ML18078A914
| ML18078A914 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 01/23/1979 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18078A913 | List: |
| References | |
| NUDOCS 7903070130 | |
| Download: ML18078A914 (6) | |
Text
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derick W. Schneider Public Service Electric and Gas ComRany 80 Park Place Newark, N.J. 07101 201/430-7373 Vice President
. Production Mr. Boyce H. Grier Director of USNRC January 23, 1979 Office of Inspection and Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Grier:
NRC INSPECTION REPORT 50-272/78-30 INSPECTION DATE DECEMBER 12-15, 1978 UNIT NO. l SALEM GENERATING STATION We have reviewed the report of your inspection transmitted with your letter dated January 2, *1979, which was received on Janu-ary 5, 1979.
The following information is provided as a response to your report:
Item A, Infraction:
- 10. CFR 50.59, "Changes, tests and experi-ments," states in part, "The holder of a license authorizing operation of a production or utilization facility may~.* make changes in the facility as described in the safety analysis report.*. without prior Commission approval, unless the proposed change...
involves a change in the technical specifi-cations incorporated in the license or an unreviewed safety question...
The licensee shall maintain records of changes in the facility.*. to the extent that such changes
- constitute changes in the facility as des-cribed in the safety analysis report...
These records shall include a written safety evaluation which provides the basis for the determination that the change *.. does not involve an unreviewed safety question."
790307013o
. ~*
Boyce H. Grier 2 -
1-23-79 Contrary to this requirement, on about August 2, 1978, the Liquid Waste Disposal System (a system described in the Final Safety Analysis Report) was changed, in that Valve Nos. 1WL79 and 1WL84 were modified in order to provide hose connections to an ancillary system.
The modification of Valve No. 1WL84 and 1WL79 changed the mode of operation as described by the Final Safety Analysis Report, but a safety evaluation providing the basis for the deter-mination that the change did not involve an unreviewed safety question was not performed.
Our r~sponse to Item "A" is:
- 1.
The modifications to the liquid waste disposal system (see ) were made to maintain radioactive waste ef-fluent release to the environment as low as practicable.
These modifications were made about August 2, 1978, as a temporary emergency change which was considered to be in the best interest of the public.
Based on this consideration it was improperly assumed that a safety evaluation was not required prior to implementation of this modification.
On-August 2, -1978, this system modification was deter-mined to be no longer temporary and the safety evaluation required by. 10CFR 50.59 was requested in accordance with station admin_istrative procedure, APB, "Design Change, Test and Experiment".
At the time of NRC Inspection 50~272/78-30 this safety evaluation had not been received at the station and the system as modified was still in use.
The required safety analysis has since been received and reviewed by the station and all procedures required for operation of the liquid waste disposal system as modified have been reviewed, revised where required, and implemented.
- 2.
We are now in compliance.
Future items of non-compliance will be prevented because the management personnel respon-sible are now aware that no exception can be made for tem-porary or emergency modifications under 10CFR 50.59.
Boyce H. Grier 3 -
1-23-79 Item B, Infraction:
10 CFR 20.103, "Exposure of individuals to concentrations of radioactive material in air in restricted areas," states in part, "No licensee shall possess, use, or transfer licensed material in such a manner as to permit any indi-vidual in a restricted area to inhale a quantity of radio-active material in any period of one calendar quarter greater than the quantity which would result from inhala-tion for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concen-trations of radioactive material in air specified in Ap-pendix B, Table 1, Column 1... For purposes of d'etermin-ing compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evalua-ting airborrie radioactivity in restricted areas."
Contrary to this requirement, on December 14, 1978, a compactor operator working in accordance with Extended Radiation Exposure Permit 2E25, was subject to exposure to radioactive material in air without suitable measure-ments of the concentrations of radioactive material in air having been performed to detect and evaluate the air-borne radioactivity in the restricted area.
Our response to Item B is:
- 1.
The personnel performing the compacting were wearing respi-rators but did not realize an air survey was also required.
- 2.
To correct the situation all compacting was stopped until an air sample was taken, measured, and analyzed.
The radioactive waste compacting operation was being per-formed under an Extended Radiation Exposure Permit (EREP).
An EREP is authorized for use by Administrative Procedure 24, "for a specific area, and for a job of a repetitive nature in an area where radiologically conditions are not likely to change abruptly", and does not require notifica-tion of the Health Physics/Chemistry Group prior to enter-ing the designated area.
We have since determined that compacting of solid radio-active waste is not within the intended scope of an EREP.
All future radioactive waste compacting shall be performed using a Radiation Exposure Permit (REP).
We are now in compliance and the use of the REP's administrative controls, which insures that the appropriate radioactivity measure-ments are taken each time compacting operations are per-formed, will prevent future items of non-compliance.
Boyce H. Grier 4 -
Item c, Deficiency:
Technical Specification 6.8, "Procedures,"
states in Section 6.8.1, "Written procedures shall be established, implemented, and main-tained covering the activities referenced.**
[in] the applicable procedures recommended in Appendix 'A' of Regulatory Guide 1.33, November, 1972."
Regulatory Guide 1.33, 1-23-79 November 1972, Appendix 'A', Section G.2.b*
lists, "Baling Machine Operation."
Maintenance Procedure M7A, "Solid Waste Compactor Operation,"
written in accordance to this requirement speci-fies that a radiation monitor (PIC-6) shall be installed, calibrated, and operating on the com-pactor while compacting operations are in pro-
. gress.
Contrary to this requirement, on December 14, 1978, while compactor operations were in progress, a PIC-6 radiation monitoring in-strument (or any other type of radiation monitoring instrument) was not installed on the compactor, nor was there such radiation monitoring instrument in the immediate ~rea.
Our response to Item C is:
- 1.
The purpose of the PIC-6 required by Maintenance Department Procedure M7A was to substitute for the installed area monitor when the latter was inoperable.
At the time of the inspection the area monitor was back 'in operation, and therefore the Maintenance Department personnel did not use the PIC-6.
Although the intent of the procedure (to have radiation monitoring at all times) had been maintained a procedure violation was committed because procedure M7A had not been revised to indicate that the PIC-6 was not re-quired when the area monitor was in operation.
Personnel who violated the procedure received a written warning counseling them on their failure to follow procedure M7A.
Maintenance Procedure M7A has since been revised and now provides instructions for the proper use of the radiation monitoring instruments.
I
' '* *,.1'....
Boyce H. Grier 5 -
1-23-79
- 2.
We are now in compliance and to prevent future items of non-compliance, the following will be completed by February 15, 1979:
a)
Personnel assigned compacting duties shall be. reinstructed in all appropriate radio-active waste procedures and procedure ad-herence.
b)
A review of a solid radioactive waste handl-ing procedures will be performed and re-visions made where required.
If you require additional information, we will be pleased to dis-cuss it with you.
CC~
Director, Office of Inspection and Enforcement Sincerely,
~
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ENCLOSURE 1 Simplified Drawing of the Chem-Nuclear/Liquid Waste System Interface To: No. 1 Waste Evaporator 1
Out of Service.
1WL90 1WL89 Chem-Nuclear >-.__ __ _
- l\\*JL84 Filtration and f
Demineralization System (TEPS)
Hoses Hose./ f:l Connections L.:J l
- ~ *
~----------
1WL79 No. l Waste Evaporator Feed Pump
- Modified Grinnel-Saunders 1 1/2 11 valves (i.e., bonnets removed; adapter plates installed with pipes for hose connections)
To: Nos. 11 and 12 Waste Hold-up Tks; No. 1 Waste Monitor Tk.
From:
Nos. 11 and 12 Waste Hold-up Tks; No. 1 Waste Monitor Hold-up Tk.