ML18093B505

Responds to NRC 890208 Ltr Re Violations Noted in Insp Repts 50-272/88-25 & 50-311/88-25.Corrective Actions:Radiation Protection Supervisors Involved W/Steam Generators Counseled on Strict Compliance W/Radiation Permits & Requirements

ML18093B505
Person / Time
Site:	Salem
Issue date:	03/10/1989
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N89043, NUDOCS 8903210178
Download: ML18093B505 (5)

See also: IR 05000272/1988025

Text

j . Public Service Electric and Gas Company A1ey LaBruna

-Nuclear Operations

Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800

rMR 10 1989 NLR-N89043

United States Nuclear Regulatory

Commission

Document Control Desk Washington, D.C. 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION

NRC COMBINED INSPECTION

REPORT NO. 50-272/88-25

AND 50-311/88-25

SALEM GENERATING

STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas Company (PSE&G) has received the subject inspection

report dated February 8, 1989, which included a Notice of Violation

regarding

failure to implement

radiation

protection

procedures.

Pursuant to the requirements

of 10CFR2.201, our response is provided in the attachment

to this letter. Should you have any questions

on this transmittal, do not hesitate to callg Attachment

9903210170 PDR ADOCK 0 PNU G Sincerely,

• , . * Document Control Desk NLR-N89043

c Mr. J. c. stone Licensing

Project Manager Ms. K. Halvey Gibson Senior Resident Inspector

2 Mr. w. T. Russell, Administrator

Region I Ms. J. Moon, Interim Chief New Jersey Department

of Environmental

Protection

Division of Environmental

Quality Bureau of Nuc1*ear Engineering

CN 415 Trenton, NJ 08625 MAR lo 1889

.. I' '{ ATTACHMENT

PUBLIC SERVICE ELECTRIC AND GAS SALEM GENERATING

STATION UNIT NOS. 1 AND.2 RESPONSE TO NOTICE OF VIOLATION

Your letter of February 8, 1989, transmitted

NRC Combined Inspection

Report No. 50-272/88-25;

50-311/88-25

for Salem Units 1 and 2 which included a Notice of Violation.

The specific items identified

in the violation

and our related responses

are presented

below. Technical

Specification

6.11, Radiation

Protection

Program, requires, in part, that procedures

for personnel

radiation

protection

shall be approved, maintained

and adhered to for all operations

involving

personnel

radiation

exposure.

1. Administrative

Procedure

AP-24, Radiation

Protection

Program, requires in part in section 5.4, that Radiation

Work Permits be adhered to. Radiation

Protection

Procedure

RP 202, Radiation

Work Permits, requires in part in section 7.3.12, that applicable

check lists from applicable

radiation

protection

procedures

be incorporated

into the RWP. The applicable

Hot Particle Check list from Radiation

Protection

Procedure

808, incorporated

into RWP No. 88-2S-00979, Revision 1, requires Masslin surveys of the entire work area every four hours. Contrary to the above, on October 18, 1988 and for an undetermined

period of time prior to this date, the Hot Particle Check list incorporated

into RWP No. 88-2S-00979, Revision 1, was not adhered to during work performed

under this RWP in that contamination

surveys of the 21/23 Steam Generator

platforms, part of the work area, were performed

only once per shift rather than every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and were performed

with paper disc smears rather than Masslin. 2. Administrative

Procedure

AP-24, Radiation

Protection

Program, requires in part in section 6.1.3, that personnel

shall be denied access to the Radiological

Controlled

Area (RCA) unless they are entering under the provisions

of a valid radiation

work permit (RWP). Contrary to the above, on October 5 and 6, 1988, an individual

was not denied access to the RCA even though it was known by Radiation

Protection

Supervision

that he could not enter under the provisions

of a valid RWP due to dose restrictions.

The individual

entered the RCA and performed

work involving

frisking of equipment

for contamination.

NLR-N89043

I, '* -2-RESPONSE -ITEM 1 1. ROOT CAUSE The root cause of this violation

was inadequate

training of Radiation

Protection

personnel

in the new survey techniques

utilized in hot particle zones, and a lack of supervisory

oversight

in not ensuring procedural

adherence.

2. CORRECTIVE

ACTIONS IMPLEMENTED

The Radiation

Protection

supervisors

involved with Steam Generators

were counselled

on strict compliance

with RWP and procedural

requirements.

They ensured that 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> surveys of the platform areas using Masslin cloths were being done in accordance

with the Hot Particle Check List and RP 808. 3. LONG TERM CORRECTIVE

ACTIONS TO AVOID FURTHER VIOLATIONS

As committed

to in our response to NRC Combined Inspection

Report No. 50-272/88-18;

50-311/88-18, critical procedures

are being taught to appropriate

Radiation

Protection

personnel

prior to the start of the next refueling

outage, currently

scheduled

for April 15, 1989. Procedure

adherence, RP 808, and hot particle controls are included in these training sessions.

The training is being conducted

from January through March 1989 and is on schedule.

In addition, RP 808 was reviewed for procedural

adequacy.

It was determined

that the procedure

adequately

addressed

hot particle control and associated

requirements

and that no changes to the procedure

were necessary.

Supervisory

oversight

is being stressed for the upcoming Unit 1 Eighth Refueling

Outage. 4. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED The training sessions will be completed

prior to the start of the next refueling

outage, presently

scheduled

for April 15, 1989. NLR-N89043

.. -:-;:-*. _ ..

• RESPONSE -ITEM 2 1. ROOT CAUSE -3-The root cause of this violation

was inadequate

guidance on the precise location of the RCA boundary in the Control Point area. 2. CORRECTIVE

ACTION IMPLEMENTED

The individual

was removed from the RCA and his dosimetry

was checked to ensure that there was no significant

exposure.

The supervisor

responsible

for permitting

the individual

to enter the RCA without being on a valid RWP was counselled.

Night orders were issued to management

and technicians

re-emphasizing

the RCA boundaries

and the AP-24 requirement

to be on a valid RWP to enter the RCA. The importance

of this issue was discussed

with all Radiation

Protection

personnel.

3. LONG TERM CORRECTIVE

ACTIONS TO AVOID FURTHER VIOLATIONS

Clarifying

instructions

have been conspicuously

posted at the entrance to the RCA and will be incorporated

into the Radiation

Worker Training sessions conducted

for all personnel.

The Radiation

Protection

procedures

which contain guidance for RCA access were reviewed for clarity. Minor changes (Advanced

Change Notices) were initiated

for two procedures

to clarify the RWP requirement

when entering the RCA. These changes will be incorporated

into these procedures

by March 31, 1989. This incident and its associated

corrective

actions are being included in the special procedure

training for Radiation

Protection

personnel

as previously

discussed.

4. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED The special procedure

training will be completed

prior to the start of the next refueling

outage, presently

scheduled

for April 15, 1989. NLR-N89043