IR 05000458/1990014

Insp Rept 50-458/90-14 on 900521-22.One self-identified Violation Noted.Major Areas Inspected:Licensee Occupational Radiation Protection Program Including High Radiation Area Controls

ML20055D525
Person / Time
Site:	River Bend
Issue date:	06/19/1990
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055D522	List: IR 05000458/1990014 ML20055D521
References
50-458-90-14, NUDOCS 9007090057
Download: ML20055D525 (6)

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APPENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

L NRC Inspection Report: 50-458/90-14 License: NPF-47 Docket: 50-458

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Licensee: Gulf States Utilities (GSU)

P.O. Box 220 St. Francisville, Louisiana 70775 Facility Name: River Bend Station (RBS)

Inspection At: RBS site, St. Francisville, Louisiana Inspection Conducted: May 21-22, 1990 Inspector: /9 90 K. E.~Baer, Radiation Specialist, Facilities Date

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Radiological Protection Section Approved: /) /24f Mk BT Murray, Chief, Facil Radiological D' ate

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Protection Section Inspection Summary

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Inspection Conducted May 21-22,1990 (Report 50-458/90-14)

Areas Inspected: Special, unannounced inspection of the licensee's occupational radiation protection program including high radiation .vea control Results: Within the area ~ inspected, one self-identified violation was identified. However, a Notice of Violation was not icsued for this violation 1 because of the prompt reporting and corrective actions taken to prevent a recurrenc l-Thel licensee had performed an extensive investigation and review of the circumstances surrounding the three incidents of personnel violating the requirements for high radiation areas. Corrective actions, including

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disciplinary mea'sures, were established by management that should ensure procedural. compliance in this area, i

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-2-s DETAILS

' Persons Contacted

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GSU

• T. F. Plunkett, General Manager

• E. M. Cargill, Director, Radiological Programs

• K. L. Chapaneri, Senior Mechanical Engineer C. L. Fantacci, Radiological Engineering Supervisor

• N. Fauver, Radiological Health Supervisor W. Frayer, Director, Projects

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• * O. Fredien, Operation Supervisor

• W. C. Hardy, Radiation Protection Supervisor

• G. K. Henry, Director, Quality Operations

• R. E. Horn, Nuclear Training Coordinator - Technical R.-Jackson, Nuclear Training Coordinator - Opert.tions

• G. R. Kimmell, Director, Quality Services

• D. N. Lorfing, Nuclear Licensing Supervisor I. M. Malik, Operational Quality Assurance (QA) Supervisor

• W. H. Odell, Manager Oversight R. T. Schoemer, QA Surveillance Engineer J. E. Spivey, Senior QA Engineer

• K F. Suhrkr, General Manager

• J. E. Venable, Assistant Operations Supervisor M. A. Vierra, ALARA Coordinator OTHERS E. J. Ford, Senior Resident Inspector, NRC The inspector also interviewed several other licensee employees including radiation protection, radwaste, and operations personne . Background On May 11, 1990, the licensee notified NRC regarding two events that occurred on May 4 and 9, 1990, involving violations of high radiation are controls. A similar event had also occurred on March 26, 1990. Since these events cccurred during a short time period, NRC decided to perform a special inspection to review the circumstances surrounding these event . Description of Events The first event occurred on March 20, 1990, and was documented in Condition Report 90-0236. This occurrence involved a nuclear equipment operator in the auxiliary building. The operator was observed by a radiation protection foreman leaving Residual Heat Removal (RHR) B room without a health physics (HP) technician as required by the radiation work permit (RWP). Procedure RWP 90-0002 i

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states that continuous HP coverage is required when radiological conditions are not depicted on the RWP. In addition, verbal instructions were also given by the HP department that entry into RHR B room would require HP coverage. The RHR B had been placed into the shutdown cooling mode and radiological conditions within the room were constantly changing at the tine the operator entered the are '

The operator had made a prior entry into RHR B room earlier the same 5 day with an HP technician providing radiological coverage. The operator also entered RHR A room, which was an established hi.gh

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radiation area, and it was determined that he had not left the .;

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barrier rope including the warning sign in the proper position while inside that room, The second event occurred on May 4, 1990, and was documented in i Condition Report 90-0395. This occurrence involved a radwaste operator who was observed by a radiation protection technician within a posted high radiation area without a dose rate meter, alarming ,

dosimeter, or HP coverage. The operator was involved in the addition !

of walnut shell filter media to the liquid waste system Filter-1 This was the first time this operator had been involved with this job and he was not familiar with the exact location of two manual valves which needed to be manipulate The third event occurred on May 9, 1990, and was documented in Condition. Report,90-0413. This occurrence involved a security guard '

who was conducting a scheduled "High Rad" door check and crossed a barrier rope which was posted "high radiation area" to check a doo The door appeared on-the door checklist provided by the shift lead HP technici n The HP technician failed to realize that the barrier had been installed across the hallway and the door was not accessible !

without crossing the high radiation area barrier. This event was identified by a radiation protection technician when the security guard attempted to gain access to a very high radiation area and i check some doors which were also on the checklist of doors to verif '

A HP technician informed the security guard it was not necessary to check those specific doors in the very high radiation area and also commented-about the door behind the high radiation area barrier. The security guard informed the HP technician that the door had already been verified closed and locke . Inspector's Determinations  !

The inspector interviewed the operations and HP personnel involved with the events. The inspector did not interview the security guard because the licensee Fad already documented the results of an extensive interview -

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-4-The inspector reviewed QA Surveillances 0$-89-10-11, " Radiological Protection Activities," dated December 12, 1989; 05-90-02-14. " Radiation Protection Activities," dated February 22, 1990; and 05-90-03-11, " Plant Walkthrough," dated March 30, 1990. These surveillances indicated that the posting of high radiation, very high radiation, and very high radiation exclusion areas was being done properl The inspector viewed the areas where the three occurrences took plac All areas appeared to be adequately posted without any over posting or congestion which might cause confusion to an individual entering the are The inspector also reviewed a memorandum dated February 27, 1990, from the assistant operations supervisor to all operations personnel. The subject of this memorandum was radiological practices, and the purpose was to bring to the attention of operations personnel specific observations that had been made during license requalification examinations regarding inconsistent radiological practices being employed by operators. Training by HP personnel of Technical Specifications (TSs) and 10 CFR Parts 19 and 20 requirements was provided to all operators during routine requalification trainin This training was conducted during the period April 2 through May ll,1990. The operators involved in the events described in paragraph 3 had not received this training prior to their problems with the control procedure The inspector made the following determination from discussions with personnel and the review of the licen:.ee's documentation of the events:

In Event A, the operator stated that after the HP technician had performed the first survey in RHR B room, he understood the HP technician to say I that everything was okay and he assumed he could enter the area without HP !

coverage. Also, while the operator acknowledged placing the barrier rope i with the sign which idantified the room as a high radiation area to one side of the stairwell, he felt he had visual control over an entry by another person should it have occurre The radiation levels in RHR B room were determined to vary from 2 to ;

150 millirem per hour (mrem /hr) in the general' area where the operator was. The radiation exposure received by the operator for work during the day, which included entries into RHR A room, a high radiation area with radiation levels up to 400 mrem /hr, was between 15 to 20 mre f In Event B, the operator was routinely provided with an alarming dosimeter at the beginning of his shift. On this particular day, HP did not issue him an alarming dosimeter and during the afternoon when he was attempting to add filter media to the liquid waste syste He stated that he was preoccupied with locating the valves and it did not enter his mind that he '

did not have the necessary instrumentation to cross into a high radiation are The radiation level was determined to be up to 150 mrem /hr in the general !

area behind the barrier rope. The operator received a radiation exposure of approximately 5 mrem for the entire da ;. . s j

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In Event C, it appears that there had been sufficient discussions and

emphasis placed on maintaining very high radiation area doors in a closed and locked condition and that the security guard had placed performance of duty over otht" concern The radiation levtis were determined to be 250 mrem /hr at contact and 120 mrem /hr at 18 inches from the door. General levels varied from 3 to 120 mrem /hr f'om the rope barrier to the doo The radiation expostre received by the security guard was considered to be minimal. The dosime,er carried by the guard. read approximately 15 mrem after the event, but :he initial dosimeter reading prior to entry into the radiological control area was not known. The licensee performed a time and motion. study of the event and determined that the maximum exposure r that could have been received by the security guard was less than 5 mre !

As a result of these events, the licensee took the following actions:

Operations personnel involved appeared before the operations accountability review panel to determine root cabse and focus on the application of accountability to individual ,

All individuals involved appeared before the ALARA committe '

A memorandum dated May 14, 1990, was issued by the plant manager to all plant staff regarding disciplinary policy concerning the lax ,

attitude towards radiation protection procedures / practices, j

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A memorandum dated May 16, 1990, was issued from the senior vice president River Bend Nuclear Group, which outlines a multistep policy pertaining to radiation protection violations,

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The licensee stated that disciplinary actions had been taken towards those individuals involved with the three event TS 6.12.1 states, in part, that entry into a high radiation area in which the radiation intensity is greater than 100 mrem /hr but less than 1000 mrem /hr requires one er more of the following:  ; A radiation monitoring device which continuously-indicates the radiation dose rate in the area, A radiation monitoring device which continuously integrates the radiation dose rate and alarms at a preset integrated dose. Entry with this monitoring device is permitted after the dose rate levels have been established and personnel have been made knowledgeable of the An individual qualified in radiation protection procedures, with a radiation dose rate monitoring device, provides positive control over ,

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-6-L The three events described are considered to be a violation of TS 6.1 However the licensee's actions in taking prompt remedial. measures, making a full evaluation and report, and the instituting of corrective actions to prevent a recurrence met the criteria of the NRC Enforcement Policy in

.10 CFR Part 2, Appendix C, Section V.G.1 (1990), for a licensee-identified

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violation. Therefore, a Notice of Violation will.not be issued for this

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[ - Exit Interview

! The inspector met with the licensee's representatives. denoted in paragraph 1 at the conclusion of the inspection on May 22, 1990, an summarized the scope and findings of the in pection. The licensee did not:

identify as proprietary any of the materials provided to, or reviewed b the inspector during the inspection.

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