IR 05000354/1989005

Insp Rept 50-354/89-05 on 890227-0303.No Violations Noted. Major Areas Inspected:Adequacy,Implementation & Effectiveness of Radiological Controls Program During mid-cycle Outage,Organization,Training & Staffing

ML20247M972
Person / Time
Site:	Hope Creek
Issue date:	03/23/1989
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247M958	List: IR 05000354/1989005 ML20247M952
References
50-354-89-05, 50-354-89-5, NUDOCS 8904060173
Download: ML20247M972 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-354/89-05 Docket No. 50-354 License No.

NPF-57 Priority

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Category C

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Licensee:

Public Service Electric and Gas Company P. O. Box 236 Hancocks Bridge, New Jersey 08038 Facility Name:

Hope Creek Nuclear Generating Station Inspection At:

Hancocks Bridge, New Jersey Inspection Conducted: February 27 - March 3, 1989 Inspector:

$1 kJ M 3lL3}BC1 R. L. Nimitz, Stfnior Radiation Specialist date'

'T[ 3 /ff'f Approved by:

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M. M. Shat 1baky, Chief / Facilities Radiation d6te

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Protection Section Inspection conducted on February 27 - March 3, Inspection Summarf:' 1989 ( NRC Inspection Report No. 50-354/89-05 ).

Areas Inspected:

Routine unannounced inspection of the adequacy, implementation and effectiveness of the Radiological Controls Program during the mid-cycle outage. Areas reviewed included: organization and staffing, training and qualifications of personnel, procedures, audits and assessments, planning and preparation, external and internal exposure controls, radioactive and contaminated material control, ALARA and licensee action on previous NRC findings.

Results:

No violations were identified by the NRC. One licensee identified violation (Failure to implement radiation 3rotection program procedures as was reviewed required by Technical Specification 6.11, Jetails section 7 ) Notice of relative to the 10 CFR Part 2 criteria for non-issuance of a Violation.

Licensee corrective actions fcr this matter were initiated in a timely manner.

No violation is issued relative to this matter, however, long term corrective action will be reviewed during a future ir.spection. Weaknesses were identified in the area of personnel work practices in the radiological controlled area and industrial safety.

8904060173 890327 PDR ADOCK 05000354 Q

PDC

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DETAILS 1.0 Individuals Contacted 1.1 Public Service Electric and Gas Company S. Miltenberger, Vice President and Chief Nuclear Officer S. LaBruna, Vice President - Nuclear Operations

• J. Hagan, General Manager, Hope Creek Operations C. Vondra, Operations Manager

• J. Clancy, RP/ Chem Manager

• T. Cellmer, Radiation Protection Engineer, Hope Creek D. Mohler, RP/ Chem Supervisor

• J. Molner, Senior RP/ Chem Support Supervisor

• M. Simpson, RP Services Engineer

• E. Karpe, Senior RP Supervisor - ALARA

• J. Wray, Radiation Protection Engineer, Salem

• J. Nichols, Technical Manager

• S. Funsten, Maintenance Manager

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• A. Giardino, QA Supervisor i

• R. Griffith, QA Supervisor

• J. Lawrence, Station Licensing Engineer l

1.2 Nuclear Regulatory Commission

• G. Meyer, Senior Resident Inspector, Hope Creek 1.3 Others

• M. Sesok, Atlantic Electric Site Representative Other licensee and contractor personnel were also contacted or interviewed during the course of this inspection.

• Denotes those personnel attending the exit meeting on March 3,1989.

2.0 Purpose and Scope of Inspection

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This inspection was a routine unannounced Radiological Controls Inspectionduringthemid-cycieoutage. Areas reviewed were:

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licensee action on previous NRC findings

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organization and staffing of the radiological controls group

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training and qualification of radiological controls personnel and

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radiation werkers l

planning and preparation for the mid-cycle outage

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procedures

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audits and assessments external and internal exposure controls

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ALARA

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3.0 Licensee Actions on Previous Findi_ng_s 3.1 (Closed) Inspector Follow-up Item (50-354/86-45-02)

Licensee to improve Containment Atmosphere sampling in the areas of provision and use of silver zeolite cartridges for sampling, use of defined sample flow value and provision of lower alarm set points fer sample station area radiation monitors. The improvements, relative to these matters, outlined in the licensee's December 18, 1986.'sponse to NRC Inspection Report 50-354/86-45 were implemented. The inspector noted that the licensee is planning to remove the Containment Atmosphere Post Accident Sampling particulate and iodine sampling capability because it was found not to be needed for core damage assessment. Such removal has been approved by the NRC. This item is closed.

3.2 (Closed) Inspector Follow-up Item (50-354/86-45-07) Licensee to improve Post Accident Effluent monitor calibration procedures to include guidance for detector alignment in order to ensure proper detector placement after calibration. The licensee implemented the improvements outlined in his December 18, 1986 response to NRC Inspection Report 50-354/86-45. This item is closed.

3.3 (Closed) Inspector Follow-up Item (50-354/86-45-09) Licensee to review for improvement the following: the need for a Containment High Range Monitor Alarm response procedure, periodic alarm verification ano the environmental qualification of the Containment High Range Monitor cable.

Review found that an alarm response procedure was developed and implemented, procedures were revised to provide for periodic alarm verification and the environmental qualifications of the cable were adequate (Reference NRC Inspection Report No. 50-354/88-03).

This item is closed.

improve Post Accident Sampling System operation and) Licensee to clarify o (Closed) Inspector Follow-up Item (50-354/86-45-11 3.4 procedures to address reset of elevator power supplies to provide power for sample transport, update of system operating manuals, use of calibration stickers and operation of valve HC-652. The licensee implemented the improvements outlined in his December 18, 1986 letter in response to NRC Inspection Report 50-354/86-45.

This item is closed.

3.5 (Closed) Unresolved Item (50-354/87-19-01) NRC to review licensee High Radiation Area Controls. Two apparent weaknesses involving method of access control and description of area surveillance frequencies were corrected.

This item is closed, i

(Closed Unresolved Item (50-354/88-06-01) NRC to review licensee action on Radiolog)ical Occurrence Reports (RORs) that were not closed and apparently 3.6 documented radiation protection procedure violations. Inspector review indicated the licensee reviewed and implemented corrective actions for the Radiological Occurrence Reports that were previously identified as not closed.

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Review indicated the subject R0Rs were minor skin or clothing contaminations. This item is clesed. Additional discussion regarding the R0R Program is included in section 6 of this report.

4.0 Planning and Preparation for the Mid-cycle Outage The inspector reviewed the licensee's planning and preparation in the area of radiological controls for the mid-cycle outaae.

Evaluation of licensee performance in this area was based on discussions with personnel, review of documentation, and review of on-going work. The following areas were reviewed and discussed with licensee personnel:

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organization and augmentation of the staff to support outage activities;

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assignment of responsibilities and oversight of outage work activities;

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training;

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work scope and work package review by radiological controls personnel; equipment and supplies (e.g., shielding and protective clothing) and

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use of engineering controls to minimize use of respiratory protection equipment;

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ALARA planning and preparation; licensee action on areas for improvement identified by the NRC during

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previous outage reviews; licensee efforts to preclude increased dose rates in the drywell due

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to Zn-65 crud bursts.

The review was with respect to applicable licensee procedures, common industry practices and applicable license conditions.

Within the scope of this review no apparent violations or deficiencies wereidentified.Licenseeplanningandpreparationfortheoutagewasof good quality. No apparent unacceptable conditions or planning oversights were noted.

5.0 Organization, Staffing, Training and Qualifications The inspector reviewed the or anization, staffing, training and qualifications of the radiolo ical controls group, including contractors

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with respect to criteria cont ined in Technical Specification 6.2, Organization, and applicable licensee procedures.

Evaluation of licensee performance in this area was based on discussions with personnel, review of documents, including resumes, and observation of activities.

Within the scope of this review, no violations were identified. The following was noted:

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The licensee recently reorganized the inplant radiological controls organization. The new organization provides for enhanced planning and preparation for outage activitie _-

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An individual was recently assigned as a permanent Radiological

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Operations Supervisor. Inspector review of the individual's qualification documents indicated the individual did not meet minimum experience requirements for the position. Licensee personnel indicated the individual was in training and will not be performing i

supervisory functions in the near future.

The licensee revised qualification paperwork to clarify the individual's actual experience.

Qualification documents identified those duties the individual was qualified to perform.

6.0 ALARA The inspector reviewed selected aspects of the licensee's ALARA Program.

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

Regulatory Guide 8.8, Information Relevant to Ensuring that

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Occupational Exposure at Nuclear Power Stations Will Be As low As Is Reasonably Achievable; Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational

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Radir' ion As Low As is Reasonably Achievable; NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure to

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Radiation As Low As Is Reasonably Achievable;

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NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power Stations; Study on High-Dose Jobs, Radwaste Handling and ALARA Incentives; and applicable licensee procedures.

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

Licensee efforts in the area of ALARA were considered good. The following was noted:

The licensee has permanently af. signed radiation protection personnel

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to the planning department. These individuals assist in work planning in the area of ALARA and intertace with the radiological controls group.

The licensee enhanced ALARA procedures to provide for improved goal

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setting and on-going job review capability. Inspector review indicated the enhancements were effective. Licensee computer capabilities are used for on-going work ALARA tracking in an effectivo manner.

The licensee instituted a number of actions to reduce long-term

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exposure at the station as follows:

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The licensee implemented zinc injection to reduce Co-60 plateout.

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The licensee installed a semi-remote CRD removal and underwater disassembly system.

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The licensee completed an analysis of snubbers for potential removal. Snubber reduction will be initiated in the near future.

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The licentee plans to initiate hydrogen water chemistry control.

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Prelimin&ry testing has been completed.

The licensee installed several television cameras in areas

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routinely entered by operating personnel. The cameras result in

I a reduction in exposure of personnel via fewer personnel entries I

into High Radiation Areas.

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The licensee has purchased state of the art robots to eliminate personnel exposures where possible.

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The licensee is currently developing a cobalt reduction program.

6.0 Audits, Assessments and Corrective Action System The inspector reviewed selected licensee audits and assessments of the Radiation Protection Program. Also reviewed was the licensee's corrective action system in the area of Radiological Occurrence Reports (R0Rs). The review was with respect to criteria contained in Technical Specification 6.5.2.4.3, Audits, and applicable licensee procedures.

Evaluation of licensee performance in this area was based on review of audits performed the past year, review of surveillance performed the past year, review of the most recent INP0 Audit and review of completed RORs.

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

Audits were considered to be thorough relative to verification of procedure compliance.

Audits were noted to review on-going work and were performance-based. Audit findir.; were resolved in an appropriate manner.

The inspector noted some RORs did not indicate if the recommended corrective actions to prevent recurrence had actually been initiated. These RORs were associated with personnel from departments other than the Radiological Controls Department. Licensee personnel indicated that personnel from other departments would be required to return the ROR to the Radiological Controls Department indicating that the action had been taken.

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7.0 External and Internal Exposure Controls The inspector toured the radiological controlled areas of the plant and reviewed the following matters:

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)osting, barricading and access control, as appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas;

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High Radiation Area access point key control;

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control of radioactive and contaminated material;

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personnel adherence to radiation protection procedures, radiation

work permits and good radiological control practices;

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use of personnel contamination control devices; use of dosimetry devices;

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use of engineering controls and respiratory protective equipment;

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records and reports of personnel exposure; and

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adequacy of radiological surveys to support pre-planning of work and on-going work.

The review was with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Protection Against Radiation.

Evaluation of licensee performance in this area was based on review of on-going work.

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

Licensee performance in the above areas was good.

Some workers and radiological controls technicians were observed reaching over contamination control boundaries. The licensee initiated a review of the particular instances identified and counseled personnel where appropriate.

Within t la scope of this review, one licensee identified violation, failure of worke s to adhere to radiation protection procedures as required by Technica Specification 6.11, was identified as follows:

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At about 7:00 p.m. on February 28, two workers, performing Limitorque maintenance on the 100 foot elevation of the Drywell under Radiation Work Permit Number 89-0H-00313 changed thei-work location and worked on a valve that had not been surveyed by radiation protection personnel. The workers apparently thought that they were working on the wrong valve because no power was provided to the motor operator.

The valve the workers moved to (the correct but unsurveyed valve)

exhibited significant removable contamination (140 millirad /hr per surveyed (20,000 dpm/ pared to the actual valve which had been100cm sq 100cm squared) as com protection personnel as the valve to be worked on by the two workers.

As a result, the workers received limited personnel skin contamination and minor intake of airborno radioactive material.

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The inspector noted that Technical Specification 6.11 requires that radiation protection procedures be implemented.

Licensee Radiation Protection Procedure SA-AP.ZZ-024(Q), Revision 5, Radiological Protection Program requires in Figure 1, Responsibilities of Each Individual, Note 20, that Radiation changes in w(RP) personnel be notified when changes oi potential Protection-orking conditions occur that were not previously evaluated by RP personnel. Contrary to this requirement the workers moved from working on a valve which had been surveyed by RP personnel, to another non-surveyed valve without notifying RP personnel.

The inspector reviewed this matter relative to criteria for non-issuance of a Notice of Violation specified in 10CFR Part 2 and concluded that the circumstances surrounding the violation meet the criteria for non-issuance as specified therein.

This matter is considered a licensee identified violation (50-354/89-05-01). The licensee's long term corrective actions to prevent recurrence will be reviewed during a subsequent inspection.

Licensee response to this problem was considered aggressive and timely. The following was noted:

The licensee issued a memorandum to all station personnel

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describing the occurrence and reemphasizing the need to have all areas and equipment properly surveyed.

The ROR for the event was sent to the training group for

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incorporation into access training.

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Th: Licensee initiated a Human Performance Evaluation of the i n;.ident.

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The licensee initiated changes to the routine drywell survey program to ensure more detailed surveys are performed.

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The valve operators which were not labeled clearly were

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properly labeled.

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Action has been taken to decontaminate the valve.

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The workers involved in the incident will be counseled.

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Since the workers received unnecessary exposure working on an abandoned valve operator, the licensee will perform a post job ALARA review of the task performed.

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8.0 Plant Tours The inspector toured the station periodically during the inspection.

The following was noted:

Numerous lights in the drywell were not working making travel to work

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locations difficult. The licensee initiated action to replace the bulbs.

The drywell upper elevations lacked work platforms. Personnel

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traversed the upper elevations by climbing on equipment and piping.

I The licensee was reviewing the status of platforms in the drywell.

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Access to and from the lower elevation of the drywell was via an oily ladder. Personnel were removing protective clothing while standing on the oily ladder. The licensee immediately initiated action to remove the oil spill creating the condition.

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Personnel were found inside the B Steam Jet Air Ejector cubicle on

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an untagged platform which is contrary to standard work practice.

Also one of the three individuals working on the platform and adjacent area did not have a safety line. The licenses initiated an immediate revietf of this matter.

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The licensee could not provide evidence that the drywell evacuation alarms could be heard by personnel throughout the dryweil including under the reactor vessel. The licensee initiated an immediate review of this matter. Audible strength problems were corrected in a timely manner.

9.0 Exit Meeting I

The inspector met with licensee representatives denoted in section 1 of this report on March 3, 1989. The inspector summarized the purpose, scope and findings of the inspection.

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