IR 05000443/1987014

Insp Rept 50-443/87-14 on 870602-05.No Violations Noted. Major Areas Inspected:Status of Occupational Radiological Controls Program,Including Organization & Mgt Control & Training & Qualification

ML20234E700
Person / Time
Site:	Seabrook
Issue date:	06/29/1987
From:	Mcfadden J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20234E630	List: IR 05000443/1987014 ML20234E627
References
50-443-87-14, NUDOCS 8707070652
Download: ML20234E700 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-14 Docket N License No. NPF-56 Category B Licensee: Public Service of New Hampshire P. O. Box 700 Seabrook, New Ham 1 shire 03874 Facility Name: Seabrook Power Station, Unit 1 Inspection At: Seabrook, New Hampshire Inspection Conducted: June 2-5, 1987 Inspectors: ) ed, W n an[ (/2W27 J. McFadden, SenioF Radiation Specialist date

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Approved by: M >

M. Sha6baky, Chi'ef, Facilitifs Radiation I/z9!cf7 date ,

Protection Section j Inspection Summary: l Inspection on June 2-5, 1987 (Inspection Report Number 50-443/87-14). ]

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Areas Inspected: Routire unannounced inspection (zero power license) of the l status of the occupavonal radiological controls program, including: organ- l ization and management controls, training and qualification, external and internal exposure control, control of radioactive materials and contamination, surveys and monitoring and ALAR Results: No violations were identifie I l

8707070652 870630 gDR ADOCK 05000443 PDR l

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DETAILS 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewe .1 Licensee Personnel

• S. Barra11ough, Lead QA Inspector D. Brouillette, Training Instructor-GET S. Buchwald, QA Supervisor ,

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W. Cash, HP Supervisor-0perations E. Darois, Health Physicist-Support

• W. DiProfio, Assistant Station Manager D. Dodge, HP Supervisor-Support

• R. Donald, QA. Auditor

• D. Kochman, Health Physicist-NSG J. Kwasnik, Principal Health Physicist-NSG

• Leland, HP and Chemistry Manager

• A. Maggio, Sr. Engineering Analyst-QA P. Neault, HP Supervisor-Dosimetry A. Parker, QA Ergineer-YAEC

• D. Perkins, Licensing Engineer

• J. Rafalowski, Health Physics Department Supervisor R. Sterritt, ALARA Health Physicist-Operations J. Tarsa, HP Staff Assistant-Support

• W. Temple, Licensing Coordinator P. Upson, Audit and Evaluation Supervisor

• C. Vincent QC Supervisor J. Warnock, Nuclear Quality Manager T. Wheeler, QC inspector

• T., Wiebold, QA Audit Team Leader 1.2 NRC Personnel Atending the Exit Interview ,

A. Cerne, Senior Resident Inspector

• Attended the exit meeting on June 5, 1987.

Additional licensee personnel were contacted or interviewed during this inspectio .0 Purpose The purpose of this inspection was to review the licensee's occupational radiation protection program with respect to the following elements:

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Organization and management controls

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Training and qualification of personnel

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External occupational exposure control and personal dosimetry

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Internal exposure control and assessment

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Control of radioactive materials and contamination, surveys, and monitoring

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Maintaining occupational exposures ALARA 3.0 Organization and Management Controls The licensee's organization and management controls for the radiological protection function were reviewed against criteria contained in:

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Licensee Technical Specification 6.0, Administrative Controls

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Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Reasonably Achievabl The licensee's organization and management controls for the radiological protection function were evaluated against these criteria by the following:

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discussions with licensee representatives  !

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review of records and documentation including:

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Radiation Safety Committee (RSC) meeting minutes

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Radiation Protection Manual and HP Operating Procedures

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QA Audit Plans

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QA Surveillance Checklist / Report forms The HP Department organizational structure and managerial / supervisory personnel have remained unchanged. There has been minimal turnover in ,

the professional / technical and technician positions. The radiation l protection manual and the HP operating procedures have remained substantively unchanged. Numerous minor procedural changes. indicated that the licensee has continued to field test the existing procedures and to incorporate improvement when indicate The minutes of the last RSC meeting (No. 87-01; March 20,1987) plus the minutes of selected previous meetings were reviewed. The minutes continue to routinely address the following topics: safety evaluations, radiological occurrence reports, ALARA updates (design deficiency status, '

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radioactive process system deficiencies, and ALARA recommendations), and general discussion items. Several changes to the RSC charter are being contemplated by the licensee. One significant proposed change is in the composition of the RSC. Presently, the composition of the committee includes the station manager, HP department supervisor, ALARA health physicist, and supervisors from six different functional unit It is proposed to replace these six supervisors with management-level personnel in order to provide for more direct communication of radiological protection activities and issues and for quicker evaluation and response when required. Also, the addition of representatives from corporate health physics, outage planning, and training is being evaluated. The implementation of these licensee-initiated improvements will be reviewed in a future inspectio The next RSC meeting is scheduled to take place before July 198 The inspector reviewed activities of the QA organization in the HP are Approximately one hundred-five QA surveillance had been performed to date since the beginning of 1986. Approximately twenty of these had been conducted in 1987. Each specific surveillance was narrow in scope (for example, limited to the implementation of a specific HP operating procedure). Review of the surveillance titles indicated that all the major areas of occupational radiation protection were being addresse The QC inspector responsible for performing the HP surveillance stated that he had greater than ten years experience in health physics (including five years at operational nuclear power plants and two years at a preoperational nuclear power plant).

The inspector also attended a QA-audit planning meeting between QA personnel and representatives from the HP department. The initial annual audit of the radiation protection program was scheduled to take place the following week. The audit team was to be composed of three auditors (one from an offsite organization) and a QC inspector. Discussions with the team's lead auditor indicated that each team member had been assigned areas to review and that checklists were being developed for each are The audit plan stated that the minimum scope of the audit included

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verification of compliance with the site radiation protection manual, {j technical specifications, final safety analysis report, guides and '

standards on administrative controls, personnel selection criteria, and training of personnel, and industry good practices. A detailed and formalized audit plan and checklists were not available at this time. The finalized audit plan and the audit report will be reviewed in a future inspectio review final audit plan, report and results During March 1987, the corporate health physicist performed an audit of the health physics program. The corporate health physicist stated that his audit, rather than being compliance oriented, focused on current regulatory concerns, technical issues, and industry good practices. One l

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of the findings concerned the composition of the RSC (lack of representatives from training and outage planning) which was addressed earlier in this repor '

Within the scope of this review, no violations were identifie .0 Training and Qualification of personnel  !

The licensee's program for training and qualification of personnel was reviewed against criteria contained in:

• 10 CFR 19.12, Instruction to Workers

• 10 CFR 20.103, Exposure of Individuals to Concentrations of Radio-active Materials in Air in Restricted Areas

• 10 CFR 20.206, Instruction of Personnel

• Licensee Technical Specification 6.0, Administrative Controls The licensee's performance relative to these criteria was determined by:

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receipt of site access training by the inspector

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discussions with licensee personnel

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review of records and documentation The inspector reviewed the status of the qualification cards for several new health physics technicians (operational HP). The licensee steted that it was still their practice to hire only technicians who were fully qualified by experience. The licensee also stated that some HP operations personnel have been assigned to outage HP work at other plants and as a resource to the radiation worker training function in order to maintain readiness for plant startup and commercial operatio Within the scope of this review, no violations were identified.

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5.0 External and Internal Occupational Exposure Control The licensee's program for external and internal occupational exposure control was reviewed against criteria contained in:

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• 10 CFR 20, Standards for Protection Against Radiation l

• Licensee Technical Specifications l

• Licensee radiation protection manual and operational HP procedure .

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discussion with licensee representatives i

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observations by the inspector

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review of records and documentation The inspector reviewed HP control point activities and radiation exposure tracking records. There were three radiation work permits (RWPs) and one standing radiation work permit (SRWP) in effect. The three RWPs had expected termination dates of December 31, 1987. HP operating procedure HD0 958.13, Generation and Control of RWPs and SRWPs, states that RWPs are normally valid until its subject work description is complete. This procedure also requires that RWPs be reviewed at least weekly by HP supervision. This review is to involve checks on radiological conditions from most recent survey data and on current job status. The procedure also includes a mechanism for revising and updating RWPs as conditions warran HP operating procedure HN0960.07, Shield Survey, was reviewed by the inspector. This procedure addressed the performance of neutron and gamma radiation surveys during low power and power ascension testing. The procedure was detailed and agreed with Regulatory Guide 1.68, Initial Test Programs for Water-Cooled Nuclear Power Plant The inspector also reviewed new procedures addressing " incremental neutron dose estimation and tracking" and " radiological guidelines for steam generator entries". Both procedures appeared adequate. The latter procedure requires initial surveys using beta-sensitive survey instruments and a TLD jig. It also includes a worksheet to be used for calculating individual stay time, actual stay times, and accumulated dos The licensee had previously identified potential deficiencies with then-existing access control methods to " locked high radiation areas". Some progress has been made on this concern. More concept designs and design change requests have been submitted. Several design changes have been approved and work is in progress. A licensee representative stated that this concern will receive greater priority as commercial operation approache Within the scope of this review, no violations were identifie .0 Control of Radiocative Materials and Contamination, Surveys, and Monitoring The licensee's program for control of radioactive materials and contam-ination, surveys, and monitoring was reviewed against criteria contained in:

10 CFR 20, Standards for Protection Against Radiation

Licensee Technical Specifications

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Licensee Radiation Protection Manual and HP Operating Procedures

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f The licensee's performance relative to these criteria was determined by:

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discussions with licensee personnel

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review of procedures and documentation i The licensee's program for leak testing sealed sources was reviewe The licensee's Technical Specification 3/4.7.8 (Limiting Condition for Operation) requires that each sealed source containing radioactive material in excess of 100 microcuries of beta and/or gamma emitting material shall. be tested for leakage and/or contamination once per 6 months when in use; stored sources not in use are not required to be tested. The licensee's Technical Specification 3/4.7.8 (Bases) states that sealad sources which are continuously enclosed within a shielded mechani s.n , sealed sources within radiation monitoring devices) are considereu to be stored. Accordingly, the licensee does not leak test sealed sources which are enclosed in installed radiation monitors. The licensee stated that all nonexempt sealed sources (10 CFR 30.18) which are not in storage or continuously enclosed within a shielded mechanism are leak tested. The inspector reviewed the sealed source inventory and leak test records selectively and found no inconsistencies with'the abov The inspector also inquired about the licensee's review, evaluation, and closing actions with regard to NRC Information Notice No. 86-23 which was issued April 9,1986. This notice was titled " Excessive Skin Exposures Due to Contamination with Hot Particles". At the time of this inspection, the licensee demonstrated that a review and evaluation was i underway, but final evaluations and closing actions had not been i completed. The licensee's evaluation and any subsequent actions in response to the following concerns raised in the information notice will l be reviewed in a future inspection:

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particle identifications

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adequate in plant radiological surveillance program l

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potential sources known j

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particle control measures

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to minimize generation

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to minimize translocation j

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work control measures

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to avoid skin contamination with hot partit!es or to minimize duration of contamination

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action to be taken upon identifying a hot particle

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laundry processing and monitoring practices l

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adequacy of monitoring and limits j

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oversight and QC of vendor performance i I

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personnel frisking practices l

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adequacy to detect hot particles j

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at or close to work site j

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dose evaluation ]

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adequate methodology i

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appropriate skin area l

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correction factors for instrument readings l

Within the scope of this review, no violations were identifie '

7.0 Maintaining Occupational Exposures ALARA The licensee's program for maintaining occupational exposures ALARA was reviewed against criteria contained in: l

• 10 CFR 20.1, Purpose ,

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Licensee Radiation Protection Manual and HP Operating Procedures !

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discussions with licensee representatives

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review of documentation As discussed in section 3.0 of this report, the licensee has continued to review design changes for ALARA concern Previously identified and newly identified ALARA action items are being tracked and their status is periodically reviewed by mcnagemen The licensee reported that their person-rem totals were 0.35 for 1986 and 0.25 for the first quarter of 198 Within the scope of this reviu, no violations were identifie .0 Exit Interview The inspector met with the personnel denoted in section 1.0 at the conclusion of the inspection on June 5, 1987. The scope and findings of the inspection were discussed at that tim .

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