IR 05000322/1982033
| ML20028F396 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 01/19/1983 |
| From: | Jang J, Mcbride M, Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028F391 | List: |
| References | |
| 50-322-82-33, NUDOCS 8302010322 | |
| Download: ML20028F396 (25) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-322/82-33 Docket No. 50-322 License No. CPPR-95 Priority Category B
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Licensee: Long Island Lighting Company 175 East Old Ccantry Road Hicksville, New York 11801 Facility Name: Shoreham Nuclear Power Station Inspection At: Shoreham, New York Inspection Conducted:
November 15 - 19, 1982 Ir.:pectors:
R.L.hf ilid %3 R. L. Nimitz, Senior Radiation Specialist
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M.' H. McBride, Ph.D., Radiation Specialist date l/@/?b c
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Approved by:
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M. M. Shanbaky, Ph.D., Chief, Facilities da t'e
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Radiation Protection Section i
l Inspection Summary:
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Inspection on November 15 - 19, 1982 (Report No. 50-322/82-33)
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l Areas Inspected: Routine, announced, preoperational, safety inspection of the licensee's Radiation Protection and Radioactive Waste Management Programs, including: previous inspection findirgs; IE Circular 81-07; organization and staffing; personnel selection; qualiiication and training; radiation worker training; external and internal exposure con' ol programs; respiratory protec-tion program; in plant radiochemical measurements; process and effluent moni-toring and control; ventilation system testing; radiation monitoring equipment; 8302010322 830124 DR ADOCK 05000 2
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- solid radioactive waste; and ALARA efforts. The inspection involved 94 inspec-tor hours on site by three NRC region-based inspectors.
Results: No violations were identified.
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Details 1.
Persons Contacted
M. Donegan, Health Physics Foreman R. E. Glazier, Field QA Engineer
P. C. Kwaschyn, Assistant Engineer, Radiochemistry
W. M. Matejeck, Lead Advisory Engineer M. L. Miele, Health Physics Engineer
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J. A. Notaro, Operating Engineer
R. Petricek, Engineer, Radiochemistry J. Rivel10, Plant Manager
J. T. Rose, QA Engineer
K. Rottkamp, Acting Training Supervisor J. Schmitt, Radiochemistry Engineer
D. Schuler, Test Engineer
W. Steiger, Chief Operating Engineer D. Terry, Assistant Start-Up Manager
NRC J. C. Higgins, Senior Resident Inspector
P. Hannes, Resident Inspector
- Denotes those present at the exit interview on November 19, 1982.
The inspectors also contacted other personnel during the inspection.
2.
Purpose and Scope of Inspection The inspection was performed to determine if the licensee is complying with regulatory requirements and Final. Safety Analysis Report (FSAR)-
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commitments in the area of Radiation-Protection, Radioactive. Waste: Manage-
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ment, and Radiochemistry. This inspection is a continuation of, and supplements, Inspection Nos. 50-322/81-19 (conducted November.9 - 13,-
1981), 50-322/82-13 (conducted during the period May 11 - June 18,-'1982),_
and 50-322/82-20 (conducted October 12 - 15, 1982).
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Certain findings of this inspection, which remain unresolved, are identi-fied in the Annex to this report.
3.
Previous Inspection Findings 3.1 (Closed) Follow-Up Item (50-322/80-17-06).
Effects of pressure decrease on measured volumes for air particulate and air. iodine samples. The licensee provided the results of an evaluation of the effects of decrease in pressure on sample volume. The evaluation was.
reviewed and found acceptable. No significant volume change was identifie.
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3.2 (Closed) Follew-Up Item (50-322/81-19-01).
Complete pre operational Radiation Protection and Radioactive Waste Management Program review.
This report, 50-322/82-33, provides the results of the NRC's review and identifies those areas that remain to be examined.
3.3 (Closed) Follow-Up Item (50-322/81-19-02).
Health Physics. Foreman position not depicted in station documents. The review of procedure SP No. 12.002.01, Revision 6, " Organization and Administration,"
indicated the procedure was revised to include the position.
3.4 (Closed) Follow-Up Item (50-322/81-19-03).
Station documents did not depict the current corporate Radiation Protection Organization. The licensee submitted a change to FSAR, Chapter 13, " Conduct of Opera-tions," to reflect the current organization.
In addition, the previous corporate Radiation Protection Organization, now defunct, was deleted from procedure SP No. 12.002.01, " Organization and Administration."
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3.5 (Closed) Follow-Up Item (50-322/81-19-04).
Licensee to establish Nuclear Operations Corporate (NOC) Policy for Radiation Protection and ALARA. The licensee established NOC Policy 20, Revision'O.
" Corporate Responsibilities for the As Low As Reasonably Achievable (ALARA) Program." The policy identifies the organizational responsi-bilities and interfaces for those activi. ties associated with manage- '-
ment's commitment to ensuring that personnel radiation exposure wfl1
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be ALARA.
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3.6 (0 pen) Follow-Up Item (50-322/81-19-05), Radiation _ Protection Organi-zation staffing level. The review of the staffing level indicated an 7,_
adequate number of qualified professional level personnel were available to support fuel load.
However, it does not appear that an
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adequate number of qualified Radiation Protection technicians were
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available (Details, Section 6.2.2).
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3.7 (Closed) Follow-Up Item (50-322/81-19-06).- Description of Responsi-bilities and Authorities of Radiation Protection Organization. The,
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licensee has established an adequate description of the responsibil-
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ities and authorities of Radiation Protection technicians. The
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descriptions are contained in procedure SP No'.'61.040.01, Revision v 6A, " Health Physics Technician Qualification Program."
The licensee has developed and is reviewing draft descript' ions for professional ' -
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level health physics organization members.
3.8 (Closed) Follow-Up Item (50-322/81-19-07).
Health Physics Foreman selection criteria not provided in FSAR or station documents. The licensee proposed Technical Specifications were reviewed and found to contain adequate selection criteria for Health Ph9 sics foremen.
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3.9 (0 pen) Follow-Up Item (50-322/81-19-08).
Complete review of Radia-tion Protection Personnel selection criteria.
The selection criteria for Plant Engineers - Health Physics, as described in the proposed Technical Specifications, do not contain educational background or experience requirements.
In addition, station documents did not provide radiation protection experience requirements for the posi-tion. (Details Section 6.2.1).
3.10 (0 pen) Follow-Up Item (50-322/81-19-09).
Experience and Training of Health Physics Personnel. The review of training and qualifica-tions of Radiation Protection personnel is not completed.
(Details Section 6.2.2).
3.11 (Closed) Follow-Up Item (50-322/81-19-10). Licensee to establish uniform acceptance criteria for evaluation of Health Physics Techni-cian qualifications. The licensee established and implemented procedure SP No. 61.040.01, Revision 6, " Health Physics Technician Qualification Program," on July 8, 1982.
The procedure provides adequate acceptance criteria.
3.12 (0 pen) Follow-Up Item (50-322/81-19-11).
Complete review of General Employee Training Program.
The NRC review's indicated that the licensee is revising certain aspects of the program. The review of this area is not completed.
(Details Section 7.0).
3.13 (0 pen) Follow-Up Item (50-322/81-19-12). Complete review of External Dosimetry Program. The inspector's review indicated that the program elements were being established, but remain to be verified as adequ-ately implemented.
(Details Section 8.3).
3.14 (Closed) Follow-Up Item (50-322/81-19-13).
Internal dosimetry evaluation criteria did not ensure compliance with 10 CFR 20.103.
l The licensee revised procedure SP No. 62.004.03, " Bioassay Program,"
on September 27, 1982, to include internal radioactive material deposition action levels requiring follow-up evaluation. The deposi-tion action levels are adequate.
3.15 (0 pen) Follow-Up Item (50-322/81-19-14).
Complete review of Internal i
Dosimetry Program. The review indicated the licensee has yet to l
fully establish the program.
(Details Section 9.2).
3.16 (0 pen) Follow-Up Item (50-322/81-19-15).
Complete review of Exposure Evaluation Program.
The inspector's review indicated that procedure SP No. 12.009.01 requires that the reports be made in accordance with 10 CFR 50.72. The need for monitoring pocket dosimeter and/or-TLD badge loss rate is being reviewed by the licensee. The licen-see's actions on this matter will be reviewed in a subsequent inspec-tion; i
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3.17 (0 pen) Follow-Up Item (50-322/81-19-16).
Review dosimetry issuance, records, and reports. The licensee revised procedure 61.050.11,.
" Health Physics Exposure History, Records, an ' Reparts," to include guidance for completion and submittal of personnel monitoring reports i
in accordance with 10 CFR 20.407.
References for reporting in accordance with 10 CFR 20.409, " Notifications and Reports to Individ-uals.? are included in the pracedure. The procedure does not addrest the requirement to determine previous, quarterly, occupational exposure in accordance with 10 CFR 20.102(a).
(Details,Section 8.3.2).
3.18 (0 pen) Follow-Up Item (50-322/81-19-17).
Review respiratory protec-tion program. The review indicated the licensee has not fully established the program.
(Details Section 10.0).
3.19 (Closed) Follow-Up Item (50-322/81-19-18).
Review Health Physics facilities.
The licensee is completing construction of an annex which will have space allotted for Health Physics functions. Dis -
cussions with licensee personnel and review of the facilities under construction indicated they would be adequate for their intended
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purpose.
3.20 (0 pen) Follow-Up Item (50-322/81-19-19).
Review portable and labcra-
tory instrumentation to determine if all. FSAR-described instrumenta-
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tion had been acquired. Tne review indicated all FSAR-described instrumentation (e.g., continuous air monitors and neutron monitoring instruments) was not yet acquired. Details Section 13.0).
3.21 (Closed) Follow-Up Item (50-322/81-19-?0).
Perform review of licen-see preoperational testing of area radiation monitors (ARMS). This matter is transferred to Item 50-322/82-20-01. The review conducted during this inspaction indicated that all ARMS have not been calibra-ted.
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3.22 (0 pen) Follow-Up Item (50-322/81-19-21).
Review Radioactive Waste Management Organization. The licansee has not fully established the organization.
(Details Section 5.3).
3.23 (Closed) Follow-Up Item (50-322/81-19-22).
Review Liquid and Ca:eous Radioactive Program.
Visual inspection verified that the. major
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components of the liquid and gaseous waste system (as described in the FSAR) were installed.
Liquid and gaseous waste system preopera-tional testing was reviewed during Inspection No. 50-322/82-2G.
3.24 (0 pen) Follow-Up Item (50-322/81-19-23).
Review Solid Radioactive Waste Program. Visual inspection of the solid radioactive waste system and discussions with licensee personnel identified certain deviations from FSAR system description and operation.
The review indicated the Waste Dewatering Tank was not to receive evaporator
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bottoms as stated in FSAR Section 11.5.3.; a decontamination system, for cleaning spills from filled waste containers, has yet to be established (FSAR Section 11.5.3); and the exhaust from the waste compacter is not directly connected into the ventilation system exhaust as described in FSAR Section 11.5.3.3.
The preoperational testing of the solid radioactive waste system was reviewed during Inspection No. 50-322/82-20 3.25 (0 pen) Follow-Up Item (50-322/81-19-24), Review Process and Effluent Monitoring System. All monitors remain to be calibrated.
(Details Section 12.0).
3.26 (Closed) Follow-Up Item (50-322/81-19-25), Review Reporting Level of Health Physics Engineer. The review indicated the reporting level of the Health Physics Engineer was consistent with the guidance in Regulatory Guide 8.8, Revision 3, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Reasonably Achievable."
3.27 (Closed) Follow-Up Item (50-322/82-13-Oo). Verify revision of i
procedure SP 61.040.01, " Health Physics Technician Qualification Program." Revision 4 of the procedure was.eviewed and found consistent with licensee commitments documented in Inspection Report No. 50-322/82 13.
3.28 (0 pen) Follow-Up Item (50-32?/82-13-09).
Procedure SP 62.020.01,
" General Contamination Survej Techniques,". to be revised to identify equipment to be used to analyze swipe activity. The licensee was in the process of revising the procedure to address this matter.
(Details Section 4.0).
3.29 (Closed) Follow-Up Item (50-322/82-13-10).
Procedure SP 62.024.03,
" Operation of Eberline SAC-4 Scintillation Alpha Counter," is to be revised to include appropriate SAC-4 information. The procedure was reviewed and found to include the information.
3.30 (Closed) Follow-Up Item (50-322/82-13-11).
Procedure SP 82.024.03,
" Receipt of Unirradiated Fuel," to be revised in accordance with commitments documented in Inspection Report No. 50-322/82-13.
The procedure was reviewed and found consiztent with licensee commit-ments.
3.31 (Closed) Follow-Up Item (50-322/82-13-12).
Review Radiation Protec-tion instrument calibration program.
The review of the program indicated licensee was adequately calibrating portable radiation protection instrumentation.
(Details Section 13.0).
4.
_IE Circular 81-07 4.1 Documents Reviewed
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IE Circular No. 81-07, " Control of Radioactively Contaminated Material," dated May 14, 1981
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ANSI-N 13.12, " Control of Radioactive Surface Contamination on Materials, Equipment, and Facilities to be Released for Un-controlled Use (Draft)," dated August 1978 Shoreham Nuclear Power Station Correspondence and Information
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Letter Action Request, dated April 21, 1982, "IE Circular 81-07" Procedure SP No. 61.020.07, Revision 2, " Tools and Equipment
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Contamination Guides and Controls," dated March 19, 1981.
Procedure SP No. 62.020.01, Revision 0, " General Contamination
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Survey Techniques," dated July 28, 1977
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Procedure SP No. 63.009.01, Revision 1, " Selection of Porttble Survey Instruments," dated September 8, 1978.
4.2 Findings The licensee established procedure SP No. 61.020.07 to provide guidance for the methods to be used to identify and contrcl contamina-ted tools and equipment. The pr;cedure provided acceptable, fixed, and removable beta gamma contamination limits for release of tools and equipment from a restricted area; however, no limits for alpha contamination were included.
Regarding selection of instrumentation for use in contamination monitoring, procedure SP No. 61.020.07 referenced procedure SP No.
62.020.01, which referenced procedure SP No. 63.009.01. This latter procedure provided guidance for instruments to be used for fixed beta gamma contamination monitoring. However, the equipment to be used for removable radioactive contamination measurement was not identified.
Licensee representatives indicated a gas-flow propor-
tioned counter is to be used for this purpose. Accordingly, lic6nsee has established draft procedure SP No. 62.020.01 which will identify the instruments to be used for removable ccatamination monitoring.
The control of other potentially-contaminated material (e.g., lumber, trash, etc.) was not reviewed during this inspection.
The control of contaminated material will be reviewed during a subsequent inspection (50-322/82-13-09).
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Organization and Staffing L
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Final Safety Analyses Report (FSAR), Chapter 12, " Radiation
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Protection"
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FSAR, Chapter 13, " Conduct of Operations"
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Procedure SP No. 12.00?.01, Revision 6, " Organization and Administration," dated January 25, 1982.
5.2 Radiation Protection Organization / Staffing The inspector reviewed the Radiation Protection Organization and staffing level with respect to that presented in FSAR Figure 13.1.-
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The organization was found to be consistent with the structure presented.
In addition, the staffing level was found to. exceed the level presented therein.
Licensee representatives indicated that the additional staffing was needed to support fuel load and normal operations.
Discussions with 1*censee representatives also indicated.that a site radiation protection organization is being considered which will include more supervisory personnel than currently described-in the FSAR.
Discussions with Radiation Protection personnel indicated that one individual was already acting in a supervisory position aepicted in the proposed organization.
In additica, one individual was found to have been hired to fill a position in the proposed organization. The proposed organization was not yet depicted in station docunents.
The inspector indicated that the licensee is required to update the FSAR to reflect the additional personnel and the revised organiza-tional structure of the radiation protection program in accord with 10 CFR 50.71, " Maintenance of Records; Making of Reports The licensee is in the process of establishing and revising the job / position descriptions to describe the responsibilities and authoritics of professional level radiation protection organization members.
Based on the above review, the current radiation protection orge'iza-tion was found adequate to support fuel load.
The inspector's review of the organization staffing level, however, indicated that although the numbers of personnel exceeded that described in the FSAR, there did not appear to be a sufficient number of qualified Radiation Protection technicians available. Of 13 technicians available, only four appeared to be fully qualified'in accordance with the proposed Technical Specification.
(See Section 6.2.2).
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Licensee representatives stated during a previous inspection (Inspec-tion No. 50-322/81-19) that in the event sufficient staffing was not available to support fuel load, contractor Radiation Protection personnel would be trained and qualified to augment the staff.
5.3 Radiochemistry Organization / Staffing The current organizational structure was consistent with that depic-ted in procedure SP No. 12.002.01.
However, it was not consistent with FSAR Figure 13.1.2-3 in that the Radiochemistry Foreman position is not described. The review of the current organization and staff-ino with respect to the responsibilities outlined in procedure'SP No.
12.002.01, indicated that the structure and number of personnel was adequate.
However, the Radiochemistry Organization was recently tasked the responsibility of developing and implementing a Solid Radioactive Waste handling, storage, and transportation program.
FSAR Section-13.1.-2.2.9 indicates that such program was, in part, the.responsibi-lity of the Radiation Protection Organization. As a result, a defined, Radioactive Waste M nagement Program has not yet been l
established; and the ability of the curr.ent Radiochemistry organiza-tion to implement the additional responsibilities-of radioactive waste handling and transportation appears questionable.
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Based on the above review, the licensee has not sufficiently esta-blished a radioactive waste handling and transportation program sufficient for the operation of the facility.
Because radioactive waste material will be generated at in cial criticality, the licensee should establish that portion of the-Radioactive Waste Management Program sufficient'to handle, process, store, and dispose of the radioactive material at that time.
The licensee's Radioactive Waste Management Program will be reviewed during a subsequent inspection.
(50-322/81-19-21).
6.
Selection, Qualification, Training 6.1 Documents Reviewed
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Final Safety Analysis Report (FSAR) Section 13, " Conduct of l
Operations" l
l Proposed Technical Specifications 6.3, " Unit Staff Qualifica-
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Plant Personnel" l
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SP No. 12.003.01, Revision 8, " Personnel Qualifications and Responsibilities"
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SP No. 12.014.01, Revision 2, " Personnel Training Requirements"
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SP No. 61.040.01, Revision 6, " Health Physics Technician Quali-fication Program" and Revision 6A
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SP No. 71.006.01, Revision 3, " Technician Qualification Prog-ram".
6.2 Radiation Protection 6.2.1 Professional Level The licensee's proposed Technical Specification 6.3, and Proce-dure No. SP 12.003.01, Appendix 12.3, contain the selection, qualification, and training requirements for Health Physics professional level personnel.
Technical Specification 6.3 states that the minimum qualifica-tions for members of the unit staff may be specified for individ-ual position qualifications as an alternate to referencing an ANSI standard. The Technical Specifications currently reference ANSI-N18.1, 1971 for use in selecting and training personnel.
The review of the qualifications and training of the Health Phys 1cs Engineer indicated the individual met the qualification requirements of the proposed Technical Specification (Regulatory Guide 1.8) and had been trained in accordance with FSAR commit-ments.
The review of the qualification and training of the two Health Physics Foremen indicated the individuals meet the qualification requirements of the proposed Technical Specifications and had l
been trained in accordance with FSAR commitments. No selection or qualification criteria for Health Physics Foremen were contained in Appendix 12.3 of Procedure No. SP 12.003.01.
i Regarding selection, qualification, and training of Plant Engineers - Health Physics, the review indicated that no defined selection or qualification requirements were contained in the proposed Technical Specifications.
Selection and qualification criteria for the position of Plant Engineer - Health Physics, were, however, contained in Appendix 12.3 of Procedure No.
l SP12.003.01.
This Appendix references the licensee's FSAR, l
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f which states that an engineer is to have a Bachelor of Science-degree in Engineering or Physical Sciences, or a high school diploma and four years of experience in a responsible position.
The inspector noted that this criteria provided no details as to
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i the minimum, radiological experience needed to fill the: position of Plant Engineer - Health Physics.
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The inspector's review indicatud'that it appeared that four
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individuals were assisting in the implementation of the -ladia-
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i tion Protection Program in.the capacity of engineer. The inspector noted that each of the individuals possessed a Bache-lor of Science degree in engineering or a physical science and
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that two of the individuals possessed at least four years of ~
radiation protection experience. The remaining two' individuals possessed about two years of radiation protection experience.
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t The two individuals with in excess of four years experience
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were noted to meet the experience criteria for staff specialist-i
as described in section 4.7.2 of ANSI /ANS-3.1, 1978, " Selection
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and Training of Nuclear Power Plant Personnel."-
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j The inspector stated that the minimum-qualification requirements-j for the position of Plant Engineer - Health Physics, will be
reviewed during a subsequent inspec. tion'.
50-322/81-19-08).
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Based on the above review,.it appears that_an adequate. number of trained and qualified Health Physics professional: level
personnel are available'to support and implement the radiation protection program at fuel load.
i 6.2.2 Health Physics Technicians
The licensee's proposed Technical' Specification 6.3 and Proce-i dure Nos. 12.003.01 and 61.040.01 contain the selection, quali-l fication, and training requirements for Health Physics.techni-
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ANSI-N18.1, 1971, which is referenced in the proposed Technical
Specification, requires that a technician acting in a responsi-l ble position have a minimum of two years of working experience
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in their speciality.
The selection criteria provided in the
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referenced procedures requires that a Health Physics Technician
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have two years of experience working in a Health Physics-disci-i pline with at least six months of the two years experience
i working. at a nuclear facility.
This latter selection criteria
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indicates that an individual need only have acquired six months-I of nuclear power plant experience to be a technician. -This
matter was brought to the licensee's attention as being inconsis-tent with the ANSI standard.
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The inspector's review of the resumes of the 13 Health Physics technicians, with respect to the Technical Specification re-quiremer.ts, indicated that 4 of 13 possessed the two years'
experience of the referenced ANSI standard; 4 of 13 possibly. met the standard; and 5 of 13 did not appear to meet the standard.
The inspector was unable to determine if the four individuals who possibly met the standard were qualified due to. the limited
information contained in-their resumes.
Since the licensee's proposed Technical Specification 6.2.2 requires continuous manning by a qualified Radiation Protection technician whenever fuel is in the reactor, it did not appear that a sufficient number of qualified technicians was available to support continuous manning at fuel load.
Licensee representatives stated that in the event sufficient
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staffing was not available, contractor radiation protection
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technicians would be trained and qualified to augment the staff.
The licensee's planned actions appear to assure that there will be adequate manning by traned and qualified personnel at fuel load.
Discussions with licensee representatives indicated Radiation Protection technicians were being trained in accordance with FSAR and procedure requirements.
The inspector stated that the training and qualifications of Radiation Protection technicians will be reviewed during a subsequent inspection (50-322/81-19-05).
6.3 Radiochemistry
The licensee's training program for chemistry personnel, as detailed in procedure no. SP 71.006.01, was reviewed. The program requires that the technicians take written or oral examinations. The inspec-tor found that the licensee did not have docomented evaluation criteria for the written or oral examination. The licensee stated
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that evaluation criteria will be implemented; This matter remains
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open.
(50-322/82-33-01).
7.
Radiation Worker Training
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7.1 Documents Reviewed
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10 CFR 19.12, " Instructions to workers" FSAR Section 12.5.3.5, " Health Physics Training Programs"
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Regulatory Guide 8.27, " Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants"
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SP No. 12.0140.03, " General Employee Training Program."
7.2 Exemptiens From Training The review of the radiation worker. training program and discussions with licensee training representatives indicated the formally esta-blished and implemented prog am was adequate to support fuel load and normal operations.
The discussions indicated that the licensee has implemented a program to exempt individuals from attendance of radiation worker training based on their previous training and experience. This was consistent with guidance contained in Regulatory Guide 8.27 and would preclude unnecessary training of personnel. This program, however, had not been formaliy documented at the time of the inspection (e.g., mini-mum previous training and experience required; length of time prior to previous training, etc.). This was brought to the licensee's attention.
Review of the qualificatlov of the. radiation worker training instruc-tors was not completed dtr7ng tais inspection.
The following matters will be reviewed during a subsequent inspection (50-322/82-33-02):
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licensee program to exempt individuals from radiation worker training.
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radiation worker training instructor qualifications.
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implementation of self-monitor training program.
8.
External Exposure Control 8.1 Documents Reviewed
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SP 61.010.03, Revision 0, " Radiation and Radioactive Material Area Designations and Signs," dated October 28, 1976
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SP 61.012.01, Revision 0, " Personnel Dose Limits and Guides,"
dated May 27, 1982
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SP 61.012.05, Revision 1, " Authorization to Exceed Dose Guides,"
dated June 25, 1982
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SP No. 61.012.07, Revision 1, " Investigation of Unauthorized Exceeding of Administrative Dose Guides or NRC Limits," dated September 4, 1980
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SP 61.018.01, Revision 1, " Radio 1cgical Survey Schedule and Locations," dated September 7, 1978
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SP 61.020.07, Revision 2, " Tools and Equipment Contamination Guides and Controls," dated March 19, 1981
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SP 61.050.11, Revision 3, " Health Physics Exposure History, Records and Reports," dated November 15, 1982
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SP 61.060.11, Revision G, " Radiological Incident Report (RIR),"
dated June 2, 1977
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SP 62.004.01, Revision 3, " Station Personnel Monitoring Prog-ram," dated February 5, 1979
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SP 62.004.23, Revision 0, " Investigation of Lost, Damaged, or Offscale Dosimetry," dated July 28, 1977
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SP 62.022.03, Revision 1, " Step-Off Pad Monitoring," dated September 1, 1977
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SP 12.012.01, Revision 3, " Radiation Work Permit," dated October 8, 1982 8.2 Exposure Control The inspector's review indicated the above licensee procedures provided adequate guidance for 10 CFR 20 and administrative exposure limits; radiologically restricted area access controls; radiation work permits; routine radiation, contamination, and airborne radio-activity surveillance; posting of radiologically-controlled areas and materials; and high radiation area control.
Regarding High Radiation Area Control, the licensee's proposed l
Technical Specification 6.12, "High Radiation Area," requires that areas which exhibit radiation dose rates between 100 mrem /hr and 1000 mrem /hr be barricaded, conspicuously posted, and access thereto controlled by use of a Radiation Work Permit.
In addition to the above controls, those areas exhibiting dose rates greater than 1000 mren/hr are to be provided with locked doors to prevent unauthorized entry.
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The review of procedure SP 61.010.03 indicated that the licensee will lock the access to High Radiation Areas that exhibit dose rates greater than 100 mrem /hr.
This provides more stringent access controls than currently required by the proposed Technical Specifica-tions.
Licensee representatives acknowledge this difference in High-Radiation Area Access Controls and indicated that access to High Radiation Areas will be controlled in accordance with proposed Technical Specifications.
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The intpector stated that High Radiation Area access controls will be reviewed durng a subsequent inspection.
(50-322/82-33-02).
8.3 Exterr.al Dosimetry Program 8.3.1 Dcsimetry Program 10 CFR 20.202, " Personnel Monitoring," requires that licensees supply appropriate personnel monitoring equipment to and require that the equipment be used by each individual who enters a restricted area and may receive or likely receive a dose of 25 percent of the limits specified in 10 CFR 20.101. This monitor-ing equipment is also required for personnel who enter high radiation areas.
10 CFR 20.201, " Surveys,"; requires that licensees make evaluations as may be necessary to comply with the regulations in part 20.
The licensee plans to use vendor supplied personnel dosimetry-pending establishment of an in-house dosimetry program. Dis-cussions with licensee personnel indicated that the vendor supplied personnel dosimetry currently did not have the capabil-ity to provide personnel neutron mo.nitoring. The inspector noted that neutrons would be generated during initial critical-ity, start-up, and power ascension, testing.
Since a potential for personnel exposures to neutrons would exist during performance of radiation surveys and other activi-ties subsequent to initial criticality, the inspector indicated that the licensee should establish and implement a neutron personnel monitoring program at initial criticality. The inspector stated that Regulatory Guide 8.14, Revision 1, " Person-nel Neutron Dosimeters," will provide guidance for establishment of this program.
The inspector reviewed the program established by the licensee to determine if the vendor supplied personnel monitoring equip-ment is acceptable (i.e., appropriate) for use at the licensee's facility. The review and discussions with licensee personnel indicated that test badges are being irradiated monthly for quality assurance purposes.
However, the review indicated that no apparent, formally-documented program has been established for this quality assurance program and that no apparent evalua-tion has been made to determine if the vendor supplied badge was an appropriate monitoring device for monitoring the radiation environment at the licensee's facility.
The inspector noted that the radiation fields generated at initial criticality and subsequent start-up will require that personnel be monitored in accordance with 10 CFR 20.202.
Conse-quently, the inspector stated that the personnel monitoring i
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device, supplied to the individuals in accordance with 10 CFR 20.202, should be evaluated in accordance with 10 CFR 20.201 prior to their use. The inspection indicated that this evalua-tion should be performed prior to initial criticality.
Licensee representatives indicated that the above matters will be reviewed.
The inspector stated that the licensee's dosimetry program will be reviewed during a subsequent inspection prior to fuel load.
(50-322/81-19-12).
8.3.2 Dosimetry Records and Reports A review of this area and discussions with cognizant licensee personnel indicated that dosimetry records and reports were to be computerized. However, this program has yet to be establish-ed. At the time of the inspection, dosimetry records were being processed, in part, manually.
Procedure SP 61.050.11 provides instructions for establishment and maintenance of exposure histories and records for personnel radiation exposure. A review of the procedure indicated it did not address the requirements of 10 CFR 20.102(a) which requires that a signed statement be completed if an individual could receive 25 percent of the limits specified in 10 CFR 20.101(a).
The procedure did provide for completion of Form NRC-4, "Occupa-tional External Radiation Exposure History," if an individual could exceed the limits of 10 CFR 20.101(a).
Licensee repeesent-atives indicated this matter would be reviewed.
Regarding staffing in this area, the licensee has assigned a clerk to process exposure information.
The inspector stated that dosimetry records and reports would be reviewed in a subsequent inspection prior to fuel load (50-322/81-19-16).
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9.
Internal Exposure Control Program 9.1 Documents Reviewed
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Final Safety Analysis Report (FSAR), Chapter 12.5, " Health Physics Program"
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Regulatory Guide 8.9, " Acceptable Concepts, Models, Equation, and Assumptions for a Bioassay. Program"
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Regulatory Guide 8.26, " Application of Bioassay for Fission and Activation Products"
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i ANSI - N343-1978, " National Standard for Internal Dosimetry for
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Mixed Fission and Activation Products"
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SP No. 62.004.03, " Bioassay Program," Revision 0, dated May 15,
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1980 (Station Procedure Change Notice, dated September 27,1982)
SP No. 63.028.01, " Operation of the Whole Body Counting System,"
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Revision 0, dated December 17, 1981
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SP No. 66,028.01, " Calibration of the Whole Body Counter,"
Revision A (Draft)
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10 CFR 20.103, " Exposure of individuals to concentration of
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radioactive materials in air in restricted areas."
i 9.2 Program Review 10 CFR 20.103 requires that no licensee possess, use, or transfer -
licensed material in such a manner as to permit any individual ~1n-
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a restricted area to inhale a quantity of radioactive material in j
excess of the limits specified therein.
For purposes of determining t
compliance with the requirements of this. section, 10 CFR 20.103(3)
states that the licensee shall use-suitable measurements of airborne
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radioactivity and, in addition, as apprapriate, shall use measurements of radioactivity in the body, measurements of radioactivity' excreted
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i from the body, or a combination of such measurements.
Review of the Bioassay Program and discussions with cognizant licen-
l see personnel indicated that the licensee was in the process of i
fully establishing the program.
The licensee is reviewing and revising current procedures and is establishing additional program elements.
Procedures which remain to be established and implemented include procedures for calibration of the whole body counter and quality assurance of indirect bio-assays. The need for a procedure for internal dose evaluation, using direct and indirect bioassay data is under review by the licensee. The licensee's current procedures'were found to adequately describe the use of direct bioassay -internal radioactive material
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deposition data to determine initial intake.
Based on the above review, the licensee has yet'to fully establish and implement a direct and indirect bioassay program.
Because radioactive material will begin to be generated at initial criticality, the licensee should ensure that the Bioassay Program is established and implemented at that time.
The inspector indicated that the Bioassay Program will be reviewed during a subsequent inspection prior to fuel load. (50-322/81-19-14).
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10.
Respiratory Protecton Proaram_
The Respiratory Protection Program is currently being reviewed by the licensee and should be in place by mid-Jaruary.
This implementation date is consistent with a licensee commitment on respiratory protection docu-mented in a recent Confirmatory Action Letter (item I.11, CAL 82-24, September 13,1982). A brief review of licensee procedures indicated that current procedures do not require Grade D breathing air or annuai reviews of the medical status of individuals who wear respirator protection equipment.
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The Respiratory Protection Program will be reviewed during a subsequent inspection (50-322/81-19-17).
11.
Inplant Radiochemical Measurements Program 11.1 Procedures
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The inspector reviewed procedures for liquid and airborne effluent sampling and analysis and instrument calibration.
The inspector identified several technical errors in the procedures..The proce-dures for reactor water sampling and ana. lysis and gamma spectral analysis of charcoal cartridge, gas, and liquid samples were not completed at the time of the inspection.. In addition, all procedures for inplant chemical and radiochemical measurements were in draft.
Based on the above review, the licensee's program for in plant sampling, analysis, and sample analysis instrument calibration remains to be fully established.
The inspector stated that these procedures would be reviewed during a subsequent inspection.
(50-322/82-33-03).
11.2 Laboratory Quality Control (QC)
The inspectors' review of the licensee's program for the quality control (QC) of analytical measurements indicated that Procedure 71.018.01, " General Laboratory Operation," defined the guidelines for the Chemistry Quality Assurance (QA) program.
The inspector noted that Procedure 71.018.01 was being reviewed at the time of inspec-tion.
Procedures which implement specific aspects of the QC program, such as chi-squared tests for the counting equipment and reagent preparation and control, were established.
Because the licensee was in the process of reviewing the Chemistry Quality Assurance program, the inspectors were unable to complete the review of this area.
The quality assurance program will be reviewed during a subsequent inspection (50-322/82-33-04).
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11.3 Capability of Radioactive Measurements The inspector toured the chemistry laboratory and noted that the licensee has two Ge(L1) detectors coupled with a computer-based multi-channel analyzer, one NaI well detector, a gas flow proportion-al counter, and a liquid scintillation counter in accordance with FSAR commitments. The licensee's lab is also equipped with an atomic absorption spectrophotometer, a spectrophotometer; and pH, conduc-tivity and turbidity meters. This instrumentation was noted to be adequate to support fuel load and normal operations.
The inspector presented standard radioactive sources (i.e., parti-
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culate filter, charcoal cartridge, and off gas) to the licensee for analysis. The licer:see was uneble to analyze the sources because the licensee had not yet calibrated counting instrumentation.
Based on the above review, the licensee's program for radioactivity measurements is not fully established in that laboratory instrumenta-tion for this purpose is not calibrated.
This area will be reviewed prior to fuel load (50-322/82-33-05).
12.
Process and Effluent Monitors 12.1 Liquid Radwaste Monitors The inspector reviewed the status of the licensee's liquid effluent and process radiation monitors.
The licensee sent the monitors to a naticnal laboratory for calibration. The inspector reviewed calibration results and noted that acceptable sources were used for the energy response calibration at the laboratory.
The calibration results and methods were found acceptable.
Subsequently, the moni-tors' response to check sources was used to verify the calibration at Shoreham Nuclear Power Station (SNPS). The sources used and methodo-logy were found acceptable.
An onsite source check of Channel 13 (liquid radwaste discharge) and Channel 24 (reactor building closed cooling water) failed, based on the 10% acceptance cr teria between the contract laboratory calibra-tion / source checks results and SNPS calibration results. The licen-see representatives stated that these monitors would be either recalibrated at the national laboratory or at the SNPS.
In order to calibrate at the SNPS, calibration procedures must be written and approved prior to calibration.
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The calibration of liquid effluent monitors will be reviewed during a subsequent inspection prior to fuel load.
(50-322/81-19-24).
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12.2 Gaseous Radwaste Monitors The review indicated all General Electric (GE) monitors were not calibrated at the time of inspection. The review of the status of the calibration of Nuclear Measurements Corporation (NMC) monitors indicated all monitors, except Channel 51 (condenser vacuum pump discharge), were calibrated.
The inspector reviewed the calibration results for NMC Monitor Channel 41, Main Stack Monitor. Channel 41 consists of three detec-tors: detector 41 for particulate, detector 42 for noble gas, and detector 43 for iodine monitoring.
Detectors 41 and 43 were calibra-ted at a national laboratory, and detector 42 was calibrated at SNPS using procedure No. SP 76.037.03, " Isotopic Calibration of RMS Beta Channels." The calibration for the main stack monitor was found acceptable.
The licensee uses charcoal cartridges for iodine sampling in airborne radioactivity effluent radiation monitors. The inspector noted that the vendor has yet to submit to the licensee data concerning the charcoal collection efficiency for methyl iodide and elemental iodine at the respective relative humidity, temperature, and flow rate of the sample stream. This matter wi-ll be reviewed during a subsequent inspection prior to fuel load.
(50-322/82-19-24).
12.3 Determination of the Quantities of Liquid and Gaseous Radioactivity Released The inspector attemoted to review licensee methods used to determine radioactive waste storage tank volumes and effluent release flow rates. The licensee was not able to furnish data addressing these matters at the time of the inspection.
The inspector stated that this will be reviewed during a subsequent inspection.
(50-322/82-33-06).
13.
Radiation Monitoring Instrumentation The inventory of radiation survey and monitoring instrumentation was reviewed against the instrumentation described in FSAR Sections 12.5.2.2.2 and 12.5.2.2.3.
Table 2 shows those instruments which were not onsite at the time of the inspection in the quantities stated in the FSAR.
The licensee stated that procedures covering operation and calibration of all Table 2 instruments onsite (except the portal monitors) had been written and approved.
Licensee representatives stated that the remaining procedures will be established and implemented prior to instrument opera-tion. A sampling of the operation and calibration procedures was reviewed and found acceptabl.
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The licensee has obtained an adequate selection of radioactive sources for gamma (and beta) calibration of the survey instruments. The licensee does not plan to calibrate the neutron survey instruments onsite. Beta gamma check sources are currently available onsite.
Table 2 Radiation Survey and Monitoring Instrumentation Deficit at the Instruments Instruments Instruments Time of the
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a Instrument Onsite Ordered Required by FSAR Inspection b
GM Count Rate
0
10 Meters, 0 to 80,000 cpm Sensitivity High Range GM
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5 Instruments with Telescoping Probes Neutron Rem
2
2 Counters Continuous Air
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3 Monitors c
PIC, 0 to 200 110 1,000 500 390 mrem PIC, 0 to I rem
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40
10
5 Personnel Radia-
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8 tion Monitors, Chirping or Integrating Type Notes for Table 2
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Deficit = (Instruments Required by FSAR) - (Instruments onsite at the time of the Inspection).
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b.
The licensee plans to change the FSAR to require only six instruments of this type. Currently, the licensee has 45 GM survey instruments of various types onsite and eight additional instruments ordered.
The FSAR requires that a total of 48 GM survey instruments be avail-able.
c.
Pocket ion chambers.
The lic'nsee's supply of radiation survey and monitoring instrumentation was fo" d adequate to support fuel load activities. The acquisition of addi+' sal equipment, described in the FSAR, will be reviewed during a fut. ' inspection.
(50-322/82-33-07).
15. ALAf 15.1 Documents Reviewed
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Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Reasonably Achievable," Revision 3.
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Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable," Revision 1-R.
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Nuclear Operations Corporate (NOC) Policy No. 20, " Corporate Responsibilities for the As Low As Reasonably Achievable (ALARA)
Program," Revision 0.
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SP No. 61.070.01, "ALARA Review Committee," Revision A (draf t).
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SP No. 61.071.01, "ALARA Job Review," Revision 0, dated August 6, 1982.
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SP No. 61.071.03, "ALARA Goals and Measurement," Revision 0, dated July 12, 1982.
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SP No. 61.071.05, "ALARA Review of Station Procedures and Design Modifications," Revision A (draft).
15.2 Findings The licensee has established an ALARA Program, consistent with the recommendations contained in Regulatory Guides 8.8 and 8.10.
This program is adequate to support fuel load and normal operations.
The licensee should approve the draft procedures and implement the ALARA Program prior to initial criticalit. -.
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16.
Exit Interview
The inspectors met with licensee representatives (denoted in section 1 of this report) on November 19, 1982. The inspectors summarized the purpose, scope, and findings of the inspection.
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Annex to NRC Region I Inspection Report 50-322/82-33 Shoreham Nuclear Power Station Pre-Operational Inspection (Radiation Protection / Radioactive Waste)
The following matters will be referred to tha NRC Office of Nuclear Reactor Regulation for consideration as Operating 1.icense Condition Items to be accomplished by the licensee prior to fuel load or initial criticality (as indicated):
Fuel Load Items A.
Inplant Radiochemical Measurements Program 1.
Establish and implement the inplant radioacti.ity sampling and analysis program (Details report Section 11).
2.
Establish and implement the Chemistry Quality Assurance Progran.
(Details report Section 11).
3.
Calibrate all laboratory analysis equipment needed to support fuel load and initial criticality (Details report Section 11).
Initial Criticality Items B.
Radiation and Airborne Radioactive Material Expo!ure Control 1.
External Exposure Control a.
Establish and implement a personnel neutron exposure monitoring program consistent with the recommendation of Regulatory Guide 8.14, Revision 1," Personnel Neutron Dosimeters." (Details report Section 8.3.).
b.
Evaluate vendor supplied personnel monitoring equipment to assure appropriate equipment is being supplied to personnel in accordance with 10 CFR 20.202.
(Details report Section 8.3.).
c.
Establish documented controls to assure continued adequacy of vendor supplied dosimetry services in accordance with 10 CFR'
20.201.
(Details report Section 8.3.).
2.
Internal Exposure Controls Establish and implement the Internal Dosimetry Program.
(Details report Section 9).
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