ML18095A850
| ML18095A850 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 03/22/1991 |
| From: | Lance R, Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18095A847 | List: |
| References | |
| 50-272-91-08, 50-311-91-08, NUDOCS 9104090088 | |
| Download: ML18095A850 (19) | |
See also: IR 05000272/1991008
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-272/91-08
50-311/91-08
Docket Nos. 50-272
50-311
License Nos. DPR-70
Licensee:
Public Service Electric and Gas Company
P.O. Box 236
Han cocks Bridge, New Jersey
Facility Name: Salem Nuclear Generating Station, Units 1 and 2
Inspection At: Han cocks Bridge, New Jersey
Inspection Conducted: March 4 - 8, 1991
Inspector:
Approved by,*
W. Pasciak, Chief, Facilities Radiation Protection
Section
'"5 I z...-z_/?1
date
~-z*~/11
tlate
Inspection Summary: Inspection on March 4 - 8, 1991 (NRC Combined Inspection
Report Nos. 50-272/91-08; 50-311/91-08).
Areas Inspected: This inspection was a routine, unannounced Radiological Controls
Inspection. The following areas were reviewed: radiological controls organization anci
staffing; personnel qualifications and training; external and internal exposure controls;
ALARA; radioactive material and contamination controls; corrective action systems and
performance monitoring; and the licensee's actions on previous inspection findings.
Results : Within the scope of this inspection, one violation was identified. The violation
involved two examples of failure to have adequate radiation protection procedures and
two examples of failure to follow radiation protection procedures as required by
Technical Specification 6.11. (Details are in Section 6 and Section 8).
9104090088 910327
ADOCK 05000272
G
DETAILS
1.0
Individuals Contacted
- S. LaBruna, Vice President Nuclear Operations
- E. H. Villar, PSE&G Licensing Engineer
- V. Polizzi, Operations Manager, Salem
- T. Cellmer, RP/Chem Manager, Salem
- J. Wray, Radiation Protection Engineer, Salem
- A. Orticelle, Maintenance Manager, Salem
- J. Pollock, Maintenance Engineer, Salem
- J. Webster, Unit 1 Outage Manager, Salem
- E. Krufka,. Atlantic Electric
- . M. Morroni, Technical Manager, Salem
- * J. Molner, Senior RP Supervisor, Hope Creek.
- E. Karpe, Senior RP Supervisor, Hope Creek
- W. R~ Schultz, QA Manager, Salem
1.2
NRC Personnel
T. Johnson, NRC Senior Resident Inspector
- S. Barr, NRC Resident Inspector
The inspectors also contacted other licensee and contractor individuals during the
course of this inspection
- Denotes 'those individuals attending the exit meeting on March 8, 1991.
2.0
Purpose and Scope of Inspection
This inspection was a routine, unannounced Radiological Controls Inspection
during the Unit 1 refueling outage. The following areas were reviewed:
the licensee's actions on previous findings;
organization* and staffing;
training and qualificatio.ns;
external and internal *exposure controls;
AIARA*
.
'
radioactive materials and contaminatio!l control;
corrective action system.
J.O
3
Status of Previously Identified Items
(Open) Unresolved Item (50-272/90-02-01)
.*
The licensee. had not completed implementation of the long term corrective *
actions for Radiological Occurrence Report (ROR) No.89-264.
This ROR involved an improper entry by workers imo the radiological controlled
area (RCA). The workers believed a radiation protection technician had signed
them onto a radiation work permit to enter the RCA. The technician had not
signed them in. The workers questioned radiation protection personnel about the*
. need for alarming dosimeters when they entered containment. The workers were
immediately signed in *an an _RWP and provided alarming dosimeters. The
inspector reviewed the completed corrective action package for this ROR and
discussed the corrective action with cognizant licensee personnel. The event was
included for discussion in the Radiation Worker Training and Requalification *
Program. In addition this event was reviewed from a generic basis via a Human
Performance Eva_luation. No common performance deficiency was *identified .
. During this inspection, the inspector reviewed worker sign-in on appropriate
.radiation work permits and use ofintegrating. alarming dosimeters. No problems
- were identified. Inspector time limitatfons precluded complete review of this item
. with respect*to the criteria for non-issuance of a Notice of Violation delineated in
- * 10 CFR Part 2, Appendix A. This item will be reviewed during a subsequent
inspection.
4.0
Organization and Staffing
The* inspector reviewed the organization and staffing of the on site 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 Exposure at Nuclear Power Stations will be As Low As Is
Reasonably Achievable.
The evaluation of the lice~see's performance in this area was based mi discussions
with cognizant personnel, review of on-going work and review of documentation.
Within the scope of this review, no violations were identified .. The following
positive observations were made by the inspe~tor:
The licensee issued a Unit 1 Ninth Refueling Outage Handbook which
included an Outage Organization Chart and descriptions of the
responsibilities of key outage personnel.
...
- -
4
The licensee made good efforts to respond tb a strike by contractor Health
Physics technicians; Work packages were priorit:lzed and the,inspector
noted no decrease in the effectiveness of Radiation Protection coverage of *
jobs in progress within the Radiologically Controlled Area.
The licensee assigned dedicated crews and supervisors to oversee major
radiologically significant work activities (e.g., Steam Generator work
, activities). The inspector noted that .the licensee assigned five dedicated
radiation protection supervisors for each shift in the operations area.
The licensee used radiation protection personnel from the Hope Creek
station to augment the Salem radiation protection staff.
5.0
Training and Qualifications
. The inspector reviewed the q~alifications and training of selected members of the
- Radiological Controls Organization with respect to criteria contained in the
following:
Technical Specification 6.3, Facility Staff Qualification;
.. ANSI N18-.l-1971, Selection and Training-of Nuclear Power Plant.*
Personnel;
Regulatory Guide 8.8, Information Relevant to Ensuring . that Occupational
Radiation Exposure at Nuclear Power Stations will be_ As Low As. Is
Reasonably Achievable.
-
The inspector's review in this area focused on the qualification and training of
contractor radiologkal controls personnel hired to augment the organization
during the outage .
.
-
.
.
.
.
The evaluatibn of the licensee's performance in this area was based on review of
resumes and training records and discussions with cognizant personnel. The
inspector also reviewed the adequacy and effectiveness of the performance of
these personnel during independent inspector review of on-going work activities.
- The inspector's review in this area also focused on the training and qualification
- program.for radiation protection supervisors. The inspector reviewed the
qualifications of personnel assigned as operational radiation protection supervisors
for the Unit 1 outage.
,
The inspector. also reviewed the training of selected radiation-workers with respect
to the criteria specified in 10 CFR 19, Instructions to Workers .
5
Within the scope of this review, no violations were identified. The contractor
personnel appeared to be qualified in accordance with applicable guidelines and
had received adequate training .. Radiation workers were trained in accordance
with 10 CFR 19.
The following matters were discussed with the licensee's personnel:
The inspector noted that there is no defined qualification/training/retraining
program for radiation protection supervisors. The requirements for
qualification are very subjective, i.e., various topics are discussed with the
Radiation Protection Engineer (RPE) and upon completion of each
discussion the appropriate area is signed off on a qualification card by the
RPE.
The licensee's management informed the inspector that the
qualification/training/retraining program for supervisory personnel was in an
evolving status and had not been completely defined and that the need for
better definition of the program had been identified by the licensee.
The licensee was in the process of establishing a defined program in this
area. The inspector noted that requirements for training of supervisors in
appropriate procedures and systems will be included in the completed
supervisor qualification/training/retraining program.
The inspector noted that one supervisor, acting as an operational radiation
protection supervisor in the Auxiliary Building, had limited direct
experience in the area of power reactor radiation protection. The majority
of the individual's experience was obtained in a hospital environment. The
inspector noted fhat ANSI-N18.l specifies that supervisors have four years
of experience in the craft or discipline being supervised. The supervisor in
question had at least four years of experience in radiation protection, but
only one year of experience in power reactor radiation protection activities .
. The inspector further noted that this individual had been signed off as
understanding the procedure aspects of the licensee's radiation protection
program using the subjective process discussed above. The licensee's
radiation protection management indicated that the individual was working
with a fully qualified experienced supervisor. The individual was noted to
possess a graduate degree in radiation protection. Since the individual had
limited reactor experience and had been signed off on program procedures
via the subjective qualification process, the inspector expressed concern
regarding this individual making independent decisions regarding the
radiological health and safety of personnel.
6.0
6
The licensee's radiation protection management indicated the following
actions would be taken:
The licensee will initiate an accelerated, individualized training
program on relevant radiation protection procedures for this
individual to ensure that the supervisor possesses an adequate
technical knowledge of programmatic requirements for areas being
supervised. The program will provide an adequate basis for
determining individual knowledge of programmatic requirements.
Pending qualification on program procedures via the above program,
administrative controls were immediately established to ensure that
- the supervisor did not make independent decisions that would affect
the radiological health and safety of personnel without concurrence
from an appropriately qualified supervisor.
The lack of a defined qualification, training and retraining program for
radiation protection supervisors is considered an unresolved item (50-
272/91-08-01; 50-311/91-08-01 ).
External and Internal Exposure Controls
The inspector toured the radiologically controlled areas of the plant and
independently reviewed the following elements of the licensee'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;
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 protection equipment including provision of appropriate
quality of breathing air for air supplied respirators,
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 radioactivity;
records and reports of personnel exposure;
adequacy of radiological surveys to support pre-planning of work and on-
going work;
- .1
7
adequacy of supply, maintenance, calibration, and performance checks of
survey instruments; 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 Unit 1.
steam generator work on both the primary and secondary sides, reactor coolant
pump maintenance, and safety injection system and residual heat removal system
valve work.
The inspector made independent radiation intensity measurements to verify the
adequacy of radiological controls.
Within the scope of this review one apparent violation was identified:
\\
.
.
.
Unit 1 and 2 Technical Specification 6.11, Radiation Protection Program, requires
that procedures for.personnel radiation protection shall be prepared consistent
with the requirements of 10 CFR Part 20 and shall be approved, maintained and
adhered to for all operations involving personnel radiation exposure .
10 CFR 20.101 provides dose limits for various portions of the body. The
inspector noted that 10 CFR 20.202 requires that ea.ch licensee is to supply
.
appropriate personnel monitoring to, and require the use of such equipment py,
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 25 % of
the applicable value specified in 10 CFR 20.lOl(a.).
The inspector's review of dosimetry placement for workers working in the
radiation gradients around the Unit 1 steam generators indicated the following:
The radiation work permit for foreign object search and retrieval (FOSAR)
on the secondary side of the number 14 steam generator (Unit 1 RWP No.
911S00121, Revision 0, F.0.S.A.R. and Sludge Lance Evolutions) required
dosimetry placement on the chest, upper arms, and upper ext~emities of
each worker.
8
The inspector observed at about 2:00 p.m. on March 6, 1991, that an
individual, operating the computer for FOSAR on the number -14 steam
generator, was sitting with his head in front of ~he steam generator
handhole. Radiation dose rates in contact with the handhole were 1200
mR/hr. Radiation dose rates to the individ-qal's head were at least 100
mR/hr and general area dose rates were 40 - 50 mR/hr. The chest
dosimeter was in the general area dose rates. The chest dosimetry did not
provide an appropriate measurement location for the dose received by the
head which was in the region of highest dosage rate. The senior radiation
protection technician present at the job site appeared unconcerned with the
dose gradient between the individual's head and his dosimetry on his chest
and asked the individual to move away from the handhole only after the
dose gradient was identified by the inspector.
As discussed in section 7 of this report, and not withstanding lack of
monitoring of the dose to the worker's head, the technician allowing the
worker to have his head positioned unnecessarily in front of the open
handhole, was a poor ALARA practice.
While observing FOSAR work on the number 14 steam generator at about
2:00 p.m. on March 6, 1991, the inspector noted that a second individual,
manipulating the items in the handhole (FOSAR snorkel tube), was
repeatedly stepping and remaining directly in front of the steam generator
handhole.-
This resulted in the individual's lower trunk and gonads to be repeatedly
exposed to a 100 - 200 mR/hr radiation field while his dosimetry was
located on his chest in the 40 - 50 mr/hr field.
The radiation protection
technician directly overseeing the wcirk did not reposition the worker or
relocate the worker's dosimetry to ensure that the highest whole body
exposure to the worker was being monitored. The technician subsequently
repositioned the worker.
The inspector reviewed Radiation Protection Procedure RP 301, Personnel
Radiation Monitoring Requirements, Revision 1, relative to the above
observations. The licensee's procedure indicated that dosimetry need not
be repositioned unless; 1) the dose rate to portions of an individual
(relative to the chest) differed by a factor of 2, 2) the expected radiation.
dose to be received would exceed 1000 millirem, and 3) the ambient whole
body dose rate is greater than 100 mRem/hr.
9
The inspector's review of the above two observations indicated that workers
could sustain twice the radiation dose to portions of the whole body that
was not monitored as compared to that portion of the whole body that was
. monitored. Literal interpretation of the procedural guidance did not .
require relocation of the dosimetry. The inspector concluded that the
licensee's radiation protection procedure, established to ensure proper
radiation monitoring of workers, was inadequate to ensure that appropriate
dosimetry was provided to monitor the dose to the body in a radiation dose
rate gradient. This is an apparent violation of Technical Specification 6.11
which requires that procedures be established consistent with the
requirements of 10 CFR 20. (50-272/91-08-02; 50-311/91-08-02)
The licensee immediately revised the procedure to provide for improved
1 guidance for repositioning of dosimetry to the highest dose location.
In addition to the above observations the inspector made the following
observation:
Unit 1 RWP No. 911S00237, Revision 0, 12SJ56: Disassemble/Inspect/ *
Repair/Reassemble, required that dosimetry be relocated to reflect highest
whole body exposure .
The inspector noted that an individual working on valve 12-SJ-56 was
resting his knee on a pipe reading 100 mR/hr contact while cleaning large *
studs and bolts with a tooth brush size wire brush. General area radiation
dose rates iri the area were 60 - 80 mR/hr, and the dose rate in the vicinity
of the individual's dosimetry was 60 mR/hr. The individual had been in the
area for one hour and forty five minutes, and interviews with the technician
covei-ing the job and inspection of the work area indicated that the
individual had been in the proximity of the pipe for a considerable portion
of that time.
The radiation protection technician present at the job site exhibited an
apparent lack of sensitivity to, and unawareness of the dose gradient
between the individual's knee and his dosimetry on his chest. The above
observation reflected a third example where a worker could receive a
radiation dose to an unmonitored portion of the whole body (leg above the
knee) in excess of that monitored by the .chest whole body badge. The
inspector noted in this case that the RWP specifically required
repositioning of the dosimeter while the RWP for the previous two
examples did not require repositioning of the whole body badge.
10
The licensee's radiation protection procedure, NC.NA-AP.ZZ-0022, Revision 0,
Radiation Protection Program, states in section 3.9 .that all personnel shall comply
with the worker responsibilities listed in Attachment 1 to the procedure.
Attachment 1, Responsibilities of Each Individual, states in part in section 2,
11Follow all approved procedures, postings, and RWP instructions."
.
The inspector indicated that the failure of the radiation protection technician to
adhere to the requirements of RWP No. 911S00237 and relocate the worker's
dosimetry to the location of highest exposure was an apparent violation of
Technical Specification 6.11 which requires that radiation protection *procedures
be adhered to. (50-272/91-08-01; 50-311/91-08-01)
The following additional matters w~re discussed with the l_icensee's persbnnel:
The licensee's Technical Specification 6. l3 provides requirements relative
. to High Radiation Area access control and radiation surveillance of
workers working in High Radiation Areas. The inspector noted that RWP
No. 911S00104, Revision 4, #12 & 14 S/G: Install/Remove WL-2/ROSA,
required continuous radiation protection technician coverage of work being
performed on the steam generator platforms. This was identified in the
RWP section for RWP coverage requirements. The inspector noted that
Technical SpecificatiOns identifies the performance of radiation surveillance
at the frequency specified on the RWP, as one option for complying with
the radiation surveillance r_equirements specified therein. The inspector
evaluated how the licensee implemented the continuous coverage
surveillance requirement. .
The inspector's review at each of the steam generator control points
indicated that radiation protection technicians were monitoring work in
progress via a television camera, but no technician was aetually on the
platform providing continuous radiation surveillance coverage when
workers were on the platforms. Further investigation showed that the
surveillance with television cameras was consistent with the station's
definition. of continucms coverage.
The inspector noted that no apparent violation was identified because the
licensee issued each worker, working on the platforms, an integrating
- alarming dosimeter. This is permitted by the licensee's Technical
Specifications in lieu of the radiation surveillance to be performed at the .
. frequency specified on the RWP. The inspector indicated that radiation
surveillance could not be performed by television camera. The inspector
concluded that the licensee did not understand the concept of continuous
coverage from a radiation surveillance point ofview and was using a
- television camera, normally used for High Radiation Area access control, to
- 11
perform radiation surveillance of the work location. The licensee
immediately initiated actions to clarify RWP coverage guidance.
Whenever an item was removed from the bowl of the steam generator, the
individual removing the item would do a frisk of his hands for hot particles
with a Geiger-Mueller survey instrument located on the platform. This was.
adequate to check for significant residual contamination on hands but
would provide no indication of radiation dose received by the extremities
when handling equipment. _
Personnel wore finger rings but they did not provide *a real time monitoring
. capability. It was also noted that the instrument used was not source or
response checked on a regular basis, and thus could only be used as a
reference instrument. It appeared inappropriate to use. tlie Instrument as a .
calibrated instrument for performing surveys of record. *
10 CFR 20.20l(b )(2) states, in part, that licensee's shall make such surveys
as are reasonable under the circumstances to evaluate the extent of
.
radiation hazards that may be present. The. inspector. noted that each time
an item was removed from the steam generator, there was the potential for
a change in the radiation hazard present due to the possibility of hot
particles being attached to the item being removed resulting in a potential
dose to the extremities. * ,
The licensee's radiation protection management stated that surveys had
been performed and an evaluation done that supported not surveying items
as they were removed from the steam generator. This evaluation had
apparently not been documented. 10 CFR 20.401 specifies that such
evaluations be documented. The* inspector rioted that .the licensee had
identified high radiation dose rate hot particles during previous outages at
Unit 2.
The licensee immediately initiated action to collect information that
supported suspension of surveys of equipment being removed from steam
generators and handled by workers prior to radiation surveys being made.
The licensee temporarily proV:ided radiation protection technician coverage
when material was being removed from the steam generator pending
complete documentation and approval of the basis for suspending surveys
of material being removed from the steam generators.
The documented evaluation and further licensee actions will be reviewed
during a future inspection. This matter is unresolved. (S0:.272/91-08-03)
7.0
12
While observing work on March 6, 1991, on valve 14-SJ-43, a safety
injection check valve, the inspector noted, and the supervisor accompanying
the inspector concurred, that the air sampler being used to draw the
breathing zone air sample for the job appeared to be placed in a less than
optimal position. A radiation protection technician present at the job site
repositioned the air sampler after being instructed to do so by the
supervisor.
The inspector had. previously observed work on valve 14-RH-27, a residuai
heat removal check valve. The radiation protection technician covering the
work activities was alert to the radiological hazards associated with the job
and performed breathing zone air sampling that was clearly representative
of the conditions present.
-
The obvious difference in the placement of the air samplers by the
technicians covering the two jobs mentioned led the inspector to investigate
the procedure for air sampling. The procedure provided limited guidance
for the performance of representative air samples. Licensee management
initiated changes to the procedure upon notification of the inspector's
observation. The procedure stated that air samples should be collected
upon breaching of systems but provided no guidance as to what constituted
a representative sample.
The inspector reviewed selected aspects of the licensee's ALARA Program. The
review was with respect to criteria contained in the following:
10 CFR 20.1, Purpose;
Regulatory Guide 8.8, Information Relevant to Ensuring that Occupational
Radiation Exposure 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 Stations; Study on High Dose Jobs, Radwaste Handling and
ALARA Incentives.
13
Within the scope of this review, no violations were identified. Licensee planning
and preparation for major work tasks, e.g., steam generators, appeared.excellent.
The following positive observations were made by the- inspectors:
The licensee's three year average personnel exposure for *the period ending
in 1990 was 409 person-rem as compared to an industry average for the
same period of 584 person-rem and an industry best quartile of 472 person-
rem (for two unit pressurized water reactors).
The licensee distributes a monthly ALARA report to station management
.. regarding status of current performance in the area of A.LARA.
Despite very good overall performance as indicated by comparison with industry
average data and excellent efforts on major work tasks (e.g., steam generators),
inspector observatio~s of mi-going work indicated the need for improved ALARA
controls on less highly visible jobs and increased personnel sensitivity to
opportunities for dose reductions. The following observations were discussed with
. licensee personnel:
While observing the work activities associated with valve 12-SJ-56, *a safety
injectiqn check valve located in the Unit 1 containment, the inspector noted
that workers had difficulties acquiring the proper tools to perform the job.
The disassembly of the valve, based on initial planning, was to have been
performed with a High Torque machine. However, the only High Torque
machine available was being used on another work activity.
The work group was preparing to perform the work on 12-SJ-56 using a
slugging wrench without the benefit of the High Torque machine. Upon
inspector identification of the apparent discrepancy with the worker's initial
plans, a radiation protection supervisor temporarily halted the job.
There were numerous delays in the execution of the job. Initially, the
workers attempted to loosen the nuts with a slugging wrench, but were
unsuccessful. The positioning of the nuts on the valve did *not allow for* use
of the slugging wrench.
Next the workers attempted to use the High Torque machine, but the
machine failed. Repairs were made to the machine at the job site, but the
new head was found to have the wrong size drive for the socket being used.
The workers then attempted to use the slugging wrenches once again, *
knowing that previous attempts proved unsuccessful.
14
The above work activities occurred* in about a 60 - 80 mR/hr radiation field.
It was not apparent, based on discussions with. the workers, that an attempt
had been made by (he workers to contact the ALARA group to re-evaluate
. the situation and expected radiation dose after changes were made to the
initial plans.
During observation of work on valve 14-RH-27, located in the annulus *of
Unit 1 containment on March 5, 1991, the inspector noted that the tooling
for the job could have been better. The job was performed with slugging
wrenches and disassembly of the valve took approximately three hours ..
.
.
.
.
- The work could possibly have been performed more expeditiously if some
sort of power tool 'Yould have been used to remove th~ bonnet nuts. *
Although the area did not exhibitsignificant radiation fields, the duration of
the disassembly indicated poteptial weaknesses in tooling selected.
A worker at the 12-SJ~56 job site was observed, at about_ 2:00 p.rn. on*
March 6, 1991, to be cleaning large studs and bolts with a tooth brush size
wire brush. The general area dose rates were 60 - 80 mr/hr. The
coinportents could have easily been removed to and cleaned in a low dose
rate area. The inspector noted that 10 CFR 20.l indicates that licensees
should make every reasonable effort to maintain radiation exposures as low
as reasonably achievable.
Also Regulatory Guide 8.8 indicates in section C.3.a., Preparation and
Planning, that the existing radiation levels frequently can be reduced by
removing and transporting components to a lower radiation zone.
The inspector concluded* that permitting workers to clean easily
transportable components in elevated radiation fields was a. poor ALARA
practice .. A senior radiation protection technician was observing the
activity.
The inspector observed work in progress on the number 13 Reactor
Coolant Pump (RCP) motor on March 5, 1991. Portions of the work was
occurring in a 60 mR/hr general area radiation field. The source of the
radiation was radiation streaming from the reactor cavity, which was
drained at the time of the work activity.
- *
15
The inspector ascertained through conversations with radiation protection
technicians and supervisors that shadow shielding had been installed prior
to the start of the RCP motor work. The shiel9ing had apparently been
moved to another job site. and had then been disassembled. The shielqing
was not re-installed when work re-commenced on the RCP.
A painter in the North Drum Storage Room was observed by the inspector
on March 4, 1991, cleaning paint cans immediately adjacent to a High
Radiation Area barricade. The general area dose rates that the painter
was in were 20 mR/hr. The work could easily have been done safely in a
significantly lower dose rate,area in the same room.
The above observations indicate lack of sensitivity by workers and radiation
protection personnel to additional opportunities for personnel radiation
exposure reduction.
8.0
Radioactive Material and Contamination Control
The inspector toured the station periodically during the inspection and reviewed
the licensee's controls for radioactive material and contamination. The following
matters were reviewed:
posting, labelling, and control of radioactive and contaminated materials;
personnel use of contamination control devices.
The evaluation of the licensee's performance in this area was based on review of
on-going work activities, discussions with personnel and review of documentation.
The following positive observation was made:
The licensee has been aggressively pursuing reduction in the square footage
of contaminated floor space at the station. The inspector observed
improved plant appearance as a result of painting and cleaning efforts.
Currently about 6.3 % of Salem station floor *space is contaminated
(excluding containment), This is as compared to an industry defined "good
plant" of about 10%. The licensee's efforts were commendable.
Within the scope of this review, one apparent violation was identified:
Unit 1 and 2 Technical Specification 6.11, Radiation Protection Program, requires,
in part, that procedures for personnel radiation protection be approv~d,
maintained, and adhered to for all operations involving personnel radiation
exposure .
16
Unit 1 RWP No. 911S00121, Revision 1, F.O.S.A.R and Sludge Lance Evolutions,
required ensuring that all equipment/tools entering the steam generator handholes
are smearably clean. The inspector noted that probes and cables used for the
evolution were lying about on the platform erected for the work. There was
traffic on the platform from personnel working on both the number 12 and 14
steam generators. No effort was made to ensure that equipment/tools were
smearably clean prior to the tools being inserted into the steam generator
handhole.
The licensee's radiation protection procedure NC.NA-AP.ZZ-0024(Q), Revision 0,
Radiation Protection Program, states in section 3.9 that all personnel shall comply
with the worker responsibilities listed in Attachment 1. Attachment 1 states that
one of the responsibilities of each individual is to follow all approved procedures,
postings, and R WP instructions.
The inspector indicated that the failure of the radiation protection personnel to
ensure the equipment/tools entering the steam generator handholes were
smearably clean as required by RevisiOn 1 of RWP No. 911S00121, as required by
radiation protection procedure NC.NA-AP.ZZ-0024(Q), was an apparent violation
of Technical Specification 6.11. (50-272/91-08-02; 50-311/91-08-02)
The following additional matters were discussed with licensee personnel:
The inspector observed a contractor individual opening bags of radioactive.
material in the general walkway area of the Unit 1 containment annulus 78'
elevation. No contamination surveys were being performed on the contents
of the bags upon opening.
The bags contained equipment for use in the steam generators and had
come from another site. The bags were marked with some numbers, but it
was unclear as to the significance of the numbers. The individual indicated
to the inspector that he did not know what the numbers meant.
A radiation protection supervisor informed the inspector that station policy
required bags containing steam generator equipment from other stations to
be opened in a contaminated area in the Fuel Storage Building established
for that specific purpose. The observation indicated lack of sensitivity. of
the worker to the potential for spread of contamination.
The inspector observed work on March 5, 1991, on valve 14-RH-27, a
residual heat removal check valve. While overall coverage of the job by
the radiation protection technician was very good, some areas for
improvement were noted with respect to contamination control as follows:
17
The inspector noted that workers handled their clean respirators
with contaminated- gloves. This could have lead to personnel
contaminations.
One worker left the job site, in an overhead area, while still in his
plastic protective clothing, to search for additional tools. This had
the potential for spreading contamination to less contaminated areas
of the containment._ Another worker tried to leave the area upon
completion of the job without removing his outer layer of protective
clothing, but the radiation protection technician restrained him. _
The job site was in the overhead piping, and at the bottom of the
scaffolding access ladder there was no undress area established.
This also had potential for spread of contamination in the
containment due to people walking through the area where workers
removed their protective clothing after the workers had left the area.
These items were discussed with licensee management on \\Vednesday
March 6, 1991, at which time the inspector expressed his concern for the
apparent need for better contamination controls upon suiting up and
exiting job sites. On Thursday March 7, 1991, four workers, including the
radiation protection technician covering the job, became contaminated
while exiting a similar work activity (disassembly of a check valve).
The inspector reviewed personnel contamination experience as identified in
radiologital occurrence reports (RORs). The review indicated the follov.ring:
The licensee has a three year average personnel contamination rate of 250
personnel contaminations for the three year period ending in 1990. This is
as compared to an industry best quartile (for a two unit pressurized water
reactor (PWR)) of 264 and an industry average (also for a two unit PWR)
of 335 personnel contaminations.
The licensee has sustained 69 personnel contaminations for 1991. Of the
69, 59 were associated with the unit 1 outage. The low level personnel
contaminations constituted the bulk of the radiological occurrences issued
for 1991.
Although the licensee's performance relative to the industry appears good, based
- on the above observations, increased licensee attention to contamination controls
appears warranted.
~.
9.0
18
Corrective Action System and Performance Monitoring
The inspector reviewed selected aspects of the licensee's corrective action and
performance monitoring system. Within the scope of *this review, the following
positive observations were made:
The licensee significantly improved attention to Radiological Occurrence
Reports (RORs) since previous inspections.
The licensee's records exhibited good follow-up effort on the part of the
radiation protection staff in the resolution of RORs.
The inspector concluded that good overall licensee review and evaluation of self-
identified findings was performed.
10.0 Plant Tours
The inspector toured the radiological controlled areas of the facility periodically
during the inspection. The following matters were discussed with licensee
personnel:
General industrial safety awareness of licensee personnel appeared
improved, however, several issues were identified by the inspector.
One worker was observed sitting in a high decibel noise area on the
pedestal of the operating Fuel Storage Building fan unit in the Unit
1 Auxiliary Building. The individual was res!ing her arms on the fan
guards, whose purpose is to prevent people from inadvertently
coming in contact with the rotating elements of the unit.. The
pedestal area was subsequently roped off as a danger zone.
A potential fire hazard was identified by the inspector in the North
Drum Storage Room in the Unit 1 Auxiliary Building. Open cans
containing residual paint and thinner were left open to dry in an
area directly adjacent to a High Radiation Area containing bags of
combustible trash. The paint cans were immediately moved. The
area was periodically checked by a roving firewatch.
The inspector noted that sections of lighting in the containment
stairwells were inoperable. The lighting was subsequently upgraded.
The inspector observed two workers on I-beams in the upper level
in~ide of the bioshield without safety belts. The licensee's safety
personnel were informed.
19
The inspector noted an excessive amount of water on the floor by
the 104 panel on the 64 foot elevation of the Unit 1 Auxiliary -
Building. The licensee initiated a revie'Y of the source of the water.
Housekeeping in the Unit 1 contaiilment *and auxiliary* building.was
adequate. Housekeeping in the Unit 2 auxiliary building was good.
11.0 Exit Meeting
The inspector met with licensee representatives denoted in section 1 *of this report
on March 8, 199L * The inspector summar~ed the purpose, scope and findings of
.
. -
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. the inspection. No written material was provided to the licensee ..