ML18086A234
| ML18086A234 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/20/1980 |
| From: | Knapp P, Nimitz R, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18086A233 | List: |
| References | |
| 50-272-80-28, NUDOCS 8104100509 | |
| Download: ML18086A234 (22) | |
See also: IR 05000272/1980028
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
Report No. p0-272/80-28
Docket No. 50-272
License No. DPR-70
Priority
Region I
Licensee:
Public Service Electric and Gas Company
80 Park Plaza
Newark, New Jersey 07101
Category __
c __
Facility Name:
Salem Nuclear Generating Station, Unit 1
Inspection at: Hancocks Bridge, New Jersey
Inspectors:
Specialist
Approved by:
Inspection Summary:
Inspection on October 7-9 and 14-17, 1980 (Inspection Report No. 50-272/80-28)
Areas Inspected: Special, announced inspection by regional based inspectors of
.
the circumstances and licensee actions taken following a personnel contamination/intake
event on October 4, 1980 and a personnel exposure event on October 10, 1980.
Areas inspected included:
intake and exposure estimates, adherence to procedures,
instructions to workers, radiation protection monitoring, and surveys.
The
inspection involved 60 inspector-hours onsite by two regional based inspectors.
Results: Of the six areas inspected, no items of noncompliance were identified
in three areas.
Eight items of noncompliance were identified in the remaining
areas (Failure to perform surveys in accordance wit~ 20.20l(b) to ensure compliance
with 10 CFR 20.103(a)(l), Paragraph 6.a; Failure to survey in accordance with 10
CFR 20.20l(b) to ensure compliance with 10 CFR 20.101, Paragraph 6.b; Failure to
adhere to posting, barricading and survey meter use requirements of Technical
Specification 6.12, Paragraph 7.a; Failure to adhere to Radiation Exposure
Permit procedures in accordance with Technical Specification 6.11; Paragraph
8.b; Failure to instruct workers entering reactor sump pump area in accordance
4
3.
Description of Events
a.
Fuel Transfer Tube Entry
On the evening of October 3, 1980, two licensee employees, a main-
tenance electrician and his helper, were directed by their supervisor
to perform adjustments of limit switches on the Unit 1 fuel transfer
system.
This system was at the time being modified by the licensee.
The limit switch adjustments were to ensure proper system operation.
At approximately 11:00 PM on October 3, the two individuals attempted
to gain access to the fuel up-ender located in the Unit 1 Transfer
Pool (Fuel Handling Building).
The individuals had signed in on the
Radiation Exposure Permit (REP) for this area, however the individuals
could not gain access to the up-ender area due to the removal of the
access ladder.
The individuals had seen other personnel near the up-
ender and believed the personnel to have gained access to the up-ender
area of the Fuel Handling Building by passing through the Fuel Trans-
fer Tube from the Unit 1 Reactor Refueling Canal area located in the
Unit 1 containment.
The illdividuals exited the Fuel Handling Building
area at approximately 11:20 PM on October 3.
At approxi~ately 11:30 PM on October 3, the individuals signed in on
the REP for the Fuel Transfer.System work in the Unit 1 containment,
descended into the drained Unit 1 containment Refueling Canal and
attempted to enter the Unit 1 Fuel Handling Building through the Fuel
Transfer Tube. The manway into the tube from the area near the reactor
had been removed on the previous shift, ho~ever the closed gate valve
in the tube prevented their entry into the Fuel Handling Building.
The individuals contacted a Senior Shift Supervisor who dispatched an
operator to open the gate valve.
The gate valve was opened and the individuals entered the approxi-
mately 2 foot diameter by 18 foot long transfer tube, crawled through
to the Fuel Handling Building then returned to the reactor area via
the same manner.
Total tube traverse time was estimated to be four
minutes.
The individuals exited the area, and were unable to perform a personal
~fris~* at the 130 foot elevation air lock, due tb no friskers being
present.
The individuals proceeded to the 100 foot elevation air
lock, however the high background on the frisker prevented the individ-
uals from performing a whole body frisk.
This high background was
apparently due to contaminated laundry in the area.
Unable to frisk
at these two locations, the personnel then went to the main control
point where frisking identified extensive personnel contamination .
5
b.
Reactor Thimble Area Entry
On the evening of October 9, 1980, the Senior Shift Supervisor requested
maintenance personnel to investigate the erratic operation of the No.
1 Reactor Sump Pump.
Since the pump was located directly under the
reactor vessel, an entry with escort by radiation protection personnel
was planned.
Prior to the entry, a briefing was he.l d to discuss the entry.
The
briefing, which included the maintenance supervisor, control room
supervisory personnel and radiation protection personnel indicated no
unusual conditions would be encountered.
They did not r~cognize * that the highly radioactive reactor flux
thimbles had been withdrawn'approximately one week earlier to permit
refueling and were producing very high radiation exposure dose rates
near the area of the Reactor Sump Pump.
The entry party, consisting of a maintenance supervisor, a maintenance
mechanic and a radiation protection technician obtained the high
radiation area access key, signed in on a radiation exposure permit,
dressed in protective clothing including respirators (full face par-
ticulate) then proceeded to enter the area under the reactor vessel
(under seal table).
The radiation protection technician descended the
25 foot ladder to the area followed by the maintenance supervisor and
maintenance mechanic.
The entry was made at approximately 12:30 a.m.
on October 10, 1980.
As the radiation protection technician descended the ladder, the
radiation exposure dose rates increased from 100 mR/hr at 10 feet down
the ladder, 2,000 mR/hr prior to stepping off the ladder, and 100,000
mR/hr after stepping off the ladder.
Realizing the measured dose rate
would result in significant personnel exposure, the technician evacu-
ated the area.
Total personnel exposure duration was estimated at 30
seconds.
Upon exiting the area, the personnel read their self-reading pocket
chambers and found them to be offscale.
4.
Fuel Transfer Tube Entry Personnel Exposure
a.
Personnel Contamination
Following identification ~f the personnel contamination at the main
control point, the personnel were whole body 11frisked
11 to determine
the extent of contamination.
b.
6
Review of the pre-decontamination surveys indicated the following:
Individual
A
B
Location
Face
Arm - R
Arm - L
Back
Hands
Face
Shoulders
Hands
Table 1
- Disintegrations Per Minute Beta-Gamma
Before Decontamination (DPM)*
12,000
100,000
60,000
60,000
2,000
24,000
50,000
2,000
The inspector reviewed the licensee 1s follow-up to the personnel
contamination with respect to the following procedures:
PD-15.1.005, "Nasal Swabs", Revision 1 .
PD-15. 1. 006,
11 Decontamination of Personne 1
11 , Revision O.
PD-15.3.027,
11Whole Body Counting Frequency and Action Levels",
Revision 0
The review indicated the licensee had adhered to the requirements of
the above procedures.
Review of the initial personnel contamination and discussions with the
individuals indicated the individuals could not frisk at the 130 or
100 foot access point due to the unavailability of a frisker at the
former location and a high background on the frisker at the latter.
The inspector noted that failure to have adequate capability to detect
these contaminated individuals earlier tended to compromise contamina-
tion control.
Licensee radiation protection representatives indicated
low background friskers are normally at these locations.
Inspector tours of the 130 and 100 foot access points on October 16,
1980 indicated each location had an operating frisker with a nominal
background of 100 counts per minute.
Fuel Transfer Tube Event Personnel Intake Estimates
The licensee 1 s radiation protection staff performed whole body counting,
urine and fecal analysis of the individuals following the event.
The
urine samples collected and counted by the licensee on October 4, 1980
indicated no detectable activity.
7
Licensee analysis of fecal samp.les collected and counted until minimum
detectable activity was reached indicated the following:
Table 2
Individual
A(l)
Radionuclide
Co-58
Total Activity
Voided (Microcuries)
1.4E-4
1. 02E-3
4.07E-3
2.2E-5
(1)
(2)
8(2)
Co-58
3.9E-5
3.15E-4
1. 61E-3
"'6E-6
Total voidings collected October 5, 7 and 9, 1980.
Total voidings collected October 5, 8 and 9, 1980.
The review of the licensee whole body count results of the individuals
indicated the following:
.Individual
. A(2)
Table 3
Radionuclide
Mm-54
Co-58
Deposition(l)
Lung (Microcuries)
1. 04E-3
1. 09E-2
1. 05E-3
2.8E-3
(1)
(2)
(3)
Deposition = amount present in organ of reference.
October 9, 1980 whole body count @ 8:41 AM.
October 9, 1980 whole body count @ 9:46 AM.
To determine the total intake of each radionuclide, the inspector
utilized the guidance presented in Regulatory Guide 8.9,
11Acceptable
Concepts, Models, Equations, and Assumptions for a Bioassay Program
11
8
The following table contains the total intake estimates based on the
summation of fecal analysis and lung count data:
Table 4C4)
Percent of
Appendix B
Quarterly Quantity
Individual
Radionuclide
Deposition
Intake{5)
Intake Limit
(4)
(5)
A
Mn"".54
2.lE-3
2.8E-3
<<1
"'2E-5
"'3E-5
<<1
Co-58
1.2E-3
1. 6E-3
<<1
l.5E-2
"'0.4
B
Mm-54
3.lSE-4
4.2E-4
<<l
"'6E-6
"'8E-6
<<1
Co-58
- "'4E-5
"'5E-5
<<l
l.6E-3
2.lE-3
<<l
Deposition, Intake specified in microcuries.
Intake amount entering the nose or mouth (I CRP 10) ,
Based on the data provided in Table 4, the individuals.that entered
the fuel transfer tube did not sustain intakes in excess of regulatory
limits fbr the identified nuclides.
The licensee has indicated an
intake evaluation is to be submitted to the Director, Region I.
This
evaluation will include evaluation of possible beta and alpha emitter
intakes which are not readily detected by whole body counting (50-'-
1
272/80-28-01).
The inspector noted that utilizing the lung deposition data of Table 3
and assuming it to be long term, non-transportable lung deposition, a
maximum value *Of "'18% (Co-60) of a Quarterly Quantity Intake for the
nuclides listed would have been sustained.
This value was noted to be
conservative.
c.
Fuel Transfer Tube Event Personnel Radiation Exposure
The licensee was unable to perform actual dose measurements in the
transfer tube due to filling of the tube and transfer canal with water
following the event.
Personnel radiation exposure was estimated based on radiation exposure
dose measurements on a fuel transfer cart which traversed the transfer
tube .
5.
9
Using the transfer cart exposure rate measurement and beta/gamma dose
rate ratios from extrapolation chamber measurements of a steam generator
diaphram the licensee estimated the following skin doses:
Table 5 *
Location
Absorbed Dose (mrad)
Eyes
80
Skin (contaminated)
10
Skin (bare direct)
600
Skin (under one pair of coveralls)
300
The skin exposure data presented indicates a maximum exposure of M:ilO
mrad.
The whole body TLD badge worn by each individual indicated 20
millirem.
This gamma exposure would be equivalent to ""300 millirem/hr
for a period of four minutes as calculated by the licensee.
The skin and whole body exposures were noted to be ,....8% and 1""'10% respec-
tively of the allowable quarterly exposure limit.
The licensee is to
submit personnel exposure estimates in a report to the Director,
Region I (50-272/80-28-02) .
Thimble Area Entry Personnel Exposure
Following exit of the personnel from the thimble area, the individuals
1
thermoluminescent dosimeters (TLDs) were processed.
The TLDs are used by
the licensee to provide whole body monitoring of personnel.
The following was noted:
Table 6
Pocket Dosimeter
Total Whole
Total 4th Quarter
Total Prior to
Body Exposure
Individual
Badge Result
Entr~ (4th Quarter)
From Entr~
(millirem)
(millirem)
(millirem)
c
1830
220
1610
D
969
290
679
E
343
0
343
During the initial TLD reads, pre-irradiated control TLDs were read with
the individuals
1
. badges.
Additionally, the three individuals' badges were
irradiated,with known amounts of Sr-90 radiation.
The irradiation and
readout results indicated the TLD reader and badges appeared to be function-
ing properly.
10
Due to the low exposure of Individual E, the TLD worn by this individual
was also irradiated with known doses of Cs-137 gamma radiation.
The sub-
sequent readouts indicated the TLD was responding properly .. The inspector
noted the dose value reported for this individual may, depending on his
location relative to the source of radiation, e.g. facing versus back to
the source, be a higher value.
Based on the individuals 1 TLD readouts presented in Table 6, the individuals
had not exceeded the quarterly whole body dose limit of 10 CFR 20 (3,000
mi Tl i rem)..
The inspectors reviewed the individuals NRC Form 4, Occupational External
Radiation Exposure History, and 5, Current Occupational External Radiation
Exposure, forms to determine if the licensee had obtained and was maintain-
ing exposure history in accordance with 10 CFR 20.102 and 20.401.
For
individuals C and D, the inspector
1s noted this data to be present, however,
for i ndi vi dual E, the inspector noted th.is i ndi vi dua 1 1 s licensee Form 5
equivalent which is to contain all the information required on the Form 5
not to reflect this individual's previous exposure received at other facili-
ties.
The Form 5 equivalent indicated 0 for previous dose received at
other facilities.
Discussions with licensee representatives indicated the
individual, in accordance with procedure PD 15.1.018 had been limited to
100 millirem for the third quarter of 1980 due to the non-receipt of this
individual 1s prior history.
This procedure allowed an individual to receive
for each new calendar quarter an exposure of 500 millirem.
The procedure
further required that doses received above 500 millirem must be approved;
and an NRC Form 4 (Previous Occupational Exposure History) must be on hand
prior to exceeding 1,000 millirem/quarter.
Licensee 1s representatives indicated action will be taken to ensure that
his Form 5 equivalent will reflect incomplete previous history for those
individuals who do not have an up-to-date exposure history (50-272/80-28-
10).
During the entry into the area under the reactor, the personnel wore respira-
tory protection.
Air sample results of the lapel air sampler worn by one
of the individuals indicated an average airborne concentration of 2.9E-
10uCi/ml.
This airborne activity was based on a sampling time of 60 minutes.
Assuming the i*ndividuals remained in this area for a period of 1 minute and
a~suming all. t~e filter actiy~ty ~as d7posite~ during that time, an .,a~e~age
airborne act1v1ty of "'2 x 10
uC1/ml is obtained for the entry.1
Ut1~l1zrng~
a 10 CFR 20 Appendix B quarterly concentration limit of 3 x 1 a- 2uci/ml,
the individuals would have received an airborne radioactivity exposure of
less than 1% of the quarterly quantity intake limit.
This exposure estimate
includes a protection factor of 50 for the respirators worn by the entry
party.
The inspectors noted this to be a conservative airborne exposure
estimate .
- - - - - - - ----
--
11
6.
Surveys and Precautionary Procedures
The inspectors reviewed radiation and airborne radioactivity surveys of the
events to.determine if the licensee had complied with the requirements *bf
10 CFR 20. 201.
11Surveys
11 , requires in paragraph (b) that each licensee
shall make or cause to be made such surveys as may be necessary for him to
comply with the regulations in 10 CFR 20.
Paragraph (a) of §20.201 defines
a survey as an evaluation of the radiation hazards incident to, among other
items, the production, use and presence of radioactive materials or other
sources of radiation under a specific set of conditi-0ns.
Paragraph (a)
also requires that, when appropriate, the evaluation will include a physical
survey of the location of materials and equipment, and measurements of
levels of radiation or concentrations of radioactive material present.
a.
Airborne Radioactivity Surveys/Precautionary Procedures
10 CFR 20.103(a)(l) requires that no licensee possess, use or transfer
licensed material in such a manner to permit any individuals in a
restricted area to inhale a quantity of radioactive material in excess
of the limits specified therein .
10 CFR 20.103(b)(l) requires each-licensee to use, as .a precautionary
procedure, process or other engineering controls, to limit concentra-
tions of airborne radioactive materials in air to levels below the
airborne radioactivity areas as defined in §20.203(d)(l)(ii).
When it
is impracticable to apply process or engineering controls, 10 CFR
20.103, paragraph (b)(2), requires to use other precautionary pro-
cedures,_ such as increased surveillance, limitation of working times,
or the provision of respiratory protective equipment, to maintain
intake of radioactive material by any individual as far below that
intake which would result from inhalation of such material for 40
hours at the uniform concentrations specified in Appendix 8, Table 1,
Column 1, of 10 CFR 20.103 as is reasonably achievable.
In reviewing the reactor thimble area and fuel transfer tube personnel
entry with respect to the above, the inspectors noted that for the
thimble area entry, the licensee had performed airborne radioactivity
surveys and had provided for other precautionary procedures, i.e.,
respiratory protection, in lieu of the process or engineering controls
required by 10 CFR 20.103(b)91).
Review of the transfer tube entry,
however, indicated no airborne radioactivity concentration surveys,
use of process or engineering controls, or the use of other precaution-
ary procedures were utilized for this entry.
b.
12
Inspector review of licensee calculated loose surface contamination
levels of the fuel transfer tube indicated the contamination, through
which the individuals crawled, may have ranged from 500,000 to 1,500,000
dpm/cm .
This was indieated by the licensee as capable of causing,
based gn a resuspension factor of lE-4, airborne radioactivity concen-
trations of 3E-7 uCi/Ml.
This concentration was noted to be approxi-
mately 130 times the value specified as an airborne radioactivity area
as defined in §20.203(d)(l)(ii) for the major radionuclides present
(Co-60) ..
The inspectors noted that failure to survey as required by 10 CFR
20.20l(b) to ensure compliance with 10 CFR 20.103(a)(l) constitutes
noncompliance with 10 CFR 20.20l(b) (50-272/80-28-03).
Review of the fuel transfer tube entry indicated no process or other
engineering controls had been used prior to personnel entry.
Con-
sequently, in discussing what other precautionary procedures were
provided during the entry, the inspectors determined that no precau-
tionary procedures, such as increased surveillance, limitation of
working times, or the provision of respiratory protective equipment
were used.
The inspectors noted the use of precautionary procedures
by the licensee would have ensured that the intake of radioactive
material would have been maintained as far below the value specified
in 10 CFR 20.203(b)(2) as is reasonably achievable.
Further, the
inspectors noted that the failure to utilize these precautionary
procedures as required by 10 CFR 20.103(b)(2) in lieu of the process
or other engineering control required by 10 CFR 20.103(b)(l) consti-
tutes noncompliance with 10 CFR 20.103(b)(2) (50-272/80-28-04).
Radiation Surveys
10 CFR 20.101, "Radiation dose standards for individuals in restricted
areas", requires in paragraph (a) that no licensee possess, use or
transfer licensed material in such a manner as to cause any individual
in a restricted area to receive in any period of one calendar quarter
from radioactive material and other sources of radiation a total
occupational exposure in excess of the standards specified therein.
In reviewing the two events with respect to the surveys performed by
the licensee, as required by 10 CFR 20.201(b) to ensure compliance
with the above requirement, the inspectors noted that for the reactor
thimble area personnel entry, the licensee had utilized a radiation
protection technician equipped with a radiation survey meter to provide
survey results and ensure compliance.
Review of the fuel transfer
tube event, however, indicated no previous radiation surveys had been
performed nor had any radiation surveys been performed during the
personnel entry .
13
Inspector review of licensee calculated radiation dose rates in the 2
foot by 18 foot transfer tube traversed by the personnel indicated
gamma and beta tube contact dose rates may have ranged to 400*mR/hr
and "'9000 mrad/hr respectively.
The inspectors expressed concern with the above and indicated that
failure to survey as required by 10 CFR 20.20l(b) to ensure compliance
with 10 CFR 20.101 constitutes noncompliance with 10 CFR 20.201(b)
(50-272/80-28-05).
7.
High Radiation Area Access Control
Technical Specification 6.12, High Radiation Area, requires in paragraph
6.12.1 that, in lieu of a control device or alarm signal required by 10 CFR
- 20.203(c)(2), each high radiation area in which the intensity of radiation
is greater than 100 mrem/hr but less than 1,000 mrem/hr shall be barricaded
and conspicuously posted as a High Radiation Area and entrance thereto
shall be controlled by issuance of a Radiation Exposure Permit and any
individual or group of individuals permitted to enter such areas shall be
provided with a radiation monitoring device which continuously indicates
the radiation dose rate in the area.
Paragraph 6.12.2 of Technica) Specification 6.12 requires that in addition
to the above, for those areas greater than 1,000 mrem/hr, locked doors to
prevent unauthorized access and administrative key control by the Senior
Shift Supervisor on duty and/or the Senior Performance Supervisor - Chem/HP
will be provided.
a.
Reactor Thimble Area Entry
Review of the events associated with the personnel entry into this
area indicated the above requirements had been adhered to.
The inspectors noted the licensee appeared to adhere to the require-
ments of Procedure PD 15.1-016,
11 Issuance and Control of High Radiation
Area Keys", Revision 0.
Additionally, the inspectors noted Radiation
Exposure Permit (REP) No. 0541, "Routine Surveys, Valving and Inspec-
tion for HP, Chemistry, Operations and Station QA", dated September
20, 1980 to have been used for the personnel entry.
The REP specified
continuous radiation protection coverage for areas inside the biological
shield with dose rates ~ 1,000 millirem/hr.
Additionally, in reviewing personnel adherence to the Radiation Expo-
sure Permit sign in and sign out requirements, the inspectors noted no
documentation, i.e., REP/EREP Access Sign-in Form to be available to
indicate the entry party had actually signed in and out on the appro-
priate exposure permit.
Inspector discussions with the entry party
personnel did indicate the individuals had signed in and out, however,
the sign in form had apparently been misplaced.
14
The' inspectors expressed concern regarding the above.
Licensee repre-
sentatives indicated action will be taken to ensure routine entry
permits will not be uied for entries into areas with significant
- radiological hazard potential and the control of access sign in forms.
(50-272/80-28-13)
~
.
b.
Fuel Transfer Tube Entry
Review of the entry with respect to the above High Radiation Area
posting, barricading and radiation monitoring requirements indicated
that the entry way into the fuel transfer tube, an area with whole
body dose rates of an estimated 300 millirem/hr, had not been barri-
.caded and conspicuously posted as a High Radiation Area.
This entry
way (man-way) had, according to discussions with licensee representa-
tives, been open since the previous shitt, a total time duration
estimated at "'6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Additionally, review of the event indicated that Radiation Exposure
Permits were in effect for performing work on either side of the tube,
i.e., reactor fuel transfer area and fuel handling building transfer
area, however, no Radiation Exposure Permit addressing entry or passage
through the fuel transfer tube was in effect.
Further, the inspectors
noted that for this entry, no continuously indicating radiation moni-
toring device was used by the personnel, the dose rate level in this
area had not been established nor had any individual with a radiation
dose rate monitoring device provided positive control over activities
within the area.
The inspectors expressed concern with the above and indicated to
licensee representatives that failure to adhere to the requirements of
Technical Specification 6.12.1 constitutes noncompliance with that
requirement (50-272/80-28-12).
8.
Procedures
a.
Maintenance Procedures
Technical Specification ~.8, Procedures, requires in paragraph 6.8.l
that written procedures be established, implemented and maintained
covering the applicable procedures recommended in Appendix 11A11 of
Regulatory Guide 1.33, November, 1972, and among other items, refueling
operations.
Regulatory Guide 1.33, recommends in Section's, General Plant Operating
Procedures, that procedures be prepared for preparation for refueling,
refueling equipment operation and core alterations.
Retraction of
reactor flux thimbles is performed in preparation for refueling.
Maintenance Procedure MlOA,
11 Incore Flux Thimble Retraction and Rein-
sertion11, Revision 1, requires in Section 9.8, 11Supervisor Witness 11 ,
15
that the supervisor witness notify the Senior Shift Supervisor *and
obtain permission to proceed with this portion of the procedure (thimble
withdrawal) and verify that all work under the reactor seal table is
complete, the. area is evacuated and access to this area has been
locked and tagged for the Shift Supervisor.
The requirements of this section of procedure MlOA*ensure that prior
to withdrawal of the highly radioactive reactor flux thimbles, the
area under the reactor (reactor thimble area) has been controlled to
prevent unauthorized personnel access and possible inadvertent personnel
exposure.
Inspector review of the personnel entry into the reactor flux thimble
area for inspection of the Reactor Sump Pump, indicated that following
thimble retraction on September 30, 1980, this area (area under seal
table) had been evacuated and the access to same had been locked.
However, the access had not been tagged to reflect retraction of flux
thimbles prior to the entry on October 10, 1980.
The inspectors noted that failure to tag the access to the area under
the reactor seal table as required by procedure MlOA was noncompliance
with Technical Specification 6.8.1 (50-272/80-28-06).
b.
Radiation Protection Procedures
Technical Specification 6.11, "Radiation Protection Program", requires
that procedures for personnel radiation protection be prepared consis-
tent with the requirements of 10 CFR 20 and be approved, maintained
and adhered to for all operations involving personnel radiation expo-
sure.
Radiation Protection Procedure PD-15.1.013, "Radiation Exposure Per-
mit/Extended Radiation Exposure Permit", Revision 2, requires in
Section C.l that a valid Radiation Exposure Permit is required to
perform all planned work in any area that is:
determined to be a High
Radiation Area (>100 mr/hr)z has loose surface contamination levels
greater than 2200 dpm/lOOcm ; requires the use of respiratory protec-
tive equipment or in which a contaminated system is being breached.
Review of the personnel entry into the fuel transfer tube indicated
that the area was a High Radiation Area (~300 mR/hr calculated after
the entry~ and had loose surface contamination of up to 1,500,000
dpm/lOOcm
(beta-gamma).
Additionally, the fuel transfer tube was
noted to essentially be a contaminated system which was breached.
Review of this entry with respect to the guidance provided in Radiation
Protection Procedure PD-15.6.009, "Respiratory Protective Equipment
Selection and Issue", Revision 2, and the li.censee 1 s memorandum of
16
July 9 to all Radiation Protection Personnel, respiratory protective
devices would have been required by the individuals for their entry*
into the fuel transfer tube.
The inspectors review of the entry indicated that valid Radiation
Exposure Permits were in effect for work on either side of the transfer
tube, however, no valid Radiation Exposure Permit was in effect for
removal of the manway to the fuel transfer or entry of personnel into
the tube.
Consequently, the inspectors indicated to licensee repre-
sentatives that failure to adhere to the requirements of procedure PD-
15.1.103 as .required by Technical Specification 6.11 constitutes
noncompliance (50-272/80-28-08).
9.
Instructions to Workers
10 CFR 19.12, "Instructions to Workers", states, in part, "All individuals
working in or frequenting any portion of a restricted area shall be kept
informed of the storage, transfer, or use of radioactive materials or of
radiation in such portions of the restricted area; ... The extent of these
instructions shall be commensurate with potential radiological health
protection problems in the restricted area" .
a.
Fuel Transfer Tube Entry Worker Instructions
The inspectors reviewed and discussed with licensee representatives
and the individuals who entered the fuel transfer tube the nature and
extent of the information and instructions given the individuals prior
to their entry into the fuel transfer tube.
Based on the review and
discussions, the inspectors determined that no information or instruc-
tions commensurate with the potential radiological health problems in
the area were given.
The discussions indicated the indivdiuals were not informed, either
through posting of signs, barricading, radiation protection technician
instruction or a pre-work meeting as to the nature and extent of
radiological conditions;present in the tube.
Review of the calculated
radiation and contamination surveys of the transfer tube indicated
removable loose surface contamination of the tube may have reached
1,500,000 dpm with whole body radiation dose rates ranging as high as
300 millirem/hr.
The inspector discussions with licensee representatives and review of
the individual contamination and whole body count data indicated the
two individuals who entered the transfer tube sustained significant
personal contamination and limited intakes of radiation material .
17
The inspector expressed concern with the above and indicated to licensee
representatives that failure to inform workers of the extensive radio-
active contamination and radiation dose rates in the fuel transfer
- tube constitutes noncompliance with 10 CFR 19.12 (50-272/80-28-07).
b.
Thimble Area Entry Personnel Instructions
Prior to entry into the area under the reactor seal table, the inspec-
tor determined through discussions with licensee representatives and
interview of entry personnel that, a pre-entry planning meeting was
held which included discussions of the radiological aspects of the
entry.
The entry party was informed at the pre-entry meeting that no
unusual radiological conditions would be encountered or expected and
the maximum whole body exposure dose rates that would be expected
ranged from 200-300 mR/hr.
The pre-entry meeting discussions did not
address the retracted flux thimbles nor the potential for significant
whole body exposure dose rates as a result of the retracted thimbles.
Upon entry into the area by descending a ladder which hampered the
performance of adequate radiation surveys, the individuals determined,
through performance of radiation surveys at the base of the ladder
that they had inadvertently entered whole body radiation exposure dose
rates of up to 100,000 mR/hr.
The individuals immediately exited the
area following the discovery.
As a result of the above, the three
individuals received inadvertent whole body radiation exposures ranging
up to 1600 millirem.
The licensee later performed a review of the cause of unexpected
radiation dose rates.
The licensee 1s Reactor Engineer identified the
cause as radiation dose rates emanating from highly radioactive reactor
flux thimbles which had been retracted prior to refueling.
The flux
thimbles had been retracted through guide tubes which pass through the
area entered by the personnel.
The inspectors expressed concern with the above and indicated to
licensee representatives that failure to inform the entry party personnel
of the flux thimbles which were retracted for storage and potentially
significant radiation dose rates emanating from the stored thimbles
constitutes noncompliance with 10 CFR 19.12 (50-272/80-28-09).
10~
Radiation Protection Monitoring
The inspector reviewed the adequacy of radiation protection monitoring
provided during the personnel entry into the reactor cavity including the
training and qualifications of the individual providing this monitoring.
The review indicated the licensee utilized a contractor radiation protec-
tion technician to provide continuous coverage during the entry.
Review of
.
18
the technician's qualification and licensee provided training information
indicated the licensee appeared to have selected the individual in accordance
with ANSI-Nl8.l, 1971, "Selection and Training of Nuclear Power Plant
Personnel and had trained the individual in accordance with Salem Generation
Statton Performance Manual, Revision 10, Section 3.4, Radiation Protection
Personnel Training.
The inspector noted this to include training iri the
applicable radiation protection procedures, instrumentation and completion
of a qualification exam.
In reviewing the individuals resume, the inspector
noted this document to be misleading in that work experience in a certain
area that was not actual, was stated to have been acquired.
Although the
experience* not actually obtained reduced the individual's total experience
by several months, the individual still appeared to meet the ANSI-N18.1
section criteria. The inspector discussed this with licensee representatives
and expressed concern regarding this.
Licensee representatives performed a review which indicated this appeared
to have been the only resume of this type.
Licensee radiation protection
representatives indicated all contractor resumes will be required to be
written in a manner to provide a concise time break down versus function
which had been performed.
(50-272/80-28-11).
11. Additional Item
In reviewing the personnel entry to the Reactor Cavity under the reactor
vessel to inspect the Reactor Sump Pump and their inadvertent entry into
the high radiation dose rates caused by the retracted flux thimbles, the
inspectors determined through discussion with licensee representatives that
one of the three individuals entering the area (the Maintenance Supervisor)
had been involved with the retraction of the flux thimbles approximately
one week earlier.
However, this individual did not realize the potential
radiological hazards associated with thimble retraction including the
potential for significant radiation dose rates from the retracted thimbles.
Consequently, as a result of this lack of familiarity with the radiological
hazards associated with the thimbles, the licensee ,has committed to estab-
lish and implement a training program for plant supervisors in plant systems.
This training, to be implemented prior to the next refueling outage, will
address the potential radiological hazards of plant systems.
This commit-
ment was documented in the October 24, letter discussed above.
12.
Exit Interview
The inspectors met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspecton on October 17, 1980.
The inspectors
summari~ed the purpose, scope and findings of the inspection .
19
Licensee representatives stated the following:
Personnel exposure and intake estimates for the two events would be
submitted to the Di rector, Region I.
All site supervisory personnel would be instructed in the requirement
to take all necessary action to prevent inadvertent or unnecessary
radiation exposure of plant personnel due to tasks under their direc-
tion.
Senior Shift Supervisory personnel would be instructed in their
special responsibility in *this area.
The reactor flux thimble maintenance procedure would be revised to
require Senior Radiation Protection Supervisor and Senior Shift Super-
visor verification of locking and tagging of the area under the seal
table upon thimble retraction.
The* radiation exposure permit procedure would be revised by October
24, 1980, to prohibit work not described on the permit from being
performed and to designate those individuals authorized to give radia-
tion protection approval.
A special Station Operations Review Committee meeting was held on
October 16, 1980 to review the two events and recommend corrective
actions .
.-
U.S. NUCLEAR REGULATORY COMMISSION
. .. OFFICE OF INSPECTION AND ENFORCEMENT
Report No.
50-272/80..:28~ Supplement
Docket No. 50-272
Region I
License No. DPR-70
Priority ___ _
Licensee: Public Service Electric Gas Company
80 Park Plaza
Newark, New Jersey 07101
Category
Facility Name:
Salem Nuclear Generating Station, Unit 1
c
date signed
Approved by:
date signed
Inspection Summary:
This supplement involves the development of additional detailed description
relating to the review of plant conditions. A new Details Section 11,
11Plant
Conditions Review
11
, involving pages 18, 19, 20, and 21 are attached .
18
the technician's qualification and licensee provided training information
indicated the licensee appeared to have selected the individual in accordance
with ANSI-N18.1, 1971, "Selection and Training of Nuclear Power Plant
Personnel" and had trained the fodividual in accordance with Salem Generation
Station Performance Manual, Revi'sion 10, Section 3.4, Radiation Protection
Personnel Training.
The inspector noted this to include training in the
applicable radiation protection procedures, instrumentation and completion
of a qualification exam.
In reviewing the individuals resume, the inspector
noted this document to be misleading in that work experi'ence ina certain
area that was not actual, was stated to have been acquired. Although the
experience not actually obtained reduced the individual's total experience
by several months, the individual still appeared to meet the ANSI-N18.1
section criteria. The inspector discussed this with licensee representatives
and expressed concern regarding this.
Licensee representatives performed a review which indicated this appeared
to have been the only resume of this type.
Licensee radiation protection
representatives indicated all contractor resumes will be required to be
written in a manner to provide a concise time break down versus function
which.had been performed.
{50-272/80-28-11).
11.
Plant Conditions Review
The inspector reviewed the reactor cavity area entry with respect to the
requirements of Procedure PD-15.1.013, "Radiation Exposure Permit/Extended
Radiation Exposure Permit", Revision 2.
Section B, Basic Personnel Requirements, of .the referenced procedure states,
11To ensure the radiological safety of personnel performing work under
any REP or EREP, the following three basic requirements shall herein
be established:
(1) Shift Supervisor or Senior Shift Supervisor shall
ensure safe plant operating conditions prior to allowance of proposed
REP/EREP work; (2) Station Radiation Protection personnel shall estab-
1 ish REP/EREP requirement so as to ensure the radiological safety of
personnel performing work under a REP/EREP; and (3) Work Party Super-
visory personnel shall ensure worker's compliance with established
REP/EREP requirements.
11
The review *of this event indicated that Item 3 appeare*d to have been adhered
to in that the Work Party Supervisor (Maintenance Supervisor) accompanied
the personnel during the entry and would ensure worker compliance,with the
REP/EREP requirements.
Regarding Item 2, a pre-planning meeting was held
prior to the entry and, based on Reactor Cavity conditions presented to the
radiation protection personnel in attendance at this meeting, appropriate
action appeared to be taken regarding this item.
In reviewing adherence to Item 1 of the above procedure, the inspector
noted that the fact that flux thimbles were retracted, an operating condition
19
which could preclude safe performance of the proposed REP/EREP work, was
not discussed during the pre-planning meeting prior to performance of the
proposed work.
Consequently, the entry party personnel were unaware of the
retracted flux thimbles and entered an area tn which plant conditions, were
not safe for purposes of the proposed work.
As a result, the apparent failure to adhere to Item 1 above, was discussed
in subsequ~nt telephone discussions with the Senior Shift Supervisor involved
and the Chief Engineer. This Senior Shift Supervisor's prior knowledge of
the thimble withdrawal and the hazards associated therewith were also
discussed.
Discussion with the Senior Shift Supervisor revealed that, well before
October 10, 1980, he was aware of the hazard associated with entry to the
Reactor Cavity when the thimbles are withdrawn because he had reviewed IE
Circular 76-03.
Additionally, it was noted that the licensee has in place
a procedure, Administrative Procedure (AP) No. 5,
110perating Practices
Program,
11 which provides for a Night Order Book to provide written orders
of a short-term nature to the Shift Supervisor including, but not limited
. to daily schedule matters, short-term operationai plans, and precautions of
a special or short-term natureJ Shift Supervisors are required to read all
entries subsequent to their last review, and initial them, signifying that
they have read and understand the orders. Review of the Night Order Book
for September 30, 1980,. indicated an entry had been made stating maintenance
was retracting flux thimbles. This entry had been initialed by the Senior
Shift Supervisor involved.
However, it was not dated.
The subsequent telephone discussions with the Senior Shift Supervisor
involved indicated he had returned to his shift duties on October 4, 1980
after having been off shift for approximately one week.
The Senior Shift
Supervisor stated that upon return to shift duties, as soon as time permits
he reads the appropriate logs, including the Night Order Book, to determine
what has transpired during his time off shift.
The inspector discussions with the Senior Shift Supervisor involved indicated
that he believed that, upon returning to shift he had, by the time of the
cavity entry on October 10, 1980, (a period of approximately five days),
read these materials including the Night Order Book.
The supervisor indicated,
however, that he did not specifically recall the entry regarding withdrawal
of flux thimbles.
Based on the above, the inspector determined that the Senior Shift Super-
visor had been apprised of the hazards associated with the Reactor Cavity
area containing withdrawn flux thimbles through his reading of the IE
Circular No. 76-03.
Additionally, it appears that the individual was
informed of the2withdrawal of the flux thimbles through the mechanism
provided by AP No. 5, i.e., the Night Order Book.
The inspector could not
determine if the individual had read and initialed this entry prior to the
event on October 10, 1980.
However, based on the discussions with this
individual it was likely that he had read and initialed prior to the event.
lReview of this procedure shows the Night Order Book is not necessarily a record of
2all work.accomplished, but rather contains a list of things to be accomplished.
planned
.
.-
,
.
20
Regarding the Senior. Shift Supervisor's responsibility for implementing the
requirements of Procedure PD-15.1.013, the inspector noted that, although
the procedure is a Performance Department Procedure and not an "operations
procedure", Senior Shift Supervisors, in their training to become licensed
operators and senior operators, receive *extensive training in radiation
protection procedures including Procedure PD-15~1.013. The inspector
. further noted that this procedure was SORC approved and bore the Station
Manager's approval.
The inspector noted that a controlled copy of this procedure was not kept
in the control room.
He questioned the licensee's Chief Engineer regarding
this matter and about the necessity for the Senior Shift Supervisor to
implement portions of the procedure.
The Chief Engineer indicated that the
procedure was not needed in the control room because the Shift Supervisor's
input was
11minimal
11
As a result of the above, the licensee's commitment that all site supervisory
personnel would be instructed in the necessity to take all necessary action
to prevent inadvertent or unnecessary radiation exposure of personnel due
to tasks under their directton was documented tn a letter dated Octo5er 24,
1980, from the Director, Region I to the licensee's Vice Prestdent-Production.
This letter also documented t6e commitment to instruct Senior Shift Supervisors
in their special responsioility i"n tnis area. Tnis tnstruction was to be
completed by October 31, 1980.
12. Additional Item
13.
In reviewing the personnel entry to the Reactor Cavity under the reactor
vessel to inspect the Reactor Sump Pump and their inadvertent entry into
the high radiation dose rates caused by the retracted flux thi't11bles, the .
inspectors determined througn dtscussion with ltcensee representatives that
one of the three individuals entertng tne area (tfie Mai"ntenance Supervisor)
had been involved with. the retraction of the flux. thimBles approximately
one week earlier.
However, thts indtvi'dual di'd not reali'ze tfte potenti"al
radiological hazards associat~d wtth thtm51e retractton including tile
potential for significant radiati"on dose rates from the retracted thtmbles.
Consequently, as a result of tnis lack of familiarity wi'th the radiological
hazards associated with the tfitm5les, the licensee has committed to estab-
lish and implement a training program for plant supervisors in plant systems.
This training, to be implemented prior to the next refueltng outage, will
address the potential radi'ologi'cal hazards of plant systems.
This commit-
ment was documented in the Octo5er 24, letter discussed aoove.
Exit Interview
The inspectors met with ltcensee. representatives (denoted in paragraph 1]
at the conclusion of the inspect'on on October 17, 1980..
The inspectors
summarized the purpose, scope and findings of the inspection.
' 21
Licensee representatives stated the following:
Personnel exposure and intake estimates for the two events would be
submitted to the Director, Region I.
All site supervisory personnel would be instructed in the requirement
- to take all necessary action to prevent *inadvertent or unnecessary
radiation exposura of plant personnel due to tasks under their direc-
tion.* Senior Shift Supervisory personnel would be instructed in their
special responsibility in this area.
The reactor flux thimble maintenance procedure would be revised to
require Senior Radiation Protection Supervisor and Senior Shift Super-
visor verification of locking and tagging of the area under the seal
table upon thimble retraction.
The radiation exposure permit procedure would be revised by October
24, 1980, to prohibit work not described on the*permit from being
performed and to designate those individuals authorized to give radia-
tion protection approval.
A special Station Operations Review Committee meeting was held on
October 16, 1980 to review the two events and recommend corrective
actions.