ML18095A952
| ML18095A952 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/22/1991 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| NUDOCS 9106030276 | |
| Download: ML18095A952 (7) | |
See also: IR 05000272/1991008
Text
Docket Nos. 50-272
50-311
Public Service Electric and Gas Company
ATTN:
Mr. Steven E. Miltenberger
Vice President and
Chief Nuclear Officer
P. 0. Box 236
Hancocks Bridge, New Jersey 08038
Dear Mr. Miltenberger:
,~
MAY 2 2 1991
Subject:
NRC Combined Inspection Report Nos. 50-272/91-08; 50-311/91-08
This refers to your letter dated April 25, 1991, in response to our letter
dated March 27, 1991.
Thank you for i~forming us of the corrective and preventive actions documented
iri your Tetter.
These actions will be examined during a future inspection of
- your licensed program.
Your cooperation with us is appreciated.
Sincerely,
o,,.:c'.r'a' s*
. fJ: '~: ; ' ~ ieneo By:
11cnard R. Keimig
James H. Joyner, Chief
Facilities Radiological Safety
and Safeguards Branch
Division of Radiation Safety
and Safeguards
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OFFICIAL RECORD ~OPY
RL PSE&G 91-08/08 - 0001.0.0
05/21/91
Public Service Electric
and Gas Company '
cc:
2
MAY 2 2 1991
S. LaBruna, Vice President, Nuclear Operations
J. Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
General Manager - Salem Operations
B. Preston, Manager, Licensing and Regulation
General Manager - Nuclear Safety Review
J. Robb, Director, Joint Owner Affairs
A. Tapert, Program Administrator
R. Fryling, Jr., Esquire
M. Wetterhahn, Esquire
S. Lingerer, Manager, Joint Generation Projects Department,
Atlantic Electric Company
D. Wefsan, Assistant Consumer Advocate, Office of Consumer Advocate
Public Document Room (PDR)
Local Public Documen\\ Room (LPDR)
Nuclear Safety Information Center (NSIC)
K; Abraham, PAO
NRC Resident Inspector
State of New Jersey
bee:
Region I Docket Room (with concurrences)
Management Assistant, DRMA
J. Joyner, DRSS
R. Blough, DRP
J. White, DRP
P. Kaufman, DRP
J. Stone, NRR
K. Brockman, EDO
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OFFICIAL RECORD COPY
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05/.;2.~/91
RL PSE&G 91-08/08 - 0002.0.0
05/07/91
Public Service
Electric and Gas
Company
Stanley LaBruna
Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-1200
Vice Pres;aent - Nuclear Ooerat 1ors *
APR 2 5 1991
NLR-N91074
United States Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
Gentlemen:
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT NOS .. 50-272/9l..;.,08 AND 50-311/91-08
DOCKET NOS. 50-272 AND 50-311
Public Service Electric and Gas (PSE&G) has received the
Inspection Report dated March 27, 19910
Within the scope of this
inspection, one apparent violation of NRC requirements was
identified.
The violation involved two examples of radiation
prot~ction personnel failing to follow requirements speci.f ied in
radiation work permits *and one example of failure.to establish an
adequate procedure to provide guidance for monitoring of
personnel working in radiation dose rate gradients.
Pursuant to the requirements of 10 CFR 2.201, PSE&G hereby
submits its response to the notice of violation.
Should you have any questions in regard to this transmittal,
do no hesitate to call:
Sincerely,
/fl{!~
Attachment
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Document Control Desk
NLR-N9-107 4
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Mr. J. c. Stone
Lice~sing Project-Manager
Mr. T. Johnson
Senior Resident Inspector
2
Mr. T. Martin, Administrator
Region I
Mr. Kent Tosch, Chief
APR 2 5 1991
New J:ersey Department of Environmental Protection
Division of Environmental Quality
-
Bureau of Nuclear Engineering
.CN 415
Trenton, NJ 08625
NLR-N91074
ATTACHMENT
- As a result of the inspection onMarch 4*to a, 1.991, and in
accordance with the NRC Enforcement Policy (10CFR2, Appendix C),
the following violation was identified:
Technical Spe6ification 6.11, Radiation Protection Program,
states that "Procedures for personnel radiation protection shall
be prepared consistent with the requirements of 10 CFR Part 20
and shall be approved, maintaineq and adhered to for all
operations involving personnel radiation exposure."
1.
station procedure NC.NA-AP.ZZ-0022, Revision o, Radiation
Protection Program, states -in part in section 3.9 that.all
personnel ,shall comply with the worker responsibilities. *
listed in attachment 1 to the procedure.
Attachment 1,
Responsibilities of Each Individual, states, in part in
section 2, "Follow all approved procedures, postings and RWP
instructions."
a. RWP Number 911S00237, Revision o, required that radiation
protection tecbnician relocate the worker's dosimetry to
reflect the highest whole body exposure.
Contrary to the above, on March 6, 1991, the radiation
protection technician, overseeing work on RWP Number
. 911S00237, Revision o, did not relocate a worker's dosimetry
to reflect the highest whole body exposure.
The worker was
observed.during a prolonged work activity with the lower
portion of the leg above the knee, a part of the whole body,
in contact with a pipe reading- lOOmr/hr while the worker's
dosimetry was located on his chest in a 60 mr/hr radiation
field.
-
b. RWP Number 911S00121, Revision 1, required e_nsuring that_
all equipment/tools entering the steam generator
handholes were smearably clean.
-
Contrary to the above, on March 6, 1991, foreign object
search and retrieval equipment, inserted into the No. 14
steam generator, was not surveyed to ensure that it was
smearably clean prior to its entry into the steam
.generator.
-2 ~ -
. 10 CFR 20 ._101 (a) provides quarterly ext~rnal radiation
limits for individuals.
10.CFR 20.202 requires that each
licensee is to supply appropriate personnel monitoring
eqiiipment to, and require use of such equipment by, ea.ch
individual who enters a restrict~d area under such
circumstances that he receives or is likely to receive a
_dose in any calendar quarter in excess of 25% of the
applicable value specified in 10 CFR 20.lOl(a).
Contrary to the above, *as of March ~~ 1991, the licensee's
radiation protection procedures were not prepared consistent
with the requirements of 10 CFR 20.202 in that they would
not* ensure that the highest exposure to the whole body of
personnel working in radiation dose rate gradients would be
monitored*with appropriate personnel monitoring equipment.
In addition, personnel were likely to receive a dose in
excess of 25% of the applicable value specified in 10 CFR
20.lOl(a).
PSE&G DOES NOT DISPUTE THE VIOLATION.
ROOT CAUSE
The root causes of these events have been attributed to personnel
error and procedure inadequacy.
Regarding parts la and lb, the root cause has been attributed to
personnel error.
The contract r~diation protection technicians
providing coverage, although aware of th~ radiation work*permit
requirements, did not properly enforce them.
Regarding part-2, PSE&G acknowledges that Radiation* Protection
Procedure RP 301, Personnel Radiation Monitoring Requirements,
Rev 1, was inadequate because it did nc:it specify for all required
cases that dosimetry would be repositioned in radiation ddse rate
gradients.
CORRECTIVE ACTIONS TAKEN
Upon notification of this discr~pancy,* the dosimeter was *
immediately relocated.
No excessive radiation exposure resulted
from the temporary misplacement of the dosimeter.
All material which had entered the secondary side of the steam
gerierator was surveyed.
No contamination was detected.
All radiation protection personnel, including contractor
personnel, were counselled to ensure that total compliance_ with
the RWPs must be achieved at all times.
Particular emphasis was
placed.on;
a. Proper pla~emertt of dosimeters in dose field gradie~ts
and,
b. Proper monitoring (surveying) of equipment entering or
leaving the secondary side of the steam generators.
I.,
Radiation Protection Procedure RP 301, Personnel Radiation
Monitoring Reqliirements I "Rev 1, . was revised to iriclude proper
guidance for the relocation of dosimetry in dose rate gradients.
All- corrective* actions state.d above were completed by -
March a, 1991.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE
Radiation Protection Procedure RP 301, Rev 1,- will be reviewed
-with all Salem radiation protection.technicians during the next
continuing education class, presently scheduled for July 1991.
A discu?sion of these events and the importance of full RWP
compliance will be incorporated into the in-processing training
of contractor radiation protection technicians.
This training is
presently scheduled to be completed prior to the beginning of the
- next scheduled refueling outage, in January 1992.
A checklist will be developed to provide guidance to radiation
protection supervision personnel on field monitoring activities.
This guidance will ensure that all field activities are conducted
in full compliance with radiation protection requirements and
that consistency among all radiation protection technicians is
achieved.
This checklist will be available by September; 1991.
PSE&G is in full compliance