ML18093B304
| ML18093B304 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/16/1988 |
| From: | Nimitz R, Oconnell P, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18093B302 | List: |
| References | |
| 50-272-88-18, 50-311-88-18, NUDOCS 8811290040 | |
| Download: ML18093B304 (20) | |
See also: IR 05000272/1988018
Text
- Report Nos.
Docket Nos.
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
50-212700-10
50-311_88-18
50-272
50-311
License Nos.
Priority
Category _ -~c __
c
Licensee:
Public Service Electric and Gas Company
P. 0. Box 236
Hancocks Bridge, New Jersey 08038
Facility Name:
Salem Nuclear Generating Station, Units 1 and.2
Inspection At:
Hancocks Bridge, New Jersey
Inspection ~onducted:
September 26-30 and October 5-6, 1988
Inspectors:
R~ L.
p. v.
Nimitz, Senioraation Specialist
0' Conne g, LR~ i'ffith~1 i si
Approved by:
- ~if~
M. M:arlaY, cle;aClles Radiation
Protection Section
Inspection Summary:
date
wl LBl~e
date
Areas Inspected:
Routine, unannounced Radiological Controls Inspection of the
fol lowing: radiological controls organization and staffing; personnel
qualifications and training; corrective action system and performance
monitoring; ALARA; external and internal exposure controls; hot particle
exposure control; industrial safety and worker concerns.
Results:
One violation was identified ( Failure to implement radiation
protection program procedures as required by Technical Specification 6.11 ).
A number of weaknesses were also identified in the areas of supervisory and
management oversight of work activities, industrial safety and contamination
control .
. :38112'~(>(>40 :3:3112:2
ADOCK 05000272
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DETAILS
I.O Individuals Contacted
I.I Public Service Electric and Gas Company
- G.
- D.
- J.
- J.
- L.
- J.
- D.
K.
M.
T.
J.
s.
Raggio, Station Licensing Engineer
Tauber, Station Quality Control Supervisor
Molner, Radiation Protection, Hope Creek
Wray, Radiation Protection Engineer, Salem
Miller, General Manager, Salem Operations
Trejo, RP/Chem Manager, Salem Operations
Mohler, RP/Chem Supervisor
O'Hare, RP Supervisor
Gray, Licensing Engineer
Cellmer, Radiation Protection Engineer, Hope Creek
Clancy, RP/Chem Manager, Hope Creek
LaBruna, Vice-President Nuclear
I.2 NRC Personnel
- R. Nimitz, Senior Radiation Specialist
- P. O'Connell, Radiation Specialist
- M. *shanbaky, Chief, Facilities Radiation Protection Section
- K. Gibson, Resident Inspector, Salem
- R. Borchard, Senior Resident Inspector, Salem
I.3 State of New Jersey
D~ White, Department of Environmental Protection, State of New Jersey
K. Tosch, Department of Environmental Protection, State of New Jersey
Other licensee and contractor personnel were also contacted or interviewed
during the course of this inspection.
- Denotes those personnel attending the exit meeting on October 6,
I988.
2.0 Purpose and Scope of Inspection
'
This inspection was a routine, unannounced Radiological Controls
Inspection. The followin~ areas were reviewed:*
- organization and staffing;
-
trainin~ and qualifications;
- corrective action system;
- external exposure controls;
- hot particle exposure control;
internal exposure controls;
- ALARA;
industrial safety concerns;
- worker concerns.
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3.0
3 .1
3.2
3
Licensee Actions on Previous Findings
(Closed) Violation (50-272/87-30-03; 50-311/87-31-02): Airborne radiation
monitors, specifically MPC-hour meters, were being used to monitor
personnel exposure to airborne radioactive material without established
procedures for their use and evaluation.of their results. Calibrations of
the MPC-hour meters were also being performed without established
procedures.
On February 24,1988 the licensee issued procedure M12-ICI306, "Calibration
of Lapel Air Samplers", and on July 14, 1988 issued procedure RP 506 "Use
of the MPC-Hour Meter", to address calibration and use of the meters
respectively. Appropriate personnel were trained on the new procedures. A
review of the training program for permanent staff radiation protection
technicians (RPTs) showed that the training program had not been updated so
that any new permanent staff RPTs would be trained in the use of this
procedure. The licensee stated that this was an oversight and the training
program would be updated prior to hiring any*new permanent RPTs.
This item
is closed.
(Closed) Unresolved Item (50-272/87-30:04; 50-311/87-31-03): The overall
adequacy of the MPC-hour meters for .sh.owing compliance with regulatory
requirements was left unresolved pending development of formal
documentation.*
.
.
.
In addition to continuous air sampling of the general plant environment,
the licensee utilizes low volume (2-4 cfm) or high volume (18-35 cfm) air
samplers for specific surveillance of work activities which have
historically presented a potential of personnel exposure to elevated
airborne radioactivity or in situations where airborne hazards are unknown.
The licensee emphasized that the function of the MPC-hour meter is to serve
as a backup air sampler and to provide a method to quickly estimate
MPC-hour exposures. The licensee stated that the MPC-hour meter is not used
for the purpose of showing compliance with regulatory requirements for
determining airborne radioactivity concentrations. Inspector observation of
the air sampling of work activities indicated that this was correct. This
item is closed.*
3.3 (Closed) Unresolved Item (50-272/87-30-05): The final determination as to
whether a fuel fragment contamination incident which occurred inside the
Unit 1 containment on October 10,1987 constituted an exposure in excess of
regulatory limits remained unresolved pending licensee completion .of the
final dose assessment.
.
The licensee conducted an appropriate time and motion study and thereby.
determined that the dose was distributed over a 16 centimeter square area
of skin of the whole body.
Calculations based on distributing the dose to
the 16 centimeter square area of skin exposed to the fuel fragment
indicated that the regulatory limit of 7.5 rem/quarter to the skin of the
whole body was not exceeded. This item is closed.
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3.4
3.5
4
(Closed) Violation (50-272/87-30-01): Failure of the licensee to maintain
the Unit 1 #14 bioshield door in a locked condition on October 8, 1987. The
inspector reviewed the corrective actions which the licensee committed to
implement in letter number NLR-N88002 dated January 8, 1988. The inspector
determined that the corrective actions had been completed. This item is
closed.
(Closed) Violation (50-272/87-30-02, 50-311/87-31-01); Failure to follow
T.S. 6.11 required procedures. The inspector verified that the corrective
actions specified in licensee's letter NLR-N88002 dated January 8, 1988
were completed. This item is closed.
4.0 Organization and Staffing
The inspector revi~wed the organization and staffing of the onsite
Radiation Protection Group with respect to criteria contained in the
following:
- Technical Specification 6.2, Organizat1on;
- Regulatory Guide 8.8, Information Relevant to Ensurin~ That
Occupational* Radiation Exposure At Nuclear Power Stations Will
As Is Reasonably Achievable;
- Salem Unit 2 Outage Information Manual; -
-
-
~r.ocedure ODP-ZZ-001? Outage Implementation Procedure.
Be As Low
Evaluation of licensee performance in this area was based on discussions
with cognizant personnel, review of ongoing work and review of _
documentation.
Within the scope of this review, no violations were identified.
Administrative controls and definition of personnel responsibilities were
up~raded as compared to the Unit 1 outage.
The following licensee
initiatives were noted:
The licensee established and implemented a defined Outage Organization
consistent with the newly developed procedure ODP-ZZ-001. The
procedure, developed, in-part, to address weaknesses encountered
during the previous outage at Unit 1, covered Management Organization,
responsibilities, schedule and update requirements, meetings, goals
and requirements.
The outage organization and responsibilities were included.in and
distributed as an Outage Information Manual. A defined organization
chart was included in the manual.
The licensee used key department heads as Outage Shift Managers.
Supervisors from various departments were used as Containment
Coordinators. These individuals were used to manage the execution of
shift functions in support of the outage and coordinate activities in
containment respectively .
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---~~-~~~-~-~---~-~*~-~*~-~-~--~--~--~-~-~--~---~-~--~-~~-~-~-~-~-~-~-~--~--~-~~~~~
5
The licensee performed a person-loading study to determine the numbers
of radiological controls contractor personnel to be hired to augment
the permanent staff. The study reviewed planned work activities
versus staffing needed.
Corporate radiological controls personnel and radiological controls
personnel from the Hope Creek Station were used to provide assistance
during the outage.
Within the scope of this review, the following areas were discussed with
the licensee as areas for improvement:
As indicated above, the licensee assigned key department managers as
Outa~e Shift Managers. This included the Radiological Controls and
Chemistry (RCC) Manager.
The RCC Manager was assigned a shift
rotation of 2 weeks on and 2 weeks off as Shift Outage Manager. During
his "off time" he returned to his principal task as RCC Manager.
The inspe~tor noted that no clearly described delegation of the
RCC Manager's responsibilities to other personnel had been made. The
Outage Manual and associated procedures did not indicate how the
Outage Manager's responsibilities were to be delegated in order to
maintain continuity and effective oversight of radiological and
chemistry activities *at Unit 1 and 2.
Licensee mana*gement indicated
this was the first time that key managers had been used in the role of
Shift Outage Managers and that its effectiveness would be critically
reviewed.
As a result of numerous observations during the inspection, as
discussed in this report, the inspector concluded that the deleg~tion
and assignment of responsibilities for Radiation Protection Supervisory
oversight of outage activities was in need of improvement. The
licensee concurred in this assessment and issued additional guidance
to improve supervisory oversight of outage activities. The licensee
also assigned additional supervisors to oversee critical outage work.
The licensee was provided about 753 of the contractor radiological
controls personnel requested. Steps to ensure meeting requested
resources should be considered.
.-
5.0 Training and Qualifications
The inspectof reviewed the qualificatjon and training of members of the
Radiological Controls Organization with respect to criteria contained in
Technical Specification 6.3, Facility Staff Qualification. Licensee
performance in this area was evaluated by review of resumes and training
records and disGussions with cognizant personnel .
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6
The inspector's review in this area focused on the qualification and
training of contractor radiological controls personnel hired to augment the
organization during the outage. The inspector also reviewed the adequacy
and effectiveness of the infield performance of these personnel.
Within the scope of this review, no violations were identified. Contractor
personnel appeared to have received adequate training and qualification.
6.0 Corrective Action System and Performance Monitoring
The inspector reviewed selected aspects of the licensee's corrective action
- and performance monitoring program.
Within the scope of this review the
following positive observations were made:
.The licensee assigned an individual to the position of Radiological
Assessor at the start of the outage. This individual was responsible
for reviewing ongoing work and radiological controls and notifying, as
appropriate, supervision and management of deficient conditions or
performance.
The licensee assigned an individual from the co*rporate Radiological
Controls group to track and monitor Radiological Occurrence
Reports(RORs).
An individual from the corporate Radtological Controls Group was
assigned to perform assessments of station radiological activities.
Within the scope of this review, the following areas for improvement were
identified:
.
Inspector review of Radiological Assessor findings since the start of
the outage indicated a number of recurrent problems (e.g. procedure
violations) .. Inspector observations during the inspection identified
similar concerns including procedure violations indicating weakness~s
in oversight and corrective action. The inspector concluded that
corrective action for identified concerns was deficient in that
multiple observations of similar concerns were identified previously
by licensee assessors and no apparent corrective action for these
concerns was apparent to the inspector.
Inspector review of completed RORs indicated that adequate immediate
corrective action for specific concerns appeared to be taken.
However,
it was not apparent that concerns we*re reviewed in a timely manner
from a generic basis in order to identify root causes of recurrent
problems.
The inspector performed a review of the circumstances and licensee
corrective actions associated with the improper entry of several personnel
into the Unit 2 Seal Table Room. The improper entry was identified by the
licensee and an ROR was subsequently issued. The following was noted:
.,
I
7
At approximately 11:00 p.m. on September 6, 1988 a work crew signed in on
RWP 789,"Trash and PC Removal andOecon in HRAs and HCAs", dated September
2, 1988.
The RWP states that entry is not permitted into the Seal Table
Room. Administrative Procedure AP 24, Radiological Protection Pro~ram ,
requires in section 5.4 that radiation work permits be complied with. A
contractor RP supervisor improperly directed a licensee RP technician to
issue the crew the key to the Seal Table Room. The crew performed
approximately 30 minutes of work in the Seal Table Room with a contractor
RP technician providing coverage.
Approximately 2. hours after the key was returned the control point
supervisor realized that an unauthorized entry had been made into the Seal
Table Room.
A review of the radiation monitoring devices worn by the crew
(ALNORs) indicated that there was no unplanned exposure of individuals
(maximum dose recorded was 1 millirem), however this room has the potential
of havin~ extremely high dose rates and an unplanned entry could result in
a potential significant personnel exposure.
A fact finding meeting was held by licensee personnel on September 7, 1988.
Licensee review indicated the key had been improperly issued by the
radiation protection technician who thought a previous work crew,
authorized to work in the Seal Table Room, would again reenter the area. On_
October 6, 1988 disciplinary lette.rs were placed in the personnel files of
the work crew involved and the RP'sapervisor and RP technician who issued
the key.
As of October 6, 1988, about 30 days after the event, the licensee had not
yet briefed or retrained all appropriate staff in order to prevent a
recurrence. The inspector concluded that the corrective actions were not
adequate to prevent recurrence in that the licensee only counseled involved
individuals. Other individuals who may issue the key were not retrained in
proper key issuance.
In addition to this weakness in completeness of corrective action, the
inspector noted that High Radiation Area control at Salem has been a
recurrent problem as follows:
.
A.High Radiation Area door was found improperly controlled on October
8, 1987. (Reference Inspection Report 50:.272/87-30; 50-311/87-31).
A memo describing HRA control requirements and proper use of locked
doors was issued to all Department Managers from the Salem General
Manager. All personnel were to be briefed on the contents of this *
memo.
Specific licensee evaluations of this matter focused on the
adequacy of the key control program. The memorandum, dated October 12,
1987 stated in part " Proper use of locked doors used for hi~h
radiation area control is essential. A review of proper use is as
follows 1) In order to enter a locked high radiation area, an
individual must sign in on an RWP for the area to be entered ... "
A problem with High Radiation Area access control control was
also identified on March* 12, 1987. ( Reference NRC Inspection Report
50-272/87-07; 50-311/87-08). -
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- - ___ ,
8
The inspector concluded that the improper entry into the Seal Table Room,
identified by the licensee, could reasonably have been prevented by the
licensee's corrective actions for the previous violations. Also as
discussed above, the licensee's corrective actions were not comprehensive
in that all appropriate personnel were not counseled in proper HRA key
issuance .. Consequently the licensee does not meet the 5 criteria for
the NRC discretionary non-issuance of a violation delineated in 10 CFR Part
2.
This is an apparent violation of Technical Specification 6.11 which
requires radiation protection procedures to be implemented.
(50-272/88-18-01; 50-311/88-18-01)
It was noted that during plant operation the key to the Seal Table Room (a
Locked High Radiation Area) is left in a key trap inside containment. After
containment is opened the key is locked up at the control point. There are
no apparent procedures which address this key and its transfer to the
control point. The licensee committed to formalizing a procedure for
control of the key. This matter remains unresolved pending licensee
completion of corrective actions. (50-272/88-18-02; 50-311/88-18-02)
7.0 External Exposure Controls
The inspector reviewed the following elements of the licensee's external
exposure control program with respect to criteria contained in applicable*
procedures and 10 CFR 20 Standards for Protection Against Radiation.
.
.
posting, barricading, and access control (as necessary) of radiation
and high radiation areas;
implementation of the radiological controls specified in radiation
work permits (RWPs);
adequacy of radiological surveys.
Evaluation of licensee performance was based on discussions with personnel,
reviews of ongoing work activities and review of documentation.
Within the scope of this inspection one apparent violation was identified,
failure to follow radiation protection procedures as follows:
Technical Specification 6.11, "Radiation Protection Program," requires, in
part, that procedures for* personnel radiation protect1on shall be approved,
maintained and adhered to for all operations involving personnel radiation
exposure.
1.
Procedure RP 1103 "Radiological Control of Reactor Cavity and Spent
Fuel Pool Operatiohs" requires in section 7.2.5 that dose.rates are to
, be carefully monitored while equipment is being withdrawn.from the
pool .
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9
On September 26, 1988 at about 2:00 p.m. the inspector observed a
rolling tool being withdrawn from the Reactor Cavity Pool without the
dose rates being monitored. The workers were on the refueling bridge
of the 130' elevation of containment and were lifting the.rolling tool
with the overhead crane. After being inserted into the internals of.
the reactor vessel the rolling tool was lifted approximately 20 to 30
feet and then moved horizontally and repositioned elsewhere in the
pool.
The portion of the rolling tool which was lifted out of the water
consisted of a round metal pole with a cable attached. The safety
concern was that even with the rolling tool being washed down with
demineralized water it was possible for hot particles or other highly
activated chips to become caught in the void spaces between the
ro 11 i ng tool and the cable.* *
Radiation Protection (RP) personnel providing coverage of the job
evolution stated that their interpretation was that the lifting and
repositioning of an object within the pool was not considered removing
or withdrawing an object from the pool.
RP management confirmed that.
the RP personnel providin~ job coverage misinterpreted the procedure
and reinstructed the applicable personnel that any lifting of an
object ~n: the pool constitutes removal or withdrawal* from the pool .
2.
Admin1strative Procedure AP 24, Radiological Protection Program,
requires in section 5.4 that each individual shall comply with the
requirements established in Radiation Work Permits.
RWP 724, "Install
Wear Reduction Inserts/New Flux Thimbles", dated September 20,1988
requires, in part, that plastics and faceshields be worn while
handling equipment re~oved from the pool.
On September 26, 1988 at about 2:00 p.m. the inspector observed two
workers, working under RWP 724 and not wearing the required plastics
and faceshields, remove a rolling tool from the Reactor Cavity Pool.
3.
Radiation Protection Procedure 808, Discrete Radioactive Particle
Exposure and Contamination Control, requires, in part, that as a
minimum loose surface contamination surveys are to be performed, once
each shift.(8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) in designated hot particle zones and twice per
shift (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) in designated hot particle buffer zones.
A review of survey documentation and the HP log book for the 130'
elevation of containment revealed that the loose surface contamination
surveys in the buffer zone were not performed with the required
frequencies for the time period (approximately) 10 am September 26 to
10 am September 27,
1~88.
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10
The surveys in the buffer zone were performed once per shift. On the
afternoon of September 27, 1988 cognizant RP personnel were not aware
of the frequency requirements for hot particle zone and hot particle
buffer zone surveys. Inspector discussions with contractor technicians
indicated that Senior licensee radiation protection technicians had
provided incorrect survey frequencies to the technicians.
4.
Procedure RP 808 also requires, in part, that upon exiting a hot
particle zone personnel are to surveyed by a RP technician using an
R0-2.
On the afternoon of September 27, 1988 at about 5:00 p.m., the
inspector observed two individuals exit the bioshield area without the
required hot particle survey. The two individuals involved were part
of the contractor RP technician staff. When questioned, the
individuals stated that they did not know of the requirement to survey
prior to exiting because the technicians were not informed that the
bioshield area was declared a hot particle area.
The inspector noted
the inner bioshield area had been declared a hot particle area at
mi dn_i ght of the previous day.
The above 4 examples of failure to follow procedures is an apparent
violation of Technical Specification 6.11. (50-272/88-18-01;
50-311/88-18-01)
.
.
Other concerns noted by the inspector and brought to the attention of the
licensee include:
Junior RP technicians were apparently being used to monitor job
activities outside the bioshield. Inspector discussions with a
junior technician indicated that he was allowed to provide coverage on
low dose jobs, but could not specify exactly which jobs he was allowed
to cover. The licensee does not have a clear definition of the job
tasks which junior RP tec_hnicians are allowed to perform. The licensee
stated that they would delineate in writing the exact duties,
responsibilities and authorized job tasks for the junior RP
technicians.
- The 1 i censee does not verify that an ind i vi dua 1 is qua 1 if i ed in the
use of a radiation monitorin~ meter prior to issuing the meter to the
individual. The licensee indicated this matter would be reviewed.
The inspector found a radiation monitoring meter (R0-2) being used
inside the bioshield which had apparently not been response checked in
6 days. Licensee procedures recommend daily response checks. Personnel
had apparently been using this meter without performing the
prescribed, recommended response checks. This ind.icated the apparent
need for improved instrument control. The licensee stated that they
would review the fssue.
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',
.... :
- -
11
RWP 645 requires, in part, that a double set of protective coveralls
(PC's) are to be worn into the bioshield area of containment.
On September 27, 1988 while inside the bioshield the inspector
observed several workers carrying their second pair of PC's into the
bioshield area. The previous night the licensee had posted the area *
inside the bioshield as a hot particle zone. The RP technician
controlling access to the bioshield agreed that carrying the second
set of PC's into a hot particle zone was not a good radiological
control practice and was contrary to the RWP. The inspector also
observed other workers inside the bioshield wearing a single set of
PC's. These personnel showed the inspector a copy of their RWP which
did not require double PC's even though they were working inside a hot
particle zone. The licensee stated that they had not updated all of the
RWPs since establishing the hot particle zone (approximately 16
hours}. The inspector concluded these discussions and findings were
indicative of weak communications between supervisors and personnel in
the field.
Inspector discussions with licensee personnel subsequent to reactor
fuel off-loading and prior to Reactor Cavity drain down indicated the
licensee would complete the the final cavity drain down using a 55 *
gallon drum type filter set~up located under the Fuel Transfer Tube in
the Outer Annulus Area at the 20'elevation of Conta.inment.
No
procedures were inplace to cover filter setup, system valve
manipulation, including plant* valves, or system disassembly.
The
inspector informed licensee personnel that procedures for this
operation appear to be required as specified in Technical
Specification 6.8 and Re~ulatory Guide 1.33.
The licensee
subsequently revised dra1ndown procedures to address this matter prior
to final draindown.
Subsequent licensee radiation surveys of sections of the system after
draindown was complete indicated contact radiation exposure dose rates
of up to 800 R /hr. The area was barricaded and a flashing red light
was placed at the filter. The inspector noted that Technical
Specification 6.13 states that a flashing red light and barricade may
be used to delineate a High Radiation Area inside a large area
provided no reasonable enclosure could be constructed around the area.
The inspector's initial review indicated that an enclosure around the
filter .could reasonably be constructed. The inspector informed
licensee personnel that this matter was unresolved pending further
inspector review and evaluation. (50-272/88-18-03; 50-311/88-18-03).
The inspector requested licensee personnel to review other areas which
may be subject to this Technical Specification. The licensee indicated
this would be done.
-- ------,---.--:----- .... =--;----...... -----:------~--- -- -- --- ----
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8.0 Hot Particle Exposures
8.1 General Experience
12
During the course of the inspection the inspector reviewed licensee hot
particle exposure frequencies and evaluations. The following was noted:
As of October 3,1988 and since the start of the outage (August 31,
1988) the licensee has issued 402 Radiological Occurrence Reports
(RORs). The majority of these were low level personnel skin
contaminations.
Since the start of the outage up to October 5, 1988, 46 hot particle
contamination incidents were identified. Dose assignments for the
contamin~tions, for which evaluations were complete, indicated that
exposures, principally to the skin, ranged from minimal to 6.7 rem.
Several evaluations were ongoing at the time of the inspection.
Inspector review of licensee methodology for dose assessment
indic~ted the methodology was innovative and appeared to provide an
accurate estimate of personnel exposure sustained from a hot particle
contamination event ..
The licensee's corporate radiological controls group performed an
evaluation of the circumstances and dose assessment methodology for
the hot particle exposures. A list of *r~commendations were generated
and are being reviewed to improve controls and exposure determination
methodology.
Inspector review of the licensee's implementation of the hot par.ticle
exposure control program identified a number of weaknesses which were
discussed with licensee representatives. These were as follows:
The hot particle survey program was not implemented in some instances.
Thi~ is discussed above.
Personnel wearing* cloth protective clothing ( 2 pair of coveralls)
were observed reclining on the floor in hot particle areas. This was
considered a poor practice. Although Radiation Protection Supervision
were ~resent, the poor practice was not corrected. The poor practice
was discussed with supervision present who subsequently corrected the
matter.
The licensee was implementing a hot particle control zone and hot
particle buffer zone only after personnel were contaminated with hot
particles . This was a questionable practice considering.several areas
of the Radiological Control Area were known or suspected hot particle
areas. The licensee indicated this matter would be reviewed .
--::*--------*--*----*~-*---~*--*--
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13
8.2 High Reading Extremity TLD
An individual, involved in surveying the No. 22 steam generator on
September 28, 1988 was identified as having a TLD badge ( right extremity
wrist badge ) which indicated about 107 rads total exposur~ to the
extremity based on reading of the individual's skin equivalent (shallow
dose ) TLD chip. Although not considered deep dose, the gamma dose to the
extremity, based on reading the deep dose equivalent
The wrist pocket dosimeter indicated 800 millirem.
The right fingertip
TLD strip indicated 767 millirem. Because of the uniformity of gamma
- penetrating exposure the licensee believes the exposure to the chip was
caused by a hot particle. Other dosimetry located on the individual did not
indicate any anomalous readings. The individual was prohibited from
radiation work pending outcome of the dose assessment.
The inspector reviewed licensee preliminary exposure evaluations. These .
included test irradiations of the TLD badge to determine its response and
linearity and test irradiations of a TLD badge with a hot particle found
in the individual's work location. The licensee's preliminary evaluations
were considered of good quality. The inspector concurred that the pattern
of the irradiation of the TLD badge and other dosimetry tended to support
licensee preliminary conclusions that the exposure was due to a hot
particle on or _very close to the TLD badge.
Since the individual was
wearing multiply layers of protective clothing, the skin appears to have
been shielded from *a significant portion of the exposure measured by the
badge which was located on the outside of the clothing.
Preliminary licensee dose estimates based on a time and motion study and
various skin shielding thicknesses indicate a maximum exposure to one
square centimeter of the skin *of the lower forearm of about 55 rads. The
licensee indicated this exposure evaluation will be reviewed and finalized.
The inspector indicated the extremity exposure was an unresolved matter
pending review of final licensee dose estimates.
(50-272/88-18-04; 50-311/88-18-04)
9.0 Internal Exposure Controls
The inspector reviewed selected aspects of the internal exposure controls
program. The review was with respect to criteria contained in applicable
licensee procedures and regulatory requirements.
The followiflg matters
were reviewed:
- posting.of airborne radioactivity areas;
- adequacy of airborne radioactivity sampling and analysis to plan for and
- support ongoing_ work;
-
timeliness of analysis of airborne radioactivity samples including
supervisory review of sample results;
installation, use and periodic operability verification of engineering
controls to minimize airborne ~adioactivity;
- bioassays and personnel airborne radioactivity intakes .
-
- -v**---*--**-**---~---. *.......-- -*-**** ****** -- ***-.**---- -*-*- *--*-*- -** .. ** -
- ***-** **-;***- * *** ... ** **-- -.-* -- ,__ *- ---*-
....
14
Evaluation of licensee performance in this area was based on review of
documentation, discussions with personnel and independent observation of
ongoing work including personnel entry into steam generators, repair of
damaged fuel transfer mechanism and work on reactor loops.
Within the scope of this review, one apparent example of failure to follow
procedures, an apparent violation,
was identified as follows:
The inspector observed ongoing work on Reactor Loop 23 on September
28, 1988 at about 4:30 p.m.
Radiation Work P~rmit No. 645 covering
the work (replacement of loop temperature detectors ) required that a
personnel air sampler (called an MPC-hour meter) be worn by a member
of the work party. Inspector observation of the two individuals
working on the detector nozzle indicated neither of the workers had an
MPC~hour meter.
The inspector noted that failure to adhere to the
work permit as required by Administrative Procedure AP 24,
Radiological Protection Program, section 5.4 is an apparent violation
of Technical Specification 6.11 which requires adherence to radiation
protection program procedures.(50-272/88-18-01; 50-311/88-18-01).
The inspector noted that a low volume air sampler was collecting a
sample in the area, however the sample it was collecting was not. *
representative of the breathing zone of the workers. A licensee
Radiation Protection Supervisor in the area indfcated the sampler had
apparently been moved by personnel.
Within the scope of this review the following additional concerns were
identified and discussed with licensee personnel:
Th~ lic~nsee's air sample procedure (~P 601 ) provided inadequate
guidance to ensure detection of unusual or unexpected levels of alpha
airborne radioactivity.
A HEPA ventilation system was taking suction on air in the reactor
cavity and blowing it into the vicinity of the radiation protection
technician desk on the 130' elevation of the Containment. The
magnehelic gauge, which is used to indicate proper operation of the
system was broken. Although the system was apparently checked for
proper operation prior to its setup, there were no procedures for
periodic verification of system operability.
An informal check sheet
for checking the devices had apparently not been implemented since the
system was continuing to operate with a broken gauge. The system was
replaced.
The licensee was ~nable to provide any data showing that smear checks
for alpha radioactivity were performed in the Reactor Cavity during
repair of the fuel transfer mechanism. This was considered not a good
practice, in that beta-gamma contamination in the work area measured
up to 400 millirad per hour and that it was known that some fuel was
damaged as evidenced by fuel fragments encountered in the cavity .
- -
--:-~---* --~-~:~~~--~----- ---*-*---. ***'7--- .. :-,-
- *--~---- --- ------
--- -** ----- -* ------------
- ---.,----*--~-=----:-- ----,----:-------.-.--------------* --------------------.-. --
15
During inspector review of airborne radioactivity surveys to support
fuel transfer mechanism repair, the inspector noted that a number of
the samples collected during work activity in the Reactor Cavity on
the fuel transfer mechanism indicated apparent high levels of alpha
airborne radioactivity. For example, air sample number 88-4780
collected on September 27, 1988 at about 1600 indicated about 100
times the 10 CFR 20 Appendix B value for unidentified radionuclides.*
A gamma spectroscopy analysis of the sample iDdicated only about 80%
of the Appendix B values for the radionuclides identified by the gamma
spectroscopy device.
Licensee radiological controls personnel
indicated the activity was due to naturally occurring radon and thoron
based on analysis of previous air samples whose activity indicated a
short half-life (about 42 minutes) when counted one hour later. This
sample (88-4780) was counted only once for alpha radioactivity.
The inspector requested that this sample be counted again to verify
that no long -lived alpha emitters were present. Licensee analysis of
this sample on September 30, 1988 at about 1400 indicated about 67
times the Appendix B value for unidentified radionuclides. The
inspector concluded that the licensee was unaware of the magnitude of
lon~-lived airborne alph~ emitters in the Reactor Cavity and had
relied on a study previously performed to discount the presence of
long-lived alpha emitters.
The inspector noted that licensee procedure RP 601*, Air Sampling, rev.
0 requires in section 7.1.3 that particulate alpha airborne
radioactivity samples be collected and analyzed as determined by RP
supervision. Also, 10 CFR 20.201 requires that evaluations of
radjological conditions be made to ensure that the requirements of
10 CFR 20 be adhered to. The inspector noted that personnel working in
the Reactor Cavity wore full face respirators which provided a
protection factor of 50. 10 CFR 20.103 c.l prohibits,making allowance
for respirators when the fraction of the 10CFR20 Appendix B airborne
radioactivity concentration. present exceeds the protection factor of
the respirator used.
The fraction of 10CFR20 Appendix B airborne radioactivity present
(about 67 times the Appendix B value) exceeded the protection factor
of the respirator. Allowance was not being made for use of the
respirators because of low levels of airborne beta gamma
radioactivity. The apparent improper use of the respirators was
attributed to apparent inadequate analysis and evaluation of air
samples. The licensee immediately placed the individuals in
respirators with a higher protection fac~or. The inspector indicated
that the adequacy of evaluations of alpha airborne radioactivity
in the Reactor Cavity was an unresolved item pending further inspector
review.(50-272/88-18-05; 50-311/88-18-05)
-* *-- .. ----.-.*--* ***-***.----- *-
. -----. - --* **-- - ---* *- - ---*- ---
- --.----. ..--**----**,.*-*
-~*-***---.- --*-------------*---------*.-----*----*---.-------- - -* -* . ---------------~---
' .
16
10.0 ALARA
The inspector reviewed selected aspects of the licensee's ALARA Program.
Emphasis was placed on licensee performance during the past outage and
planning and goal setting for the upcoming outage. The review was with
respect to criteria contained in the following:
Regulatory Guide 8.8, Information Relevant to Ensuring that
Occupational Exposure at Nuclear Power Stations Will Be As Low As Is
Reasonably Achievable; *
Regulatory Guide 8.10, Operating Philosophy for Maintaining
Occupational Radiation As Low As is Reasonably Achievable;
NUREG/CR-3254, Licensee Programs for Maintaining Occupational Exposure
to Radiation As Low As Is Reasonably Achievable;
NUREG/CR-4254, Occupational Dose Reduction and ALARA at Nuclear Power
Stations; Study on High-Dose Jobs, Radwaste Handling and ALARA
Incentives.
Within the scope of this review no violations were identified. The
following matters were discussed with licensee personnel:
Inspector observation of ongoing .work indicated good overall ALARA
controls to be in place for in-field work. Licensee planning and
preparation for major work' tasks appeared good. Exposure accrued was
within goals established by the licensee. Several isolated instances*
where the inspector observed workers waiting in non-low dose rate
areas were observed. These were of concern because Radiation
Protection Supervision in the area did not correct this situation.
Licensee management was informed and directed personnel to be more
aware of this poor work practice.
11.0 Industrial Safety
During initial tours of the Reactor Containment the inspector noted several
matters of an Industrial Safety concern as follows:
The inspector noted on September 26, 1988 that personnel were working
in close proximity to the Reactor Cavity. The 40 -50 foot deep cavity
did not have any railing around it. The railing had apparently been
removed.
The inspector noted that personnel walking along the cavity
did not have safety belts on. The belts and safety lines were hanging
along side the cavity. The inspector informed the refueling floor
Radiation Protection Supervisor and the Containment Coordinator of
this con~ern. Personnel were directed to wear safety belts .
. . **** **- **-**----*--*-* ****--*.-** ----**--,----~***-*.-- *-:-**o*.*:;--. *-*.------~----*- --*-~-... --. -:------ -:......--- ........ *-**----------- **-**------***-~----
..
. "
17
The inspector left the area and returned a short time later. The
inspector observed the cavity area directly above the Fuel Transfer
mechanism not to have in place any railings or barricading to prevent
inadvertent falls into this narrow end of the Reactor Cavity. The
insp~ctor jmmediately informed the ~bove individuals of this matter
who initiated action to barricade this area.
During the inspection, the inspector noted a number of instances where
individuals experienced ~pparent heat exhaustion. This included the
Reactor Cavity and the steam generator areas. The personnel were in
full protective clothing including plastic suits and full face
respirators. The inspector questioned licensee personnel as to what
measures were being taken to prevent heat exhaustion ( e.g. use of
supplied breathing air or ice vests ). Licensee personnel indicated
these were considered but not used. ~allowing id_entification of alpha
airborne radioactivity (.discussed above) in the Reactor Cavity,
personnel were placed in supplied air fu11 face respirators. This
apparently alleviated the problem in this area. The licensee indicated
this would be reviewed.
- **
The inspector met with the Plant Manager and Vice President *Nuclear
Operations on September 27,1988.
The inspector expressed concern regarding
the industrial safety matters i~entified.
.
On October 5,1988, the inspector toured the area around the Reactor Cavity
(filled). The inspector noted that although the cavity was full of water,
there were no life rings readily visible. Personnel were observed walking
.around the cavity. The inspector discussed this with the Senior Reactor
Operator overseeing refueling who subsequently unpacked a life-ring.and
rope contained in a plastic bag to make it readily available for use.
Because of the above observations and the subsequent incident on October 11,
1988 in which a worker fell into the partially drained Reactor Cavity, the
Director, Division of Radiation Safety and Safeguards, NRC Region I,
contacted the Salem Station Plant Manager to request that the area of
Industrial Safety be reviewed in the aggregate in order to identify and
correct any potential safety concerns identified during the revie~. The
Station Manager was also requested to review the effectiveness of the
station's roving Safety Inspectors.
The above safety concerns were referred to the Occupational Safety and
Health Administration (OSHA) in telephone conversations on October 4 and .
October 11, 1988. Representatives of OSHA subsequently performed an onsite
review of the matters referred to them.
. '
.------------. , ... -__..,..." .. -------------..----------.,..---:~-----~;------:-***-----..,- -**---*--*----------**-,.,....,- .. -----:--*--,-- ... ----**--** --------------~------------------------------------
I'
12.
Worker Concerns
12.1 General
18
During the course of the inspection several worker concerns were brought to
the-attention of the inspector. The concerns and associated findings are
discussed below.
12.2 Individual A ( RI-A-0097 )
Individual A met with the inspector and the NRC resident_ inspector on
Sept~mber 30, 1988. The individual's concerns involved some contractual
matters and some apparent harassment matters. The inspector recommended
that the individual meet with licensee Radiation Protection Management to
discuss his concerns. The individual agreed to meet with licensee personnel
.and discuss his specific concerns. The concerns relayed to the inspector
were as follows:
Concern 1
The individual was directed to perform decontamination work in his work
area. The individual stated such work is not in his job description and
that he w~s not required to perform .it. *
.
Inspector Finding *
The inspector informed the individual that the particular matters contained
in his job description were the responsibility of his employer and the
.licensee and that this was not within the purview of the NRC unless the
individual was performing safety significant tasks that he was not
qualified to perform. The individual agreed to discuss this with licensee
Radiation Protection management. The inspector did not identify any safety
significance with this matter. The individual appeared to be qualified to
perform this task. This concern is considered closed.
Concern 2
The individual was required to stay on the job in containment for long
periods of time creating the potential for fatigu~. Also there was a lot of
work going on resulting in the potential for a job not to receive adequate
radiological controls oversight.
Inspector Finding
The inspector reviewed the work history, including overtime records for all
contractor technicians for the period of three weeks preceding the
inspection. Work history and overtime was within NRC and licensee
procedural guidelines.
.....---.-:-... :*:-.:* ----*-_-. -----*------* -*** -***--*---- --- *'**-**-.... --., . ---*-- -*--* --- _,.. ____ --- --- - .--*- *****--*-***--.- --- - -- ------------------* - ------ -- .. *****- **- --..-.---.-------.---*""T--
..
/
19
The individual stated he had stop work authority and would stop a job if
conditions warranted. Because some contractors had resigned to go to other
stations and the licensee did not receive his requested complement of
contractor technicians, the frequency of breaks was reduced and some
schedule changes were imposed on the remaining contractor technicians.
Although this created some morale problems, the inspector did not identify
any apparent situation where radiological safety was jeopardized. This
concern.is closed.
.
Concern 3
The individual was harassed on the job by workers when h~ was trying to do
his job.
Inspector Finding
The inspector recommended that the individual meet with licensee personnel
to discuss this concern. The individual stated that this was acceptable.
The inspector indicated that if the worker was not satisfied with the
licensee's response to his concern he $hould re-contact the NRC. It was the
individual's desire to terminate employment at Salem. The inspector
informed the individual that any apparent concerns in the area of
discrimination should be brought to the attention*of the Department of
Labor wi th"i n* 30 days of the concern.
.
The individual met with licensee Radiation Protection Management on
September 30, 1988. Licensee personnel subsequently met with contractor
management and personnel identified as responsible on September 30 and
October 1, 1988. Based on discussions with the. individual's co-workers and
with* members of the work party, the licensee was unable to clearly identify
that the specific apparent incidents of harassment or any other incidents
of harassment Qf other radiological controls personnel had actually
occurred.
However, the licensee counseled the contractor mana~ement and
specific workers that any harassment or intimidation of radiation
protection personnel would not be tolerated. The licensee concluded that
harassment was not a common problem and that this incident, had it
occurred, was isolated. The licensee committed to document his evaluation
for subsequent NRC review.
The inspector did not notice any incidents of
harassment or intimidation of radiation protection personnel during
numerous tours of the radiological controlled area and discussions with
personnel. This concern is closed.
.
12.3 Individual B
Con*cern
On October 6, 1988 Individual B .informed the inspect-Or that because of a
high reading TLD badge identified on or about September 29, the individual
was prohibited from si~ning in and working in the controlled area. However
the individual was assigned to frisk out material at the step-off pad
inside the controlled area at the Main Control Point.
~--------*'" . -----*--** ------*-~------.. -* --
- ------------~------ -- -----*-**- *------ -- -----.. -----
-~----- _____________ ..,.._ --
.. -*-
-------*---------------------.,----------------- -----~----
'
.--
.
\\
20
Inspector Finding
The inspector requested that this individual discuss his concern with
licensee Radiation Protection Management since he had been directed to
perform the work by a supervisor. The individual agreed and met with
licensee Radiation Protection Management on October 6, 1988.
Licensee
personnel indicated a review would be performed and the results would be
available for subsequent NRC review.
Preliminary inspector review indicated the individual worked on 4 separate
occasions on October 4, 1988 just inside the Radiological Controlled Area
(RCA) boundary at the Main Access Control Point. This area does not exhibit
any significant dose rates nor is there a significant possibility of an
individual becoming contaminated. The inspector did no4e however that
Administrative Procedure AP 24 requires that personnel shall be denied
access to the RCA unless he is on a valid RWP. The individual was not on a
valid RWP.
Supervision apparently authorized the individual to perform
frisking activities. This matter remains unresolved pending further
inspector review.(50-272/88-18-06; 50-311/88-18-06)
13.0 Exit Meeting
~he inspectors met with licensee representatives denoted in section 1 of
this report on September 30 and October 6, 1988.
The inspector summarized
the purpose, scope and findings*of the inspection.
No written material was
provided to the licensee.
- -- **-.---..-.-*__,,..--.* .. **-----,.-----.--------~**-: *--.... -*-- ------~-------- ---- --- . ---- __ , _____ ------.--
- ------~---* --.-*"""'!"'"";"~----- ---:*--=------*-"<""*--~--- --------------------~-----*--*-