IR 05000387/1982002
| ML20054K868 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/17/1982 |
| From: | Baer R, Dan Collins, Greenman E, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054K866 | List: |
| References | |
| 50-387-82-02, 50-387-82-2, NUDOCS 8207060236 | |
| Download: ML20054K868 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-387/82-02 Docket No.
50-387 License No. CPPR-101 Priority Category B
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Licensee: Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18108 Facility: Susquehanna Steam Electric Station, Units 1 and 2 Inspection At: Berwick, P;cnsylvania Inspection Conducted: harch 1-5, 1982 Inspectors:
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M k b 2-.
R. L. Nimitz, Radiation Specialist date RLI
[-o e 6 k /4lSt R. E. Baer, Radiatfdn Specialist date (,
75, 88
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D. J. Collins, Radiation Specialist date
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Approved by:
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E M Greenm K Chi Facilities Radiation (ate Protection Secti n Technical Program Branch Inspection Summary:
Inspection on March 1-5, 1982 (Report No. 50-387/82-02)
Areas Inspected: Special, a..nounced preoperational inspection of the licensea's radiation protection and radioactive waste management programs including:
organization; persorinel selection, qualification and training; internal and external exposure control; facilities and equipment; and radioactive waste management. The inspection involved 90 inspector-hours on site by three NRC region based inspectors.
Results: No violations were identified.
8207060236 820618 PDR ADOCK 05000387 G
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DETAILS 1.
Persons Contacted
- R. A. Brouse, Senior Analyst, NQA
- M. R. Buring, Health Physics Supervisor F. G. Butler, Instrumentation and Control Supervisor
- T. R. Clymer, Senior Analyst, NQA
- R. E. Doebler, Chemistry Supervisor W. Di Domenico, Instructor F. T. Eisenhuth, Senior Compliance Engineer G. T. Glaser, Assistant Instrumentation and Control Supervisor
- R. M. Harris, Project Licensing Specialist
- J. M. Hettinger, Radioactive Waste Supervisor F. P. Jaeger, Health Physics Foreman
- H. W. Keiser, Station Superintendent
- W. H. Lowthert, Supervisor Technical Training
- M. W. Mianus, Health Physics Specialist
- D. G. Mitchell, Plant Staff-Compliance D. P. Potocik, Radiological Support Supervisor J. B. Rimsky, Senior Results Engineer M. Rochester, Health Physics Specialist - Dosimetry B. J. Ruthoskie, Assistant Foreman Instrumentation and Control D. G. Sutton, Material Supervisor
- R. C. Yoder, Radiological Group Supervisor V. Zukauskas, Assistant Health Physics Foreman USNRC G. G. Rhoads, Resident Inspector
- denotes those present at the exit interview on March 5, 1982 2.
Purpose of Inspection This inspection was performed to determine if the licensee's program ade-quately provides-the health physics staff, training, procedures, facilities, instruments, and equipment, to comply with regulatory requirements and commitments made in the Final Safety Analysis Report (FSAR).
In addition, the inspection was performed to verify that the components of the liquid, solid, and gaseous waste systems are as described in the FSAR, that the licensee has conducted preoperational tests of waste systems to verify their operability and that the licensee's effluent and process monitoring program is adequate and conforms with the FSAR description.
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Because of the status of completion of the licensee's Radiation Protection and Radioactive Waste Programs, a complete preoperational review was not performed at this time. The major findings of this portion of the overall program review requiring resolution are contained in the Annex to this report.
The remainder of the program review will be completed during a subsequent inspection prior to fuel load (50-387/82-02-01).
3.
Radiation Protection Organization The licensee's Radiation Protection Organization was reviewed with respect to the following:
Final Safety Analysis Report (FSAR) Chapter 12, " Radiation Protection"
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FSAR Chapter 13, " Conduct of Operations"
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Regulatory Guide 8.8, Revision 3, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be as Low as Reasonably Achievable" Susquehanna Steam and Electric Station (SSES) Procedure AD-QA-100,
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Revision 0, " Station Organization and Responsibilities," dated August 10, 1981 and Temporary Change No.82-045, dated December 20, 1981 SSES Procedure AD-00-700, Revision 0, " Conduct of Health Physics"
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SSES Station Organization, dated January 4, 1982.
a.
Description The inspector verified that the SSES Radiation Protection Organization was consistent with that described in the licensee's Station Organization Charts dated January 4, 1982. This organization is shown in Figure 1 (see Page 18).
The reporting chain, as shown, reflects the recom-mendation of Regulatory Guide 8.8 that the Radiation Protection Manager (i.e, Health Physics Supervisor) be independent of station divisions such as operations, maintenance or technical support.
The organization currently in place was not consistent with that as described in Procedure AD-QA-100.
In addition, the organization depicted in FSAR Figure 12.5-1, " Health Physics Organization," was not consistent with that of FSAR Figure 13.1-6, " Plant Staff Organization."
Figure 12.5.1 indicated the Health Physics Supervisor reported to the Superintendent of Plant and did not identify, among other positions, the positions of Health Physics Foreman and Assistant Foreman.
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Although Figure 13.1-6 indicated the Health Physics Supervisor reported to the Assistant Superintendant of the Plant, this Organization Chart did not reflect all Specialists positions.
The inspector brought the above matters to the attention of licensee representatives who indicated a FSAR change was to be submitted which would address, among other matters, the Radiation Protection Organization.
In addition, appropriate procedure revisions would be made. These items will be reviewed prior to fuel load to assure current Station Organization is reflected in Station Documents.
(50-387/82-02-02)
b.
Staffing The inspector reviewed the current and proposed, Radiation Protectior.
Organization staffing level.
The following table depicts the FSAR, the current staffing level, and the staffing level indicated by the Health Physics Supervisor that would be needed to support fuel load.
TABLE 1 i
Radiation Protection Organization Staffing Level
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FSAR(I)
Current Level Needed Position Level Level For Fuel Load Deficit (2)
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Engineers
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2 Foremen
2
0 Technicians
8
8 Clerks
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Total ~ 28 Total
(1) FSAR Figure 13.1-6, Revision 18 (2) Deficit = Fuel Load Level minus current Staff Level Based on the above information and discussions with the licensee's
Health Physics Supervisor, the inspector determined that the organiza-tion's current staffing level would be deficient by approximately 14 individuals for fuel load.
The licensee is actively recruiting potential candidates to fill the
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organization vacancies. At the time of the inspection, the licensee's
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Health Physics Supervisor had determined the number of contractor Radiation Protection personnel that would be needed to support fuel load activities.
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Licensee representatives stated that contractor Radiation Protection
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Technicians would be brought on site 30 days prior to fuel load to train and qualify them, in the event sufficient permanent staffing was not on-hand.
The contractor Radiation Protection Technician Training Program is discussed in Section 4.(d) of this report The adequacy of the licensee's Radiation Protection Organization staffing level and training program for contractor personnel brought onsite to augment the staff will be reviewed during a subsequent i
inspection prior to fuel load. (50-387/82-02-03)
c.
Responsibilities and Authorities of Radiation Protection Personnel The licensee has not yet established job position descriptions for all positions in the Radiation Protection Organization. This area will be reviewed during a subsequent inspection prior to fuel load.
(50-387/82-02-04)
4.
Selection, Qualification and Training The inspector reviewed the selection, qualification, and training programs for selected members of the licensee's onsite Radiation Protection Organi-zation. This review included the following:
FSAR Section 12.5, " Health Physics Program"
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FSAR Section 13.1, " Organizational Structures
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FSAR Section 13.2, " Training Program"
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ANSI-N18.1, 1971, " Selection and Training of Nuclear Power Plant
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Personnel",
ANSI /ANS-3.1, 1978, " Selection, Qualification and Training of Personnel
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for Nuclear Power Plants"
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Regulatory Guide 1.8, Revision 1, " Personnel Selection and Training,"
dated September 1975
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SSES Procedure AD-00-011, Revision 0, " Training Organization and Requirements,"- dated July 16, 1979 SSES Procedure AD-00-013, Revision 0, " General Employee Training,"
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dated October 8, 1979
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SSES Procedures AD-QA-115, Revision 0, " Qualification and Training
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of Station Personnel," dated January 26, 1982 SSES Procedure AD-00-700, Revision 0, " Conduct of Health Physics,"
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dated January 26, 1982
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SSES Procedure AD-00-730, Revision 0 " Health Physics Training Programs,"
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dated November 12, 1981 Nuclear Department Instructions (NDI) No. 4.1.2, Revision 0, " Training
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Responsibilities," dated July 1,1981
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NDI No. 4.1.3, Revision 0, " Training Courses and Schedules," dated October 16, 1980
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NDI No. 10.1.7, Revision 0, " Verification of Applicants' Qualification and Experience," dated June 4, 1981
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- Curriculum Committee Report-Health Physics, Revision 1, dated January 28, 1982
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Training Curriculum, Health Physics Section, Susquehanna SES, Revision 0, dated January 15, 1982.
a.
Selection Criteria FSAR Section 13.1.1.1.2, "Preoperational Activities," and Section 12.5.1.4, " Experience and Qualification," provides selection criteria for the Radiation Protection Organization.
NDI-QA-10.8.1. provides minimum qualification levels required for nuclear safety and emergency response personnel.
Procedure AD-QA-115 references the requirements of NDI-QA-10.801.
The inspector verified that the selection criteria for the Health Physics Supervisor was consistent with NRC Regulatory Guide 1.8, and that the Health Physics Supervisor met the criteria.
The review of the selection criteria for the Health Physics Foreman and Assistant Foreman, as presented in FSAR Section 13.1.3.1 and NDI-QA-10.8.1, indicated the criteria of ANSI /ANS-3.1, 1978 was used in selecting personnel for these positions. This standard requires a minimum of four years experience in the craft or discipline supervised.
The inspector's review of the individuals' resumes filling the position indicated they meet the section criteria of the standard.
During the review of the documentation of the Health Physics Foreman's and Assistant Foreman's position descriptions, the inspector noted that no job description had yet been prepared for these positions.
In addition, the review of NDI-QA-10.8.1 indicated that only one year of nuclear power experience and three months onsite were required to enter this position.
This was noted to be contrary to the standard which requires four years experience.
The inspector indicated the area of job descriptions and minimum selection criteria (i.e.,
experience) would be reviewad during a subsequent inspection prior to fuel load (50-387/82-02-05).
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The review of the position of Radiological Support Supervisor indicated this-position was not described in either Section 12.5 or 13.1 of the FSAR but the position was identified in FSAR Figure 13.1-6 and AD-00-700. The position was not identified or described in NDI-QA-10.8.1. A Job Analysis and Description had been established for the position, however the experience requirement in-the job description was not consistent with ANSI /ANS-3.1, 1978 to which licensee is committed.
The job description indicated that three years of the four years minimum experience reouired should be nuclear power station related.
However, the description permitted a maximum of two years of this experience to be related training. Consequently, the job description permitted an individual with only two years of nuclear power station related experience to enter the position.
The review of the resume of the individual filling the position indicated he meet the selection criteria of ANSI /ANS-3.1, 1978.
The area of job description and minimum selection criteria for this position will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-06).
The review of the selection criteria for the position of Health Physics Specialist indicated a minimum of four years of experience in applied radiation protection is needed for entry into the position, however two of the four years experience may be met by related training (FSAR Section 12.5.1.4).
This is inconsistent with ANSI /ANS-3.1, 1978 which requires four years experience. Although the licensee's organization chart identifies the positions of Health Physics Specialist-ALARA (filled), Health Physics Specialist -
Dosimetry (filled), and Health Physics Specialist - Rad Waste /Whole Body Counting / Respiratory Protection (vacant), only one Job Analysis and Description exists for the position of Health Physics Specialist.
The generic job. description does not identify the minimum qualifications to enter the separate positions. Consequently, the job description would not preclude and individual with limited specialty knowledge and experience from entering the specialty positions. The review of the resumes of the individuals filling the position of Health Physics Specialist - ALARA and Dosimetry indicated the individuals meet the minimum selection criteria of ANSI /ANS-3.1, 1978. Job descriptions and minimum selection criteria for these positions will be reviewed prior to fuel load (50-387/82-02-07).
Health Physics Technician selection criteria are not contained in the FSAR. NDI-QA-10.8.1 however, identifies the position of Senior Health Physics Monitor as requiring 3 years of nuclear power plant experience.
This requirement was specified in the job description of a Health Physics Technician Level II. Health Physics Technician Level I job descriptions were also established.
These are entry level positions requiring no previous experience.
The inspector's review indicated 6 of 7 Level II Health Physics Technicians met the
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minimum selection criteria. The experience of the remaining Level II Technician will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-08).
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b.
Training and Qualification The licensee's Health Physics Training Program is desc.ibed in FSAR2 Section 12.5.3.7 and 13.2.1.1.5.
Procedure AD-QA-115 requires that training matrices be used to establish the specific training requirements which are defined in NDI-QA-10.8.1.
- The licensee issued a Health Physics Curriculum Committee Report to present the Training Curriculum and provide appropriate explanations of the curriculum for each job position in the Health Physics Section.
A training matrix was established for the Health Physics Section.
Included in the training requirements are Health Physics Technician Phase I Training (Theory) and Health Physics Technician Phase II Training (Hands On). The licensee's Phase I Training used approved procedures and lesson plans.
The Phase I training duration was indicated to be approximately six months.
Regarding Phase II, the hands on program is to be described by Procedure HP-TP-501. The inspector noted that procedure was in draft and the Phase II program remains to be fully established.
Licensee representatives indicated that a Phase II Health Physics Technician Training Program would be fully established and current Level II Health Physics Technicians would be qualified in the Phase II Program by fuel load. The extent of training provided the Susquehana Steam and Electric Station Health Physics Section and the status of Phase II Health Physics Training will be review'ed during a subsequent inspection prior to fuel load (50-387/82-02-09).
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General Employee Training Licensee procedure AD-00-730 describes the General Employee Health Physics Training Program. The procedure provides for three levels of Health Physics Training. The purpose, prerequisites, requirements and other course information is provided in NTI-3220.
Inspector review of major topics presented, as described in AD-00-730, indicated the training meet the requirements of 10 CFR 19.12.
Inspector discussions with the licensee's Supervisor Technical Training indicated that all appropriate personnel have not received General Employee training but would be trained prior to fuel load.
The General Employee Health Physics Training Lesson Plans and the extent of training provided will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-10).
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Contractor Health Physics Technician Training At the time of this inspection no contractor Health Physics Technician Training Program had been established and implemented.
Inspector discussions with licensee. representatives indicated that a contractor Health Physics Technician Training Program would be esta-blished and implemented within 30 days ofs fuel load.
This training program will be used to train and qualify those technicians brought on site to augment the licensee Radiation Protection Staff.
The Contractor Health Physics Tech'nican Training Program will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-11).
5.
Exposure Control
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The inspectors reviewed the licensee's Exposure Control Program with respect to the following:
Final Safety Analysis Report (FSAR), Chapter 12, " Radiation Protection"
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N10 CFR 20, " Standards of Protection Against Radiation" Regulatory Guide 8.2, "Administr$tive Practices in Radiation Monitoring"
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Regulatory Guide 8.4, " Direct Reading and Indirect Reading Pocket
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Dosimeters"
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Regulatory Guide 8.7, " Occupational Radiation Exposure Records
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System" Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and
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i Assumptions for a Bioassay Program" R'egulatory Guide 8.13, " Instructions Concerning Prenatal Radiation
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Exposure" Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection"
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Regulatory Guide 8.26, " Application of Bioassay for Fission and
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Activation Products" NUREG-0041, " Manual of Respiratory Protection Against Airborne
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Radioactive Materials" ANSI-N343-1978, "American National Standard for Internal Dosimetry
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for Mixed Fission and Activation Products."
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a.
External Exposure Control The licensee has established the following procedures and instructions for external exposure control:
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SSES Procedure AD-00-735, Revision 0, " External Dosimetry Program," Dated December 21, 1981
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SSES Procedure HP-TP-210, Revision 0, "Use of Self-Reading Dosimeters," dated June 10, 1980
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SSES Procedure HP-TP-213, Revision 0, " Direct Reading Dosimeter Calibration Response,. Drift Check and Leak Checking," dated February 10, 1982
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SSES Procedure HP-TY-001, Revision 1, " Issuance, Use and Evaluation l
of Dosimetry Required for Personnel Approved to Use NRC Licensed Materials," dated October 8, 1981
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NDI 6.4.1, Revision 0, "Susquehanna Radiation Protection Program -
General," dated November 9, 1981 l
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NDI 6.4.3, Revision 0, " Personnel Radiation Exposure Policy,"
dated December 21, 1981
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NDI 6.4.4, Revision 0, " Pre-Natal Radiation Exposure Policy,"
June 15, 1981.
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FSAR Section 12.5.3.6 provides details of the licensee's Personnel Exposure Monitoring Program. The FSAR states that routine personnel dosimetry required will include Beta / Gamma / Neutron Thermoluminescent Dosimeters (TLD) and/or film badges as dosimetry of record. The TLD or film badges will be processed monthly, and may be processed more often if necessary.
Extremity monitoring TLDs or film badges are to be worn when appropriate.
Self-reading pocket dosimeters will be worn to indicate current exposure status between processing of TLDs or film badges.
The review of the External Dosimetry Program indicated that a.TLD processing system had been installed in the Training Facility complex.
Initial calibration of the system had not been accomplished at the time of inspection.
No procedures directly associated with the TLD system had been approved for use.
Inspector discussions with licensee representatives regarding the-above, indicated that the in-house TLD Program was not anticipated to be fully established by fuel load and that a vendor would supply dosimetry services.
The status and development of the licensee's Dosimetry Program and nyersight of vendor sxaplied dosimetry services (if needed) 'will be reviewed during a subsequent inspection prior to fuel load (50-307/82-02-12).
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b.
Internal Exposure Control The licensee has established the following procedures and instructions for internal exposure control:
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SSES Procedure AD-00-715, Revision 0, " Airborne Radioactive Material Concentration Sampling Program, Evaluation and Record Keeping," dated December 7, 1981
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SSES Procedure AD-00-720, Revision 0, " Contamination Control,"
dated January 13, 1982
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SSES Procedure HP-TP-720, Revision 1, " Airborne Concentration Sampling and Evaluation," dated February 13, 1981
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SSES Procedure HP-TY-003, Revision 0, " Radioactive Materials Area Air Flow Verification," dated May 28, 1980
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SSES Procedure HP-TY-005, Revision 1, " Temporary Bioassey Program," dated March 19, 1981.
The licensee's bioassay program is described in FSAR Section 12.5.
The licensee has obtained a shadow-shielded NaI whole body counter for performing in-vivo bioassays. At the time of this inspection, no procedures were established for the system. The counter had been calibrated by the vendor, however the licensee had not received calibration data for the system nor certification of the traceability of sources used for the calibration.
The licensee's temporary bioassay procedure (HP-TY-005) states that in the case of a' suspected or confirmed intake of radioactive material in excess of 40 MPC-hours in-vivo analysis will be performed whenever practicable. This was noted to be inconsistent with 10 CFR 20.103 which requires an evaluation of exposures in excess of 40 MPC-hours and action taken to prevent recurrence.
Regarding in-vitro bioassays (i.e., urine and fecal analysis),
procedure HP-TY-005 indicates that if in-vivo analysis is unfeasible, urine and/or fecal sampling will be performed. No procedures providing action levels requiring this sampling, sample collection, handling, transport, or sample analysis data evaluation procedures were esta-blished.
Because the licensee remains to fully establish and implement an Internal Exposure Control Program, the inspector indicated this area will be reviewed during a subsequent inspection' prior to fuel load.
(50-387/ 82-02-13).
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c.
Respiratory Protection The licensee has established the following procedures and instructions-for respiratory protection:
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. NDI 6.4.5, Revision 0, " Respiratory Protection Program," dated -
May 26, 1981 SSES Procedure AD-00-725, Revision 0, " Respiratory Protection
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Program," dated December 16, 1981
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SSES Procedure HP-TP-634, Revision 0, " Respiratory Protection Device Surveys, Care and Maintenance," dated November 27, 1981
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SSES Procedure HP-TP-750, Revision 0, " Description and Selection of Respiratory Protection Equipment," dated December 28, 1981
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SSES Procedure HP-TP-761, Revision 0, " Issuance, Use and Return of Respirators," dated July 21, 1981 SSES Procedure HP-TP-762, Revision 0, " Operation and Calibration
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of the Frontier Enterprises Model FE-560A Nacl Aerosal_ Test System" SSES Procedure HP-TY-017, Revision 1, "SCBA Inspection," dated
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February 19, 1982.
The inspector review of this area indicated that although NDI No.
6.4.5 requires that respirable air of Grade D quality be used for breathing purposes, the inspectors were unable to identify station procedures which implemented the NDI and required the evaluation of breathing air to ensure it meet Grade D specifications prior to use.
In addition, no procedure was identified specifing the test requirements for Grade D breathing air.
The inspector indicated this will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-14).
d.
Dosimetry Insuance, Exposure Records and Reports The licensee has established the_following procedures for dosimetry issuance, exposure records and reports:
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NDI 6.4.3, Revision 0, " Personnel Radiation Exposure Policy,"
dated December 21, 1981
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NDI 6.4.5, Revision 0, " Respiratory Protection Program," dated l
May 26, 1981
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SSE3 Procedure AD-00-700, Revision 0, " Conduct of Health Physics,"
dated January 26, 1982
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SSES Procedure AD-00-735, Revision 0, " External Dosimetry Program," dated December 16, 1981 SSES Procedure AD-QA-425, Revision 0, " Station Respiratory
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Requirements," dated October 29, 1981
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SSES Procedure HP-TP-217, Revision 0, " Exposure Records,"
dated February 17, 1982
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SSES Procedure HP-TY-001, Revision 1, " Issuance, Use and Evaluation of Dosimetry Required for Personnel Approved to Use NRC Licensed Materials," dated October 8, 1981.
The review of the above procedures indicated the procedures provided for maintenance of exposure records and reporting in accordance with 10 CFR 19 and 10 CFR 20.
The review of HP-TY-001 indicated the procedure was a temporary pro-cedure which delineates the requirements for the issuance and use of personnel dosimetry prior to fuel load. At fuel load, this procedure is apparently to be replaced by procedure HP-TP-215 which remains to be established.
Regarding procedure HP-TY-001, the procedure provides no guidance for dosimeter placement for monitoring of beta radiation fields and monitoring exposure to noble gas atmospheres.
These matters and HP-TP-215 will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-15).
6.
Facilities and Equipment The inspectors reviewed the licensee's onsite Radiation Protection Facilities with respect to that described in Final Safety Analysis Report Section 12.5, " Health Physics Program."
a.
Facilities The review of this area indicated the license is currently in the process of constructing additional Radiation Protection Facilities.
Consequently a complete facility review was not possible.
The review of the Radiation Protection Office and Decontamination Room (elevation 691') indicated they were as described in the FSAR.
The inspector noted that the room designated as the Clean Laundry is being used as a sample counting room. One wall of this room is part of the Turbine Building. The adequacy of current shielding should be reviewed. The room that was to be used for Emergency Equipment
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storage was being used as the Health Physics Foreman's office while the laundry storage and issue area was being used for Emergency Equipment storage. The Chemistry Area was as described in the FSAR.
The facilities under' construction will be reviewed during a' subsequent inspection prior to fuel load (50-387/ 82-02-16).
b.
Equipment 1)
Portable Equipment The inspector performed a limited review of portable equipment.
The inspector's review of portable radiation detection instruments at the station indicated the instruments were calibrated by a vendor.
Calibration certificates supplied by the vendor provided the calibration accuracy and traceability of sources. However, no license Quality Assurance Program had been established or-implemented for oversight of the vendor calibrations.
Regarding air sampling equipment, the licensee has available 9 high volume and over 50 low volume air samplers. About 40 of the low volume air samplers are capable of detecting radioactive-iodine deposited within a removable charcoal cartridge.
The charcoal cartridge must be removed and taken to the health physics counting room for analysis.
The inspector noted that the licensee had not developed a procedure for handling or counting charcoal canisters or cartridges.or silver zeolite cartridges under routine or emergency conditions. Silver zeolite cartridges are addressed in procedure AD-00-715 but no Health Physics Implementing procedure addresses the usage of this cartridge.
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The above matters will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-17).
A licensee representative stated that six Eberline AMS-3 units were available and had been rodified by the licensee to incorporate a charcoal cartridge. This modification or the use of a charcoal cartridge is not addressed in procedure HP-TP-272 "Use and Operation of the AMS-3."
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The above matters and the number of portable instrumentation available will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-18).
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2).
Fixed Equipment The licensee had three Nuclear Measurements Corporation Abb331F continuous air monitors capable of detecting particulate, iodine, and gaseous radioactivity.
These units were not operational at the time of this inspection.
A procedure HP-TP-233, " Operations of NMC Continuous Air Monitor, Model AM-331F," was available for review and states these units will be used for trend analysis only. They are not hard-wired to the Main Control Room and provide for a local alarm only.
Procedures for the calibration, calibration frequency or establish-ment of alarm points had not been developed. The licensee's fixed equipment will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-19).
7.
Radioactive Waste Management The inspectors reviewed selected portions of the licensee's Radioactive Waste Management Program with respect to: SSES FSAR Chapter 11, " Radioactive Waste Management;" Chapter 12, " Radiation Protection;" Chapter 13,
" Conduct of Operations;" and Chapter 14, " Initial Tests Program."
Documents Reviewed
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NDI QA 6.5.1, Revision 0, "Radwaste Program," dated November 9, 1981
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SSES Procedure AD-QA-100, Revision 0, " Station Organization and Responsibilities," dated October 10, 1981 and Temporary Change No.82-045, dated December 20, 1981
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SSES Procedure AD-QA-111, Revision 0, "Radwaste Management Program,"
dated January 30, 1982
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SSES Protsdure AD-QA-305, Revision 0, " Rad Waste Process," dated January 30, 1982 and Temporary Change No.82-043 dated February 20, 1982.
a.
Program Responsibility The responsibilities for implementing various aspects of the Radioactive Waste Management Program is described by procedures.
Recent procedure revisions were made to ensure consistency of assigned responsibilities.
The Rad Waste Supervisor is assigned the responsibility for the safe and efficient management of Rad Waste Facility operation including operation of the Liquid, Solid and Gaseous Waste Treatment System.
The Health Physics Section is responsibile for safe transfer, storage, transport, and shipment of radioactive material.
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At the time of this in;pection, the Health Physics position responsible for these activities (i.e., Health Physics Specialist - Rad Waste /
Whole Body Counting / Respiratory Protection) was vacant.
Regarding Rad Waste Facility operations, at the time of this inspection, the licensee had not yet decided on a staffing plan for the Rad Waste Facility. The Rad Waste Supervisor had no assigned staff.
The inspector indicated the Rad Waste Facility staffing and Health Physics Section Rad Waste responsibilities will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-20).
b.
Inspection and Enforcement Bulletin No. 80-10 The inspector reviewed the extent of licensee implementation of IE Bulletin No. 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release to the Environment." The licensee received the bulletin (for information)
in a letter dated May 6, 1980.
The inspector discussions with the licensee's Chemistry Supervisor indicated the review of plant design, systems, and operating procedures to identity those systems considered nonradioactive but could possibly become radioactive through interfaces with radioactive systems had not been performed at the time of this inspection. There were no monitoring, sampling schedules or procedures developed to provide a means for monitoring potentially contaminated effluent release paths.
Based on the above discussion, the inspector determined that the licensee has not implemented the bulletin requirements.
The inspector indicated this area will be reviewed during a subsequent inspection prict to fuel load (50-387/82-02-21).
c.
Effluent Monitoring Instrumentation Control The review of effluent monitoring instrumentation indicated all FSAR described effluent monitoring instrumentation was installed.
The inspector's review indicated however that the monitors remained to be " turned over" to the licensee, calibrated, and sample collection efficiencies evaluated.
The inspector indicated the area of effluent monitoring instrumentation calibra?. ion and collection efficiency determinations will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-22).
Regarding control of effluent releases, this portion of licensee's program was not reviewed and will be reviewed during a subsequent inspection prior to fuel load (50-387/82-02-23).
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17-8.
Exit Interview The inspectors met with licensee representatives (denoted in Section 1)
at.the conclusion of_the inspection.
The inspector summarized the purpose, scope, and findings of the inspection.
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l-Figura 1
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SUSQUEHANNA STEAM AND ELECTRIC STATION RADIATION PROTECTION ORGANIZATION
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SUPERIhTENDENT OF PLANT
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H.P. 50RIMAN RADIOLOGICAL
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H.P. SPECIALIST ALARA D051MITRT Rur.1C/ RESP. Pa0TECTION HEALTH PHYSICS
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TECHNICIAN !!
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I TECHNICAL RECORDS HfALill PHYSICS INPL*T OPERATOR TECHNICIAN 1 I
HEALTil PHYSICS
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TECICflCI AN 11
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Annex to NRC Region I Inspection Report 50-387/82-02 Susquehanna Steam and Electric Station Pre-Operational Inspection (Radiation Protection / radioactive Waste)
The initial site visit identified the following matters which should be addressed by the licensee prior to fuel load.
A.
Radiation Protection Organization The review of this area identified the following:
The current Radiation Protection Organization is not as described in
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the FSAR or approved station documents.
(Section 3.a)
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The current Radiation Protection Organization staffing level is not adequate to support fuel load.
(Section 3.b)
B.
Selection, Qualification and Training The review of this area identified the following:
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Job / position description have-not been established for all positions in the Radiation Protection Organization.
In addition, the selection-criteria for certain positions is not consistent with industry standards.
(Section 4.a)
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Several positions in the Radiation Protection Organization are described by generic job descriptions.
(Section 4.a)
The current permanent Radiation Protection Technician Training Program
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is not fully established.
(Section 4.b)
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The Contractor Radiation Protection Technician Selection, Training and Qualification Program is not fully established.
(Section 4.d)
C.
Exposure Control j
The review of this area identified the following:
1.
External Exposure Control l
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The Permanent External Exposure Monitoring Program is not fully established.
(Section 5.a)
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2.
Internal Exposure Control
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The Internal Exposure Control Program is not fully established.
(Section 5.b)
3.
Respiratory Protection Program
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No implementing procedures were in place to ensure use of minimum grade breathing air.
(Section 4.c)
4.
Exposure Records
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The permanent dosimetry issuance and use procedures have not been established.
(Section 4.d)
D.
Facilities and Equipment The review of this area identified the following:
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No Quality Assurance Program has been established for vendor calibrations of portable radiation survey instruments.
(Section 6.b.1)
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No implementing procedures have been established for handling and analysis of charcoal or silver zeolite cartridges.
(Section 6.b.1)
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Procedures for calibration and alarm point setting have not been established for all continuous air monitors (CAMS).
In addition, several CAMS were modified and appropriate procedure changes were not made to reflect the changes.
(Section 6.b.2).
E.
Radioactive Waste Management The review of this area identified the following:
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The staffing plan for Radioactive Waste Facility was not established.
(Section 7.a)
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The Radiation Protection Organization position responsible for radio-active waste transfer, storage and transport was vacant.
(Section 7.a)
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The requirements of IE Bulletin 80-10 were not implemented.
(Section 7.b)
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All effluent monitoring instrumentation had not been turned over, calibrated or appropriate sample collection efficiencies determined.
(Section 7.c)
]
e.