ML18093B505

Responds to NRC 890208 Ltr Re Violations Noted in Insp Repts 50-272/88-25 & 50-311/88-25.Corrective Actions:Radiation Protection Supervisors Involved W/Steam Generators Counseled on Strict Compliance W/Radiation Permits & Requirements

ML18093B505
Person / Time
Site:	Salem
Issue date:	03/10/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89043, NUDOCS 8903210178
Download: ML18093B505 (5)

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j Public Service Electric and Gas Company A1ey LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800

~resident - Nuclear Operations rMR 10 1989 NLR-N89043 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC COMBINED INSPECTION REPORT NO. 50-272/88-25 AND 50-311/88-25 SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection report dated February 8, 1989, which included a Notice of Violation regarding failure to implement radiation protection procedures. Pursuant to the requirements of 10CFR2.201, our response is provided in the attachment to this letter.

Should you have any questions on this transmittal, do not hesitate to callg Sincerely, Attachment 9903210170 a~g55g72 PDR ADOCK 0 PNU G

Document Control Desk 2 MAR lo 1889 NLR-N89043

• c Mr. J. c. stone Licensing Project Manager Ms. K. Halvey Gibson Senior Resident Inspector Mr. w. T. Russell, Administrator Region I Ms. J. Moon, Interim Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuc1*ear Engineering CN 415 Trenton, NJ 08625

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ATTACHMENT PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING STATION UNIT NOS. 1 AND.2 RESPONSE TO NOTICE OF VIOLATION Your letter of February 8, 1989, transmitted NRC Combined Inspection Report No. 50-272/88-25; 50-311/88-25 for Salem Units 1 and 2 which included a Notice of Violation. The specific items identified in the violation and our related responses are presented below.

Technical Specification 6.11, Radiation Protection Program, requires, in part, that procedures for personnel radiation protection shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

1. Administrative Procedure AP-24, Radiation Protection Program, requires in part in section 5.4, that Radiation Work Permits be adhered to. Radiation Protection Procedure RP 202, Radiation Work Permits, requires in part in section 7.3.12, that applicable check lists from applicable radiation protection procedures be incorporated into the RWP. The applicable Hot Particle Check list from Radiation Protection Procedure 808, incorporated into RWP No.

88-2S-00979, Revision 1, requires Masslin surveys of the entire work area every four hours.

Contrary to the above, on October 18, 1988 and for an undetermined period of time prior to this date, the Hot Particle Check list incorporated into RWP No.

88-2S-00979, Revision 1, was not adhered to during work performed under this RWP in that contamination surveys of the 21/23 Steam Generator platforms, part of the work area, were performed only once per shift rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and were performed with paper disc smears rather than Masslin.

2. Administrative Procedure AP-24, Radiation Protection Program, requires in part in section 6.1.3, that personnel shall be denied access to the Radiological Controlled Area (RCA) unless they are entering under the provisions of a valid radiation work permit (RWP).

Contrary to the above, on October 5 and 6, 1988, an individual was not denied access to the RCA even though it was known by Radiation Protection Supervision that he could not enter under the provisions of a valid RWP due to dose restrictions. The individual entered the RCA and performed work involving frisking of equipment for contamination.

NLR-N89043

I, RESPONSE - ITEM 1

1. ROOT CAUSE The root cause of this violation was inadequate training of Radiation Protection personnel in the new survey techniques utilized in hot particle zones, and a lack of supervisory oversight in not ensuring procedural adherence.

2. CORRECTIVE ACTIONS IMPLEMENTED The Radiation Protection supervisors involved with Steam Generators were counselled on strict compliance with RWP and procedural requirements. They ensured that 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> surveys of the platform areas using Masslin cloths were being done in accordance with the Hot Particle Check List and RP 808.

3. LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER VIOLATIONS As committed to in our response to NRC Combined Inspection Report No. 50-272/88-18; 50-311/88-18, critical procedures are being taught to appropriate Radiation Protection personnel prior to the start of the next refueling outage, currently scheduled for April 15, 1989. Procedure adherence, RP 808, and hot particle controls are included in these training sessions. The training is being conducted from January through March 1989 and is on schedule.

In addition, RP 808 was reviewed for procedural adequacy. It was determined that the procedure adequately addressed hot particle control and associated requirements and that no changes to the procedure were necessary.

Supervisory oversight is being stressed for the upcoming Unit 1 Eighth Refueling Outage.

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The training sessions will be completed prior to the start of the next refueling outage, presently scheduled for April 15, 1989.

NLR-N89043

• RESPONSE - ITEM 2

1. ROOT CAUSE The root cause of this violation was inadequate guidance on the precise location of the RCA boundary in the Control Point area.

2. CORRECTIVE ACTION IMPLEMENTED The individual was removed from the RCA and his dosimetry was checked to ensure that there was no significant exposure. The supervisor responsible for permitting the individual to enter the RCA without being on a valid RWP was counselled. Night orders were issued to management and technicians re-emphasizing the RCA boundaries and the AP-24 requirement to be on a valid RWP to enter the RCA. The importance of this issue was discussed with all Radiation Protection personnel.

3. LONG TERM CORRECTIVE ACTIONS TO AVOID FURTHER VIOLATIONS Clarifying instructions have been conspicuously posted at the entrance to the RCA and will be incorporated into the Radiation Worker Training sessions conducted for all personnel.

The Radiation Protection procedures which contain guidance for RCA access were reviewed for clarity. Minor changes (Advanced Change Notices) were initiated for two procedures to clarify the RWP requirement when entering the RCA. These changes will be incorporated into these procedures by March 31, 1989.

This incident and its associated corrective actions are being included in the special procedure training for Radiation Protection personnel as previously discussed.

4. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The special procedure training will be completed prior to the start of the next refueling outage, presently scheduled for April 15, 1989.

NLR-N89043