IR 05000354/1985052
| ML20138J302 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/10/1985 |
| From: | Bicehouse H, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20138J274 | List: |
| References | |
| 50-354-85-52, IEB-79-19, IEB-80-03, IEB-80-10, IEB-80-3, IEB-81-03, IEB-81-3, NUDOCS 8512170482 | |
| Download: ML20138J302 (29) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report N /85-52 Docket N License N CPPR-120 Priority --
Category C Licensee: Public Service Electric & Gas Company 80 Park Plaza - 17C Newark; New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge and Salem, New Jersey Inspection Conducted: October 28 - November 15, 1985 Inspectors:
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H. J. Bicehouse, Radiation Specialist
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' Approved by: b.'asciak,WChief, BWR Radiological
. W. J \Michf date\
Pr; ction Section Inspection Summary: Inspection on October 28 - November 15, 1985 (Inspection Report 50-354/85-52)
Areas Inspected: Routine unannounced inspection of the applicant's preopera-tional radiation protection and radioactive waste (radwaste) programs including Previously Identified Items, NRC Bulletin Actions, Radiation Protection 4 Organization, Personnel Selection, Training and Qualification, Exposure Controls, Facilities and Equipment, ALARA, Radwaste Management Program, Pre-
-operational Test Program,Startup Test Program and Identification / Correction of Deficiencies. The inspection involved 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> onsite and 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> in office review of procedure Results: Within the areas reviewed, no violations or deviations were note An unresolved item relating to damper closure time changes on the Filtration, Recirculation and Ventilation System (FRVS) and several additional weaknesses in the development of the applicant's radiation protection, radwaste management and preoperational test programs were note PDR ADOCK 05000354 G PDR
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DETAILS 1. Persons Contacted During the course of this routine' pre ~ operational inspection, the following personnel were contacted or interviewed:
1.1 Public Service Electric & Gas Company (PSE&G)
- A. D. Barnabei, Principal Quality Assurance (QA) Engineer
~*V. Blenx, Construction Manager & Assistant Project Manager
- W. Britz, Manager, Radiation Protection Services
- J. F. Duffy, Site Engineering
- A. E. Giardino, Manager, Station QA
- R. T. Griffith, Principal QA Engineer R. Harrington, Senior Radiation Protection Supervisor - Radioactive
' Material Control
- J. L. Kotsch, Senior Health Physicist - Radiation Protection Services
- C. W. Lambert, Site Engineering
- J. R. Lovell, Chemistry / Radiation Protection Manager
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- J. Molner, Senior Radiation Protection Supervisor - Operations
- L. Piccirelli,.QA Engineer Other applicant's employees were contacted or interviewed during this inspectio .2 Bechtel~ Construction Company
- J. A. Dahnert, Quality Control Staff Assistant / Lead Turnover
- G. L. Goldsmith, Resident Engineer
- Grochel, QA Engineer
- A. Indico, Project Start-up Manager
- D, L. Long, Facility Construction Manager
- P. Van Der Veer, Field Engineering Other contractor employees were also interviewed or contacted during the inspectio .3 USNRC A. R. Blough, Senior Resident Inspector
- L. E. Briggs, lead Reactor Engineer
- J. J. Lyash, Resident Inspector
- Attended the Exit Interview on November 15, 198 I:
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L Purpose The purpose of this routine -preoperational inspection was to review the
'.a applicant's developing radiation protection and radwaste programs with'
respect to the following elements:
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Previously Identified Items;
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Radiation Protection Organization / Staffing;
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Personnel Selection, Training and Qualification;
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Exposure Control Program;
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Facilities and Equipment;
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ALARA Program;
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Radwaste Management Program; ,
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Preoperational Test Program;
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Startup Test Program; and
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Identification / Correction of Deficiencie In addition, the applicant's actions regarding four NRC Bulletins were reviewe . Previously Identified Items 3.1 (Closed) Inspector Followup Item (50-334/85-02-01) Review the status of general employee training. Completion of general employee training under 10 CFR 19.12 was reviewed for fuel handlers during Inspection No. 50-354/85-41. The general employee training program was reviewed during this inspection. Selected applicant and
- contractor employee's records were reviewed for completion of the training and overall completion by Departments was determined. This item is close .2 (Closed) Inspector Followup Item (50-354/85-16-01) Procedures to fit test respirator users, calibrate and repair survey instruments and maintain exposure records. Radiation Protection Services had issued controlled procedures and instructions, governing each of the above areas of their responsibility. This item is close .3 (Closed) Inspector Followup Item (50-354/85-16-02) Additional safety ,
meetings and instructions to caution workers about radiography I barriers. The Construction Contractor provided " tool box" safety meetings and additional written safety instructions to its worker Selected workers were interviewed to determine their understanding
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I of industrial radiography exposure barriers and their responsibili-ties. The Construction Contractor appeared to have adequately addressed concerns raised in regard to Inspection N /85-01. This item is close .4 (0 pen) Inspector ~ Followup Item (50-354/85-44-02) Applicant to provide TIP Room Entry Procedure by October 15, 1985. .The applicant had not completed a TIP Room Entry Procedure on-November 15, 1985. This item-remains ope ~ (Closed) Inspector Followup Item (50-354/85-44-05) Review ALARA Program. The applicant's As low As Reasonably Achievable (ALARA)
Program was. reviewed in detail during this inspection and appeared to be adequate for the issuance of an operating license. This item is close . ~ Bulletins The applicant's actions in response to four NRC Bulletins were reviewed to determine if those. actions were adequate to address issues and concerns in.the Bulletins. Each Bulletin was considered " closed" ( actions completed) in the applicant's tracking syste .1 Bulletin No. 79-19 (8/10/79) " Packaging of Low-Level Radioactive Waste for Transport and Burial Bulletin-No. 79-19 described 9 actions to be taken by licensees to assure the safe transfer, packaging and transport of low-level rad-waste. Those actions included 2 actions applicable to operating licensees only, i.e. Item 8 regarding audits of ongoing waste disposal activities and item 9 regarding reporting action plans and radwaste disposal-shipments and activities. The applicant's actions regarding the remaining 7 actions was reviewed and-discussed with cognizant personne Within the scope of this review, the following items requiring the applicant's actions were noted:
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Action Item No. 4 of Bulletin No. 79-19 requires the provision of management-approved, detailed instructions and operating procedures to all personnel involved in the transfer, packaging and transport of low-level radwaste. Operating procedures for collection, radwaste processing and packaging were incomplet Approximately one-third of the procedures were not approved at the time of the inspection. Mandatory quality control hold points were not identified (see related item in Detail 13.2).
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Action Item No. 5 requires, in part, training and retraining in instructions and operating procedures. Operators, quality control personnel and radiation protection personnel had not received training in instructions and operating procedure .. - _-
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Action Item No.-6 requires, in part, training and periodic retraining to employees'who operate the processes to assure that waste is processed into acceptable chemical and physical form for transfer and shipment. Radwaste operators had not received training in the' operation of solid radwaste processes. Much of the radwaste processing equipment had not been preoperationally tested and operating procedures had not been. finalize At the exit interview on November 15, 1985, the inspector stated that'the applicant's actions regarding Bulletin No. 79-19 were incomp' ate and that procedures and training in radwaste processes would be reviewed during a subsequent inspection. 50-354/85-52-0 .2 Bulletin No. 80-03, (February 6,1980) Loss of Charcoal from Standard Type II, 2 Inch Tray Adsorber Cells Bulletin No. 80-03 described two actions to be taken by applicants regarding loss of charcoal from charcoal adsorber cells in certain ventilation systems. The applicant's actions regarding this Bulletin were reviewed. The applicant verified that the type of adsorber cells described in the Bulletin were not being used; selected suppliers of adsorber cells did not have the problem; and the perforated screens were assembled in a manner which prevented the problem noted in the Bulletin. The applicant's responses to the Bulletin were adequate and no additional actions are neede This Bulletin is close .3 Bulletin No. 80-10, (May 16, 1980), " Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment" Bulletin No. 80-10 described four actions to be taken by licensees to identify, sample, review and safely' operate nonradioactive systems which become contaminated. The applicant's actions regarding this Bulletin were reviewed and discussed with the applicant. The appli-cant's construction contractor reviewed the Hope Creek design to identify systems and evaluate the system's design for systems sus-ceptible to radioactive contamination. The contractor assumed the operating presence of certain process radiation monitoring systems in that review. The applicant has requested deferral of several of those process monitoring systems (see Inspection Report N /85-44). Sampling points for grab samples of nonradioactive systems have been provided but procedures and instructions regarding the frequency, sample size and type of analysis were not. In addi-tion, procedures for safety reviews under 10 CFR 50.59'were not discussed in the applicant's closure of the Bulleti At the exit interview on November 15, 1985, the inspector stated that the applicant's actions regarding Bulletin No. 80-10 were
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incomplete and that this item would be reviewed during a subsequent inspection. 50-354/85-52-02 l
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4.4 Bulletin No. 81-03, (April 10,1981), " Flow Blockage of Cooling Water to Safety System Components by Corbicula Sp. (Asiatic Clam)
and "Mytilus Sp. (Mussel)"
Bulletin No. 81-03 described three actions to be completed by holders of Construction Permits (including the applicant) to address l biofouling flow blockage of cooling water to safety system L components. The applicant's actions as presented in response to an open item in the HCGS Draft Safety Evaluation Report (SER) were l . reviewed. The applicant indicated that the referenced organisms were L not indigenous to the local _ estuary but biofouling by similar species was possible. The only safety related heat exchangers which I
receive estuarine water are the Safety Auxiliaries Cooling System L (SACS)heatexchangers(HX). The remaining safety related heat l exchangers are cooled by condensate quality water cooled on the shell side of the SACS HX. Continuous injection of. sodium
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hypochlorite is used to control biofouling. In addition, HX l- performance will be monitored in the applicant's Performance and l Reliability Program. However, the effectiveness of continuous l injection of sodium hypochlorite in controlling biofouling due to t
indigenous species of clams and mollusks was not determined'and the l applicant's monitoring of HX performance had not'been initiated.
l _At the exit interview on November 15, 1985, the inspector stated that
!- the adequacy of the applicant's actions regarding Bulletin No. 81-03 j would be reviewed during a subsequent inspectio /85-52-03.
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l S. Radiation Protection Organization / Staffing The applicant's radiation protection organization was reviewed against commitments provided in the Hope Creek Generating Station Final Safety l Analysis Report (HCGS-FSAR), Volume 16, Section 13.1, " Organization Structure." The applicant's organization had been reviewed during Inspection Nos. 50-354/85-02 and 50-354/85-44. During Inspection N t 50-354/85.44, the reorganization and merger of the Radiation Protection
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and Chemistry groups into a single department was noted. The Radiation Protection Engineer (RPE) vacancy was also noted and discussed as a weakness in the applicant'.s organization during Inspection N /85-44. During this inspection, the applicant's radiation protection organization and current staffing were reviewed relative to t fuel load (i.e. issuance of a Low-Power License).
5.1 Organization
'- The applicant's Chemistry / Radiation Protection Department and the Radiation Protection Services (RPS) Department (corporate)
organizational structures were reviewed to determine if:
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organizational charts depicting the site and corporate radiation protection organizations as presently constituted were present;
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responsibilities and authorities were clearly assigned; and
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additional collateral or supplementary responsibilities to be performed by the radiation protection organizations had been assigne RPS has responsibility for site-widc radiation protection services including dosimetry (external, internal and records), respirator fit testing, health physics instrument repair and calibration, coordi-nation of ALARA activities, maintenance of the Radiation Protection Program Manual and assessments (i.e. audits) of plant radiation protection activities. Within the scope of these responsibilities, RPS had developed administrative and operating procedures and instruc-tions to control its activitie Procedure M12-AP-1 provides an
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organizational chart and defines RPS responsibilitie The Chemistry / Radiation Protection Department has responsibility for the plant radiation protection program. Two procedures describe radiation protection organization and responsibilities:
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SA-AP.ZZ-002(Q), " Station Organization and Operating Practices,"
Revision 0 (July 6, 1984); and
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RP-AP.ZZ-002(Q), " Radiation Protection Department Organization,"
Revision 1 (October 2, 1985)
Neither procedure reflects the reorganized and merged Chemistry /-
Radiation Protection Department. The duties and responsibilities of the Manager, Chemistry / Radiation Protection Department are not defined in either procedure. Although revised organizational charts providing the duties and responsibilities of the Chemistry / Radiation Protecti.on Department are available, both procedures should be revised to reflect the current organization duties and responsibi-lities for the Chemistry / Radiation Protection Department. At the Exit Interview on November 15, 1985, the inspector stated that the two procedures would be reviewed for the inclusion of updated organizational structure and duties during a subsequent inspection.
l 50-354/85-52-04 L 5.2 Staffing l Staffing for the three sections of RPS was reviewed. The Radiation Health section (responsible for the central radiation protection facility including dosimetry, respiratory fit testing and instrument repair and calibration) had two vacancies: Senior Operations Super-l visor and a Technical Support Engineer. The Senior Operations .
- Supervisor position is responsible for day-to-day direction of the l
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operations of the external dosimetry, internal dosimetry / bioassay and instrument repair and calibration section The Technical
' Support Engineer position provides technical expertise in dosimetry and other health physics activities to the RPS Operations personnel and, on request, to the plant. Other RPS positions were filled with either permanent applicant employees or contractor personne Staffing for the radiation protection function of the Chemistry /-
Radiation Protection Department was reviewed. The RPE vacancy (as l noted in Inspection No. 50-354/85-44) was still present. The applicant indicated that interviews and final selection were complete and an RPE would be reporting in early January 198 Supervisory and Senior Supervisory positions were filled. Current
! staffing includes: 6 radiation protection technicians, 15 radiation protection assistants and 6 radiation protection worker Contractor personnel were filling additional positions. The staffing appeared to be adequate to support fuel load and initial criticality.
I 6. Selection. Training and Qualification Programs
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Selection, training and qualification programs in radiation protection were reviewed relative to criteria and commitments provided in the HCGS-FSAR, its referenced ANSI . standards and NRC Regulatory Guide Training programs given onsite and those offered by the applicant' Training Center in Salem, New Jersey were reviewe .1 General Employee Training (GET)
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Procedures, lesson plans and handouts for GET were reviewed. The applicant provides GET in a two part program. Part I provides a four hour program for indoctrination for unescorted access to the facility including special rule: established by the applicant, conduct onsite, emergency response to alarms and individual responsiblitties. Part II provides an additional 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> program including instruction in radiation protection fundamentals, radioactive materials, radiation, biological effects, radiation exposure limits, exposure monitoring, area monitoring and ALAR GET classes are conducted under the direction of the Supervisor -
Access Trainin The inspector reviewed Training Procedure (TP)-201 HC, " General Employee Training," Revision 2 (August 14,1985) and noted that the l procedure conformed to guidance in INP0-82-004-1982, " Institute of Nuclear Power Operations Guidelines for General Employee Training,"
and NRC requirements and guidance.
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6.2 Radiation Worker Training (RWT)
i The applicant provides RWT under TP-202 HC, " Radiation Worker Training," Revision 1 (August 15,1985). TP-202 HC contained both classroom and practical factors training and appeared to conform to INPO Guideline 82-004-1982. An examination requiring a 70% passing grade is given for classroom instruction and practical factors
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demonstrations of skills are also graded on a pass-fail basis by course instructors. The inspector noted that RWT did not include Respiratory Protection Trainin Annual review and requalification of radiation workers under TP-200 HC, " Radiation Worker Review," Revision 0 (July 26, 1985) was also reviewe The completion of training (i.e. GET and RWT) for 20 radiation workers was also reviewe Within the scope of this review, no deviations from the applicant's
~ commitments were note .3 Respiratory Protection Training The applicant's training program for the use of respiratory protec-tive equipment was reviewed. An 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> program consisting of classroom instruction and a practical factors demonstration by the student of the use of a respirator under simulated working conditions is used to qualify workers. The course covers negative pressure full-face piece particulate filtering devices and a medical examina-tion is a prerequisite for course attendance. The inspector noted that the course met guidance provided in Regulatory Guide 8.15 and NUREG-0041 for such course TP-211 HC, " Respirator Protection Training," describes the course but the procedure has not been approved in accordance with Nuclear Training Department requirements for training procedures approva TP-211 HC provides the basis for lesson plans, formal instruction, practical factors demonstration and verification of trainin The applicant should complete review of TP-211 HC to establish the basis
for the ongoing respiratory protection training progra .4 Radiation Protection Assistant / Technician Training / Qualification The applicant's training program for Radiation Protection Assistants and Technicians was reviewed and discussed with the Nuclear Training Department and Radiation Protection personnel. A 24-week course is provided to train Radiation Protection Assistant TP-401 HC,
" Apprentice Radiation Protection Assistant, Revision 1 (June 28, 1985)" provided the basis for this course. The inspector noted that
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10- the course provided training.in mathematics, physics, radiation protection fundamentals, biological effects, NRC regulations, ALARA and job specific topics and included plant systems trainin ,
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A six-week course is provided for Radiation Protection Technician training. TP-402 HC, " Radiation Protection Technician," Revision 3
.(September 30,1985) provided the basis for this cuurse. The
- inspector noted that more comprehensive instructions were provided
! in this course in radiation protection areas than that provided in i the Assistant program.
- The applicant plans to provide continuing training annually to Radiation Protection Assistants and Technicians in a 5-day topical course. TP-406 HC, " Radiation Protection Continuing Training," i Revision 1 (April 12, 1984) includes topical training in plant modifications and regulatory problems as well as general review, emergency plan review and training in packaging and shipping requirement In Section 12.5 of the HCGS-FSAR, the applicant stated that the qualifications of the Radiation Protection Technicians would meet or exceed the personnel requirements of ANSI /ANS 3.1-1981, "American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants." Section 4.5.2 of ANSI /ANS 3.1-1981 requires technicians to demonstrate their ability to perform assigned tasks and their knowledge of the significance of the tasks on plant operations. The applicant's Radiation Protection Admini- ,
strative Procedure (RP-AP).ZZ-014(Q), " Training and Qualification Program," Revision 0 (February 8,1985) considers an individual qualified to perform a task if formal and/or practical training has been completed and the individual has demonstrated competence in the performance of the task. The appitcant documents task qualification on a " Qualification Record" for each individua Review of selected " Qualification Records" for the Radiation Protec-tion Assistants and Technicians showed that many task competence demonstrations had not been completed. In addition, task competence demonstrations could not be performed in several areas due to proce-dures not being developed, (e.g. competence in the use of the gamma spectroscopy system used in air sample analysis and the source testing of survey instruments). At the exit interview on November 15, 1985, the inspector stated that task competence for assistants and techni-cians would be reviewed in a subsequent inspection prior to fuel load for those tasks needed to support fuel load. 50-354/85-52-05
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5.5 Radiation Protection Supervisory / Technical Staff The applicant's training programs for Radiation Protection l Supervisors, Radiological Engineers and other management personnel r
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in Radiation Protection were reviewed and discussed with Nuclear .
Training Department and Radiation Protection' personnel. Supervisory !
training as described in the following procedures was. reviewed:
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TP-901HC, " Technical Supervisory Skills Program-1," Revision 2 (August 15,1985);
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TP-902HC, " Technical Supervisory Skills Program-2," Revision 2 (August 15,1985);
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TP-903HC, " Technical Supervisory Skills Program-3," Continuing Training for Hope Creek Station Supervisors and Senior
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Supervisors," Revision 1 (August 15,1985);
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TP-905HC, " Technical and Management Training," Revision 0 j (April 23, 1985); and
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TP-913HC, " Qualifying Hope Creek Station Personnel to Conduct
, and Evaluate On-the-Job Training," Revision 0 (August 15, l 1985). '
l The inspector noted that plant systems training and technical short course training had also been given to management personnel in i Radiation Protection. Within the scope of this review, the following
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item was noted: Radiological Engineers did not receive training given i to other engineers on the applicant's staff. A formal training program for Radiological Engineers had not been developed and imple-mented. Radiological Engineers had received training including portions of the supervisory skills program in certain instances but training procedures (including goals and objectives) were not avail-l able.
l Radiological Engineers provide technical support to other radiation l protection groups, develop ALARA work practices, interact with i
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station work planning groups to perform initial reviews of planned i work and coordinate radiation protection input to the emergency plan. Radiological Engineers provide "ALARA hold points" in Radiation Work Permits (RWPs) which are a primary radiological administrative control in the applicant's RWP program. A formal l training program to prepare and qualify the Radiological Engineers ,
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in their duties and responsibilities was discussed with the applicant's representatives and will be reviewed during subsequent l inspections. 50-354/85-52-06 Exposure Controls I
The applicant's developing exposure control program was reviewed against
! criteria in 10 CFR 20, commitments provided in the HCGS-FSAR and guidance j
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in NRC Regulatory Guides. Procedures in each exposure control program
- area were reviewed and discussed with cognizant members of the radiation
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7.1 External Exposure Control The applicant's external exposure control program was reviewed to determine if each of the following met requirements and HCGS-FSAR commitments:
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administrative measures for controlling access and stay times in radiation and high radiation areas;
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personal dosimetry equipment and procedures;
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provisions for control of radioactive materials and contamination; and
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provisions for surveys and monitoring of radiation and radioactivit Within the scope of this review, the following items were noted:
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Implementing procedures and instructions for entry into locked high radiation areas and controlling keys to those areas were not provided. Station Administrative Procedure (SA-AP).ZZ-046(Q), " Radiological Access Control Program," Revision 0 (February 12,1985) identified the need for such procedures and instructions but they had not been provided. At the exit in-terview on November 15, 1985, the need for implementing proce-dures and instructions for entry into locked high radiation areas and controlling keys to those areas was discussed with the applicant's representatives. The applicant's representatives acknowledged the finding and indicated that procedures would be developed and implemented prior to fuel load. 50-354/85-52-07
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Guidance for radiation protection technicians and personnel designated as "self-monitors" entering high radiation areas as to the maximum dose rate in which they could remain was not provided. In view of the recent experience with a radiation protection technician entering and remaining in a 200 Rem / hour field at another facility, appropriate guidance is needed. The ,
applicant's representatives indicated that guidance on dose I rates would be developed and implemented prior to fuel loa /85-52-08
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The applicant's upper dry well can experience transient high radiation levels as a result of fuel movement during refuelin Administrative controls to ensure that radiation protection personnel are aware of fuel movement and, thus, able to exercise adequate control of personnel access to the upper drywell are needed. At the exit interview on November 15, 1985, the appli-cant stated that
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station administrative procedures governing fuel movement would be developed and implemented prior to irradiated fuel movement to the fuel pool. 50-354/85-52-09
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Regulatory Guide 8.28, (" Audible - Alarm Dosimeters"), recom-( mends, in part, that the dosimeters be checked for response to
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radiation prior to use and periodically between calibration intervals in accordance with the manufacturer's instruction The. inspector noted that procedures for response checks of audible alarming dosimeters, (e.g. Dositec Model DOS-502) were not provided. The applicant stated that audible alarming dosi- r meter source checks would be included in procedures to be developed for the use of the cesium-137 source check modul /85-52-1 i 7.2 Personnel Dosimetry '
The applicant's personnel dosimetry program was reviewed to determine if:
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provisions for timely measurements, recording and dissemination of current dose data and accurate recording of prior dose were made;
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provisions to prevent tampering with dosimeters, use of dost-meter by persons other than the individual to which it was l assigned and for investigating loss of, or damage to dosimeters
were provided;
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photon, beta and neutron exposures could be measured in the ranges and energies normally encountered in ccmmercial operation;
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procedures for selection and placement of dostmeters in non-uniform radiation fields were adequate;
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provisions for special processing of dosimetry were provided; and
-- a quality control program testing dosimetry accuracy and sensitivity was in plac t
The inspector noted that tiie applicant's personnel dosimetry program had received accreditation from the National Voluntary Laboratory
- Accreditation Program (NVLAP),
Within the scope of this review, the following items were noted:
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Gamma energies from 51 kev (x-ray) through 662 kev (cesium-137)
were used in the NVLAP tests of the applicant's thermolumines-i cent dosimetry (TLD) system. Higher energy gamma response, i l ('e.g. 6,130 kev and 7,110 kev from Nitrogen 16) were not deter-mined during the NVLAp tests. In addition, information relating
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plant radiation protection staff. The applicant indicated tha tests and analyses of the TLD response to high energy gamma photons would be completed and information related to the energy response characteristics of the TLD would be provided to the plant radiation protection staf /85-52-11
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Although the applicant planned to use a contractor-supplied i neutron monitoring device occasionally to monitor possible neutron exposures, the applicant's planned method for deter- i mining recorded doses to personnel was a calculation of neutron
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dose rate (as measured by suitable survey instrumentation) and ,
I the individual's occupancy time. However, procedures for cal- *
culation and recording of possible neutron dose were r.ot pro-vided. The applicant indicated that procedures for calculating and recording possible neutron doses would be developed. The inspector noted that the procedures were needed to support initial criticality and low power testing and stated that this item would be reviewed in a subsequent inspection prior to fuel load. 50-354/85-52-12-
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Procedures and guidance in the determination of skin doses resulting from the presence of radioactive contamination on the skin were not provided. The applicant indicated that procedures to determine skin dose from the presence of skin contamination I would be provided by fuel load. 50-354/85-52-13
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Self-reading pocket dosimeters (SRD) are used by the applicant as an immediate indication of dose received during work activities in radiologically controlled areas. Procedures for l evaluating exposures to personnel when SR0s were offscale were l not provided. The applicant indicated that procedures for evaluating exposures to personnel whose SRDs were offscale would be provided by fuel load. 50-354/85-52-14 7.3 Internal Exposure Control The applicant's internal exposure control program was reviewed to :
determine if
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airborne radioactivity monitors and air sampling were planned for locations in normally occupied areas where airborne i radioactivity could be present* !
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administrative measures for controlling intake of radioactive materials including access control, procedures, control / action levels and posting were adequate;
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engineering controls including air balance, auxiliary ventilation systems and provisions for evaluating engineering 3 controls were planned; ;
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protective clothing, contamination monitoring and other !
measures were planned to prevent internal-exposures in contaminated work areas; and
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guidance for bioassay, (i.e. whole body counting and excreta !
analysis, were provided, l l
Within the scope of the review, the following items were noted:
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The applicant planned to use a dehumidification method for determining airborne tritium concentrations. In this method tritium specific activity in the air sample condensate is determined by measurement of the specific activity of the condensate and determination of the airborne water concentration (i.e. a relative humidity determination). The applicant's procedure failed to provide instruction for the conversion of relative humidity to airborne water concentration. The applicant indicated that guidance for this conversion would be provide /85-52-1 The applicant plans to sample airborne particulates from a sampling line into the drywell prior to entry into the drywell. Particulate sample losses in that sampling line were calculated by the applicant. However, verification of the ,
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calculationbyparticulatetesting,(e.g.DOPTesting)wasnot planned. When this concern was brought to the applicant's attention, the applicant indicated that a drywell sample line loss test with a known aerosol would be complete /85-52-16
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The applicant's procedure for testing air sampling media collection efficiencies required the use of an airborne radioactivity concentration of greater than 1E-6 microcuries ;
per cubic centimeter. The inspector suggested that the use of a nonradioactive method, (e.g. corn oil or DOP testing) would be more appropriate as a means to ensure that air sampling
'
media collection efficiencies met specifications. The applicant stated that nonradioactive test methods would be considered in future revisions to the procedur '
50-354/85-52-17 l t
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Although personal air samplers, (i.e. " lapel samplers") had been obtained for sampling airborne radioactivity concentrations in the breathing zone, the applicant had not provided procedures for the use of those samplers in work situations. The applicant stated that procedures for issue, use and control of personal air samplers would be provided. 50-354/85-52-18 7.4 Respiratory Protection Program Under the provisions of 10 CFR 20.103(g), the applicant provided notification to the Administrator, USNRC Region I of the intent to apply protection factors for the use of respiratory protective equipment. The applicant stated that the Hope Creek Generating Station Respiratory Protection Program was complete in that notifi-cation. The applicant's respiratory protection program was reviewed against criteria provided in 10 CFR 20.103(c) and guidance in Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protec-tion."
Within the scope of this review, the following items were noted:
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Regulatory Guide 8.15 recommends, in part, that a written policy statement on respiratory usage be issued from a high management level. Subjects to be covered by the policy statement include the use of practicable engineering controls instead of respirators, routine, nonroutine and emergency situa-tions and periods of respirator use and relief from respirator use. However, a policy statement on respirator usage issued by a high management level was not available during the inspectio The applicant stated that a policy statement on respirator usage would be provided in the pSE&G Radiation Protection Plan which was undergoing review for eventual signature by the Vice President, Nuclear. 50-354/85-52-19
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Regulatory Guide 8.15 recommends, in part, written procedures for maintenance to ensure full effectiveness of respiratory protection equipment including procedures for cleaning and disinfection, decontamination, inspection, repair and storag Although pror*dures in the areas were provided, radiation pro-tection persc..nel responsible for implementing those procedures had not been trained and qualified to perform the procedure The applicant stated that radiation protection personnel would be trained and qualified on the procedures prior to the first use of protection factors for respirator /85-52-20
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The presence of facial hair in the sealing surface of negative pressure operating respirators can compromise the sealing surface and diminish the respiratory protection provided. A policy statement concerning the presence of facial
s
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hair in the sealing area'was not provided by the applican The applicant stated that a policy statement would be provided concerning facial hai /85-52-21
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The procedures for determining and recording exposure to airborne radioactivity concentrations, (i.e. MPC-Hour accounting) listed an incorrect protection factor (PF) for full-face powered air purifying respirators, (i.e. a PF=100).
If the respirator remains at a positive pressure at all times
, (including inhalation), the PF is 1000. As a " continuous flow" respirator, (i.e. without assurance that positive pressure is
'
maintained throughout the breathing cycle), the PF is 50. The applicant stated that the PF in the procedure would be corrected to 50 since the powered air purifying respirators were considered " continuous flow". 50-354/85-52-22 7.5 Radiation Work Permit Program The applicant's Radiation Work Permit (RWP) Program was reviewed initially during Inspection No. 50-354/85-44. As noted during that inspection, the applicant's RWP program procedure described a manual RWP syste The computer-based RWP system remains under development and will be reviewed upon its completion and initiatio /85-52-23. During this inspection, the following aspects of the RWP Program were reviewed:
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communication of the work scope to radiation protection personnel;
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measurement and evaluation of radiological conditions in the work area;
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identification and control of radiological hazards; and
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ALARA Program interactions and interface Within the scope of this review, the following items were identified:
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Section 5.3 of ANSI /ANS 3.2-1982,("AdministrativeControlsand Quality Assurance for the Operational Phase of Nuclear Power Plants"), recommends that each procedure be sufficiently detailed for a qualified individual to perform the required function without direct supervisio The journal, Radiation Protection Management (July 1984), in reporting the results of a survey of radiation work permit systems at 31 utilities recommended that each RWP contain a job description complete enough so that workers will know what is outside the scope of the permit. The applicant's RWP procedure requires "a brief, concise description of the work to be performed" in the job description section of routine and extended RWPs. Discussions
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.with radiation protection personnel indicated a general under-standing of the need for exact job description However, vague job descriptions, (e.g. " pump surveillance," " valve inspection,"
,
-" valve repair," etc.) also appeared to be acceptable "brief, i
concise" descriptions of the work. If a clear understanding of the nature and extent of the work is not shared by the workers and radiation protection personnel, it is unlikely that adequate evaluations of potential radiological conditions to be encoun-tered by the workers will be considered. This concern was discussed with the applicant and will be reviewed during sub-sequent inspection /85-52-24
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Extended RWPs authorize work of a routine nature, (e.g. routine sampling, valve lineups or calibration checks), which do not change the radiological status of the system or work are Extended RWPs are issued for periods up to 6 months. Dis-cussions with radiation protection personnel indicated that special precautions and instructions were to be used to indicate the need to suspend work in progress for significant changes in radiological working conditions. However, the RWP procedures failed to provide guidance as to when such special precautions
, and instructions should be considered. This concern was dis-cussed with the applicant and will be reviewed during a subse-quent inspection. 50-354/85-52-25 8. Radiation protection Facilities / Equipment The applicant's radiation protection facilities / equipment were reviewed relative to commitments in the HCGS-FSAR, Volume 16, Section 12.5.2,
" Facilities, Equipment and Instrumentation," to determine if:
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suitable areas were available at appropriate locations for counting room, calibration, personnel decontamination, access control, equipment decontamination, instrument storage, fitting / testing /-
cleaning respiratory protective equipment, training, contaminated equipment storage and laundry of protective clothing;
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the facility provided adequate change rooms equipped with sufficient lockers reasonably close to the decontamination area and the control points to the radiologically controlled areas;
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sufficient quantities of respiratory protection devices, anticontami-nation clothing, temporary shielding, containment materials, portable ventilation systems, portable survey instruments and air samplers were present; and
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laboratory instruments (e.g. multichannel analysers, proportional counters, etc.) were available and ready for use.
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The applicant's performance in meeting the commitments above was assessed by tours and observations of plant areas and equipment, discussions with radiation protection personnel and review of calibration procedures and other records related to the equipment present. Within the scope of this t review, the following items were noted:
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The inventories of portable survey instruments available for use exceeded commitments provided in Table 12.5-1, " Types of Portable Instruments."
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Three proportional counters (used to count alpha and/or beta i samples) in the applicant's radiation protection count room were out of. service. Discussions with cognizant radiation protection personnel indicated that a lack of P-10 counting gas was the caus The inspector noted that the instruments had been down since 4
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October 25, 1985. An Eberline Model BC-4 and an Eberline Model SAC-4 were being used to count wipe samples and air samples from the i refueling floor. The inspector stated that the operability of the I three proportional counters, (i.e. Tennalec Model LB 5100 and two i NMC Model 0S-33 units), would be reviewed during a subsequent [
. inspection prior to fuel load. 50-354/85-52-26 ;
i I
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Procedures for operation of two Nuclear Data Multichannel analyzers '
l and EG&G--Ortec GeLi detectors to be used by radiation protection personnel for analysis of air samples, smears and other samples were ,
! not in place during the inspection. The applicant stated that
! procedures for routine operation, calibration, operability and l quality control would be in place to support fuel loa !
l 50-354/85-52-27 l
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Installation and operability tests for 7 National Nuclear " Beta Max ;
i Standup Frisk all" personnel contamination survey instruments, (4 at ;
!
the 137 foot elevation control point and 3 more at the 124 foot '
elevation control point) were incomplete. Procedures for source l checks, operation and calibration for those instruments were also l unavailable. The applicant stated that installation, operability tests and supporting procedures would be in place prior to fuel
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load. 50-354/85-52-28 l -
Installation and operability testing of an Air Techniques Incorpor-ated (ACI) Penetrometer Model TDA-100 used to test air particulate
'
filter cartridges and masks used in the respiratory protection ,
! program was incomplete. The applicant stated that installation and ;
testing would be completed prior to fuel load. 50-354/85-52-29
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A 30 millicurie costum-137 source check module for checking response i of portable survey instruments was being assembled by the app 1tcan ;
Testing and procedural development for use of the source in operability tests was also incomplete. The applicant stated that i installation, testing and procedures for use of the source check i module would be in place prior to fuel load. 50-354/85-52-30 i
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Cabinets and other storage facilities for support services, ( protective clothing / equipment, self-reading dosimeters, etc.) were not installed on um 137 foot and 124 foot elevations. The applic' ant stated that cabinets and other storage facilities sufficient to store needed protective clothing / equipment and dosimeters would be in place prior to fuel load. 50-354/85-52-31
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Whole body counting equipment and respirator fit test equipment were being relocated from the Salem Generating Station to the new Guardhouse facility basement. The applicant stated that relocation would be completed and operability of the units would be established prior to fuel loa /85-52-32 9. ALARA Program The applicant's development of an ALARA Program to support plant operation was reviewed relative to the guidance and commitments provided in:
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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 Is Reasonably Achievable," Revision 3 (June 1978);
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Regulatory Guide 8.10. " Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reasonably Achievable," Revision 1-R (September 1975);
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HCGS-FSAR, Volume 15, Section 12.1, " Ensuring that Occupational Radiation Exposures Are As Low As Is Reasonably Achievable;" and
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HCGS-FSAR, Volume 16, Section 12.5, " Radiation Protection Program."
The applicant's performance relative to the guidance and commitments was determined by interviews of radiation protection personnel, examination of preoperational ALARA reviews, observations of work areas during plant tours and review of the following procedures and manuals:
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Public Service Electric and Gas Nuclear _ Department ALARA Manual;
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M12-AP-7, " Radiation Protection Services ALARA Program Responsibilities," Revision 0 (Draf t);
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SA-AP.ZZ-007(Q), "ALARA Program," Revision 1 (May 14,1985);
i
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RP-AP.ZZ-007(Q) "ALARA Program Implementation," Revision 0 l
(April 29,1985);
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RP-TI.ZZ-005(Q) "ALARA Reviews and Documentation," Revision 0 (September 17,1985);
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RP-TI.ZZ-016(Q), "Special Radiological Surveys and Hot Spot i
Tracking," Revision 0 (August 15,1985);
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RP-AP.2Z-103(Q), " Trending Program," Revision 0 (April 29, 1985); and
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RP-TI.ZZ-002(Q), "Use of Portable Shielding," Revision 0 l (September 16,1985).
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ALARA Program development was reviewed to determine if:
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the program was established with policies, responsibilities and authorities assigned;
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facility / equipment design features were included;
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the program was integrated with the radia. tion protection program; and
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sufficient procedural guidance was provided to ensure program implementation during startup.-
Within the scope of this review, the applicant appeared to be developing l and implementing generally effective ALARA program to support startup j activities. ALARA procedures appeared to be consistent on the corporate i
and site level . Radwaste Management Program t
During Inspection No. 50-354/85-02, organization, responsibilities and authorities for the applicant's radwaste management program were reviewe During this inspection, plans and procedures for implementing the appli-
- cant's radwaste management program were reviewed relative to commitments >
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l in the HCGS-FSAR and recommendations and guidance provided in NRC l
Regulatory Guides and ANSI standards. The applicant's performance in i developing an adequate radwaste management program was assessed by review ,
l of procedures relating to solid, liquid and gaseous radwaste disposal and l discussions with members of the Operations and Chemistry / Radiation Pro- ;
I taction Department staff ;
! 10.1 Program Responsibility StationAdministrativeProcedure(SA-AP).ZZ-029(0)," Radioactive ,
Waste and Material Control Program," Revision 1 (March 11, 1985) i defines departmental and individual responsibilities in the radwaste :
l management program. The inspector noted that major programmatic l responsibilities were spilt between the Operations and the
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l l Chemistry /RadiationProtectionDepartmentsandSA-AP.ZZ-029(Q)had i not been revised to reflect the merger of Chemistry and Radiation ,
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Within the Operations Department, release of radwaste liquid and gaseous effluents require:. the approval of the Senior Nuclear Shif t Supervisor. The Senior Operating Support Supervisor has responsi-bility for the development and implementation of procedures for processing liquid radwaste, radwaste solidification and control of gaseous radwast Within the newly-formed Chemistry / Radiation Protection Department, Chemistry personnel sample and analyze liquid radwaste and perform calculations to ensure release requirements are not exceeded. The Radioactive Material Control (RMC) Group (under the supervision of the Senior Radiation Protection Supervisor - RMC) samples and analyzes radwaste gaseous effluents and solid radwaste, sets release requirements for gaseous radwastes, develops and implements procedures for generation, packaging and shipping of solid radwaste and ensures all releases are ALAR .2 Radwaste Operatirg Procedures
.The status of 22 radwaste operating procedures was reviewe Sixteen procedures had been reviewed and approved and the remaining six were in various stages of draf t, review or being held for additional information. In eleven approved procedures reviewed, additional information (identified by the applicant as "laters") was needed. The procedures had been approved for training or validation processes but not for implementation until the additional information was provided in the procedure. The following table summarizes the status of radwaste operating procedures:
Procedure N Title S ta tu_s OP-SO.HA-001 " Gaseous Radwaste" approved with "laters" OP-SO.HA-002 " Gaseous Radwaste approved with "laters" Ambient Charcoal Compartment Ventilation System Operation" OP-SO.H0-001(R) " Liquid Radwaste - approved with "laters" Equipment Drain System Operation" OP-50.HB-002(R) " Liquid Radwaste - approved with "lators" Floor Drain System Operation" OP-50.HB-003(R) " Liquid Radwaste - approved with "lators" Chemical Waste System Operation"
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OP-50.HB-004(R) " Liquid Radwaste - approved with "laters" Regenerate Waste
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Collection and Processing"
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OP-50.HB-005(R) " Liquid Radwaste - approved with "laters" Release and Recycle System Operation" 0P-SO.HB-006(R) " Liquid Radwaste - approved with "laters" Filter Demineralizer System Operation" OP-50.HC-001 " Solid Radwa:te - approved with "laters" Collection System Operation" OP-SO.HC-002(R) " Solid Radwaste - approved with "laters" Asphalt Storage and Transfer System Operation" 0P-50.HC-003 " Solid Radwaste - awaiting inclusion of Auxiliary Boiler SORC comments initial Operation" draft OP-50.HC-004 " Solid Radwaste - initial draft Crystal 11zer Operation" 0P-50 HC-005 " Solid Radwaste - final comment Extruder Evaporator Operation" OP-SO.HC-006(R) " Solid Radwaste - Drum approved with "laters" Handling System" OP-SO.HG-001 " Radioactive Drains and initial draft Waste System Operation" OP-50.HH-001(R) " Radioactive Laundry approved Drains System Operation" OP-AR.HA-XXX " Gaseous Radwaste Alarm hold for information Response" OP-AR.HB-XXX " Liquid Radwaste Alarm initial scope / draft only Response:"
OP-AR.HC-001(R) " Slurry - Solid Radwaste awaiting inclusion of Annunciator Panel" SORC ct.wments
._. __ -_________ -_____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _
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OP-AR.HC-002(R) " Concentrates - Solid awaiting inclusion of Radwaste Alarm Response" SORC comments OP-AR.HC-003(R) " Asphalt - Solid approved with "laters" l Radwaste Annunciator (alarm setpoints)
t Panel 00C377C"
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- ' OP-AR.HC-004(R) ." 'A' Extruder - Solid approved but missing
!' Radwaste Annunciator alarm setpoints Panel 00C3770" At the exit interview on November 15, 1985, the inspector stated that -
radwaste operating procedure development would be reviewed during a l subsequent inspection prior to fuel load. 50-354/85-52-33 L - 10.3 Solid Radwaste Packaging / Shipping Procedures The following procedures were reviewed and discussed with members of the applicant's RMC Group:
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RP-AP.ZZ-029(Q), " Radioactive Material Control," Revision 2 (August 6,1985);
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RP-RW.ZZ-004(Q), " Shipment of Radioactive Material," Revision 1 (June 7, 1985);
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RP-RW.HC-001(Q), " Collection and Segregation of Radioactive Waste," Revision 0 (April 26, 1985);
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RP-RW.HC-002(Q), " Compaction of Radioactive Waste," Revision 0 (June 27,1985);and
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RP-ST.ZZ-001(Q),"RadioactiveMaterialShipmentSurveillance,"
Revision ) (June 7,1985).
Within the scope of this review, the following items were identified:
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Procedures for radwaste shipments under 10 CFR 71.12 " General Licensees" had not been developed by the applicant although the applicant intended to make shipments using packages for which a certificate, general Itcense or other approval had been issued by the NRC. The inspector stated that the development of procedures for using packages under 10 CFR 71.12 would be reviewed during a subsequent inspection. 50-354/85-52-34~
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Radiation Protection Radwaste Procedure (RP-RW).ZZ-004(Q)
provided a conversion factor for determining the contained activity within a low Specific Activity-(LSA) box radwaste shipment. The basis for the dose rate to activity conversion factor was reviewed and discussed with the applicant. An error
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in the basis calculation was noted which would have caused activity determinations in LSA shipments to be incorrec The applicant acknowledged the error and stated that it would be corrected in a revision to RP-RW.ZZ-004(Q) prior to fuel loa /85-52-35 10.4 Liquid and Gaseous Radwaste Procedures
!
Liquid and gaseous radwaste procedures were not available for revies. Procedures for sampling, analysis, offsite dose calculations, recording and reporting of gaseous and liquid radwaste effluents will be reviewed during subsequent inspectio /85-52-36 1 Preoperational Test Program Initial reviews of the applicant's preoperational test program for the gaseous, liquid and solid radwaste systems were conducted during Inspection No. 50-354/85-44. During this inspection, completed / approved preoperational test procedures were reviewed, ongoing preoperational tests were observed and completed tests were. reviewed for dispositioning of test exceptions. Criteria and commitments for this review were provided in the HCGS-FSAR Chapter 14, Regulatory Guides and ANSI standards. The inspector noted that preoperational tests of radwaste systems appeared to be behind schedul .1 Gaseous Radwaste Systems Preparations and tests for the Offgas System (Preoperational Test Procedure (PTP) HA-1 " Gaseous Radwaste") were observed during walkdowns of the Offgas System components and subsystems. PTP N GU-1, " Filtration, Recirculation and Ventilation System," Revision 0 (October 25,1985) was reviewed. Planning for tests of the isokinetic sampling systems on the North and South Plant Vents were also reviewe Within the scope of this review, the following items were identified:
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Acceptance criteria for closure of dampers in the Filtration, Recirculation and Ventilation System (FRVS) in PTP No. GU-1 allowed response times of 3-10 seconds to close the damper The HCGS-FSAR, Section 9.4, (Pages 9.4-25 and 9.4-27) provides a response time of 3-5 seconds for FRVS damper closure. The applicant had not requested changing the closure time to 3-10 seconds as specified in PTP No. GU-1. The adequacy of a response time of 3-10 seconds for FRVS damper closure is unresolved pending submittal of a request for amendment to the HCGS-FSAR and review and approval of that request by NR /85-52-37
_ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ - - - _ _ - - - _ _ _ _ _ _
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. Air particulate, radioiodine and gaseous samples are removed by l .the isokinetic samplers in the North and South Plant Vents and transported through several meters of tubing to sample c'ollection and monitoring equipment. Line losses for air
, particulates and radioiodines during transport to the sample
collection point should be determined by tests on the system.
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The applicant indicated that line loss tests would be
? -considered. 50-354/85-52-38
- 11.2 Liquid Radwaste Systems Preparations and preliminary tests of the liquid radwaste system
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were observed during_walkdowns of liquid radwaste syste In addition, the following preoperational test procedures were reviewed:
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PTP No. HB-3, " Liquid Radwaste Equipment Drains," Revision 0
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(November 7, 1985);
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PTP No. HB-4, " Liquid Radwaste Neutralization Waste Concentration," Revision 0 (November 7, 1985); and PTP No. HB-5, " Liquid Radwaste Floor Drains and Equipment Waste
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Processing," Revision 0 (October 30,1985)
Within the scope of this review, no violations or deviations were note .3 Solid Radwaste System Twelve preoperational test procedures were identified during
' Inspection No. 50-354/85-4 PTP No. HC-1.01, " Solid Radwaste Auxiliary Boiler," had been completed and test results were undergoing review by the applicant. Test exceptions from PTP N HC-1.01 were reviewed and discussed with representatives of the applicant's Startup QA organization. Additional walkdowns were completed verifying components and systems were installed in accordance with commitments in the HCGS-FSA Within the scope of this review, no violations or deviations were note . Startup Test Program A preliminary review of the applicant's startup test program was-completed relative to commitments in Subsection 14.2.12.3, "Startup Test Procedures," of the HCGS-FSAR. Plans, preparations and preliminary test procedures for the applicant's radiation measurements during initial operation were reviewed. The objective of the radiation measurements test is to monitor radiation at selected power levels during plant I
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operation to ensure the adequacy of shielding for personnel protection and verify compliance with requirements in 10 CFR 20. Two procedures relating to this test were reviewed:
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TE-SU.ZZ-022(Q), " Radiation Measurements - Post Fuel Load,"
Revision 0 (undergoing review); and
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TE-SU.ZZ-021(Q), " Radiation Measurements," Revision 0 (undergoing review)
The draft test procedures were reviewed relative to recommendations in ANSI /ANS 6.3.1.-1980, "American National Standard Program for Testing Radiation Shields in Light Water Reactors (LWR)."
Within the scope of this review, the applicant's planned radiation-measurements test appeared to meet recommendations in ANSI /ANS 6.3.1-198 . Identification / Correction of Deficiencies The applicant's development of a program to identify and correct radio-logical controls deficiencies was reviewed to determine if a program to identify, investigate, document, report, track, close and trend discre-pancies in radiological controls had been developed to support preopera-tional testing and operation. The applicant's program was reviewed relative to criteria and commitments provided in:
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10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants";
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HCGS-FSAR, Volume 16, Section 12.5, " Radiation Protection Program";
and
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HCGS-FSAR, Volume 18, Section 17.2, " Quality Assurance During the Operations Phase".
13.1 Preoperational Testing Quality Assurance The applicant's program for identifying, tracking and closing preoperational test _ exceptions in radwaste systems was reviewed relative to the criteria and commitments above by interviews of test engineers and Startup Quality Assurance personnel and review of the following procedures:
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Startup Administrative Procedure (SAP)-6, "Startup Quality Assurance Program Interface," Revision 1 (August 29,1985);
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SAP-10, "Startup Deviation Report Program," Revision 10 (August 10,1985); '
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SAP-20, " General Detail and Corporate Test Procedures,"
' Revision 7 (August.2, 1985); and
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SAP-24, "Preoperational Test Procedure, Format and Instructions," Revision 9 (August 26,1985)
The applicant's program to verify that radwaste systems were designed.and constructed to meet commitments and criteria and that tests conducted prior to fuel load demonstrated the capability of those systems to meet performance requirements was also reviewe Within the scope of. this review, the following was noted:
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the applicant's commitments in Subsection 17.2.11, (" Test Control"), of the HCGS-FSAR were being met for testing of radwaste systems;
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Sttrtup Quality Assurance personnel provided a generally adequate overview to ensure that acceptance criteria for radwaste. systems were being tested and met and that exceptions I to those acceptance criteria were properly disposition'ed; and
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Radwaste system tests were being treated administratively as qua?ity or "Q" procedure . i No' deviations ~from previous commitments were note ,
13.2 Operational Quality Assurance The applicant's p ogram development for inspection, surveillance and audit of, radiological controls activities was reviewed relative to the criteria above. The applicant's performance was determined by
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interviews of~ Quality' Assurance personnel and review of procedures and quality assurance record ,
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The applicant's developing program appeared to be generally adequate in providing inspection,. surveillance and audits of radiological controls activities. However, the following item was brought to the applicant's attention:
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Under Subsection 17.2.10, (" Inspection"), of the HCGS-FSAR,
' Department Heads and Nuclear Quality Assurance personnel are responsible for identifying hold points for quality control inspection. Review of radwaste processing, packaging and shipping procedures showed that inspection hold points for critical activities had not been identified. Discussions with gognizant Quality Assurance personnel indicated that the~
. applicant had identified this deficiency and planned to include inspection hold pointssin radwaste procedures in subsequent
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revisions. At the exit interview on November 15, 1985, the e
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inspector stated that radwaste' procedures would be reviewed for identification of critical inspection hold points requiring quality control concurrence during a subsequent inspectio /85-52-39 13.3 Radiological Occurrence Reporting System lhe applicant's development of a program to identify,' notify,
_ investigate and document abnormal radiological occurrences involving potential or actual excessive exposure to radiation and/or radioactive material was reviewed. RP-AP.ZZ-111(Q)," Abnormal Radio 1cgical Occurrence Report System," Revision 0 (October 11, 1984) was reviewed and discussed with cognizant radiation protection personnel. The inspector noted that the procedure contained several incorrect procedure references including the procedures for lost, damaged or offscale personnel dosimetry, monitor alarm response, internal contamination and abnormal external exposures. The applicant indicated that the procedure would be updated to include the correct procedural references in a subsequent revision. The inspector stated that the procedure would be reviewed during a subsequent inspectio /85-52-40 The inspector noted that the procedure contained the following elements needed in a radiological occurrence reporting program:
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_ identification of the cause o'f the occurrence;
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actions taken to correct any deficiencies noted;
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actions planned to prevent future occurrences; and
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documentation for trending and recording purpose The applicant appeared to be_ developing'a generally adequate program to identify, notify, investigate and document abnormal radiological
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occurrence . Exit Interview The inspector met with.the applicant's representatives (denoted in Detail 1) at the conclusion of the inspection on November 15, 198 Additional informal meetings with the applicant's representatives were also held on November 1, and 8, 1985. During these meetings', the
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inspector summarized the purpose anu scope of the inspection and-identified findings as described in this repor At no time during this inspection was written material provided to the applicant by the inspecto No information exempt from disclosure under 10 CFR 2.790 is discussed in this repor .