ML18093A523
| ML18093A523 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 12/04/1987 |
| From: | Loesch R, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093A521 | List: |
| References | |
| 50-272-87-30, 50-311-87-31, NUDOCS 8712140421 | |
| Download: ML18093A523 (11) | |
See also: IR 05000272/1987030
Text
Report No.
Docket No.
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
50-272/87-30
50-311/87-31
50-272
50-311
License No.
Priority
Category C
Licensee:
Public Service Electric and Gas Company
P. 0. Box 236
Hancock Bridge, New Jersey 08038
Facility Name:
Salem Nuclear Generating Station
Inspection At:
Hancock Bridge, New Jersey
Inspection Conducted:
October 19-23, 1987
Inspectors:
~j.._,,
, Radiation Spec*
dat~
/J-/L/-/n-
date
1z/f /11z
'
date
Inspection Summary:
Ins ection on October 19-23, 1987 (Combined Ins ection
Report Nos. 50-272/87-30; 50-311/87-31 *
Areas Inspected:
Reactive, unannounced inspection of the licensee's
Radiological Controls Program.
The following incidents were reviewed:
hot
particle contamination of a worker, a primary spill from the No. 13 steam
generator and subsequent decontamination effort, and the reported intentional
defeat of locked high radiation area doors.
Results: Three violations were identified:
1) failure to adequately control
locked high radiation area doors, T.S. 6.12; 2) failure to follow RWP
requirements, T.S. 6.11; and 3) failure to have procedures for use and
calibration of breathing-zone air sampler (MPC-hr meter), T.S. 6.8.
8712140421 871209
ADOCK 05000272
Q
DETAILS
1.0 Personnel Contacted
1.1 Licensee Personnel
During the course of this inspection, the following personnel were
contacted or interviewed:
J. Beattie, Training Instructor
H. Bergerdahl, Sr. Supervisor, RP-OPS
- E. Browde, Station QA Supervisor - Nuclear Operations
- T. Cellmer, Radiation Protection Engineer, Hope Creek
- J. Clancy, Principal Health Physicist, RPS
J. Lewis, Sr. Health Physics Technician
- D. Mohler, Radiation Protection Engineer
T. Parry, Sr. Health Physics Technician, BG&E
D. Radley, Jr., Decon Technician, HPTS
J. Rodriquez, Decon Technician, HPTS
- G. Raggio, Station Licensing Engineer
S. Simpson, Sr. Supervisor, RP - Projects
- J. Trejo, Radiation Protection/Chemistry Manager
- J. Zupko, General Manager, Salem Operations
Other licensee or contractor personnel were also contacted.
1.2 NRC/State Personnel
T. Kenny, Senior Resident Inspector
- K. Gibson, Resident Inspector
- N. DiNucci, Dept. of Environmental Protection, State of New Jersey
The representative from the State of New Jersey accompanied the
inspectors during various periods of the inspection.
- Denotes attendance at the Exit Meeting held on October 23, 1987.
2.0 * Purpose
The purpose of this reactive inspection was to review the radiological
protection activities associated with three incidents. Areas inspected
included:
0
0
0
spill of primary water from the No. 13 Steam Generator on
October 9, 1987, and the subsequent decontamination effort;
fuel particle (hot particle) contamination of an individual
associated with the steam generator decontamination; and
defeating of locked high radiation doors.
1--
3
3.0 Steam Generator Primary Spill
On October 9, 1987, a spill of primary coolant into the 78' elevation of
the Unit 1 containment resulted upon removal of the steam generator(S/G)
- 13 cold leg diaphragm.
Original estimates indicated approximately 8500
gallons of coolant leaked into containment; subsequent.review of
containment sump l~vels, etc., led to a revised estimate of the spill
volume of approximately 900 gallons.
Eight individuals in the area were
contaminated.
Details concerning operational aspects of the spill are
discussed in the NRC Resident Inspectors Report (Combined Report No.
272/87-28; 311/87-30). Regional radiation specialists reviewed health
physics aspects related to the spill by the following methods:
interview of cognizant (Radiation Protection) RP staff, including
the RP technician covering the diaphragm removal operation,
review of the following documentation:
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0
0
0
0
RWP 87-0810,
11 13 S/G Primary Manway Removal/Clean, Inspect
11
Radiological Occurrence Report (ROR) #381 and the ROR logbook,
selected whole body count results for four individuals
contaminated in the spill,
selected radiological survey results,
Procedure RP 205, Rev. O,
11 Decontamination of Personnel and
Skin Dose Assessment.
11
An interview with the RP technician covering the diaphragm removal work
identified three individuals that were on the steam generator (S/G)
platform when the spill occurred.
Licensee surveys identified a total of
eight people that were contaminated as a result of the spill. Four of
these eight individuals received subsequent whole body counts on the
basis of contamination greater than 200 cpm over background above the
neck, in accordance with procedure RP205.
Initial whole body count
results and intake estimates for these individuals ranged from
approximately 2 to 8 MPC-hrs; these values are well below regulatory
limits (520 MPG-hrs/quarter).
The maximum intake was measured for the RP technician. This individual
stated that during the incident the force of the spill unseated the
respirator on his face and he subsequently discovered a small amount of
water inside his respirator.
Air samples were being taken on the S/G platform but were soaked during
the spill. Results from air samples drawn in an adjacent area on the
same elevation indicated air activity was less than 0.1 MPC for iodine
and particulates as a result of the spill.
4
The inspector reviewed licensee actions relative to the subsequent
decontamination of the inner bioshield area. Air samples were taken
prior to and during the decontamination effort; however no survey was
made and documented to show radiation and contamination levels inside the
bioshield prior to initiating decontamination efforts. The licensee
indicated that a decision not to perform such a survey had been made
consciously, to conserve exposure.
The licensee indicated, however, that
an appropriate evaluation of radiological hazards was made prior to
allowing work in the area, as:
based on a knowledge of coolant activity, the licensee knew the area
was highly contaminated, and provided appropriate protective
clothing and respiratory protection,
'an RP technician provided direct coverage and surveys during
decontamination.
The inspector noted the licensee in effect performed an
11evaluation
11 of
radiological hazards consistent with the 10 CFR 20.201 definition of
11survey
11 and had no further questions in this area.
Overall, licensee follow-up actions in response to the S/G spill appear
appropriate.
The inspector did identify, however, that an MPC-hr meter
was not worn by the worker performing the S/G diaphram removal as
required on the RWP.
This is discussed in Section 6.0.
4.0 Hot Particle Contamination Incident
On October 10, 1987, at approximately 0030, an individual who had been
performing decontamination work inside the Unit 1 containment (78'
elevation) alarmed the contamination monitor at the control
point.
Subsequent investigation identified that a small, high activity fragment
(hot particle) was located in the sleeve seam of the individual's
T-shirt, close to the armpit.
No contamination was identified on other
members of the decontamination crew.
The inspector evaluated the licensee's investigation into the hot
particle contamination incident by the following methods:
interview of the contaminated individual;
interview of cognizant members of the RP staff;
review of the following documentation;
0
0
- o
ROR logbook;
draft procedure RP 808,
11Discrete Radioactive Particle Exposure
and Contamination Control
11
licensee memo RP 87-413, "Handling of Discrete Particle
Contaminations.
11
5
Licensee subsequent analysis of the particle identified it as a fuel
fragment or "fuel flea" rather than an activated corrosion product.
Preliminary dose calculations performed independently by the licensee and
the NRC using the VARSKIN computer code indicated a potential skin
exposure (approximately 12 rem), which was in excess of the regulatory
limit of 7.5 rem/quarter to the skin of the whole body.
The licensee
stated they felt this preliminary value to be an overestimate and was
still in the process of evaluating the dose during the period of this
inspection. A time motion study was performed which indicates the2dose
may have been distributed over a larger area of skin (i.e., 16 cm) than
that assumed in the computer calculations.
The licensee has also sent
the particle to a contract laboratory for further analysis.
Final determination as to whether the fuel fragment contamination
incident discussed above constitutes an exposure in excess of regulatory
limits remains unresolved pending licensee completion of their final dose
estimate (50-272/87-30-05).
The inspector noted the licensee's actions upon identification of the
above fuel fragment appear appropriate.
Decontamination and subsequent
particle analysis was timely.
The individual was also suspended from
work inside the radiologically controlled area pending completion of the
licensee's evaluation.
During NRC interview, the subject worker
indicated that the licensee's RP staff had been conscientious in
explaining the status of their ongoing evaluation.
In response to hot particle contamination concerns, the licensee is
implementing an increased hot particle surveillance and control program.
Surveys have identified two areas, the reactor cavity and the 78'
elevation inner bioshield area, as potential hot particle contamination
areas.
Hot particle protective measures have been included as an
attachment to RWPs for these areas, and variously include the use of
additional protective clothing (PC's), hourly frisking of workers by RP
technicians, and shiftly hot particle surveys in the area. Additionally,
the licensee has performed spot checks on protective clothing available
for issue in the plant and has performed an audit of the site PC
laundering facility.
During the time period of this inspection, the above measures were being
implemented as RP policy and through the use of the RWP system.
However,
a specific hot particle control procedure was not in place.
The
inspector did review draft procedure RP 808 and noted it described a
detailed hot particle control program.
The licensee indicated that the
need to formalize their hot particle program had been recognized and
procedure RP 808 would be approved as soon as possible.
The licensee's
efforts in this area will continue to be reviewed during subsequent
inspections.
6
5.0
Failure to Control High Radiation Area Doors
Licensee Technical Specifications (TS) 6.12.2 requires that
11areas
accessible to personnel with radiation levels such that a major portion
of the body could receive in one hour a dose greater than 1000 mrem shall
be provided with locked doors to prevent unauthorized entry *.*
11
On October 8, 1987, licensee radiation protection (RP) technicians
identified on two separate occasions that the #14 bioshield door on the
78' elevation of the Unit 1 containment was in an unlocked condition.
The door was first discovered open at approximately 1030 and was secured
at that time.
The door was subsequently discovered open again by a
different RP technician at approximately 1225.
In each instance, the
installed self-locking mechanism on the door had been intentionally
defeated by inserting a wadded-up plastic shoecover into the door plate.
The #14 bioshield door was one of four doors providing access to the -
inner loop area, which was posted and controlled by the licensee as a
lockable High Radiation Area (HRA).
A licensee survey taken inside the bioshield area on October 6, 1987,
identified dose rates of 1.5 R/hr at 18 inches from the N-16 pipe tunnel.
The licensee stated that as of October 8, 1987, the N-16 pipe tunnel
inside the bioshield had not been individually roped off and posted with
a flashing light and sign to identify it as a high radiation area as
allowed in the Technical Specifications.
NRC review into circumstances surrounding the above event, as well as
station HRA key control practices, included the following:
discussion with RP and training department personnel;
inspection of the HRA
11 key trap
11 and key issue log.
review of the following documentation:
0
0
0
Procedure RP 1.016,
11 Issuance and Control of High Radiation
Area Keys
11
Radiological Occurrence Reports (RORs) #87-097,87-367, 87-368;
lic~nsee memo No. RP87-412,
11Locked High Radiation Door
Access", dated October 12, 1987.
Licensee immediate actions in response to the above incidents included
removing the shoecovers and locking the door, ensuring the other three
bioshield doors were secure, and performing tours into the bioshield area
to ensure any personnel in the area were authorized.
The licensee also
issued two RORs addressing the events (#87-367, #87-368).
The following
actions were also taken by the licensee:
1.
Computer access and exposure records were reviewed to identify
personnel that could have been in the area and to ensure no
unusually high exposures were received.
7
2.
An investigative, "fact-finding" session was held with individuals
signed in on Radiation Work Permits for the bioshield area for the
subject time periods.
3.
Two of the four access doors to the inner bioshield area were
padlocked shut.
4.
RP technician surveillance of HRA door integrity were increased,
pending installation of a closed circuit TV system to monitor the
most commonly used bioshield access door.
5.
The RP services group conducted an audit of the bioshield access
area and HRA key control.
6.
A memo, describing HRA control requirements and proper use of locked
doors, was issued to all Department Managers from the Salem General
Manager.
The memo required that all personnel be briefed by their
supervisors concerning the contents of the memo.
A similar loss of control of a HRA door, in which a plastic shoecover was
used to defeat the locking mechanism of the Unit 1 #14 bioshield door,
was identified by the licensee on March 12, 1987.
Details, along with
the licensee
1 s corrective actions, are discussed in NRC Combined Report
No. 272/87-07; 311/87-08.
In recognition of the licensee
1s
identification of that event, and in accordance with 10 CFR 2,
Appendix C, a notice of violation was not issued for the March, 1987,
event.
To encourage licensee self-identification of problems, 10 CFR 2,
Appendix C states the NRC will not generally issue a notice of violation
for a violation that meets the following tests:
(1) it was identified by the licensee;
(2) it fits in Severity Level IV or V;
(3) it was reported, if required;
(4) it was or will be corrected, including measures to prevent
recurrence, within a reasonable time; and
(5) it was not a violation that could rea~onably be expected to have been
prevented by the licensee
1s corrective action for a previous
violation.
Failure of the licensee to maintain the Unit 1 #14 bioshield door in a
locked condition on October 8, 1987, constitutes an apparent violation of
T.S. 6.12.2 (272/87-30-01).
The inspector stated to the licensee that
despite the licensee
1s identification of the door
1s unlocked condition on
October 8, 1987, that all mitigative tests given in 10 CFR 2, Appendix C
were not met and consequently a notice of violation would be issued.
Specifically, the licensee
1s corrective actions for the March, 1987 event
were not ef~ective in preventing the October 8, 1987 recurrence.
The licensee
1s investigation into circumstances surrounding the October
8, 1987, event had not identified specific individuals responsible for
defeating the HRA do~r. Part of the evaluation was directed towards
8
determining if the current HRA key control system was too cumbersome for
workers seeking access to HRAs.
If so determined, steps could then be
taken to modify the procedure to ease constraints without compromising
its purpose of control.
The inspector determined, through discussion with RP management and.
review of licensee memo RP87-412, that the intent of the HRA key control
system is that qualified workers can be issued HRA keys and can open,
guard, and provide positive control over HRA accesses.
Interview of
several technicians indicated, however, that this intent is not being
carried out in the field; only RP technicians are controlling HRA keys
and are physically unlocking HRA doors for each worker entry to HRA.
The
inspector noted that procedure RPl.016 indicates that HRA keys can be
issued to personnel qualified in the use of the procedure; however it
does not define who these individuals are (i.e., technicians only, or
technicians and workers).
The inspector communicated this apparent inconsistency between intent and
practice to the licensee, who indicated it would be evaluated.
6.0 Internal/External Exposure Control
The licensee's program relative to internal and external exposure control
was reviewed against criteria contained in the following:
0
0
0
0
Technical Specification 6.11, "Radiation Protection Program";
Technical Specification 6.8, "Procedures and Programs";
10 CFR 20, "Standards for Protection Against Radiation"
Licensee.procedures:
RP-202, Rev. 1, "Radiation Work Permits";
M12-BOP-04, Rev. 0, "Evaluation of Bioassay Data";
AP-24, Rev. 9, "Radiological Protection Program.
11
Licensee performance relative to the criteria was evaluated by the
foll owing:
0
0
0
0
0
0
0
0
Review of air sample records and associated MPC's;
Discussions with cognizant personnel;
Review of outage Radiation Work Permits;
Tours of the Auxiliary Building and Containment;
Review of survey documents;
Review of letter dated October 5, 1986, Ref. No. RP86-123,
11MPC-Hours Meter Guidelines";
Review of vendor's manual for MPC-hour meter.
Within the scope of this inspection, two apparent violations were
identified; i) failure to follow radiation protection procedures, and
ii) failure to have an approved procedure for instrument use and
calibrations.
9
1.
11Radiation Protection Program,"
requires, in part, that procedures for personnel radiation
protection shall be approved, maintained and adhered to for all
operations involving radiation exposure.
A.
Procedure RP-202, "Radiation Work Permits
11
, requires, in part,
for all jobs requiring continuous Radiation Protection
coverage, the Radiation Protection technician assigned to the
job shall brief the work party and the pre-job briefing shall
be documented on Attachment 12.3,
11Pre-job Briefing Summary,
11
and filed with the respective RWP.
Inspector review of currently posted active RWP's identified
ten (10) RWP's where continuous coverage and
pre-job briefings
were required on the RWP.
The RWP's identified were as
follows: 87-787, 87-813,87-814, 87-819,87-821, 87-867,87-912, 87-958,87-980, and 87-1001.
Review of the RWP
Compliance Agreement sheets, to verify dates the RWP's were
used, and of the RWP folders revealed that pre-job briefings
were not documented as required.
B.
Attachment 12.1,
11 RWP Compliance Agreement
11
, to Procedure
RP-202 states that
11your (the worker's) signature below
indicates that you have read, understand and will abide by the
provisions of the RWP referenced above.
11
The inspector identified three (3) instances, RWP's87-962,* 87-810 and 87-813, which required use of a MPC-hour meter.
Review of the air sample log sheets and interviews with the
Health Physics technicians that provided job coverage
determined that MPC-hour meters were not used as required by
the RWPs.
The above represents two examples of a failure to follow T.S
6.11 required procedures (50-272/87-30-02 and 50-311/87-31-01).
The above matters were brought to the licensee's attention.
The
licensee indicated that pre-job briefings were routinely performed
as required, and that the above instances represented only a failure
to appropriately document those briefings.
The licensee also
indicated that substantiating records (i.e, mock-up training*
records, radiography check lists, etc) could be provided for the
majority of the RWPs listed above to demonstrate that workers
received pre-job briefings concerning radiological conditions.
The
inspector stated that although other written records might have been
available, the licensee could not produce documentation of pre-job
briefings as required by the procedure.
r--,
10
2.
Technical Specification 6.8, "Procedures and Programs," requires, in
part, that procedures be established, implemented, and maintained
which meet the requirements and recommendations of Regulatory Guide
1.33, 1978, Appendix "A.
11 Regulatory Guide 1.33, 1978, Appendix "A"
recommends that procedures for airborne radioactivity monitoring,
personnel monitoring, and airborne radiation monitor calibrations be
established.
The inspector noted that airborne radiation monitors,. specifically,
MPC-hour meters, were being used to monitor personnel exposure to
airborne radioactive material for the purpose of showing compliance
with regulatory requirements without established procedures for
their use and evaluation of their results. Calibrations of the
MPC-hour meters were also being performed without established
procedures.
The inspector noted that the MPC-hour meters were not used as the
sole monitoring device; general area air samplers were also used.
It was also noted that when documentation of personnel exposures as
required by 10 CFR 20.103 was necessary, the MPC-hour meter results
were used in lieu of the general area air samples.
Guidelines for the use of the MPC-hour meters were issued as a memo
on October 5, 1986, stating that the units were in the process of
being evaluated.
The inspector informed the licensee that field
evaluations are appropriate, but i,;1 consideration of the time they
have been in use (one year) and their routine use for showing
compliance with regulations, formal procedures for their use and
calibration are required.
Lack of such formal procedures for
equipment in routine use constitutes a violation of Technical
Specification 6.8 (50-272/87-30-03, 50-311/87-31-02).
Within the scope of this review, the following additional matters
were identified which should be addressed by the licensee:
0
0
Inspector review of RWP's found that all RWP's that required
continuous coverage did not always specify that pre-job briefings
were required as specified in procedure RP-202.
Health Physics
management down to first line supervisors were not aware of this
requirement.
The licensee stated that this was not their original
intention and that the procedure would be revised to reflect current
administrative practices.
Current use of the MPC-hour meters is in accordance with
guidelines as set forth in a memo dated October 5, 1986; from
the Radiation Protection/Chemistry Manager.
Review of this
guideline indicated that all results greater than 2 MPC-hours
should have an isotopic analysis performed.
In discussions
with technicians in the counting facility, none of the results
in excess of 2 MPC-hours were isotopically analyzed and they
were not aware of any such requirement.
11
Prior to use, the guideline recommends checking the flow rate to
verify the 2 lpm calibration only if it is equipped with a
flowmeter.
No other.checks are required either prior to,
during, or after use except for verification of a full battery
charge.
Review of the vendor's manual for the model P2500A's
revealed that the Unit is equipped with a flow control assembly
that attempts to maintain the flow rate as set during calibration.
In addition, a flow control light (LED) is present to indicate that
a flow control problem has occurred.
The vendor recommends that
this LED should be checked before turning off the pump since a
problem in flow control invalidates the sample.
This matter was
discussed with the licensee who stated they were not aware of this
feature in the unit and the necessity to check its functioning prior
to determining flow.
The overall technical adequacy of the use of the MPC-hours meters
for showing compliance with Federal Regulations is left unresolved
pending development of formal documentation and will be reviewed in
a subsequent inspection.
(Item Nos. 50-272/87-30-04 and
50-311/87-31-03).
7.0 Exit meeting
The inspector met with licensee management personnel on October 23, 1987,
at the conclusion of this inspection to discuss the results.
At no time
did the inspector provide written material to the lic1msee.