IR 05000272/1992006
| ML18096A751 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 05/22/1992 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18096A750 | List: |
| References | |
| 05-311-92-06, 05-354-92-07, 5-311-92-6, 5-354-92-7, 50-272-92-06, 50-272-92-6, NUDOCS 9206090197 | |
| Download: ML18096A751 (16) | |
Text
U~ S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-272/92-06 50-311192-06 50-354/92-07 Docket Nos. * 50-272 50-311 50-354 License Nos. DRP-70 DPR-75 NPF-57 Licensee:
Public Service Electric and Gas Company P. 0. Box 236 Hancocks Bridge. New Jersey Facility Names:
Inspection At:
Salem Nuclear Generating Station. Units 1 and 2 Hope Creek Nuclear Generating Station Hancocks Bridge. New Jersey Inspection Conducted:
April 28 - May 1. 1992 Inspector: ~~
Jffr
/il.~Nimitz, CHP, Senior RadiatioSJ>ecialist -
6". 21-9 date-Approved baa""'=~
W. Pasciak, Chief *
.s'*.12 -9 date Facilities Radiation Protection Section Areas Inspected:
This inspection was a routine, unannounced inspection of the radiation protection program at the Salem Station during the Unit 1 refueling outage. Areas reviewed were organization and staffing, training and qualifications, audits, ALARA, routine radiological controls, radioactive material and contamination controls, and process and area radiation monitor
- calibration. Previous findings, which involved both the Salem and Hope Creek Stations, were also reviewe * Findings:* The inspection identified that the licensee implemented a very good radiological controls program to support the Unit 1 outage.. No violations were identifie PDR ADOCK 05000272 G
....
- . DETAILS Individuals Contacted Public Service Electric and Gas Company
- C. Vondra, General Manag~r, Salem
- T. Celliner, Radiation Protection/ Chemistry Manager, Salem
- V. Polizzi, Operations Manager, Salem
- I. Wray, Radiation Pioteetion Engineer~ Salem
- E. Katzman, Radiation Protection/Chemistry Service8 Engineer
- W. Schultz, Manager, Station QA, Salem
- E. Villar, Station Licensing Representative
- R. Antonow, Salem Outage Manager
- M. Shedlock, Salem Maintenance Manager
- E. Lawrence, QA Audito *K. Watson, Dosimetry Supervisor
- M. Prystupa, Radiation Protection Engineer - Hope Creek NRC
. *T. Johnson, Senior Resident Inspector, Salem/ Hope Creek Stations
- Denotes attendance at the exit meeting on May 1, 1992.
The inspector also contacted other licensee personnel during the course of the inspectio.0 Areas Reviewed The following areas were reviewed during the inspection:
. action on previous findings orga.niz.ation and staffing training and qualification ALARA external exposure control internal exposure controls radioactive material and* contamination control process and area radiation monitor calibration
3. 0 Licensee Action on Previous Inspection Findin~s (Open) Unresolved Item (50-272/91-32-01)
The NRC will review the circumstances and licensee corrective actions (as appropriate)*
associated with the December 16, 1991, discovery, by the licensee, of contaminated tubing outside the radiological controlled area (RCA)~ This matter was reviewed during NRC Combined Inspection No. 50-272/92-05; 50-311/92-05: and 50-354/92-05. During the previous inspection, the inspector noted several instances where contaminated material was identified outside the RCA. During the previous inspection, the inspector indicated that the instances appeared to warrant further review by the licensee. The inspector's review during the current inspection determined that the licensee initiated an*
independent evaluation of the effectiveness of. contamination controls at radiological controlled area (RCA) boundaries. this matter remains unresolved pending NRC review and evaluation of the licensee's evaluation result.2 (Open) Unresolved Item (50-272/92-05-03; 50-311/92-05-03; 50-354/92-05~03)
During NRC Combined Inspection No. 50-272/92-05; 50-311/92-05; and 50-354/92-05 the inspector identified apparent incomplete or inaccurate dosimetry record The licensee initiated an immediate review of the inspector's observations and concluded that the errors appeared to be attributable to one individual, no widespread dosimetry records problem were identified, and no personnel exposures in excess of administrative limits had occurred. Of particular concern to the inspector was the potential for an individual to be granted a radiation* exposure (dose) extension, to receive additional radiation exposure above the licensee's administrative limits, with incomplete records. This was possible when an individual's radiation dose history status was i]ldicated as complete (C status) in computer files when in fact the records were incomplete or previous exposure was estimated (E status). The inspector's review had identified one individual whose status was incorrectly indicate A subsequent licensee review identified several additional example The inspector noted that the licensee's procedure M12-DOI-701, Revision 5, Personne TLD Issue and Documentation Requirements, requires in Section 5.3.3, that if an
- individual has estimated exposure for the current quarter or missing (incomplete) or estimated exposure for other periods, the individual's dose limit was to be 1000 millirem and his exposure status was to be E (ie., inCQmplete or estimated). Based on the inspector's preliminary review, as discussed above, it appears that several individuals had incomplete or estimated exposure but were improperly assigned a status of. "C" which indicated that their records were complet The inspector noted that a number of dosimetry records concerns had been self-identified by the licensee *(Reference Unresolved Item 50-272 & 311/92-28-01; 50-354/92-21-01) and extensive corrective actions were on-going to address the concerns identifie *
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Time limitations precluded the inspector from completely evaluating this matter to determine if it* had previously been identified by the licensee. However, the inspector noted that the licensee took the following ~tions following inspector identification of the records concerns:
A verification by a qualified* senior dosimetry technician of an individual's dosimetry records and dose history status prior to issuing him/her a TLD was immediately initiate *
The Dosimetry staff was informed of the error.
Independent audits of dosimetry records were performed by experienced persorirte The licensee changed all contractor worker's d9simetry record status to.
incomplete. (This will provide for a complete review of the worker's dosimetry records prior to authorization of any exposure extensions.)
The licensee re~qualified all personnel on dosimetry procedure The function of the clerical staff, t6 perform Dosimetry records processing, was
- removed; The licensee evaluated the identified concerns and developed contributing factors to the problems identifie *
The licensee also initiated a number of longer term corrective actions to perfopn a more
. extensive review of active records, enhance the dosimetry organization and enhance prOcectures. This item remains unresolve.0 Organization and Staffing The inspector *reviewed the organization and staffing of the Salem Station on-site radiation protection organization. The review 'was with respect to criteria contained in.
applicable Techriical Specifications and licensee administrative document The inspector evaluated licensee performance in this area by review of applicable documentation, discussions with cognizant individuals, and independent observation of
. on-going work activities during tours of the facilit *
The inspector determined that the organization was well defined and well staffed. There were no changes s~ce the pr~vious inspectio There was generally good supervisory oversight of work activities and a good level of staffiilg to support work activities. The
- inspector noted that the licensee was performing contingency planning to address a potential planned strike. This was considered a very good initiativ No violations were identified.
5. 0 Trainin& and Oua1ification The inspector reviewed the training and qualification of radiological controls oontractor personnel supporting outage work activities. The inspector also reviewed the training and qualification of radiation *worker The review was with respect to applicable Technical Specification requirements and 10 CFR 19, Instructions to Worker The evaluation of the licensee's performance in this area.was based on discussions with personnel, review of training records and qualification documents, and review of resumes. The inspector also. observed personnel performance in the fiel The inspector's review determined that personnel were trained and qualified in accordance with the licensee's program requirements.
. The following observation was made:
- The inspector reviewed selected aspects of the licensee's ALARA Progra The priricipal focus of the review was the observation of on-going work activities to determine if work was performed in a manner to maintain personnel radiation exposures as low as reasonably achievable (ALARA). The review was with respect to criteria contained in the following:
Regulatory Guide 8. 8, Information Relevant to Ensuring * that Occupational Radiation Exposures at Nuclear Power Stations will be As Low As Is Reasonably Achievable Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As Is Reas0nably Achievable NUREG/CR4254, Occupational Dose Reduction and ALARA at Nuclear Power Plants; Study on ffigh-Dose Jobs, Radwaste Handling and ALARA Incentive The evaluation of the licensee's performance was based on discussions with cognizant personnel, independent inspector observations during tours of the station, observations of on-going work activities, and review of documentatio *
The inspector's review indicated that the licensee had performed excellent planning and preparation for the Unit 1 refueling outage. Of particular note was the licensee's efforts to plan for steam generator work activities. In addition inspector observation of on-going work activities indicated effective implementation of ALARA concepts during the actual
- performance of wor The following matters were noted:
Lessons learned from previous work activities we~ incorporated into ALARA planning effort The licensee constructed shielded wait area8 in steam generator "bull pen" areas to reduce the exposure of personnel standing by to support non-destructive testing of steam generator *
A special po\\Ver supply was installed for poweririg electrical equipment used to support steam generator wor The licensee incorporated a second setting of the reactor vessel head onto the reactor vessel to reduce radiation levels of personnel performing reactor coolant pump motor maintenance on the refueling floor.. The radiation.had been streaming from the reactor vessel and increasing ambient radiation levels in the work areas during previous motor maintenance activitie The licensee installed a stand alone computer dose tracking system at each steam generator control station to provided for live time tracking and control of radiation exposure for personnel performing steam generator wor The licensee used advanced robotics (a remotely operated tracked vehicle with grapple arm) to load highly radioactive filter media into shipping container The licensee performed extensive shielding inside Unit 1 containment (e.g~
pressuriZer spray line and heat exchangers) to reduce exposure to personne Extensive audio-video coverage was used for steam generator work, including remotely positioned radiation monitors, which minimized exposure of radiation
- protection personnel during job coverage activitie No violations or unacceptable practices were noted.
7. Radioactive Material Control and Contamination Control 7.1
- General The inspector reviewed the control of radwaste, contaminated * material;* and contamination. The following areas were reviewed:
personnel frisking practices use of proper contamination control techniques at work locations,. including control of hot particles
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posting and labeling (as appropriate) of contaminated and radioactive material efforts to reduce the volume of contaminated trash. induding steps to minimize introduction of unnecessary material into potentially contaminated areas *
adequacy of contamination surveys to support planning for and support *of on-.
going wor *The inspector's review during the inspection indicated that overall control of radioactive and contaminated material, and contamination appeared to be good. The following observations were made:
The licensee placed radioactive waste (contained in plastic bags) into separate cloth bags for transport to preclude inadvertent personnel and facility contamination due to tearing of plastic bag The licensee re-configured the work areas for reactor coolant pump motor work to enhance contamination controls Overall contamination levels within the Unit i containment were considered lo The licensee made excellent efforts to preclude tracking of isolated high levels of contamination into general work area Control of contamination of steam generator platforms; typically high contamination areas during work activities inside the primary manways, was commendable. Glove boxes were used to enclo~ non-destructive test equipmen * which minimized the spread of contaminatio As discussed in Section 3. 0 of this report, the licensee was performing an in depth independent evaluation of the identification of some contaminated tubing outside the radiological controlled area (RCA) and the potential causes of its release from the RC *
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The licensee's portal monitors, installed at the security center appeared to effectively identify instances of contaminated material or individuals attempting to leave the facility (as discussed below). The licensee's security force responded promptly to egress portal alarm.
The following matter was brought to the licensee's attention:
The iitspector' s review of radiation work permits identified that the lieensee established and implemented Hot Particle Control Instructions for hot particle zones where appropriate. However, the inspector's review of selected completed instruction sheets indicated that "special instructions" were added to the instruction sheet by a radiation protection supervisor which appeared to supersede the survey frequencies specified in the Hot Particle Control Instruction shee The special instruction indicated that the guidance contained therein, including survey requirements for hot particles, were to be followed when hot particles greater than 500 mR/hr were identified. This guidance appeared to indicate that
- no surveys were* required until a particle of greater than 500 mR/hr was identified, apparently during shiftly surveys. However, the licensee's hot particle control procedure indicated that hot particle survey frequencies shall not exceed 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and that no criteria regarding maximum dose rates on a particle versu survey frequency was given. The licensee concurred with this observation and initiated action to inform supervisors regarding the* use of special instructions to preclude inadvertent superseding of procedure guidanc.2 Events The inspector's review indicated that in all instances where the special instruction was usect, radiation protection technicians adhered to the guidance of the Hot Particle Control Instruction sheet and performed appropriate survey The licensee has installed walk-through portal monitors in the security center. Personnel entering and leaving the site (both Salem and Hope Creek Stations) are required to pass through the monitors which monitor the individuals for contamination. The inspector reviewed the circumstances, licensee evaluations, and corrective actions associated with two events involviD.g identification of a contaminated individual and a contaminated tool at the security cente *.
Event 1 (Contaminated Individual Identified at the Security Center)
At about 5:45 a.m. on April 20, 1992, two contractor workers attempted to exit the radiological controlled area (RCA) at tlie main egress point after completing work on the refueling floor in the Unit 1 containment. The workers had been working under Radiation Work Permit (RWP) No. 92-15-00334, Revision 0, Remove/Replace Incore Flux Thimbles, and had worn standard protective clothing with plastic pant The
. individuals had signed the RWP _and were provided a pre-work briefing. The workers were involved in cutting incore instrumentatio Both workers were unable to pass through the whole.body friskers at the ma.iii egress point due to identification of contaminatio Individual A exhibited low level contamination (1000 net counts per minute) on the left side of the face. No other contamination was note The individual was decontaminated, he again attempted to exit the RCA and again alarmed the whole body frisker. After additional decontamination efforts, the individual was able to clear the friskers. The individual was permitted to leave the RCA after successfully* passing through a whole body friske The individual's co-worker (Individual B) was found to exhibit 1000 net counts per minute on his right cheek, 100
- net counts on per minute on his left wrist and chest, and 300 counts per minute on the left side of his face. Some personnel articles were found contaminated and confiscate This individual was also successfully decontaminated and released from the RC A dose evaluation was performed for the two workers that indicated 17 millirem and 16. 6 millirem, respectively for the two individuals, to a small portion of the skin of the whole body. Because of contamination above the neck, * the individuals were sent for whole body counts. The preliminary cause of the contamination, as documented on the Radiological Occurrence Report (ROR), was attributed to worker sweatin When attempting to exit the security center at about 7:30 a.m. on April 20, 1992, to leave the facility to obtain a whole body count in the in-pr6cessing building,- Individual A alarmed one of the walk-through portal monitors. The individual was challenged by security personnel who informed radiation protection personnel of the even A subsequent contamination survey of the individual determined that the individual had a hot particle on the right lower (back) portion of his head. The hot particle measured about 240,000 disintegrations per minute {dpm) per 16 centimeters squared. The licenSee collected the particle, performed a gamma isotopic analysis of it, and performed a skin dose estimate for Individual A. The licensee's skin dose estimate indicated about rem to a small portion of the skin of the head. The licensee initiated an immediate investigation to deternnne how the individual was able to get out of the radiological controlled area with the hot particle on hi *
- The inspector reviewed this event and noted the follo~g:
The licensee restricted the individual from further access to the RCA. to preclude any additional radiation exposur The licensee issued a second radiological occurrence report and also issued a plant incident report for this matte The licensee initiated an extensive investigation of the event which included interviewing of all personnel involve The licen_see re-verified. the operability of the pqrtal monitor used by the individual to exit the RCA. The licensee concluded that the portal monitor was *
operating properly when the individual used it. *
The licensee performed tests using the particle in various geometries, including inside a hard hat, in order to attempt to leave the RCA, via use of the whole body friskers, without detection of the particle. The licensee was unable, due to the levels of radiation emitted by the particle and the sensitivity of the whole body friskers to identify any way that the particle could have been released from the RCA if the whole body friskers had been used properly by the individual (Individual A).
The inspector did note that it was not apparent that the individual had, based on information provided by the licensee, properly used the whole body friskers at the_
main egress point from the RC *
. The inspector had the following preliminary oonclusions:
The inspector evaluated the adequacy of the licensee's dose estimate for Individual A attributable to radiation exposure from the hot particl The inspector independently evaluated potential exposure times by review of security access records. The exposure estimate appeared reasonable based on criteria*
used. The inspector questioned the adequacy of the activity determination of the particle which prompted the licensee to re-:evaluate the activity and conclude that the* activity. estimate,,. was conservativ The inspector also performed an independent dose assessment which generally confirmed the licensee's estimat The licensee plans to refine the dose calculation which is expected to reduce the dose estimate. No exposures in excess of NRC limits were identified.
The inspector observed licensee personnel perform radiation measurements of the particle. The inspector concluded that it was highly unlikely that the particle would not have been detected by the licensee's whole body friskers at the main RCA egress point and be inadvertently released. from the RCA. The particle activity was well above the minimum* detection capability of the whole body friskers and tool monitors at the main egress poin The inspector reviewed licensee conformance to applicable radiation protection.
procedures and noted no apparent instance where the licensee's radiological controls personnel did not implement program procedure The licensee attributed the release of the particle to apparent improper use of.the whole body friskers by the individual r (Individual A). The licensee informed the inspector that radiation workers are provided specific training on proper use of the whole body friskers. This was apparently contrary to procedure NC.NA-AP.ZZ-0024(Q), Revision 1, Radiation Protection Program, which specifies in Attachment _ 1, Responsibilities of Each *Individual, that personnel follow all procedures and instructions and use appropriate contamination monitoring equipmen The inspector reviewed the final whole body count results *for Individual*s A and B and noted that the whole body counts did not indicate any significant intakes of radioactive* materia The inspector reviewed the licensee's evaluation of the event, including signed statements submitted by individuals. The inspector's review of the statements indicated that the individual (Individual A), who sustained the contamination with the hot particle, exhibited poor radiological work practices during the performance of his work activity on the Unit 1. refueling floor. These included such matters as sticking his gloved hand into -the flooded reactor cavity, and walking across contamination control step-off pads. Since the RWP for the work activity required continuous radiation protection* coverage, the worker was frequently informed of poor work practices..
The inspector noted that aggressive action apparently was not taken to correct the apparent poor work -practice The licen~;s. radiation protection management acknowledge this concern and informed applicable supervisors of the need to maintain aggressive control of radiological work actiVitie The inspector indicated that the licensee's evaluation including completion of the Plant Incident Report would be reviewed during a future inspectio *
The following matter was brought to the licensee's attention:
The inspector reviewed tool control log sheets associated with tool *control for _
refueling cavity work to determine estimated times that the individual (Individual A), who had sustained the hot particle contamination, had been working in the hot particle area. The inspector noted that the individual was not signed in on tool control log sheets on April 19 and 20,' 1992, as being inside the tool control
_ boundary, which the individual apparently wa The licensee's procedure, SC.MD-GP.ZZ-0006(Q), Revision 0, Tool and Miscellaneous Items, Cleallliness and Closure Control, specifies in Section 5.3, that all personnel enteririg and leaving the area are to be logged on the Personnel Control Form (Attachment 1 to the procedure).
The inspector indicated adherence to the licensee's tool control program requirements was an unresolved item (50-272/92-06-01).
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Event 2 Ondividual Identified at the Security Center with a Contaminated Tool.)
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At about 5:50 a.m. on March 13, 1992, an individual alarmed the portal monitors while attempting to exit the protected area through the_ Security Center. A security guard
'requested the individual to re-try the monitor which again alarmed. The individual-subsequently removed a rolled up cloth, later de~rmined to be a shirt, from his bag, deposited it in a loCal trash can, and then succe8sfully cleared the walk-through portal monitors. The individual did not wait but left the security cente A radiological controls supervisor who was entering the security center observed the portal monitor alarm and investigated what was thrown in the trash can. The supervisor found a small hand sander wrapped in a shir A subsequent survey of the tool found it to measure about 14,000 disintegrations per minute* (dpm) * of non-removable radioactive contamination.-_ In addition, subsequent licensee review deterinined that the sander may have been improperly removed from the RC The licensee also deteimined that the sander was similar to others at the individual's work location and that the levels and mixtures of radionuclides were simila The individual's employment was terminate The inspector did not identify any apparent performance concerns associated with radiological controls personne The inspector concluded that the tool (hand sander) would most likely been identified as contaminated and not permitted to be removed from the* RCA if the sander had been provided for radiation protection surveys prior to its removal from the RCA.
- The inspector concluded that.the event, based on review of the circumstances, appeared to be attributable to an individual not adhering to the guidance of licensee procedure NC.NA-AP.ZZ-0024(Q), Revision 1, Radiation Protection Program, which specifies in Attachment 1, * that contaminated tools be placed * in designated areas and radiation protection personnel be notified prior to removing material from the RC The inspector noted that the licensee issued a memoradum to all station personnel on April 1, 1992, regarding the proper removal of material from the RCA and the general guidelines to follo.0 Routine Radiological Controls The inspector reviewed the implementation, adequacy and effectiveness of the radiological controls programs provided for the Unit 1 outage. The inspector ioured selected portions of the radiolqgical controlled areas of and reviewed the following elements of the license's radiological controls program:
performance and adequacy of radiological surveys to support pre-planning of work and on-going work use of appropriately calibrated instrumentation to measure radiation arid
- contamination
- personnel adherence to radiation protection procedures, radiation work permits and good radiological control practices posting, barricading and access control as appropnate, * to Radiation, High Radiation, and Airborne Radioactivity Areas High Radiation Area access point key control use of dosimetry devices airborne radioactivity sampling and controls installation, *use and periodic operability verification of* engineering* controls to minimize airborne radioactivity use of respiratory protection devices including provision of appropriate quality of breathing air for supplied air respiratory protective equipment implementation of radiation work permit The evaluation of the licensee's performance in this area was based on discussions with cognizant personnel, review of on-going work activities and review of various documents~
The inspector's review identified overall, very good* radiological controls were implemented for work activities. There was a good level of supervisor and management oversight of work activities. Radiological controls technicians provided a good level of control of work activities. Airborne radioactivity control measures were effectively used, and High Radiation Areas were properly controlled.
The following matters were brought to the licensee's attention:
The inspector reviewed use of respiratory protective equipment for No. 11 steam generator support activities. Workers on the steam generator platform were provided LANCS air supplied hoods. Breathing air was supplied by a Biosystems Travel Panel 50 apparatus. The licensee's procedure for use of the equipment (ProcedureSC.RP-TI.ZZ-0403(Q), Revision 0, Operation and Maintenance of the Biosystems Travel Panel 50) indicated in Section 3. 3 that manifold pressure, when using the LANCS hood was to be between 25-45 pounds per square inch gauge (psig).
The licensee was, according to Technical Specification 6.11, required to adhere to radiation protection procedures. The inspector's review of the daily in use inspection log indicated the following:
date pressure (psig)
April 24, 1992
April 25, 1992
April 26, 1992
April 27, 1992
April 28, 1992
The inspector noted that personnel were using the equipment during the period April 25-28, 1992, when supply pressure was above allowable procedure limit The inspector noted that a supervisor had apparently authorized the pressure to be increased as a result of worker complaints, apparently due to heat related concern The inspector noted that the supervisor apparently was unaware he had exceeded procedure specified values. The inspector noted that the equipment was not being used to provide protection from airborne radioactivity in that ambient airborne radioactivity levels were well below those requiring respiratory protective equipment. Rather the licensee was using the equipment to preclude instances of personnel facial contamination which was a previous problem when personnel were required to stand by to support wor..
Subsequent licensee review iridicated that the airflow rate (standard cubic feet per minute (SCFM)) provided to the workers would have exceeded the allowable maXimum (15 scfm) for the device when pressures exceeded 55 psi The inspector's review of breathing air results indicated breathing air was the appropriate grad Since this matter had minor safety significance because individuals were not making allowance for the use of the device, the matter was quickly corrected, supervisors were notified of the need to follow procedures, and a radiological
. occurrence report was issued, *the inspector.concluded that this matter was considered a non-cited violation in accordance with 10 CFR Part 2, Appendix B, Section V. *
9. Process and Area Radiation Monitor Calibrations The inspector reviewed the calibrations of the following listed radiation monitors. The review was with respect to criteria eontained in Technical Specifications and industry specification Refueling Floor Area Radiation Monitors Fuel Storage Area Radiation Monitor Fuel Handling Building Area Monitor Refueling Bridge Portable Radiation Monitor The inspector evaluated the performance in this area by review of calibration records and discussions with cogniz.ant individual The inspector concluded that the licensee provided acceptable calibrations. No violations or unacceptable conditions were note.0 Plant Tours -
The following observations were made during tours of the station:
The inspector toured the Unit 1 refueling _floor and noted at about 2:00 p.m. on April 28, 1992, that the access door to the drained reactor cavity was not marked to require use of safety belts or line The licensee's radiation protection personnel posted the access door with a sign that requires personnel to don a safety belt when entering the are During tours of the Unit 1 containment annulu~ areas on April 28, * 1992, the inspector observed personnel working in the overhead on service water piping on the low~r elevation of containment.. A small.work group was not using safety belts.. A licensee radiation protection supervisor. was notified who informed the work group supervisor who initiated action to ob~ belt Use of proper safety gear was later discussed at Outage Planning meeting. 0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1.0) on April 28, 1992. The inspector summarized the purpose, scope and fin~ings of the inspection. ~o written material was provided to the license The inspector indicated to the licensee's representatives that the results of the past two NRC radiologicat controls inspections (in the area of in-plant radiation protection) had identified several examples of personnel not. adhering to procedure guidanc The inspector indicated that the individual events were minor in nature but the events, in the aggregate, should be reviewed by the. q~nsee to determine if they were indicative of a potential adverse trend. The licensee acknowledged the commen /