ML18086B032
| ML18086B032 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 10/19/1981 |
| From: | Knapp P, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18086B031 | List: |
| References | |
| 50-272-81-20, NUDOCS 8111130755 | |
| Download: ML18086B032 (12) | |
See also: IR 05000272/1981020
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No. 50-272/81-20
Docket No. 50-272
Region I
License No. DPR-70
Priority ---
Category __ c __
Licensee:
Public Service Electric and Gas Company
80 Park Place
Newark, New Jersey 07101
Facility Name:
Salem Nuclear Generating Station
Inspection at:
Hancocks Bridge, New Jersey
Inspection
1
Inspectors:
/t7-if!!!f'-Y/
A~~P--
P.J.~ility
Radiological Protection Section,
Technical Inspection Branch
date signed
10~1°1-~(
date signed
Inspection Summary:
Inspection on June 29-July 2, 1981 (Inspection Report No. 50-272/81-20)
Areas Inspected:
Special, unannounced inspeytion by a regional based
inspector to follow up and verify commitments and corrective actions performed
in response to the Health Physics Appraisal (Inspection Report No. 80-03,
dated June 13, 1980).
The inspection involved 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> onsite by one NRC
regional based inspector.
Results:
No items of noncompliance were identified .
( 8111130755 811026
PDR ADOCK 05000272
I G
DETAILS
1.
Persons Contacted
- Mr. John Driscoll, Chief, Engineer
- Mr. R. L. Swetnam, Radiation Protection Engineer
- Mr. L. K. Miller, Performance Engineer
Mr. Frank Dickey, Technical Assistant (Rad Service Incorporated)
Mr. Paul Greenbaum, Training Assistant (Hydro-Nuclear Services)
Quality Assurance
In addition, other personnel including technicians, clerical assistants,
and operators were interviewed.
- denotes those personnel present at the exit interview.
2.
Purpose and Scope
The purpose of the inspection was to verify and review the licensee's
corrective actions implemented as a result of the Health Physics
Appraisal.
The following references pertain~
a.
Letter from B. H. Grier, Director, USNRC Region I, to F. W.
Schneider, Vice President - Production; dated June 13, 1980;
b.
Salem Health Physics Appraisal, Report No. 80-03 (January 28 -
February 8, 1980);
c.
Letter from F. W. Schneider, Vice President - Production, to B. H.
Grier, Director, USNRC Region I, dated July 7, 1980;
d.
Letter from F. W. Schneider, Vice President - Production, to B. H.
Grier, Director, USNRC Region I, dated October 7, 1980.
The scope of this inspection effort involved verification and evaluation
of the licensee's responses (References c. and d.) to the Significant
Items and Items of Noncompliance contained in Reference a.
Section 3,
Status of Health Physics Appraisal Items, summarizes the findings of this
inspection.
3.
Status of Health Physics Appraisal Items
Reference a. identified the following Significant Appraisal Findings in
Appendix A:
a.
3
Organization - Technical Competency
Health Physics Appraisal Finding
There was a general lack of technical proficiency in the Health
Physics (HP) staff predominately due to:
Failure to select, qualify and train personnel in the Health
Physics specialty;
failure to develop and implement a technician retraining
program to assure that technician 1s skill and knowledge is
maintained at a satisfactory level; and
failure to have an adequate back-up for the designated
Radiation Protection Manager.
Licensee Response
The licensee 1s response, Reference c, indicated that a training and
retraining program would be developed and implemented by December 1,
1980; and that initial qualification and training would be completed
by July 1, 1981.
Followuo
The inspector determined that significant effort had been made to
train and qualify HP personnel (including supervisory personnel) as
well as provide for periodic retraining.
Training
The general training program currently implemented involves the
following:
Upon being selected to work in the Radiation Protection Department,
entry level personnel (HP Helpers) are required to pass a general
knowledge test (Steven 1 s Battery Test), a personality profile
evaluation and a medical examination.
If performance is satisfactory, the individuals attend a general HP
technician indoctrination course of 2-weeks duration.
The course is
formalized with developed lesson plans and is intended to introduce
the ~tudent to the nuclear power plant and the concepts relating to
radiation protection in the facility.
Such topics as plant layout,
power generation, organization, and the purpose and scope of
radiation protection are discussed .
4
Following the indoctrination the individual is designated as a
Technical Helper (TH) and for the next 6 months to a year, works in
a limited capacity under the direction of supervisory and qualified
technician personnel.
The individual is then given a 7-week course entitled
11Apprentice
Radiation Protection Assistant Course
11 , in which more in-depth
training is presented.
Such topics as atomic structure,
radioactivity, biological effects of radiation, radiation shielding,
radiation detection instrument fundamentals, respiratory protection,
and radioactive waste handling are discussed.
The course has been
formalized with written lesson plans.
Following the above, the student attends
11 Phase II School
11 at the
licensee's main training facility in Quinton, New Jersey.
The
20-week school provides training in electronics, instrument repair,
chemistry techniques, etc.
Ten weeks of this period are devoted to
intensive training in basic Health Physics in which generic
radiation protection theory, practices and methods are presented.
At the completion of the
11 Phase II School,
11 the student returns to
the station and, within the next 6 weeks, the individual is
subjected to an oral examination and a written examination
(involving over 200 essay type questions) on applied and theoretical
health physics.
Upon successful completion, the individual is
upgraded to the position of Technical Assistant (TA).
For at least the next 20 months, the individual works in this
capacity, at which time the person is eligible for promotion to the
position of Technician Nuclear (TN).
A training program called
11 Phase III School
11 is currently under
development by both the station staff and the main training center
in Quinton, to develop the technicians more fully prior to promotion
to TN.
Retraining
The retraining program was reviewed.
A formalized system currently
exists based on written lesson plans that are generated from
observed deficiencies, problems, weaknesses in the staff performance
as well as new regulatory requirements or information that has come
to the attention of the Radiation Protection Department.
Retraining
is performed at least annually and currently involves 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of
instruction. Additionally, personnel are familiarized with the
current Emergency Planning Program and their respective functions .
5
Documentation
The inspector reviewed the training records of five individuals and
determined that adequate documentation existed, including
qualification records, tests, and procedures.
Contractor Training
In accordance with the licensee's program, HP contractor
qualifications were reviewed for acceptance by management personnel.
Following this review, the contracted individual is tested by a
written examination containing at least 50 essay type questions, 70%
of which must be answered correctly in order to be retained by the
licensee.
Contractor personnel who are retained for long periods by the
licensee are subjected to the same training requirements as the
station's HP staff.
RPM Back-up Capability
The inspector reviewed the qualifications of the individual who had
been directed to act in a back-up capacity to the Radiation
Protection Engineer, the designated Radiation Protection Manager,
(RPM).
The licensee stated that the current Radiation Protection
Supervisor is assigned this responsibility.
The inspector reviewed the qualifications of the individual and
determined that the person had sufficient training and experience to
allow his designation as back-up RPM.
Summary
The inspector verified that the licensee has satisfactorily met the
committment specified in Reference c, and that the finding presented
in Reference a has been adequately addressed.
At the time of this
inspection all personnel had been trained or were completing the
training in accordance with the established program.
It was noted however, that Administrative Procedure No. 24, Rev. 5,
dated April 15, 1981, Radiological Protection Program, Section
2.3.3, "Radiation Protection - Personnel Training", and Section 2.4,
"Retraining," indicate that such training shall be as specified in
the Radiation Protection Instructions.
Review of the applicable
instructions, RP 2.012, "TN Retraining," and RP 2.013, "TN Training
Requirements," revealed that while a training program was
established, it was technically different from that described in the
procedures.
In response, the licensee stated the procedures (RP
2.012 and RP 2.013) were not currently applicable.
The inspector's
b.
6
review indicated that the currently established program was a
significant improvement compared to the program described in RP
2.012 and 2.013.
However, the current program was not described in
accordance with the licensee's procedures.
In further review, the inspector noted that the Radiation
Protection Department Administration Procedure, Revision 1, Section
3.4.3, indicates that the training program shall be in accord with
the
11 Personnel Training Manual
11 *
The licensee indicated that this
manual was currently being developed; and would completely describe
the established program.
This item was further discussed in the Exit Meeting on July 2, 1981.
At that time the licensee's representatives stated that the
procedures RP 2.012 and 2.013 would be withdrawn, AP-24 would be
revised to reflect the current training program, and the
11 Personnel
Training Manual 11 would be completed by September 1, 1981.
This item will be reviewed in a subsequent inspection.
(272/81-20-01).
Organization-Inordinate Reliance on Contractor Personnel
Health Physics Appraisal Finding
There was inordinate reliance of contractor personnel due to:
attempting to cross-train personnel to function as Instrument
and Control technicians, Chemistry technicians and Health
Physics technicians.
As a result very few personnel were ever
fully qualified to assume responsible positions as technicians.
As much as 80-90% of the HP staff positions were filled by
contractor personnel, who were predominately responsible for
the performance of the program in normal and off-normal
conditions, including emergency conditions.
Licensee Response
The licensee's response, References c and d, indicated that to
reduce reliance on contractor personnel, a schedule had been
developed to recruit additional station personnel and to
phase ,out dependence on the contractors, such that by July 1,
1981, the majority of the contractors would be replaced.
In
addition, the licensee indicated that the Peformance Department
would be reorganized to remove the Radiation Protection
Department from that division and to form a new department with
the Radiation Protection Engineer reporting directly to the
Station Superintendent.
It was further stated that in the
interim period, personnel (station and contractor) would be
7
trained in accordance with the Performance Department Manual
(which referenced the previously discussed training
procedures).
Followup
The inspector determined, that, in accord with the licensee's
commitment, a reorganization had occured in which the radiation
protection activity was removed from the Performance
Department.
The Radiation Protection Department, with the
department head (Radiation Protection Engineer) reporting
directly to the Station Superintendent, was formed.
It was noted that the Radiation Protection Department was
comprised of personnel specially dedicated to radiation
protection activities.
The Instrument and Control and
Chemistry activities were no longer a function of the Radiation
Protection Department, but rather remained in the Performance
Department.
The inspector verified that the interim personnel training was
performed in accordance with the licensee's procedures RP 2.012
and RP 2.013.
The training process has subsequently been
upgraded as previously discussed in this report.
As of July 1, 1981, the majority of radiation protection
personnel were noted to be employees of the licensee instead of
contractors; 33 licensee personnel and 26 contractor personnel
were directly involved in the radiation protection activity.
The licensee was still actively recruiting personnel.
The
Radiation Protection Engineer stated that it was anticipated
that the radiation protection function would be supported
entirely by licensee personnel by November 1981.
Summary
The inspector verified that the licensee was performing in
accordance with the commitment specified in Reference b.
c.
Radioactive Waste Management - Responsibility
Health Physics Appraisal Finding
There was no formalized program implemented in the area of
management of the disposition of radioactive waste materials
(solid, liquid and gaseous).
----
--- -----
-
Summary
8
Licensee Response
The licensee's response~References band c, indicated that a
radioactive waste management program would be implemented in
accordance with a new administrative procedure, AP-29,
11 Radioactive Waste Management
11 , and a Radwaste Manual
containing implementing procedures.
Such actions were to be
completed by October 1, 1980.
Followup
The inspector verified that AP-29 had been established and
implemented.
The Radwaste Manual, Volume II, which describes
the responsibilities and authorities of the Radiation
Protection Department in regard to solid radioactive material
disposition, was verified to have been issued prior to October
1, 1980.
Volume I, which describes the responsibilities and
authorities of organizations in regard to liquid and gaseous
radioactive waste, was issued during this inspection on July 2,
1981.
However, the lateness of the implementation of this
volume did not appear to compromise or impede actions in the
area of radioactive waste management.
The inspector verified that the licensee was currently performing in
accordance with the commitment specified in References b and c.
d.
Radioactive Waste Management-Effluents
Health Physics Appraisal Finding
Deficiencies noted in this area included:
failure to develop a system for reviewing anomalous noble gas
~elease that might occur between the time that routine samples
are collected;
an erroneous formula in procedure PD-3.8.016 used to estimate
Waste Gas Decay Tank releases;
lack of procedures for primary coolant sample collection in
emergency conditions;
failure to install a high-range noble gas measurement
capability in accordance with NRR ~irectives issued October 30,
1979.
,
'
e .
9
Licensee Response
The licensee 1 s response, Reference c, indicated that procedure
PD-3.8.023
11 Chemistry Analysis Summary Forms,
11 was amended to
provide for daily review and documentation quantifying anomalous
releases.
Further, the response stated that procedures PD-3.3.020,
11 Plant Vent Sample Analysis,
11 and PD-3.8.016,
11Gaseous Radwaste
Release Calculations,
11 were similarly amended to provide for
additional review and control to assure that all gaseous releases
were subject to evaluation.
The response stated that all of these
actions were completed as of July 7, 1980.
Followup
The inspector determined that none of the actions described in the
licensee 1 s response had been implemented.
Review tif procedures
PD-3.8.023, PD-3.3.020 and PD-3.8.016 indicated that the procedures
had not been amended or revised; and that at the time of this
inspection there was still no system established to review and
quantify anomalous noble gas releases.
The inspector verified that the erroneous formula previously noted
in procedure PD-3.8.016 had been corrected.
The licensee 1 s actions on post-accident sampling capability (primary
coolant collection and high-range noble gas monitoring) were
previously verified in NRC Combined Inspection Report 50-272/81-07
and 50-311/81-08.
Summary
With the exception of the licensee 1 s failure to meet the commitment
to revise and amend existing procedures to provide review and
control of anomalous noble gas releases, the licensee actions were
verified to be in accordance with References c and d.
With regard to the failure to amend and revise the specified
procedures, the licensee was not able to offer any explanation, but
did state that such procedures would be amended by August 1, 1981.
Further discussion of this item is included in Section 5,
11 Exit
Meeting
11 *
This item will be reviewed in a subsequent inspection.
(272/81-20-02)
Health Physics Surveillance Activities
Health Physics Appraisal Finding
The following specific deficiencies were noted:
.
, .
a.
b.
c.
d.
10
An acceptable Respiratory Protection Program was not developed;
Station personnel did not perform reviews of instrument
calibration performance or documentation;
Actual efficiency determination was not performed for HP-210
personnel frisking detectors; and
The bioassay program did not provide for baseline data on
personnel that may be subjected to exposure to airborne
radioactivity.
Licensee Respon~e
The licensee 1 s response, Reference c, indicated that:
a.
A Respiratory Protection Program had been developed and
implemented on March 14, 1980;
b.
Personnel were trained in instrument calibration, and
supervisors were directed to perform routine reviews of
performance in this area;
c.
Efficiency factors for HP-210 detectors were determined; and,
d.
A bioassay procedure was developed to provide for baseline
determinations on all personnel expected to be subject to
exposure to airborne rad1oactive material.
The procedure,
PD-15.3.027, was implemented on July 30, 1980.
Summary
The inspector verified the licensee 1 s performance in these areas to
be in accordance with References c and ~-
f.
Health Physics Appraisal Finding
The following deficiencies were noted:
a.
Failure to assign emergency duties and responsibilities for
radiation protection personnel, the Station Manager, and
response teams;
b.
c.
Failure to establish a clearly defined training program for
individual~ assigned to emergency functions;
I
Failure to develop emergency procedures in the area of
radiation protection and security.
11
Summary
The licensee's action on these items and other related areas were
reviewed and reported in NRC Combined Inspection Report 50-272/81-07
and 50-311/81-08.
4.
Status of Previously Identified Items
(Closed) Noncompliance (50-272/80-03-01)
Failure to identify radioactive
material in accordance with 10 CFR 20.203(f).
The licensee has
established a program that provides for the proper identification of
radioactive material.
Pre-labeled polyethylene bags are currently
utilized in this regard.
(Closed) Noncompliance (50-272/80-03-05)
Failure to adhere to Station
Procedures PD-15.9.004 and PD-15.9.009 in accordance with Technical
Specification 6.8.1; failure to establish a procedure covering
calibration of air sampling equipment.
The procedures in question were
subjected to revision to assure that user instructions could be followed
and personnel were instructed in the revised technique.
A specific
procedure for calibration of air sampling equipment was established and
implemented.
(Closed) Noncompliance (50-272/80-03-07)
Failure to make changes to
Station Procedure 15.9.002 in accordance with Technical Specification 6.8.2.
Procedural control has been strengthened by the implementation of
a Radiation Protection Administrative Manual.
All unapproved procedures
have been removed and controlled procedures have been implemented.
(Closed) Unresolved Item (50-272/79-07-04) Training of Health Physics
Technicians.
The current training program has been significantly
upgraded; and has adequately addressed previously identified
discrepancies.
5.
Exit Interview
0
The inspector met with the licensee's representatives (denoted in Section
1 of this report) on July 2, 1981.
The findings of the inspection were
presented.
The licensee made the following comments regarding the failure to
implement the corrective actions described in Section 3.d of this report
as specified in the letter from Mr. Frederick W. Schneider, Vice
President - Production to Mr. B. H. Grier, Director, NRC Region I, dated
July 7, 1980;
The commitment as specified in the letter will be implemented by
August 1, 1981;
A review will be conducted to determine why the stated commitments
were not initially implemented;
12
In response to this inspection, a report will be submitted
identifying the specific degradation in management controls that
permitted inaccurate information to be submitted in response to an
NRC request; and the upgraded management controls established to
preclude recurrence.