IR 05000354/1987025

Insp Rept 50-354/87-25 on 870921-25.No Violations Noted. Major Areas Inspected:Organization & Staffing,Mgt Oversight, Training & Qualification,External Exposure Controls,Alara, Internal Exposure Controls & High Radiation Area Controls

ML20236W269
Person / Time
Site:	Hope Creek
Issue date:	11/25/1987
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236W263	List: IR 05000354/1987025 ML20236W261
References
50-354-87-25, NUDOCS 8712070365
Download: ML20236W269 (10)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-354/87-25 Docket No. 50-354 Category C

License No. NPF-50 Priority

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Licensee:

Public Service Electric and Gas Company 80 Park Plaza 17C Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At:

Hope Creek Generating Station Inspection Conducted:

September 21-25, 1987 Inspectors:

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)i 35 99 R. L. Nimitz, Senior Radidtion date Specialist, Approved by:

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M. M. Shanbaky, Chief V

date Facilities Radiation Protection Section Inspection Summary:

Inspection on September 21-25, 1987 Report No.

50-354/87-25 Areas Inspected:

Routine, unannounced inspection of radiological controls during the outage including: organization and staffing; management oversight; training and qualification; external exposure controls; ALARA; internal exposure controls; high radiation area controls; and radioactive and contaminated material controls. The inspection was performed by one region based inspector.

Results: No violations were identified.

A number of areas for improvement were identified.

8712070365 071130 PDR ADOCK 05000354 O

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DETAILS 1.

Individuals Contacted 1.1 Public Service Electric and Gas

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• S. Miltenberger, Vice-President Nuclear Operations r

• S. LaBruna, General Manager - Hope Creek

• J. Lovell, Radiation Protection and Chemistyy Manager - Ucce Creek

• J. Hagan, Maintenance Manager - Hope Creek

• R. Griffiths, Principai QA Engineer

• T. Cellmer, Radiation Protection Engineer - Hope Creek

• D. Mohler, Radiation Protection Engincar - Salem

• J. Clancy, Principal Health Physicist

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1.2 NRC

• R. W. Borchardt, Senior Resident Inspector - Hope Creek D. K. Allsopp, Resident Inspector - Hope Creek

• K. H. Gibson, Resident Inspector - Salem

• denotes those individuals attending the exit meeting on September 25, 1987

i The inspector also contacted other licensee personnel.

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Purpose of Inspection This inspection was a routine unannounced Radiological Controls /

Inspection during the outage. Areas rev Nwed were:

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Organization and Staffing

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Management Oversight

Training and Qualifications V

External Exposure Control v-

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High Radiation Area Controls r

ALARA

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Internal Exposure Controls

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i, Radioactive and Contaminated Materid Controls

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Organization and Staffing

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i The inspector reviewed the organization and staffing of the t9 tion and 6 corporate radiological control organizati n.

The review was $ th respech to criteria contained in applicable tecbaical specifications ynd licensee administrative procedures.

g Evaluationoflicenseeperformanceinthisareawasbasedon'dhv$ssions with personnel, review of documents and observations of organi,te,*.ional performance during the inspectica.

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, Findings i

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s kithin the s' cope of this review, rn viol'atiord were identifiet The licensee's staciornudiological controls organization, unda ihe ( direction of t'.ie Radiat%n ratection and C hmistry Manager is o

nsentially fully 3 staffed,. The station radiological controls,

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prganizatio.1 was augmentis mita trataad and qualified contractor

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personnel to support outage activities.

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, The Corporate Radirttion Pr'otr,tfer( Cervice Group, under the dire /, tion of

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Manager, Radiation Protectier/Mrvices, has several positions remaining

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to be filled.

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The following ma,1!ars were discussed with the licensee:

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3serdt!,ons cturing inspector tours noted that station INiclogicai

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cont als supervisory staff appeared to be ovenxtended as e result ofsu6 anticipate 6 work activities (i.e recirculc. tion purt n el rep'lacerent, unanticipated spills, and retirculath n loop flow sensi g line crec'. repairs).

The licensee was aware of this matter g work t5 minimiz9 its impact on the station and and w k ' priori,*/ @ftM(ogicai co trols for work activitier.,

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,, e individual is,9errentlj act t, ir J.he capacity of Maneger -

'dadi a tion Protection SM ices. 4 pVmnent replacement is to be selected in,the near fut6rtL This tod & 7n has been open for an extended pe-fod of time.(ab'ut ont/yearp.

I rs Six permanent positions 7Nain 'to be filled iir the Radiation

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Protection Services Gim) in the areas of whole body counting, respirator fittin'g and insf ument calibration.

Contractors are currentlyfillingtheposit{; ens, The licensee 7titicipates filling the positio7 with permanent personnel 4 thr/ne w future.

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Management Oversight,

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The inspector review'ed th'e edeqd cy and effectiveness of licensee management oversight of outaga al.thiths h the areas of radiological controls.

Evaluatan of 1.icensee perfo) war e h this area was based on i

observations of.on going activities, di.u:ossions w'th zognizant personnel f

and attendance at r alected treetingt.

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Findings Within the scope of tus review, no violations were 'dentified. The following positive oLstrvations were discussed with licensee management:

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The licensee's Rtalation Protection and Chemistry Manager has

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er,tablished a R7aiolie)ical Controlled Area Tours Program. The program includes a schedu'e whareby designated supervisors are directed to tout t% tt7 tion for purposes of ider.tifying problems,

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T 3dentified concerns are trended and analyzed. Those requiring immediate corrective actions are addressed via established corrective action processes.

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Licensee Radiological Controls supervisory personnel, other than the

individuals assigned to perform tours, were actively involved in y

reviewing on-going work at the work locations (e.g. Drywell)

Licensee management was monitoring adherance to radiological controls practices and procedures. Action is initiated to resolve identified deficiencies.

The following areas for improvement were identified:

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The Corporate Radiation Protection Services Group has in-place a

" Radiation Protection Program Monitoring Program." Assessments are designated as routine (ncn-scheduled) or surveillance (scheduled).

The following weaknesses were identified with this program:

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The program does not provide for transmittal of assessment findings

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to the affected organization in a timely manner.

The prograsu does not provide a mechanism to resolve significant

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concerns (e.g. licensee identified violations) in a timely manner.

The program does not provide adequate administrative controls to

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ensure prouerly qualified individuals performed the assessments.

The licensee is currently revising the program procedure and plans to address the above weaknesses.

The methodology for reviewing radiological occurrence reports was

not established in a manner to allow timely identification of adverse trends.

Several radiological occurrence reports involving personnel from one of the licensee's onsite contractors were identified in a period of about four days.

It was not apparent whether thest occurrence reports were an adverse trend or were isolatcJ concerns.

The licensee immediately initiated a review of th". Identified occurrence reports and the review methodology.

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Training and Qualifications The inspection reviewed the traintog and qualifications of selected Radiological Controls personnel.

T/rphasis was placed on the training and qualification of those individuals providing responsible radiological controls oversight of on-going work activities.

The review was with

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respect to applicable Technical Specifications and licensee procedures.

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The evaluation of licensee performance in this area was based on discussion with personnel, review of in-field performance of personnel and review.of documentation.

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l Findings

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Within the scope of this review, no violations were identified, i

Adequately trained and qualified personnel were overseeing on-going work i

activities. Within the scope of this review, one improvement item was brought to.the. licensee's attention.

Radiological Controls training records'for contractor radiological controls personnel were fragmented and in some instances, incomplete.

The licensee was aware of the. problem and attributed it to the inception of a-new training program for contractor personnel.

The licensee immediately initiated acticn to complete applicable paper work and resolve this concern.

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ALARA The inspector reviewed the implementation and adequacy of the licensee's ALARA program for.the current outage. The review was with respect to cr.iteria contained in' applicable regulatory guides and licensee procedures.. Evaluation of licensee performance was based.on discussions with personnel, review of documentation, observation of in-field work activities, and attendance at selected licensee meetings.

Findings Within the scope of this review, no violations were identified. The following positive observations were made:

Corporate'and station management were aggressively monitoring accumulated exposure. Discussions regarding optimum work. methods and' practices to maintain occupational exposure ALARA routinely occurred at' planning and status meetings. Station department exposure goals were established and aggressively tracked.

The licensee contacted personnel at other similar vintage reactors in order to obtain anticipated primary system dose' rates. These dose rates were used in generating initial outage person-rem goals for purposes of initial ALARA planning and preparation for planned work.- Exposure goals and ALARA estimates were updated when the facility was shut down for the outage and actual surveys were made.

ALARA planning for outage work was aggressive and challenged for improvement by station management. Management support for the station ALARA Program was clearly evident.

The licensee was performing generally adequate oversight of on-going work to ensure work activities are being conducted to maintain personnel exposures as low as reasonably achievable.

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Within the scope of this review, the following items for improvement were

' discussed with. licensee personnel:

The licensee's ALARA program did not provide an' effective method-for

estimatinc actual time to perform work at a job location in the radiological controlled area. Work times were in some instances aggregate estimates of time for passing to/from the job site, supporting the job, and actual performance of-the job. These aggregate estimates resulted in additional ALARA personnel effort to obtain more reasonable efforts for ALARA planning purposes.

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The licensee's program for performing ALARA reviews of on-going work

in order to identify, review and correct (if appropriate) adverse trends was not well defined.

No criteria were in place to provide for expeditious identification of work tasks needing.further review.

The licensee indicated these matters would be reviewed.

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External Exposure Controls The inspector reviewed the following aspects of the licensee's external exposure control program:

issuance and adequacy of radiation work permits including their

implementation; performance, documentation and adequacy.of radiation surveys; a

maintenance of radiation survey records;

use of appropriate, properly calibrated radiation survey

instrumentation; generation and maintenance of external exposure records and/or

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exposure reports.

The review was with respect to applicable regulatory requirements and licensee procedures.

The licensee's performance in this area was based on observation of on-going work activities, review of documentation and discussions with personnel.

Within the scope of this review, no violations were identified.

The following items for improvement were discussed with licensee personnel:

Frequency of radiological surveillance was not clearly specified on radiation work permits.

The licensee immediately revised applicable radiation work permits to clearly define survey frequency.

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Some examples of a need to improve pre-planing of work were identified (i.e. outboard Main Steam Line Isolation Valve work).

Communications on the job were difficult resulting in some work delays at the job site. The licensee immediately initiated action to improve communications.

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Internal Exposure Control Program The inspector reviewed the following aspects of the licensee's internal exposure control program:

performance of appropriate airborne radioactivity surveys; use of engineering controls to minimize airborne radioactivity; adequacy and implementation of the respiratory protection program;

performance of appropriate bioassays; generation and maintenance of internal exposure records and/or reports.

The review was with respect to criteria contained in applicable regulatory requirements and licensee procedures.

The evaluation of the licensee's performance in this area was based on observation of on-going work, review of documentation and discussion with personnel.

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Within the scope of this review, no violations were identified. The following items for improvement were discussed with licensee personnel:

The inspector noted a limited use of breathing zone air samplers by

operators performing valving operations in contaminated areas.

General area air samples were observed to be collected for some of the operations (e.g. Reactor Water Heat Exchanger Isolations). The licensee immediately initiated a review of the acceptability of this practice. The licensee indicated lapel air samples would be considered for use if appropriate.

l Some air samolers being used to collect air samples for on-going work activities were noted to be left running after the work activity ceased.

This practice could result in clean air being sampled causing a subsequent reduction in the calculated values for the actual airborne concentration values encountered by personnel.

The licensee indicated this matter would be reviewed.

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Radioactive Material and Contamination Control Program The inspector reviewed the following aspects of the licensee's radioactive material and contamination control program.

labeling of radioactive material containers and posting of radioactive material storage location; control of contaminated material / areas; personnel work practices in contaminated areas;

personnel frisking practices.

Within the scope of this review, no violations were identified. The following items for improvement were discussed with licensee personnel:

An auxiliary operator by-passed a second (inner) step-off pad when returning from tagging valves in the Outboard Main Steam Line Isolation Valve Area.

The individual removed two sets of protective clothir.g at the outer (final) step-off pad. The licensee issued a radiological occurrence for this event.

Personnel were found to be improperly wearing dosimetry while working inside a contaminated area.

Dosimetry was worn outside protective clothing whereas the practice at the licensee's station is to wear it inside protective clothing.

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individual, improperly wearing dosimetry, was a radiological controls technician.

Contaminated boundary area ropes and ropes for hanging contaminated liquid drip pans were attached to valves.

Drip pans were observed attached to Control Rod Drive Accumulator valves.

The licensee has not yet established a " hot particle" control program (e.g. surveillance procedures).

The licensee indicated the above matters will be reviewed.

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Spills several spills occurred at the facility during the inspection and shortly prior to the inspection. The spills resulted in minor personnel intake of radioactive material, area contamination within the facility, and the expenditure of some personnel exposure to decontaminate the affected areas. The spills were as follows:

Drain valves were left open down stream of A Reactor Water Clean-up Pump. When the system was placed in service with a drain line open

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(September 10,1987) several individuals received intake of radioactive material (maximum about 39 MPC-hours) when the drain system was pressured and blew down to the 145' elevation of the Reactor Building. The licensee was investigating the event during the inspection.

On or about September 24, 1987, the wrong Reactor Water Clean-Up Heat Exchanger was isolated for diaphragm repairs. When the correct heat exchanger was opened, which was not drained, water was

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introduced into the work area. The licensee was investigating the l

incident during the inspection.

On or about September 24, 1987 a drain line down stream of the A Recirculation Pump Isolation valve was drained to the floor of 77'

elevation of the Drywell.

This resulted in contamination of the floor area to levels up to 1000 millirad / hour removable contamination. The area was posted as a High Radiation Area.

Personnel were sent to decontaminate the area which was a previously low contamination area.

Personnel opening the valve believed clean water would come out of the line.

However, the valve was an apparent crud trap.

j The licensee was investigating this event.

The abuve spills were discussed with licensee representatives. The inspector indicated that the spills appear to indicate an apparent need for attention to detail when systems are actually drained and subsequently placed back in service. The licensee acknowledged the inspector's comments and indicated the spills were under review.

11. High Radiation Area Control The inspector reviewed the adequacy and implementation of licensee High Radiation Area Controls. The review was with respect to licensee technical specification requirements and applicable procedures.

Licensee performance in this area was based on observations during plant tours, discussions with personnel and review of documentation.

Within the scope of this review, no violations were identified. The following item for improvement was discussed with licensee personnel:

A radiological controls technician, escorting personnel performing penetration labeling, was observed to leave High Radiation Area Master Keys at the entrance to the cubicle entered. This could result in the keys being removed without the technician's knowledge.

Because the facility was shutdown and has not been operating for an extended period of time, the inspector did not identify any areas of significant exposure dose rates that the keys would grant access to.

The licensee immediately initiated an Radiological Occurrence for this event.

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The inspector indicated high radiaction area access controls will be reviewed during future inspections.

12. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at

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the conclusion of the inspection. The insnector summarized the purpose, scope and findings of the inspection.

No written material was provided to the licensee.

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