ML20136F090

Insp Rept 50-293/85-32 on 851117-22.Violations Noted:Failure to Search Package Brought Into Protected Area & Failure to Perform Instrument Channel Test

ML20136F090
Person / Time
Site:	Pilgrim
Issue date:	12/20/1985
From:	Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20136E983	List: ML20136E975 ML20136F062 ML20136F090
References
50-293-85-32, NUDOCS 8601070233
Download: ML20136F090 (24)

See also: IR 05000293/1985032

Text

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c.

U.S. NUCLEAR REGULSTORY COMMISSION

REGION I

Report No. ,P-293/85-32

Docket No. 50-293

License No. OPR-63 Priority --

Category C

Licensee: Boston Edison Comoany M/C Nuclear

800 Boylston Street

Boston, Massachusetts 02199

Facility Name: Pilgrim Nuclear Power Station

Inipection At: Plymouth, Massachusetts

Inspection Conducted: Novcmber 17-22, 1985

Inspectors: 9..L d M

R. L. Nimitz, SenioY Radiation Specialist

n.\ h { SS

date ~

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Approved by: .

/1J/A .

W. J.! sctik, Chief, BWR Radiation Protectieff

[ c 1. o . I 9FI

date'

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Sects n

Inspection Summary: Inspection on November 17-22, 1985 (Report No.

E0-293/85-32)

Areas Inspected: Routine, unannounced inspection of the following:

implementation of improvement items identified in the Radiological Improvement

Program; radiological controls for fuel pool re-racking and removal of the

Radwaste Concentrator; and Effluent Release Monitors / Controls. Upon arrival

at the site on November 17, 1985, the inspector toured the facility and

reviewed implementation of radiological controls practices and procedures.

The inspection involved 43 inspector-hours on-site by one region based

inspector.

Results: Two violations were identified (Failure to search packages when

brought into the protected area; section 6, Failure to perform instrument

channel test; paragraph 5). The Radiological Improvement Plan was being

satisfactorily implemented. Some concerns were identified in management

oversight of radiological work. The licensee took timely corrective action

for this matter.

8601070233 851231

PDR ADOCK 05000293

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DETAILS

1.0 Persons Contacted

1.1 Boston Edison

• L. Oxsen, Vice President, Nuclear Operation

• C. Mathis, Station Manager

• W. Deacon, Assistant to Senior Vice President, Nuclear

"K. Roberts, Director, Outage Management

"T. Sowdon, Radiological Section Head

"J. Crowder, Senior Compliance Engineer

• P. Smith, Chief, Technical Engineer

• B. Eldridge, Acting Chief Radiological Engineer

• E. Graham, Compliance Group Leader

• G. Anderson, Outage Management Engineer

• E. Menslage, Outage Management Engineer

• D. Mills, Acting CMG Group Leader

• M. Noon, Corporate Security

• J. McEachern, Resource Protection and Control Group Leader

Contractors

• M. Jackimowicz, CYGNA

G. Smith, Hydro Nuclear

1.2 NRC

• L. E. Tripp, Chief Reactor Projects Section 3A, NRC Region I

• M. McBride, Senior Resident Inspector

• denotes those individuals attending the exit meeting on November 22,

1985.

The inspector also met with other individuals.

2.0 Purpose of Inspection

The purpose of this routine, unannounced radiological controls inspection

was to review the following program elements:

Implementation of the Radiological Improvement Program

Radiological Controls for re-racking of the spent fuel pool

Radiological Control for Removal of the Radwaste Concentractor.

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3.0 Implementation of Licensee Commitments Presented to NRC in the

Radiological Improvement Program (RIP)

3.1 General

The inspector reviewed the implementation of Radiological Improvement

Program commitments presented to the NRC. The review was with respect to

criteria and/or information cor4tained in the following documents:

Order Modifying Licensee, Notice of Violation, and Notice of

Deviation (NRC Inspection No. 50-293/84-25 and 50-293/84-29), dated

November 29, 1984,

=

Letter (W. D. Harrington, Senior Vice President-Nuclear, Boston

Edison, to T. E. Murley, Regional Administrator, NRC Region I),

dated February 28, 1985, (BECo ltr No.85-042),

Licensee Completed Regulatory F quirement Analysis Forms (various)

relative to Radiological Improvement Plan (RIP) Milestones,

Licensee Radiological Activity Assessment Reports (RAAR) (various),

Radiological Oversight Committee (ROC) Meeting Minutes (various),

NRC Inspection Report No. 50-293/85-13, dated July 16, 1985, and

NRC Inspection Report No. 50-293/85-22, dated October 7, 1985.

The purpose of this review was to determ- .f:

the licensee met the commitments (i.e. milestones) specified in the

Radiological Improvement Program (RIP);

the material or actions taken/ generated by the licensee

satisfactorily met the commitments made to NRC in the RIP; and

a

the material or actions taken/ generated were properly implemented.

The following aspects of RIP implementation were noted and verified

implemented:

a tracking program was in place to identify milestones due;

adequate management controls were in place to monitor implementation

of milestones and initiate proper action when milestones were

identified as potentially not being met;

review was performed of the material or actions taken/ generated to

determine its adequacy prior to its acceptance and implementation.

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3.2 Findings

The inspector reviewed a total of 71 commitments that were to have been

completed by the licensee by October 31, 1985. The commitments reviewed

are identified in the attachment to this report.

The review indicated the licensee satisfactorily completed his action on

50 of the commitments. Several commitments were left open due to the

need for additional licensee action or NRC review. These are identified

in the attachment to this report.

<-

Based on the above review, the licensee is aggressively monitoring

implementation of the RIP improvement items, and is meeting commitments

provided to NRC Region I.

Within the scope of the review, the following positive attributes were

noted:

1*

The licensee's Senior Vice President-Nuclear is closely monitoring

implementation of the Radiological Improvement Program.

Radiological Oversight Committee members are touring the facility

once per week. Findings identified during the tours are brought up

and discussed at the, ROC meetings. Action is initiated to resolve

problems identified.

The licensee has taken action to upgrade the quality of procedures

being developed to satisfy RIP commitments.

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4. Radiological Controls Implementation

The inspector reviewed the implementation, adequacy, and effectiveness of

Radiological Controls for the 1:stallation of high density fuel racks in

the fuel pool and for removal of the Radwaste Concentrator. The following

matters were reviewed:

adequacy and effectiveness of management oversight and control of

the activities,

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establishment, adequacy, and implementation of appropriate

g procedures for the activities,

e

adequacy and adherence to Radiation Work Permits,

selection, qualification and training of personnel,

e

implementation and adequacy of ALARA controls,

high radiation area controls implementation and adequacy,

4 :

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adequacy and evaluation of radiological surveys,

supply and use of appropriate personnel monitoring equipment, and

use of acceptable, properly calibrated radiological survey

instrumentation.

The review was with respect to criteria contained in the following:

applicable Technical Specifications,

10 CFR 20, " Standards for Protection Against Radiation," and

applicable licensee procedures.

4.1 General

The inspector reviewed the management oversight and control of the fuel

pool re-racking and concentrator removal with respect to criteria con-

tained in the following:

VPN0 Letter No. 85-95, " Improved Control of PNPS Work Process", and

Outage Management Work Instruction No.11.0, " Inter-Disciplinary

Critiques", dated November 21, 1985.

The above documents were established to provide improved oversight and

control of projects that involve significant radiological and/or

industrial safety risk.

Within the scope of this review, no violations were identified. The

licensee was found to be providing, in general, acceptable oversight of

the radiological significant work. However, the following items for

improvement were identified:

Provide a mechanism to ensure that each inter-disciplinary group has

a clear understanding of its responsibilities. In some areas (e.g.

personnel training) it was not clear that each group understood its

responsibilities. In addition licensee oversight responsib,'lities

of contractor activities should be clearly identified. The

licensee's Work Instruction No. 11 provides general guidance in

these areas. However, the implementation of this guidance was not

uniform for the two tasks.

The licensee immediately initiated action to:

1) revise the Work Instruction No.11 to provide for uniform

interpretation of guidance contained therein,

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2). clearly identify each inter-disciplinary groups responsibilities

and oversight requirements, and , ,

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3) provide for clear identification and implementation of

training / retraining requirements.

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The licensee's actions on this matter were timely.

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Upgrade controls on field changes to re-rack and concentrator

removal procecures to ensure appropriate radiological controls

. personnel (as necessary) review field changes to procedures.

The licensee initiated action to ensure radiological controls

personnel (as necessary) review field changes to procedures.

Provide (as. appropriate) a methodology and criteria for use in

monitoring on going radfological work in order to identify

unfavorable exposure tre.nds such that appropriate actions can be

taken to correct the situation.

The licensee provided a mechanism for clear oversight / review of day

,

to day exposure received on the tasks.

-> 4.2 Radwaste Concentrator Removal (Radiological Controls)

Documents Reviewed

Procedure 6.1-012, " Access to High Radiation Areas"

Temporary Procedure No. TP85-107, " Dismantling / Removal of Radwaste

Concentrator and Associated Equipmant" -

Procedure 6.1-022, " Issue, Use, and Termination of Radiation Work

Permits (RWPs)"  ;

Temporary Procedure No. TP85-108, " Operation of the AP-1000 and

AP-2000 HEPA Filter Units Including Filter Changeout

Procedure PNPS SI-RP.5002, "Use and Control of Portable. Ventilation

Units and HEPA Vacuum Cleaners", September 18, 1985 /

Findings

Within the scope of this review, no violations were identified. The

licensee was providing and implementing generally commendable in-field

Radiological Controls for removal of the Radwaste Concentrator.

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The following positive attributes were noted:

The licensee made effective use of engineering controls (e.g. tents,

HEPA filters) to minimize airborne radioactivity concentrations.

The licensee provided and utilized shielding were appropriate and

cost beneficial to minimize personal exposure.

The licensee installed closed circuit TV to monitor on going work

activities.

The licensee provided closed circuit two way communication with

workers.

The licensee implemented multi-layer high radiation area controls to

provide for effective high radiation area controls.

Senior level, qualified personnel were monitoring on going

radiological work.

Within the scope of this review, the following items needing licensee attention

were identified:

Evaluate and provide. (as appropriate) personnel dosimetry for the

backs of personnel to provide for non-uniform whole body exposure.

The licensee immec:ately initiated action to evaluate and provide

(as appropriate) dosimetry for the backs of personnel.

. Evaluate and control (as appropriate) the exposure of personnel to

airborne pure beta emitters.

The licensee immediately initiated action to evaluate and control

(as appropriate) airborne beta exposure of personnel.

4. *

Label HEPA air filtering systems. The systems were not labeled.

Consequently, personnel were uncertain as to applicable operating

acceptance criteria.

The units were immediately labeled.

Establish HEPA exhaust airborne concentration limits requiring

personnel actions. Procedures said take action when airborne

radioactivity " specification" is exceeded. Specification was

undefined.

The licensee immediately initiated action to provide a defined

specification.

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Some area surveys were not readily available for briefing

personnel. Procedures specify surveys be available.

The licensee initiated action to obtain and post all appropriate

surveys on a Radwaste Concentrator Status Board.

The following item for improvement was identified:

Clearly identify the minimum controls and/or equipment needed to be

present and/or operable in order to continue work removing the

Radwaste Concentrator, particularly in the area of high radiation

area access controls. '

The licensee immediately established a Radwaste Concentrator Daily

check list. The check list provides minimum controls and/or equip-

ment to be operable for work to continue.

4.3 Fuel Pool Re-Racking (Radiological Controls)

Documents Reviewed

Procedure 6.1-022, " Issue, Use, and Termination of Radiation Work

Permit"

Procedure No. 6.7-121, " Radiation Protection Requirements for Diving

, in Radiologically Controlled Areas"

Procedure NEDWI-308, " Fuel Pool Re-racking"

Procedure 3M1-19, " Spent Fuel Pool Cleaning"

Temporary Procedure 85-83, " Fuel Pool Vacuum Filter Change-Out"

Findings

Within the scope of this review, no violations were identified. The

licensee was providing acceptable in-field Radiological Controls for

installation of new racks. The licensee is currently performing

preplanning for removal of the old racks and diving.

The following positive' attributes were noted:

The licensee was providing effective control of radioactive material

being. removed from the fuel pool. Radiological Controls personnel

were in constant attendance.

Fuel pool water clarity was very good.

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A procedure log was established and in place on the refueling

floor.

The licensee initiated a comprehensive effort to evaluate the

' underwater radiation environment entered by the divers.

The licensee is decontaminating the fuel pool to minimize exposure

to divers, prevent water clarity problems, and in general eliminate

unnecessary radioactive material in the fuel pool.

Within the scope of this review, the following items needing licensee

attention were identified:

An unapproved procedure for rack removal was found on the refuel

floor.

The _ licensee removed the unapproved procedure, provided an approved

copy, and initiated action to ensure appropriate, approved

procedures were in use on the Refueling Floor. No differences were

apparent between the approved and unapproved copies.

The licensee has taken action or is taking action to address the

following matters:

Evaluate the radiation environment entered by divers. Provide

proper dosimetry to monitor diver exposure.

Evaluate the acceptability of radiation survey meters used to

measure underwater dose rates. Provide for properly calibrate

survey meters.

Establish (as appropriate) pre-dive check lists / instructions.

Define diver bioassay program.

Establish (as appropriate) post-dive check lists / instructions.

Establish controls to limit / control exposure to critical body parts

of diver.

Establish (as appropriate) procedures for use of the hydro-lazer

hydrolazer.

5.0 Effluent Monitoring / Control Instrumentation

The inspector reviewed the implementation, adequacy, and effectiveness of

the licensee's calibration program for Effluent Monitoring / Control

Instrumentation. The following matters were selectively reviewed:

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establishment of appropriate procedures for calibration / checking of

the Reactor Building Vent and Stack Effluent Monitors,

implementation of procedure requirement.

adequacy of alarm set point determinations, and

a

control room personnel oversight / monitoring of effluent monitoring

instrumentation.

The review was with respect to criteria contained in the following:

a

10 CFR 20, " Standards for Protection Against Radiation,"

Applicable Technical Specifications, and

Applicable Licensee procedures.

The licensee's performance in the area was based on discussions with

personnel, review of documentation, and visual observation of

instrumentation.

Within the scope of this review, the following violation was

identified:

Technical Specification 4.8 c.10 requires, in part, that each waste

gas monitor have an instrument channel test at least monthly.

Lc.itrary to the above, as of November 22, 1985, instrument channel

.ests were not being performed on a monthly basis for the Reactor

Building Vent and the Stack Waste Gas Monitors. (50-293/85-32-01)

Licensee representatives immediately initiated action to review and

resolve (as appropriate) this matter.

In addition, the following matter needing licensee attention was iden-

tified:

No defined methodology was in place which described determination and

set-up of alarm set points for the waste gas monitors.

The licensee was aware of this matter and had initiated action

to upgrade appropriate procedures.

Excluding the above matters, no other unacceptable practices were

identified.

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6.0 Plant Tours

The inspector toured the facility initially upon arrival and periodically

during the inspection. The following matters were reviewed:

adherence to procedures.

posting, barricading, and access control (as appropriate) to

radiation and high radiation areas, and

adequacy of radiological survey.

Within the scope of this review, the following violation was identified:

At about 9:30 p.m. on November 17, 1985, the inspector

observed two articles being brought into the protected area that

were not searched.

The licensee's investigation of this matter determined that of the

two articles, one was not adequately searched. This is a

violation of the Pilgrim Nuclear Power Station Security Plan,

Section 1.6.4 (50-293/85-32-02)

Within the scope of this review, the following matter needing licensee

attention was identified:

The inspector was improperly processed into the restricted area at

about 9:30 p.m. on November 17, 1985. The inspector was provided

incorrect quarterly dose limits and radiation exposure card. This

matter was identified by the inspector and licensee personnel.

The licensee subsequently modified the inprocessing form to provide

for ease of use and minimization of errors. The licensee

reinstructed and/or counseled personnel as appropriate.

The licensee's action on this matter was timely.

No other unacceptable practices were identified.

7. Exit Meeting

The inspector met with those individuals denoted in section 1 of this

report at the conclusion of the inspection (November 22,1985). The

inspector summarized the purpose, scope and findings of this inspection.

No written material was provided to the licensee.

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ATTACHMENT TO REPORT

50-293/85-32

Status of Boston Edison Company's

Radiological Improvement Program (RIP)

Commitment to be Completed after

July 31, 1985 and before October 31, 1985

COMMITMENT STATUS NRC Comment

1. 1.2.2-7 Formal position Complete The licensee established

descriptions to be formal position descrip-

established for each tion for each title.

Radiological Group title.

(September 31,1985)

2. 1.2.3-1 Distribute Radio-- Complete None

logical Control Group's

Organization Chart and conduct intergroup meetings (August 31, 1985

Deferred)

3. 1.2.4.a-2 Perform a basic Complete The licensee performed

task analysis for all the task analysis and

positions within the projected staffing

Radiological Group level 2.

Organization and project

staffing levels

(September 30,1985)

4. 1.2.4b-1 Complete staffing Open Several positions remain

of exempt positions in the to be filled. Personnel

Radiological Control Group are filling the post-

(August 31,1985) tions in an acting

capacity.

(50-293/85-32-03)

5. 2.1.1-1 Define Radiolog- Complete None

tcal Control Group person-

nel qualification criteria

(August 31,1985)

6. 2.1.1-2 Use task analysis Complete None

to define qualifications

needed for each Radiological

Group position. Incorporate

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qualification criteria into

material to be generated to

meet Milestone 1.2.2(1-7)

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COMMITMENT STATUS NRC Comment

7. 2.1.2b-1 Establish formal Open The licensee estab-

position specific selection lished formal '

criteria for hiring position specific

(September 30,1985) selection criteria

for hiring. However,

the criteria were not

consistent with

Technical Specification

requirements relative to

minimum required

experience. The

incorrect criteria had

been incorporated into

job postings.

(50-293/85-32-04)

8. 2.1.3-1 Develop a program Complete None

to assist a supervisor

following assignment to

a new area of responsibility

(August 31,1985)

9. 2.2.2.6-1 Establish a formal Complete None

training program for Radio-

logical Group supervisory staff.

(August 31,1985)

10. 2.2.2.b-2 Establish speciality Complete None

for technicians in such areas

as TLD processing and whole

body counting.

(September 30,1985)

11. 2.2.3-1 Establish a formal Open Retraining program

continting training program not clearly defined

for all Radiological Group (50-293/85-32-05)

personnel. Technical training

material will be developed.

(October 31, 1985)

12. 2.2.4-1 A Radiological Open The training department

Group member will review did not have all

course material developed applicable review find-

for Health Physics technical ings and consequently

personnel. (September 30, was unable to demon-

1985) strate where all review

findings were addressed.

(50-293/85-32-06)

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COMMITMENT

_ STATUS NRC Comment

13. 4.1.la-1 Evaluate the Open The licensee evaluated

effectiveness of the the effectiveness of the

extremity dosimetry extremity dosimetry

program and ensure that program and revised

guidance for calculating appropriate procedures

and recording extremity (SI-RP-2402). However,

exposures is adequate extremities were not de-

(September 30,1985)

fined (50-293/85-32-07)

14. 4.1.1b-1 Evaluate Complete None present guidance

for resolving TLD data

discre pancies

(August 31,1985)

15. 4.1.lb-2 Provide Open Procedure 6.2-011

additional guidance established. To be

for resolving TLD revised. (SI-RP. 2400

discrepancies.

(September 30,1985)

in draft) (50-293/65-

32-08)

16. 4.1.2a-2 Evaluate current Complete Licensee evaluated the

TLD QA program and modify current TLD QA program

procedures to include the and modified procedures

requirement for " spiked" as appropriate (SI-RP-

TLDs (September 30,1985) 2001)

17. 4.1.2.a-3 Evaluate Complete Licensee evaluated the

the current QA program current TLD QA program

for extremity monitoring and modified procedures

devices. Modify procedures as appropriate (SI-RP-

to include " spiked" TLDs 2001)

based on evaluation of

Millstone 4.1.2(c)

(September 30,1985)

18. 4.1.2b-1 Develop support Complete Evaluation of current

data necessary to document correction factor

the basis for the beta found that it provided

correction factor currently for underestimation of

used by the TLD vendor. true beta dose by a

(October 31,1985) factor of about 3.

Licensee has modified

factor used and; is

reviewing previous beta

exposure data to

determine need for

correction of personnel

exposures.

(50-293/85-32-09)

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COMMITMENT STATUS NRC Comment

19. 4.1.4-1 Evaluate proce- Open Licensee addressed

dural guidance for the exposure trending in the

evaluation of dosimetry Radiation Protection

data. Address ALARA Program document. A

exposure trending in the temporary procedure

ALARA section of the (TP 85-45) was

- Radiation Prote: tion established for ALARA

Program document implementation. The

(October 31, 1985) temporary procedure

did not provide clear

guidance relative to

performance of ALARA

reviews of on going work

(50-293/85-32-10)

20. 4.2-3 Issue Policy Complete Licensee issued a policy

statement if required statement. The state-

on the exposure of ment was signed by the

fertile females Senior-Vice

(R. G. 8.13 President-Nuclear.

October 31,1985)

21. 4.3-1 Review High Complete Review during Inspection

Radiation Area Physical 50-293/85-22 found that

Controls (June 30, 1985) high radiation area key

control had not been

addressed. Licensee

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subsequently reviewed

key control and

implemented additional

controls.

22. 4.3-2 Improve the level Open Licensee upgraded level

and quality of physical and quality of physical

controls applied to high controls applied to high

radiation areas, as appro- radiation areas. Key

priate (October 31,1985) access was restricted,

posting was upgraded, a

high radiation area

statis board was

established and a new

procedure was drafted to

provide administra-tive

controls over access to

high radia-tion areas.

The proce-dure remains

to be approved.

(50-293/-85-32-11)

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COMMITMENT STATUS NRC Comment

The following matters do

not appear to have been

addressed:

a minimum training /

qualification of person

issuing and receiving

keys (Both) Areas >1R/hr

and areas >10R/hr)

,

• updating of high

rad status board.

23. 5.2.lb-1 Evaluate the air Open The licensee established

sampling program to deter-- a revised air sampling

mine if appropriate air procedure. However,

samples are being obtained provisions were not

(October 31,1985) contained in the proce-

dure for limitations of

self-absortion factors

and methodology for

sampling for and

evaluation of pure beta

emitters. Also, Pu-238

is being used as the

alpha MPC. No basis for

the use of Pu-238 was

provided.

24. 6.1.1-1 Establish, (50-293/85-32-12)

Open Licensee established,

approve, and implement

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approved and imple-

a procedure and/or a mented a group instruc-

group instruction tion for performance of

.

for the routine perfor- an in vitro bioassay

mance of an in vitro program. (SIRP.2100)

bioassay program.

(September 30,1985) Procedures do not pro-

vide clear guidance for

determination of intake

(i.e. MPC-hour exposure)

(50-243/85-32-13)

25. 6.1.2-1 Complete review Complete None

of ANSI N343, and ANSI

N13.30 (August 31,1985)

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COMMITMENT STATUS NRC Comment

26. 6.1.2-2 Determine the need Open The licensee uses the

for a QA program for the services of Yankee Labs

commercial, off-site for performance of

analytical laboratory. analytical work. The

Develop QA procedure acceptability of the

and/or group instruction lab is reviewed once a

as needed (October 31, 1985) year by a utility

committee consisting of

members from different

utilities who use the

lab. This is

acceptable. However,

time limitations

prevented the inspector

from determining what

mechanism is in place to

determine the need for

and to establish a QA

program (if needed) for

labs other than the

Yankee Labs.

(50-293/85-32-14)

27. 6.2.1.b-1 Validate Complete None

bench marks of whole

body counter (One month

after receipt of sources)

28. 6.2.1 9-1 Review procedures Complete Procedure 6.2-161

and resolve any discrep- should be revised to

ancies in recommended reflect new procedures

internal deposition action (SI-RPs) (50-293/85-

levels and external contami- 32-15) (i.e. cross

nation limits (August 31,1985) referenced)

29. 6.2.1h Approve a Complete None

procedure or group

instruction for a systematic

, methodology for

investigation, documentation,

and records maintenance of

abnormal internal exposures.

(August 31,1985)

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COMMITMENT STATUS NRC Comment

30. 6.2.11 Develop procedure Open Procedures do not

that contains the provide clear guid-

approved methods and

ance for determina-

calculations for tion intake by in

determining intake of radio- vivo counting active

material (August 31,1985) (50-293/85-32-16)

31. 6.2.1k Order whole body Open

counter spare parts and/or

(50-293/85-32-17)

new equipment (as appro-

priate) (deferred to

November 30,1985)

32. 6.2.2-1(a,b,c) Establish Complete Guidance included in

guidance for the bicassay procedures

program to address:

a

selection of individuals

for non routine bioassays

review of data by super-

vision

work restrictions

33. 7.1.1-1 Develop a formal Open Licensee has estab-

summary / mat.-ix of all lished the summary /-

routine surveys matrix. However, pro-

(August 31,1985) cedure is in draft.

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(50-293/85-32-18)

34. 7.1.1-2 Determine if Complete Licensee determined

matrices addressing the calibration matrices

calibration are needed were not needed.

(August 31,1985)

35. 7.1.3-1 Review present Complete Licensee reviewed

procedures for types of applicable procedures.

surveys to be performed A summary / matrix was

and for ensuring survey established for routine

documentation is appro- surveys.

priate and approved.

(August 31,1985)

36. 6.2.2.e Develop program Opea Documentation not

for the routine comparison provided to demonstrate

of air sample, whole body closure of item

count and respiratory (50-293/85-32-19)

protection program data.

(September 30,1985)

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9

8

'

COMMITMENT STATUS NRC Comment

37. 7.1.4-1 Identify and Complete Procedure SR-RP-4702

implement if necessary

a frequency for changing

CAM filters. (August 31,

1985)

38. 7.1.5-1 Consolidate and Complete SI-RP-3000

Standardize air sampling

requirements. (August 31,1985)

39. 7.1.7-1 Evaluate present Cngoing Internal review program

practice for adequacy and currently reviewing, in

timeliness of radiological an on going fashion, the

surveys (on going) adequacy and timeliness

(August, September, October of surveys

1985)

40. 7.1.8-1 Complete procedure Open Licensee established

changes to improve account- group instruction to

ability and storage of survey improve accountability

and air sample data by and storage of data.

ensuring: (SI-RP-1002)

+ surveys located with RWPs Procedure in draft.

• document transfer to (50-293/85-32-20)

document control

• assigning long-term

responsibility

(September 30,1985)

41. 7.1.8-2 Complete evalu- Complete Licensee completed

ation and assign respon- evaluation and

sibility for account- assigned responsibility

ability and storage of

Radiological Group records

(September 30,1985)

42. 7.1.9 Evaluate the Open Procedure not established

of the frisker-only to incorporate recom-

analysis clean area

smears (August 31,1985) mendations (50-293/85-32-21)

43. 7.1.10-1 Evaluate methods to0 pen Procedure not established

reduce high to incorporate evaluation

minimum detectable findings (50-293/85-32-22)

activities currently

associated with alpha

smears, and incorporate

and use an appropriate method

(August 31,1985)

r

..

.-

4

9

COMMITMENT STATUS NRC Comment

44. 7.1.11-2 Order new area Complete Licensee evaluated

Radiation Monitors if the need for additional

required (August 31,1985) ARMS and determined

they were not needed.

45. 7.2.1 through 10, Item 3 Open Draft program in place.

Establish an restructured Final procedure and

RWP program. (September 30, program to be

1985) (Deferred to October 15, established

1985) (50-293/85-32-23)

46. 7.2.1 through 10, Item 4 Complete Revised material,

Approve training materials as appropriate should

for structured RWP program be provided to address

final program and

procedures (See

Item 7.2.1 through 10,

Item 3)

(50-293/85-32-24)

47. 7.3.2-2 Develop and Complete Licensee established

implement a contami- Nuclear Operators

nation control Policy (NDP) 85 RC1.

effectiveness review The NOP provides for

process (August 31, contamination control

1985) effectiveress review.

Implementation will be

reviewed during a

substv.ient inspection

48, 8.1.2-2 Consolidate Open 50-293/25-32-25

current radioactive

waste storage areas.

(September 30,1985)

(Deferred to December 30,

1985)

49. 8.1-3-3 Provide enclosure Open 50-293/85-32-26

to protect radioactive

material stored outdoors.

(September 30,1985)

(Deferred to November 30,1985)

50. 8.1.4-4 Shield consoli- Open 50-293/85-32-27

dated radwaste storage

areas (September 30,1985) 1

(Deferred to December 30,

1985)

.

&

10

CC$NITMENT STATUS NRC Comment

51. 9.1.1-3 Radiation Complete None

Protection Program

document will contain an

,

ALARA section. The section

will discuss shielding,

engineering controls, key

performance indicators, goals,

and procedures. (August 31,

1985)

52. 9.1.1-4 Approval ALARA Complete None

committee charter

(August 31, 1985)

53. 9.1.1-5 Define specific Complete Licensee defined

Key Management responsi- specific key management

bilities in the area of responsibilities in a

ALARA (September 30, 1985) Nuclear Operations

Policy (NOP)

54. 9.1.1-6 Approve ALARA Open The document was

section of Radiation approved g' the Radio-

Protection Program logical Group Section

documents (September 30, Head. The document

should be approved by

Station Management since

the document effects

-

the entire station.

(50-293/85-32-28)

55. 9.1.6-1 Incorporate Open Requirements incorpor-

revised RWP requirements ated into temporary into

RWP and ALARA pro- procedures. Procedures

cedures (September 30, should be made perma-

1985) nent. (50-293/85-32-29)

i

O

o

'<

11

-COMMITMENT STATUS NRC Comment

56. 9.1.7a, b-1 conduct Open Licensee performed a

a thorough, systematic review of PNPS areas,

review of PNPS for areas, systems, activities,

systems, activities, etc., that could benefit from

that require or would ALARA consideration.

benefit from ALARA consider- However, the criteria

ation (October 31, 1985) that was used to

determine if a system

or activity could

benefit from ALARA

consideration was not

specified.

Consequently, it was not

clear that all

appropriate activities

or systems had been

considered.

(50-293/85-32-30)

57. 9.1.8-1 Evaluate Complete None

programmatic controls

over the use of shielding

(August 31,1985)

58. 9.1.8.a through d, Complete None

Item 2 complete the

ALARA section of the

Radiation Protection

Program document.

(September 30,1985)

59. 10.1.3-3 Establish a Open Licensee Program

long term approach currently being

to housekeeping developed (50-293/

(October 15, 1985 85-32-31)

deferred)

60. 10.1.4-2 develop Complete Licensee performed

action plan for the review and the

review of the established procedures

issuance and control for issuance and control

of Health Physics of instrumentation

(August 31,1985) (SI-RP-5000). Pr.cedure

in draft

(50-293/85-32-32)

r-

0

o

e

12

61. 10.1.4-3 Order equipment Complete Additional instrument

as appropriate lockers were installied

to improve issuance and

control of health physics ,

'

instrumentation

(September 30,1985)

62. 10.1.6 Set up Instrument Complete None

storage racks.

(September 30,1985)

63. 10.2 1.a-2 Upgrade Open 50-293/85-32-33

whole body counting

equipment. Order

appropriate equipment,

including software

(September 30,1985)

(Deferred to November 30,

1985)

64. 10.2.5.c Implement Complete None

use of new calibration

jigs. (August 31,1985)

65. 10.2.6-2 Determine Complete The licensee evaluated

the need for new the need to obtain addi-

equipment to aid in tional equipment. Addi-

the conduct of Radio- tional equipment as

logical Group activities appropriate was

(August 31,1985) obtained/ ordered.

66. 10.2.8-2 Establish Complete None

group instructions

or procedures for

checking high efficiency

particulate filter units

for breakthrough.

(August 31,1985)

67. 12.2-2 Management to Complete Program outline approved

approve Radioactive

and Contaminated

Material Control

Program (August 31,

1985) (Deferred to

October 15,1985)

F

o

1

0

13

COMMITMENT

STATUS

I NRC Comment

68. ,

p-

12.2-3 Oraft Radioactive Complete Program document

Contaminated Material

Control Program document drafted. Facility modi-

and develop recommended fication recommended,

facility modification

(September 30,1985)

69. 13.3.1-1 Develop and Open

publish goals for the The goals did not appear

Radiological Group comprehensive or

challenging.

(50-293/85-32-34)

70. 13.3.2-1 Establish Complete

key performance Indicators contained in

indicators as guidance Nuclear Operations

for measuring performance Policy

and effectiveness of the

Radiation Protection Program.

(September 30,1985)

71. 13.4-1 Complete develop- Complete

radiation Draft documents ment of

protection program developed. Documents

documents to provide to be reviewed and

cohesiveness to the approved by December

31, 1985 Radiation

Protection Program (September 30,1985)

i