IR 05000293/1986016

Insp Rept 50-293/86-16 on 860414-17.No Violations Noted. Major Areas Inspected:Radiological Improvement Plan & post-accident Sampling & Analysis.Deficiency Noted in Area of Radiation Area Access Control

ML20195C449
Person / Time
Site:	Pilgrim
Issue date:	05/21/1986
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20195C432	List: IR 05000293/1986016 ML20195C430
References
50-293-86-16, NUDOCS 8605300327
Download: ML20195C449 (22)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-16 Docket N License No. DPR-63 Priority -

Category C Licensee: Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: April 14-17, 1986 Inspectors- ,&& W >. [ b-l f/.c)

, . L. Nimitz, Senior Radiation Specialist /date /

Approved b : A6 /d M.' Shanbaky, Chief,/

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date Facilities Radiation Protection Section Inspection Summary: Inspection on April 14-17, 1986. (Report No. 50-293/86-16)

Areas Inspected: Routine, announced inspection of the following: licensee action on previous findings; Radiological Improvement Plan; Post-Accident Sampling and Analysis; Radiological Control during the unplanned outage; and exposure. reportin Results: No violations were identified. Deficiencies were identified in the area of high radiation area access control and maintenance of emergency breathing apparatus qualification by reactor operations personne PDR 0 ADOCK 05000293 PDR

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1.0 Individuals Contacted 1.1 Boston Edison Company l

• C. J. Mathis, Station Manager

• Deacon, Assistant to Senior Vice President, Nuclear

• T. Sowdon, Radiological Section Head

• J. Crowden, Compliance Engineer 1.2 Nuclear Regulato,ry Commission

• McBride, Senior Resident Inspector

• denotes those individuals attending the exit meeting on April 17, 1986

The inspector also contacted other individual .0. Purpose of Inspecti_on ,

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The purpose of this routine, announced radiological controls inspection was to review the following matters:

• Licensee action on previous inspection finding *

Implementation of the Radiological Improvement Progra * Radiological Control for the Unplanned Outag *

Review of licensee response to the Post-Accident Sampling and *

Analysis inspection finding t

• Personnel Exposure Summaries sent to the NR .0 Licensee Action on Previous Inspection Findings

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3.1 (Closed) Follow-up Item (50-293/84-06-01) Licensee to upgrade his ALARA program to improve capabilities of ALARA personnel responsible for the performance of ALARA job assessments. Licensee also to .

improve methods for estimating man-rem expenditure:s. The licensee

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has established an ALARA training program for ALARA personnel. Also ,

the licensee is ypgrading his ALARA procedures. The implementation .

of the newly established ALARA training program and adequacy of procedures wi.il be reviewed in conjunction with follow-up item 50-293/85-32-2 t a

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3.2 (Closed) Follow-up Item (50-293/84-25-01) Licensee to establish and implement a program to train radiation protection technicians in new procedures and procedure changes. The licensee is currently establishing a progr.am to train and qualify radiation protection technicians in new procedures and procedure changes. The licensee's efforts in the area will be reviewed in conjunction with follow-up item 50-293/85-32-0 .3 (Closed) Follow-up Item (50-293/84-25-02) Licensee to upgrade posting of radiological controlled areas to ensure compliance with 10 CFR 20.203. The licensee revised his procedure to ensure c6mpliance with 10 CFR 20.20 .4 (Closed) Follow-up Item (50-293/85-02-01) Licensee to review and implement reconnendations regarding internal exposure control of alpha emitters. The licensee reviewed and implemented (as necessary)

the recommendations contained in a September 1984 contractor report of alpha emitters at Pilgrim Statio .5 -(Closed) Follow-up Item (50-293/85-13-05) Licensee to ensure radioactive waste shipping procedure controls provide for compliance with Certificate of Compliance (C of C) cask seal change-out requirements. The licensee radioactive waste shipping procedures provided for review and compliance with the cask C of C. Cask seal change-out dates are determined and compared to change-out requirements of the C of .6 (Closed) Deviation (50-293/85-13-13) Licensee did not implement IE Bulletin 80-10. The licensee implemented corrective action consistent with his August 15, 1985 letter to NRC Region I. The licensee is currently establishing controls to ensure Watch Engineers initiate appropriate action when they are notified of contamination of normally noncontaminated system The licensee's action in this matter will be reviewed in conjunction with follow-up item 50-293/85-22-0 .7 (0 pen) Follow-up Item (50-293/85-22-05) Licensee to resolve the fo.ilowing matters associated with the unplanned release of airborne radioactive material from the Hot Shop vent: Evaluation of offsite releases with respect to 10 CFR 20.106, Evaluation of onsite releases with respect to 10 CFR 20.103, Close-out of applicable Radiological Occurrence Reports '

and Failure and Malfunction Reports, Completion of a safety evaluation for further operation of "liot $ hop" exhaust ventilation (including need to monitor this release point),

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Source of contamination of duct work in Control Room Corridor

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and HP Count Room, Design change methodology to preclude recurrence, and Update of Final Safety Analysis Report to reflect actual conditions of " Hot Shop" are The adequacy of licensee action on these matters was determined from:

discussions with personnel, independent inspector review of calculations performed by the licensee and review of procedures / documents.

Findings

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Item a: The licensee evaluated the offsite releases. No apparent release in excess of 10 CFR 20.106 occurred. This item is close Item b: The licensee evaluated the onsite releases. No apparent exposure

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in excess of 10 CFR 20.103 occurred. This aspect is close Note: Licensee to provide surveys / evaluations of extent of onsite soil contamination at base of release point. This matter j is ope Item c: Open: No information provided to demonstrate resolutio Item d: Open: No information provided to demonstrate resolution. The non-monitored release points from the hot shop are currently blocked close Item e: Open: No information provided to demonstrate resolution.

Item f: The licensee established procedure NED 3.02, " Preparation, .

Review. Verification, Approval and Revision of Design Documents for Plant Design Changes," subsequent to conversion of the L machine shop to a hot shop. The procedure provides for l radiological controls reviews of plant design changes. This item is close Item g: Open: No information provided to demonstrate resolution.

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3.8 (0 pen) Follow-up Item (50-293/85-22-03) Licensee to complete evaluation of facility design with respect to IE Bulletin 80-10,

" Contamination of Nonradioactive System and Result Potential for Unmonitored/ Uncontrolled Release to the Environment." The licensee completed his assessment of normally clean systems on January 28, 1986 with respect to the criteria contained in IE Bulletin 80-10. A sampling and analysis program and schedule is in place to address sampling requirements contained in the bulletin. The licensee issued a memorandum to Watch Engineers describing their actions when a normally non-contaminated system is identified as contaminated.

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l Inspector discussions with one Watch Engineer indicated he was unaware of this memorandum. The license is taki.ng action to address this matter. This ite~m remains ope .9 (Closed) Follew-upItem(50-293/85-22-09) Licensee to develop and j implement a training program to ensure personnel are trained in new procedures. The licensee is curr.ently establishing his program to

! train personnel .in new procedures. The licens&e has established an i

action plan with Milestones to train personnel in reyised procedures resulting from Radiological Improvement Plan commitments. 'The

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licensee's efforts in the area will be reviewed in conjunction with follow-up item 50-293/85-32-0 .10 (0 pen) Follow-upItem(50-293/85-22-11) Licensee to upgrade <

procedures for determination of personnel skin dose. Procedures do l not provide limitations for use of ski.n dose conversion factors or limitations of instruments used for measuring skin dose. This item  ;

remains open. (See Radiological Improycment Plan Item 4 1.3-2).

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3.11(Closed) Follow-up Item (50-293/85-22-12) Licensee to upgrade ,

physical controls of high radiation areas. The licensee upgraded  :

. physical control of high radiation areas in accordance with Radiological Improvement Plan Commitment No. 4.3.2. The licensee is currently revising his procedure for high radiation area access

, control to address NRC identified deficiencies. These will be reviewed in conjunction with follow-up item No. 50-293/85-32-1 (See Radiological Improvement Plan Item 4.3-2).

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3.12 (Closed) Follow-up Item (50-293/85-22-13) Licensee to establish a  !

non-radiological respiratory protection program. The licensee established procedure No. 1-4.32, " Industrial Respiratory Protection." The procedure established the non-radiological respiratory protection program at Pilgri i 3.13 (0 pen) Follow-up Item (50-293/85-22-16) Licensee to upgrade his radiological occurrence report program to provide for: clear identification of problems; notification of appropriate levels of management;'and implementation of lasting corrective actions. The licensee is currently ' reviewing and revising his program relative to these matters. The licensee plans to implement corrective actions as appropriat .14 (Closed) Follow-up Item (50-293/85-32-04) Licensee established position-specific personnel selection criteria which was inconsistent with Technical Specifications. The licensee revised the selection  !

criteria to make them consistent with Technical Specification .

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3.15 (Closed) Follow-up Item (50-293/85-32-06) Licensee to review Health Physics Technical personnel training program. The licensee reviewed the training program. Documentation was available to demonstrate rasolution of review finding .16 (Closed) Follow-up Item (50-293/85-32-08) Licensee to approve draft procedure for resolving TLD discrepancies. The licensee approved the procedure. This closes Radiological improvement Item 4.1.lb- .17 (Closed) Follow-up Item (50-293/85-32-10) Licensee to establish and

' implement procedures for performing A1 ARA review of on going wor The licensee is currently reviewing and revising his ALARA progra Licensee efforts in establishing a program for performing on going job reviews will be reviewed in conjunction with follow-up item 50-293/85-32-2 .18 (open) Follow-up Item (50-293/85-32-12) Licensee to address airborne radioactivity sampling and analysis program deficiencies. The ifcenses has addressed the following matters; dead time correction, identification of pure be a emitters, trigger levels requiring supervisor review of pure beta ettitter air sample results, minimum sample v.olumes and count times, self-absorption correction factors, and selection of MPCs based on nuclide solubility. The following eatters renain open; resolution of filter loading concerns, and

- approval of revised procedures (See Radiological Control Improvement Ites 5.2.lb-1).

3.19-(Closed) follow-up Item (50-293/85-32-17) Licensee to order spare whole body counter parts and/or order new equipment in accordance with Radiological Improvement Plan Commitment No. 6.2.1k. The licensee ordered four new whole body counters. The counters are on site and ans awaiting set-u .20 (Closed) follow up Item (50-293/85-32-24) Licensee to restructure Radiation Work Permit procedure and approve training material. The licensee restructured the RWP program. Training will be reviewed in conjunction with follow-up item 50-293/85-32-0 .21(0 pen) Follow-up Iten (50-293/85-32-27) Procedures do not contain guidance nelative to the necessity of shielding areas or material (e.g. new radioactive waste storage location) not currently shielde Licenses currently evaluating this matte .22.(Clcsed) Follow-up Item (50-293/85-32-30) Criteria used by licensee for performing ALARA review of station systems and component not provided. The licensee used general criteria in evaluating systems and conpanents that could benefit from implementation of ALARA techniques. The criteria included personnel occupancy, conta'aination levels, and dose rates. Those systems or components which could benefit from ALARA considerations were recommended for ALARA action l . .-

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. 7 3.23(Closed) Follow-up Item (50-293/85-32-31) Licensee to establish a housekeeping program in accordance with Radiological Improvement Plan. The licensee has established and is implementing a housekeeping program. The program includes a Nuclear Operation Policy (No. 83-04), a Nuclear Policy Statment on Housekeeping (Policy 35), and a housekeeping inspection progra .24 (Closed) Follow-up Item (50-293/85-32-33) Licensee to upgrade whole body counting equipment in accordance w tt Radiological Improvement plan. The licensee purchased four new wole body counters. The counters are being tested. Appropriate procedures will be written prior to use of the counte .25 (Closed) Follow-up Item (50-293/86-02-03) Licensee to evaluate airborne radioactivity sample analysis errors and initiate appropriate corrective action. The licensee evaluated and corrected the analysis errors. The errors involved failure to correct for dead time losses and selection of appropriate 10 CFR 20 Appendix B limiting concentration values based on solubility of radionuclide .26 (0 pen) Follow-up Item (50-293/86-02-05) Licensee to re-evaluate the need to use' continuous air monitors (CAMS). The licensee's re-evaluation indicates CAMS should be used for routine airborne radioactivity monitoring purposes. The licensee had initiated action to obtain additional CAMS and upgrade procedures for use of the CAM .27 (Closed) Follow-up Item (50-293/86-02-06) Licensee to develop and implement an expanded engineering controls program and incorporate applicable methods into training and procedures. The licensee established an ALARA training program which includes use of engineering controls. This matter is closed. The development and implementation of procedures for use of engineering control will be reviewed in conjunction with follow-up item 50-293/85-32-29. (RIP Item 5.2.2-1).

3.28 (Closed) Follow-up Item (50-293/86-02-07) Licensee to establish procedures for use of whole body counting phantoms. The licensee established and implemented procedure for use of phantoms (SI-RP-5113). Appropriate individuals were trained on the new procedure. (RIP Item 6.2.lb-1).

3.29 (Closed) Follow-up Item (50-293/86-02-08) Licensee to verify capability of Trash Compactor Facility effluent monitor to collect representative samples. The licensee repositioned the sampler in close proximity to the isokinetic probe. This eliminated collection of a sample that had passed through a 20 foot section of tygon. tubin '.* .

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• 8 4.0 Implementation of Licensee Commitments Presented to NRC in the Radiological Improvement Program (RIP)

4.1 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 contained in the following documents:

• Order Modifying Licensee, Notice of Violation, and Notice of Deviation (NRC Inspection No. 50-2,93/84-25 and 50-293/84-29),

dated November 29, 198 * 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 Requirement Analysis Forms (various) relative to Radiological Improvement Plan (RIP)

Milestones,

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a Licensee Radiological Activity Assessment Reports (RAAR)

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• 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, 198 * NRC Inspection Report No. 50-293/85-32, dated December 31, 198 =

NRC Inspection Report No. 50-293/86-02, dated March 10, 198 :

4.2 Findings The inspector reviewed 34 items associated with the Radiological Improvement Program. The status of these items are presented in the attachment to this inspection report. The licensee adequately -

addressed 13 of-the item The licensee's action on the remaining items will be reviewed during a subsequent inspectio .0 Radiological Controls for the Unplanned Outage The inspector reviewed the implementation and adequacy of radiological controls for selected aspects-of the unplanned outag .- . . - , -- _-,_ _ . . . - . - _ . . . - _ _ _ . _ _ , . - . _ . _ _ . _ . _ _ _ - _ - . . .-

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The following matters were reviawed:

adequacy and adherer.ce to radiation work permits;

• adequacy of radiation and airborne radioactivity surveys; and

• high radiation area access contro The evaluation of the licensee's performance in this area was based on:

• discussions with personnel;

• review of selected on going activities;

• review of procedures; and

* review of radiological surveys, i The following matters requiring licensee attention were identified:

Procedures and radiological contrcls technician briefings of workers did not provide sufficient guidance to ensure compliance with the high radiation area control requirements of Technical Specification 6.1 The licensee initiated a review of this matter. The licensee is currently revising his high radiation area control procedure The revision will incorporate measures to address the identified deficiency. See follow-up item 50-293/85-22-12 discussed in section 3 of the report.

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Establish an effective mechanism to notify personnel (where appropriate) of upcoming expiration of respiratory protection equipment use qualificatio A majority of nuclear watch operations personnel were found

unable to wear self-contained breathing apparatus (SCBA) due to

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lack of full qualification.

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The licensee initiated action to address this matte The licensee's action to establish a mechanism to notify personnel of upcoming expirations of SCBA qualifications will be reviewed during a subsequent inspection. (50-293/86-16-01)

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6.0 Review of-Licensee Response to NRC Inspection 50-293/85-27, l h

Post-Accident Sampling System and Analysis Capability" The inspector reviewed the adequacy of the licensee's February 13, 1986 response (BEco Letter No.86-012) to the findings of the special Post-Accident Sampling and Analysis Inspection (50-293/85-27).

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L Findings The licensee provided an acceptable response to 47 of the 51 items for improvement listed in report 50-293/85-27. The licensee provided additional information relative to the four remaining items as follows:

• Item 50-293/85-27-10 Clarify commitments and capabilities relative to pH analysis of post-accident liquid sample The licensee is currently generating a safety evaluation (SER)

relative to implementation of Regulatory Guide 1.97 guidance. This

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safety evaluation will address pH and will be submitted to NRC. The licensee will provide justification in his SER as to whether pH analysis will or will not be performed on post-accident liquid sample * Item 50-293/85-27-14 Establish a spare parts program for the Post-Accident Sampling System (PASS).

The licensee has established a new procurement group. This group will review the PASS to determine what spare parts should be available. The licensee is coordinating the program development with the BWR owners grou * Item 50-293/B5-27-16 Finalize agreements with Millstone personnel relative to the back-up

post-accident sample analyses Millstone station personnel will l perform.

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The licensee has verbally finalized an agreement with Millstone personnel regarding this matter and plans to place this agreement into an documen * Item 50-293/85-27-21 Evaluate the need to install charcoal filters in the exhaust of the chemistry lab hood.

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l The licensee performed an evaluation of the need to install charcoal filters in the hood. The licensee's evaluation concluded that charcoal filters were not needed. NRC will review the evaluation during an subsequent inspection.

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The licensee's implementation of commitments provided in his February 13, 1986 letter and the licensee's action on the above four matters will be reviewed during an subsequent inspection.

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. 11 7.0 Review of 1985 Annual Exposure Report (Regulatory Guide 1.16 Report)

The inspector reviewed the licensee's 1985 Regulatory Guide 1.16 Report (BECo Letter No.86-025 dated February 28,1986).

The review was performed to determine if reporting was consistent with Regulatory Guide 1.16 guidance and applicable Technical Specification Within the scope of the review, the following matters needing licensee attention were identifie *

The report did not provide sufficient information to explain the l licensee's inability to meet the 80% exposure reporting criterion contained in the Technical Specifications. The licensee accounted for only 73% of the in-field personnel exposur * The report did not provide sufficient information to justify subtraction of 50% of the background exposure sustained by TLDs badges while in storage. The badges sustained a total cumulative exposure

of about 370 man-rem in 198 Licensee representatives indicated a revised 1985 Regulatory Guide 1.16 report will be submitted to address these matter .0 Exit Meetings The inspector met with-licensee personnel (denoted in Section 1) at the conclusion of the inspection on April 17, 1986. The inspector summarized

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the purpose, scope and findings of the inspection. No written material was provided to the license i

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ATTACHMENT TO REPORT 50-293/86-02 Status of Boston Edison Company's Radiological Improvement Program (RIP)

Commitment Status NRC Comments 1. 2.2.7-1 Develop Closed The licensee is and implement a program currently establishing to ensure personnel all program element are trained in new An action plan has been procedures. May 31, 1985 developed to train all personnel in new and revised procedures associated with RIP commitments. This item will be reviewed in conjunction with Item 50-293/85-32-05. This closes follow-up item 50-293/85-22-0 . 4.1.la-1 Evaluate the Open The licensee evaluated effectiveness of the the effectiveness of extremity dosimetry the extremity dosimetry program and ensure that program and revised guidance for calculating appropriate procedures and recording extremity (SI-RF-2402). However, exposures is adequat extremities were not de-(September 30,1985) fined (50-293/85-32-07)

3. 4.1.lb-2 Provide Closed The licensee established additional guidance and a> proved procedures for resolving TLD which include additional discrepancie guidance for resolving (September 30,1985) TLD discrepancies. This closss item 50-293/

85-32-0 . 4.1.2b-1 Develop support Closed 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 vendo true beta dose by a (October 31,1985) factor of about Licensee has modified factor used and; is reviewing previous beta l

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. 2 Attachment exposure data to determine need for correction of personnel

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exposures.(50-293/

85-32-09 remains open)

5. 4.1.3-2 Develop Open Licensee established guidance for procedure for assigning skin determining skin dos exposure (July 31, 1985). Procedure does not:

• define / explain-limitations of instrument *

define / describe limitations of skin dose correction facto Follow-up Item ,

(50-293/85-22-11)

remains ope . 4.1.4-1 Evaluate proce- Closed Licensee addressed dural guidance for the exposure trending in the evaluation of dosimetry Radiation Protection data. Address ALARA Program document. The exposure trending in the licensee is currently ALARA section of the reviewing and revising Radiation Protection his ALARA Program.

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Program documen Licensee efforts in (October 31,1985) this area will be l' reviewed in conjunction with follow-up item I

50-293/85-32-29. This closes item 50-293/85-32-10.

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7. 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 status board was established and a new procedure was drafted to

provide administrative controls over access to high radiation areas, i

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. 3 Attachment The following matters do not appear to have been addressed:

(50-293/85-32-11)

• minimum training /

qualification of person issuing and receiving key * updating of high rad status boar * compliance with selected techni-cal specifica-tion . 5.2.1 a-2 Evaluate Closed The licensee evaluated the Use of Alarming the need to use alarm-CAMS. Modify Air ing Continuous Air Sampling Program Monitors. It was as appropriat determined that CAMS (December 31,1985). were needed. The licensee is currently ordering CAMS and will write appropriate procedures for their us This closes follow-up item 50-293/86-02-0 Establishment of Program procedures will be reviewed during a subsequent inspection. (50-293/

86-16-02).

9. 5.2.lb-1 Evaluate the air Open The licensee established sampling program to deter- a revised air sampling mine if appropriate air procedur However, samples are being obtaine the following matters (October 31,1985) remain open. (50-293/

85-32-12).

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resolution of filter loading correctio * approval of revised procedure * *

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.- 4 Attachment 10. 5.2.2-1 Develop Closed The licensee and implement an established expanded engineering three separate control progra ALARA training Incorporate applicable courses. The methods into training courses address and procedure engineering (December 31,1985) control Development of program procedures will be reviewed in conjunction with follow-up item 50-293/85-32-2 , 6.1.1-1 Establish, Open Licensee approve, and implement established, a procedure and/or a approved and group instruction implemented a for the routine perfor- group instruc-mance of an in-vitro tion for perfor-bioassay progra mance of an in-(September 30,1985) vitro bioassay progra (SIRP.2100)

Procedures do not provide. clear guidance for determination of intake (i.e.,

MPC-hourexposure)

(50-243/85-32-13)

12. 6.1.2-2 Determine the need Open The licensee uses for a QA program for the the services of commercial, off-site Yankee Labs for analytical laborator performance of Develop QA procedure analytical wor and/or group instruction The acceptability as neede (October 31,1985) of the lab is reviewed once a year by a utility committee consisting of members from diferent utilities who use the la This is acceptabl : ,

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5 Attachment The inspector was unable to determine what controls are inplace to ensure review of acceptability of other analylical labs if neede . 6.2.1.b-1 Closed Licensee validated Validate bench bench mark of whole mark of whole body counter body counter Procedures written using sources for use of phanto (one month This closes item following receipt 50-293/86-02-0 of sources).

14. 6.2.11 Develop procedure Open Procedures do not that contains the provide clear guid-approved methods and ance for determina-calculations for tion of intake by determining intake of radio- invivo counting active material (August 31,1985) (50-293/85-32-16)

1 .2.19-1 Review procedures Open Procedure 6.2-161 and resolve any discrep- be revised to ancies in recommended reflect new internal deposition action procedures (SI-RPs)

levels and external contami- (50-293/85-32-15)

nation limits. (August 31,1985) (i.e., cross referenced).

1 .2.1k Order whole body Closed The licensee counter spare parts and/or obtained four new equipment (as appro- new whole body priate). (deferred to counter This November 30,1985) closes item 50-7.93/85-32-1 . 6.2.2.e Develop program Open Documentation not for the routine comparison provided to of air sample, whole body demonstrate count and respiratory closure of item protection program dat (50-293/85-32-19)

(September 30,1985)

1 .1.1-1 Develop a formal Open Licensee has summary / matrix of all established the routine survey summary / matri . . . . .-

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. 6 Attachment (August 31,1985) However, procedure is in draf (50-293/85-32-18)

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19. 7.1.8-1 Complete procedure Open Licensee changes to improve account- established group ability and storage of survey instruction to and air sample data by improve account-ensuring: ability and

• surveys located with RWPs storage of dat *

document transfer to (SI-RP-1002)

document control Procedure in draf * assigning long-term (50-293/85-32-20)

responsibility.

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20. 7.1.9 Evaluate the adequacy Open Procedures do not of the frisker-only incorporate recom-analysis of clean area mendations smears. (August 31,1985) (50-293/85-32-22)

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21. 7.1.10-1 Evaluate method to Open Procedure not reduce high minimum established to detectable activitites incorporate

, currently associated with evaluation findings alpha smears, and incorporate (50-293/85-32-21)

and use an appropriate metho (August 31,1985)

22. 7.2.1 through-10, Item 3 Closed The licensee Established a restructured restructured his RWP progra (September,1985) RWP program to (Deferred to October 15, 1985). address, in part, the deficiencies identified in inspection report 50-293/86-02. The following matters remain open:

• Establish control.to pro-vide for review of long duration jobs in low dose rate areas to ensure inter-face with ALARA Progra .

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. 7 Attachment

• Approve the procedur Follow-up item 50-293/85-32-23 remains ope . 7.4 Procure, install Closed Licensee installed and turnover airborne effluent monitor-effluent monitoring ing equipment in equipment for the Trash the Trash Compactor Facilit Compactor Facilit (December 31,1985) The monitor / sampler was repositioned to collect re-presentative samples. This closes item 50-293/86-02-0 . 8.1.4-4 Shield Closed Consolidated areas consolidated radwaste shielded where storage area necessary. No (September 30, 1985 " trigger" levels deferred) identified requiring shielding of areas currently not shielde Item (50-293/85-32-27 remains open).

2 .1.7 ab-1 complete Closed Licensee performed systematic review of a review of systems PNPS for systems and and components that

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. components that could could benefit from t benefit from ALARA ALARA

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consideratio consideration.

Review criteria were general. A summary of the criteria was provided. No unacceptable i conditions were

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closes follow-up item 50-293/85-32-30.

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8 Attachment 26, 9.2.1 through 4 Closed The licensee Develop an ALARA developed three Training Program to separate ALARA accomplish the following courses: one for objectives: crafts personnel (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

• Demonstrate Management's duration); one desire and commitment for non-radio-to improving the radio- logical controls logical controls program supervisors (12 at PNPS; hours duration);

and one for

- Help formulate a more radiological positive "can do" attitude; controls personnel (40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> duration);

• Help formulate better worker The courses include habits with respect to radio- the attributes logical controls; and, listed. A schedule has been establish-

• Sensitize all levels of ed for initial personnel to the benefits presentation of the to be derived from actively courses. This implementing ALARA principles closes follow-up in their everyday work habit item 50-293/

86-02-0 * Develop specialized training Implementation of for crafts with emphasis on the training the following: (Section 3.2) schedule will be reviewed during

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Mockups; subsequent

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Special tooling; inspection Radwaste Minimization;

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ALARA; and,

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Contamination contro . 10.1.3-3 Establish a Closed The licensee long term approach established and to housekeepin implemented an

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(October 15, 1985 housekeeping deferred) program. This closes item 50-293/85-32-31 2 .2.1.a-2 Upgrade Closed The licensee whole body counting obtained four equipment. Order new whole body appropriate equipment, counters. This including softwar closes item (September 30,1985) 50-293/85-32-3 (Deferred to November 30, 1985)

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. 9 Attachment 29. 11.1-2 Develop, maintain Open The licensee has and implement new and revised and existing Radiological reissued the Group Procedures in majority of his accordance with the radiological Procedure Improvement controls proce-Plan. (December 31, 1985) dures. The licensee is currently addressing NRC and INP0 identified procedure deficiencies and is re-reviewing approximately 35 procedures. This commitment remains open pending:

1) licensee correction of identified procedure deficiencies, and 2) review, and revision (as necessary) of identified procedure deficiencie . 11.7-1 Review and Open The licensee is revise current currently review-Radiological Controls ing and revising procedures which affect procedures to a similar precess to address self-ensure that the same identified and action levels are INP0-identified used for identical deficiencies activitie Review and is currently current procedures re-reviewing to correct any deft- approximately 35 ciencie (December 31,1985) previously issued procedures to identify and correct deficiencie This area remains open pending:

licensee action on item 11.1-2 (50-293/

86-02-10).

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10 Attachment 3 .1 and 1 Open The licensee (milestone 4) reviewed and Approve Plan for approved the-Control of Radio- Radioactive active Material and Materials Control authorize recommended Program. No facility modification facility modifications were identified requiring authorizatio The following matters remain open:

1) Formal incorporation of the program into the station procedure progra ) Resolution of need for Radioactive Material Control Program Manager 3) Verification that procedures are-inplace to implement the progra (50-203/86-02-11).

3 .3.1-1 Develop Open Licensee currently and publish goals establishing goals for the Radiological and goals program Controls Grou Item 50-293/

(August 31,1985) 85-32-34 remains ope . 13.4-2 Develop and Closed The following approve a Radiation matters remain Protection Pla open:

(December 31,1985). (50-293/86-02-12)

= vertification that all elements of the described program have

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11 Attachment associated implementory procedure . 14.1-1 Expand the Open The following current corrective matters remain action system to include open:

a follow-up evaluation of significant events * Completion (July 31, 1985) of additional procedures identified in licensee program revie * Provision of timely review of significant event * Implementation of timely corrective action to prevent recurrenc * Documentation of corrective action Follow-up item 50-293/85-22-16 remains ope i