IR 05000443/1986016

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Insp Rept 50-443/86-16 on 860317-21.No Violation Noted.Major Areas Inspected:Radiation Protection Program,Including Mgt, Training,Internal/External Exposure Control & Dosimetry & Matl & Contamination Control
ML20205N594
Person / Time
Site: Seabrook NextEra Energy icon.png
Issue date: 04/18/1986
From: Mcfadden J, Shanbaky M, Sherbini S, Weadock T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205N582 List:
References
50-443-86-16, NUDOCS 8605020202
Download: ML20205N594 (15)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-16 Docket N _0-443 License N CPPR-135 Priority --

Category C Licensee: Public Service of New Hampshire P.O. Box 700 Seabrook, New Hampshire 03874 Facility Name: Seabrook Power Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: March 17-21, 1986 Inspectors: h /776 Ac h -/[- 8b 64. McFadden, Ra iation Specialist date signed Tl L T. Weadock, Rad aticn Specialist hkl-date signed n&L 6 S.Sherbini,RadfapionSpecialist vhkc date signed Approved by: M 3/ //[///d'[

M. Shanbaky, Ch1Ef [/

Facilities Radiation Protection Section da'te s'igned Inspection Summary: Inspection on March 17-21, 1986 (Inspection Report No. 50-443/86-16).

Areas Inspected: Unannounced preoperational inspection of the radiation protection program including: organization and management controls, training and qualifications, external occupational exposure control and personnel dosimetry, internal exposure control and assessment, control of radioactive materials and contamination, surveys, and monitoring, and maintaining occupational exposures ALARA. Three regionally-based inspectors were onsite for this inspectio Results: No violations were identifie PDR ADOCK 05000443 G PDR .

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DETAILS 1.0 Persons Contacted

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During the course of this preoperational inspection, the following personnel were contacted or interviewe .1 Licensee Personnel

  • W. Cash H. P. Supervisor-Operations B. Clark- H. P. Working Foreman-Operations
  • S. Dodge H. P. Supervisor-Support
  • R. Guillette Assist Constr. QA Manager D. Hadlock H. P. Working Foreman-Support
  • G..Kingston Compliance Manager J. Kwasnik Corporate Principal Health Physicist
  • W. Leland Chemistry and H. P. Manager
  • J. March Start-up QC Manager
  • W. Middleton QA Staff Engineer
  • P. Neault H. P. Supervisor-Dosimetry J. Rafalowski H. P. Department Supervisor
  • R. Sterritt ALARA H. P.-Operations D. Tailleart Training Instructor J. Warnock Nuclear Quality Group Manager N. Wiggin Training Department Manager (non-licensed)
  • Attended the exit interview on March 21, 198 Additional licensee employees were contacted or interviewed during this inspectio .2 NRC Personnel Attending the Exit Interview R. Barkley Resident Inspector A. Cerne Senior Resident Inspector D.~Ruscitto Resident Inspector 2.0 Purpese The purpose of this preoperational inspection was to review the operational readiness of the licensee's radiation protection program with respect to the following elements:
  • organization and management controls;
  • selection, training, and qualification of personnel;

external exposure control and personnel dosimetry;

  • internal exposure control and assessment;

control of radioactive materials and contamination, surveys, and monitoring; and a maintenance of cccupational exposures ALAR .

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3.0- Organization and Management Controls The licensee's organization and management controls for the radiation protection function were reviewed against criteria contained in:

= Seabrook Station Radiation Protection Program Manual

  • Seabrook Station Management Manual; Chapter 3, Station Policies; Section 3.3, Interfaces
  • NHY Nuclear Production Operational QA Program Manua The licensee's performance relative to these criteria was reviewed in discussions with the Health Physics Department Supervisor and his staff and with the Nuclear Quality Group Manage Discussions with the Health Physics Department Supervisor covered his department working relationships / interfaces with the Nuclear Safety Audit and Review Committee (NSARC), the Station Operation Review Committee (SORC), the Radiation Safety Committee (RSC)(ALARA), the Station Manager, the other station departments (especially Training (Non-licensed),

Chemistry (Radiological), Radioactive Waste, and Instrumentation and Control), the Nuclear Services Group (corporate HP presence on-site / inter-face for off-site support), the Nuclear Quality Group, and the Environ-mental Engineering Department (radiation protection, radiological engineer-ing, and environmental laboratory support services) of the-Yankee Ncclear Services Division (YNSD) of the Yankee Atomic Electric Company (YAEC).

The division of responsibilities between the three groups (Operations, Support, and Dosimetry) under the HP Department were also discussed. The HP Department Supervisor stated that all reporting / communication channels, responsibilities and interfaces directly connected to and within his department were established, documented, and implemented except for a few instances which were presently being addressed. He also indicated that his direct communication channel with the Station Manager has been exercised and is effective and that there has been strong management support for the radiation protection functio The HP Department managerial, supervisory, technical, and foreman positions were fully staffed at the time of this inspection. The department's operational staffing plan indicates that nine technicians and an engineering aide (records) are to be added.

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A system for identification and correction of deficiencies was evider.ced by reports generated by Administrative Procedure 2.2, " Radiological Occurrence Reports", in the Radiation Protection Program Manua ,

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The following previous licensee commitments / licensee-identified action items will require further NRC review when the licensee's scheduled implementation dates are reached:

a documentation of the responsibilities and interfaces between the HP, Chemistry (Radiological), Radioactive Waste, and Instrumentation and

, Control Departments

assignment of overall responsibility for the Radiological Environmental Surveillance Program

documentation of the altered line organization above the HP Department to include the Chemistry and Health Physics Manager.

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The Nuclear Services Group's principal health physicist has the respon-sibilities to assist in the appraisal of radiation and contamination control and to evaluate the overall effectiveness of the Radiation Protection Progra During this inspection, a commitment was made by the licensee to further define and document the scope of these respon-

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sibilities for appraisal and evaluation. This area will be reviewed in a future inspection (50-443/86-16-01).

The Nuclear Quality Group manager has developed a five year rolling audit plan. This plan calls for an audit of the Health Physics Department on an annual basis. The Nuclear Production Operational Quality Assurance Program Manual describes a three-level QA system

, including: 1) inspections (tests), 2) surveillances, and 3) an audit and evaluation program to ensure that levels 1 and 2 are functioning properly. Records indicated that approximately 30 HP surveillances had been conducted in 198 .0 Selection, Training, and Qualification The licensee's selection, training, and qualification programs for radiation protection personnel were reviewed against criteria contained in:

= Seabrook Station Radiation Protection Program Manual

  • ANSI /ANS 3.1-1978," American National Standard for Selection and Training of Nuclear Power Plant Personnel".

The licen.ee's performance relative to these criteria was reviewed by discussions with radiation protection and training personnel, review of training materials and facilities, and review of personnel education and experience. This area had also been addressed in previous inspections (50-443/85-28 and 86-08).

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Emphasis during this inspection was placed on the selection criteria for the radiation protection manager and for the radiation protection supervisors in Regulatory Guide 1.8 and ANSI /ANS 3.1-1978 versus the qualifications of Seabrook radiation protection staff. The education and experience of selected radiation protection technicians were also reviewe The following previous licensee commitments / licensee-identified action items will require further NRC review when the licensee's scheduled implementation dates are reache * supplemental HP training program for self-monitoring by operations and chemistry (radiological) personnel has not yet been finalize * level of HP training to be provided to radioactive waste personnel is presently undecided and who will provide this training (Training or HP Department) is undecide .0 External Exposure Control The licensee's external exposure control and personnel dosimetry program was reviewed against criteria contained in:

  • 10 CFR 20, " Standards for Protection Against Radiation"
  • Seabrook Station Radiation Protection Program Manua The licensee's performance relative to these criteria was determined by discussions with members of the radiation protection staff, tours of the facilities, and review of procedures and record .1 Dosimetry Records The record system used to track personnel exposure was inspecte The system is a computer-based one and accepts inputs from both self-reading dosimeter records and TLD monthly reports. The self-reading records reflect daily exposures from entries into the radiation control area. A number of flags are incorporated in the computer program to alert supervisory personnel of exposures approaching administrative limits and of disagreements between TLD and self-reading dosimeter doses. Inputs to the system are supplied by the Dosimetry group and the Health Physics Operations group. The record keeping system is maintained and updated by the Health Physics Support grou .

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5.2 TLD Dosimetry

'The Dosimetry group is one of three groups making up the Health Physics organization. The group supervisors report to the Radiological Protection Manage The qualifications of the supervisory personnel in the Dosimetry group were reviewed. The personnel were found to be well qualified for their assigned function The TLD dosimetry system is a Panasonic system with dosimeters designed for beta, . gamma and neutron whole body monitoring and extremity dosimetr The TLD procedures were reviewed and their adequacy was discussed with the licensee. The inspector identified no deficiencies in the procedures in regard to regulatory compliance but was concerned about the level of detail and clarity. The licensee stated that the procedures have been used in training the dosimetry technicians and were ~ound to be adequate for their purpose The quality assurance program for the TLD system was found to be adequate. However, the inspector noted that there were no provisions for testing new dosimeters to ensure that they contained tha proper phosphors and filters in the proper locations in the dosimeter. The licensee stated that the various steps involved in initial calibration of the dosimeters were adequate to identify dosimeters that do not meet the required specifications. The licensee further stated that the flags designed into the records system will also identify bad dosimeters because they would fail the comparison test with self-reading dosimeter results. The licensee also plans to conduct random sampling of new dosimeters for testing purposes. Finally, the licensee cited the good quality control record of Panasonic Company as further assurance of the negligible probability of receiving an incorrectly manufactured dosimete These conditions appear to adequately ensure that the probability of using an improper lLD in a personnel monitoring situation is very smal Examination of the methods used in beta dose assessment revealed that the methodology used by the licensee is inadequate to quartify beta doses resulting from exposure to fields most likely to be encountered during normal plant operation. The licensee stated that data is available to support the position that their current practice is adequat The data was not available for examination at the time of the inspection and the decision on the adequacy of this current practice must be left until that data is examined. This is an inspector follow-up item (50-443/86-16-02).

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The neutron dosimeters'used by the Dosimetry program were tested in a moderated californium field and their response was adequately quantified. The inspector stated that despite these tests, calibration factors must be derived for the neutron fields that would be encountered in the licensee's facilit The licensee stated that commitments have been made to perform these studies after the reactor reaches the power operation stage. This matter will require further NRC review at start up:

derivation of neutron calibration factors at start u The inspector stated to the licensee that the methods used in dose assessment using TLD readings were not available for inspection in a readily accessible form. The licensee stated that these methods are contained in the computer programs used in TLD dose assessment and in flow diagrams for these programs; furthermore, the licensee has made the commitment, in_ station procedure HD0961.03, "TLD Dose Evalua-tion", to produce a document entitled " Technical Basis for the Personnel Thermoluminescent Oosimetry Program". This document must clearly explain the dose assessment methods, including methods for assigning whole body, eye, and skin doses from gamma, beta, and neutron fields, as well as extremity doses. All parameters and constants used in this process must be clearly documented and justified, as well as methods used in making background corrections and de minimis dose level determinations. This is an inspector follow-up item (50-443/86-16-03).

5.3 Calibration Facility The facility used to calibrate dosimeters and other radiation instruments was inspected. The facility is housed in a concrete structure that is separate from the plant structure Several CS-137 sources are used in two irradiators, and the exposure rates are measured using Shonka-Wycopf chambers. The design of the facility was found to be adequate, and the proper signs and interlocks required for a locked high radiation area were in place. Design and equipment changes are planned to reduce the need for operators to be in the source area during irradiations. Such presence is currently needed to enable reading of instrument dials during calibratio Although the operator in such situations stands behind the source, he will be exposed to some scattered radiation. Reduction or elimination of such exposure is consistent with ALARA philosoph The design and equipment changes in the calibration facility will be reviewed during a future inspectio c

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6.0 Internal Exposure Control and Assessment The. internal exposure control and assessment program was reviewed against criteria contained in:

  • 10 CFR 20, " Standards for Protection Against Radiation"
  • Seabrook Station Radiation Protection Program Manua The licensee's performance relative to these criteria was determined by

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discussions with members of the radiation protection staf This program received only a preliminary review due to time constraints and requires a further detailed NRC revie .1 Administrative Control _s There are procedures in place addressing access control to airborne radiation areas, administrative / control limits for exposure control, posting of airborne radiation areas, and generation, tracking, and maintenance of exposure record .2 Engineering Controls There-is a documented policy to apply engineering controls, whenever possible, to reduce incidence of airborne hazards in order to reduce both the potential for intake and the need for respiratory protective equipmen Further NRC review is required of provisions for evaluating use of engineering controls for specific jobs before authorizing the use of respiratory protective equipment and of design air flows for the

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normal plant ventilation system The radiation protection staff stated that auxiliary ventilation systems for local control of airborne radioactivity were on orde The following require further NRC review:

  • availability of portable ventilation units (PVUs)

= procedures for use and maintenance of PVU .3 Respiratory Protection Equipment The licensee stated that it is intended to establish, implement, and maintain a respiratory protection program which will allow the use of protection factors to limit recorded uptake Procedures are in place which address equipment selection, exposure estimation, fitting of equipment, equipment maintenance and testing, training, issuance records, annual physical requirement, and policy statement on usag .

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The following items were discussed with the licensee and will be reviewed further by the NRC inspectors: I

  • training for the repsir of respirators

conditions under which qualitative fit testing will be substituted for quantitative fit testin *

adequacy of respirator use procedures

availability of a breathing-air system

  • provisions for testing the air quality of supplied-air system and recording result .4 Air Sampling for Assessing Individual Exposure Written procedures for collecting and analysis of air samples and -

for evaluating and recording of data are in place. Calibration procedures for air samplers have been established. The following item was discussed with the licensee and will require further NRC review:

-provision for review and evaluation of air sampling data and MPC-hour calculation .5 Bioassays This area will be reviewed in a future inspectio .0 Control of Radioactive Materials and Contamination, Surveys, and Monitoring 7.1 General Radioactive material and contamination control, and in plant surveys and monitoring programs were reviewed against the requirements of 10 CFR 20.201, " Surveys"; 10 CFR 20.203, " Caution signs, labels, signals and controls"; 10 CFR 20.401, " Records of surveys, radiation monitoring and disposal"; licensee commitments in the FSAR Chapter

. 12; and the criteria in RG's 8.2, 8.7 and Licensee procedures j reviewec included:
  • HD0958.01 Airborne Activity Survey Requirements
  • H00958.02 Radiation and Contamination Survey Techniques
  • HD0958.03 Personnel Survey and Decontamination Techniques
  • HD0958.04 Establishing and Posting Radiologically Controlled Areas
  • H00958.17 Routine Radiological Surveys

HD0963.02 Control and Calibration of Health Physics Instrumentation and Equipment

  • HD0963.08 Calibration of Air Sampling Equipment

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  • HD0963.34 Calibration of PNR-4 Portable Neutron REM Counter
  • HD0963.25 Calibration of the Scintrex Model 189C Emergency Gamma Meter
  • RP Use of Protective Clothing
  • RP RCA Access Requirements
  • RP1 RCA Egress Requirements
  • RP1 Control of Contaminated and Radioactive Material 7.2 Area Radiation and Airborne Radioactivity Monitors The licensee's Radiation Data Management System (RDMS) includes process and effluent radioactivity monitors and samplers, area radiation monitors, and airborne radioactivity monitors. All l monitors are linked via a computer hookup to provide integrated I radiological status and trending information on various display terminals. This system has not been turned over; calibration and

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computer link-up is being performed by the Start-up grou Verification of monitor installation as described in the FSAR could not be performed during this inspection as the containment was sealed for leak-rate testing. Calibration and installation of the RDMS area radiation monitors will be reviewed during a subsequent e inspection:

area radiation monitoring syste .3 Portable Survey, Sampling, and Contamination Monitoring Instruments The licensee's supply of portable survey and sampling instrumentation was reviewed against instrumentation commitments made in Table 12.5-1 of the FSAR. Generally, commitmer+t were achieved and ample instrumentation was available to pro,- a the capability for an adequate radioactivity surveillance progra However, the inspector noted that the following instrumentation was not available on site at the time of this inspection and will be required prior to fuel load to meet FSAR commitments:

  • An additional two continuous air monitors (with particulate, ,

iodine, and noble gas sampling capabilities). '

  • An additional 1300 self-reading dosimeter The licensee was aware of the above outstending instrumentation and indicated that it was on order and would be available prior to fuel load. This will be reviewed in a subsequent inspectio l l

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Table 12.5-1 of the FSAR currently commits to having a minimum quantity of four high-range ion chamber instruments, with a range up to 10,000 R/hr. The licensee currently has two ion-chamber instruments with this range, and owns and proposes to use two GM detectors, with ranges from 0-200 R/ minute, to provide a commensu-rate detection capability in lieu of procuring two additional ion chamber The licensee indicated that a R/ minute scale was more appropriate for the post-accident monitoring situations in which this instrument would be used. The inspector noted two apparent diffi-culties with this proposal:

1) GM detectors have been known to have saturation problems in high dose rate areas, and 2) The 100-200 R/ minute portion of the readout falls in the upper 10% of the instrument's log readout. Therefore, the effective top range of the instrument is 100 R/ minute, or 6000 R/h Adequacy of the licensee's proposal to use GM detectors as a commensurate, high-range monitoring instrument will remain open pending additional investigation in this area:

adequacy of high-range GM detectors 7.4 Protective Clothing and Equipment The inspector reviewed the licensee's capability to provide adequate protective clothing for radiation workers by: Review of purchase orders, Discussion with licensee personnel, Review of applicable procedure The inspector verified that the licensee has adequate procedures in place to effectively control the use of protective clothing. The licensee has currently not placed an order for coveralls ar,d therefore coveralls are not available for use on site; however at the time of this inspection the HP department had recommended a vendor to the station procurement department and was drawing up the purchase order. All other required rubber type protective clothing (gloves, shoecovers, rainsuits, air-fed Hoods) was on ortler or on sit .5 Radioactive Material and Contamination Control The inspector reviewed procedures related to radioactive material (RAM) and contamination control. Procedures setting control limits and defining and controlling the identification and transport of RAM were approved and in place. Signs, barrier ropes, and step-off pads

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i are available for posting conte.minated and controlled areas. At the

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time of this inspection, only the Fuel Handling Building was posted as a controlled area;.the inspector toured this facility and found it to be effectively controlled and poste .6 In plant Surveys and Monitoring The inspector reviewed the Seabrook survey program for compliance with the requirements of 10 CFR 20.201, 20.203, and 20.401; the

criteria of RG 8.2 and ANSI N13.2-1969, and FSAR commitments. The

! licensee program includes routine and special surveys for alpha, beta, gamma and neutron radiations, including the capability and i surveillance and measurements of dose rates, contamination levels, i and airborne particulates, iodines and noble gases. Frequency of surveys generally appeared adequate for controlled areas. The inspector noted, however, that procedure HD0 958.17, Routine

- Radiological Surveys, does not specify the frequency and areas where routine air-sampling will be performed. This is instead described as "sttuational". The procedure also does not indicate whether certain survey frequencies will be modified during outage conditions, for example, increasing contamination survey frequency in the tunne The licensee indicated that specific frequencies for these surveys will eventually be determined by operating history and experienc The licensee intends to do a lot of air-sampling, for example, during startup: sampling results will then be used to develop a reasonable frequenc The licensee intends to evaluate their noble gas sampling technique after startu This matter will receive further NRC review:

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  • evaluation of noble gas sampling technique after startu .0 ALARA 8.1 Design and Equipment Selection The following documents were reviewed to evaluate the licensee's preoperational review of design and equipment selection:

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Design Control Manual,

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( * Selected portions of United Engineers and Constructors L Seabrook Shielding Calibrations, Vol. 1, i

  • Seabrook Station FSAR Chapter 12,

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  • Health Physics Department Pre-turnover System Checklists for the following systems:

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Primary Component Cooling,

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Spent Fuel Cooling and Purificatio Based on the above review, the licensee's review efforts appear consistent with FSAR commitments and USNRC Regulatory Guide guidance. In addition to ALARA incorporation into facility design in the design and construction phases, the licensee's Health Physics department is conducting pre-turnover field reviews of each system with potential exposure implications. The inspector reviewed the evaluation criteria and the completed reviews for several of these walkdowns and found them to be an effective means of identifying potential ALARA concerns. The results of these reviews are currently being organ' zed and Design Change Requests will be initiated as necessar The inspector verified, by review of the current and updated draft versions of the Design Control Manual, that appropriate ALARA review criteria is included in the engineering review of proposed design l changes. A specific procedure, #EN0 820.028, "ALARA Design Input,"

was developed to aid engineering staff in their ALARA revie Proposed design changes also require a final approval by the Station Operation Review Committee, which includes the Health Physics Depart-ment Supervisor as a membe .2 Maintaining Occupational Exposure ALARA The inspector reviewed the licensee's ALARA program including management policy, assignment of responsibilities and authorities, procedures and standards, indoctrination and instruction, and design and equipment selection. Review criteria include the Seabrook FSAR, Chapter 12, Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Station Will Be As low As reasonably Achievaole," and Regulatory Guide 8.10,

" Operating Philosophy for Maintaining Occupational Radiation Exposure As low As Is Reasonably Achievable."

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The following licensee procedures were also reviewed:

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RP 15.1, " Job Preplanning and Review for Radiation Exposure,"

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RP 15.2, " Administrative Processing of ALARA Recommendations,"

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RP 15.3, " Evaluation of ALARA Recommendations,"

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HD0 958.13, " Generation and Control of Radiation Work Permits and Standing Radiation Work Permits,"

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HD0 959.02, " Cost Benefit Analysis of ALARA Recommendations,"

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RP 6.1, " Requesting and Use of Radiation Work Permits and Standing Radiation Work Permits."

-The above procedures are in final form and have received necessary

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reviews. An additional procedure, HD0 959.01, " Radiation Exposure l Performance Assessment," is currently in a draft form. The licen-l see indicated this procedure would be reviewed and approved by April 30, 1986. This will receive further NRC review:

  • procedure for radiation exposure performance assessmen Section 3.3, ALARA Program, of the Seabrook Station Radiation Pro-tection Program Manual (SSRP), includes Station goals and objectives i concerning ALARA and also defines departmental responsibilities. The l Station has developed manrem goals of 70 manrem for an operational year and an additional 200 manrem for outage conditions. These specific goals are planned to be included in the Nuclear Production
Management Manua The licensee's ALARA review and recommendation process, as described in RP 15.1, requires the Job Supervisor to develop the preliminary ALARA review for a job. This review, which details the ALARA controls to be followed during a job, is then reviewed by HP/ALARA staf The inspector noted this system places significant ALARA responsi-bilities on the various Job Supervisors. These Station personnel may require additional Health Physics and ALARA training before they can perform in this role productively. The licensee indicated that a need for additional ALARA training had already been identified for the following groups
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'The licensee indicated that a request for additional funding to provide training for the above groups had been submitted. The performance and effectiveness of this training will be reviewed during a subsequent inspection:

  • additional ALARA trainin The inspector reviewed two procedures controlling the generation and use of Radiation Work Permits (RWPs). During this review, the following concerns were noted:

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Procedure RP 6.1 does not specifically define who may generate an RWP,

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Procedure HD0 958.13 does not require that the controls developed in the ALARA Review be included in or as an attach-ment to the RW The licensee indicated that procedure RP 6.1 would be revised to specify that a Health Physics Technician is responsible for generating an RWP. The licensee also committed to revise procedure HD0 958.13 to require that the ALARA review be incorporated with or

- into the RWP. These commitments will be reviewed during a subsequent inspection (443/86-16-04 and -05).

9.0 Exit Interview The inspectors met with the personnel denoted in section 1.0 at the conclusion of the inspection on March 21, 1986. The scope and findings of the inspection were discussed at that time. At no time during this inspection was written material provided to the licensee by the NRC inspector ,

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