IR 05000206/1990026
| ML20058L904 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/23/1990 |
| From: | Cillis M, Coblentz L, Garcia E, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20058L901 | List: |
| References | |
| 50-206-90-26, 50-361-90-26, 50-362-90-26, NUDOCS 9008080355 | |
| Download: ML20058L904 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report:
50-206/90-26,50-361/90-26,and50-362790-26
Licenses:
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i Licensee:
Southern California Edison Company
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23 Parker Street i
Irvine, California 92718
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i Facility:
San Onofre Nuclear Generating Station In:;pection site:
San Clemente, California Inspection period:
June 25-9, 1990 l'
Inspected by:
L. C 1 tz, Kadiation Specialist D'att Signed
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arcia, Senior Radiation Specialist Date Signed hf.
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M. Cillis, Senior Radiation Specialist Date Signed l
Approved by:
O. M e 7Q3/92)
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G. Yuhps, Chief Date '51gned Reacw Radiological Protection Branch Summary:
Areas Inspected:
Routine, unannounced inspection of followup items, occupational exposure, control of radioactive materials and contamination,-
surveys, and monitoring.
Inspection procedures 92701,'83750, and 83726 were used.
Results:
The licensee's radiation protection program appeared capable of meeting established safety objectives.
The inspectors identified weaknesses in the licensee's implementation of internal exposure controls (Section 3) and control of contamination (Section 4).
No violations of NRC requirements were identified.
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9006080355 900723
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DETAILS n
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Persons Contacted Licensee
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k T. Adler, Supervisor, Health Physics (HP)' Planning l
S. Allen, Supervisor, Dosimetry
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J. Barrow, General Foreman, HP
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E. Bennett', Engineer, Quality Assurance (QA)
C. Bostrom Supervisor, Training
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D.Brevig, Supervisor,OnsiteNuclearLicensing(ONL)
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D. Duran, Engineer, HP
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R. Erickson, Senior Engineer, San Diego Gas & Electric J. Fee, HP Superintendent.
S. Folsom Supervising Engineer, ALARA E. Goldin, Supervisor, HP Engineering P. Hammond, General Foreman, HP P. Knapp, Manager, HP
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R. Krieger, Acting Station Manager.
J. Moore, Engineer,HP(BartlettNuclear)
R. Morgan, Engineer, HP K. O'Connor, Contract Manager J. Pope, Supervisor, Internal Dosimetry M. Ramsey, Supervisor, QA-J. Rolph, Supervising Engineer,-HP J. Reust, General Foreman, Radioactive Material Control'
J. Scott, Supervisor, HP M. Speer.. Lead Engineer, ONL L. Stilwagen', Engineer, Nuclear Construction
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A. Tally, Supervisor, HP Operations R. Waldo,; Assistant Technical Manager D. Werntz, Engineer, ONL
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H. Wood, Engineer, QA NRC
-C. Caldwell, Senior Resident Inspector
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The individuals listed above attended the exit meeting on June 29, 1990.
The inspectors met and held-discussions with additional members of the.
licensee',s staff during the inspection.
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Followup (92701)
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'Open-Item 50-206/89-23-01(Closed): This item concerned the interpretation of Technical Specification (TS) 6.5.3.5.b, which requires that audits performed under the cognizance of the Nuclear Safety Group shall encompass "the performance, training and qualifications of the entire unit staff at least once per 12 months." Based on clarification of the intent of this TS provided by NRC's Office of Nuclear Reactor Regulation, this item is considered closed.
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Occu'pational-Exposure (83750)
Audits
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The inspectors reviewed SCE QA Audit SCES-033-089, rhich examined
elements of the licensee's HP program, including personnel exposure
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records, radiation worker training, radiological.inc Hent reporting,
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radiation surveys, radiation exposure permits, and raficactive waste
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shipments. Six deficiencies resulted from the audit.
Particular attention was given to internal dosimetry, respiratory protection, and air. sampling, in response to concerns raised by the HP and Environmentel Group.
In addition, the inspectors reviewed' selected QA Activity Monitoring Reports and QA Surveillance Reports dating from July 1989 to May 1990.
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These reports focused on control of contamination and radioactive material, internal and external exposure, and HP survey instrumentation.
Findings of the audits and surveillances were routed in a timely manner.
Corrective actions were being appropriately addressed. At the time of the inspection some of the corrective actions were not yet complete.
The licensee maintained its previous level of performance in this area, and the audit program was adequate in meeting the recommendations of
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ANSI /ANS-3.2/N18.7. " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear. Power Plants."
Training and Qualifications of New Personnel The inspectors reviewed documentation of the training and experience of-contractor HP personnel for compliance with HP Procedure S0123-VII-9.8,
" Employment of Contract Personnel," and agreement with the recomendations of ANSI /ANS 3.1-1978, "Selecti m and Training of Nuclear Power Plant Personnel." Samples of senior and Junior HP technician resumes. indicated that a majority had previously worked for the licensee.
Incoming HP technicians had been administered a screening test to ensure
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basic HP knowledge prior to receiving the licensee's site-specific training.
The inspectors reviewed a study guide, consisting of a series of-multiple-choice questions and answers, made available to incoming contractor HP technicians prior to taking the screening exam. A copy of the~ actual exam was not available for comparison with the study guide; however, the licensee assured the inspectors that exam questions were
. periodically changed, and that the study guide did not compromise exam integrity.
The licensee's program for selecting and training contract health physics personnel had maintained its previous level of performance.
. External Exposure Control Selectedrecordsofexternalexgosuretoworkerswerereviewedfor compliance with 10 CFR 20.101, Radiation dose standards for individuals
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in restricted areas." No exposures were identified in excess of specified limits.
TheinspectorsexaminedRadiologicalObservationReports(RORs)for1990.
No reports had been submitted in four out of nine designated categorics,
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including reports'for " Failure to use sound radiological work practices."
f Seven reports had been submitted for TLD damage, and two for work-i'
activities not covered by a Radiation Exposure Permit (REP). The remaining 33 reports related to problems with access control, including
" Failure to log in at the control point," " Failure to log out at the
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control point," and " Failure to obtain PICS at the control point."
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.i The inspectors observed the implementation of access controls at the i
entrance to the Unit 2/3 Radiologically Controlled Area (RCA). All HP technicians and supervisors questioned agreed that-responsibilities of the access control technician included verbal verification of REP sign-in and visual verification of proper dosimetry; however, this practice was not consistently followed. During several entries.into the RCA the inspectors were ignored by the access control technician, and dosimetry
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On one occasion a worker was observed returning to the
access control station after having been in the RCA for approximately 5
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minutes, having forgotten to obtain Pocket Ion Chambers (PICS) prior to
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RCA entry. No ROR was submitted for thi: occurrence. The inspectors mentioned these observations to the HP manager, who agreed that access control technicians needed to improve performance.
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The inspectors also asked the HP manager why no RORs had been submitted for categories such as: failure to use f,ound radiological work prartkes.
The HP manager stated that the ROR stugram had been hphas1 zed in order to keep focus on the Personnel Contamination / Injury Report (PCIR) program i
(see Section 4 of this report). The HP manager stated, in addition,.that unsound radiological work practices were being monitored by HP technicians and reported to immediate supervisors through normal
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-logkeeping and shift turnover briefings.
The licensee had maintained its previous level of performance in this area, and the external exposure control program was adequate'in meeting the licensee's safety objectives.
Internal Exposure Control Inspector concerns regarding this arec were previously discussed in NRC Inspection Report 50-361/90-19.
Some improvements were observed;
'however, as noted below. several areas of program implementation require further management and technical staff attentinn.
The inspectors examined the licensee's Work Control Plans (WCPs) for tracking Maximum Permissible Concentrations (MPCs) 'and determining personnel internal exposure. The WCPs used three identifying codes for air sampling: JLC (Job Location Code) samples, taken for general areas in which concentrations of airborne radioactivity are presumed to be relatively uniform, REP (used for a particular Radiation Exposure Permit), and IND (special samples drawn when airborne radioactivity concentrations are expected to be higher than normal in the breathing
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zoneof'aLparticularindividual). Samples are obtained' daily or more
. frequently, as required, and data is entered into the computerized
HPC-tracking system by count-room personr.e1. Personnel exposure times
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are recorded on Air Sample Data Tags for REP:and IND'sampi m : exposure-
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times for various JLCs are estimated by individual workers after exiting containment-(based on memory), and provided orally' to dosimetry clerks at the'" nested" exit computer stations.
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During facili.ty tours,-the inspectors noted the following deficiencies in
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implementation of the MPC-tracking program:
'A.
On one occasion, when an inspector exited the Unil 3 Containment Building, the dosimetry clerk at the " nested" exit computer station failed to ask where the inspector had toured, and which JLCs applied. The inspector brought this to the clerk's-attention, and the clerk stated that it didn't really matter,
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i B.
In the Unit 2/3 Radwaste Building, the inspectors observed several.
workers _ compacting trash taken from Zone III hot particle areas.
The area imediately adjacent to the compactor was posted as a Zone III, and the worker inside this area wore a respirator during
' compacting operations. The surrounding crea was posted as a Zone II (hot particle buffer zone) and as a Contamination Area, and the worker in this area was not required-to wear a respirator. A-continuous air sample ns being drawn at the outer perimeter of the Zone II area using a '". ow-Vol" sampler, outside. the breathing zone for the worker actua11; operating the compactor. The HP technician covering the job statet that the observed. Low-Vol air. sampler was being used to determine internal exposure-for both workers, even
though they were working under different REPS.
The inspectors noted that REP 41146, for Zone III Trash Compacting,
required airborne radioactivity monitoring with grab-type short -
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duration ("High-Vol") air samples. The HP-technician; stated that he was unaware of the REP requirement, and that he had been told by the
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-HP' Planning Office that Low-Vol saroles-were to be taken for this-task. ' The HP Planning Office conf timed this statement..and promptly issued a revision to the REP to reflect use of Low-Vol air samples.
L The HP supervisor stated that the use of a respirator.by the individual wurking in the Zone III area was primarily to prevent facial contamination, and that High-Vol air samples drawn during previous performances of this task had revealed no significant airborne activity for either worker.
AMS-3) pectors noted also that the continucus air monitor (Model C.
The ins for the waste compactor exhaust duct had not received a current source check (weekly). The lead HP technician was notified, and the instrument was satisfactorily source checked.
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In the Unit 3 Containment Building, the inspectors noticed three general area (JLC) Low-Vol air samplers not running. Although
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sample heads were installed and start times and dates annotated on these samplers, power had apparently been lost. When questioned, several HP technicians stated that loss of power to air samplers was
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a consnon problem in the Containment Building. The HP manager stated that when air samples were interrupted, the airborne concentration from the previous day was used for purposes of MPC-tracking; the HP manager acknowledged, however, that inaccurate air samples could go undetected if power cords were unplugged and subsequently reconnected. The HP planning supervisor stated that insufficient electrical connections had been identified as a lesson learned during the present Unit 3 outage, and plans were in place to prevent recurrence during future outages.
The inspectors reviewed the Airborsne Radioactivity Survey Sheets and MPC Logs, and verified that the invalid samples had not been used for MPC tracking.
E.
The inspectors noted, during review of the MPC-tracking system, that two JLC samples entered into the system had been collected over a 50-hour period, although the Work Control Plan indicated that JLC samples should be collected daily. A cognizant engineer stated that the computer should have rejected the 50-hour sample, and that samples significantly longer th a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> were not normally used.
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Loss of electrical outlet service was also noted to be a recurrent problem in the Unit 2 Spent Fuel Pool area. Discussions with technicians and review of associated logs revealed numerous occasions when hydrolazing and other work had caused electrical breaker trips, interrupting power to Low-Vols and the continuous air monitor. On each occasion, work in the area had been halted until power could be restored. The project supervisors stated that specific plans were being developed to ensure that sufficient temporary electrical service outlet panels were installed prior to beginning work in the Unit 3 Spent Fuel Pool.
An MPC-hour report cated May 31, 1990, indicated that three workers had received greater than 40 MPC-hours of internal exposure. The exposure had occurred during entries at Modes 3 and 4 to the Unit 1 Containnient Building, in May 1990. The initially assigned internal exposures were based on air sample results and entry and exit times recorded on individual MPC tracking cards (IMTCs). The cognizant engineer stated that subsequent bioassays had determined the highest exposure to be approximately 25 MPC-hours. The licensee's evaluation of the incident, results of the bionssays, and calcuietions used to finalize assessment of internal exposure were not available for inspector evaluation. These documents will be reviewed in a future inspection, under Open item 50-206/90-26 01.
The licensee's performance in this program area appeared marginal in meeting stated safety objectives. Although improvements in computerization and overall structure of the program were noted, the inspectors concluded that considerable improvement in program implementation was necessary to ensure accurate tracking of MPC-hours.
!!o violations of NRC requirements were identifie [
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Maintaining Occupational Exposure ALARA j
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The inspectors examined the licensee's ALARA program by observation, i
p discussions with responsible personnel, and review of applicable records and procedures.
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Radiation Source and Field Control The licenset's efforts in this area included a hot-spot reduction
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program and limited replacement of cobalt-containing components.
The licensee had also hired a contractor to analyze reactor coolant
system particle size, as part of plans to initiate ultra-fine filtration.
The inspectors noted the licensee's effective use of temporary shielding, including the use of water shields, " soft bricks" (lead-shot in a gel form), and lead putty. The licensee was also pioneering the use of " Lead-Ex," a lead-impregnated vinyl sheeting purchased in 50-foot rolls, easily adaptable to varying component
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shapes and system configurations.
For the upcoming replacement of the Unit 1 thermal shield, the
licensee was constructing a horseshoe-shaped temporary shield of
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depleted uranium to fit around the core basket. The use of depleted l
uranium was intended to both reduce local exposure rates and allow essential equipment maneuverability.
Worker Awareness and Involvement
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The inspectors noted an adequate level of ALARA awareness among workers interviewed during facility tours. HP technicians covering specific tasks were knowledgeable of variations in local ex)osure t
ates. Workers generally knew the requirements of their RE), and ext.,cised appropriate measures to avoid posted hot spots. On one
occasion, workers were obrerved waiting in a high radiation area of
the steam generator platform for the arrival of the HP technician; this practice, however, was not observed to be commonplace, t
The inspectors noted that, although the licensee uses an ALARA Suggestion Form, workers appeared disinclined to submit proposals on this fonn because no monetary reward was associated with it. This condition was somewhat offset, however, by repeated submission of
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ALARA-related proposals via the Productivity Input Program (PIP)
(which does result in monetary reward).
ALARA Goals. Objectives, and Results i
The inspectors reviewed the licensee's 1990 Station Personnel Radiation Exposure Goal, current 1990 dose equivalent expenditures by work group and task, and current ALARA status reports.
Significant evolutions scheduled for 1990 included refueling outages in Units 1 and 3, Unit 1 thermal shield repair, and Unit 2 Spent Fuel Pool reracking.
Detailed person-rem breakdowns of these evolutions were used to establish an initial overall station goal of
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750 person-rem, incorporating exposure reduction factors for werk r
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force experience, lessons learned from previous outages, and extensive mockup training.
The inspectors noted that the Unit 3 refueling outage goal was
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originally set at 210 person-rem; however, at the time of the
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inspection this goal had been significantly exceeded. A memorandum
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dated June 4, 1990, had reset this goal at 285 person-rem due to additional manual plugging.of steam generator tubes and emergent
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work on steam generator feedrings.
The inspectors conducted a detailed examination of the licensee's Al. ARA planning for the Unit 1 thermal shield modifications.
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Preparation for this evolution included sending approximately 20 licensee personnel to Germany to begin coordination and specialized trainingattheKraftwerkUnion(KWU) facility;videotapesofthe KWU trip were being used for additional training.
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level of performance in this area, and the ALARA program was fully adequate in meeting the licensee's safety objectives.
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Surveys, Contamination Controls, and Control of Radioactive Material-(83726)
The lnspectors reviewed selected radiation and contamination surveys and weekly sumary sheets for compliance with the HP Routine Survey Schedule and Survey Pre-Job Planning Cards. Surveys were complete, and supervisory review was timely.
A tour was conducted of the licensee's ' Mesa" radioactive material storage area to verify that proper controls were being maintained. The inspectors performed independent boundary surveys using the licensee's ion chamber survey instrument Model PRM-7, Serial No. 662, due for calibration September 15, 1990.
Tours were also conducted of the Unit 2/3 Auxiliary and Radwaste Buildings, the Unit 1 outside areas, and the Unit 3 Containment Building.
The inspectors performed independent radiation surveys using NRC ion chamber survey instrument Model R0-2 Serial No. 9163, due for calibration September 30, 1990. The inspectors made the following observations:
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General housekeeping was good. Work areas and step-off pads, in general, were well kept, with radwaste, debris, and laundry neatly sequestered into convenient bags and receptacles.
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Portal monitors and frisking equipment were used properly.
Radiological postings were consistent with survey map information, and consistent with the inspectors' independent surveys. Monitoring instrumentation was in current calibration and had been performance checked,
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C.
Hoses and cords traversing contaminated areas were not in all cases (
secured to prevent spreading contamination. Plastic retaining clips had been installed on some hoses and cords, and when used, these
clips appeared to be effective.
D.
At the exit to Unit 3 Containment Building, an HP technician was observed assisting a worker in removing anti-contamination clothing, using cotton liners without protective rubber gloves. When all protective clothing had been removed, the worker threw a cordura bootie approximately 15 feet across the contaminated area, with the stated intention of trying to hit the HP technician. Although several HP technicians observed this event, none attempted to correct the worker.
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Faceshields were observed stored for reuse inside contaminated areas
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throughout the Radwaste Building and Unit 3 Containment Building, including storage in Zone 11 hot particle areas. Workers were observed periodically donning and rem # ng the faceshields, handling both sides of the shield with potenti y contaminated gloves.
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Within the Unit 3 bioshield area one individual was observed wearing rubber gloves not taped to the protective coverall sleeves, and another individual was observed wearing rubber gloves from which the tip of a finger was missing. Both workers acknowledged the inspectors' observations, and promptly corrected the problems.
During a subsequent tour inside the bioshield, a lead HP technician was observed wearing rubber gloves without tape.
In response to the inspectors' observation, the HP technician stated that tape was unnecessary, and prevented periodic wristwatch checks, which he proceeded to demonstrate, exposing his bare wrist and lower palm in the demonstration. The inspectors noted that the licensee's Red Badge training explicitly requires taping rubber gloves to protective coverall sleeves.
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Several radiological postings in the Unit 3 Containment Building were not consistent with those defined by HP procedures. Three areas were posted as " Highly Ctntaminated Area" and one was posted simply as " Rubber Gloves and Boaties," An area on the 17' level appeared to be in a partial state of disassembly, crisscrossed with several yellow and magenta ropes and two step-off pads, but unposted. The HP technician nearby was unaware of anticipated work in the area, and did not know the radiological conditions present.
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During a backshift tour, evidence of food consumption (in the fonn ofcandyandcrackerwrappers, chewed _chewinggum,etc.)wasfound in various areas of the Radiologically Controlled Area, i-The inspectors reviewed the PCIRs recorded for 1990. The licensee's PCIR
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database provided a detailed breakdown of whether the contamination was of skin or clothing, activity levels, size and specific location of the area contaminated, presumed cause, and work group of the individual contaminated. The inspectors noted the following items:
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Of the 399 PCIRs recorded between January 1 and May 31, 1990, 204
took place in supposedly " clean" (non-contaminated) areas.
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Of the remaining PCIRs, approximately 20 per cent were listed as due to inadequate protective clothing; of this group, however, none listed a change to the REP protective clothing requirements as a corrective action.
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Review of the PCIR worksheets revealed a significant number of facial contaminations caused by contaminated faceshields, and hand contaminations due to handling contaminated material wearing cotton liners without rubber gloves.
The above observations resulting from tours and document review were brought by the inspectors to the attention of the licensee. The licensee acknowledged the inspectors' observations, and stated that aggressive steps were being taken to correct the large number of PCIRs. PCIR summar';s were being distributed to managers monthly, to increase awareness of problem work groups and individuals. An evaluation of housekeeping procedures in the Radwaste Building was in progress, with changes in cleanup frequency, cleaning materials, training, or cognizant work group being considered as possible sr,1utions to the high number of (
contaminations occurring in supposedly rion-contaminated areas. An extensive program was also being started to interview every individual involved in a PCIR, to determine the specific circumstances of each case.
An action team had been established to implement tnese improvements.
i The licensee's performance in this area was declining. Although no violations of NRC requirements were identified, the inspectors concluded that improvements in workers' awareness of sound radiological work practices were necessary in order to achieve the licensee's safety objectives.
5.
Exit Interview l
The inspectors met with the individuals denoted in Section 1 at the conclusion of the inspection on June 29, 1990. The scope and findings of the inspection were summarized.
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