ML18095A347

Responds to NRC 900611 Ltr Re Violations Noted in Insp Repts 50-272/90-14 & 50-311/90-14.Corrective Actions:Directive from Radiation Protection Mgt to All Radiation Protection Personnel Issued Re Control of Compliance Agreement Sheets

ML18095A347
Person / Time
Site:	Salem
Issue date:	07/11/1990
From:	Labruna S Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N90148, NUDOCS 9007170314
Download: ML18095A347 (5)

Text

Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nuclear Operations

JUL 11 1990 NLR-N90148 United States Nuclear Regulatory Commis.sion Document Control Desk Washington, DC 20555 Gentlemen:

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT.NO 50-272/90-14 AND 50-311/90-14 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas (PSE&G) has received the Notice of Violation dated June 11, 1990, regarding the failure to implement radiation protection procedures. Pursuant to the requirements of 10 CFR 2. 201, .our response this Notice of Violation is provided in the attachment to this letter.

Should you have any questions in regard to this transmittal, do not hesitate to call.

Attachment

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Document Control Desk 2 NLR-N'90148 ~JUL 11 1990 c Mr. J. c. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625

ATTACHMENT As a result of the inspection conducted from May 1-4, 1990, and in accordance with the NRC Enforcement Policy, (10 CFR 2, Appendix C), the fo'llowing violation was identified:

Technical Specification 6.11 requires, in part, that procedures

.for personnel radiation protection shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

1. Radiation protection procedure RP 201, Revision 2, Access Control Point Management, requires, in part, in section 1.2.1, that radiation protection personnel ensure that individuals entering the radiological controlled area (RCA) have-read the applicable Radiation Work Permit (RWP) and signed the RWP compliance agreement.

Contrary to the above, during the period April 24, 1990 through May l, 1990, radiation protection personnel did not ensure that all personnel working under Revision 2 of RWP No. 901S00383 had read the RWP and signed the RWP compliance agreement.

Between April 24, 1990 and May 1, 1990, two individuals entered the RCA and worked under Revision 2 of RWP No. 901S00383 a total of 15 times and had not signed the.

RWP compliance agreement.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of this violation was attributed to inadequate document control.

Interviews were conducted with the two individuals noted above and with applicable radiation protection personnel.

The two individuals noted stated that t_hey _had read the RWP, and demonstrated that they were aware of the specific requirements of revision 2. Both individuals stated that they had signed compliance agreements for the applicable RWP although they did not remember the specific revision.

Radiation protection personnel interviewed stated that, to the best of their knowledge, compliance agreements had been signed in ac*cordance with the applicable RWP. A review of all RWP files was conducted, but a compliance agreement sheet for the applicable RWP could not be located. An audit was performed by radiation protection supervisory personnel comparing Personnel Radiation Exposure Monitoring System (PREMS) entries with compliance agreement sheets, and Page 1 of 3

no other similar conditions were noted. Based on the interviews that were conducted and the audit of the agreement sheets, PSE&G believes that a compliance sheet was

• signed, but subsequently lost or destroyed.

CORRECTIVE ACTIONS TAKEN The following corrective actions have been taken: 1) A directive from radiation protection management to all radiation protection personnel was issued, specifying actions to be taken to strengthen control of compliance agreement sheets. 2) The event was reviewed with all radiation protection personnel. 3) An.audit of compliance agreement sheets against PREMS for the period of May 17 through June 11 was conducted. No other discrepancies were found.

CORRECTIVE ACTIONS TO PREVENT RECURRENCE A review of radiation protection procedures RP 201 and RP 202 is being conducted. This review will be completed and any required revisions will be initiated by .

July 31, 1990.

PSE&G IS IN FULL COMPLIANCE.

2. Radiation protection procedure'RP 204, Revision 2, Posting of Radiation Signs and Barriers, requires, in part, in section 7.1.7, that each room or area in which radioactive material is used or*stored and contains in excess of ten times the applicable quantities specified in 10 CFR 20 Appe!ldix .c be posted as "Caution - Radioactive Materials".

Contrary to the above. on May 1; 1990 the entrance to a trailer within the protected area of Salem Station was not posted "Caution - Radioactive Materials". The trailer contained in excess of 100 times the applicable quantities of radioactive materials as specified in 10 CFR 20.

Appendix c.

RESPONSE

PSE&G DOES NOT DISPUTE THE VIOLATION.

The root cause of this event has been attributed to procedural inadequacy.

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CORRECTIVE ACTIONS TAKEN The following corrective act~ons have been taken: 1) The material that had been placed in the trailer was removed to an area that was properly posted and controlled. 2) A walk down of all areas outside the RCA was performed to insure .

that no other similar situations existed. No other discrepancies were found. 3) Procedural requirements and management direction for control and posting of radioactive material was reviewed with all radiation protection personnel.

CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE Procedures RP 804, "Labelling and Control of Radioactive Material, RP 901, "Receipt and Inspection of Radioactive Material, and RP 909, "Shipment of Radioactive Materials*

Exclµding Wastes" are being revised. These revisions will be completed by July 31, 1990.

PSE&G IS IN FULL COMPLIANCE .

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