IR 05000354/1987027

Radiological Controls Insp Rept 50-354/87-27 on 871116-18 & 20.No Violations Noted.Major Areas Inspected:Process & Area Radiation Monitor Surveillance Testing,Sealed Sources, Radiological Controls for New Fuel Receipt & Insp & ALARA

ML20149D293
Person / Time
Site:	Hope Creek
Issue date:	12/31/1987
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149D291	List: IR 05000354/1987027 ML20149D288
References
50-354-87-27, NUDOCS 8801120262
Download: ML20149D293 (9)

Text

.

.

.

-

-

-

-.

.

.

.o

.

.

-

.

.

!

U. S. NUCLEAR REGULATORY COMMISSION

!

REGION I

I Report No. 50-354/87-27

,

Docket No.

50-354 Category C

{

License No.

NPF-50 Priority

--

Licensee:

Public Service Electric and Gas Company

l 80 Park Plaza, 170

!

Newark, New Jersey 08038 t

Facility Name:

Hope Creek Generating Station

,

Inspection At: Hancocks Bridge, New Jersey

.

Inspection Conducted:

November 16-18 and 20, 1987

!

Inspector:

R L kitM tthcl M R. L. Nimitz, Senior Radiation date

,

Specialist L.!?/,!/'?

Approved By:

y nfes _ \\

J.:

M. M.~5hanbaky,iCnief FacFlities date l

Radiation Protection Section

!

!

Inspection Summary:

Inspection conducted November 16-18 and 20, 1987 BspectionReportNo. 50-354/87-27)

l Areas Reviewed:

The inspection was a routine, unannounced radiological

controls inspection.

The following was reviewed: licensee action on previous i

findings, audits, process and area radiation monitor surveillance testing,

!

sealed sources, radiological controls for new fuel receipt and inspection,

!

post-outage ALARA reviews, and planning and preparation for the refueling outage.

Results:

No violations were identified.

,

I p"manw503s4-DCD

'

_ _. _

._

_.

-.

.

e

.

.

Details 1.

Individuals Contacted 1.1 Public Service Electric'and Gas Company

• S. LaBruna, General Manager

• J. R. Lovell, Radiation Protection / Chemistry Manager

• R. W. Beckwith, Licensing Engineer

• J. Clancy, Principal Health Physicist

• E. Karpe, Senior Radiological Engineer

• E. Galbraith, Chemistry Engineer

• T. Cellmer, Radiation Prtoection Engineer

• J. Molner, Senior Radiation: Protection Supervisor

• J. Hagan, Maintenance Manager 1.2 Nuclear Regulatory Commission

• R. W. Borchardt, Senior Resident Inspector

• J. J. Kottan, Radiation Laboratory Specialist

• A. S. Kirkwood, Radiation Specialist

,.

• Denotes those individuals attending the exit meeting on November 20, 1987.

,

The inspector also contacted other licensee personnel, t

2.0 Purpose of Inspection The purpose of this inspection was to review the following program elements:

Licensee action on orevious findings; Audits;

-

Sealed source receipt, control, accountability and leak checking;

Surveillance of Process and Area Radiation Monitoring Systems; Radiological controls during new fuel receipt; and '

'

ALARA l

'

3.0 Licensee Action on Previous Inspection Findings 3.1 (0 pen) Inspector Follow-up Item (50-354/86-45-07)

This item consisted of six sub-items.

Four of the items were

reviewed and closed during NRC Inspection No. 50-354/87-19.

The following two items were reviewed.

Item 1 (Closed)

~

Licensee to review and evaluete the ability of the "CRCONV" program to determine effluent release-rates and offsite dose rates with

,

appropriate correction factors.

,

-

. -. --

. -,

..

._..

.-

-

-

.

.__

.

.

.

.

.

Findings The licensee performed a detailed evaluation of the program's ability to determine effluent release rates and offsite doses during accident conditions. The licensee selected scveral representative source terms and compared final dose rate estimates using various methodology, including the program CRCONV.

The results using the program CRCONY were acceptable.

Item 2 (0 pen)

Licensee to establish administrative controls to ensure proper placement of the High Range Noble Gas Detectors in their detector shields pending system modifications.

Findings The licensee personnel have not revised applicable Instrument and Controls Procedures to address this matter.

0.2 (Closed)InspectorFollow-upItem(50-354/86-45-06)

This item contained three sub-items.

Two of the items were reviewed and closed during NRC Inspection No. 50-354/87-19. The following remaining item was reviewed:

Item 2 (Closed)

Licensee to establish maximum allowable dose rates for handling of PASS undiluted liquid samples to ensure nmeting GDC-19 criterie.

.

Findings The licensee determined the maximum dose rates which could be encountered and determined that the dose rates would not preclude sample collection, transport and analysis.

Consequently, the licensee concluded that no maximum dose rate criteria was needed.

The licensee plans to incorporate these maximum expected dose rates into personnel training for Emergency Drills.

4.0 Audits The inspector reviewed licensee QA audits with respect to criteria contained in applicable Technical Specification requirements. The principal area of review was the timeliness and adequacy of licensee l

corrective actions for QA identified audit findings.

Evaluation of licensee performance was based on review of Audit NQA 87-0196, Radiation Protection / Chemistry, and review of licensee closecut of the audit findings.

.

_

.

_

.

.

.

.

.

'

,

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

Licensee close out of audit findings was-generally timely and adequate.

5.0 Radiological Controls

.

The inspector toured the plant during the inspection. The following matters were reviewed:

Posting, barricading, and access control (as appropriate) to

,

radiation, high radiation and airborne radioactive material areas; Adequacy and implementation of Radiation Work Permits; Personnel contamination control including frisking; and

Use of properly calibrated radiation survey instrumentation.

Also reviewed was the implementation and adequacy of licensee radiological controls to support new fuel receipt and inspection.

Evaluation of licensee performance in this area was based on observations of on-going work activities and discussions with cognizant personnel.

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

The

.

following matters were discussed with licensee representatives:

.

A continuous air monitor (CAM) was being used by'the licensee to monitor general area airborne radioactivity in the area where new

fuel was being uncrated and inspected.

The inspector found the alarm set about 3-4 times the allowable value specified in Radiolcgica'

Controls Night Orders.

The inspector noted that: 1) the Radiological Controls Procedure for Fuel Inspections required monitoring the fuel inspection and 3)gical controls technicians were

?

checking of the alarm, 2) two radiolo two radiological control supervisory personnel had checked the work activities prior to the inspector. The inspector indicated this finding indicates a lack of attention to detail.

The licensee concurred with the inspector's findings.

The licensee counselled the two technicians and reset the alarm.

The licensee was using a combination of baa-gamma and alpha smear j

surveys to check for contamination of new fuel.

About 10% of all smear surveys were checked for alpha contamination.

The licensee primarily used the beta-gamma smear surveys to check for contamination.

Thelicenseehadnogevaluatedthebeta-gamma

'

contamination limit (1000 dpm/100cm ) to verify its acceptability

- - -

.,.. - -

- - -,

-

,

,

.

-

-

.

.-

-..

.

-.

.

'

.

.

.

for evaluating the extent of alpha contamination.

The licensee initiated a 100% check of smears for alpha contamination and initiated a review of this matter. No significant beta-gamma contamination had been identified.

6.0 Process and Area Radiation Monitor Surveillance The inspector reviewed the implementation of Technical Specification surveillance requirements for the following monitors:

'

Drywell Atmosphere Radioactivity Monitor;

Control Room Intake Airborne Radioactivity Monitor; Control Room Area Radiation Monitor;

Refueling Floor Exhaust Airborne Radioactivity Monitor;

Refueling Floor Area Radiation Monitor; and New Fuel Storage Area Radiation Monitor.

• Items reviewed were establishment and implementation of procedures for

.

channel check, functional tests, calibration and setting of alarm set

!

points.

Evaluation of licensee performance in this area was based on review of procedures, review of completed work history files, discussion with cognizant personnel, and review of Control Room instrumentation.

Findings

,

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

The licensee was implen:enting the Technical Specification surveillance

.

,

requirements for these monitors.

A procedure for performance of

surveillances provided clear guidance to ensure compliance with Technical

Specification monitor alarm set points and operability requirements. A

management control system was in place to identify overdue surveillarces, r

7.0 Sealed Source Receipt, Inventory, Control and Leak Testing

,

The inspector reviewed the program for sealed source receipt, inventory,

control and leak testing.

The review was with-respect to criteria

!

contained in the following;:

{

Technical Specification 3/4.7.6, Sealed Source Contamination; 10 CFR 20.207, Storage and Control of Licensed Material in

'

Unrestricted Areas; Procedure RP-AP.22-029(Q), Rev. 5, Radioactive Material Control;

'

Procedure RP-ST.22-003(Q) Rev. 4, Source Accountability

.

Surveillance;

.-

_

--

.- - _ _

._.

,

_.

-., _

__

_

-

-

.

,

.

Procedure RP-TI-22-18(Q), Rev. 4, Routine Operation of Counter Scalers; Procedure SA-AP.22-046(Q), Rev. 4, Radiological Access Control Program; and Procedure RP-AP.22-014, Rev.1, Training and Qualification Program.

lhe following areas were reviewed:

receipt and control of sources; implementation of source leak check frequencies;

'

adequacy of sample analysis methodologys; training of personnel; disposal of sources; and notifications of source leakage.

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

The licensee was providing effective control of licensed sealed sources.

Properly trained personnel performed source leak testing.

Smear sample counting instrumentation was adequate for its intended purpose

,

One licensee identified violation was reviewed.

This violation involved failure to perform leak tests of four sources at the frequency specified in Technical Specifications.

The inspector reviewed the circumstance surrcunding this matter, the licensee reports made and licensee corrective actions with respect to criteria contained in 10 CFR Part 2 Appendix C, General Statement of Policy and Procedure for NRC Enforcement Actions.

Inspector review indicated the licensee u t the five criteria contained in Appendix C for non-issuance of a violation.

(50-354/87-27-01)

The following matters were discussed with licensee personnel:

i Procedures for source control do not provide guidance for controlling and storing sources in unrestricted areas to ensure compliance with 10 CFR 20,207.

.

Procedures for receipt of sources do not provide clear guidance to individuals receiving sources as to what notifications to make in j

the event package contamination or dose rates exceed the criteria of 10 CFR 20.205.

The licensee immediately initiated a review of these matters.

8.

ALARA The inspector reviewed the implementation and adequacy of the licensee's program to reduce occupational exposure to as low as reasonably achievable ( ALARA).

The review was with respect to criteria contained in the following:

i a

,

.

..

.-

. -. _..

.

,

.

'

.

.

.

10 CFR 20.1, Purpose; Regulatory Guide 8.8, Information Relevant.To Ensuring The

Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Is Reasonably Achievable (ALARA);

Regulatory Guide 8.10, Operating Philosophy For Maintaining

Occupational Radiation Exposures As Low As Is Reasonably

, Achievable; Regulatory Guide 8.19, Occupational Radiation Dose Assessment in Light-Water Reactor Power Plants Design Stage Man-Rem Estimates;"

Vice President Nuclear Procedure VPN-PLP11, Radiation Prntection;

Procedure M12-AP-7, ALARA Program Responsibilities; Procedure SA-AP.22-002(Q), Station Organization and Operating

Practices; Procedure RP-AP.22-002(Q), Radiation Protection Department Organizations; Procedure SA-AP.22-007(Q), ALARA Program;

Procedure GM8-EMP-009, Operational Design Change Control; and

.

"

Procedure ALP-1, Design change ALARA Review Process.

• 8.1 Outage Performance The licensee conducted a surveillance outage in September 1987.

The inspector performed a post-outage review of various work activities that were performed during the outage.

Particular emphasis was placed on review of licensee repair of unanticipated cracking of recirculation pump flow sensing lines.

i Within the scope of this review, no violations or unacceptable conditions were identified.

The following positive observations were noted:

The licensee performed generally effective ALARA reviews of planned work. Accuaulated exposure was tracked and reviewed for adverse trends.

Cognizant personnel performed reviews of on-going work to ensure adherence to ALARA Plans and practices.

The licensee effectively re-prioritized planned work when unanticipatedconditionswereencountered(i.ecracked recirculation pump flow sensing lines).

The licensee's ALARA planning and preparation for repair of the cracked recirculation pump flow sensing lines was commendable.

The following was noted:

engineering controls were effectively used to limit

-

airborne radioactivity;

.

-

a full scale mock-up was constructed of the planned work; system flushing and shielding were performed;

-

'

freeze seals were practiced on the full scale mock-up;

-

video cameras were effectively used to monitor work and

-

train workers.

,

-- -

..

- -

-

-

-

- -.

-

-

-

- - -

-

.

.

..... -

_

-

--

~.

.. _- -

.

-.

. -

---

,

,

.

.

'

,

The licensee generated a Post Outage ALARA Sumary Report.

• This report provides a data base for the work performed and

,

provides suggestion for enhancing ALARA performance during

,

subsequent outages.

i Licensee radiological controls personnel developed a performance improvement summary document.

This document identified areas for enhanced performance in all radiological controls functional areas.

Personnel were assigned action.

i items from this list.

,

The licensee anticipates completion of the enhancement items prior to the start of the first refueling outage.

The following areas for improvement were identified and discussed:-

j The licensee's on-going job review methodology does not

effectively use or monitor person-hour ~ expenditure in.

radiological control areas.

!'

The current program does not appear to clearly identify

non-productive exposure problems (e.g. rework).

!

,

The licensee indicated these matters would be reviewed.

j 8.2 Pre-Outage Planning (Refueling Outege)

The inspector reviewed and discussed licensee planning and preparation for the upcoming refueling outage.

Evaluation of licensee performance was based on discussions with l

cognizant personnel and review of documentation.

.;

The following areas were reviewed and discussed:

organization and staffing,

,

training and qualification of contractor personnel, i

procedures and policies,

!

equipment, material and supplies, i

licensee plans for overseeing on-going work activities,

overtinte,

planning and preparation, I

licensee radiological controls group understanding of work to i

i be performed, radiological controls for movement of irradiated fuel.

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

The licensee was performing generally effective planning and preparation for the refueling outage.

The following positive observations were noted:

.

_ - -

-..

.

._ _

__ _._. -.

-._.

-.-

-

- -

..--

.

.

.

-

e

.

_

.

An Outage Radiological Controls Organization has been

established.

The licensee plans to use indvendent assessors to oversee on-going work.

The licensee developed a Radiological Control Action Item list

to address areas for improvement identified during the September 1987 surveillance outage.

Areas to be shielded in the Drywell have been pre-identified.

• The following areas for improvement were identified:

Al. ARA planning for the outage is behind schedule due in part to the extension of the September 1987 surveillance outage; The licensee is aware of the matter and has initiated action to address it.

The licensee currently does not have a "cattle chute" shield for use in Drywell shielding during fuel movement. The licensee plans to install a chute.

The licensee plans to evaluate the effectiveness cf "cattle chute" shielding prior to allowing personnel to work in the Drywell. This matter was identified by the licensee's collective Radiation Exposure Task Force.

The licensee is aware that very high dose rates could be realized in the Drywell without the use of such a shield.

8.3 New Initiatives The inspector reviewed and discussed major long term initiatives to reduce exposure. The following was noted:

The licensee established a collective radiation exposure reduction task force in January 1987.

The charter of the task force was to develop a performance plan that recommends specific improvements and actions to be taken to reduce collective exposure at Hope Creek. The report of the task force was submitted to the Vice President-Nuclear in April, 1987.

Specific, cost-beneficial recommendations have been incorporated into a schedule for tracking and performance.

The licensee is initiating a program of "Dose Budgeting".

In

such a program, each specific group will have a limited exposure budget to use to perform their yearly tasks.

This program is

'

currently under development and scheduled for testing in 1988 and full implementation in 1989.

9.-

Exit Meeting The inspector met with licensee representatives denoted in Section 1 of this report on November 20, 1987.

The inspector summarized the purpose, scope and findings of the inspection.

No written material was provided i

to the licensee.

'

.

-.

- -

.

--