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IE Insp Repts 50-003/76-05, & 50-247/76-08 on 760406-09. Noncompliance Noted:Individual in Restricted Area Received Whole Body Exposure of 10.06 Rem & Failure to Perform Surveys to Assure Compliance W/Postings Requirement
	ML20042A801
Person / Time
Site:	Indian Point
Issue date:	05/07/1976
From:	Knapp P, Neely D, Streeter J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20042A797	List: IR 05000003/1976005; ML20042A796;
References
	50-003-76-05, 50-247-76-08, 50-247-76-8, 50-3-76-5, NUDOCS 8203240094
	Download: ML20042A801 (31)
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U. S. !!UCLEAR REGULATORY CC:CIISSIO:t

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OFFICE OF I::SPECTIO:: A::D E:rFORCD!E:IT

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RECIO:I I

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50-003/76-05 50-003

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50-247/76-08 Docket No: 50-247 IE Inspection Rep,rt Mo:

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DPR-5 Consolidated Edison ~ Company of New York, Inc.

License No: DPR-26 Licensce:

a 4 Irving Place Priori ~ty:

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New York, New York C

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Safeguards

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j Group:

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Loca tio n:

Buchanan, New York

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FWR, old MWt (36W)

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PWR, 2758 MWt ( W)'

Type of Licensec:

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Special, Announced Type or.,nspec t,on:

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April 6-9, 1976 Dates of Inspection:

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Dates of Previous Inspection:

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Repertin; Inspecce.: [. l? hfim E '- (s 'rJ /,.

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!ieel'//, Radiatio.1 Specialist DATE Accomptinying Inspectors:

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Streeter, Reactor Inspector DATE

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DATE None Oth r Accompanying, Personn

DATE

T Reviewed By M _-(k 6-6 ' 7 -

w e i_ a n UAIU

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?) J. Knapp, Chief, RacNation Support Section

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SUMMARY OF FINDINGS Enforcement Action

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Items of Noncompliance

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A.

Violations 1.

Contrary to 10 CFR 20.101, on April 5, 1976, an individual in a restricted area received a whole body exposure of 10.06 rem.

(Details, 3)

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Contrary to 10 i:FR 20.201(b), surveys adequate to assure compliance with the posting and control requirements of 10 CFR 20.203(c)(1) and 10 CFR 20.203(c)(2) and to assure compliance with the radiation exposure limits of 10 CFR 20.101(a) were not made, in that on April 5, 1976, unidentified radiation levels as high as 666 R/hr existed in areas accessible to personnel in the Reactor Vessel Su=p Room.

(Details, 6)

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Contrary to Technical Specification 6.11',' Station"Adminis-i trative Order (SAO) No. 105,was not adhered to on April 3, 1976, in that (1) the Maintenance Foreman and the Health Physics Technician did not jointly present RWP 076-2-204 to

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the Watch Foreman, which could have provided the opportunity

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for any required discussion of the work to be performed to c,, g, u..c r

assare that the job was properly planned, (2) the Health

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,2 Physics Technician did not enter RWP No. 076-2-204 on WP 24560

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and initial the WP signifying that the job was prepared from a radiation safety standpoint, (3) Work Permit 24560 was issued 3 ;m

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by the Watch Foreman before he had received the required,

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completed RWP, (4) a ccmplete job description, required to be L te.,: ~,2

attached to the RWP form and used as the basis for determining i

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radiation safety requirements, was not supplied, (5) the

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" Isolation and Protection Provided" section of WP 24560 was C "#M ) f "

not stamped with the words " Radiation Work Permit Required"

, and associated wording and spaces for signatures and dates,

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and (6) Work Permit 24560 remained in effect beyond the shift

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of the person.to whom it was issued and work was continued the

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following shift; however, neither the person to whom it was issued nor his relief signed and dated the reverse side of the

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WP under a heading " Transfer of Work Permit" to indicate that they had discussed the work together and with the Watch Foreman l

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or General Watch Foreman. as required.

The same Station Administrative Order was not adhered to on March 31, 1976, when Radiation Work Permit No. 076-2-149 was issued over the signature of an Outage Coordinator rather than a Watch Foreman or General Watch Foreman as required.

(Details, 4 and 5)

4.

Contrary to Technical Specification 6.8.1 and ANSI N18.7-1972 referenced therein, cautionary notes were not contained in l

Maintenance Procedure 2/3 CM-RVI 2.4 to alert the individual performing the task of the i=portant measures that should be

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taken early to protect personnel from the Nigh radiation area that initiation of step 12 (withdrawal of he incore thimbles)

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would produce in the Reactor Vessel Sump Ro>m.

Although step

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1". of the procedure required a survey of the Reactor Vessel Sump Room, it did not provide early warning to the individual

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performing the task of the radiological significance of ste.p 12.

(Details, 8)

B.

Infractions

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Contrary to Technica1' Specification 6.11, Station Adminis-4l

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trative Order (SAO) No. 105 va's not adhet:ea to on April 9, 1976, in that individuals worked in the Reactor Cavity without

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the protective equipment (respirators) required by RWP 076-2-i 45, and individuals worked on the 95' elevation of the Vapor i

Containmen't without the. protective equipment (gloves) required

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by RWP 076-2-87.

(Details, 7)

2.

Contrary to Technical Specification 6.11 and Revised Control Area' Sign-In Procedure, effective November 11, 1975, during the period of April 2-5, 1976, there were more than 60 in-stances wherein individuals failed to log the number of the RWP under which they were entering the Controlled Area.

(Details, 7)

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3.

Contrary to Technical Specification 6.11 and General Adminis-trative Directive RS-CAD-2, Revision 1, " Radiological Health

and Safety Procedures," dated February 24, 1975, areas identi-fied by the licensee as contaminated areas were not properly

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roped off and controlled on April 9, 1976, in that, (1) one i

end of rope barricade marking a contaminated area near the Boric Acid Storage Tanks in the Unit 2 Primary Auxiliary

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Building (PAB) was removed from its proper termination near the step off pad, moved approximately 900 and draped loosely

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over a hand rail, leaving a gap of approximately 12 feet in f

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- d the barricade, (2) a gap of approximately 3 feet existed in a

the barricade marking the contaminated area in the Nitrogen Storage Area of the Unit 2 PAB, and (3) the Waste Evaporator i

Room of the Unit 2,-PAB, a contaminated area, was not roped

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off and contamination control was not instituted.

(Details,

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Contrary to 10 QFR 20.203(c)(2), on April 9,1976, six high radiatica areas in the Unit 2 PAB and one high radiation area in the Unit 1 PAB established.for more than 30 days were not equipped with the specified control device or locked with positive control over each individual entry, and positive control over each individual entry into other locked, high radiation areas'in the Unit 1 PAB and Unit 2 PAB was not.

maintained in that at least one station e=ployee who was not permitted to enter such areas without authorization had a

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master key in his possession and could enter or unlock these j

high radiation areas without the knowledge or authorization of j

plant management.

(Details, 9)

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Contrary to 10 CFR 20'203(c)(1), on March 31, 1976, high.

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radiation areas were not prope'rly posted'i'n that. (1) the Reactor Vessel Sump Room had radiation levels up to 150 mR/hr and was not posted as a high radiation area, (2) cx1 April 9,,

1976, the RHR Heat' Exchanger Room had radiation levels up to

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200 mR/hr and was improperly posted as a radiation area with a-notation that the radiation field was 100-150 mR/hr, and (3)

on April 9, 1976, the general area accessible to personnel around the letdown valves in the vapor containment had radia-

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tion levels up to 150 mR/hr and was improperly posted as a

radiation area with a notation that the radiatica field was 150 mR/hr.

(Details, 10)

C.

Deficiencies

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Contrary to 10 CFR 20.203 (b), on April 9, ' 1976, a corridor in the -

Unit 2 PAB connecting the tank and surp rooms with the No. 21 and 22 RHR pump rooms had radiation fields up to 20 mR/hr and was not posted as a radiation area.

(Details, 11)

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Licensee Action on Previous 1v Identified Enforcement Action

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l Not inspected.

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Design Changes Not inspected.

Licensee Events This inspe.ction was primarily concerned wi'th an employee overexposure which occurred on April 5, 1976 and was reported to the Commission on that date.

Other Significant Findings A.

Current Findings 1.

Unresolved Items Delegation of authority to issue Work Permits.

(Details 4)

2.

Infractions and Deficiencies Identified by the Licensee Item A.l. under Enforce =ent Action was identified by the licensee and reported to the Commission in a timely manner'.

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Deviations None.

B.

Status of Previously Identified Unresolved Items

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Not inspected.

Management Interview (Site)

A management interview was coaducted at Buchanan, New York on April 9, 1976.

Persons Present

l Consolidated Edison Company of New York, Incorporated L

l Mr. E. Kessig, Assistant Vice President, Power Generation Operations Mr. W. Stein, Manager, Nuclear Power Generation Department.

Mr. S. Salay, Plant Manager l

Mr. R. VanWyck, Manager, Nuclear Services i

Mr..i. Cheifetz, Fbnager, Radiation Safety I

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-5-Mr. J. Makepeace, Director, Technical Engineering Mr. P. Epson, Quality Assurance Monitoring and Review

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Mr. S. Cantone, Chief Operations Engineer Region I, Office of Inspection and Enforcement, USNRC

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Mr. D. Neely, Radiation Specialist

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Mr. J. Streeter, Reactor Inspector, Reactor Projects Section No.1 Items Discussed A.

Furpose of the Inspection The inspectors stated that the purpose of the inspection was to review the circumstances surrounding the whole body exposure of

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10.06 rem received by an employee on April 5, 1976.

They noted

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that during the course of their review they also observed other

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items of noncompliance that were not directly related to the overex-i posure.

It was pointed out that the meeting was to be limited to a i

preliminary review of the. inspection findings Gith a more specific

,and detailed presentation to take place at a se,cond man,agemen.t

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i meeting to folloa in a few days.

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B.

Discussion Icess The items discussed are as identified under the " Enforcement Action" i

section of this report.

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Management Interview (Region I)

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A second manage =ent meeting was held at the request of Region I at the

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NRC Office in King of Prussia, Pennsylvania on April 14, 1976.

This i

meeting is documented in reports numbered 50-003/76-06, 50-247/ 76-10 and 50-286/76-12.

. Persons Present Lonsolidated Edison Company of New York, Incorporated i

Mr. W. J. Cahill, Vice President, Quality Assurance, Reliability, and Special Assistant Nuclear Licensing.

Mr. E. F. Kessig, Assistant Vice President, Power Generation Operations Mr. S. Salay, Plant Manager Mr. W. Stein, Manager, Nuclear Power Generation Department Mr. R. W. VanWyck, Manager, Nuclear Services

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Region I, Office of Insoection and Enforcement, USNRC Mr. E. J. Brunner, Chief, Reactor Operations and Nuclear Support Branch Mr. J. W. Devlin, Section Chief, Security and Investigation Section Mr. P. J. Knapp, Section Chief, Radiation Support Section Mr. D. R. Neely, Radiation Specialist, Radiation Support Section Mr. J. P. O'Reilly, Regional Director Mr. J. F. Streeter, Reactor Inspector, Reactor Projects Section No. 1 Mr. W. J. Tobin, Physical Security Inspector, Security and Investiga-tion Section Items Discussed A.

Purpose of the Inspection The meeting with Consolidated Edison Company of New York, Incor-l porated, management was held to discuss Region I concerns. related to the licensee's Health Physics Program and Physical Protection

Program.

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' Discussion Items

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The Regional Director stated the purpose of the meeting was to discuss with corporate and plant management certain areas of concern to Region I to assure that (1) the licensee was aware of the nature

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and extent of these concerns, and (2) the licensee had either completed or initiated associated corrective action.

Specific topics discussed were as follows:

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Summary discussion of inspection findings during recent inspec-tions 1.1 the areas of Health Physics and Physical Protection.

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Overexposure (10 rem) of an individual at Unit 2 on April 5, 1976.

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Adherence to Health Physics procedures and management of the

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Health Physics Program.

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Management of. the Physical Protection Program.

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DETAILS

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Persons Contacted Mr. W. Stein, Manager, Nuclear Power Generation Department Mr. R. VanWyck, Manager, Nuclear Services Mr.' A. Cheifetz, Manager, Radiation Safety Mr. S. Salay, Plant Manager Mr. T. Nespoli, Operations Engineer - Unit 2 Mr. J. Cullen, Director, Health Physics Mr. G. Liebler, Radiological Engineer I

Mr. G. Imbimbo, Health Physics Supervisor Mr. J. Perrotta, Health Physics Supervisor Mr. P. Caudio, Health Physics Supervisor i

Mr. J. Makepeace, Director, Technical Engineering

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Mr. M. Anderson, Watch Foreman Mr. F. Gross, General Maintenance Foreman

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Mr. W. Monti, Plant Engineer Mr. H. Rosenblum, General Maintenance Foreman Mr. J..Heigel, General Maintenance Foreman

"Mr. D. Giles, Maintenance Foreman

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'E Mr. L. Alverez, Maintenance Foreman

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Mr. R. Orzo, Watch Foreman Mr. S. Munoz, Outage Coordinator Mr. R. Astrab, Senior Reactor Operator Mr. P. Gilbert, Nuclear Plant Operator

Mr. D. Bishop, Nuclear Plant Operator

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Mr. I. Earlin, Nuclear Plant Operator

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Mr. S. Sadlon, Health Physics Technician Mr. R. Vogle, Health Physics Technician Mr. J. Dempsey, Mechanic A, Chief Steward Mr. J. Keenan, Union Business Agent

Mr. G. O' Dell, Mechanic A, Shop Steward

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Mr. J. Odendahl, Senior Electrical Technician, Radiation Safety

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Steward j

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Scope of the Inspection

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l The scope of the inspection was to investigate the exposure to a Nuclear Plant Operator of 10.06 rem.

This consisted of reviewing l

survey records, Radiation Work Permits, Work Permits, interviews l

with plant personnel and an inspection of the Unit 1 and Unit 2 controlled areas.

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3.

Exposure of Nuclear Plant Operator to 10.06 rem

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On April 5, 1976, at approximately 9:30 a.m.,

a Nuclear Plant

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Operator (NPO), received a whole body radiat' ion dose of 10.06 rem during an inspection of the Unit _2, Reactor Vessel Sump Room.

The exposure was reported to an NRC inspector at the site April 5, 1976. He telephoned the report to the Region I office. A follow-up report was sent to the Region I office by facsimile April 6, 1976.

Table 1 lists the sequence of events relating to the individual's exposure.

I As det iled in Table 1, the NPO had entered the controlled area, l

opened an unlocked access hatch and climbed down a ladder into the

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unlighted Reactor Vessel Sump Room using a flashlight to light his

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way, (see figures 1 and 2).

He spent a short time on the grating l

i at the 32' elevation and then climbed down a second ladder, to the 19' elevation.

There he read two of his three dosimeters (one 0-200 mR dosimeter and one of the two 0-500 mR ' dosimeters) which he found to be off scale and he immediately left the Reactor Vessel Sump Room.

Th'e NPO went to the entrance to the Controlled Area where a Health'

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Physics Supervisor confirmed that all of his dosimeters were off scale. The Health Physics Supervisor made arrangements for immediate processing of the NPO's film badge, He then interviewed the NPO.

The NPO stated that he had been checking the lighting in the Reactor

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Vessel Sump Room and that he had been in the room for about 2 minutes.

At approximately 0930, the Health Physics Supervisor and a Reactor Operator wen. to the access hatch at the 46' elevation and surveyed the area above it.

Survey results revealed that a radiation field of 1500 mR/hr was present.

The Health Physics Supervisor opened

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the access hatch, extended a Teletector survey meter probe'14'

.into the Reactor Vessel Sump Room and measured a radiation level of 250 R/hr at the point shown in figure 2.

He then locked the access hatch and the Reactor Operator affixed a "Do Not Operate" tag to it.

In order to obtain more infor=ation on the radiation fields to which the worker was exposed, the Reactor Vessel Sump Room v's a

entered twice between 1100 and 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months on the 5th.

Each entry was made by a Health Physics Supervisor.

During these entries, in addition to survey instrument measurements, dose rates were determined by wrapping two 0-5R dosimeters in plastic to absorb shock, attaching

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-9-them to a string and tossing the dosimeters over the railing in the

Reactor Vessel Sump Room.

This positioned the two dosimeters

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between the lower grating and the 19' elevation.

The dosimeter results are as follows:

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Dos. No. 1 Dos. No. 2 Avsrage R/h Test No. 1 (30 second exposure)

~4600 mR 5400 mR*

5000 mR 60C

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Test No. 2 (20 second exposure).

3900 mR 3500 mR 3700 mR 66!

It was estimated from these dosimeter results that the Nuclear Plant Operator had bden exposed to radiation fields of up to 11 R/ minute.

The licensee's 30 day report, dated April 29, 1976, stated that,

"the maximum radiation field to which this individual was exposed was approximately 600 R/hr." In view of this, the radiation levels described above were confirmed in a telephone contact with a licensee representative on May 4,1976.

,0n the afternoon of April 5 the h;PO,was taken,to the. Unit 3 Reactor

,4 Vessel Sump Room which is a duplicate of that in Unit 2.'.

Bccause the Unit 3 reactor was not yet licensed to operate there were no radiation fields in that location.

Here, he was asked to duplicate his actions and based on his reenactment it was estimated that his a

time.in the Unit 2 Sump Room totaled 100 seconds.

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A licensee representative stated that film badge results were l

received at 1700 hours0.0197 days 0.472 hours 0.00281 weeks 6.4685e-4 months , establishing that the Nuclear Plant Operator

received a whole body exposure of 10.06 rem.

The inspector noted

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that this constituted noncompliance with 20.101.

4.

Work Permit and Radiation Work Permit System

In order to assure that all necessary measures are'taken in connec-tion with work performed, the licensee utilizes a Work Permit l

System (specified by Station Administrative Order No. 105, Revision l

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3, dated March 1, 1975.) The provisions of this system are summarized

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briefly here as an aid in following the chronology of events described

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in a later section.

The steps to be taken are controlled and documented by means of a permit, called a Work Permit (WP), which is prepared and utilized as follows:

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This exposure.vas estimated by the licensee since the hair line was

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beyond the scale range of the dosimeter.

Test No. 2 was performed to I

develop more reliable data, i

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-10-A foreman with a task to accomplish consults with the Watch Foreman, (the highest level of operating management who is responsible for all activities carried out at the unit during his shif t) or the General Watch Foreman (r te next higher level of management, responsible for all units).

An Operating Order, which requires all necessary isolation, lockout, inspection, and other safety measures, must be issued and its provisions must be carried out and docu=ented with signature on the Work Permit.

If the Work Permit is to authorize work within the controlled area, an additional document, a Radiation Work Permit, which is designed to ensure that all necessary radiation protection measures are taken, must be prepared and approved.

.i state-ment to this effect must appear on the Work Permit.

In the preparation,and issuance of a Radiation Work Permit (RWP) the following must be done; (1) the initiator must prepare the first section of the RWP including a complete description of the job, and he,must discus,s the, work with a

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representative of the Health Physics organization, (2) based on his understanding of the work, the Health Physics repre-sentative must complete and sign the second portion of the RWP form specifying the radiological protection measures which must be provided, both individuals must sign and date the RWP form, (3) after the required radiation protection has been provided and verified by both individuals, they must jointly j

bring the form to the Watch Foreman and af ter any required

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discussion and presuming all parties are in agreement the Health Physics represents'..ve must enter the RWP number on the WP and initial and date it signifying that the job has been prepared from a radiation safety standpoint, (4) the Watch Foreman may then sign and issue the RWP.

The Watch Foreman is prohibited from issuing a Work Permit until a required RWP has been issued according to the steps outlined ab6ve.

Once the RWP has been issued the Watch Foreman may then sign and issue the Work Permit.

Whenever a Work Permit remains in effect beyond the working hours of the person to whom'it has been issued and the job is to be continued, that person must report with his relief to the Watch Foreman before leaving the plant and discuss the work and protection provided.

Both must sign the time and date on the reverse side of the Work Permit which has been stamped ". Transfer of Work Permit".

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-11-d The inspector reviewed the steps involved in the issuance of Work Permit No. 24560 and the associated Raciation Work' Permit No. 076-2-204.

A similar review relating to other Work Permits and Radia-tion Work Permits, including RWP No. 076-2-149 was conducted. The inspector identified, through examination of the appropriate documents and through the statements s cognizant licensee per-sonnel, the following instances of failure to follow the require-ments of Station Administrative Order No.105:

The Maintenance Foreman and the Health Physics Technician did not jointly present RWP 076-2-204 to the Watch Foreman, which would have provided the opportunity to discuss the work to be performed, and arrive at agreement among all parties that the job had been prepared from a radiation safety standpoint.

The Health Physics Technician did not enter RWP No. 076-2-204 on WP 24560, and initial the WP signifying that the job had been prepared from a radiation safety standpoint.

Work Permit 24560 was' issued by the Watch Foreman before he

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had received the required, c'ompleted RWP.**

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A complete job description, required to be attached to the RWP form and used as the basis for determining radiation safety requirements, was not supplied.

The " Isolation and Protection Provided" section of WP 24560 was not stamped with the words " Radiation Work Permit Required" and other required wording and spaces for signatures and dates and it had not been signed and dated as required.

Work Permit 24560 remained in ef fect beyond the shif t of the person to whom it was issued and work was continued on following shifts. However, neither the person to whom it was issued nor his relief signed and dated the reverse side of the WP under a heading " Transfer or Work Permit," to indicate that they had discussed the work together and with the Watch Focecan or General Watch Foreman, as required.

Radiation Work Permit No. 076-2-149 was issued by an Outage Coordinator on March 31, 1976, and not by a Watch Foreman or General Watch Fore =an as required.

A memorandum was issued March 29, 1976, designating personnel in addition to the Watch Foreman who were authorized to sign and issue

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-12-The authorized personnel included two Outage Coordina-Operats s and all Work Permits.

tors, one Engineer Trainee, all Senior Reactor Reactor operators assuance by the Senior Reactor Operator and b

f Reactor Operators was limited to activities conducted by mem ers o The licensee stated that this change the Operations Department.)is authorized by SAO 105; which simply be issued by a General Watch Foreman, a Watch Foreman or any othe d by the management employee provided written approval is granteThe ins diation Work Station Manager."

only to Work Permit approval and issuance and not to RaT Unresolved Item pending further review by the inspector.

Permits.

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As noted below and in section 5, the Nuclear Plant Operator actua i ities.

entered the Vessel Sump Room to perform relamping issued to cover this activity.149, relating to this work, was issued b h

In connection with the incident in the Reactor Vessel Sump Room t e fellowing Work Permits and Radiation Work Permits are pertinent:

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'E (RWP)No.076-2-130,"installIeactor Radiation Work Permit Cavity Sump Pit Pumps," (associated Work Perm i

Watch Foreman, covered installation of reactor cavity sump p t pumps at the 19' elevation in the Reactor Vessel Su=p Room.under th l

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076-2-130 Instructions on RWP No.

Protection Provided," were, " Contact EP before doing any drilling."

076-2-149, " Lamp up V. C." (Vapor Radiation Work Permit No.

31, 1976, at 1630 by an outage Containment), was issued thrchA licensee representative stated that no Specific,instruc-Coordinator.

Permit was issued to authorize chis work.

076-2-149 were, " Observe all radiation tions documented on RWP d HP area signs and obtain dose rate measurements from assigne j

for all areas requiring changing of Lamps".

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076-2-153, "Take Measurements" (The Radiation Work Permit d March associated Work Permit could not be found) was issueThis RWP, which 33. 1976, at 0900 by the Watch Foreman.

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-13-

.

'

authorized personnel to take mecsurements at the 19' elevation

-

in the Reactor Vessel Sump Room, had specific instructions,

"HP to accompany work party to obtain dose rate measurements."

.

. Radiation levels indicated on the RWP were, " Variable (as

.

a determined by HP in work areas)" and the allowed time in the j

area was given as, "As determined by NP".

Radiation Work Permit No. 076-2-202, " Remove and store incore

'

detectors (remove from reactor and store on 19' elevation-in v.c.)," was never officially issued or used.

Special instruc-tions were, "HP to be present at storage locations to check for change in field conditions." The RWP was refused by a Maintenance Fore =an because it provided no radiological protec-tion measures for working on the Seal Table at the 68' elevation.

A Representative of the Health Physics unit and the Mainten-ance Foreman, both agreed, however, that an RUP was needed to

'

specifically cover Seal Table work at.the 68' elevation, (it was later issued as RWP No. 076-2-204). The HP thought that RWP No. 076-2-202 would be issued later to cover the actual thimble withdrawal.

Radiation Work Permit No. 076-2-204, " Disc'onnect t*ubing and ""

'

pull detector tubing back up," was issued 4/4/76 at 0420 by the Watch Foreman, to cover work on the seal table at the 68'

elevation.

On April 3, 1976, at 2010, prior to the issuance of the RWP, associated Work Permit No. 24560, " Move Seal Table and Remove Fixed Incore Detectors" was issued by the Watch.

{-

Foreman. Based on information from HP transmitted by a Mainten-ance Foreman, the Watch Foreman believed that the thimble

withdrawal could present a radiation problem, and wrote special

.

instructions on Work Permit No. 24560 as follows, " Caution, Notify HP's prior to withdrawing fixed incore detectors." The Maintenance Foreman subsequently followed this instruction.

When he did so the Health Physics representative told him that

,

further notification prior to pulling would not be required because permits covering work in the sump area would be tabled.

!

l

..

-

.

..

.

-

.

5.

Chronology

-

i-14-

-

,

-'

The following table was constructed on the basis of extensive review of records and

i-permits and interviews with many of the persons involved.

.

ble 1, Chronology of Events Relating to 10.06 rem Exposure llealth Physics Re-Lamping Thimble Sump Pump Measure.

te/ Time Management Actions Actions

Activities Withdrawal Activities ment Activities i.'

.

31/0400

---

Initial survey of Vessel Sump

---

.

!

Room after reactor was shut mi down - survey completed, 150

.

mR/hr field measured, access hatch in grating locked closed y

I f

!

31/0900 Watch Foremen signed Endorsed RWP No. 076-2-153,

---

and issued RWP No. 076- "Take Measurements" (Vessel j

2-153 "Take Measure-Sump)

ments" (Vessel Sump)

ast,?mted Work Permit

,

alv-aued

---

--

I 31/1630 Outage Coordinator ap-Endorsed RWP No. 076-2-149 I

proved and issued RWP

" Lamp up vapor containment"

No. 076-2-149 " Lamp up vapor containment",

an

,

associated WP was not issued

_

'1/2000*

---

Surveyed vessel sump area

---

--

again, found 50 mR/hr radia-V j

tion field, access hatch in

grating, locked closed again

'

t i

ndicates estimated time.

!

t

-

i i

i

.

e

-..

--

~.. - _..

._

.

- _. -

_ __

_ _____

_,_

-

-15-

-

V

.

Sump.Purp M2asurc I '

IIcalth Physics Re-Lamping Thimble

' *

e/ Time Fbnagement Actions Actions Activities Withdrawal Activities ment Activities

---

--

A worker in the netime be-I operations de-

---

2en 4-1/2000 partment, was in -

structed to, and i unlocked access i

'

hatch in grating based on 50' mR/'S'

observed 4-1 s,

A l'

to permit work to be done there Construction

.

3/0830 Watch Foreman issued Endorsed RWP No. 076-2-130

--

Foreman picked up RWP No. 076-2-130, "In-

.

stall Reactor Cavity did not commence -

Sump pit Pumps," and work associated WP No. 24621 i

.

'.---

Construction

-

3/sometime Foreman requested

---

etween 0830 of IIP that access id 2000 hatch be unlocked

,

so that work I

n could begin r

WP No. 24621

,

i 13/1000*

Outage Coordinator llP Supervisor A (who was

---

--

'

requested an RWP to actit.g as Unit 2 IIP super-l cover the withdrawal visor from 0800-1200) dis-

'

l of 8 fixed incore de-cussed job with Outage

'

Coordinator and llP Techni-

l

-

tectors cian, instructed IIP Techni-clan to indicate on RUP 076-2-202 that, "llP to.be

,

present at storage location

to check for change in

,

field conditions" M

'

~^

- - -

.

~.-%#,m...._

d

-- -

- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_

-16-

.

!

f; t

f.

IIcalth Physics Re-Lamping Thimble Sump, Pump Mercure.'

tc/ Time Management Actions Actions Activities Withdrawal Activities ment Activities

" *

3/1020*

---

Attempted to endorse RWP No.

---

taintenance Foreman

---

076-2-202, " Remove and stbre rejected RWP No. 076-

2-202, because it incore detec.or,s," this was rejected by the Maintenance specified work at the 19' elevation (see Foreman, RWP included state-

,

Figure 1) and the job i

ment " IIP to be present at

storage location to check was to take place at

~

-s the 68' elevation

.

for change in field *condi-tions"

-3/1200

-

IIP Supervisor Shift Change

---

,

Shift Change Shift Change Shift Change

--

-3/2000 Shift Change

.---

---

-3/2010*

Watch Foreman issued

---

WP No. 24560, " Move Seal table and remove fixed incore detectors" although the associa-

'

,

ted RWP, No. 076-2-204, had not yet been issued, this was contrary co requirements of SAO

.

105

-

'

IIP Supervisor B and another

---

-3/2045*

t IIP Technician discussed thimb1'e withdrawal operation at 68'

[

elevation with Mbintenance Foreman, RWP not prepared, i

because llP preparation of job not complete, IIP Supervisor B quoted a number (076-2-204)

to the Maintenance Foreman and

"

'

told him, " IIP is to be notified at. commencement.of Pulling" i

_

- - - -

.

_ _

. - _ _

_ -,

.

_

,

-17-

-

.

llealth Physics Re-Lamping Thimble Sump Purp Measure '

tc/ Time Management Actions Actions Activities Withdrawal Activities ment Activities

-

l 3/2050*

Maintenance Foreman

---

--

---

,

told Watch Foreman that t

t IIP was to be notified i

at commencement of

-

thimble pulling, at

this time the Watch

Foreman documented A;

this statement on WP 24560

,

4/0000

---

IIP Supervisor Shif t Change

--

---

--

'

4/0330*

---

IIP Supervisor C told Mainten-RWP No. 076-2-Maintenance Foreman WP No. 24621 and ance Foreman that contrary to 149 still went to llP to pick associated RWP No statement made 4-3/2045*, llP, valid and in up RWP No. 076-2-204 076-2-130 still

-

did not need to be notified'

effect valid and in prior to pulling because, effect

" Permits for work in the sump

,

?

,*

area would be tabled", he'

1ater stated he said this be-

-

cause he understood that RWP

-

076-2-202 would be issued to cover thimble withdrawal after m

preparations for withdrawal had been accomplished under RWP No. 076-2-204 and he*

looked on tabling the RWP's as an additional precauti.on

,

i 4/0420 RUP No. 076-2-204 " Dis-RWP No. 076-2-204 endorsed Shortly after 0420

---

l

'

connect tubing and pull by llP who instructed Main-maintenance work begun

'

detector tubing back up" tenance to decontaminate at seal table, 68'

f (work location was the seal table

clevation

i specified as 68' Vapor Containment) issued by

Watch Foreman, associated

-

WP No. 24560 had been

,

previously improperly issued j

__

vgws

.

Ilealth Physics Ke-Lamp ing Thimble Sump Purp Meesurs.,

Activities Withdrawal Activities ment Activities ate / Time Management Actions Actions

.

Shift Change Shift Change Shift Change j

'

---

-4/0800 Shift Change I

---

1 /0830*

Outage planning meeting

---

1

.

held, during the meeting

!

the Operations Engineer asked that a radiation I

survey be made in the

'

Vessel Sump Room after

.

,

the thimbles were with-drawn

___

---

!!P Supervisor Shif t Change

---

-4/1200

---

At Seal Table Mainten-

---

ance pulled first thim-

-4/1500*

ble 25' according to Section L of Maintenance Procedure No. 2/3 CM-RVI 2.4 " Removal of Reactor Vessel Upper Internals

,.

and Closure head", work

{

.

was done during this

shift although WP No.

24560 was not signed and dated on the reverse side under a heading " Transfer m,

of work permit", as re-

quired by SAO 105

,

.

e

.

M

,

._

-

,--

7_

^

-

.

__

llaalth Physics Re-Lamping Thimble Sump Puap Mercur -

ate / Time Management Actions Actions Activities Withdrawal Activicies unnt Activities.'

-4/between

---

11P technician went to

---

Maintenance working on

,

---

500 and 1830 68' elevation seal table withdrawing additional

!

area in response to air g thimbles borne activity alarm, at

'

that time one thimble could

'

be observed to be in the withdrawn position but ilP stated that he did not

'-

.

see it-4/1830*

Maintenance Foreman

---

All fifty thimbles with-

---

notified Watch Foreman drawn, Maintenance Proce-that all thim'bles had dure No. 2/3 CM-RVI 2.4 been withdrawn

Complete through Step 12, Maintenance encountered difficulties at Step 13

therefore did not go on to Step 14, Step 14 reads,

" IIP to make radiation sur-veyaof area under vessel"

-4/2000 Shift Change Shift Change Shift Change Shift Change Watch Foreman for pre-vious shift passed on

,

information to new l

'I Watch Foreman that all

.

thimbles were withdrawn

-

!)

,

---

Work resumed at 68' ele-i l-4/2030*

---

.---

vation under maintenance

,

Prucedure No. 2/3 CM-RVI

-

2.4 although WP No. 24560 i

was not signed and dated

,!

on the reverse side under a heading, " Transfer of

,

Work Permit", as required by SAO 105 M

_ _ _ _ _ _ _ _ _ _ _ _

--r---

--_

--

__-S

. _. - _ --.

_

,_

'

-

t

.

,. -

IIcalth Physics Re-Lamping Thimble Sump Pump Measure *

ste/Tioe Management Actions Actions Activities Withdrawal Activitici ment Activities

.

-5/0000 A Nuclear Plant Operator IIP Supervisor Shif t Change

---

stated that he observed

.

that the access hatch was locked about 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months be-

l fore the overexposure

-

occurred.

-5/0800 Shift Change Shift Change Shift Change Shift Change-5/0820*

A Unit 1 Watcih Foreman When an individual from Work resumed at 68'

An individual

,

who was assisting an construction unit re-elevation under Main-from construction i

Outage Coordinator quested RWP No. 076-2-tenance Procedure No.

unit came to HP in the Unit 2 outage 153, the llP representative 2/3 CM-RVI 2.4 al-representative

,

work, authorized the told him that he could though WP 24560 was and asked for RWP affixing of a "Do Not not have it because llP not signed and dated No. 076-2-153, HP Operate" tag on the ac-was tabling all RWP's re-on the reverse side refused to give cess hatch,.this would lating to the Vessel Sump under a heading it to him

serve to prevent persons Room because thimbles were

" Transfer "of Work from entering the high to be withdrawn soon and Permit," as required-i radiation area, tag was a significant radiation by SAO 105 not yet affixed field would exist there.

The IIP, assuming that the NOTE: Work on step 13 The Operations Engineer, access hatch was locked. -

at the seal knowing that the thim-instructed the individual table was com-bles had been withdrawn, from the construction unit pleted later in believing this could to contact the Watch the day

{

present a radiation Foreman and request that problem, but also be-a "Stop Tag" be placed on

'

lieving existing RWP's the access hatch and WP's were adequate to assure safety, then

-

ordered the Unit 2 Watch Foreman to provide

lighting in the Reactor

Vessel Sump Room

,

.

k

_ _ _ _

__

_

. _ _. _ _ _

_ _ _ _ _

_ _.

_ _.. _ _ _

.

_ _ _ _ _

_ _ ___ _ _ ___ _

_..

__

_ _ _ _. _ _

_

.

_

-

-21-

-

.

licalth Physics Re-Lamping Thimble Sump Pump Measure l

,

ste/ Time Management Actions Actions Activities Withdrawal Activities ment Activities.

,

---

Nuclear Plant

---

-5/0825*

Watch Foreman gave order

'

---

to have Nuclear Plant

Operator was in-structed to enter Operator enter Vessel the Vessel Sump Sump Rocm to check for

. Room to check lighting, because Watch Foreman had been off lighting, he selec-

'

ted RWP No. 076-2

.

_

the previous day and had-149 (see row

,

not been inforned, he

'

headed 3-31/1630)

did not know, that the

,

as authority to thimbles had been with-accomplish the work

,

drawn

.

A construction

---

-5/0830*

Outage Planning meeting The llealth Physics super-foreman, with RWP held, during the meeting visory representative 076-2-130 in his

-

the Operations Engineer agreed to provide the Opera-asked for results of tions Engineer with the re-

, possession, appro-

ached,the access

the survey of the Vessel sults of the survey o,f the hatch intending

'

f Sump Room

.

Vessel Sump Room, at this to enter'the Ves-time the supervisory repte-

,

sel Sump Room. The

Outage Coordinator, sentative did not know hatch was found to.

j using the plant paging that the thimbles had been system tried to locate withdrawn.

.

be unlocked (see

'

row headed,.c

-

the holder of RWP No.

time between

./

076-2-130 so that it 2000 and 4-2/2000)

-

,

could be tabled However, because

[

there were no lights in the Ves-sel Sump Room he

-

.

did not enter but exited the area to request that l

-

lights be instal-

'

led. At the exit

'

to the controlled area the llP tabled

'

RWP No. 076-2-130.-

i M

,

__

_

v'r

-

- - - -

y-

- +

_ _ _ _ _ _ _ _. _ _ _.

_.. _.. - _ _ _ _ _.. _. _ _ _ _ _ _

_ _ _. _ _

_ ___ _. _ _ _

.. _.. _ _ _ _ _. _... _ _ _ _

.._...

-22-

[

Re-Lamping

.

,

'

Health Physics Activities

,

Actions

-

.s i! :c/ Time Management. Actions t

!

,

. l.

The NPO signed in at the entrance to the controlled

'

5/0845 area, entered and went to the Vessel Sump Room access !

---

hatch, (see figure 2), where he noted a sign with a

,

l l

radiation symbol stating, "30 to 40 mR/hr below

!

i He opened the access hatch which was not grating".

'

I locked or tagged, and went down into the Vessel Sump

'

i-Using a flashlight, the NPO walked across the Room.

grating on 32' elevation to a railing, checked lighting l

needs, went to the second ladder, and climbed down *he

'

second ladder to the 19' elevation. At this time

'

.

NPO read two of his dosimeters (one 0-200 mR and one

,

l 0-500 mR) with the aid of the flashlight, observed the Vessel i

them to be off scale, and immediately 1cft It was later estimated that his total time

[

Sump Room.

l inside the access hatch wcs approximately two minutes.

[

The NPO notified HP and telephoned the Senior Reactor

[

-5/0900*

As NPO exited controlled HP, confirmed dositeter in turn, notified his supervisor, that j

readings, removed badge, Operator who, his dosimeters were off scale. Then he went to the l

area a Reactor Operator came to the control point carrying questioned NPO and wentto the access hatch with entrance to the controlled area.

Here his. dosimeters o

the, "Do Not Operate" tag were confirmed off scale, his film badge was removed f

the Reactor Operator

[

authorized for*the access and he was questioned by HP.

l j

hatch 0920* by the Watch

\\

,

'

Foreman

!

,

-5/0930*

Watch Foreman interviewed HP and Reactor Operator

-

l

---

nmde measurements shown I

the NPO in figure 2 from acpess

,

hatch. The access hatch t

!

was locked and the "Do j

j Not Operate" tag was t

'

i attached

.

!

,

i

.

' Indicates estimated time.

.

-

i

- - - - - - - - - - - -. -..-.

_. __ _ _ _ _

'

We-.m%en,,

,

Y

.

--

-_

_.

,_m__.

\\

8,

-

.

-

L,_..

.

,

'

-23-

-

'

,

_.

6.

Evaluation Requirements 10 CFR 20.201 requires that each licensee make or cause ta be made such surveys as may be necessary to comply with the regulations of 10 CFR 20.

This section defines a survey as an evaluation of the radiation hazards incident to the use of sources of radiation under a specific set of conditions and notes that where appropriate such an evaluation includes a physical survey and measurements of radia-tion levels.

.

The inspector stated that an evaluation of the radiation hazards incident to the withdrawal of the thimbles and subsequent entry of the Reactor Vessel Sump, Room was not adequate to permit compliance with 10 CFR 20.201 on April 5,1976 in that due to the inadequacy of the evaluation an employee received an exposure of 10.06 rem.

He further noted that the posting and control requirement of 10 CFR 20.203(c) were not complied with, apparently for the sa=c reason.

.

7.

Radirtion Work Permits, Sign-In Procedures and Control of Con-taminated Areas Tephnical Specification 6.11' requires that procedures for personnel

radiation protection be prepared consistent with the requirements of 10 CFR 20 and approved, maintain,ed and adhered to for all opera,

tions involving personnel radiation exposure.

Station Administrative Order (SAO) No.105, Revision 3, " Work

.

Permits," dated March 1, 1975 was issued in accord.iith this requirement.

It requires that Work Permits and Radiation Work Permits be issued.

On April 9, 1976 an inspector examined RWP No. 076-2-45 covering work on the 95' elevation of the Vaoor Containment.

He noted that the RWP required the use of respirators.

The inspector then observed the job and saw that two maintenance workers involved in head detensioning were not wearing respirators.

The inspector stated that this was contrary to the requirements of the RWP.

He later noted that this constituted noncompliance with Technical Specification 6.11.

The HP Supervisor immediately took action requiring the workers to don respirators.

On the same date, the inspector observed individuals working on the 95' elevation of the Vapor Containment under RWP No. 076-2-87.

The inspector observed that contrary to the requirement of this RWP, the workers were not wearing gloves.

The EP Supervisor took action to have this matter corrected immediately.

Revised Controlled Area Sign-In Procedure, dated November 11, 1975, was issued in accord with the requirements of Technical

.

- - - - -

---

-

, - - -

- -, - - -

vv-m--

--w

--e

,

_

'.

.-

.

s

<

.

~

-24-

_

Specificati.on 6.11.

It required certain types of information to be entered on the sign-in sheet by individuals entering or leaving the Controlled Area, and among other things, it required each sign-in entry to include a statement of the RWP number

-

under which work, requiring the entry, was done.

The inspector l

selected, at random, some of the sign-in log sheets filled out Observation

!

during the period from April 2 to April 5, 1976.

f One revealed 65 entries for which no RWP number was listed.

of these entries was that made by the Nuclear Plant Operator as he made the entry to the Controlled Area which lead to his 10.06 rem exposure.

The inspector stated that was contrary to the requirements of the sign-in procedure.

General Administrative Directive RS-GAD-2, Revision 1, " Radio-logical Health and Safety Procedures," dated February 24, 1975 i

was issued in accord with the Technical Specification Require-It requires that areas be roped off and contamination ments.

control instituted when removable radioactivity exceeds 1000 dpm per 100 square centimeters.

i'

The inspectors observed the following on April 9, 1976; (1)

I one end of a rope barricade marking a contaminated area near

-

the Boric Acid Storage Tanks in the Unit 2 Primary Auxiliary 9g i

Building (PAB) was removed from its proper termination near the step off pad, moved approx'imately 90 and draped loosely

,

'

over a hand rail, leaving a gap of approximately 12 feet in the barricade, (2) a gap of approximately 3 feet existed in the barricade marking the contaminated area in the Nitrogen Storage Area of the Unit 2 PAB, and (3) the Waste Evaporator Room of the Unit 2 PAB a contaminated area, was not roped off and contamination control was not instituted.

A licensee representative stated that the first two areas were

,

areas that required contamination control under company control procedures. Rebarding the third area, the inspector observed a record of a survey made on April 8,1976 which indicated

<

removable contamination levels of up to 4000 dpm per 100 square centimeters.

The inspector identified these instances as examples of noncompliance with RS-GAD-2.

8.

Maintenance Procedure Covering Thimble Withdrawal

Adequacy of Procedure 2/3 CM-RVI 2.4 As noted in the row headed 4-4/1830* in the chronological table,

Step 14 of Maintenance Procedure 2/3 CM-RVI 2.4 which states, "H.P.

'

to make radiation survey of area under vessel," had not been arrived at because of a, delay in implementing Step 13 and was not accom-plished. The inspector noted that since Step 12 (withdrawal of the

_.

_

_- __ _ ____ _ _

__

_. _ _ _

.

_ -.

__.._._ _.

. _

.-_

"

.....

.

_

.t

-

p.t.

-

.

--.

... - -

,

f

'

.

-25-i i

incore thimbles) was expected to produce high radiation fields at the 19' elevation in the vicinity of the reactor vessel, a require-l ment for a survey at step 14 was out of sequence.

-

Technical Specification 5.8.1 states in part, " Written procedures and administrative policies shall be established, implemented and-j maintained that meet or exceed the requirements and recommendations

,

'

of Sections 5.1 and 5.3 of ANSI N18.7-1972."

'

,

l Under Section 5.3 of ANSI 18.7-1972,." Operating and Maintenance

,

l Procedures," Subsection 5.3.2.5, " Precautions," reads,

" Precautions should be established to alert the individual performing the task to those situations in which important measures should be taken early or where extreme care should be used to protect equipment and personnel, including the public,

-

,

or to avoid an abnormal or emergency situation.

It may be

convenient to specify precautions separately.

Cautionary notes applicable to specific steps in the procedure should be included in the main b.ody of the procedure and should be identified as such."

yg

-

. -

..

)

As mentioned above, Maintenance Procedure 2/3 CM-RVI 2.4 did not

.

alert the individual performing the task to a situation (the creation of a hazardous radiation field in the Reactor Vessel Sump

,

j Room), in which important measures (survey, identification as a high

'

radiation area, posting and specified control) should be taken early.

Also, as mentioned above; (1) the requirement to survey came in Step 14 instead of Step 12 which created the high radiation

'

area, and (2) problems encountered in accomplishing Step 13 caused a delay and Step 14 was not undertaken at all.

Although the procedure contained many cautionary notes regarding non-radio-logical matters, there was no cautionary note alerting personnel to 3'

the potential radiological ha:ard that would be created through l

.

implementation of Step 12.

,

l The inspector noted Maintenance Procedure 2/3 CM-RVI failed to alert personnel in advance of the potential radiological hazards

'

involved in withdrawing incore instrumentation thimbles, and that this appeared to be a violation of Technical Specification 5.8.1 because an adequate procedure could have prevented the overexposure of the individual on April 5, 1976.

A licensee representative stated that he recognized after the overexposure that the procedure

'

was inadequate and intends to process a revision to the procedure.

, - -,.

.,-

_

m-

---

-.,

-

-,,,w--

-r

-

--.--wy

t (

-

,

..

.

-26-Procedure Review i

The inspector asked if the Health Physics Unit had reviewed Main-tenance Procedure 2/3 CMRVI 2.4 in view of the fact that it had the l

potential for creating hazardous radiation fields.

A licensee j

representative stated that the Chairman of the Stati.. Ncelear

,

Safety Committee (SNSC) had the authority to determine which

procedures were reviewed by the Health Physics Unit and that in this case, it was decided that Health Physics review was unnecessary.

A licensee representative subsequently stated that in the future all procedures dealing with work in the controlled area will

,

require Health Physics review and the SNSC Charter will be revised to reflect that requirement.

The licensee also stated that Unit 2 procedures not previously reviewed by Health Physics personnel will

,

undergo such review which had already begun.

9.

Control of Hich Radiation Areas

On April 9, 1976 the inspect. ors observed the following high radiation areas which were reported to have been established for more than 30

~

d'ays, were not equipped with control' devices and'which had been f

left unlocked and unattended.

!

RER Pump Room No. 21 (Unit 2):

The licensee reported that this was a high radiation area.

The area was posted as a high radiation area and an airborne area.

PAB Sump Pump and Tank Room (Unit 2):

The inspector measured s 400 mR/hr at the entrance to the room at 18" from accessible surfaces.

It was posted as a high radiation area.

Ion Exchange Valve Gallery (Unit 2):

The inspector measured s 400 mR/hr at 18" from accessible surfaces.

The area was posted as a high radiation area and a dose rate of 100 mR/hr was specified.

Three adjoining Charging Pump Cubicles (Unit 2):

The licensee reported that they contained high radiation areas.

They were posted as such.

One was posted as airborne radioactivity

area, f

Gas Decay Tank Room (Unit 2):

The inspector measured s 125 i

mR/hr at 18" from accessible surfaces.

It was posted as a j

high radiation area.

s

.

_. - - - -

-.

.

. _ - - - - -

-

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Sample Room (Unit 2):

The inspector observed that the entrance

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to the area was posted as a high radiation area but did not have any provision for preventing entry.

The licensee stated'

l that donc rates of up to 500 mR/hr, accessible to personnel, existed in the area.

'

.

42' Pipe Chase (Unit 1):

The inspector observed that elec-

_

trical cables and hoses had been laid through the doorway which p cvented closing and locking of the door.

The inspec-

'

I tor asked a licensee representative if personnel were working in the r'oom and he stated that' the workers vere out of the

'

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area because it.vas their lunch hour.

He further stated that

'

the vorhers had been given instructions not to leave this arca

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unattended..In addition, the licensec representative stated l

the electrical cabics and hoses would be removed so the door

!

could be locked.

The inspector noted that an item of noncon-l pliance* had resulted from observations on December 9 and 12,

'

1975, when a door to another high radiation area in Unit 1 was

'

found standing open and unattended.

,

A member ef licensee canagement stated that although Techni. cal h

Specification 6.13.1 of license DpR-26. contained.citernato provisions

for the contrcl of areas in which dose rates c::cceded 100 cR/hr,

.

the licensee does not utilize these alternate provisions of the Technical Specifications because workers are not trained to use the

,

necessar survey instruments.

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The inspector determined from review of key controls for high

{

radiation areas that management.vas not aware of all persons having l

master keys to high radiation area locks.

The inspector stated I

j that this demonstrated lack of positive control over each individual

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!

entry as required by 10 CFR 20.203.

i

.

The inspectors noted that failure to centrol these high radiation i

areas constituted noncompliance with 10 CFR 20.203.

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Sec Inspection Report No. 50-003/75-11

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10.

Tour of containment

.

On April 9, 1976, the inspectors toured containment to observe the implementation of radiological protection controls including centain-ment entry controls, posting of high radiction areas, and adherence to the provisions of radiation work permits (RUps).

The inspector's

'

findings with respect to adherence to the provisions of RWPs is discussed in Detail 7.

The inspector's findings with respect to'

the other areas observed during the tour are as follow:

-

a.

Personnel Access Hatch'at Elevation 79

-

On April 9, 1976, at approximately,10:00 a.m.,

the inspectors entered containment through the 79' personnel access hatch under the escort of a health physics supervisor.

The inspectors

.

noted prior to entering containment, that the containment entrance was not posted a's a high radiation area or a radiation area. The health physics supervisor stated that he had previously posted the entrance as a high radiation cran but acknowledged that the entrance was not posted.at that time.

The supervisor we

-

immediately posted the entrance as a high radiation area in

,

the presence of the inspectors..

.The inspectors noted that the licensee's failure to post the 79' personnel access hatch was contrary r the licensec's stated practice of posting the containmc.tt entrances rather than posting individual high radiation areas within containment.

.b.

Posting of High Radiation Areas The inspectors made the following coasurements and observations with respect to posting of high radiation areas within contain-ment:

(1) The inspectors measured radiation Icvels up to 200 mR/hr in the RHR Heat Exchanger Room.

The area was posted as a

-

radiation area with a. notation that the radiation field was 100-150 mR/hr.

'

(2) The inspectors measured radiation levels in the area around the letdown valves, and found radiation levels up to 150 mR/hr.

The area was posted as a radiation area

rather than a high radiation area with a notation that the radiation field was 150 mR/hr.

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In addition to the items described above, during the course of the inspection, the inspectors reviewed survey records which h

revealed another high radiation area had not been properly posted.

On March 31, 1976, a survey taken in the Reactor Vessel Sump Room, revealed radiation icvels up to 150 mR/hr.

The individual who perforced the survey stated that the acc. css

'

hatch had been locked but that he had not posted the area as a high radiation area.

The inspectors also noted that a radiation survey log sheet,, dated March 31, 1976, 0400, documented that

,

the area was locked and that radiation warning signs had not been posted.

.

10 CFR 20.203(c)(1) requires that each high radiation area be

,

conspicuously posted uith the radiation symbol and the words,

,

" Caution, High Radiation Arca." The above described high radiation areas were not posted as high radiation areas.

This is'an Item of Noncompliance of the Infraction level.

"

..

.

11.

Posting of Radiation Areas 10 CFR 20.203(b) requires that each radiation area be conspicuously posted with a sign or signs bearing ~the radiation caution symbol and the words, " Caution, Radiation Arca."

.

Contrary to the above, on April 9, 1976 the inspector measured radiation levcis up to 20 cR/hr in a corridor of the Unit 2 PA3 connecting the tank and sump rooms with the no. 21 and 22 RilR pump rooms.

The inspector noted that the area was not posted as a radiation area and that this constituted noncompliance with 10 CFR 20.203.

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v t e Inspection Report - Indian Point - 1976005
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1976 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 10(0) 11(0) 12(0) 13(0) 14(0) 48(0) 9(0) 13(0) 26(0) 30(0) 16(0) Security Operator Exams Emergency Planning Other

IR 05000003/1976005

Text

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