ML18078A374

Responds to 780906 NRC Ltr Re Deviation Noted in Inspec Rept #50-272/78-18.Util Claims Alleged Violation Was Not & Did Not Represent Noncompliance w/10CFR50.59 Since Subteired Procedures Are Controlled by QA Prog to Comply W/Fsar

ML18078A374
Person / Time
Site:	Salem
Issue date:	09/29/1978
From:	Schneider W Public Service Enterprise Group
To:	Grier R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML18078A372	List: ML18078A374
References
NUDOCS 7811130119
Download: ML18078A374 (28)

See also: IR 05000272/1978018

Text

.-* Frederick

W. Schneider

Vice President

Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373

Production

• -* Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory

Commission

Office of Inspection

and Enforcement

Region 1 631 Park Avenue King of Prussia, Pennsylvania

19406 Dear Mr. Grier: NRC INSPECTION

REPORT NO. 50-272/78-18

SUPPLEMENTAL

INFORMATION

NO. 1 UNIT SALEM NUCLEAR GENERATING

STATION September

29, 1978 Pursuant to your letter of September

6, 1978 in response to our letter of August 11, 1978, we acknowledge

that revision to Operational

Quality Assurance

Instruction

Number 5, "Auditing," to a two-year audit cycle constituted

a noncompliance

with our FSAR commitment.

It also was noncompliant

with Admiriistrative

Procedure

17, "Operational

Assurance

Program," which is subject to review and approval by the Corporate

Quality Assurance

Department.

Please be advised that the Operational

QA Program was not, and can not, be changed by revising subtier procedures

such as OQI's. The "premature" revision to OQI-5 was identified

by Corporate

QAD in March, 1978 and brought to the attention

of the Salem Generating

Station by letter dated March 13, 1978. The Manager -Salem Generating

Station was therefore

apprised of the noncompliance

with recommended

corrective

action by Corporate

QAD well in advance of your May 2-5, 1978 inspection.

This compliance

was appropriately

identified, documented

and seminated

under the provisions

and controls of the QA Program and there was no intent to permit this item to remain uncorrected.

'1811130111

• ... ... * ... ' '."' Mr. B. H. Grier -2 -9/29/78 As previously

stated in our response dated August 11, 1978, the subject item of noncompliance

did not represent

noncompliance

with lOCFRS0.59

since subtiered

procedures

are controlled

by the QA Program to assure continuing

compliance

with our FSAR as demonstrated

in this case. CC: Director-Inspection

and Enforcement

Bethesda, Maryland 20014

UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA

19406 Public Service

Electric and Gas Company ATTN: Mr. F. W. Schneider

Vice President

-Production

80 Park Place Newark, New Jersey 07101 \. Gentlemen:

Subject: Inspection.

50-272/78-18;

50-311/78-13

SEP 6 1978 This refers to your letter dated August 11, 1978, in response to our letter dated June and July 19, 1978. Your letter requested

clarification

of the word "annual".

As noted in our report, annual (when used to describe.

the frequency

for auditing a particular

activity)

means that the activity must be audited within 12 months following

the last review of the area. Further clarification

is given in your Technical

Specification, Section 6.5.2.8, Audits, which requires aud.its of the. conformance

of the facility to the Technical

Specification;

and the performance, training and qualifications

of the facility staff " .*. at least once per 12 months.11 For example, an audit of the performance, training and .qualification

of personnel pleted on October 15, 1976, is required to be performed

agai'n by October 15, 1977. . Regarding

your comments concerning

the item of noncompliance, although only Procedure

OQI-5 was changed, this procedure

effected actual mentation

of your FSAR commitment

for an annual audit frequency.

As noted in our report, superceding

this FSAR commitment.

by changing cedure OQI-5 without an evaluation

in accordance

with 10 CFR 50.59 stitutes noncompliance.

We note that your effort to amend OQI-5 to reflect the annual ment and to complete all of the requ.ired

audits in a timely manner appears as effective

corrective

action for this item of noncompliance.

This action will be examined in a subsequent.inspection

of your licensed pr.ogram.

L-*-------

-*----*-... -, Public.Service

Electric and Gas Company 2 Your cooperation

with us is appreciated.

cc: Sincerely, !lf<P fl .$4_._;r Boyle H. Grier Director F. P. Librizzi, General Manager -Electric Production

E. N. Schwalje, Manager -Quality Assurance

R. L. Mittl,

Managerr -Licensing

and Environment

H. J. Midura, Manager -*sa l em Generati_n*g

Sta ti on

Frederick

W. Schneider

Vice President

Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373

Production

Mr. Boyce H. Grier Director of USNRC August 11, 1978 Off ice of Inspection

and Enforcement

Region 1 631 Park Avenue King of Prussia, Pennsylvania

19406 Dear Mr. Grier; NRC INSPECTION

REPORT NO. 50-272/78-18

MAY 2 -5, 1978 UNIT NO. 1 SALEM NUCLEAR GENERATING

We have reviewed the report of your inspection

conducted

on May 2 -5, 1978, which was transmitted

with your letter of July 19, 1978, and received on July 24, 1978. Our response to the item of noncompliance

is as follows: Item A. Infraction, in NRC Inspection

50-272/78-18, Appendix A: 10 CFRS0.59, "Changes, tests and experiments", states in part, "The holder of a license authorizing

operation

of a production

or utilization

facility may ... make changes in the procedures

as described

in the safety analysis port ..* without prior Comr.i.ission

approval, unless the posed change ... involves a change in the technical fications

incorporated

in the license or an unreviewed

safety question ... " Contrary to this requirement, a change was made in a procedure

described

in the safety analysis report, namely, the Salem Generating

Station Operational

Quality Assurance

Instruction

Number 5, "Auditing 11 , without a determination

of whether or not the change involved an unreviewed

safety question.

Reply: The activity described

in Appendix A, appears to be a standing between the station QA Engineer (SQAE) and the spector, rather than a violation.

This is explained

in the following:

Inspection

Report No. 50-272/78-18 -2 -8-11-78 Regulatory

Guide 1.33 and ANSI 45.2.12 are spelled out in Salem FSAR and are the basis for our operational

audit program. The latest revisions

of these two standards

are: (a) Regulatory

Guide 1.33 "Quality Assurance

Program quirements (Operation)

Rev. 1, February 1978." (b) ANSI N45.2.12 "Requirements

for Auditing of Quality Assurance

Programs for Nuclear Power Plants -1977." By examining (a) and (b) the SQAE realized that NRC guidance, as well as industry practice on the minimum audit period quirement, has changed from a cycle of one year to a cycle of two years. Therefore, he proposed a revision in the applicable

FSAR section for Unit 2 to reflect a two year cycle. He then submitted

this revision to Company management

for approval and submittal

to the NRC with the understanding

that the revised FSAR will apply to both Units 1 and 2. Since the audit cycle could not be changed prior to the approval of the revision of the FSAR, the SQAE prematurely

revised ""?" ational Quality Instruction

No. 5 (OQI-5). This instruction

is not part of the FSAR and its revision did not constitute

a change --T pursuant to 10CFR50.59.

During the first week of May 1978, the SQAE realized that the approval of his proposed revision to the FSAR would not be ceived in time to permit him to switch to a two year cycle. For this reason, and because of the inspector's

comments during his visit, OQI-5 was revised back to a cycle of one year, and the SQAE proceeded

to complete the audits within one year. We hope this explanation

is satisfactory

to show.that

no tion was involved in our activity.

Inspection

Report No. 50-272/78-18 -3 -8-11-78 We would also lik.e to bring to your attention

an area that needs clarification.

In the middle of page 5 of his report, the spector interpreted "annual" to be "once within each 12 month interval following

the last previous audit of the same area." We interpret "annual" differently, i.e. "once in a calendar year." In conclusion:

1. All audits shown in our implementing

documents

will be pleted prior to the end of the annual audit cycle. 2. The latest available

revisions

of regulatory

guidance to which the FSAR is committed, suggest that audits of all safety related functions

be completed

within a period of two years. 3. In light of 1. and 2. above, it is suggested

that the activity described

in Appendix A of your report is not a violation, but a misunderstanding

as explained

in this letter. If you require additional

information, we will be pleased to discuss it with you. Sincerely, CC: Director -Inspection

and Enforcement

Bethesda, Maryland 20014

UNITED STATES NUCLEAR REGULATORY

COMMISSION

REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVANIA

19406 Public Service Electric and Gas Company ATTN: Mr. T. J. Martin JUN 1 2 W13-Vice President

-Engineering

and Construction

Mr. F. W.

• Vice President

-*Production

80 Park Place Newark, New Jersey 07101 Gentlemen:

Subject: Inspection

50-311/78-13;

50-272/78-18

This refers to the inspection

conducted

by Mr. J. R. White of this office on May 2-5, 1978, at Salem Nuclear Generating

Station, of activities

authorized

by NRC Permit No. CPPR-53 and DPR-70 and to the discussions

of our findings*held

by Mr. White with Mr. H. J. Midura of your staff at the

of the inspection, and to a subsequent

telephone

discussion

between Mr. White and Mr. J. L. Stillman of your staff on May 15, 1978. * Areas examined during this inspection

are described

in the Office of Inspection

and Enforcement.

Inspection

Report which is enclosed with this letter. Within these areas, the inspection

of selective

examinations

of procedures

and representative

records, interviews

with personnel, measurements

made by the inspector,.

and observations

by the inspector.

• Based on the results of this inspection, it appears that one of your *activities

was not conducted

in full compliance

with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance

has been categorized

into the levels as described

in our correspondence

to you date*d December 31, 1974. This

is sent to yob pursuant to the provisions

of Section 2.201 of the NRC's "Rules of Practice-," Part 2, Title Code of Federal Regulations.

Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement

or explanation

in reply including:*-

(1) corrective

steps which have been taken by you and the results (Z) corrective

steps which will be taken to avoid further items of noncompliance;

and (3.) the date when full compliance

will be achieved.

.... *-----------.

.. -. --. -**--=-===================---......,;;;;;,,

Service Electric and Gas Company 2 In accordance

with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures

will be placed in the NRC 1 s Public Document Room. If this report contains any information

that you (or your contractor}

believe to be proprietary, it is necessary

that you make a written application

within 20 days to this office to withhold such information

from public disclosure.

Any such application

must be accompanied

by an affidavit

executed by the owner of the information, which identifies

the document or part sought to be wi.thheld, and which contains a statement

of reasons which addresses

with specificity

the items which will be considered

by the Commission

as listed in subparagraph (b)(4} of Section 2.790. The informatian

sought to be withheld *shall be incorporated

as far as possible into a separate part of the affidavit.

If we do not hear from you in this regard within the specified

period, the report will be placed in the Public Document Room. Should you have any questions

concerning

this inspection, we will be pleased to discuss them with you. * Enclosures:

Sincerely, Hilbert W. Crocker, Acting Chief Fuel *Facility

and Materials

Safety Branch l. Appendix A, Notice of Violation . 2. Office of Inspection

and Enforcement

Inspection

Report Numbers 50-311/78-13;

cc w/encls: E. N. Schwalje, Manager -Quality Assurance

Docket No. 50-272 License No. DPR-70 APPENDIX A NOTICE OF VIOLATION

Based on the results of an NRC inspection

conducted

on May 25, 1978, it appears that one of your activities

was not conducted

in full compliance

with NRC r_egulations

as indicated

below: This item is an infraction.

10 CFR 50.*59,*11 Changes, tests and experiments

11 , states in part, 11 The holder*of

a license authorizing

operation

of a production

or *utilization

facility may ... make changes in the procedures

as scribed in the safety analysis report *.* without*prior

Commission

approval, unless the proposed change ... involves a change in the technical

specifications

in the license

unre-viewed Safety question.***

II . Contrary to this requirement, a change was made in a procedure

described

in. the safety analysis report, namely the Salem ting Station Operational

Quality Assurance

Instruction

Number 5, 11 Auditing 11 , without a determination

of whether or not the change e involved.

an unreviewed

_safety question.

--

Report No. U.S. NUCLEAR REGULATORY

COMMISSION

OFFICE OF INSPECTION

AND ENFORCEMENT

50-272/78-18

50-311 /78-13 50-272 Region I Docket No. 50-311 -=o=p=R""""'-7=-=o.---

License No. ---------Priority cPPR-53 ------. Category c A3 -------Licensee:

Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name: Sa:lem Nuclear Generation

Station, Units 1 & 2 Inspection

at: Hancocks Bridge, New Jersey Inspection

Inspectors: J .JR. White, Radfat.fon

Specialist

.-e .... __ Approved by: Inspection

Summary: date signed * date signed date signed

on

• 1973 {Repott Nos. 50-311/78-13;

50-272/78-18)

• 1 Areas.Inspected:

Routine, unannounced

inspection

of the pre-operational

status of the Radiation

Protection

Program to be implemented

for Unit No. 2. Areas examined included organization, inifial and refresher

training, radiation'

protection cedures, faci 1 i ty status,. instruments

and equipment, respiratory

protection

and. the implementation

of ALARA concepts.

The-inspection

consisted

of 26 inspector"-hours

on site by on NRC

Results: Of the seven areas inspected

there was one item of: noncompliance

identified (Infraction

-implementing

a change in an FSAR listed audit practice and procedure

without a determination

of safety related status contrary to 10 CFR 50.59, Paragraph

J 2, Docket No. 50-272). * e-Regi on I Form 1 2 (Rev. April 77)

DETAILS l. Persons Contacted

2. *H. J. Midura, Manager, Salem Nuclear Generating

Station *L. K. Miller, Performance

Engineer *J. L. Stillman-, Station Quality Assurance

Engineer *M. F. Metcalf, Resident Quality Assurance

Engineer *N. L. Millis, Nuclear Operations

-Health Physicist

• J. C. Gueller, Performance

Supervisor, Health Physics and Chemistry

• A. W. Kapple, Quality Assurance, Staff Assistant

B. Leap, Senior Quality Assurance

Specialist

T. Spencer, Quality Assurance

Specialist

D. Lyons, Quality Assurance

Specialist

J. Wood, Technical

Foreman, Health Physics D. Godlewski, Technical

Foreman, Health Physics -J. Lloyd, Station Training Coordinator

• denotes those present at the exit interview

conducte'd

May 5, 1978. Organization

The licensee's

representative

indicated

to the inspector, that the following

organization

chart depicted both the current and expected organizational

support for the radiation

protection

program at Salem Nuclear Generating

Station (SNGS). Manager -SNGS Performance

En ineer Performance

Supervisor

Instrument

and Control (l) Performance

Supervisor

Health Physics and Chemistry (RPM) I Instrument

Foreman T h . . I ec nic1ans r I Technical

Assistants

(14) I' Technical

Helpers (15) Technical

Fdreman (5) Technicians

1-Nuclear I (l) (9) _J

3 The licensee's

representative

stated that to support Unit 2 operation

there would be two more Technical

Foreman and an increased

number of Technical

Assistants.

An increase in the number of Technicians

-Nuclear is expected pending qualification

of some Technical

Assistants

with ANSI Nl8.l-1972, "Selection

and Training of Nuclear Power Plant Personnel.

11 During the course of this review, the inspector

verified the following:

The Performance

Supervisor

-Health Physics and Chemistry

is the designated

Radiation

Protection

Manager (RPM); and does fully meet the qualifications

for RPM as set forth in Regulatory

Guide 1.8, "Personnel

Selection

and Training.11 The RPM reports directly to the Performance

Engineer, a high level of station management

who does not have any functional

responsibilities

pertaining

to the operational

or production

aspects of SNGS. All Technicians, Nuclear, are regarded as technicians

in responsible

positions

and are fully qualified

in accordance

with ANSI Nl8.l-1971.

The responsibilities

of the members of the Performance ment relating to their functional

areas in radiation

protection

are fully described

in the Performance

Department

Manual (PDM) in accord with the specifications

of ANSI 18.7-1972

(1976), "Administrative

Controls for Nuclear Power Plants.11 The inspector

did note the following

discrepancies

in the PDM: a. The qualifications

statement

for the Performance

Supervisor

-Health Physics and Chemistry (RPM) does not reflect that the individual

is required to meet the specifications

as set forth in Regulatory

Guide 1.8, "Personnel

Selection

and Training.11 b. The Corporate

Health Physicist

is still designated

as the formance Supervisor

-Health Physics and Chemistry.

c. The qualifications

statement

for Technician

-Nuclear does not reflect that each technician

is to be qualified

in accordance

with ANSI Nl8.l-1971.

4 The licensee's

representative

indicated

that the PDM was currently

being revised and that the matters covered in the inspector's ments would be considered.

in the revision process. The inspector

indicated

that this item would be further reviewed at a subsequent

inspection

of the facility.

(78-13-01)

The licensee representative

stated that the Technical

Specification

6.3 requirement

to have an individual

qualified

in radiation tection procedures

on site when fuel is in the reactor was currently

met by having a Technician, Nuclear on site continually;

and that the same practice would extend to Unit No. 2 after fuel load. The inspector

reviewed the licensee's

audit program as required by Unit No. l Technical

Specification

6.5.2.8, 11 Audits 11 , and noted the following:

a. Regulation

10 CFR 50.59, 11 Changes, tests and experiments

11 , states, in part: 11 (a) (1) The holder of a license authorizing

operation

of a production

or utilization

facility may .. '. make changes in the procedures

as described

in the safety* analysis report.* .. without prior Commission

approval, unless the proposed change ... involved a change in the technical*

specifications

incorporated

in the license or an unreviewed

safety question.

(2) A proposed change . * . shall be deemed to involve.an

unreviewed

safety question (i) if the probability

of occurrence

or the consequences

of an accident of malfunction

of equipment

important

to safety previously

evaluated

in the safety analysis report may be increased;

or (ii) if a possibility

for an accident or

of a different type than

any evaluated viously in the safety

report may be created; or (iii) if the margin of safety as defined in the basis for any technical

specification

is reduced. (b) The licensee shall maintain records of changes in procedures

..* cluding} a written safety evaluation

which provides basis for the determination

that the change does not volve an unreviewed

safety question.11 b. The licensee's

Final Safety Analysis Report (FSAR), pendix D, Section 5.18, 11 Audits, 11 states: 11 Under the ection of the station Manager, the SQAE {Station Quality Assurance

Engineer}

is responsible

for a system of planned periodic audits to verify plant compliance

with all aspects

e. 5 of the OPQA {Operational

Quality Assurance}

program and station administrative

procedures.

The audit program will be established

in accordance

with ANSI N45.2.12.

Audits will be performed

by qualified

personnel (SQAE and other visory personnel, as assigned)

who are independent

of the area or function being examined, and will involve coverage of safety related site activities

as they are taking place, as well as review of records and documentation

in accordance

with an established

periodic program. The frequency

of audit will depend upon the criticality

of each function and will be adjusted in view of problems encountered.

However, audits will be scheduled

on an annual basis as a minimum.11 c. ANSI N45.2.12, 11 Requirements

for Auditing of Quality surance Program for Nuclear Power Plants, 11 Section 3.4.2 states: 11 Audits will be regularly

scheduled

on the basis of the status and importance

of the activities

to assure the adequacy of, and conformance

with, the program. plicable elements of the quality assurance

program shall be audited at least annually or at least once within the life of the activity, whichever

is shorter.11 The inspector

noted that such statements

indicate that the plicable audits must be performed

at least once within each 12 month interval following

the last previous audit of the same area. Upon review by the inspector, it was noted that the licensee had revised the "Salem Generating

Station Operational

Quality surance Instruction

No. 5 -Auditing 11 as of January 30, 1978, to indicate the fo.llowing

audit cycles for various elements in the quality assurance

program: Audit Cycle Audit Cycle Records & Documents

Procurement

& Storage A. l Document Control 2 years B. l Procurement

Control 2 years A.2 Records Management

2 years B.2 Spare Parts Control 2 years A.3 Reports Management

2 years

Audit Fuel-Waste-Refueling

C. l Refueling

C.2 In Core Fuel Man. C.3 Rad. Waste Man. C.4 SNM Safeguards

Trng-Security-Safety

E.l Security Program E.2 Rad. & Safety & Chemistry

E.3 Emergency

Plan E.4 Training & Qual. Cycle 2 years 2 years 2 years 2 years 2 years 2 years 2 years Annual 6 Audit Testing & Inspection

D.l Startup Testing D.2 In-Service

Insp. D.3 Measuring

& Test Equipment

Plant Maintenance

Cycle 2 years 2 years 2 years F.l Repair & Modifi-2 years cation F.3 Tech. Spec. Re-Annual quirements

F.4 Corrective

Action 6 months The SQAE stated to the inspector

that such change was done in order to align the licensee's

program w*ith the recommendations

of ANSI Nl8.7-1976, "Administrative

Controls for Nuclear Power Plant, 11 but that a determination

had not been made in accord with 10 CFR 50.59 to establish

that the change did not involve an unreviewed

safety question.

The inspector

noted that the implementation

of this procedure

revision resulted in at least 24 audits.not

being completed

within the 12 month period fallowing

the last previous audit of the same area, as is noted by the following:

ANNUAL AUDIT INTERVALS

First 12 Month Second 12 Month Interval Interval-Status

Audit No. Date Initiated

Subject/Number

Date Completed

as of May 5, 1978 76-1-B .1-1 9/1/76 Procurement

Control/B.l

l 0/6/76 Not Done 76-1-F.l-2

9/1 /76 Repair & Modification

-l 0/28/76 Initiated

4/1/87 * Cleanliness/F.l.b

76-1-E.4-3

9/1/76 Personnel

Training and Quali-l 0/15/76 Not Done fication -Training/E.4.a

76-1-A.2-4

9/7/76 Records Management

-Maintenance

10/21 /76 Not Done Equipment

History File/A.2 {Special}

76-1-A.3-5

10/4/76 Reports Management

-Nan-Routine

11/23/76 Not Done Event Reports/A.3.b

76-1-C.l-6

10/4/76 Ex Core Fuel Management/c.1.a

11/4/76 Not Done 76-1-D.3-7

10/4/76' Inservice

Inspection/D.3

l /28/77 Initiated

5/1/78 76-1-F.3-8

10/4/76 Tech. Spec. Requirements

-Organi-11/3/76 Not Done zation and Administration/F.3.a

76-1-C.4-9

11/1/76 SNM Safeguards

and Accountability/c.4

12/2/76 Not Done 76-1-E.3-10

11/1/76 Emergency

Planning -Facilities, 2/22/77 Not Dane Equipment, Test & Drills/E.3.c

Audit No. Date Initiated

76-1-F.2-ll

11/1/76 76-1-0.2-12

12/l /76 76-1-E.4-13

12/l /76 76-1-F.3-14

12/1/76 77-1-8.2-15

1/3/77 77-1-D.l-16

l /3/77 77-1-E.3-17

l /3/77 77-1-F.l-18

l /3/77 77-1-F.4-.19

l /3/77 77-1-A.3-20

2/1/77 77-1-D.4-21

2/1/77 77-1-A.l-22

3/8/77 Subject/Number

Special Processes

-Welding-NDE/F.2

Pre-Service

Inspection/D.2

Personne.l

Training and Qualification/

E.4.b Tech. Spec. Requirements

-Environmental

Protection/F.

3. d ANNUAL AUDIT INTERVALS

First 12 Month Second 12 Month Interval Interval-Status

Date Completed

as of May 5, l-978 2/22/77 8/l /77 See Audit 76-1-E.4-3

2/7/77 Not Dor:ie Not Done Initiated

1/11/78 Spare Parts Control -Issue of Spares/B.2

Startup Testing/D.l

2/7 /77 4/28/77 Not Done Not Done Emergency

Planning -Fire Prevention/

Protection/E.3.a

Repair and Modification

-Design Changes and Modification/F.l.a

Corrective

Action -Outstanding

Items Followup/F.4.a

Reports Management

-Review of Audits and Annual Reports/A.3.a

Changes, Tests and Experiments/D.4

Document Control/A.l

5/20/77 * 2/16/77 * 8/25/77 Not Done Initiated

4/1/78 Initiated

3/1/78 Not Done D.3 ated 5/1/78** Initiated

3/1/78

--*-*-------* ". --***-* ----'*--e ANNUAL AUDIT lNTERYALS

First 12 Month Second 12 Month Interval Interva 1-Sta.tus

Audit No. Date Initiated

Subject/Number

Date Completed

as of May 5, 1978 77-1-C. 1-23 3/8/77 Excore Fuel Management

-Spent Fuel 3/18/77 Not Done Packaging

& Shipping/C.l.b

77-1-E.2-24

3/8/77 Radiation

Safety & Chemistry/E.2

4/28/77 Not Done 77-1-F.l-25

3/8/77 Repair & Modification

-Maintenance

12/16/77 Initiated

4/1/78 /F.l.c . 77-1-A.2-26

4/5/77 Records Management/A.2

5/18/77 Not Done 77-1-C.3-27

4/5/77 Radioactive

Waste/C.3

6/7/77 Completed

3/22/78 77-1-E.l-28

4/5/77 Security Program -Physical Pro-7 /15/77 Initiated

4/1/78 tection/E.

l 77-1-F.3-29

4/5/77 Tech. Spec. Requirements

-Refueling

4/28/77 Not Done Operations/F.3.c

77-1-B.3-30

5/5/77 Materials

Handling and Ccintrol/B.3

6/3/77 Not Done 77-1-D.6-31

5/5/77 Measuring

and Test Equipment

Control 7 /13/77 D.3 Initiated

and Calibration/D.6

5/l/78 ** 77-1-E.3-32

5/5/77 Emergency

Planning -Strike Con-* Not Done tengency Plan/E.3.d

77-1-C.2-33

6/6/77 In Core Fuel Management/C.2

6/27 /77 Not Done 77-1-D.5-34

6/6/77 Surveillance

Testing/D.5

• D.3 Initiated

5/1/78 ** 77-1-F.4-35

6/6/77 Corrective

Action -Event Followup/

• Not Done F.4.b 77-1-E.3-36

6/27 /77 Emergency

Planning -Emergency

8/15/77 Not Done Planning Offsite/E.3.b

ANNUAL AUDIT INTERVALS

First 12 Month Second 12 Month Interval Interval-Status

Audit No. Date Initiated

Subject/Number

Date Comp 1 eted as of May 5, l978; 77-1-F.l-37

6/27 /77 77-1-F.3-38

6/27 /77 Repair & Modification

-Construction

Testing/Design

Change/F.l.d

Tech. Spec. Requirements

-Review of Plant Operations

Review of Limiting Conditions

for Operation/F.3.b

• 8/23/77 * A licensee Quality Assurance

Specialist

stated that these particular

audits were postponed

by Station Quality Assurance

Engineer.

• • A licensee Quality Assurance

Specialist

that as of the date of initiation

of the Second Audit Cycle (second 12 month interval), audits D.3 -"In-Service

Inspection, 11 D.4 -11 Changes, Tests and Experiments

11 , D.5 -11 Surveillance

Testing, 11 and D.6 -11 Measuring

and Test ment Control and Calibration, 11 are incorporated

in revised audit D.3 -11 Measuring

and Test Equipment.

11 Initiated

4/1/78 Not Done

. ' ' 11 The inspector

noted that changing the procedure

which implements

the FSAR commitment

regarding

audit performance

from an annual to a 2 year requirement, without determining

whether such a;* change constituted

an unreviewed

safety question was contrary to the requirements

of 10 CFR 50.59 and constituted

an item of pliance. . (78-18-01) . The licensee 1 s Station Quality Assurance

Engineer (SQAE) stated that the failure to meet the FSAR commitment

was acknowledged

by the licensee and that immediate

effort*would

be made to complete all audits required in the second 12 month interval by August, 1978. . 3. Radiation

Protection

Procedures

The inspector

reviewed all of the licensee 1 s implemented

Radiation

Protection

Procedures

against the requirements

of Unit No. l 1 s Techncial

Specifications, 6.8, 11 Procedures

11 , 6.11, 11 Radiation tection Program *. 11 and ANSI Nl8.7-1972.

(1976), 11 Adminis.trative

Controls for Nuclear Power Pl ants. 11 * It was verified by the inspector

that: a) all procedures

had been approved by the Station Operations

Review Committee

in accordance

with Unit No .. l 1s Technical

Sped ficati on 6. 5, 11 Review and Audi t 11; b) c) d) the procedure*

format was as described

by ANSI Nl8.7-1972

(1976); the proce.dures

reflected

As Low As Reasonably

Achievable (ALARA} concepts in accord with Regulatory

Guide 8.8, 11formation

Relevant to. Ensuring That Occupational

Radiation

Exposures

At Nuclear Power Stations Will Be As Low As ably Achievable";

an administrative

guide for procedure*

preparation (PDM, Section 3.3, 11 Document Control 11) detailed the

review and implementation

of Radiation

Protection

Procedures

in accord with ANSI Nl8 . .7-1972 (1976). rn the course of theinspector

1 s review. of Radiation

Protection

Procedures, the inspector

noted that there. were no procedures

developed

relating to the following

areas:

MPC-Hour Accountability

Extremity

Monitoring

12 Beta Dose Rate Determination

Overexposure

Investigation

Lost, Damaged, or Off-Scale

Dosimeter

or TLD Evaluation

Bioassay Nasal Smears Various Respiratory

Protection

Procedures

Decontamination

of Personnel

The licensee's

representative

indicated

that these areas would be reviewed and procedures

would be developed

as necessary.

The inspector

indicated

that this area would be reviewed in a . subsequent

inspection.

(78-13-03)

The inspector

noted the following

discrepancies

in the procedures

that were implemented

by the licensee:

Procedure

15.3.009, "Current Radiation

Exposure Record, 11 indicates

that only permanent

station employees

need to have their exposure recorded on a Form NRC-5. The inspector

out that the procedure

needs to indicate that all persons who are subject to exposure at the licensee 1 s facility must have their exposure recorded on Form NRC-5 in accordance

with the requi'rements

of 10 CFR 20.401, 11 Records of surveys, radiation

monitoring, and disposal.11 Procedure

15.4.008 and 15.4.009, 11 Airborne Particulate" and "Airborne

Iodine" respectively, does not indicate that air samples, to be meaningful, must be related to actual personnel

exposure, i.e., taken in the expected breathing

zone of nel. The inspector

pointed out that such an air sampling program was necessary

to fully comply with the requirements

of 10 CFR 20.103, "Exposure

of individuals

to concentrations

of radioactive

materials

in air in restricted

areas."

4. 13 Procedure

15.3.009, "Radioactive

Material Shipping" was noted by the inspector

as not reflecting

the current regulatory

requirements

of 49 CFR Parts 170-189 "Department

of portation

Hazardous

Material Regulations;" and 10 CFR 71, "Packaging

of Radioactive

Material for Transport

and portation

of Radioactive

Material Under Certain Conditions." The inspector

pointed out to the licensee the provisions

in 10 * CFR 71 regarding

the shipment of radioactive

material in excess of Type A quantities;

and the necessity

of promulgating

an NRC approved quality assurance

program satisfying

each of the applicable

criter*ia

specified

in 10 CFR 71, Appendix E, "Quality Assurance

Criteria for Shipping Packages for active Material." The licensee stated that these procedures

would be reviewed and amended as necessary.

The inspector

indicated

that these items would be reviewed in a subsequent

inspection.

(78-13-04)

Instruments

and Equipment

The inspector

reviewed the licensee's

inventory

of radiation

monitoring

instruments, as listed below: Instrument

AMS-2 Dosimeter

Charqers E-140N (Count Rate Meter) E-520 High Volume Air Samplers Low.Volume

Air Samplers PIC-6 RAP-1 (Air Pump) RAS-1 (Regulated

Air Sampler) RM-14 RM-16 R0-2 Teletector

RD-17 (High Level Detector)

PNR-4 PNC-4 PRM-4A SAM-2 (Stabilized

Assay Meter) AC-218 (Beta Probe) SAC-4 (Scint. Alpha Counter) . LCS-1 (Scaler) Quantity 6 7 6 13 20 3 24 9 8 29 2 6 7 2 2 2 10 2 l l 2

Instrument

BC-4 (Beta Counter) MP-1 (Pulser) HD-28 (Air Sampler) FC-2 (Gas-Flow

Counter) SH-4 (Sample Holder) MS-2 (Scaler) PAC-4G LS-6 (Shield) AM-33! (Air Monitor) PMC-4 (Portal Monitor) PMC-48 (Portal Monitor) HFM-3 (Hand-Foot

Monitor) LM-3 (Laundry Monitor) HP-177 HP-210 Prima II I NP-2 (Neutron Monitor) 14 Self Alarming Dosimeter

Charger TLD Self Reading Dosimeter

TLD Reader Quantity l l 3 l 3 4 2 l 3 2 7 2 l 20 10 4 2 9 3000 600 l The inspector

noted that the instruments

were capable of measuring

various types of radioactive

emissions

over a sufficient

range; and that the instruments

appeared in sufficient

quantity to initially

support two operating

units, provided all of the instruments

are op-erational.

• The licensee indicated

that additional

equipment

woulcf.be

acquired as necessary

to support the operation

of the facility.

5. Training The inspector

reviewed the following

aspects of the licensee's

training program: A. Health Physics Training Program -The licensee currently

utilizes a consulting

service to augment the technical

training of Technical

Assistants

and Technical

Helpers. The training course includes the following

elements:

r -----------r-------

__ _ e ' .

15 Plant System and Design Basic Math and Physics Health Physics to include personnel

monitoring, surveys, radiological

fundamental,

ALARA cepts, emergency

response, radioactive

material handling, and respiratory

protection

License Conditions

Federal Regulations

On-the-job

training provisions

The inspector

verified that the personnel

currently

holding the position of Technicians

-Nuclear have completed

an initial training program; but found that there was no refresher (or retraining)

at this time in accordance

with ANSI Nl8.7-1971.

The licensee's

representative

acknowledged

the lack of a malized retraining

program and indicated

that such a program would be developed

in time to support the Unit 2 operation.

The inspector

indicated

that this item would be reviewed in a subsequent

inspection. , (78-13-05)

B. General Employee Training (GET) -The licensee has implemented

a GET program which encompasses

the following

areas: General Radiation

Protection

Emergency

Plan Security Plan Quality Assurance

Occupational

Safety The program is conducted

by lectures given by members of the station's

training staff; and usually amounts to approximately

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of instruction.

For those persons who are to be radiation

workers, GET is augmented

by 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of additional

instruction, which is delineated

in Administrative

Procedure

AP-24, 11 Radiological

Safety Program. 11 -The inspector

noted that various ALARA concepts are included in the training program; and that a retraining

program is being currently

developed

with implementation

expected in about 3 months.

16 The licensee's

training coordinator

indicated

that the training staff is expected to increase from 4 to 6 people to support Unit 2 operation.

6. Respiratory

Protection

Program The inspector

noted that as of the time of the inspection, the licensee did not have a respiratory

protection

program in accord with 10 CFR 20. 103. The licensee's

representative

indicated

that an approved program was expected to be implemented

by September, 1978. The inspector

stated that pursuant to 10 CFR 20.103(e), the licensee must inform the Director, Region I, (Philadelphia)

30 days before the date that respiratory tection is first used under the provisions

of 10 CFR 20.103. The licensee representative

acknowledged

this requirement

and dicated that the licensee would comply. The inspector

indicated

that the respiratory

protection

program would be reviewed in a subsequent

inspection.

(78-13-06)

7. Facility Layout The inspector

reviewed several elements of the Unit 2 layout to determine

agreement

with the FSAR. The inspector

noted that currently

the radiation

protection

offices are located in a trailer complex adjoining

the west side of Unit 1 turbine structure.

It was pointed out by the inspector

that failure to have adequate facilities

located conveniently

to those areas and functions

controlled

by Health Physics Performance

Group would tend to compromise

and jeopardize

various radiological trols, particularly

during outage conditions.

The licensee representative

stated that facilities

would be designed into the 100' elevation

of the Service Building between the Unit 1 and Unit 2 containments;

and the the Health Physics Performance

Group would be expected to move into these facilities

by January, 1979. The inspector

indicated

that this area would be reviewed in a

sequent inspection.

(78-13-07)

.17 8. Exit Interview

The inspector

met with the licensee's

representatives (denoted iri paragraph

1) at the conclusion

of the inspection

on May 5, 1978. The inspector

summarized

the scope and findings of the inspection

as noted in this report.