IR 05000322/1988009
| ML20206J512 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/18/1988 |
| From: | Dragoun T, Markley M, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206J501 | List: |
| References | |
| 50-322-88-09, 50-322-88-9, NUDOCS 8811290011 | |
| Download: ML20206J512 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 88-09 Docket No.
50-322 License No.
NPF-36 Priority _-
Category C Licensee:
Long Island Lighting Company Post Office Box 618 Wading River, New York 11792 Facility Name:
Shoreham Nuclear Power Station Inspection At: Wading River, New York 11792 Inspection Conducted: October 17-21, 1988 Inspectors:
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// -//f - N M. Markley, RadiationdI(pecialist date n/n/w
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_ ior Radiation Specialist
'dat6 Dragou(
Approved by:
kl. N L[-b
I s ( BE, R. Shanbaky, Chief, Sicilities Radiation date Protection Section Inspection Summary: Inspection on October 17-21, 1988 (Report No. 50-322/88-09)
Are s Inspected:
Routine, unannounced inspection consisting of a review of radiation protection program areas. Areas reviewed included:
previously identified iteh, organization and staffing, training and qualification of personnel, internal and external exposure controls, control of radioactive material and contamination, and ALARA.
Results: Within the scope of this review, no violations were identified. One weakness was noted in procedure maintenance for operation of the whole body counter. However, it was isolated in nature and not indicative of a programmatic breakdown.
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DETAILS 1.0 P_eg ons Contacted During the course of this inspection, the following personnel were contacted or interviewed:
1.1 Licensee Personnel
- L. Britt, Licensing Division Manager
- H. Buring, Health Physics Engineer
- M. Donegan, Health Physics Supervisor
- N. DiMascio, Radiological Controls Division Manager
- G. Gisonda, Neclear Licensing Supervisor
- P. Kwaschyn, Raawaste Engineer
- M. Ma, Radiochemistry Engineer
- W. Maloney, QC Manager, NQAD J. McLeer, Radiological Engineer
- S. Skorupski, Asst. VP Nuclear Operations
- D. Smith, Compliance Engineer
- W. Steiger Jr., Plant Manager R. Thompson, Oosimetry Specialist
- E. Youngling, Nuclear Engineering Panager 1.2 NRC Personnel
- F. Crescenzo, Senior Resident Inspector Other personnel were contacted or interviewed during tnis inspection.
- Attended the exit meeting on October 21, 1988.
2.0 Purpose The purpose of this inspection was to review the radiation protection
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program.
Specific areas reviewed were:
- status of previously identified items;
- organization and staffing;
- training and qualification of personnel;
- internal and external exposure controls;
- effluent monitors;
- control of radioactive material and contamination; and
- ALARA.
3.0 Status of Previously_ Identified Items 3.1 (Closed) Follow Item (83-19-04).
Determine the ability of the airborne radioactivity ef fluent monitoring systems to collect repre:antative samples.
A licensee engineering evaluation, reviewed
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by the inspector during inspection 86-07, revealed several minor problems with the sample piping. Acceptable modifications to the piping to resolve these problems were completed in early 1988.
This item is closed.
3.2 (Closed) Follow Item (85-04-06 subpart A) Verify the operability of
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PASS system in-line chloride analyzer. Chlorides are analyzed using a Dionex Ion Chromatograph.
The system is eclibrated at 6 month intervals using 10 ppm of chlorides in a matrix with boron, uranium, barium and nitrites. The ion exchange column is regenerated monthly.
Every 2 months t5e piping is checked for leaks and the operability of the pump is verified.
Records of these activities are properly maintained and indicate the operability of the system.
There actions are complete and satisfactory.
This item is closed.
3.3. (Closed) Follow Item (85-04-12 Subpart A) Implement procedures for analysis of highly radioactive effluent samples.
The licensee received approval to use "reference samples" to derive dose rate to curie conversion factors for post accident samples (NRR Letter, R.
Lo, dated 2/26/87) The licensee has implemented the following procedures using this concept:
EP192-7 Post Accident Gaseous Effluent Sampling DP1P2-8 Post Accident Gaseous Effluent Sample Analysis This item is closed.
J.4 (Closed) Follow Item (85-04-19) Obtain NRR approval to use in-line hydrogen analysis to satisfy NUREG-0737 Item II.B.3.
This approval was obtained on August 29, 1985.
Additional analytical requirements were invoked by NRR in license condition 2.C.F "Post Accident Sampling Capability." Since the follow item is consistent with the license requirements, the follow item is now closed.
However, future licensee action will be tracked relative to satisfying the license conditto.s.
3.5 (0 pen) Follow Item (86-11-01) Licensee to determine validity of using generic efficiency factors for the liquid radwaste detectors.
Detector efficiency studies are complete and will be used to produce a new curve for figure 2.1-1 in the Offsite Dose Calculation Manual (ODCM).
This will be complete by November 1938.
In the interim, the RMS computer code based on the original efficiency factors was declared "non-functional" and offsite doses are hano calculated using the method specified in 00CM section 3.
3.6 (Closed) Follow Item (86-11-02) The post accident sampling chloride and boron in-line analyzers are unreliable.
This problem was attributed to poor maintenance by chemistry department personne.
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The entire department has been reorganized and upgraded. As a result, both the Dionex chloride analyzer and Orion boron analyzer have passed the semi-annual calibration checks in 1987 and 1988.
This item is closed.
3.7 (Closed) Follow Item (87-06-01) Revise procedures to clarify special dosimetry processing.
The licensee issued procedure SP 62.004.10,
"Special Dosimetry", Rev. O, to specify special dosimetry processing and use.
Inspector review indicated that the procedure provided adequate instructions.
This item is closed.
3.8 (Closed) Follow Item (87-18-01) ALARA concerns regarding HIC processing.
The licensee performed a thorough engineering evaluation of the handling of radwaste High Integrity Containers (HIC). The handling procedures and equipment were modified.
Plans were formu-lated to procure a special shielding device.
The i h ensee has r.ignificantly improved ALARA considerations as a result of this evaluation.
This item is closed.
3.9 (Closed) Follow Item (87-18-02) Specify actions upon loss of high radiation area access control key.
The licensee revised Work Instruction #005-1 to specify requiremeats in the event of the loss of a high radiation area access control key.
The inspector determined that this work instruction provided adequate guidance for notifications and corrective actions.
This item is closed.
4.0 Organization and Staffing Changes in the licensee's radiological controls organization and staffing were reviewed with respect to requirements in Technical Specifications and recommendations in NQAD audits and surveillances.
The status of the organization was determined through discussions with the Radiological Controls Manager and his staff, review of station procedures and observa-tion of work activities. Within the scope of this review, no violations were idertified.
4.1 Health Ph"sics Section No significant changes in structure or personnel have occurred in the Health Physics sectinn.
Staffing levels are adequate to support current extended plant shutdown conditions or full power operations.
Turnover and attrition have been relatively low while staff morale remains high. A list of 19 accomplishments of this group provided by the licensee is included as attachment A.
A program to produce "home grown" HP technicians is well underway.
This effort involves recruitment and training of locally hired personnel to produce long term stability of the HP technician staff.
There are no contractor HP technicians onsite and approximately 20 bome grown technicians in various stages of qualification.
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5 The inspector observed the Health Physics staff to be motivated, competent, and continuing to improve performance and preparations for power operation.
4.2 Radwaste Section The Radwaste Section was newly formed last year.
During the year, the licensee performed a comprehensive study of the station's radio-active waste processing needs. Management then made specific decisions regarding use of installed systems and contracted vendor services.
This resulted in clear objectives for the radwaste program.
The radwaste section was subsequently reorganized with new position descriptions designed to support the new program objectives. The most significant change was the introduction of the
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"radwaste mechanic" position.
These personnel will operate as well as maintain certain equipment.
In addition, the interfaces between the Radwaste Section and the Plant Operations Department are now clearly defined. A list of specific accomplishments of this section provided by the licensee is included in attachment B.
All critical positions within this section are currently filled.
The program is fully capable of supporting the current extended plant shutdown or power operations.
4.3 Radiochemistry Section Two years ago major programmatic weaknesses in the Radie:hemistry section were discovered.
Last year the licensee completed an extensive restructuring and replacement of personnel.
Currently, all critical positions have been filled. A review of selected resumes indicates that the staf f, including management t.hrough technicians, are qualified for their assigned responsibilities. All contractors and consultant positions have been eliminated.
The use of home grown chemistry technicians, similar to the Health Physics approath, is nearly complete. All foreman and 2/3 of the technician staff are home grown.
Turnover of personnel remains very low.
The licensee provided a list of accomplishments for this section which is included as attachment C.
The inspector concluded that this section is fully capable of administering the radiochemistry program.
5.0 Training and Q_u_alification of Personnel Evaluation of the licensee's training and qualification of personnel was based on:
-criteria contained in 10 CFR 19, "Notices, Instructions, and Reports to Workers; Inspections";
-site Technical Specifications;
-review of station procedures;
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-discussions with licensee personnel and appropriate contractor personnel;
-review of resumes; and-review of training records.
Within the scope of this review, no violations were identified.
The licensee's program for the selection, training, and qualification of radiation protection personnel was adequate.
Licensee implementation of the program was effective. All individuals were determined to meet or exceed minimum qualification requirements.
Personnel are trained and qualified according to functional areas of assignment. Inspector tours of the facility and discussions with the staff indicated that personnel were knowledgeable of their functional areas and plant systems.
The licensee has demonstrated good initiative in training RP technicians by sending them to operating nuclear power plants for "hands-on" experience.
6.0 Audits and Surveillances Inspector review of licensee audits and surveillances indicated good performance.
In addition to satisfying Technical Specification requirements, audits and surveillances were performance-based.
The licensee has taken good initiative in testing health physics technician performance in detecting hidden low level radioactive sources.
A "Quality Hotline" for employee concerns has been introduced.
The licensee addresses all quality concerns for any program including radiological safety.
Resolution of identified items was adequate and appropriate.
7.0 Internal Exposure Controls The licensee's program for internal exposure controls was reviewed against criteria contained in the following:
-10 CFR 20, "Standards For Protection Against Radiation";
-Regulatory Guide 8.15, "Acceptable Programs for Respiratory Protection";
-Regulstory Guide 8.26, "Applications of Bioassay for Fission and Activation Products";
-ANSI N13.1, 1969, "Sampling Airborne Radioactive Materials in Nuclear Facilities"; and-NUREG-0041, "Manual of Respiratory Protection Against Airborne Radioactive Materials".
Licensee performance relative to the above criteria was based on:
-discussions with cognizant personnel;
-review of air sampling and whole body counting records;
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-review of Radiation Work Permits (RWPs);
review of station procedures; and-observation of facilities and equipment.
Within the scope of this review, no violations were identified.
7.1 Air Sampling Inspector review of licensee radiological air sampling indicated good performance. During October prior to the inspection, the licensee had taken approximately two hundred general area and job specific air samples. All air sample activities were less than Minimum Detectable Activity (MDA) of licensed material.
7.2. Engineering Controls The licensee has an adequate program to control and reduce occupational exposure to airborne radiological materials.
Included in this program are tents and enclosures as well as exhaust ventilation systems.
The inspector observed effective use of tents where appropriate.
The licensee has four 200-1000 cfm HEPA filtration units and two 500-2000 cfm HEPA units. The inspector noted that equipment for engineering controls is adequate.
7.3 Whole Body Counting Inspector review of the whole body counting (WBC) program indicated good performance.
The whole body counter was properly calibrated with radioactive sources traceable to the National Bureau of Standards (NBS).
Daily background and source check tests were being performed and trended on quality control charts. WBC records were complete and clearly documented.
No anomalous results were noted.
One weakness was noted in procedure m 'ntenance for operation of the whole body counter.
Specifically, an in-use working copy of pro-cedure SP No. 62.028.01, Rev. 4, "Operation of the Whole Body Counting System" was found to have hand written procedure changes.
Examination of the document indicated that it had been issued on April 10, 1987.
The cognizant individual responsible for the whole body counter was not aware of the handwritten charges.
The licensee immediately removed the procedure from use.
Evaluation of the pro-cedure indicated that the hand written changes did not affect the proper operation of the whole body counter.
Licensee managemert stated that a Licensee Discrepancy Report (LDR) would be issued to address the problem.
The inspector noted that this was an isolated incident in that no other procedure maintenance anomalies were identifie _ _ _ _ - _ _ _ _ _ _ _ _ _ - _
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7.4 Respiratory Protection Inspector review indicated that the licensee has a good respiratory protection program.
The licensee has an adequate supply of respirators to support the plant if it were optional.
Respirators were stored in accordance with manufacturer's recommendations.
Personnel are specifically trained in respirator issuance, maintenance, testing, and repair.
Currently, most respirator use in the plant is for industrial safety rather than radiological safety.
Inspector review of respirator issue records indicated that all persons were trained nd qualified for the respiratory protection devices provided to them.
8.0 External Exposure Controls The licensee's program for the control of external radiation exposure as required by 10 CFR 20 and the technical specifications was evaluated by:
-review of routine radiation survey results and recordkeeping;
-review of stocks of portable radiation monitoring devices that are calibrated and ready for issue;
-observation of work in progress and compliance with Radiation Work Permit requirements;
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-review of terminated Radiation Work Permits;
-tour of Plant areas to observe postings and housekeeping; and-review of technician manning schedules.
Within the scope of this review no violations were identified.
The inspector noted good attention to detail in the routine survey and RWP programs even though significant radiation levels did not exist.
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9.0 Effluent Monitors The inspector reviewed the maintenance and calibration of the liquid and gaseous effluent monitors by discussions with Radiochemistry Department and Computer Engineering personnel and review of appropriate records.
The responsibility for calibration and maintenance of the monitors was shifted to Computer Engineering due to the complex nature of the electronics of the system.
Each calendar quarter the detectors are functionally tested while calibrations are performed on a 18 month cycle.
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Each detector has its own calibration and maintenance procedure.
These were found to be up to date.
The procedures follow the manufacturer's recommendations and industry standards.
Records indicate that the proce-dures were completed at the required intervals for the liquid radwaste panels PNL-013, PNL-23A, PNL-238 and PNL-079 and the vent stack panel PNL-041:
The inspector observed the effluent monitors to be properly
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The inspector reviewed the radiochemistry program to periodically grab sample the effluent paths and conduct laboratory analysis on the samples.
Gaseous samples are drawn weekly while liquid effluents are sampled daily.
The laboratory multi-channel analyzers are subjected to a rigorous calibration prior to their use for analyzing the effluent samples.
Bo h lab calibrations and sample results are maintained on a computer spreadsheet that detects any adverse trends.
The inspector noted a high level of technical competence of the radiochemistry personnel.
10.0 Control of Radioactive Material and Contamination Inspector review of this area was based on:
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-observation of radioactive material control in the facility;
-observation of worker frisking practices;
-review of station procedures; and-discussions with licensee personnel.
Within the scope of this review, no violations were identified.
Personnel were observed to be properly frisking themselves and personal items.
Inspector evaluation of the licensee's frisking instrumentation indicated good performance.
The licensee demonstrated good initiative in acquiring several state-of-the-art whole body personnel friskers.
11.0 ALARA The licensee's ALARA program was evaluated against criteria contained in the following:
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-Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupat'onal Radiation Exposures at Nuclear Power Stations Will Be As
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low As Is Reasonably Achievable";
-Regulatory Guide 8.10, "Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonable Achievable".
Licensee performance relative to these criteria was evaluated by:
-discussions with cognizant personnel; and-review of station procedures.
Procedurally, the licensee has a good program for maintaining exposures
However, because the plant is not operational, it was not j
possible to observe program implementation.
12.0 Exit Meeting The inspector cet with licenseo management listed in section 1.0 on October 21, 1988 at the conclusion of the inspection.
The findings of the inspector were discussed at that tim.
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ATTACHMENT A HEALTH PHYSICS ACCOMPLISHMENTS 1)
Prepared new procedures on Personnel Decontamination and skin dose calculations and trained Health Physics personnel in them.
2)
Prepared a Hot Particle Program procedure.
3)
Procured, Calibrated, and placed in-service 3 Whole Body Contamination monitor (PCMIB's).
4)
Prepared a Technical Basis for use of the Trash Monitor.
5)
Prepared a work instruction on isotopic composition review to assure proper calibration of equipment.
6)
Prepared a new procedure which covers all aspects of diving within the RCA.
7)
Completed the preliminary tests, on site assessment and received NVLAP accreditation for the Personnel Dosimetry Program.
8)
Started, tested, and placed in service the dry cleaning facility for
protected clothing.
9)
Procured and proceduralized the remote dosimetry (Teledose) system.
10) Started and tested the Wet Wash Laundry and Dryer.
11) Procured and calibrated microrem meters from low dose surveys.
12)
Implemented individual assignment of ORD's with resultant reduction of loss by 95'e.
13) Performed Man-Rem estimates for operator rounds and changed to reduce
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exposure to ALARA.
t 14) Procured and proceduralized a laundry monitoring system.
15) The Health Physics Section Training and Qualification Program was accredited by INPO in April 1988.
16) Under the program, there were approximately 27 functional area qualifications completed by the Health Physics Technicians.
The majority of these were completed on the Junior Technicians hired locally, but the qualifications of Senior Technicians are being expanded also.
17) In-house training and qualifications are being enhanced by practical experience from of fsite assignments to operating Nuclear Power Plants,
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Attachment A
Included in these offsite assignments were 1 Supervisor 4 weeks, 1 Engineer 10 weeks, 1 Foreman 10 weeks and 3 Technicians 10 weeks.
18) A comprehensive audit of the Health Physics and ALARA Programs encompassing both in,al65t and corporate support areas was performed by the NQA Department. Only two minor deficiencies were identified.
19) Health Physics also participated in the Work Planning and Scheduling Task Force, and the subsequent rework of the Work Request and Radiation Work Permit Procedures, to assure that work at SNPS is adequately planned and scheduled, and performed in an ALARA manner.
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ATTACHPENT B RADWASTE PREPARE / MAINTAIN READINESS FOR FULL POWER OPERATION LIST OF ITEMS COMPLETED IN LAST YEAR FOR READINESS
Reorganized Radwaste Section - Created & filled Radwaste Foreman &
Mechanics positions.
Filled Radwaste Ops. Engineer position.
- Gained practical experience thru attendance at Seminars - Radwaste Management - observation training at an operating B'4R - RADMAN User Training - TSMT Training - 79-19
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Prepared decision matrix on new operating philosophy - throw - away mode of Condensate Demineralizer Resins, Mobile Demineralizer vs Evaporation; Dewater vs Solidification
Researched & developed ALARA Operations with respect to HIC handling -
from placement of HIC on cart to filling, dewatering, moving, and shipping via new portable platform
Developed T&Q Program for Radwaste Mechanics - Program description complete, Station Procedure - draft; task - draft Shipped 14 HIC's in December - 3 trailer shipments vs 14 cask shipments
Water Management Program - inputs monitored for leakage detection
Auditing improvements - increased attention tt. detail - less findings / observations - back to normal 1 year audit cycle Increased communications with Operations Engineer, Radwaste Day Watch
Engineer & Assistant Operating Engineer to ensure smoother and more efficient Radwaste Operations Increased awareness to safety - New program / weekly & monthly tailboards
Procured Oil Skimmer for TB Floor Drain Sump Leased back-up mobile demin system for Floor Drain Filter
Procured scale for weighing Radwaste containers Incorporated ANI transportation concerns into shipping contracts
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ATTACHMENT C RADI0 CHEMISTRY ITEMS ACCOMPLISHED FOR STARTUP 1)
All Laboratory HpGe's (Gamma Spec. System) have been calibrated.
Readiness to accurately quantify radioactive samples demonstrated through semi-annual check analysis program (Analytics, Inc.)
2)
Received INP0 accreditation for technician Training and Qualification program.
Implementing continuing retraining program for technicians.
3)
Established and maintain the operability of the Post Accident Sampling Facility.
4)
Good evaluation given to Section's performance in two successive Q.A Audits.
Return to normal annual audit cycle.
5)
Significant reduction in the number of identified deficiencies.
(LER LILC0 Deficiency Reports, SPDES violations).
6)
The Radiochemistry Laboratory was ca-tified by New York State Department of Health, for the Environmental Laboratory approval program.
7)
Improvement of Conductivity Monitor preventive maintenance program.
8)
Surveillances for Tec. Spec. Chloride Intrusion Monitors were complete by 4/15/88 and have b)en maintained current.
9)
The laboratory has consistently maintained excellent results for all inter-laboratory samples analyzed.
10)
Improvement in station chemistry has been achieved by implementation of sampling frequencies and limits of BWR Owner's Group Water Chemistry Guidelines.
Purchased new ton chromatograph and portable oxygen analyzer.
11)
Station procedures used to implement radiological effluent technical
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specifications have been reviewed and upgraded to ensure accuracy of
documentation.
12)
Filled two Foreman vancantes with permanent LILC0 personnel.
13)
Two Supervisors completed the GE BWR Radiochemistry Course.
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Attachment C
14) Developed / Implemented a computerized Chemistry Data Management / Trending System (80% complete).
15) Purchased new Ion Chromatograph.
16) Implementation of an aggressive maintenance program to schedule and perform routine activities.
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