the radwaste concentrator.
The following matters were reviewed:
establishment, adequacy, and implementation of appropriate
procedures for the activities, adequacy and adherence to Radiation Work Permits,
selection, qualification and training of personnel, a
implementation and adequacy of ALARA controls,
external exposure controls
internal exposure control
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radiological surveys a
items needing improvement identified in Inspection Report
50-293/85-32.
The evaluation of the licensee's performance in this area was based on discussions with personnel, review of appropriate documents and records, and observations by the inspector.
5.1 Fuel Pool Re-Racking (Radiological Controls)
Documents Reviewed 10 CFR 20, Standards for Protection Against Radiation
applicable technical specifications
applicable licensee procedures including:
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Procedure No. 6.7-121, " Radiation Protection Requirements for Diving in Radiologically Controlled Areas,"
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Temporary Procedure No. TP85-126, "ALARA Review for Diving in Support of Re-Rack Work,"
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Temporary Procedure No. TP 85-119, " Operation of the Liquid Blasting Hydrolyzer,"
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applicable records including:
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RWPs covering diving operations and top-side support work
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In pool survey maps of dive areas
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Calibration records for underwater survey meters and alarming dosimeters
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Dosimetry results for TLD badges and pocket dosimeters
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Pre-and post-diving operations whole body co;nting results of divers
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HP control point logbook for fuel pool re-racking i
Radiclogical occurrence reports
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Findings Within the scope of the review, no violations or deviations were identified.
The licensee was providing generally acceptable radiological controls for diving operations.
The following item needing licensee attention was identified:
Establish station wide controls to limit / control exposure to
critical body parts.
A formal program to address this matter has yet to be developed.
Licensee representatives indicated a station wide program to address this concern would be established.
This matter will be reviewed during a subsequent inspection (50-293/86-02-02).
Within the scope of this review, the following was noted:
The licensee performed extensive clean-up efforts in the dive
areas of the spent fuel pool.
The clean-up efforts resulted in an average dose rate of 20 mrem / hour in the areas.
Note: The re-rack job is about 75P. complete. Total exposure received by divers is about 0.8 person-rem.
The licensee performed an evaluation of the radiation fields in
the dive areas.
The evaluation provided data to support the adequacy of calibration of dose rate monitoring instruments used and personnel monitoring devices wor.
The licensee established and implemented a diver bioassay
program.
The licensee established pre-dive check-lists for divers.
- The licensee provided appropriate training of personnel
associated with diving activities.
5.2 Radwaste Concentrator Removal (Radiological Controls)
Documents Reviewed 10 CFR 20, Standards for Protection Against Radiation a
applicable technical specifications
applicable licensee procedures including:
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Temporary Procedure No. TP85-107, " Dismantling / Removal of Radwaste Concentrator and Associated Equipment,"
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Temporary Procedure No. TP85-108, " Operation of the AP-1000 and AP-2000 HEPA Filter Units Including Filter Changeout,"
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Station Instruction No. SI-RP.5002, "Use and Control of Portable Ventilation Units and HEPA Vacuum Cleaners,"
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Station Instruction, SI-RP.7001, " Issue, Use, and Turn-In of Respiratory Equipment,"
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Procedure No. 6.1-209, " Radiological Occurrence Reports,"
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Station Instruction No. SI-RP.1100, "MPC-Hours Determination,"
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Station Instruction No. SI-RP.0100, "ALARA Daily Exposure Review (ADER),"
applicable records including:
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radiological survey data
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radiation work permits
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personnel exposure data
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ALARA review sheets
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MPC-hour logs
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radiological occurrence reports
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breathing air quality data
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Findings Within the scope of this review no violations or deviations were identified.
During evaluation of airborne radioactivity samples collected in the concentrator room in early December,1985, the licensee determined on or about December 9,1985 that at least three samples had been inadequately evaluated.
The licensee had failed to make dead time correction for the samples thus underestimating the total activity contained on air sample filter paper.
This resulted in the gross beta gamma air activity in the concentrator room to be underestimated by a factor of 2-3.
Upon identification, the licensee performed the following:
Work was halted in the concentrator room at that time.
- an evaluation of the adequacy of current respiratory protection
devices used was initiated, Based on the evaluation of respiratory protection dev1ces, a
decision was made to change from full face (negative pressure)
particulate respirator to full face air supplied equipment. The licensee's evaluation indicated that the protection factor (PF)
(PF=50) of the full face negative pressure respirator had been exceeded.
The licensee re-calculated and corrected previous personnel
airborne radioactivity exposure results to incorporate the dead time correction.
No significant exposure was identified.
Radiological Controls personnel overseeing activities at the
concentrator were instructed to inform supervisory personnel of air samples with apparent count rates in excess of 10 cpm.
The licensee determined that no other current activities in the plant would result in airborne activities of the magnitude experienced in the concentrator room.
On or about December 12, 1985, the licensee recommenced work
in the concentrator room.
Personnel were provided with full face air supplied equipment.
On or about December 23, 1985, the licensee determined that the
airline hose, which supplies air to the full face respirator from the pressure control station, was the incorrect hose for the NIOSH approval number.
Consequently, this voided the approval of the respirator.
The licensee halted work in the concentrator room.
Several days later the licensee whole body counted the individuals who wore the full face air supplied equipment.
No intake of radioactive material was indicated.
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The licensee reviewed all station respiratory protection equip-
ment to identify similar problems.
None were identified. The licensee revised appropriate procedures to clearly specify approved combinations of equipment.
On January 10, 1986, the licensee issued interim written
instructions to personnel to provide guidance as to correction factors to use to correct for counter dead times.
Inspection Evaluation The inspector review of the licensee findings in the area of airborne radioactivity sample analyses and use of respiratory protection equipment indicated the following:
Three apparent violations were identified by the licensee.
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Failure to perform surveys (i.e. evaluation of instrument
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dead time) required by 10 CFR 20.201 b to ensure compliance with intake limits of 10 CFR 20.103
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Use of respiratory protection equipment whose protection factor is less than the ambient airborne radioactivity MPC-factor contrary to 10 CFR 20.103(c) (1)
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Use of a non-NIOSH approved respirator / hose combination contrary to 10 CFR 20.103(c).
The licensee implemented corrective action to address the
violations. Based on review of these corrective actions, the licensee met the criteria of 10 CFR 2 Appendix A relative to non-issuance of a violation.
The following matters remain unresolved and will be reviewed during a subsequent inspection (50-293/86-02-03):
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final licensee evaluation of acceptability of current MPCs used relative to limiting nuclides and solubility.
The licensee is currently using, reasonably conservative nuclides and solubilities.
licensee establishment of final program procedures for
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correction of detector dead times when counting samples.
The licensee established interim guidance in the are.
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Within the scope of the review, the following was noted:
The licensee was using daily ALARA check sheets to provide
control and oversight of personnel exposure received during the work. Work was suspended to review and resolve situations resulting in personnel receiving unnecessary exposure.
The licensee was providin5 effective high radiation area
access control.
The licensee provided dosimetry for the backs of personnel.
- Evaluation of badge read-out results indicated the exposure of the backs of personnel was normally lower than that received by the front of the torso.
The licensee evaluated and took action to control the exposure
of personnel to pure beta emitters.
6.0 Area Radiation Monitoring System (Test and Calibration)
The inspector reviewed the adequacy and implementation of the testing and calibration program for the Area Radiation Monitoring System (ARMS).
The following matters were reviewed:
adequacy, establishment and implementation of procedures
adequacy of calibration
use of appropriate radiation sources.
- The calibration and testing of the following instruments was selectively reviewed:
New Fuel Storage Area ARM
Traversing Incore Probe (TIP) ARM
Control Room ARM
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Refuel Floor Area Exhaust Monitor
Standby Gas Treatment Monitor
The review was with respect to criteria contained in the following:
applicable Technical Specifications
Ai45I/ANS-HPSSC-6.8.1-1981, " Location and Design Criteria for
Area Radiation Monitoring System for Light Water Nuclear Reactors"
applicable licensee procedures including:
Procedure PHPS SI-RP.5001, " Radiological Protection
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Instrumentation Calibration Frequency," Revision 0
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Procedure PNPS SI-RP.6100, "Use of the Technical Operations Model 682 Gamma Instrument Calibrator," Revision 0
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Procedure PNPS SI-RP.6400, "Use of the G.E. Gamma Calibrator for the ARMS," Revision 0
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Procedure PNPS SI-RP.6403, " Operation of the Model 570 Victoreen Condenser R-Meter," Revision 0
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Procedure No. 2.2.62, " Area Radiation Monitoring System,"
Revision 6
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Procedure No. 6.6-113, " Source Calibration," Revision 0
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Procedure No. 6.5-160, " Calibration of Area Radiation Monitoring System,"
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Procedure 6.5-170, " Calibration of Ventilation System Radiation Monitor Using ARM Type Sensor /Cenverter."
The evaluation of the licensee's performance was based on discussions with personnel, review of documentation, and observations by the inspector.
Findings Within the scope of the review, no violations or deviations were identified.
The following matters needing licensee attention were ic entified.
i These matters will be reviewed during a subsequent inspection (50-293/86-02-04):
The radioactive source used to calibrate ARMS has decayed.
- The dose rates from the decayed source are not high enough to verify calibration of the full vange of the high range ARMS (maximum range 10R/hr).
The licensee has ordered a new source and is awaiting its arrival.
The ARM in the New Fuel Storage Location is not being source
calibrated due to its inaccessibility. Alarm set points are being properly set and cperability (from the Control Room)
is being checked.
The licensee indicated this matter will be reviewe. _ _ _
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The ARM located at the TIP room appears to be positioned in a
non-optimum location. The detector should be positioned to readily detect increased radiation levels in the TIP area.
Within the scope of this review, the following iten for improvement was identified:
Procedure No. 6.5.170 does not provide for recording of "as
found" ARM reading. Review of "as found" data could provide indication of instrument problems between calibrations.
Problem identification may necessitate changing of calibration frequency.
6.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on January 17, 1986. The inspector summarized the purpose, scope and findings of the inspection.
No written material was provided to the license ATTACHMENT TO REPORT 50-293/86-02 Status of Boston Edison Company's Radiological Improvement Program (RIP)
Commitments to be completed Between November 1, 1985 and December 30, 1985 COMMITMENT STATUS NRC Commert 1.
1.2.5 Develop an Complete The licr:nsee addressed administrative pro-the commitment in his cedure which describes action to satisfy item the Radiological Control 13.4 These matters are Group's policies and addressed in the Radia-includes guidance to tion Protection Plan.
improve communication.
The document should contain goals and objectives, policies, interface and key performance indicator (December 31, 1985).
2.
2.2.7-1 Develop Open Licensee established and implement a program procedure PNPS to ensure personnel SI-RP.1001, " Radio-are trained in new logical Protection procedures (May 31, 1985).
Procedure Change Train-ing."
The procedure doee not provide for timely training of personnel in health and safety significant procedure changes.
(50-293/85-22-09 Remains Open)
3.
4.1.3-2 Develop Open Licensee established guidance for procedure for assigning skin determining skin dose.
exposure (July 31,1985).
Procedure does not:
define / explain
limitations of instruments define acceptable e
instruments
define / describe
limitations of skin dose correction factor.
define "DPM"
Follow-up Item (50-293/
85-22-11) remains open.
4.
5.2.4-1 Licensee Complete The licensee established to develop a non-a procedure to control radiological issuance and use of respiratory pro-respiratory protection tection program.
equipment for non-radiological uses.
5.
2.2.3-2 Develop Complete Licensee developed Training Material training propram for for Radiological Radiological Controls Controls Super-Supervisory personnel.
visory personnel.
(December 31, 1985)
6.
2.2.5(a)(b)(c)-1 Complete The licensee developed Expand Contractor a slide presentation Health Physics of the site, expanded Training Program the current technician to include: site training program to layout, site organi-address site criteria zation, site criteria and action levels, and and action levels.
included the radio-logical controls organization in the training program. The site organization is presented in General Employee Training.
7.
3.1.3 (a)(b)(c)-2 Complete INPO performed a A review of the first review of the three months experience General Employee with the General Employee Training Program.
Training program is to The program was be conducted.
subsequently certified (November 30,1985)
by INPO.
INP0 comments and trainee comments were incorporated into the cours.
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8.
5.2.1 a-2 Evaluate Open Licensee performed an the Use of Alarming review (June 30,1985)
CAMS. Modify Air which indicated CAMS Sampling Program no+. needed.
Radio-as appropriate logical Oversight (December 31, 1985).
Committee (ROC)
currently reviewing this matter.
Revolution of this matter by ROC will be reviewed during a subsequent inspection (50-293/86-02-05).
9.
5.2.2-1 Develop and Open Licensae to provide and implement an information showing expanded engineering incorporation into control program, training and Incorporate app'icable procedures.
methods into training (50-293/86-02-06)
and procedures.
(December 31, 1985)
10.
6.2.1.b-1 Open Licensen performod Validate bench bench work. However, mark of whole procedures for phantom body counter not approved using sources (50-293/86-02-07).
(one month following receipt of sources).
11.
7.1.7 Requi.re that Complete On going.
Implemented responsible Health by Radiological Physics Supervisors Assessor and Radio-assure that RWPs have logical Oversight adequa'.e and current Committee Reviews.
surv:ys (November, December 1985) (on going).
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7.2.1 through 10, Item 2 Complete The licensee established Approve plan for improving an RWP improvement the RWP program at Pilgrim plan. The plan was Station (July 31, 1985).
approved by Radiological Controls Management.
The plan was imple-mented.
This closes item 50-293/85-22-1 E
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7.2.1 through 10, Item 3 Open Review of final program Established a restructured and procedure identified RWP program (September,1985)
the following matters (Referred to October 15, 1985).
needing licensee atten-tion (50-293/85-32-23).
RWP issuance for:
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combined estimated exposure
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welding use of compressed
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air Definition of minimum
lead time for issuance Procedure not clear
regarding use of attached forms Incorporation / interface
with ALARA program RWP Suspension
Sign in of workers and
their resprrsibilities Radiological Conditions
which preclude use of an Extended RWP 14.
7.3.3-2 Prepare Complete The licensee prepared a plan and ;hedule plan and schedule for for modification modification of the Main of the Main Control Control Point.
The Point (May 31, 1985).
licensee's plans will provide for improvements at the access control point.
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7.4 Procure, install Complete Licensee procured and and turnover airborne installed equipment.
effluent monitoring Licensee has yet to equipment for the Trash verify capability of Compactor Facility monitor to collect (December 31,1985).
representative samples (50-293/86-02-08)
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8.1.2-2 Consolidate Complete Licensee consolidated Current radioactive radwaste storage areas.
waste storage areas Approved areas are (September 30, 1985 described in procedure deferred).
This closes item 50-293/85-32-25.
8.1.3-3 Provide Complete Enclosure provided.
enclosure to protect This closes follow-up radioactive waste item 50-293/85-32-26.
stored outside (September 30, 1985 deferred).
18.
8.1.4-4 shield Complete Consolidated areas consolidated radwaste shielded where necessary, storage areas No " trigger" levels (September 30, 1985 identified requiring deferred).
shielding of areas currently not shielded.
Item (50-293/85-32-27 remains open).
19.
8.1.5 Radwaste Shipping Complete Licensee reviewed and Procedures will be revised radwaste shipping reviewed, revised and procedures.
approved as necessary (November 30,1985).
20.
9.1.1-6 Approve Complete The entire Radiation ALARA Section of Protection Program Radiation Protection document was approved Program documents by the Station Manager (September 30,1985)
The document included the ALARA Section.
(This closes follow up item 50-293/85-32-28.)
21.
9.1.2 Establish Complete Committee established.
ALARA Committee with Charter described in appropriate BECO procedure NOP 83RC1.
personnel (November 30, 1985)
22.
9.1.7 ab-1 complete Open Review complete.
systematic review of Criteria for review not PNPS for systems and provided (50-293/85-32-30).
components that could benefit from ALARA consid,eatio.
23.
9.2.1 through 4-1 Complete A contractor developed Develop an ALARA a program for the Training Program to licensee.
Course accomplish the following material was not pro-objectives:
vided to the inspector.
Also no schedule for Demonstrate Management's initial course presen-
desire and commitment tation and subsequent to improving the radio-presentations was pro-logical controls program vided (50-293/86-02-09).
at PNPS; Help formulate a more
positive "can do" attitude; Help formulate better worker
habits with respect to radio-logical controls; and, Sensitize all levels of
personnel to the benefits to be derived from actively implementing ALARA principles in their everyday work habits.
Develop specialized training
for crafts with emphasis on the following:
Mockups;
-
-
Special tooling;
-
Radwaste minimization;
-
ALARA; and, Contamination control.
-
24.
10.1.4 Order equipment as Complete Licensee obtained appropriate to improve and provided instrument facilities and methodology lockers. No other for the issuance and control equipment was needed.
of health physics instru-mentation (September 30, 1985).
25.
10.1.6 Obtain storage Complete See comment for space and racks for the Commitment 10.1.4.
Radiological Groups instru-ments and calibration equipment (Based on results of review conducted per Item 10.1.4).
.
I
.
26.
11.1-2 Develop, maintain Open The licensee has revised and implement new and and reissued the majority existing Radiological of his radiological Group Procedures in controls procedures.
accordance with the The licensee is cur-Procedure Improvement rently addressing Plan (December 31, 1985).
NRC and INP0 identified procedure deficiencies.
The licensee is re-reviewing approximately 35 procedures. This commitment remains open pending:
1)
licensee correction of identified procedure deficiencies, and 2)
review, revision (as necessary) of identified procedures.
27.
11.7-1 Review and Open The licensee is currently revise current reviewing and revising Radiological Controls procedures to address procedures which affect self-identified, NRC-a similar process to identified and INPO-ensure that the same identified deficiencies.
action levels are In addition, the licen-
'
used for identical see is currently re-activities.
Review reviewing approximately current procedures 35 previously issued i
to correct any defi-procedures to identify ciencies (December 31,1985).
and correct any deficien-i
,
.
cies.
This area remains
'
open pending:
licensee I
action on item 11.1-2 (50-293/86-02-10).
.
28.
12.1 and 12.2 Open The licensee reviewed (milestone 4)
and approved the Radio-Approve Plan for active Materials Control of Radio-Control Program. No
active Material and facility modifications
!
authorize recommended were identified facility modifications requiring authorization.
s
!
'
l
I I
.v.--.
_ _.-
__,,y.
- -,
,,,.y__-.__,-.___,___..__.__._,,,,,,._,..,,..c_,__,
.,,,..
.r--,.,-.,,._.,m.-
..,,.
..y_y.
m.
_ _ _ _ - _ _
__
______
_ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
(
(November 30,1985).
The following matters remain open:
1)
formal incorporation of the program into the station procedure pro-gram 2)
resolution of need for Radioactive Material Control Program Manager 5)
verification that proce-dures are inplace to implement the program (50-203/86-02-11).
29.
13.3.1-1 Develop Open Licensee currently and publish goals establishing goals for the Radiological and goals program.
Controls Group Item 50-293/85-32-34 (August 31, 1985)
remains open.
30.
13.3.1-2 Develop Complete Licensee met with goals for individuals appropriate individuals within the Radiological within the radiological Group (November 30, 1985)
controls organization to establish goals for them.
The goals were developed around the individuals capabilities and expectations.
31.
13.3.7 Implemen+.
Complete See Commitment 13.3.1-2.
a personnel develop-In addition, the licen-ment program that is see has established in concert with the training programs based functional respon-on performance of a Task sibilities of the Analysis of each position.
,
personne m P
?
.
.
32.
13.4-2 Develop and Complete The licensee developed approve a Radiation and approved a Radiation Protection Plan Protection Plan for (December 31,1985).
Pilgrim Station.
The plan was developed using the recommendation of NUREG-0761, " Radiation Protection Plan for Nuclear Power Station,"
Regulatory Guide 8.XX-Draft, " Standard Format and Content for Radia-tion Protection Program Descriptions for Nuclear Power Reactor Licen-sees", and INPO Guide-lines for Radiological Protection at Nuclear Power Stations.
The following matters remain open:
(50-293/86-02-12)
verification that all elements of the des-cribed program have associated implementory procedures.
33. 14.1-1 Expand the Open The following matters remain current corrective open:
action system to include a follow-up evaluation completion of additional i
of significant events procedures identified (July 31, 1985)
in licensee program review provision of timely
review of significant events implementation of timely
=
corrective action to prevent recurrence documentation of correc-
tive actions Follow-up item 50-293/85-22-16 remains open.