ML20136F090
| ML20136F090 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/20/1985 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20136E983 | List: |
| References | |
| 50-293-85-32, NUDOCS 8601070233 | |
| Download: ML20136F090 (24) | |
See also: IR 05000293/1985032
Text
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U.S. NUCLEAR REGULSTORY COMMISSION
REGION I
Report No. ,P-293/85-32
Docket No.
50-293
License No.
OPR-63
Priority
Category
C
--
Licensee:
Boston Edison Comoany M/C Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Facility Name:
Pilgrim Nuclear Power Station
Inipection At:
Plymouth, Massachusetts
Inspection Conducted: Novcmber 17-22, 1985
Inspectors:
9..L d M
n.\\ h { SS
R. L. Nimitz, SenioY Radiation Specialist
date ~
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1. o . I 9FI
Approved by:
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W. J.! sctik, Chief, BWR Radiation Protectieff
date'
Sects n
Inspection Summary:
Inspection on November 17-22, 1985 (Report No.
E0-293/85-32)
Areas Inspected:
Routine, unannounced inspection of the following:
implementation of improvement items identified in the Radiological Improvement
Program; radiological controls for fuel pool re-racking and removal of the
Radwaste Concentrator; and Effluent Release Monitors / Controls.
Upon arrival
at the site on November 17, 1985, the inspector toured the facility and
reviewed implementation of radiological controls practices and procedures.
The inspection involved 43 inspector-hours on-site by one region based
inspector.
Results:
Two violations were identified (Failure to search packages when
brought into the protected area; section 6, Failure to perform instrument
channel test; paragraph 5).
The Radiological Improvement Plan was being
satisfactorily implemented.
Some concerns were identified in management
oversight of radiological work. The licensee took timely corrective action
for this matter.
8601070233 851231
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DETAILS
1.0 Persons Contacted
1.1 Boston Edison
- L. Oxsen, Vice President, Nuclear Operation
- C. Mathis, Station Manager
- W. Deacon, Assistant to Senior Vice President, Nuclear
"K. Roberts, Director, Outage Management
"T. Sowdon, Radiological Section Head
"J. Crowder, Senior Compliance Engineer
- P. Smith, Chief, Technical Engineer
- B. Eldridge, Acting Chief Radiological Engineer
- E. Graham, Compliance Group Leader
- G. Anderson, Outage Management Engineer
- E. Menslage, Outage Management Engineer
- D. Mills, Acting CMG Group Leader
- M. Noon, Corporate Security
- J. McEachern, Resource Protection and Control Group Leader
Contractors
- M. Jackimowicz, CYGNA
G. Smith, Hydro Nuclear
1.2 NRC
- L. E. Tripp, Chief Reactor Projects Section 3A, NRC Region I
- M. McBride, Senior Resident Inspector
- denotes those individuals attending the exit meeting on November 22,
1985.
The inspector also met with other individuals.
2.0 Purpose of Inspection
The purpose of this routine, unannounced radiological controls inspection
was to review the following program elements:
Implementation of the Radiological Improvement Program
Radiological Controls for re-racking of the spent fuel pool
Radiological Control for Removal of the Radwaste Concentractor.
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3.0 Implementation of Licensee Commitments Presented to NRC in the
Radiological Improvement Program (RIP)
3.1 General
The inspector reviewed the implementation of Radiological Improvement
Program commitments presented to the NRC.
The review was with respect to
criteria and/or information cor4tained in the following documents:
Order Modifying Licensee, Notice of Violation, and Notice of
Deviation (NRC Inspection No. 50-293/84-25 and 50-293/84-29), dated
November 29, 1984,
Letter (W. D. Harrington, Senior Vice President-Nuclear, Boston
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Edison, to T. E. Murley, Regional Administrator, NRC Region I),
dated February 28, 1985, (BECo ltr No.85-042),
Licensee Completed Regulatory F quirement Analysis Forms (various)
relative to Radiological Improvement Plan (RIP) Milestones,
Licensee Radiological Activity Assessment Reports (RAAR) (various),
Radiological Oversight Committee (ROC) Meeting Minutes (various),
NRC Inspection Report No. 50-293/85-13, dated July 16, 1985, and
NRC Inspection Report No. 50-293/85-22, dated October 7, 1985.
The purpose of this review was to determ-
.f:
the licensee met the commitments (i.e. milestones) specified in the
Radiological Improvement Program (RIP);
the material or actions taken/ generated by the licensee
satisfactorily met the commitments made to NRC in the RIP; and
the material or actions taken/ generated were properly implemented.
a
The following aspects of RIP implementation were noted and verified
implemented:
a tracking program was in place to identify milestones due;
adequate management controls were in place to monitor implementation
of milestones and initiate proper action when milestones were
identified as potentially not being met;
review was performed of the material or actions taken/ generated to
determine its adequacy prior to its acceptance and implementation.
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3.2 Findings
The inspector reviewed a total of 71 commitments that were to have been
completed by the licensee by October 31, 1985. The commitments reviewed
are identified in the attachment to this report.
The review indicated the licensee satisfactorily completed his action on
50 of the commitments.
Several commitments were left open due to the
need for additional licensee action or NRC review.
These are identified
in the attachment to this report.
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Based on the above review, the licensee is aggressively monitoring
implementation of the RIP improvement items, and is meeting commitments
provided to NRC Region I.
Within the scope of the review, the following positive attributes were
noted:
The licensee's Senior Vice President-Nuclear is closely monitoring
1*
implementation of the Radiological Improvement Program.
Radiological Oversight Committee members are touring the facility
once per week.
Findings identified during the tours are brought up
and discussed at the, ROC meetings. Action is initiated to resolve
problems identified.
The licensee has taken action to upgrade the quality of procedures
being developed to satisfy RIP commitments.
4.
Radiological Controls Implementation
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The inspector reviewed the implementation, adequacy, and effectiveness of
Radiological Controls for the 1:stallation of high density fuel racks in
the fuel pool and for removal of the Radwaste Concentrator.
The following
matters were reviewed:
adequacy and effectiveness of management oversight and control of
the activities,
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establishment, adequacy, and implementation of appropriate
g
procedures for the activities,
adequacy and adherence to Radiation Work Permits,
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selection, qualification and training of personnel,
implementation and adequacy of ALARA controls,
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high radiation area controls implementation and adequacy,
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adequacy and evaluation of radiological surveys,
supply and use of appropriate personnel monitoring equipment, and
use of acceptable, properly calibrated radiological survey
instrumentation.
The review was with respect to criteria contained in the following:
applicable Technical Specifications,
10 CFR 20, " Standards for Protection Against Radiation," and
applicable licensee procedures.
4.1 General
The inspector reviewed the management oversight and control of the fuel
pool re-racking and concentrator removal with respect to criteria con-
tained in the following:
VPN0 Letter No. 85-95, " Improved Control of PNPS Work Process", and
Outage Management Work Instruction No.11.0, " Inter-Disciplinary
Critiques", dated November 21, 1985.
The above documents were established to provide improved oversight and
control of projects that involve significant radiological and/or
industrial safety risk.
Within the scope of this review, no violations were identified.
The
licensee was found to be providing, in general, acceptable oversight of
the radiological significant work. However, the following items for
improvement were identified:
Provide a mechanism to ensure that each inter-disciplinary group has
a clear understanding of its responsibilities. In some areas (e.g.
personnel training) it was not clear that each group understood its
responsibilities.
In addition licensee oversight responsib,'lities
of contractor activities should be clearly identified.
The
licensee's Work Instruction No. 11 provides general guidance in
these areas. However, the implementation of this guidance was not
uniform for the two tasks.
The licensee immediately initiated action to:
1)
revise the Work Instruction No.11 to provide for uniform
interpretation of guidance contained therein,
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2). clearly identify each inter-disciplinary groups responsibilities
and oversight requirements, and
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provide for clear identification and implementation of
training / retraining requirements.
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The licensee's actions on this matter were timely.
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Upgrade controls on field changes to re-rack and concentrator
removal procecures to ensure appropriate radiological controls
. personnel (as necessary) review field changes to procedures.
The licensee initiated action to ensure radiological controls
personnel (as necessary) review field changes to procedures.
Provide (as. appropriate) a methodology and criteria for use in
monitoring on going radfological work in order to identify
unfavorable exposure tre.nds such that appropriate actions can be
taken to correct the situation.
The licensee provided a mechanism for clear oversight / review of day
,
to day exposure received on the tasks.
4.2 Radwaste Concentrator Removal (Radiological Controls)
->
Documents Reviewed
Procedure 6.1-012, " Access to High Radiation Areas"
Temporary Procedure No. TP85-107, " Dismantling / Removal of Radwaste
Concentrator and Associated Equipmant"
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Procedure 6.1-022, " Issue, Use, and Termination of Radiation Work
Permits (RWPs)"
Temporary Procedure No. TP85-108, " Operation of the AP-1000 and
AP-2000 HEPA Filter Units Including Filter Changeout
Procedure PNPS SI-RP.5002, "Use and Control of Portable. Ventilation
Units and HEPA Vacuum Cleaners", September 18, 1985
/
Findings
Within the scope of this review, no violations were identified.
The
licensee was providing and implementing generally commendable in-field
Radiological Controls for removal of the Radwaste Concentrator.
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The following positive attributes were noted:
The licensee made effective use of engineering controls (e.g. tents,
HEPA filters) to minimize airborne radioactivity concentrations.
The licensee provided and utilized shielding were appropriate and
cost beneficial to minimize personal exposure.
The licensee installed closed circuit TV to monitor on going work
activities.
The licensee provided closed circuit two way communication with
workers.
The licensee implemented multi-layer high radiation area controls to
provide for effective high radiation area controls.
Senior level, qualified personnel were monitoring on going
radiological work.
Within the scope of this review, the following items needing licensee attention
were identified:
Evaluate and provide. (as appropriate) personnel dosimetry for the
backs of personnel to provide for non-uniform whole body exposure.
The licensee immec:ately initiated action to evaluate and provide
(as appropriate) dosimetry for the backs of personnel.
. Evaluate and control (as appropriate) the exposure of personnel to
airborne pure beta emitters.
The licensee immediately initiated action to evaluate and control
(as appropriate) airborne beta exposure of personnel.
Label HEPA air filtering systems. The systems were not labeled.
4.
Consequently, personnel were uncertain as to applicable operating
acceptance criteria.
The units were immediately labeled.
Establish HEPA exhaust airborne concentration limits requiring
personnel actions.
Procedures said take action when airborne
radioactivity " specification" is exceeded.
Specification was
undefined.
The licensee immediately initiated action to provide a defined
specification.
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Some area surveys were not readily available for briefing
personnel. Procedures specify surveys be available.
The licensee initiated action to obtain and post all appropriate
surveys on a Radwaste Concentrator Status Board.
The following item for improvement was identified:
Clearly identify the minimum controls and/or equipment needed to be
present and/or operable in order to continue work removing the
Radwaste Concentrator, particularly in the area of high radiation
area access controls.
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The licensee immediately established a Radwaste Concentrator Daily
check list. The check list provides minimum controls and/or equip-
ment to be operable for work to continue.
4.3 Fuel Pool Re-Racking (Radiological Controls)
Documents Reviewed
Procedure 6.1-022, " Issue, Use, and Termination of Radiation Work
Permit"
Procedure No. 6.7-121, " Radiation Protection Requirements for Diving
,
in Radiologically Controlled Areas"
Procedure NEDWI-308, " Fuel Pool Re-racking"
Procedure 3M1-19, " Spent Fuel Pool Cleaning"
Temporary Procedure 85-83, " Fuel Pool Vacuum Filter Change-Out"
Findings
Within the scope of this review, no violations were identified.
The
licensee was providing acceptable in-field Radiological Controls for
installation of new racks. The licensee is currently performing
preplanning for removal of the old racks and diving.
The following positive' attributes were noted:
The licensee was providing effective control of radioactive material
being. removed from the fuel pool.
Radiological Controls personnel
were in constant attendance.
Fuel pool water clarity was very good.
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A procedure log was established and in place on the refueling
floor.
The licensee initiated a comprehensive effort to evaluate the
' underwater radiation environment entered by the divers.
The licensee is decontaminating the fuel pool to minimize exposure
to divers, prevent water clarity problems, and in general eliminate
unnecessary radioactive material in the fuel pool.
Within the scope of this review, the following items needing licensee
attention were identified:
An unapproved procedure for rack removal was found on the refuel
floor.
The _ licensee removed the unapproved procedure, provided an approved
copy, and initiated action to ensure appropriate, approved
procedures were in use on the Refueling Floor. No differences were
apparent between the approved and unapproved copies.
The licensee has taken action or is taking action to address the
following matters:
Evaluate the radiation environment entered by divers.
Provide
proper dosimetry to monitor diver exposure.
Evaluate the acceptability of radiation survey meters used to
measure underwater dose rates. Provide for properly calibrate
survey meters.
Establish (as appropriate) pre-dive check lists / instructions.
Define diver bioassay program.
Establish (as appropriate) post-dive check lists / instructions.
Establish controls to limit / control exposure to critical body parts
of diver.
Establish (as appropriate) procedures for use of the hydro-lazer
hydrolazer.
5.0 Effluent Monitoring / Control Instrumentation
The inspector reviewed the implementation, adequacy, and effectiveness of
the licensee's calibration program for Effluent Monitoring / Control
Instrumentation.
The following matters were selectively reviewed:
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establishment of appropriate procedures for calibration / checking of
the Reactor Building Vent and Stack Effluent Monitors,
implementation of procedure requirement.
adequacy of alarm set point determinations, and
control room personnel oversight / monitoring of effluent monitoring
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instrumentation.
The review was with respect to criteria contained in the following:
10 CFR 20, " Standards for Protection Against Radiation,"
a
Applicable Technical Specifications, and
Applicable Licensee procedures.
The licensee's performance in the area was based on discussions with
personnel, review of documentation, and visual observation of
instrumentation.
Within the scope of this review, the following violation was
identified:
Technical Specification 4.8 c.10 requires, in part, that each waste
gas monitor have an instrument channel test at least monthly.
Lc.itrary to the above, as of November 22, 1985, instrument channel
.ests were not being performed on a monthly basis for the Reactor
Building Vent and the Stack Waste Gas Monitors. (50-293/85-32-01)
Licensee representatives immediately initiated action to review and
resolve (as appropriate) this matter.
In addition, the following matter needing licensee attention was iden-
tified:
No defined methodology was in place which described determination and
set-up of alarm set points for the waste gas monitors.
The licensee was aware of this matter and had initiated action
to upgrade appropriate procedures.
Excluding the above matters, no other unacceptable practices were
identified.
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6.0 Plant Tours
The inspector toured the facility initially upon arrival and periodically
during the inspection.
The following matters were reviewed:
adherence to procedures.
posting, barricading, and access control (as appropriate) to
radiation and high radiation areas, and
adequacy of radiological survey.
Within the scope of this review, the following violation was identified:
At about 9:30 p.m. on November 17, 1985, the inspector
observed two articles being brought into the protected area that
were not searched.
The licensee's investigation of this matter determined that of the
two articles, one was not adequately searched.
This is a
violation of the Pilgrim Nuclear Power Station Security Plan,
Section 1.6.4 (50-293/85-32-02)
Within the scope of this review, the following matter needing licensee
attention was identified:
The inspector was improperly processed into the restricted area at
about 9:30 p.m. on November 17, 1985. The inspector was provided
incorrect quarterly dose limits and radiation exposure card. This
matter was identified by the inspector and licensee personnel.
The licensee subsequently modified the inprocessing form to provide
for ease of use and minimization of errors. The licensee
reinstructed and/or counseled personnel as appropriate.
The licensee's action on this matter was timely.
No other unacceptable practices were identified.
7.
Exit Meeting
The inspector met with those individuals denoted in section 1 of this
report at the conclusion of the inspection (November 22,1985). The
inspector summarized the purpose, scope and findings of this inspection.
No written material was provided to the licensee.
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ATTACHMENT TO REPORT
50-293/85-32
Status of Boston Edison Company's
Radiological Improvement Program (RIP)
Commitment to be Completed after
July 31, 1985 and before October 31, 1985
COMMITMENT
STATUS
NRC Comment
1.
1.2.2-7 Formal position
Complete
The licensee established
descriptions to be
formal position descrip-
established for each
tion for each title.
Radiological Group title.
(September 31,1985)
2.
1.2.3-1 Distribute Radio--
Complete
None
logical Control Group's
Organization Chart and conduct intergroup meetings (August 31, 1985
Deferred)
3.
1.2.4.a-2 Perform a basic
Complete
The licensee performed
task analysis for all
the task analysis and
positions within the
projected staffing
Radiological Group
level 2.
Organization and project
staffing levels
(September 30,1985)
4.
1.2.4b-1 Complete staffing Open
Several positions remain
of exempt positions in the
to be filled.
Personnel
Radiological Control Group
are filling the post-
(August 31,1985)
tions in an acting
capacity.
(50-293/85-32-03)
5.
2.1.1-1 Define Radiolog-
Complete
None
tcal Control Group person-
nel qualification criteria
(August 31,1985)
6.
2.1.1-2 Use task analysis
Complete
None
to define qualifications
needed for each Radiological
Group position.
Incorporate
qualification criteria into
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material to be generated to
meet Milestone 1.2.2(1-7)
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COMMITMENT
STATUS
NRC Comment
7.
2.1.2b-1 Establish formal
Open
The licensee estab-
position specific selection
lished formal
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criteria for hiring
position specific
(September 30,1985)
selection criteria
for hiring.
However,
the criteria were not
consistent with
Technical Specification
requirements relative to
minimum required
experience. The
incorrect criteria had
been incorporated into
job postings.
(50-293/85-32-04)
8.
2.1.3-1 Develop a program
Complete
None
to assist a supervisor
following assignment to
a new area of responsibility
(August 31,1985)
9.
2.2.2.6-1 Establish a formal
Complete
None
training program for Radio-
logical Group supervisory staff.
(August 31,1985)
10.
2.2.2.b-2 Establish speciality Complete
None
for technicians in such areas
as TLD processing and whole
body counting.
(September 30,1985)
11.
2.2.3-1 Establish a formal
Open
Retraining program
continting training program
not clearly defined
for all Radiological Group
(50-293/85-32-05)
personnel.
Technical training
material will be developed.
(October 31, 1985)
12.
2.2.4-1 A Radiological
Open
The training department
Group member will review
did not have all
course material developed
applicable review find-
for Health Physics technical
ings and consequently
personnel.
(September 30,
was unable to demon-
1985)
strate where all review
findings were addressed.
(50-293/85-32-06)
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COMMITMENT
_ STATUS
NRC Comment
13.
4.1.la-1 Evaluate the
Open
The licensee evaluated
effectiveness of the
the effectiveness of the
extremity dosimetry
extremity dosimetry
program and ensure that
program and revised
guidance for calculating
appropriate procedures
and recording extremity
(SI-RP-2402).
However,
exposures is adequate
extremities were not de-
(September 30,1985)
fined (50-293/85-32-07)
14.
4.1.1b-1 Evaluate
Complete
None present guidance
for resolving TLD data
discre pancies
(August 31,1985)
15.
4.1.lb-2 Provide
Open
Procedure 6.2-011
additional guidance
established.
To be
for resolving TLD
revised. (SI-RP. 2400
discrepancies.
in draft) (50-293/65-
(September 30,1985)
32-08)
16.
4.1.2a-2 Evaluate current
Complete
Licensee evaluated the
procedures to include the
and modified procedures
requirement for " spiked"
as appropriate (SI-RP-
TLDs (September 30,1985)
2001)
17.
4.1.2.a-3 Evaluate
Complete
Licensee evaluated the
the current QA program
for extremity monitoring
and modified procedures
devices. Modify procedures
as appropriate (SI-RP-
to include " spiked" TLDs
2001)
based on evaluation of
Millstone 4.1.2(c)
(September 30,1985)
18.
4.1.2b-1 Develop support
Complete
Evaluation of current
data necessary to document
correction factor
the basis for the beta
found that it provided
correction factor currently
for underestimation of
used by the TLD vendor.
true beta dose by a
(October 31,1985)
factor of about 3.
Licensee has modified
factor used and; is
reviewing previous beta
exposure data to
determine need for
correction of personnel
exposures.
(50-293/85-32-09)
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COMMITMENT
STATUS
NRC Comment
19.
4.1.4-1 Evaluate proce-
Open
Licensee addressed
dural guidance for the
exposure trending in the
evaluation of dosimetry
Radiation Protection
data. Address ALARA
Program document. A
exposure trending in the
temporary procedure
ALARA section of the
(TP 85-45) was
- Radiation Prote: tion
established for ALARA
Program document
implementation. The
(October 31, 1985)
temporary procedure
did not provide clear
guidance relative to
performance of ALARA
reviews of on going work
(50-293/85-32-10)
20.
4.2-3 Issue Policy
Complete
Licensee issued a policy
statement if required
statement.
The state-
on the exposure of
ment was signed by the
fertile females
Senior-Vice
(R. G. 8.13
President-Nuclear.
October 31,1985)
21.
4.3-1 Review High
Complete
Review during Inspection
Radiation Area Physical
50-293/85-22 found that
Controls (June 30, 1985)
control had not been
addressed.
Licensee
subsequently reviewed
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key control and
implemented additional
controls.
22.
4.3-2 Improve the level
Open
Licensee upgraded level
and quality of physical
and quality of physical
controls applied to high
controls applied to high
radiation areas, as appro-
radiation areas. Key
priate (October 31,1985)
access was restricted,
posting was upgraded, a
statis board was
established and a new
procedure was drafted to
provide administra-tive
controls over access to
high radia-tion areas.
The proce-dure remains
to be approved.
(50-293/-85-32-11)
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COMMITMENT
STATUS
NRC Comment
The following matters do
not appear to have been
addressed:
a minimum training /
qualification of person
issuing and receiving
keys (Both) Areas >1R/hr
and areas >10R/hr)
,
- updating of high
rad status board.
23.
5.2.lb-1 Evaluate the air
Open
The licensee established
sampling program to deter--
a revised air sampling
mine if appropriate air
procedure. However,
samples are being obtained
provisions were not
(October 31,1985)
contained in the proce-
dure for limitations of
self-absortion factors
and methodology for
sampling for and
evaluation of pure beta
emitters. Also, Pu-238
is being used as the
alpha MPC. No basis for
the use of Pu-238 was
provided.
(50-293/85-32-12)
24.
6.1.1-1 Establish,
Open
Licensee established,
approve, and implement
~
approved and imple-
a procedure and/or a
mented a group instruc-
group instruction
tion for performance of
for the routine perfor-
an in vitro bioassay
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mance of an in vitro
program. (SIRP.2100)
bioassay program.
(September 30,1985)
Procedures do not pro-
vide clear guidance for
determination of intake
(i.e. MPC-hour exposure)
(50-243/85-32-13)
25.
6.1.2-1 Complete review
Complete
None
of ANSI N343, and ANSI
N13.30Property "ANSI code" (as page type) with input value "ANSI</br></br>N13.30" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. (August 31,1985)
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COMMITMENT
STATUS
NRC Comment
26.
6.1.2-2 Determine the need
Open
The licensee uses the
for a QA program for the
services of Yankee Labs
commercial, off-site
for performance of
analytical laboratory.
analytical work. The
Develop QA procedure
acceptability of the
and/or group instruction
lab is reviewed once a
as needed (October 31, 1985)
year by a utility
committee consisting of
members from different
utilities who use the
lab. This is
acceptable.
However,
time limitations
prevented the inspector
from determining what
mechanism is in place to
determine the need for
and to establish a QA
program (if needed) for
labs other than the
Yankee Labs.
(50-293/85-32-14)
27.
6.2.1.b-1 Validate
Complete
None
bench marks of whole
body counter (One month
after receipt of sources)
28.
6.2.1 -1 Review procedures Complete
Procedure 6.2-161
9
and resolve any discrep-
should be revised to
ancies in recommended
reflect new procedures
internal deposition action
(SI-RPs) (50-293/85-
levels and external contami-
32-15) (i.e. cross
nation limits (August 31,1985)
referenced)
29.
6.2.1h Approve a
Complete
None
procedure or group
instruction for a systematic
methodology for
,
investigation, documentation,
and records maintenance of
abnormal internal exposures.
(August 31,1985)
-
.
. - - _ - - _ _
--
.-
.
fm
D
7
COMMITMENT
STATUS
NRC Comment
30.
6.2.11 Develop procedure
Open
Procedures do not
that contains the
provide clear guid-
approved methods and
ance for determina-
calculations for
tion intake by in
determining intake of radio-
vivo counting active
material (August 31,1985)
(50-293/85-32-16)
31.
6.2.1k Order whole body
Open
(50-293/85-32-17)
counter spare parts and/or
new equipment (as appro-
priate) (deferred to
November 30,1985)
32.
6.2.2-1(a,b,c) Establish
Complete
Guidance included in
guidance for the bicassay
procedures
program to address:
selection of individuals
a
for non routine bioassays
review of data by super-
vision
work restrictions
33.
7.1.1-1 Develop a formal
Open
Licensee has estab-
summary / mat.-ix of all
lished the summary /-
routine surveys
matrix. However, pro-
(August 31,1985)
cedure is in draft.
(50-293/85-32-18)
-
34.
7.1.1-2 Determine if
Complete
Licensee determined
matrices addressing
the calibration matrices
calibration are needed
were not needed.
(August 31,1985)
35.
7.1.3-1 Review present
Complete
Licensee reviewed
procedures for types of
applicable procedures.
surveys to be performed
A summary / matrix was
and for ensuring survey
established for routine
documentation is appro-
surveys.
priate and approved.
(August 31,1985)
36.
6.2.2.e Develop program
Opea
Documentation not
for the routine comparison
provided to demonstrate
of air sample, whole body
closure of item
count and respiratory
(50-293/85-32-19)
protection program data.
(September 30,1985)
.
6
9
8
'
COMMITMENT
STATUS
NRC Comment
37.
7.1.4-1 Identify and
Complete
Procedure SR-RP-4702
implement if necessary
a frequency for changing
CAM filters. (August 31,
1985)
38.
7.1.5-1 Consolidate and
Complete
SI-RP-3000
Standardize air sampling
requirements.
(August 31,1985)
39.
7.1.7-1 Evaluate present
Cngoing
Internal review program
practice for adequacy and
currently reviewing, in
timeliness of radiological
an on going fashion, the
surveys (on going)
adequacy and timeliness
(August, September, October
of surveys
1985)
40.
7.1.8-1 Complete procedure Open
Licensee established
changes to improve account-
group instruction to
ability and storage of survey
improve accountability
and air sample data by
and storage of data.
ensuring:
(SI-RP-1002)
+ surveys located with RWPs
Procedure in draft.
- document transfer to
(50-293/85-32-20)
document control
- assigning long-term
responsibility
(September 30,1985)
41.
7.1.8-2 Complete evalu-
Complete
Licensee completed
ation and assign respon-
evaluation and
sibility for account-
assigned responsibility
ability and storage of
Radiological Group records
(September 30,1985)
42.
7.1.9 Evaluate the
Open
Procedure not established
of the frisker-only
to incorporate recom-
analysis clean area
mendations (50-293/85-32-21)
smears (August 31,1985)
43.
7.1.10-1 Evaluate methods to0 pen
Procedure not established
reduce high
to incorporate evaluation
minimum detectable
findings (50-293/85-32-22)
activities currently
associated with alpha
smears, and incorporate
and use an appropriate method
(August 31,1985)
r
..
.-
4
9
COMMITMENT
STATUS
NRC Comment
44.
7.1.11-2 Order new area
Complete
Licensee evaluated
Radiation Monitors if
the need for additional
required (August 31,1985)
ARMS and determined
they were not needed.
45.
7.2.1 through 10, Item 3
Open
Draft program in place.
Establish an restructured
Final procedure and
RWP program. (September 30,
program to be
1985) (Deferred to October 15,
established
1985)
(50-293/85-32-23)
46.
7.2.1 through 10, Item 4
Complete
Revised material,
Approve training materials
as appropriate should
for structured RWP program
be provided to address
final program and
procedures (See
Item 7.2.1 through 10,
Item 3)
(50-293/85-32-24)
47.
7.3.2-2 Develop and
Complete
Licensee established
implement a contami-
Nuclear Operators
nation control
Policy (NDP) 85 RC1.
effectiveness review
The NOP provides for
process (August 31,
contamination control
1985)
effectiveress review.
Implementation will be
reviewed during a
substv.ient inspection
48,
8.1.2-2 Consolidate
Open
50-293/25-32-25
current radioactive
waste storage areas.
(September 30,1985)
(Deferred to December 30,
1985)
49.
8.1-3-3 Provide enclosure
Open
50-293/85-32-26
to protect radioactive
material stored outdoors.
(September 30,1985)
(Deferred to November 30,1985)
50.
8.1.4-4 Shield consoli-
Open
50-293/85-32-27
dated radwaste storage
areas (September 30,1985)
1
(Deferred to December 30,
1985)
.
&
10
CC$NITMENT
STATUS
NRC Comment
51.
9.1.1-3 Radiation
Complete
None
Protection Program
,
document will contain an
ALARA section. The section
will discuss shielding,
engineering controls, key
performance indicators, goals,
and procedures. (August 31,
1985)
52.
9.1.1-4 Approval ALARA
Complete
None
committee charter
(August 31, 1985)
53.
9.1.1-5 Define specific
Complete
Licensee defined
Key Management responsi-
specific key management
bilities in the area of
responsibilities in a
ALARA (September 30, 1985)
Nuclear Operations
Policy (NOP)
54.
9.1.1-6 Approve ALARA
Open
The document was
section of Radiation
approved g' the Radio-
Protection Program
logical Group Section
documents (September 30,
Head.
The document
should be approved by
Station Management since
the document effects
the entire station.
-
(50-293/85-32-28)
55.
9.1.6-1 Incorporate
Open
Requirements incorpor-
revised RWP requirements
ated into temporary into
procedures.
Procedures
cedures (September 30,
should be made perma-
1985)
nent. (50-293/85-32-29)
i
O
o
'<
11
-COMMITMENT
STATUS
NRC Comment
56.
9.1.7a, b-1 conduct
Open
Licensee performed a
a thorough, systematic
review of PNPS areas,
review of PNPS for areas,
systems, activities,
systems, activities, etc.,
that could benefit from
that require or would
ALARA consideration.
benefit from ALARA consider-
However, the criteria
ation (October 31, 1985)
that was used to
determine if a system
or activity could
benefit from ALARA
consideration was not
specified.
Consequently, it was not
clear that all
appropriate activities
or systems had been
considered.
(50-293/85-32-30)
57.
9.1.8-1 Evaluate
Complete
None
programmatic controls
over the use of shielding
(August 31,1985)
58.
9.1.8.a through d,
Complete
None
Item 2 complete the
ALARA section of the
Radiation Protection
Program document.
(September 30,1985)
59.
10.1.3-3 Establish a
Open
Licensee Program
long term approach
currently being
to housekeeping
developed (50-293/
(October 15, 1985
85-32-31)
deferred)
60.
10.1.4-2 develop
Complete
Licensee performed
action plan for
the review and the
review of the
established procedures
issuance and control
for issuance and control
of Health Physics
of instrumentation
(August 31,1985)
(SI-RP-5000).
Pr.cedure
in draft
(50-293/85-32-32)
r-
0
o
e
12
61.
10.1.4-3 Order equipment
Complete
Additional instrument
as appropriate
lockers were installied
to improve issuance and
control of health physics
,
'
instrumentation
(September 30,1985)
62.
10.1.6 Set up Instrument
Complete
None
storage racks.
(September 30,1985)
63.
10.2 1.a-2 Upgrade
Open
50-293/85-32-33
whole body counting
equipment. Order
appropriate equipment,
including software
(September 30,1985)
(Deferred to November 30,
1985)
64.
10.2.5.c Implement
Complete
None
use of new calibration
jigs.
(August 31,1985)
65.
10.2.6-2 Determine
Complete
The licensee evaluated
the need for new
the need to obtain addi-
equipment to aid in
tional equipment. Addi-
the conduct of Radio-
tional equipment as
logical Group activities
appropriate was
(August 31,1985)
obtained/ ordered.
66.
10.2.8-2 Establish
Complete
None
group instructions
or procedures for
checking high efficiency
particulate filter units
for breakthrough.
(August 31,1985)
67.
12.2-2 Management to
Complete
Program outline approved
approve Radioactive
and Contaminated
Material Control
Program (August 31,
1985) (Deferred to
October 15,1985)
F
o
1
0
13
COMMITMENT
STATUS
I
NRC Comment
68.
12.2-3 Oraft Radioactive
Complete
Program document
p-
,
Contaminated Material
Control Program document
drafted. Facility modi-
and develop recommended
fication recommended,
facility modification
(September 30,1985)
69.
13.3.1-1 Develop and
Open
publish goals for the
The goals did not appear
Radiological Group
comprehensive or
challenging.
(50-293/85-32-34)
70.
13.3.2-1 Establish
Complete
Indicators contained in
key performance
indicators as guidance
Nuclear Operations
for measuring performance
Policy
and effectiveness of the
Radiation Protection Program.
(September 30,1985)
71.
13.4-1 Complete develop-
Complete
Draft documents ment of
radiation
protection program
developed.
Documents
documents to provide
to be reviewed and
cohesiveness to the
approved by December
31, 1985 Radiation
Protection Program (September 30,1985)
i