IR 05000219/1987039

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Reactive Insp Rept 50-219/87-39 on 871102-06.Violations Noted.Major Areas Inspected:Unauthorized Entry Into Drywell & Apparent Breach of Access Door Integrity to Locked High Radiation Area
ML20149D757
Person / Time
Site: Oyster Creek
Issue date: 12/23/1987
From: Shanbaky M, Sherbini S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149D739 List:
References
50-219-87-39, NUDOCS 8801130114
Download: ML20149D757 (5)


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U. S. NUCLEAR REGULATORY COMMISSION

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REGION I

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Report No.

50-219/87-39 Docket No.

50-219 License No. DPR-16 Licensee:

GPU Nuclear Corporation P.O. Box 388 Forked River, New Jersey 08731

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Facility Name: Oyster Creek Nuclear Generating Station Inspection At:

Forked River, New Jersey l

Inspection Lcnducted:

November 2-6, 1987 d. Od AOW W

/2-27 478}

Inspector:

S. Sherbini, Senior Radiation Specialist.

Date Facilities Radiation Protection Section

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Approved by:

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N. M. Shanbaky, Chief / Facilities Date'

Radiation Protection Section

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_ Inspection Summary:

Inspection on November 2-6, 1987 (Report No. 50-219/87-39)

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Areas Inspected: A reactive inspection to review the circumstances connected i

with an unauthorized entry into the drywell, and also the apparent breach of the l

integrity of an access door to a locked high radiation area.

Results: Three violations of Technical Specifications and radiation work permit

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requirements were identified.

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llj12 JOCK 05000219 114 871230

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DCD

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DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel R. Bingham, Supervisor, General Employee Training

  • P. Cervenka, Plant Engineering
  • B. DeMerchant, Licensing Engineer
  • M. Douches, Operations QA
  • F. Fiedler, Vice President, Oyster Creek
  • J. Kowalski, Licensing ;4anager, Oyster Creek D. Long, Security Manager, Oyster Creek
  • M. Slobodien, Director, Radiological Controls
  • D. Smith, Manager, Rad Controls Field Operations
  • J. Sullivan Jr., Director, Plant Operations
  • P. Thompson, QA Audits G. True, Superintendent, Mechanical Maintenance 1.2 NRC Personnel
  • W. Bateman, Senior Resident Inspector
  • J. Wechselberger, Resident Inspector
  • denotes attendance at the exit meeting.

2.0 Purpose The purpose of this reactive inspection was to review the circumstances surrounding an entry into the drywell that resulted in multiple violations of the Station's Technical Specification requirements as well as violations of station procedures. The inspection was also conducted to review the results of the licensee's investigation into an apparent breach of the integrity of a locked high radiation area access door. The inspection consisted of reviewing all documents related to the two separate incidents, as well as interviews with personnel.

3.0 Review of the Drywell Entry The drywell entries under review in this report were made on October 9, 12, and 13, 1987, by two electricians and four contractor personnel. These entries were made on RWP number 870842 to work on valves located in the drywell at the 95' elevatio _ _ _ _ _

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The October 9 entry was made by two electricians. Before the entry, they were briefed by a Radiological Controls Technician (RCT) at the drywell access point, as required by the RWP. The briefing appears to have been adequate based on accounts by the workers. The RWP called for special dosimetry on the thigh, and both workers had their TLDs in place. The entry proceeded without any deviations from procedure.

On October 12, the four contractor workers made their entry. They were briefed at the drywell control point by a RCT. According to the account of the incident, the briefing appears to have been brief and incomplete, apparently because the RCT thought the workers already knew the job and the entry requirements. The entry was made without the thigh dosimetry required by the RWP. The workers entered without a thigh TLD or SRD. The RCT apparently did not discuss dosimetry requirements with the workers. There appears to be some misunderstanding within the station regarding the extent and the material to be covered in a pre-job briefing. One view, which seems to have prevailed during this incident, is that the briefing is not supposed to cover RWP requirements. These requirements, which include dosimetry placement, are believed to be the worker's responsibility. The briefing is viewed by the RCTs as covering only a review of the latest radiological survey data for the areas in which the workers will be going.

There does not appear to be a procedure explaining the function and extent of pre-job briefings, and there appears to be a difference in perception between the workers and the RCTs regarding the function of this briefing.

The inspector discussed these findings with the licensee.

The licensee stated that the matter will be reviewed and corrected.

The next entry into the drywell was made by the same four contractor workers on October 13, on the same RWP. On this entry, however, there was no briefing. There was no RCT at the drywell control point. Entries into the drywell without the presence of a RCT at the control point are in violation of Station Procedure number 233. This procedure specifies that no personnel access is to be permitted unlar.s the drywell access control point is manned by a security guard, by Radiological Controls personnel, RWP requirements are met, and dosimetry requirements are met. The access point was manned at the tin,e of the entry by a security guard but no RCT. The guard verified that the workers were on the drywell access list and then permitted them to proceed into the drywell. Although the requirements in Procedure #233 are cleer, the procedure does not specify who is to see that these requirements are implemented at the access point. There appears to have been an impression among Radiological Controls personnel that the security guard will assume the functions of the RCT whenever a RCT is not present at the control point. Discussions between the inspecto-and the security management, as well as a review of security procedures and

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cions of the security guard at the control point are clearly desci ed in the procedures and directives: they are to ensure that those entering the drywell are on the access list, and that no unauthorized material is taken into the drywell. There is also misunderstanding among station personnel regarding the need for a RCT to man the drywell control point at all times when the drywell is unlocked for general access. Some thought that the control point should be manned at all times by RCT while others believed it should be manned only when needed. Procedure #233 does not provide guidance on this point. The net result of all these procedural weaknesses was that access to the drywell, which is a locked high radiation area, was not maintained under positive control at all times, in violation of Section 6.13 of the Technical Specifications. (50-219/87-39-01)

Another point of misunderstanding among station personnel was the interpretation of the pre-job briefing requirement specified on the RWP.

There was disagreement as to whether this briefing meant a briefing only prior to initial enti.' on the RWP or a briefing every time an entry was made on the same RWP.

The contractor workers made the entry on October 13 without the Technical Specifiestion's required instrumentation for entry into high radiation areas, as specified on the RWP. The RWP called for either a survey meter or an alarming dosimeter. Neither was used during the entry. This is a violation of the requirements of the Station's Technical Specifications Section 6.13. (50-219/87-39-02)

In addition to the violations of requirements described above, the four workers made the entry on October 13 without complying with other requirements specified on the RWP. The RWP required thigh dosimetry, and a breathing zone air sampler. These requirements were not implemented by the workers. This constitutes a violation of the RWP requirements for entry into the high radiation area (50-219/87-39-03).

During the inspection, the inspector reviewed the training records of the workers involved in the entries discussed above. The RCT involved in this incident was appointed Junior Health Physics Technician in 1983, a Senior Health Physit.s Technician in 1984, and was requalified as a Senior Technician in 1986. Three of the four workers who made the entries on October 12 and 13 were experienced workers who had completed their radiation worker retraining in October 1987 and had passed with grades ranging from 85% to 100%. The fourth worker had completed his radiation worker training in August 1987 with grades above 95%. It is therefore evident that all personnel involved in the incident were at least formally well trained and qualified for their respective jobs. The inspector briefly reviewed the course contents for the General Employee and Radiation Worker training courses, and also the examination questions for these courses. No

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significant findings were made as a result of this review. However, in view of the apparent RCTs and workers lack of understanding of policies and procedures, the inspector stated a detailed review of radiological workers

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training will be performed during a future inspection. (50-219/87-39-04)

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4.0 Apparent Breach of Access Door The access door in question is a steel frame and wire mesh door that serves as the access point to the Clean Up System area located on the 51'

elevation of the reactor building. This area is classified as a locked high radiation area. The breach occurred due to a separation of the wire mesh from the door frame close to the area where the lock is attached to the frame. This would f. ave enabled any person to reach through the broken wire mesh and open the door using the door handle on the inside of the locked area.

The breach was discovered by a Station Services person on the evening of October 31, 1987. Security and Radiological Controls were notified immediately. An inspection inside the locked high radiation area did not reveal anything unusual. The Senior NRC Resident Inspector was notified of the incident at that time. The breach in the door was repaired by welding steel plates that covered the area of the wire mesh in which the wire was broken.

An investigation was conducted by security in an attempt to determine who was responsible for the break in the wire mesh. The results of the investigation were that the break was apparently not the result of any deliberate attempt to break into the locked high radiation area. The licensee stated that one reason for arriving at this conclusion was that the wire mesh enclosing the area is open at the top and the area is therefore easily accessible to anyone who wishes to make an unauthorized entry by climbing over the wire mesh frame. Also, the licensee's investigators found that the ends of the broken wires were corroded, thus indicating that the break was not recent. There was also evidence of previous welding around the area of the broken wires. The conclusion of the licensee's investigation was that the wires were not broken deliberately, but rather as a result of repeated rough handling of the door by grabbing

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the wire mesh close to the area where the break was found. The inspector

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had no further question in this area.

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l 5.0 Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on November 6, 1987. The inspector summarized the scope of the inspection and the findings.

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