ML18085A342
| ML18085A342 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/13/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Schneider F Public Service Enterprise Group |
| Shared Package | |
| ML18085A339 | List: |
| References | |
| NUDOCS 8012080186 | |
| Download: ML18085A342 (6) | |
See also: IR 05000272/1980003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
631 PARK AVENUE
KING OF PRUSSIA, PENNSYLVANIA 19406
Docket No. 50-272
JUM 13. l98G,
Public Service Electric and Gas Company
ATTN:
Mr. F. W. Schneider
Vice President - Production
80 Park Place
Newark, New Jersey 07101
Gentlemen:
Subject: Health Physics Appraisal
The NRC has identified a need for licensees to strengthen the health physics
programs at nuclear power plants and has undertaken a significant effort to
assure that action is taken in this regard.
As a first step in this effort, the
Office of Inspection and Enforcement is conducting special team appraisals of
.
the health physics programs, including the health physics aspects of radioactive
waste management and onsite emergency preparedness at all opeNti_ng power reactor
sites. The objectives of these appraisals are to evaluate. the overall adequacy
and effectiveness of the total health physics program at each site and to identify
areas of weakness that need to be strengthened.
We will use the findings from
these appraisals as a basis not only for requesting individual licensee action .
to correct deficiencies and effect improvements but also for effecting improvements
in NRC requirements and guidance.
This effort was identified to you in a letter
dated Jcrnuary 22, 1980,° from Mr. Victor Stello, Jr., Director, NRC Office of
Inspection and Enforcement.
During the period of January 28 -"February 8; 1980, the NRC conducted the special
appraisal of the health physics program at the Salem Nuclear Generating Station.
Areas examined during this apprais.al are described in the enclosed report (50-
272/80-031_.
Within* these areas, the appraisal team reviewed selected procedures.
and representative records; observed work practices, and interviewed personnel.
It is requested that you carefully review the findings of this report for consideration
in effecting improvements to your health physics program.
The findi_ngs of the appraisal at Salem indicate that altho_ugh your overall
health physics program is adequate for present operations, several significant
weaknesses exist.* These include the followi_ng:
(1)
(21
an inordinate reliance on contracted health physics personnel.
a general lack of technical proficiency among the staff assigned to
heal th physics, and
(3) several deficiencies associated with the ability to organize and
mobilize personnel, particularly in health physics, in the event of an
emergency.
}
Public Service Electric and
Gas Company
2
Ju.~ 13 t9aB.
- These findings are discussed in more detail in Appendix A,
11Significant Appraisal
Findings.
11 *We recognize that an explicit regulatory requirement pertaining to
each *significant weakness identified in App.endi x A may not currently exist.
Howeve*r, to determine whether adequate protection wi 11 be pr>ovi ded for the
health and safety of workers and the public,* you are requested to submit a
written statement within twenty (20} days of your receipt of this letter, describing
your corrective action for each significant weakness identified in Appendix A
includi.ng: . (1) steps which have *been taken;. (2} steps which will be taken; and
(3) a schedule for completion of action. This request is made pursuant to
Section 50.54(f} of Part 50, .Title 10, Code of Federal Regulations.
. .
.
.
. During this appraisal, it was also found that certatn of your activities do not
appe.ar to have been conducted in full compliance with NRC requirements as set
forth in the Notice of Violation enclosed herewith as Appendix B.
The items of
noncompliance in Appendix B have been categorized into the levels of severity as
described in our Criteria for Enforcement Action dated December 13, 1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations,. requires you to
submit to this office, within twenty (20.} days of your -recetpt of this notice, a
written statement or explanation in reply incl udi.ng:
(11 corrective steps which
have been taken by you and the results achteved; (21 corrective steps which will
be taken to avoid further items of noncompliance; and (31 the* date when full
compliance will be achieved.
.You should be aware that the next step in the NRC effort to: strengthen health
.physics pr.ograms at nuclear power plants. will be* the. impositton.of a requirement
by the Office of Nuclear Reactor Regulation (NRR1 that each licensee develop,
submit to the NRC for approval, and implement a. Radtation Protection Plan.
Each
licensee will be 8xpected to. include in the Radtation Protection Plan sufficient
- .measures to provide las ting corrective actton for stgniftca,nt weaknesses tdenti fi ed
during the special appratsal of the current *health.physics .program.
Guidance
for the development of this plan will incorpora.te pertinent ftndi"ngs from all
special appraisals. and wi'll *De tssued by NRR i"n the fall of this year.
In accordance with Sectton 2.790 of the NRC's
11 Rules of Practice,
11 Part 2, Title
10, Code of Federal Regulatfons, a copy of this letter and the enclosures will
be placed in the NRC"s Public Document Room .. If this material contains any
information that you believe to be. proprietary, it ts necessary that you make a
written application wtthfo 20 days to this office to withhold such information
from public disclosure.* Any such applicatton must be accompani'ed by an affidavit
executed by the owner of the information, whtch identifies.the *document or part
sought to be withheld, and which contai'ns a statement of reasons which addresses
wfth specificity the items whi"ch *Will be considered by the Conmtssi on as 1 i sted
Subparagraph (8)(4) of Section 2.790.
The informa.tton so.ught to be withheld
shall be incorporated as far as possible into a separate part of the afftdavit.
If we do not hear from you in thts r.egard wtthfo the spectfied period, this
letter and the enclosures will be placed tn the Public Document Room *
Public Service Electric and
Gas Company
3*
Jlltl 13 19H ..
Should you have any questions concerning this inspection, we will be
pleased to discuss them with you.
Enclosures:
1. Appendix A, Significant Appratsal
Findings
2.
Appendi~ B, Notice of Vtolatton
Sincerely,
3. Office of Inspection and Enforcement Inspection
Report No. 50-272/80-03 *
cc w/encls:
F. P. Librizzi, General Manager;. Electric Production
E. N. Schwalje, Manager - Quality As*surance
R. L. Mittl, Gener~l Manager - Ltcenstng and Environment
H. J. Midura, Man.ager - *salem Generatfog Statton
I. Organization
APPENDIX A
SIGNIFICANT APPRAISAL FINDINGS
a..
Technical Competency (Technical Depth) of the Health PhYsics (HP)
.. O_rgani zati on
. There is a general lack of technical proficiency in the HP Staff pre-
dominently due to:
failure to select, qualify and train personnel (particularly
technicians) speci.fically in the HP specialty. The current
program attempts to qualify and train technicians so that they
are capable of performing activities- in tpe Instrument and Con-
trol, Chemistry and HP *specialities.
To further confound the
development of proficiency, the personnel job ass_ignments are
rotated continually through each of the specialities so that
personnel are not afforded sufficient time and experience to
appreciate and develop the technical skills necessary to perform
in a responsible position.
failure to develop and implement a technician retraining pr_ogram
to assure that the technicians* skill and knowledge is maintained
at a satisfactory level.
Previous training sessions were given
on an ad hoc basis, however these were gi'ven without reviewable
lesson plans, formalized procedures or training documentation.
Currently, another retraining session is underway but lesson
plans, training procedures *and training documentation systems
have yet to he formalized;
failure to have an adequate back-up for the Senior .Performance
Supervisor - Radiation .Protection (RPM).
Currently there are no
individuals on the HP staff at the station with management and
technical abilities sufficient to act as an altern~te to the RPM,
including the HP foreman.
At this time, essentially all of the
technic.al and man_agerial expertise is vested in a si_ngle indi-
vidual, the RPM *
APPENDIX A
2
b.
Inordinate Reliance on HP Contractor Personnel
Because of the attempt to cross train and qualify personnel (techni*
cians particularly), to perform in I&C, Chemistry and HP specialities,
few PSE&G personnel are ever qualified to assume responsible positions
as technicians.
To support a two unit operation, the station's
Performance Department has identified the need for about 55 people.
Of this number PSE&G supplies approximately 12 people (1 RPM; 2
Foremen; 4 Technicians Nuclear (ANSI-Nl8.l qualified); and 5 Technical
- Assistants or Helpers).
The remainder are supplied by a contractor
.organization (Rad Services, Inc. (RSI)).
RSI provides the entire
techntcal and administrative support, all in-plant radiological
controls and monitoring; all HP training; and radioactiv~ waste
coordination.
PSE&G *personnel .provide* dosimetry and records main-
tenance, operation of counting equipment, and provides the respiratory
protection program.
In thes*e areas RSI provide up to 50% of the
manpower needs.
RSI is relied on heavily in all normal, off normal and emergency
conditions. However, the technicians (some are ANSI-Nl8. l qualified
in terms of 2 years previous experience) are not subjected to any
formalized academic trainfog related to their specialty. The1r know-
ledge comes from either previous experience or on-the-job training.
an* the average, technicians spend about 6 to 8 months at Salem Nuclear
Generati.ng *station. _Therefore, they are. generally not familiar with
the plant's characteristic systems.
In emergency or off normal.
conditions this could greatly reduce the effectiveness of the HP
organization.
Generally 80-90% of the HP staff openings essential for two unit
operation are filled by contractor personnel.
I I. Radioactive Waste Man.agement
a.
Responsibility
Although the RPM is designated as the individual responsible for
coordinatidn of radioac.tive waste management, there is essentially no
program in this area at this time.
The licensee's response to Inspection
Re.port 272/79-31 appears to address this concern and indicates that a
program will be formally implemented by March 30, 1980 as a function
of a new Administrative.Procedure (AP) called
11 Radioactive Waste
Management.
11
In actuality, the AP is to provide for an interim solution
for the management of solid rad-waste.
Currently, there is no program
underway t6 deal effectively with the management of all types of rad-
waste.
)
APPENDIX A
3
.b.
Effluents
There is currently no system in place for reviewing noble gas
recorders to quantify anomol ous rel eases that may* occur between
the weekly grab samples taken of gaseous effluents.
.
.
Procedure PD 3.8.016 contains an erroneous formula for calibra-
ting total activity in Waste Gas Decay Tank releases, causing
un.derestimating of noble gas, iodine and particulate activity by
as much as 20%.
-
Procedures have not been developed for primary sample collection
and analysis in eme_rgency conditions.
Interim actions pertaining to high-range capability in Noble Gas
moni taring have not been* completed as* required by the NRR Lessons
Learned *directives issued October 30, 1979, as specified in
III. Health Physics Surveillance Activities
a.
An acceptable Respiratory Protection Program has not been demonstrated
in that several deficiencies pertaining to quality assurance, training,
equipment maintenance were observed. *
b.
There .is no routine review by station personnel of rad.iation protection
instrumentation and equipment calibration records for procedure*
adherence and accuracy for those instruments and equipment calibrated
by contractors. *
c.
Arbitrary efficiency factors are utilized for HP 210 detectors used to
eva.1 uate radioactive contamination.
No actua 1 efficiency determina-
tion has been made.
d.
Bioassay procedures are deficient in that there is no provision to
collect baseline or termination data on individuals subjected to
exposure to airborne activity.
a.
There is a lack of assignment of emergency duties and responsibilities
for radiation protectfon personnel, the Station Manager and repair/corrective
actions teams.
b.
There is no clearly defined program for training a11 individuals who
may be ass_i gned eme_rgency dutfes .'
c.
Procedures governing radiation protection and security activities
during emergenciei do not exist .