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)

Text

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Frederick W. Schneider Vice President Production Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 September 29, 1978 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 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 Q~ality 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 Manager-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 non-compliance was appropriately identified, documented and dis-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 9/29/78 As previously stated in our response dated August 11, 1978, the subject item of noncompliance did not represent noncompliance with 10CFRS0.59 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 SEP 6 1978 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 This refers to your letter dated August 11, 1978, in response to our letter dated June 12~ 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 com-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 imple-mentation of your FSAR commitment for an annual audit frequency. As noted in our report, superceding this FSAR commitment. by changing Pro-cedure OQI-5 without an evaluation in accordance with 10 CFR 50.59 con-stitutes noncompliance.

We note that your effort to amend OQI-5 to reflect the annual require-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.

Public.Service Electric and Gas 2 Company Your cooperation with us is appreciated.

Sincerely,

!lf<P fl .$4_._;r Boyle H. Grier Director cc:

F. P. Librizzi, General Manager - Electric Production E. N. Schwalje, Manager - Quality Assurance R. L. Mittl, Gener~l Managerr - Licensing and Environment H. J. Midura, Manager - *sa l em Generati_n*g Sta ti on L-*------- -*----*-

Frederick W. Schneider Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Vice President Production August 11, 1978 Mr. Boyce H. Grier Director of USNRC 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 ST.?-l~TION 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 re-port ..* without prior Comr.i.ission approval, unless the pro-posed change ... involves a change in the technical speci-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 misunder-standing between the station QA Engineer (SQAE) and the in-spector, rather than a violation. This is explained in the following:

Inspection Report 8-11-78 No. 50-272/78-18 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 re-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 re-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 Oper-

""?" 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 re-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 viola-tion was involved in our activity.

Inspection Report 8-11-78 No. 50-272/78-18 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 in-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 com-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 JUN 1 2 W13-Public Service Electric and Gas Company ATTN: Mr. T. J. Martin Vice President - Engineering and Construction Mr. F. W. Schneid~r

• 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 concl~sion 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 consi~ted 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 notic~ is sent to yob pursuant to the provisions of Section 2.201 of the NRC's "Rules of Practice-," Part 2, Title 10~ 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 ~chieved; (Z) corrective steps which will be taken to avoid further items of noncompliance; and (3.) the date when full compliance will be achieved.

P~blic Service Electric and Gas 2 Company 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 s Public Document Room. If this 1

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.

• Sincerely, Hilbert W. Crocker, Acting Chief Fuel *Facility and Materials Safety Branch

Enclosures:

l. Appendix A, Notice of Violation .

2. Office of Inspection and Enforcement Inspection Report Numbers 50-311/78-13; 50-272/78~18 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,* Changes, tests and experiments states in part, 11 11 11 The holder*of a license authorizing operation of a production or

• utilization facility may ... make changes in the procedures as de-scribed in the safety analysis report *.* without*prior Commission approval, unless the proposed change ... involves a change in the technical specifications incorpo~ated in the license ~ran 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 Genera-ting Station Operational Quality Assurance Instruction Number 5, e

11 Auditing 11 , without a determination of whether or not the change involved. an unreviewed _safety question.

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-272/78-18 Report No. 50-311 /78-13 50-272 Docket No. 50-311

-=o=p=R""""'-7=-=o.--- c License No. cPPR-53 Priority . Category 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 conduct~ -;;May~a Inspectors: ~. k~

J .JR. White, Radfat.fon Specialist date signed

• date signed

.- e date signed Approved by:

Inspection Summary:

Insp~ction on M~y 2~5~ *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 pro-cedures, faci 1i 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 inspector~.

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 12 (Rev. April 77)

DETAILS

l. Persons Contacted

• 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.

2. 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 (l) Performance Supervisor (l)

Instrument and Control Health Physics and I Chemistry (RPM)

Instrument Foreman Tec hnic1ans I Technical Fdreman (5) 1 Technicians - Nuclear (9) r I I Technical Assistants (14)

I' Technical Helpers (15)

_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 Depart-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 Per-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 com-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 pro-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 malfunctio~ of a different type than any evaluated pre-viously in the safety an~lysis 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 . . * {in-cluding} a written safety evaluation which provides the-basis for the determination that the change does not in-volve an unreviewed safety question. 11

b. The licensee's Final Safety Analysis Report (FSAR), Ap-pendix D, Section 5.18, Audits, states:

11 11 11 Under the dir-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

5 e.

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 super-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, Requirements for Auditing of Quality As-11 surance Program for Nuclear Power Plants, Section 3.4.2 11 states: Audits will be regularly scheduled on the basis 11 of the status and importance of the activities to assure the adequacy of, and conformance with, the program. Ap-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 ap-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 As-surance Instruction No. 5 - Auditing as of January 30, 1978, to 11 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

6 Audit Cycle Audit Cycle Fuel-Waste-Refueling Testing & Inspection C. l Refueling 2 years D.l Startup Testing 2 years C.2 In Core Fuel Man. 2 years D.2 In-Service Insp. 2 years C.3 Rad. Waste Man. 2 years D.3 Measuring &Test 2 years C.4 SNM Safeguards 2 years Equipment Trng-Security-Safety Plant Maintenance E.l Security Program 2 years F.l Repair & Modifi- 2 years E.2 Rad. &Safety 2 years cation

&Chemistry E.3 Emergency Plan 2 years F.3 Tech. Spec. Re- Annual E.4 Training &Qual. 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

ANNUAL AUDIT INTERVALS First 12 Month Second 12 Month Interval Interval-Status Audit No. Date Initiated Subject/Number Date Completed as of May 5, l-978 76-1-F.2-ll 11/1/76 Special Processes - Welding-NDE/F.2 2/22/77 Not Dor:ie 76-1-0.2-12 12/l /76 Pre-Service Inspection/D.2 8/l /77 76-1-E.4-13 12/l /76 Personne.l Training and Qualification/ See Audit Not Done E.4.b 76-1-E.4-3 76-1-F.3-14 12/1/76 Tech. Spec. Requirements - Environmental 2/7/77 Initiated Protection/F. 3. d 1/11/78 77-1-8.2-15 1/3/77 Spare Parts Control - Issue of Spares/B.2 2/7 /77 Not Done 77-1-D.l-16 l /3/77 Startup Testing/D.l 4/28/77 Not Done 77-1-E.3-17 l /3/77 Emergency Planning - Fire Prevention/ Not Done Protection/E.3.a 77-1-F.l-18 l /3/77 Repair and Modification - Design Changes 5/20/77 Initiated and Modification/F.l.a 4/1/78 77-1-F.4-.19 l /3/77 Corrective Action - Outstanding Items

• Initiated Followup/F.4.a 3/1/78 77-1-A.3-20 2/1/77 Reports Management - Review of Audits 2/16/77 Not Done and Annual Reports/A.3.a 77-1-D.4-21 2/1/77 Changes, Tests and Experiments/D.4

• D.3 Initi-ated 5/1/78**

77-1-A.l-22 3/8/77 Document Control/A.l 8/25/77 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 1eted as of May 5, l978; 77-1-F.l-37 6/27 /77 Repair &Modification - Construction

• Initiated 4/1/78 Testing/Design Change/F.l.d 77-1-F.3-38 6/27 /77 Tech. Spec. Requirements - Review of 8/23/77 Not Done Plant Operations Review of Limiting Conditions for Operation/F.3.b

• A licensee Quality Assurance Specialist stated that these particular audits were postponed by Station Quality Assurance Engineer.

• • A licensee Quality Assurance Specialist ~tated that as of the date of initiation of the Second Audit Cycle (second 1211 month interval), audits D.3 - "In-Service Inspection, 11 D.4 - 11 Changes, Tests and Experiments , D.5 - 11 Surveillance Testing, 11 and D.6 - 11 Measuring and Test Equip-ment Control and Calibration, 11 are incorporated in revised audit D.3 - 11 Measuring and Test Equipment. 11

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 noncom-pliance. . (78-18-01) .

The licensee 1s 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 1s implemented Radiation Protection Procedures against the requirements of Unit No. l 1s Techncial Specifications, 6.8, 11 Procedures 11 , 6.11, 11 Radiation Pro-tection Program *. and ANSI Nl8.7-1972. (1976), 11 Adminis.trative 11 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, Review and Audi t 11 11 b) the procedure* format was as described by ANSI Nl8.7-1972 (1976);

c) the proce.dures reflected As Low As Reasonably Achievable (ALARA} concepts in accord with Regulatory Guide 8.8, 11 In-formation Relevant to. Ensuring That Occupational Radiation Exposures At Nuclear Power Stations Will Be As Low As Reason-ably Achievable";

d) an administrative guide for procedure* preparation (PDM, Section 3.3, 11 Document Control detailed the development~ review and 11

)

implementation of Radiation Protection Procedures in accord with ANSI Nl8 ..7-1972 (1976).

rn the course of theinspector 1s review. of Radiation Protection Procedures, the inspector noted that there. were no procedures developed relating to the following areas:

12 MPC-Hour Accountability Extremity Monitoring 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 p~inted out that the procedure needs to indicate that all persons who are subject to exposure at the licensee s facility 1

must have their exposure recorded on Form NRC-5 in accordance with the requi'rements of 10 CFR 20.401, Records of surveys, 11 radiation monitoring, and disposal. 11 Procedure 15.4.008 and 15.4.009, Airborne Particulate" and 11 "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 person-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."

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 Trans-portation Hazardous Material Regulations;" and 10 CFR 71, "Packaging of Radioactive Material for Transport and Trans-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 Radio-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)

4. Instruments and Equipment The inspector reviewed the licensee's inventory of radiation monitoring instruments, as listed below:

Instrument Quantity AMS-2 6 Dosimeter Charqers 7 E-140N (Count Rate Meter) 6 E-520 13 High Volume Air Samplers 20 Low.Volume Air Samplers 3 PIC-6 24 RAP-1 (Air Pump) 9 RAS-1 (Regulated Air Sampler) 8 RM-14 29 RM-16 2 R0-2 6 Teletector 7 RD-17 (High Level Detector) 2 PNR-4 2 PNC-4 2 PRM-4A 10 SAM-2 (Stabilized Assay Meter) 2 AC-218 (Beta Probe) l SAC-4 (Scint. Alpha Counter) l

. LCS-1 (Scaler) 2

14 Instrument Quantity BC-4 (Beta Counter) l MP-1 (Pulser) l HD-28 (Air Sampler) 3 FC-2 (Gas-Flow Counter) l SH-4 (Sample Holder) 3 MS-2 (Scaler) 4 PAC-4G 2 LS-6 (Shield) l AM-33! (Air Monitor) 3 PMC-4 (Portal Monitor) 2 PMC-48 (Portal Monitor) 7 HFM-3 (Hand-Foot Monitor) 2 LM-3 (Laundry Monitor) l HP-177 20 HP-210 10 Prima II I 4 NP-2 (Neutron Monitor) 2 Self Alarming Dosimeter Charger 9 TLD 3000 Self Reading Dosimeter 600 TLD Reader 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:

e

15 Plant System and Design Basic Math and Physics Health Physics to include personnel monitoring, surveys, radiological fundamental, instrum~ntation, ALARA con-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 for-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, Radiological 11 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 pro-tection is first used under the provisions of 10 CFR 20.103.

The licensee representative acknowledged this requirement and in-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 con-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 sub~

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.