IR 05000272/1990025
| ML18095A633 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/26/1990 |
| From: | Lance R, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A632 | List: |
| References | |
| 50-272-90-25, 50-311-90-25, NUDOCS 9012100052 | |
| Download: ML18095A633 (12) | |
Text
Report N Docket No License No Licensee:
50-272/90-25 50-311/90-25 50-272 50-311 DPR-70 DPR-75 U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge, New Jersey 08038 Facility Name:
Salem Nuclear Generating Station, Units I and 2 Inspection At:
Hancocks Bridge, New Jersey Inspection Conducted: October 22-25, 1990 Inspectors:
R. A. Lance, Radiation Spe alist R. L. Nimitz, Senior Radia~*Specialist Approved by:
W. Pas~i~1;.Qtion *
\\ 1-t.b-9a Protection Section InsRection Summary:
Inspection conducted on October 22-25g 1990j (NC Combined Inspection Report No. 50-272/90-25; 50-311/ 0-25 date Areas Ins¥ected: This inspection was a routine, unannounced Radiological Controls nspection of the following: the licensee's actions on previous inspection findings, planning and preparation for the Unit I outage, external and internal exposure controls, radioactive material and contamination controls, and workers concern Results:
No violations were identified. The licensee was found to be performing good ALARA planning for the upcoming outage. Observations indicated lack of worker adherence to prohibitions of eating and smoking in the RC PDR ADOCK 05000272 Q
Pillt _J
DETAILS 1.0 Individuals Contacted 1.1 Public Service Electric and Gas Company
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- * * * * * * * * H. Villar, PSE&G Licensing Engineer Wray, Radiation Protection Engineer, Salem Polizzi, Operations Manager, Salem Operations Cellmer, RP/Chem Manager, Salem Operations Thomson, Assistant to General Manager, Salem Operations Orticelle~ Maintenance Manager, Salem Operations Gary, Senior RP Supervisor, Hope Creek Operations Karpe, Senior RP Supervisor, Hope Creek Operations Molner, Senior RP Supervisor, Hope Creek Operations Prystrupa, Radiation Protection Engineer, Hope Creek Operations O'Malley, Operating Engineer, Hope Creek Operations Other licensee personnel were also contacted or interviewed during the course of this inspectio.2 NRC
- T. Johnson, NRC Senior Resident Inspector S. Barr, NRC Resident Inspector
- Denotes those personnel attending the exit meeting on October 25, 199.0 Purpose and Scope of Inspection.. *
This inspection was a routine, unannounced Radiological Controls Inspectio The following areas were reviewed:
the licensee's actions on previous inspection findings planning and preparation for the upcoming Unit 1 outage external and internal exposure controls radioactive material and contamination controls worker concerns The inspector's evaluation of the licensee's performance in the above areas was based on observations during plant tours, review of documentation and discussions with cognizant personne.0 Licensee Actions on Previous Findings (Closed) Violation (50-272/90-14-01; 50-311/90-14-01):
The NRC identified two examples of personnel not following radiation protection procedure Radiation Protection personnel did not ensure that personnel had read the applicable Radiation Work Permit (RWP) before allowing them to enter the Radiologically Controlled Area (RCA).
In addition, a trailer containing radioactive material was not properly poste _Regarding the first example, the licensee issued a departmental directive to notify personnel of the need to follow procedures. Compliance sheets were completed, audits of compliance sheets was performed, and increased emphasis on the need to comply with RWPs was included in trainin Supervisors now periodically review completion of compliance sheet Procedure revisions_ for the RWP were initiated and a new procedure for document control is bei~g drafte Regarding the second example, the licensee immediately removed the radioactive material to a properly posted are An immediate walkdown of all areas outside.of the RCA was performed to identify similar concern The licensee also revised applicable procedures for control of radioactive material to strengthen control of radioactive material removed from th RC Appropriate personnel have received training on the new procedures and re-training on posting requirement In addition, supervisor tours
have been increased to identify problem areas. Also, the licensee initiated scheduled, documented routine technician surveys to ensure posting and
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barriers are properly maintaine This item is close.0 Planning and Preparation for the Unit 1 Outage The iTispector reviewed the licensee's planning and preparation for the -
upcoming Unit 1 outag The following matters were reviewed:
increased health physics staffing, including the station's method of providing supervisory control over contracted radiological controls personnel _
proposed training program for contracted radiological controls personnel, including Steam Generator mockup training adequacy of the licensee's controls and monitoring of contractor work standards, equipment and practices use of lessons learned from previous outages plans for ALARA review of work packages, dose reduction methods and radwaste reduction
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early involvement of radiation protection group and knowledge of work to be performed increased supplies, including clothing and temporary shielding provisions fqr engineering controls to minimize the need to use respiratory protection equipment and new initiative Within the scope of this inspection, no violations were identified. The following observations* were ~ade:
The licensee was closely examining each upcoming job for ALARA considerations. Jobs targeted for special attention were cavity decontamination and steam generator work including examination of girth weld The licensee has assigned, to date, about 30% of the outage work scope to radiation work permit The licensee was establishing a draft organization and staffing levels for the upcoming outag The lic~nsee was reViewi~g problems encountered during steam generator work which was conducted during the previous outag Action was bein$ taken to address problems that had been encountered.
. during the previous outag *
The licensee has taken action to improve the estimating of man-hours used for ALARA planning purpose The licensee has established a radiation protection task force for the outag Personnel have been assigned duties and responsibilities for outage planning matters in the area of radiation protection..
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The licensee has developed redundant means of tracking and monitoring radiation exposures. in the event of problems with the primary compute Licensee personnel will be used in.the field to supervise contractor radiological controls personnel~
The licerisee ass~gned specific personnel to monitor and review personriel contaminations and radiological occurrence report The licensee has developed special training ~apes for briefin$ a~
steam generator worker The licensee has also developed training tapes for repair of portable high efficiency particulate air (HEPA)
ventilation systems and vacuum cleaner *
- The inspector concluded the licensee was providing effective planning for the upcoming outag Inspector discussions with licensee representatives indicated that the licensee.was aggressively pursuing new initiatives to reduce exposure to radiation over the life of the facilit Some additional initiatives include:
down-sizing filter pore sizes in water clean-up systems to enhance clean-up capabilities use of zero entry steam generator nozzle dams in an attempt to make all steam generator work zero entry the Unit 2 facility completed the change to operations at elevated lithium levels. Such operation has found ALARA benefits in reduced system radiation dose rate development of a Hot Spot tracking and reduction program development of specific procedures for ALARA goal development development of a ~obalt reduction checklist as part of the design change package procedure development of a program to identify and repair or replace, as appropriate, leaking valves within the radiological controlled are.0 External and Internal Exposure Controls The inspector toured the radiologically controlled areas of the plant and reviewed the following elements of the licensee's external exposure control program:
postin~, barricadin~, and access control, as appropriate, to Radiation, High Radiation, and Airborne Radioactivity Areas personnel adherence to radiation protection procedures, radiation work permits and good radiological ~ontrol work practices use of dosimetry devices adequacy of supply, maintenance, calibration and performance checks of survey instruments This review was with respect to criteria contained in applicable licensee procedures and 10 CFR 20, Standards for Protection Against Radiatio *
Within the scope of the above review, no violations were identified. The licensee was providing effective external and internal exposure control The following positive observations were made:
The inspector visited the instrument calibration laboratory and the in-plant instrument issue roo The licensee's instrument program appears to be effective. A computer system is used for instrument r
accountability and to monitor instrument calibration frequency requirements. Calibration methods are effective, and supervisory review of calibration records appears to occur in a timely fashio The following matters were brought to the licensee's attention:
A cigarette butt was found by a floor drain in the Unit 1 Decontamination Roo The room is located within the radiological controll~d area (RCA) where no eating, drinking or smoking is permitte In addition, the drain is located within a posted contamination' are A piece of gum was found stuck on the wall of the Unit 1 Demineralizer Alle The alley is also located in the RC The above observations indicate lack of worker sensitivity to ingestion of radioactive material.*
The licensee initiated an immediate review of the above listed
- matters. The licensee subsequently issued a memorandum to management personnel discussing the above events and requesting that the identified concerns be addressed with station department personne As a result of weaknesses identified during NRC Combined Inspection Number 50-272/90-14; 50-311/90-14, the licensee initiated a number of actions in the area of exposure control as follows:
The licensee has initiated a plant supervisory tour progra Supervisors are required to tour various assigned areas and report on plant condition Radiation work permits are periodically audited by radiation protection supervisor.0 Radioactive and Contaminated Material Controls The inspector toured the station periodically during the inspection and reviewed the licensee's controls for radioactive material and contaminatio The following matters were reviewed:
posting, labeling and control of radioactive and contaminated material
- personnel use of contamination control devices Within the scope of this review, no violations were identifie The following observations were brought to the licensee's attention:
Barricades, which held radiological postings, were in less than favorable conditions, e.g., ropes were slack, combinations of ropes and ribbons were used, several types of stantions were used for one area, and the base of some stantions were within the contaminated area delineated by the radiation boundary tape on the floo One stantion in the Unit 2 spent fuel building had fallen into the area it was used to barricade. The inspector noted that a supervisor had identified the fallen stantion and had initiated action to re-erect it. Although areas were properly posted, the lack of consistency in barricading resulted in some inspector confusion with respect to what type of area was being demarcate The inspector observed several instances where ropes and wires crossed into contaminated areas without being properly secure A number of weaknesses in radiological controlled area (RCA) boundary control and contamination control was identified during NRC Combined Inspection No. 50-272/90-19; 50-311/90-1 The licensee developed a task action plan to address each of the weaknesses identified therein. In addition to other actions, the licensee initated the following actions:
The licensee revised procedures to require final frisking of material to be removed from the RCA to be performed by a senior technicia The licensee ~urchased and placed inservice high sensitivity tool monitors for frisking material to be removed from the RC The licensee also initated a review of tool control practice The licensee's radiation protection personnel have been meeting with work groups to stress the need to adhere to RCA boundary contro.0 Worker Concerns (RI-90-A-0062)
7.1 General On May 24, 1990, a contractor radiation protection technician contacted the NRC and expressed concern that a second contractor radiation protection technician had falsified a radiation survey of the Unit 2 Letdown Heat Exchanger Are The technician indicated that the licensee's mana~ement had been made aware of the concern but did not take any action on it. The technician also indicated that he was told to drop the matter or suffer job repercussion ~---
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- This matter was reviewed by the NRC and deemed appropriate to bring to the licensee's attention for internal review and evaluatio The inspector met with cognizant licensee personnel and discussed the results of the licensee's internal review and evaluatio The inspector also independently evaluated licensee compliance with applicable radiological controls procedures and the circumstances surrounding the even.2 Specifics On May 15, 1990, a contractor radiation protection technician (Individual A) was directed to assist in the decontamination of the hallway leading to the Unit 1 Letdown Heat Exchanger Cubicl The area was decontaminated and the step-off pad leading to the hallway was moved back to the doorway leading to the heat exchanger cubicle. A survey of the hallway was performed and documented at 7:30 p.m. that da The survey indicated *
contamination levels less than the licensee's criteria for posting an area as contaminated (1000 disintegrations per minute per 100 centimeters squared (dpm/100cm2)).
Because the technician (Individual A) was unsure as to how the entrance to the cubi~le should be posted, he contacted a supervisor and asked for guidanc The supervisor never got back to the technician and.the technician left for the da On May 16, 1990, at 9:00 a.m. a second radiation protection technician (Individual B) performed a second survey of the hallway. That survey indicated contamination levels ranging up to 10,000 dpm/100cm2 in the area that had been de-posted* as non-contaminate The second survey identified contamination in localized areas which were not identified by the initial surve However, the initial survey did not appear to include the areas that were later found to be contaminated during the second survey~
As a result of the identified contamination, and the belief by Individual B that the Letdown Heat Exchahger Cubicle was not posted as a High Radiation Area as it should be, a Radiological Occurrence Report (ROR)(90-158) was issued on May 16, 199 On May 17, 1990, several licensee supervisors met with the*technician (Individual A) who performed the original survey on May 15, 1990, to discuss the survey, the posting and the subsequent discovered contamination of the hallway..
During the period May 17-24, 1990, numerous discussions occurred regarding the adequacy of the surveys and postin On May 25, 1990, the ROR was voided by a radiation protection supervisor, who believed that the permit was written by the wrong supervisor and it did not contain sufficient fact On May 28, 1990, after a QA representative questioned why the ROR had been canceled, the Radiation Protection Engineer (RPE) reviewed the RO When he learned that the proper posting of a High Radiation Area was in question, he had the ROR reinstate l
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The contractor technician (Individual A),
who released the hallway as not contaminated, continued to believe that he had performed adeguate surveys to release the area and that he was not responsible for the lack of posting of the High Radiation Area entrance because he had notified a supervisor of the posting matte On or about May 24, 1990, it was discovered that the survey performed by the second technician (Individual 8) on May 15, 1990, at 3:00 p.m., to release the hallway after additiona1 decontamination efforts, was aJtere A contaminated area boundary was added to the original survey after it had been turned in and reviewed by a superviso.3 Inspector Findings Regarding Worker Concerns The inspector reviewed the licensee's evaluation of the above matters: The inspector reviewed radiation and contamination surveys, signed statements of workers, radiological occurrence reports, and applicable procedure The inspector's review of the circumstances surrounding this matter
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indicated the following:
The licensee's evaluation of the circumstances surrounding the alteration of the original May 15, 1990, (3:00 p.m.) radiation survey of the access hallway of the Unit 1 Letdown Heat Exchanger concluded that the survey was altered to add a contamination control boundary on the left wall area of the hallway (See attached survey).
The survey was altered after it was turned in for review. This was discovered when it was noticed that a copy of the original survey, which was included with ROR 90-158, did not have this boundar *
The licensee was not able to identify who altered the survey but the licensee concluded it was not done malici-0usly and that the
maintenance of radiation safety had not been compromise The licensee concluded that this was an isolated even The inspector concluded that, regardle~s of who altered the survey, or why, the alteration did not affect the health and safety of personnel because the area in question was clearly demarcated at the hallway as a contaminated area. Further, there was limited procedural criteria as to what information had to be on a survey for In addition, there were no prohibitions against changing a survey that had been reviewed and approve The inspector's review concluded that the Unit 1 Letdown Heat Exchanger Cubicle, based on available radiation surveys, was not required to be posted as a High Radiation Area during the period in question (May 15-16, 1990).
No violations of High Radiation Area posting requirements were identifie.
The inspector's review found that, at the time of this incident, there was no prohibition against supervisors voiding RORs based on the belief that an ROR was not warrante *
The licensee's review indicated that the questions concerning the ROR were not discussed above the radiation protection supervisor leve Consequently, the licensee *concluded that radiation protection management was not aware of this matter and therefore could not resolve the concer The inspector identified no information t dispute this conclusio *
The specific concern expressed by the technician re9ardin~ job repercussions was not substantiated by the 1 icensee s r*eview and evaluatio The licensee's reviewer, who examined this matter, concluded that the technician who expressed concerns about job repercussions had taken out of context statements by individuals who were attempting to maintain "harmony within the contractor radiation protection organization. The inspector found no information to
~ispute this conclusio The licensee's reviewer concluded that the concerns raised as a result of this event stemmed from apparent disagreements between contractor radiation protection technician The licensee's Radiation Protection Engineer counseled Radiation Protection-Supervisors regardin~ the failure to bring the disagreements and survey concerns to his attention. _
two The inspector's independent review of signed statements by involved
-- individuals indicated that the statements supported this conclusio.4 *Inspector Conclusi-0ns Regarding Circumstanc~s
--Jhe following conclusions wer~ made:
The licensee's radiation protection supervisor signed off on radiation surveys that did not identify.area postings. There is no guidance provided to supervisors as to what aspects of survey results they should be reviewing prior to signing them of The licensee's program does not clearly identify the extent of surveys that are to be made when de-posting a contaminated are As discussed above, a survey performed on May 15, 1990, at 7:30 p.m. of the Unit 1 Letdown Heat Exchanger Cubicle was found at 9:00 a.m. on May 16, 1990, to not identify localized removable contamination within the area that had been de-poste Upon identification, the
_ area was contro 11 ed and decontaminated by 1 i censee p_ersonne 1.
The licensee's radiological occurrence program (RORs), at the time, allowed supervisors to void ROR The ROR procedure was revised on June 28, 1990, to require documentation to support voiding of ROR The licensee is currently re-writing the entire ROR procedure to improve it. Personnel were made aware of the revisio _
The licensee's program did not contain guidance for revisin~
previously reviewed and approved survey The licensee revised the radiation and contamination survey procedure on June 28,1990, to include guidance for changing approved survey Personnel were made aware of the revision *
At the time of this event, there was limited management review and involvement with ROR All RORs are now reviewed by radiation protection management and discussed weekly at station management meeting The licensee has taken actions to ensure that proper administrative procedures are in place and will be followed should the need to revise approved surveys or void an ROR arise in the futur However, actions taken to ensure review of radiation protection surveys and to improve the consistency of surveys, particularly those used as the basis for de-posting a previously contaminated area, will be reviewed in future inspection.0 Plant Tours The inspector toured the radiologically controlled areas of the facility during the inspectio The following matters were discussed with licensee personnel:
Two fire extinguishers were found standing unsecured and unattended in the plan One was found by the Unit 2 personnel airlock and one was found outside by the compressed gas storage rac The extinguisher found outside was in need of charging and had no inspection tag attached to it. This matter was brought to the attention of the licensee's Fire Protection Departmen Plant housekeeping appeared to have improve.0 Exit Meeting The inspectors met with licensee representatives denoted in section 1 of this report on October 25, 199 The inspector summarized the purpose, scope, and findings of the inspectio No written material was provided to the license tachment to RC ornbined Inspe tion Report No /90-25 50-311/90-25 Contamination Boundry Added
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