ML20102A770

Responds to Violations Noted in Insp Rept 50-272/84-35. Corrective Actions:Radiation Protection Procedure 3.021 Revised to Clarify Placement of Special Dosimetry,To Be Clearly & Consistently Indicated on Diagrams

ML20102A770
Person / Time
Site:	Salem
Issue date:	12/19/1984
From:	Liden E Public Service Enterprise Group
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20102A765	List: ML20102A770
References
NUDOCS 8502080564
Download: ML20102A770 (15)

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Pubhc Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038

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T Nuclear Department

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l December 19, 1984 4

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Nuclear Regulatory Commission I

Region 1 631 Park Avenue f

King of Prussia, PA 19406

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Attention:

Mr. Thomas T.

Martin, Director Division of Engineering and Technical Programs

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Gentlemen:

t NRC INSPECTION 50-272/84-35 SALEM NUCLEAR GENERATING STATION UNIT NO. 1 T

DOCKET / LICENSE:

50-272/DPR-70 The referenced inspection, conducted on September 18 and 24, 1984, identified one violation, which involved inadequate procedures for monitoring upper arm exposures in non-uniform i

radiation fields.

The following is Public Service Electric 4

and Gas's response to the Notice of Violation:

4 ITEM OF VIOLATION:

'l 10 CFR 20.202 " Personnel Monitoring" states, "each licensee shall supply appropriate personnel monitoring' equipment to, 2

and shall require the use of such equipment by:

...Each individual who enters a restricted area under such circumstances that he receives, or is likely to receive, a dose in any calendar quarter in excess of twenty-five percent f

(25%) of the applicable value specified in paragraph (a) of 3

Part 20.101."

B5020e0564 850125 PDR ADOCK 05000272 0

PDR i

The Energy People E

95 2168 (76M; 12-83 I

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' Mr. Thomas T. Martin

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12/19/84 Contrary to.the Above:

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'Assof July 2, 1984,.the licensee failed to supply or require,the use'of personnel monitoring equipment appropriate for monitoring whole body exposure to the

_ upper arms of individuals.

RESPONSE TO THE VIOLATION:

Identification and removal of debris from the Unit 1 Steam Generators were performed under Radiation Exposure Permit (REP) 0375,_and prior to July 2, 1984, the workers had

. dosimeters only on.the wrist, chest, and head.

As a result of

-an allegation by one of the workers, it was determined that dosimeters were required on the upper arm as well, and the

. orkers on REP 0375 were issued additional badges on July 2 to w

mor itor whole-body exposure to the upper arms.

Because of the pot.ential for unmonitored exposure prior to July 12, a work stoppage was' ordered.on July 6, until an investigation could

~be conducted. -The results of the investigation are detailed in: Lapse of Radiological' Control 84-125 and an Incident Report 84-109.(attached).

' li-CORRECTIVE STEPS WHICH.HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Radiation Protection. Procedure - (RP) 3.021 was revised to clarify the placement of special~ dosimetry,. which :will be clearly and consistently indicated on diagrams.

This specificLincident involving upper-arm exposure in a non-uniform radiation field, thecchange to RP.3.021, and

_theoguidance provided1in IE Information-Notices 81-26 and 83-59 were reviewed-by all PSE&G and contractor health-

physics. personnel.-

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CORRECTIVE STEPS WHICH WILL-BE,TAKEN TO AVOID FURTHER-VIOLATIONS:-

See paragraph l~Above..

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DATE WHEN. FULL COMPLIANCE WILL BE ACHIEVED:.

.We are now in full compliance. ",

Veryctruly-yours, s

E. A.LLiden Manager - Nuclear-Licensing and_ Regulation P

RSP:mg

? Attachment i(NRC only).

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.Mr4. Thomas T.. Martin 12/19/84 C.

~ Mr.: Donald.C.-Fischer Licensing Project._ Manager EMr. ' James Linville

' Senior Resident Inspector e ]

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+*O ATTACHMENT ADMINISTRATIVE OVER-EXPOSURE OF WESTINGHOUSE WORKERS REP #0375 During this. Refueling Outage, all Unit No. 1 Steam Generator 3

Moisture _ Separators.were modified to install additional

. drains.. Following this modification, Westinghouse was contracted to perform an annulus search and retrieve any debris

observed.

Ferformance of the search required that a worker insertuthe-optical device through the secondary handhole located just above the tube' sheet on each Steam Generator.

The worker then extends-his arm inside the handhole and manipulates / guides the: optical. device to the location desired.

He then removes his arm:and. views as much area as possible. prior;to moving the.

' C device-to alnew location.

During1 this search,na significant

' amount'of' debris was observed on the' tube sheet.

A method of

= debris removal was developed which utilized the same method to 11'nsert a' vacuum cleaner hose as was previously used to insert

the optical viewing; device., Manipulation.of the vacuum cleaner hose did ' require; more time;with the. workers. arm inside / the handhole..This method of debris removal was not discussed

'during the Pre Work Alara Review meeting but was discussed during the Subsequent Planning meeting at which1 radiation

[-

. protection personnel were in. attendance.

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. During the1 course of an-investigation of an administrative

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overexposure of E.

Burkholder (Westinghouse) concerns were v.

~ identified regarding the work practices being following by Westinghouse.. personnel,4and about a change of. location..of L

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' dosimetersLforithose-personnel; performing.that work.

The apparent result ofe relocating the-personal dosimeters-wasian Lincrease t in the rate. at which ' personnel weref receiving L

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This. raised the t questionlof iwhether 1 there had' been

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-exposure.

ihighertexposure to the workers than'had.previously;been-p recorded. 'Since,. forLa m'ajority ofLthe workers, the work practice had not changed:significantly,)a review of-;their; L

p

previousiand' current exposure.wasuundertaken.; (Thatgissthey; L

i werei spending ~ thel same -.amou'nt of time" with - their.. arms E inside ~ the -

h handhole now as'beforenthe relocation of-thefdosimetry.).

As:aLresult' of-thisfreview, and.after' interviewing al'ls..

'available.Westinghouselpersonnel,Lthe.followingiconclusions:were

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slb-The workers followed one.of-two basic' work methodsEregarding

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itheJextensionDof: their 'armslinside -.the steam; generator.

~J Jhandhole.-

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>They worked.a majorityLof<theitimefusing._onlylthe:

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forearm withLoccasional extensionLofithe-wholeLarm..

8 IB)i /They workediaimajority' of' the' time with' the. entire ar'm.

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extended ~insideCthe-steam' generator handhole.

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e Attachment Page 2 2.

Por.the workers in Category "A",

there is no significant difference of wrist to highest of whole body, chest or head ratios after the time of relocating the dosimeters as compared to these same ratios prior to relocation.

3..

For workers in Category "B",

there was a significant change in.the ratio ~of highest wrist to highest of whole body,

. chest or head ratio after relocating the dosimeters as compared to before relocation.

' 4.

There were three wo'rkers'who met Category'"B" criteria (see

~

attached worksheet).

For these personnel, it will.be necessary to adjust the whole body record, values to account for the exposure they received to the upper arm prior to relocation of dosimetry..

As a result of this incident, and because there have been several other instances of administrative overexposure to

~

- personnel this outage, the following actions shall be taken:

1.

A procedural review shall be conducted to determine adequacy

-of procedures for controlling personnel, and changes to these procedures shall be made as needed.

2.

The recent incidents of overexposure will be reviewed with all radiation protect 1

.1 personnel with special emphasis on

.a

.the urgency of follow' procedures and being alert for gchanging conditions.

It is felt that-these actions along with those. corrective actions -of the previously mentioned incidents will be ef fective in preventing any further instances of personnel overexposures.

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ATTACHMENT ADMINISTRATIVE OVER-EXPOSURE OF WESTINGHOUSE WORKERS REP #0375 1

During this Refueling Outage, all Unit No. 1 Steam Generator Moisture Separators were modified to install additional

[

drains.

Following this' modification, Westinghouse was contracted to perform an annulus search and retrieve any debris observed.

Performance of the search required that a worker

' insert the optical device through the secondary handhole located just above the tube sheet on each Steam Generator.

The worker then extends his arm inside the handhole and manipulates / guides the optical device to the location desired.

He then removes his arm and views-as much area as possible prior to moving the device to a new location.

During this search, a significant

. amount of debris was observed on the tube sheet.

A method of debris removal was developed which utilized the same method to insert a vacuum cleaner hose as was previously used to insert the optical viewing device.

Manipulation of the vacuum cleaner t

hose did require more time with the workers arm inside the

=

F handhole.

This method of debris removal was not discussed during the Pre Work Alara Review meeting but' was discussed during the Subsequent Planning meeting at which radiation protection personnel were in attendance.

During the course of an investigation of an administrative overexposure of E.

Burkholder (Westinghouse) concerns were

=

5 identified regarding the work practices being following by Westinghouse personnel, and about a change of location of dosimeters for those personnel performing that work.

The apparent result of relocating the personal dosimeters was an increase in the rate at which personnel were receiving e

exposure.

This raised the question of whether there had been 4

s higher exposure to the workers than had previously been

~

recorded.

Since, for a majority of the workers, the work practice -had not changed sig'nificantly, 'a review of their a

previous and current exposure was undertaken.

(That is they were spending the same amount of time with their arms inside the handhole now as before the re' location of the dosimetry.)

b As a result of this review, and after interviewing al'1 available Westinghouse personnel, the following conc'usions were

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made:

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'The workers followed one of two' basic work methods regarding the extension of.their. arms inside the steam generator handhole.

E A)- They worked a majority of the time using only the r

forearm with occasional extension of the whole arm.

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B)

They worked a majority of the time with the entire arm extended inside the steam generator handhole.

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Attachment Page 2 2.

- Por.the workers in Category "A",

there is no significant

. difference of wrist to highest of whole body, chest-or head ratios after the time of relocating the dosimeters as compared to these same ratios prior to relocation.

3.

For workers in Category "B",

there was a significant change in the ratio of highest wrist to highest of whole body,

- chest or head ratio after relocating the dosimeters as compared to before relocation.

4.

There were three-workers who met Category "B"

criteria (see

- attached worksheet).

For these personnel, it will be

- necessary to adjust the whole body record values to account for the exposure they received to the upper arm prior to relocation of dosimetry.

As a result of this incident, and because there have been several other instances of administrative overexposere to personnel'this outage, the following actions shall be taken:-

.l.

A p'rocedural review shall be conducted to determine adequacy of procedures for' controlling personnel,.and changes to these procedures shall be made as needed.

2.

- The recent incidents of overexposure:will be reviewed with all radiation protection personnel with special emphasis on the urgency' of.following procedures and-being alert for

. - changing conditions.

ItLis felt that these~ actions along with th'ose corrective actions of.the previously mentioned incidents will be ef fective in preventing any further instances of personnel overexposures.

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REPORTc0 SY c4ra r.qt 2

g RADtATION PROTECTION DEPARTMENT REVIEW CoweeENT5 ANO RECOMWINOED PERMANEMf COAAECTNE ACTION

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All Exposure Values are in mrem Name Date Wrist WB Chest

' Head Decker 6/28 2615 1188 419 464 7/1 2250 390 375 308 Dosimetry 7/3 2385 855 873 291 Relocated

- 7/5 850 487 591 92 Effective 07/02/84 Procedure 1.

Add chest values of 7/3 and 7/5 and divide by 2 to obtain average Chest = C.

2.

Add wrist values of 7/3 and-7/5 and divide by 2 to obtain average wrist = W.

3.

Divide W by C to obtain Ratio = R.

4.

Divide wrist values of 6/28 and 7/1 by R to.obtain new whole body value ='WB.

5.-

' Add new WB reading to previous or correct exposure to.obtain corrected'whole body values.

Results 1.

-873 + 591 = C = 732

^

2 2.-

2385 +1850~= W = 1617 2

3.-

1617 = R = 2.2 732 Attachment l' (page 1)

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4.

2615 = WS = 1188 for 6/28: 2250 = WB = 1022 for 7/1 2.2 2.2 5.

2nd Quarter 1156 Arriving Dose 3rd Quarter 1022 1188 Corrected Dose

+873 2344 Total

+591 2486 mrem Total 1

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' Attachment 1 (page 2)

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All Values Are In mrem J

Name Date Wrist WB Chest Head

- Burkholder 6/28 1845 423 444 449 7/1 2310 240 252 271 Dosimetry 7/3 1960 484 830 156 Relocated 7/6

• See Note 900 Mrem Effective

- 07/02/84 4

Procedure 1.

Divide wrist by chest to obtain Ratio = R.

2.

Divide wrist values of 6/28 and 7/1 by R to obtain new whole body value = WB.

3.

Add new WB value to previous or c'rrect values current quarter to o

obtain corrected whole body values.

Results 1.

1960 = 2.36 830 9

~

2.

~6/28 1845 = WB = 782 2.36 7/1 2310 = WB = 979 2.36 3.

979 + 830 + 900* = 2709* mrem third. quarter 1452 arriving dose + 782 corrected doses = 2234 mrem second-quarter.

• TLD will not be read until.7/9/84.. Dosimeter reading from REP' sign in sheet used to~ calculate current quarter exposure when TLD is-read this value will be updated. (page 3) m-_

All Exposure Values in mrem Name Date Wrist WB Chest Head

' Chassion 6/28 770 377 325 362 No entries since relocation of dosimetry.

i During the interview the worker stated he also worked with his arm fully extended into hand hole.

For this reason the following procedure will be used to correct his second quarter dose.

1.

Add the ratios R determined for Decker and Burkholder and divide by 2 to obtain an average worker Ratio = AR.

2.

Divide wrist value of 6/28 by AR to obtain new whole body value =

IfB.

1 3.

Add WB to previous exposures or any exposure received at SNGS i

during the second quarter to obtain, corrected whole body _value.

Results 1.

2.36 + 2.2 = 2.28 =-AR 2

2.

770 = WB = 338*

2.28-

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• Since this valuefis less than listed WB value no change to.

3.

i exposureirecord will be.needed.

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UPDATE OF ATTACHMENT TO LRC 84-125 TLDs worn by D. Burkholder during his last entry on REP 0275 dated 7/6/84 were processed on 7/9/84 with the following results.

Wrist WB Chest Head 1330 497 637 120 Following the process previously outlined for Decker:

1.

Add the chest readings of 7/3 and 7/6 to obtain C.

2.

Add the wrist readings of 7/3 and 7/6 to obtain W.

3.

Divide W by C to obtain R.

4.

Divide wrist values of 6/28 and 7/1 to obtain new whole body values WB.

5.-

Sum the new WB readings to previous or correct exposure to obtain corrected whole body value.

Results 1.

830 + 657 = 743.5 2

2.

1960-+ 1330 = 1645 2

3.

1645 = 2.2~

743.5 4.

1845 = WB = 838 mrem for 6/28, 2310 = 1050 mrem for 7/1 2.2 2.2

' (page 5) i

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5.

Second quarter exposure = 1452 arriving dose + 838 corrected dose of (7/3) = 2290 mrem.

Third quarter exposure = 1050 corrected dose of (7/1) + 830 (7/3).

+ 657 (7/6) = 2537 mrem.

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