ML18095A291
| ML18095A291 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/06/1990 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A289 | List: |
| References | |
| 50-272-90-14, 50-311-90-14, NUDOCS 9006200170 | |
| Download: ML18095A291 (7) | |
See also: IR 05000272/1990014
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-272/90-14
50-311/90-14
Docket Nos.
50-272
50-311
License Nos.
Licensee:
Public Service Electric and Gas Company
P.O. Box 236
Hancocks Bridge, New Jersey 08038
Facility Name:
Salem Nuclear Generating Station, Units 1 and 2
Inspection At:
Hancock~ Bridge, New Jersey
Inspection Conducted:
May 1-4, 1990
Inspectors:
Approved by:
R. L. Nimitz, Senior Radiation Specialist
W. Pasciak, Chief, Facilities Radiation
Protection Section
c, - e:, - qo
date
Inspection Summary:
Inspection conducte~ on May 1-4, 1990 (NRC C6mbined
Inspection Report No. 50-272/90-14; 50-311/90-14).
Areas Inspected:
Routine, unannounced Radiological Controls Inspection of the
following:
radiological controls -organization and staffing; personnel
qualifications and training; corrective action systems and performance
monitoring; ALARA; and external and internal exposure controls.
Results:
One violation was identified.
(Failure to follow radiation
protection procedures - Details Section 7).
~006200170 900611
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05000,;,~72
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DETAILS
1.0 Individuals Contacted
1.1
Public Service Electric and Gas Company
- L. Miller, General Manager, Salem Operations
- J. Wray, Radiation Protection Engineer, Salem
- D. Mohler, Manager, RP/Chem, Salem
_
- T. Cellmer, Radiation Protection Engineer, Hope Creek
1.2
NRC Personnel
- T. Johnson, Senior Resident Inspector
- Denotes those personnel attending the exit meeting on May 4, 1990.
The inspector also contacted other licensee personnel.
2.0 Purpose and Scope of Inspection
3.0
This inspection was a ~outine, unannounced Radiological Controls -
Inspection during the Unit 1 refueling outage.
The following areas were
reviewed:
organization and staffing;
training and qualifications;
corrective action system;
external and internal exposure controls;
A LARA.
Organization and Staffing
The inspector reviewed the organization and staffing of the onsite
Radiation Protection Group with respect to criteria contained in the
following:
Technical Specification 6.2, Organization;
Regulatory Guide 8.8, Information Relevant to Ensuring that
Occupational Radiation E~posure at Nuclear Power Stations will be As
Low As Is Reasonably Achievable.
Evaluation of licensee performance in this area was based on discussions
with cognizant personnel, review of on-going work and review of
documentation.
Within the scope of the review, no violations were identified.
The
following positive observations were made by the inspector:
The licensee issued a Unit 2 Fifth Refueling Outage Organization
description on March 20, 1990.
The licensee identified each
position, its reporting chain and responsibility.
3
The licensee assigned dedicated crews and supervisors to oversee
major radiological significant work activities (e.g., steam generator
work activities).
Because of emergent work activities at Unit 1, the licensee
established a designated support group to assist in the oversight of
the Unit 1 activities.
4.0 Training and Qualifications
The inspector reviewed the qualification and training of members of the
Radiological Controls Organization with respect to criteria contained in
Technical Specification 6.3, Facility Staff Qualification.
The licensee's
performance in this area was evaluated by review of resumes and training
records and discussions with cognizant personnel.
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 performance of these personnel during
review of work activities.
Within the scope of this review, no violations were identified.
Contractor personnel appeared to have received adequate training and
qualification.
The inspector noted that the licensee provided special training for
personnel involved with steam generator work activities.
The licensee
sent personnel to a vendor facility to receive training regarding steam
generator repair activities.
5.0
The inspector reviewed selected aspects of the licensee 1 s ALARA Program.
The review was with respect to criteria contained in the following:
Regulatory Guide 8.8, Information Relevant to Ensuring that
Occupational Radiation Exposures at Nuclear Power Stations will be
As Low As Is Reasonably Achievable;
Regulatory Guide 8.10, Operating Philosophy for Maintaining Occupational
Radiation Exposures As Low As is 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
- Plants; Study on High-Dose Jobs, Radwaste Handling and ALARA
Incentives.
6.0
4
Within the scope of this review, no violations were identified.
Inspector observation of on-going work indicated good overall ALARA
controls to be in place for in-field work.
The following positive observations were made:
The licensee provided special video taped training for steam
generator workers.
The station ALARA Committee reviewed out-of-scope steam generator
work.
The licensee closely monitored accumulated radiation exposure
relative to established goals.
The following matter was discussed with the licensee:
There appears to be a need to improve estimates of person-hours
needed to complete work activities.
The person-hours for some work
activities appeared to be overestimated while person-hours for other
work activities were underestimated.
The licensee indicated this matter would be reviewed.
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 established and implemented Procedure SC.RP. TI.ZZ-1001(0),
Radiological Occurrence Investigation, to provide a consistent means
of documenting and reviewing radiological occurrences (e.g., radiation
protection violations).
A weekly summary of radiological occurrence reports (RORs) is
provided to station management.
A monthly summary and analysis is
also provided to station management.
The licensee tracks RORs by
computer.
The inspector noted that the licensee's attention to RORs
has-increased.
The following matters were discussed with the licensee:
A number of RORs appeared to contain an. incorrect identification of
root cause.
The root cause needs to be clearly identified in order
to provide for effective corrective actions.
The licensee indicated this matter would be reviewed .
7.0
5
The inspector noted that the licensee was using a radiological
assessor to review on-going work activities.
The findings were
reviewed by the licensee 1 s Radiation Protection Engineer.
External and Internal Exposure Controls
The inspector toured the radiological controlled areas of the plant and
reviewed the following elements of the licensee 1 s external and internal
exposure control program:
posting, barricading and access control as appropriate, to
Radiation, High Radiation, and Airborne Radioactivity Areas;
High Radiation Area access point key control;
control of radioactive and contaminated material;
personnel adherence to radiation protection procedures, radiation
work permits and good radiological control practices;
use of personnel contamination control devices;
use of dosimetry devices;
use of respiratory protective equipment;
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 peri6di~ operability verification of
engineering controls to minimize airborne radioactivity;
bioassays and personnel airborne radioactivity intakes;
records and reports of personnel exposure;
adequacy of radiological surveys to support pre-planning of work and
on going work; and
hot particle controls.
The review was with respect to criteria contained in applicable licensee
procedures and 10 CFR 20, Standards for Protection Against Radiation.
The inspector independently reviewed on-going work activities including
personnel entry into steam generators, various fan cooler work activities,
and safety injection pump work,
The inspector made independent radiation
measurements to verify adequacy of radiol.ogical controls.
Within the scope of the review one apparent violation was identified:
Unit 1 and Unit 2 Technical Specification 6.11, Radiation Protection
Program, requires, in part, that procedures for personnel radiation
protection be approved, maintained and adhered to for all operations
involving personnel radiation exposure.
Unit 1 RWP No. 901S00383, Revision 1, No. 11 SI Pump Mechanical Seals and
Rotation Element Replacement, was terminated on April 23, 1990.
Revision
2 of the same RWP was issued on April 23, 1990.
The new revision
required, in part, that respiratory protection be worn for system breach
and cleaning of pump internals.
- '
.. ,
6
The.inspector noted that two individuals entered and worked under Revision
2 of the RWP but had not signed the RWP compliance sheet indicating that
they had read and understood the new revision.
The individuals made a
total of 15 entries between April 24, 1990 and May 1, 1990.
One indi-
vidual received 23 millirem whole body exposure while the other individual
received 84 millirem cumulative exposure during the entries.
Unit 1 and 2 Radiation Protection Procedure No. RP201, Revision 2, Access
Con~rol Point Management, provides instructions to radiation protection
personnel for control entry/exit of personnel and e*quipment to/from the
Radiological Control Area.
Section 7.2.1 of Procedure RP201, Revision 2,
requires that radiation protection personnel ensure that individuals
have read the applicable RWP and signed the RWP compliance agreement.
The inspection indicated that the failure of the radiation protection
personnel to verify that the above two individuals had read.Revision 2 of.
RWP No. 901S00383 and signed the RWP compliance ~greement is an apparent
violation of Technical Specification 6.11.
(50-272/90-14-01;
50-311/90-14-01)
During tours of the area outside and around the station at about 2:00
p.m., on May 1, 1990, the inspector identified a trailer with boxes of
reusable contaminated tools.
The back portion of the trailer had a
ramp leading inside the trailer to the boxes.
The sides of the trailer
were posted
11 Radi oact i ve
11 *
The in specter noted the boxes were 1abe1 ed
11 Radioactive
11 *
The boxes exhibited contact dose rates of 8 millirem/hr
and 14 millirem/hr, respectively.
The inspector questioned the licensee's
Radwaste Coordinator as to the reason for the boxes b~ing in the
trailer.
The Radwaste Coordinator believed the boxes came from the Unit
2 Containment but he was not sure.
He was unaware that boxes were being
removed from containment and were being placed in trailers within the
protected area.
The licensee's radiation protection procedure, RP 204, Posting of
- Radiation Signs and Barriers, Revision 2, requires in Section 7.1.7 that
each room or area in which radioactive material in exces~ of 10 times the
amount specified in 10 CFR 20 Appendix C, is used or stored, shall be
posted as "Caution - Radioactive Materials".
The inspector noted that
the access ramp was not posted as a radioactive materials area and the
trailer contained in excess of 100 times the amount of Appendix C values
of radioactive material.
This is an apparent violation of Technical
Specification 6.11.
(50-272/90-14-01; 50-311/90-14-01)
The following additional matters were discussed with the licensee's
personnel:.
The radiation work permit (RWP) procedure does not provide
instructions or guidance for revising an RWP.
RWPs are not included in work packa*ges in the field.
This made it
difficult for Radiation Protection Technicians covering work to be
aware of RWP requirements.
. .
7
The radiation work permits do not describe dosimetry to be worn by
personnel entering the radiological controlled areas (RCA).
There was evidence (candy wrappers) indicating that personnel were
ingesting food in the RCA.
Improvement was noted in the licensee's control of steam generator
work activitie~. However, the following matters were discussed with
the licensee:
The licensee was using digital alarming, tele-dosimetry to
monitor personnel on the steam generator work platforms.
There
were no procedures for *use of the digital dosimetry.
The licensee used three methods of exposure control to monitor
steam generator worker exposures (timing entrjes, alarming
dosimeters and tele-dosimetry).
This was considered a good
initiative.
The inspector noted, however, that the results of
the three methods were not being inter-compared to check for
anomalies.
The licensee indicated the above observations would be reviewed.
The li~nsee's personnel dosimetry is appropriately accredited for
use.
Improvement was noted in the area of industrial safety.
Some
personnel were, however, observed not wearing safety glasses or hard
hats during the performance of their work.
Housekeeping had improved, but the inspector observed paper suits in
various areas of the Primary Auxiliary Buildings.
The paper suits
were found on junction boxes, welding machines and.on the floor.
Posting of radiological controlled areas outside th~ main station
buildings was in need of improvement.
Postings were inconsistent.
Also, some signs were observed-to be laying on the ground.
The gate to the Low Level Outdoor Waste Storage Area was broken.
Personnel could potentially gain access to High Radiation Areas not
exceeding 1000 millirem/hr (maximum of about 800 mR/hr near a resin
liner). A work order had been written on July 12, 1989, to repair
the gate.
The gate repair was given a very low priority.
10.0 Exit Meeting
The inspector met with licensee representatives denoted in Section 1 of
this report on May 4, 1990.
The inspector summarized the purpose, scope
and findings of the inspection.
No written material was provided to the
licensee.