ML18085A340
| ML18085A340 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/07/1980 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML18085A339 | List: |
| References | |
| NUDOCS 8012080122 | |
| Download: ML18085A340 (11) | |
Text
rick W. Schneider ice President Public Service Electric and Gas Company 80 Park Place Newark, N.J. 07101 201/430-7373 Production
- auly 7, 1980 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement USNRC Region 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
NRC INSPECTION 50-272/80-03 UNIT NO. 1 SALEM GENERATING STATION We have reviewed the report of your inspection conducted during the period January 28-31 and February 1-8~ 1980.
Our response to the Significant Appraisal Findings and to the noncompliances indentif ied in Appendices A and B of your Inspection Report are as.follows:
Appendix A - Significant Appraisal Findings Finding Ia in your Appendix A, "Technical Competency (Technical Depth) of t_he Heal th Physics (HP) Organization",
states:
There is a general lack of technical proficiency in the HP Staff predominantly due to:
failure to select, qualify and train personnel (partic-larly technicians} specifically in the HP specialty.
The current program attempts to qualify and train technicians so that they are capable of performing activities in the Instrument and Control, Chemistry and HP specialities.
To further confound the development of proficiency, the
- personnel job assignments are rotated, continually through each of the specialities so that personnel are not afforded sufficient time-and experience to appreciate and develop the technical skills necessary to perform in a responsible position.
failure to develop and implement a technician retraining*
program to assure that the technicians' skill and knowledge is maintained at a satisfactory level.
Previous training sessions were given on an ad hoc basis, however these were given without reviewable lesson plans, formalized procedures or training documentation.
Currently, another retraining session is underway but lesson plans, training procedures and training documentation systems have yet to be formalized;
- fHrP Jl 2 0 8 0 /).1.
L Boyce H. Grier, Dir.
2 -
7-7-80 failure to have an adequate back-up for the Senior Performance
- supervisor - Radiation Protection (RPM).
Currently there are no individuals on the HP staff at the station with manage-ment and technical abilites sufficient to act as and alternate.to the RPM, including the HP foreman.
At this time, essentially *all of*.the technical and managerial expertise** is vested. in a single individual, the RPM.
Reply to Finding (Ia)
- 1.
The present Performance Department organization makes it difficult to retain personnel in one specific area long enough to fulfill the requirements*of ANSI Nl8.l.
Staffing.problems have prevented the establishment and implementation of a formal training program.
- 2.
The station had identified the lack of a formal tech--
nical training and retraining program through internal audits completed by the Station QA group prior to the NRC Inspection.
A modest program was developed and presented to the Radiation Protection staff.
Expansion
- of the present program to include additional topics.
and management training is being evaluated by corporate
- management at tnis time.
The implementation of an ex-panded program should reduce the burden currently placed on the RPM.
An alternate to the RPM was acquired and is presently on station.
- 3.
The responsibility for the training and retraining program has been delegated to the "Training Coordinator" for Radiation Protection.
This individual is responsible for the development, administration, updates and documentation of the Radiation Protection Training Program.
- 4.
Date for expanded formal training program implementation is December 1, 1980.
Date for completion of appropriate training and qualification is July 1, 1981.
Finding Ib in your Appendix A,. "Inordinate Reliance on HP Contractor Personnel", states:
Because of the attempt to cross train and qualffy personnel (technicians particularly), to perform in I&C, Chemistry and HP specialities, few PSE&G personnel are ever qualified to assume responsible positions as technicians.
To support a two unit operation, the station's Performance Department has identified the need for about.55 people.
Of this number PSE&G supplies approximately 12 people*(! RPM; 2 Foremen; 4 Technicians Nuclear (ANSI-Nl8.l qualified); and 5 Technical Assistants or Helpers).
The remainder are supplied by a contractor organization
Boyce H. Grier, Dir.
3 -
1:...1-so (Rad Services, Inc. {_RSI}).
RSI provides the entire technical
- a:nd administrative support,*.all in-plant radiological controls and moni-t:.oring; all HP training; and radioactive waste
- coordination.
PSE&G personnel provide dosimetry and records maintenance, operation of counting equipn;tent, and provides the respirat0ry protection program.
In
.these areas RSI provide up to 50% of the manpower needs.
RSI is relied on heavily in all normal, off normal and emergency conditions.
However,.the technicians (some are.ANSI-Nl8.l qualified in terms of 2 years previous experience)* are not *subjected to any formalized academic
- training related to *their specialty..
- Their knowledge "
comes from either previous experience or on-the-job training.
On the average,.technicians spend about 6 to 8 months at Salem Nuclear Generating Station.
Therefore, they are generally not familiar with the plant's char-acteristic systems.
In emergency or off normal conditions this could greatly reduce the effectiveness of the HP organization.
Generally 80-90% of the HP staff _openings essential for two unit operation are 'filled by contractor personnel.
Reply to Finding * (:Ib)
- 1.
The cause of this item was address*ed in sufficient detail in the main body of the inspection report.
2 *.
A complete re-.organiz~tion of th.e ll?erformance Department is currently under.management review.
Upon final acceptance and development, the new organization will provide enough flexibility to allow th.e technicians to obtain the necessary experience to satisfy ANSI Nl8.l.
The plan provides a time-table for permanent station personnel to gradually replace the majority of contractor personnel currently on-station.
- 3.
We expect that the action described in 2 above will prevent recurrence.*
- 4.
Date for.full compliance is July 1, i981.
Finding IIa in your Appendix A "Responsibility", states:
Although the RPM is designated as the :individual.responsible for coordination of radioactive waste :management, there is essentially. no program in this area: at this time.*
The licensee's response to Inspection Report 272/79-31 appears*
to address this concern and indicates that a program will be 'formally implemented by March *30, 1980 as a function of a new Administrative Procedure (AP) called "Radioactive Waste Management."
In actuality, the AP is to provide for
Boyce H. Grier, Director 4 -
7-7-80 an interim solution for th.e :management 6£ solid radwaste.
Currently, there *;1.s no program Underway to deal effectively with. *the *management of. all types of radwas_te.
Reply to Fi"ndin*g *:t::ra. *
- 1.
The program was still under investigation during the inspection period.
- 2.
The new Administrative Procedure -
29 has been completed, approved and implemented.
A supervisor has been assigned the res*ponsibili ty for direct supervision of radwaste shipments.
The RPM has retained ultimate responsibility for the program as Radwaste *coordinator.
- 3.
A aad~aste Manual is being written at this time.
The manual will provide further detailed instructions for packaging, labeling and loading of radwaste.
The com-pletion and implementation of the manual will prevent recurrence.
- 4.
Date for full compliance is.October 1, 1980
- Finding IIb in your.Appendix 'A, "Effluents", states:*
- a.
There is currently no system in place for reviewing noble
. gas recorders to quantify anomalous releases that may occur between the weekly_ grab samples taken of gaseous effluents.
- b.
Procedure PD-3.8.016 contains an erroneous formula for calibrating total activity in* waste Gas Decay Tank releases, causing underestimating of noble gas, iodine and particulate activity by as much as 20%.
- c.
Procedures have not been developed for primary sample collection and analysis in emergency conditions.
- d.
Interim actions pertaining to high-range capability in Nobel Gas monitoring have not been completed as required by the NRR Lessons* Learned directives issued October 30, 1979, as specified in NUREG-0578.
- 1.
No approved procedure existed to specify this required function.
- 2.
Recorders are reviewed and documented daily to quantify anomalous releases.
Results are kept in the Radiochemistry Lab, as retjuired by procedure PD-3;3.023.
Boyce H. Grier, Dir.
5 -
7-7-80 3~
4 ***;
~* ~
_The daily action described in 2 above has been incorporated in "l?lant::Verit Sample Analysis"* procedure PD-3.3.020 and "Gaseous Radwaste Release Calculations" procedure PD-3.8.016.
It is expected that this will prevent recurrence.
We are in compliance now.
- Reply* to Finding Tib,: S:ubp'ar:t: b
- 1.
Procedure PD-3.8.016 specified an incorrect_ gas decay tank volume.
2.*
Revision 3 of PD-3.8.016 contains the corrected formula and is now in the approval process.
- 3.
We expe:ct that the action described in 2 above will prevent recurrence.
- 4.
Date for full compliance is August 1, 1980.
Reply to Findin*g I'Ib,* Subpart c
- 1.
Information was being accumulated over a long period of time to provide a design basis for the interim post accident sampling system.
- 2.
Procedure PD-3.5.071 has been developed for post-accident primary sample collection and analysis in emergency conditions.
This procedure is presently in the approval cycle.
A Design Change request has been initiated to install the necessary equipment.
- 3.
Date for full compliance is August 1, 1980.
Reply to Findi*ng* *I:rb, * -S-ubp*a:rt d
- 1.
Oversight in not installing the high range capability in noble gas monitoring by the commitment date.
- 2.
The required monitors have been installed between the vent stacks on Unit 1 and 2.
- 3.
No action to prevent recurrence is applicable.
- 4.
we are in complaince now
- Finding III in your Appendix A, "Health '.Physics Surveillance Activities", states:
.a.
An acceptable Respiratory Protection Pro9ram has not been: demonstrated in that *several deficiencies pertaining to quality assurance, training, _equipment maintenance *
- were observed.
L Boyce H. Grier, Dir.
6 -
7-7-80
- b.
There is no routine review by station personnel of radiation protection instrumentation and equipment calibration records for* procedure adherence and accuracy for those instruments and equipment calibrated by contractors.
- c.
Arbitrary efficiency factors are utilized for HP 210 detectors used to evaluate radioactive contamination.
No actual efficiency determiniation has been made.
- d.
Bioassay procedures are deficient in that there is no provision to collect baseline or termination data on individuals subjected to exposure to airborne activity.
Reply to Finding rr-r-, * *subpart *Cal
- 1.
Training and procedure for the proper use and maintenance of respiratory equipment were stilt under development during the inspection period.
- 2.
The Respiratory.l?rotection Program has been completed and all the items noted in the inspection have been rectified.
Notice of program completion was transmitted to the NRC on March 14, 1980.
- 3.
We expe9t that the action described in. 2 above will prevent recurrence.
4*.
We are in compliance now.:
Reply to* Finding -rrr:,: :s:ubp*art b
- 1.
Insufficient training for superviso*rs and Instrument Technicians.
- 2.
Instrument Technicians and cognizant supervisors have received instr.uction on procedure adherence and the conduct of appropiate *reviews of calibration records.
- 3.
It is expected that the *action described in 2 above increased supervisory invo.'.l,vement and will p:i::'event rec"urrence *
- 4.
We are in compliance now.
- 1.
Previously determined efficiency f?1,cto.;rs. we;i:;re not adequately documented.
- 2.
New efficiency data was accumulated to :reverify th;e
- previously obtained val-ues-.
Tc-99 sources with; an
Boyce H. Grier, Dir.
7 -
7-7-80 average beta energy within 8% of C0-60 we;re used for the *efficiency determination.
- 3.
The action described in 2 above will prevent recurrence.
4
- We are in compliance now.
Rep'ly to* Finding* *rrI, * *subp:art d
- 1.
The primary cause was the dependence on an outside con-tractor for whole body counti~g and an inadequate procedure.
- 2.
A whole body counter operated by the Radiation Protection
. group is in operation at the *station.
The system is installed adjacent to the Dosimetry Office, which allows for prompt processing of personnel.
A newly written procedure, PD-15.3.027 "Whole Body Counting Frequency",
when implemented, will reinforce the requirement to provide whole body counting for all incoming and terminating personnel.
- 3.
The action described in 2 above will prevent recurrence *
- 4.
Date for full compliance is July 30, 1980.
Finding IV in your Appendix A, "Emergency Preparedness",
states:
- a.
There is a lack of assignment of emergency duties and responsibilities ;for radiation protection personnel, the Station Manager and repair/corrective action teams.
- b.
There is no clearly defined program for traini,ng all individuals who may be assigned emergency duties.
- c.
Procedures governing radiation protection and security activities during emergencies do not exist.
- Reply to: Findin*g :;rv
- 1.
The cause is tha:t the three* items identified are newly established requirements primarily pertaining to NUREG-0654.
2a.
Revision 11 of the Emergency Plan defines the :res*ponsi-bilities of the Station Manager.
Additional clarification is planned for revision 12 *.
- Revision 12 will elaborate on the necessary manni~g of the repair/corrective action teams.
These teams will consi*st of the t*echnical support individuals (department hea;ds}
- and the'ir subordinates.
The assignment of emergency duties* for the *radiation protection personnel is now de;fined in the* Emergency Plan.
Additional guidance will be 'incorporated in the Radiation Prote.ction Manual.
Boyce H. Grier, Dir.
8 -
7-7-80 2b.
All Emergency Outy Office~s and most of the shift personnel
.have received trainin9 in the current revision of the Emergency Plan.
Appropriate training for those 'personnel having post accident responsibilities, as defined in the upcoining revision 12 to the Emergency Flan, is under
- evaluation at this time.*
2c.
Security activities during emergencies are addressed in the Security Manual.
The appropriate references in the Emergency Plan will be incorporated in the next revision.
Procedures governing radiation protection activities are incorporated in the Radiation Protection Manual.
Approxi-mately 60% of the necessary procedures are complete and*
approved.
The remainder are still being developed.
- 3.
It is expected that the actions described in 2 above will prevent recurrence.
- 4.
Date for full compliance is October 1,.1980 *
. Ap*p*e*ndiX B *-* Notice *o*f Vi;oTati*on Item 1 (Infraction) of your Appendix B, states:
Technical Specification 6. 8.1 states, in part,.that written procedures shall be *established, implemented. and maintained covering the activities
.. recommended in Appendix A of Regulatory Guide 1.33, Rev. 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 8.B(l) (aa) states that, specific proce-dures fol:' surveillance, test, inspections and calibrations should be written: for area, portable, and airborne radiation monitoring instruments.
The following procedures were written in accordance with this Technical Specification:
- a.
Station Procedure J?P-15.9.004, "Calib:i:;ation of the Radiation Monitor,.Model RM-14", Rev. O,.:Paragraph A.I.7 states, "place a beta-gamma, standa,rdiz.3.tion source ~gainst or directly Under the probe, the indicated count rate should be *10.20% of the indicated standard DPM for the pancake *detectors."
- b.
Station Procedure PD-15.9.009, "Calibration of Eberline
- Portable Neutron Rem Counter", J?:RN-4, Rev. o, l?a,ragraph A. I. 2-5 states, "place *instrument in a 4 *ml.llireni per hour, 40 millirem per hour, _400 mil.lirem per hour and 4 rem per hour neutron field and check reading.
If correct readings within 10% are *not obtained in all fields,.
proceed to Secti,on II."
Contrary to Techri.i.cal SJ;Decification 6. 8.1,.the. *foll.owi~g observations were made on February s, 1980:
Boyce H. Grier, Dir.
9 -
7-7-80
- a.
Station Procedure PD-15.9.004 was not adhered to in that a beta-gamma standardization source was not being used to calibrate the RM-14 instrument.
Observations and interviews with Instrument Repair Technicians indicates that only an electronic calibration using a pulse generator is used in the calibration of the RM-14.
- b.
Station Procedure PD-15.9.009 is not being adhered to in that the PNR-4 instrument is not placed in a 4. millirem per hour, 40 millirem per hour, 400 millirem per hour or 4 rem per hour neutron field and checked.
Observations and*interviews indicated that this part of the procedure is not being adhered to because the output from the
'neutron source is not known.
- c.
On February 6, 1980 it was determined that there are no procedures established, implemented or maintained detailing calibration of the air flow on air sampler equipment used within the station, specifically the Staplex air samplers.
Reply to Item 1, Subpart a
- 1.
A source was not used for calibration because of a lack of adequate supervision to ensure procedure adherence and of an improperly written procedure (PD-15.'9.004).
- 2.
The indentified procedure will be revised to use electronic pulsing as the primary calibration.
The efficiency factor commonly used in the station (20%) was verified as correct.
- 3.
Supervisors have been instructed to become more involved in assuring that procedures are properly written and com-plied with.
This, together with the revision of the pro-cedure described in 2 above, will prevent recurrence.
- 4.
Date for full compliance is July 30, 1980.
Reply to Item 1, Subpart b
- 1.
Dose calculations for the neutron sources were not available
~o the technicians who perform the source checks.
- 2.
Dose rate calculations have been completed for the two neutron sources utilized at the station.
These calculations verify that previous electronic calibrations were accurate.
The associated procedure will be revised to indicate the use of electronic primary calibration.
A source check with the
, neutron source will be performed at each calibration, to verify the operability of the detectors.
Due to ALARA considerations, the source check will.be conducted at low dose rates only, since the ratio of pulses to MR/HR remains constant for all scales.
- 3.
The Instrument Technician and the cognizant supervisor have been informed of the:.dose calculations availability and
Boyce H. Grier, Dir. 7-7-80 instructed to utilize this information for each calibration.
- 4.
Source checks are *currently being performed.
Date for procedure revision is August l,* 1980.
- Rep:ly to Item T,: S:u:bpa:r't c
- 1.
Calibrations conducted on air sampling equipment were previously completed by an off-station facility and the appropriate procedures for on-station calibration were
- never established.
- 2.
- Procedure PD-15 *. 9.026, "Calibration of the Staplex High*
Volume Air Samplers", was approved and implemented on March 12,.1980.
- 3.
It is expected that the action des-cribed in 2.above will prevent recurrence.*
- 4.
We are in compliance now.
Item 2 (Infraction) of your Appendix B, states:
Technical Specifi..cation 6.8.2.states in part that, each procedure and administrative policy of Technical Specification 6. 8 *. 1 and changes thereto shall be reviewed by the SORC and approved by the Station Manager prior to implementation.
Contrary to this specification, on February 6, 1980 it was observed that Station Procedure PD-15.9.011, "Calibration of Teletector 6112" and Station Procedure l?D-15.9.002, "Background and Efficiency Determination of BC-4 and SCA-4 Co\\inting Instruments"
- had been changed and implemented in the field without being subjected to review by the SORC and approved by the Station Manager prior to implementation of those changes.
Reply to* Item 2
- 1.
Due to an administrative oversight, approved procedures were not available for use 'in the field; therefore the unapproved copies have been used.
- 2.
Prior to the audit, the *Radiation Protection CRPl group was in the process of retrieving all copies of radiation protection procedures.
Ali. unapproved pX'ocedures were removed from service and sixteen complete sets of approved procedures were *issued on March *1, 1980 *
- 3.
Written instructions have bee*n issued to the entire Radiation Protection staff etriphasizin9' the requirement to use approved procedures exclusively.
Additionally, an RP Administrative Manual-has been: assenibled to strengthen procedural control.
Boyice H. *. G:r.;i.e;ri,.. D;i,;i:;o. *
- 4.
We are in compliance now.
Item 3 (Deficiency) of your Appendix B, states:
10 CFR 20.203 (f) requires that each container of licensed material shall bear a durable, clearly visible label identifying the radioact-ive contents.
The label shall bear the radiation caution symbol *and the words:
"Caution Radioactive Material" or "Danger Radioactive Material" The label shall also provide sufficient information to permit individuals handling or using the containers, or working in the
~icinity thereof* to take precautions to avotd or minimize exposures.
Contrary to the above, several tours in the controlled areas, conducted during the period January 28 thru February 8, 1980, identified bags of radioactive trash reading up to 4 mR/HR on contact that we:r;e not labelled and no exemption applied.
Reply to Item 3*
- 1.
Some Rad Protection personnel were not appreciative of the importance of labelling bags that contain tools and material from a contaminated area.
- 2.
Pre-labeled poly bags with the standard radiation symbol and the phrase, "Caution Radioactive Material", are currently in use.
These bags are only used in contaminated areas.
Routine station tours are conducted by supervisory personnel and a. memo has been issued to all station personnel concerning radioactive material containerse
- 3.
It is* expected that the action described in 2 above will prevent recurrence.
- 4.
We are in compliance now.
If you have any further questions with regard to this matter, *we will be pleased to discuss them with you.
Sincerely,
--#~
CC Director, Office of Inspection and Enforcement NRC Washington, DC 20555