ML16342B631
| ML16342B631 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/04/1989 |
| From: | Cillis M, Tenbrook W, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F476 | List: |
| References | |
| 50-275-89-25, 50-323-89-25, NUDOCS 9001020199 | |
| Download: ML16342B631 (42) | |
See also: IR 05000275/1989025
Text
U ~
S ~
NUCLEAR REGULATORYCOMMISSION
REGIONY
Report
N os
~
5 0-275/8 9- 2 5 and
50- 3 23/8 9-25
License Nos.DPR-80
and
Licensee:Pacific
Gas
and ElectricCompany
77
Be a 1 e Street
Room 1451
S a n
Fra nci s co,
Ca 1 ifornia
9410 6
Facility Name:
Di a b 1 o Canyon
Power Plant, Units
1 a nd 2
a
Inspection at:
Diablo Canyon Site,
Seven miles north of Avi 1 a Beach,
Inspection conducted:October
25 through
November 2,1989,and
telephone calls
of November 7-8,1989
Approved by
is,
e n i o
a i a )on
p e c i a i s
ensaws i,
l e
Fac i 1 itiesRadi ol ogi ca 1 Protection Section
Inspected
by
e n roo,
a i ati o n
p e ci a i st
/2 / -FP
a
e
i
ne
iaae
i gne
ae
i gne
~Su m mar
Areas Ins ected:Rout ine unannounced
inspecti on covering fo 1 1 ow-up of open
i ems,occupa
i ona 1
expo sure dur i ng extended
outages, fo 1 1 ow-up of allegations,
and fac i 1 ity tours.
Inspect ion procedures 30703,9270 1 and 83729 were
addressed
Res u1 ts:The inspectors identified weaknesses
i n response toradi o 1 ogi ca 1
~aarms
in the Fuel Handling Building,resulting in one violation(Section 3.H),
and poor housekeeping
in control
1 ed areas(Sect i on 5).Program strengths
included the construction of anewcontainment
access fac i 1 ity(Secti on 3 ~ B),
the High-Impact Team(HIT)concept
(Sect ion
3 ~ C),and the administration of
dose limits ( S e cti o n
3 ~ E ) .
Two allegations
were evaluated
a nd c 1 o s e d ( S e cti o n
4) ~
DETAILS
Per sons
Contacted
Licensee
Personnel
J.
D
S.
- W
kJ
- R.
- D
AW
~W.
)LJ
- R.
)\\J
G.
L.
J.
M.
M.
D.
A ~
A.
J.
R.
D. Townsend,
Plant Manager
B. Miklush, Assistant Plant Manager
P.
Powers,
Radiation Protection
Manager
R. Fridley, Operations
Manager
J. Kelly, Regulatory
Compliance
Engineer
Y. Boots,
Chemistry Manager
'Gray, Senior Radiation Protection
Engineer
'.
Taggart, Director, equality Support
(gS)
B.
McLane,
Outage
Manager
G. Crockett, Assistant Plant Manager,
Support Services
A. Hays, Radiation Protection,
General
Foreman
,
P.
Kohout,
ESS Supervisor
Flohaug,
gS Supervisor
E. Gardner,
Senior Chemistry Engineer
S.
Boi les,
Dosimetry Foreman
T. Moretti, Radiat'ion Protection
Foreman
E. Knight, Radiation Protection
Foreman
Bilicska, Acting Radiation Protection
Foreman
L. Anderson,
Security
B. Anderson,
Security
I.
Dame, Training Supervisor
J.
Newell, Acting Training Supervisor
S.
Bard, Shift Supervisor
Arroyo, Security
Contractor
Personnel
R. Tinkel, Bechtel
W. Davis, Bechtel
C.
Kennedy,
Bechtel
R. Doran,
Bechtel
R. Spencer,
Bechtel
J.
Chadwick,
Delphi Group,
Inc.
M. Shackelford, Bartlett Nuclear,
Inc.
NRC
- P. Narbut, Senior Resident
Inspector
(SRI)
K. Johnston,
Resident
Inspector
~Denotes
those individuals present
at the exit interview conducted
on
November 2,
1989.
In addition discussions
were held with other
members of the licensee's
staff and contractor personnel.
2.
Follow-u
of 0 en Items (92701)
0 en Items 50-275/87-24-01
and 50-323/87-24-01
(Closed)
These
items
concerne
e
ac
o
an exp 1cit pipe repair
an
rep acement criteria in
the licensee
s pipe erosion/corrosion
surveillance
program.
Engineering
Instruction I-67, issued
March 30,
1989, contained specific criteria for
'decisions
to leave eroded or corroded pipe in service until the next
scheduled
outage,
or repair and replace
such pipe.
The methods
used were
consistent with NUMARC guidance for repair and replacement
decisions
per
the licensee's
reply to Generic Letter 89-08.
This item is closed.
0 en Item 50-275/87-30-04
(Closed)
This item involved modifications to
t e
squs
ra waste
sys
em in en
ed to reduce
alarms
on the liquid
radwaste effluent discharge
monitor,
RE-18.
The licensee
had completed
installation of 5 micron filters upstream of RE-18 to capture entrained
radioactive particulate material that could'cause
spurious
RE-18 alarms.
This item is closed.
0 en Item 50-275/88-27-01
(Closed)
This item concerned
heightened
levels
o
isso
ve
>n con ensa
e,
and the actions
taken to mitigate this
condition.
Periodic condenser
cleaning
had briefly decreased
condensate
oxygen to 3 ppb in 1989.
Overall levels rose to 5-7 ppb after such
cleaning.
Other actions
included
improved sealing of feedwater
pump
turbine discharge
to the condenser,
increasing
the size of cross-tie
piping in condenser
waterboxes,
and recycling oxygenated
deminerali zer
beds to the condenser
rather than the condensate.
The licensee's
actions
have observably
improved secondary
dissolved
This item is closed.
3.
Occu ational
Ex osure Durin
Extended
Outa
es
(83729)
A.
Audits and
A
raisals
The inspectors
examined audit and surveillance
reports
and checklists
involving radiation protection.
One Audit Report, entitled
"Radiation Protection:
Radioactive Materials Management,"
Audit
89815T,
had been
issued in October,
1989, following the last
inspection,
June,
1989.
No audit findings were issued.
The report
recommended
periodic training of warehouse
personnel
in the handling
of radioactive material
shipments.
The audit scope,and
depth were
satisfactory,
incorporating
document review, plant tours
and
surveillance of work practices.
The inspectors
reviewed
one approved
equality Support Surveillance of
work in-progress
involving radiation protection practices
in the Unit
1 outage.
Several
remaining
Suri~ei 1lances of these
areas
were
scheduled
to be completed later in the outage.
equality Assurance activities pertaining to Radiation Protection
were
satisfactory to the extent of thei r completion during the inspection.
~Chan
ea
The inspectors
noted the construction of a permanent radiological
access facility on the 140
level of the Turbine Building, adjoining
the Unit j. containment
personnel
hatch.
The
new facility provided
easier
access
to radiologically controlled areas
(RCAs) in
containment during outages
by relieving congestion at the containment
access.
The licensee
planned to construct
a similar facility to
support Unit 2 outages after the next fuel cycle, early in 1990.
The
new facili'ty included offices, dosimetry issue station,
an area for
personnel
to don protective clothing prior to entering
RCAs,
a
personnel'fr'isking station,
and an area for monitoring equipment to
be removed
from RCAs.=
In addition, 'the inspectors
noted major changes
in the licensee
s
ALARA program implementing procedures.
These
changes
are described
in paragraph
3.C, below.
The changes
to the licensee'
radiological
access facilities were
beneficial.
No detrimental
or unreviewed
changes
were identified.
Outa
e Plannin
and Pre arations/Maintainin
Occu ational
Ex osures
NRC concerns
involving the licensee's
ALARA program were discussed
in
Inspection
Reports
50-275/89-03 'and 50-323/89-03.
The inspectors
verified that
ALARA implementing procedures
had
been completely
revised to address
the concerns
discussed
in the Inspection
Reports.'he
procedures
contained
the recommendations
of Regulatory Guide
(R.G.') 8.8, "Information Relevant to Engineering That Occupational
Exposures...Mill
Be As
Low As Reasonably
Achievable."
The inspectors
also observed
work practices
and examined job specific
ALARA goals,
exposure
data,
work permits,
work scheduling
documents
and
ALARA 'reviews.
The radiation protection staffing for the outage
was also
examined
and found to be satisfactory.
Contractor radiation
protection personnel
and other contractor radiation workers were
interviewed during the inspection.
All personnel
interviewed were
aware of the
ALARA concept.
The inspector
noted that the
RPM and his staff conducted daily tours
of the plant to identify and correct poor ALARA practices.
The
ALARA procedures
reviewed are
as follows:
o
RCP D-205, "Performing ALARA Review"
o
AP C-200S2,
"Implementation of the
ALARA Program.
The review disclosed that
DCPP Management
has
made
a commitment for
" the implementation of a strong
ALARA program.
The licensee's
staff
used historical data
from previous
outages
and information from other
sources
to establish their ALARA goals.
Additionally the licensee
3
0
has established
an
ALARA Management
Incentive Program whereby
personneI
are given awards for meeting or exceeding the
ALARA goals.
The licensee
had established
an
AI ARA goal of 400 Map-rem for this
outage.
As of November 8, 1989, approximately
280 Man-rem of the 400
Man-rem had been
expended.
The
RPM and his staff expressed
some
concern
over the rate at which they were approaching
the established
ALARA goals.
The staff reviewed the exposure
data daily and compared
it to previous refueling outages
to determine
a cause for the rapid
increase.
It was concluded that the critical work where high
exposures
could be expected
had been
scheduled
during the initial
phases
of the outage.
The staff expected that the Man-rem usage
would eventually level off.
The
RPM informed the inspector that
he
and his staff would continue to closely monitor their
Man-rem goals.
The
ALARA group per forms dose tracking by discipline and by job
specific.
The review of this data did not disclose
any abnormal
trends
or conditions.
The
ALARA organization
possessed
the depth in the radiological
protection group that is normally necessary
to maintain
an effective
ALARA program.
A contractor
and two shielding engineers
were
assigned
to implement the program.
Few radiation protection
technic'ians
involved in day-to-day activities were included in the
planning
and preparations
for the outage.
This observation
was
discussed
with the
RPM and at the exit interview.
The
RPM stated
that the inspectors'bservation
would be considered
as
a possible
improvement for, the
ALARA program.
Paragraph
3(c) of Inspection
Ressort
50-275/89-18
and 50-323/89-18
describes
the "High Impact
Team 'HIT).
The HIT Team was led by the
radiological
engineer
responsible
for ALARA.
The HIT Team planned,
prepared,
scheduled
and maintained surveillance
in three major areas
during the refueling outage;
reactor disassembly/reassembly,
refueling preparations/fuel
off-load, and valve maintenance.
This
was
a
new concept which required
approximately 15-20 different
disciplines to work together to ensure all activities with the
selected
work activities are effectively accomplished.
The
inspectors
reviewed the teams'ffectiveness.
The following
observations
were made:
The
Team worked in one office area
located
on the Turbine
Deck of Unit 1.
The Team functioned
as described
in prior
Inspection
Reports.
Shiftly planning meetings
were
conducted to discuss
the status
of work and to resolve
any
problems.
All work was carefully planned.
HIT activities were well documented.
The information was
to be used
as reference
material for future outages.
o
The HIT worked closely with the
ALARA group
and other.
organizations
involved in the refueling outage.
o
t1an-rem exposures
for two of the three jobs were less
than
expected.
Exposures
incurred during valve repair
activities
had been greater
than expected.
The HIT was
developing methods to improve future valve repair work
practices.
The HIT staff informed the inspectors
that they were planning to
expand their involvement during the next scheduled
outage at Unit 2.
The activity in this area fully supported
the licensee's
safety
objectives
and the concept of ALARA.
Trainin
and
uglification of Personnel
The inspectors
examined
the licensee's
General
Employee Training
(GET) program
and the qualifications
and training. program established
for Radiation Protection
Technicians=(RPT)
and 'radiation workers
hired for the outage.
The licensee
used
an acceptance
test to help determine
whether
contractor
RPTs are qualified., RPTs passing
the test are provided-
with approximately
one week of site specific training in radiation
protection.
The inspectors
reviewed selected
RPT resumes
provided
prior to employment
and examinations
upon completion of the training
program.
The
RPTs selected
for the outage
met or exceeded
the the
qualifications prescribed
in ANSI/ANS 3. 1-1978,
"American National
Standard for Selection
and Training of Nuclear
Power Plant
Personnel."
All workers assigned
to work in radiologically controlled areas
were
required to attend the General
Employees Training program
and
Practical
Factors
Training" program.
These
two programs collectively
met the requirements
prescribed
in 10 CFR 19. 12, "Instruction to
Morkers."
Mock-up training was provided to workers involved in steam generator
inspection
and repair activities.
Personnel
attending
the mock-up
training felt that the quality of the training provided to them was
good.
Morkers required to wear respiratory protective
equipment attended
a
training session
on the
use
and control of such equipment.
The
workers must complete
a medical
and fit test before they are
considered qualified to wear respirators.
The inspectors verified
that respirators
had only been
issued to individuals who met the
qualifications.
The licensee's
performance
in this area
appeared
to be adequate
to
accomplish its safety objectives.
External
Ex osure Control
The inspectors
reviewed dosimetry records
and data for workers
who
had
had their administrative
dose limits increased
to 1850
mi llirem
5
or more during the current calendar quarter.
The inspectors verified
Form 69-11579,
"Additional Exposure Authorization," from procedure
RCP G-110,
"Personnel
External
Exposure
Dosimetry and Control," had
been properly reviewed
and approved
by Radiation Protecti'on for each
worker authorized to receive
1850 mi llirem or more durinq the current
quarter.
In some cases,
Dosimetry and Radiation Protection only
approved additional
exposure
to a lower administrative limit than
that requested
by the worker's supervisor,
in order to conserve
the
worker's
dose.
NRC Form 4 was
on file for each worker receiving
authorization for exposure
up to and exceeding
1850 millirem.
The inspectors
obtained current exposure status-to-date
from the
Plant Information Management
System for each worker authorized to
receive
1850 mi llirem or
more during the current quarter,
and
reviewed
a current
report of margin between
dose received
and the
authorized administrative limit for each radiation worker.
The
inspectors verified that the workers'ose
status
was within both
administrative
and regulatory limits.
Doses for several
contractors
involved in steam qenerator
maintenance
were approaching
authorized
administrative limits of 1250 and
1850
mi llirem, with work in the
bowls completed.
No exposures
exceeding
1250
millirem were observed for individuals other than steam generator
maintenance
workers,
The licensee's
program for external
exposure
dosimetry
and control
was satisfactory.
The approval of Addition Exposure Authorizations
at lower administrative limits than those
requested
demonstrated
a
conservative
review of worker dose status.
Internal
Ex osure Control
The inspectors
examined
surveys of personnel
contamination
incidents
involving .facial contamination
as recorded
on Procedure
RCP D-600,
Form 69-9392,
"Personnel
Decontamination
and Evaluation Reports."
The inspectors verified that special
whole body counts
had been
promptly performed for each facial contamination incident.
The
inspectors
observed
one report of contamination
on a worker's chin
where radiation protection personnel
did not specifically document
a
recommendation
for a whole body count, but a count was performed
promptly nonetheless.
The inspectors
examined
Special
Mork Permit 264, "Disassemble
and
Check Valve 8948A-D and 8956A-D," and its associated
instructions,
logs
and Airborne Entry Logs.
The inspectors verified that breathing
zone air
samples
were obtained
and documented
on October 28,
1989,
during replacement
of a check valve disc and reassembly
of the valve.
Airborne Entry Logs were also kept throughout work on
SMP 264 for
Maximum Permissible
Concentration
(MPC)-Hour tracking.
The
inspectors, verified that High Efficiency Particulate Air (HEPA)
filter units
had been installed at the job location as engineering
controls for airborne radioactive material.
The inspectors
observed respiratory protection
equipment
issue at the
140'evel
of the containment building.
Issuing personnel
verified
each worker's authorization to wear the particular respirator
required for their job.
Radiation Protection Technicians
were
stationed at the entrance of each level of containment to query
workers
as to their work area
and, if an airborne area, verify that
respirators
had been properly issued to the workers.
The licensee's
program to evaluate
and control internal
exposure
during the outage
was satisfactory.
Control of Radioactive Materials 'and Contamination
Surve
s
and
~on> ton n
Prior to the inspection,
the inspectors
were informed of several
occurrences
related to control of'adioactive effluent.
These
occurrences
had been investigated
by Chemistry
and Radiation
Protection.
The inspectors
reviewed preliminary reports
on pressure
observed
in the Unit j.'aste
gas
decay tanks
on October
7
and 8,
1989,
and the release
of millicurie amounts of fission product
noble gases
in the Auxiliary Building with a release
path to the
environment,
also
on October 7,
1989.
The pressure
drops in the waste
gas
system were minor,
and plant vent
effluent monitor RE-14 did not indicate
any release
of effluent
during the transients.
However, the appearance
of 3
MPC levels of
noble gas at the 100', and 115'ontainment
areas
shortly
before
one of the pressure
caused
concern
over
a possible
gaseous
radwaste
system
(GRS) leak.
The noble
gas
leakage
was
released
to the environment at the 140'oof area
through
a tear in
the rubber seal
between
the containment wall and the 115'enetration
area ceiling.
The tear
was subsequently
repaired.
The licensee
evaluated
the release
and will include their evaluation in the
semi-annual
effluent release
report.
The licensee's
investigation determined that the gaseous
radwaste
system
was not a credible source for the leakage,
as there were
no
GRS components
in the areas
where airborne activity was detected.
In
addition,
the expected
pressure
behavior of hot reactor coolant
system offgas in the gas
decay tanks
was consistent with gas cooling.
The licensee's
investigation
had tentatively attributed the noble
gas
leakage
to momentary
leakage
from valve packing in the Residual
Heat
Removal
(RHR) system.
The licensee
proposed
airborne
surveys
and
contamination
surveys of RHR valves
and the surrounding
areas
upon
actuation of the
RHR system in Unit 2 to evaluate this explanation.
The inspectors
inquired whether the leakage
from the
RHR valves, if
substantiated,
would indicate
a problem with the valves performing
their safety function.
The Senior Chemical
Engineer stated that
he
would inform Maintenance of the observed
leakage
and its probable
sour'ce.
The Chemistry staff also proposed to obtain accurate
measurements
of waste
gas
temperatures
to confirm that the pressure
7
in the gas
decay tanks are
due to gas coolin~ and not
leakage.
The inspectors
wi 11 follow-up on the licensee
s evaluation
of the cause of the noble gas
leakage
and the
GRS pressure
in a future inspection
(50-275/89-25-01).
The inspectors
examined post-decontamination
surveys of steam
generator
bowls performed in support of maintenance
and testing
during the Unit 1 outage.
The licensee
employed Electric Power
Research
Institute (EPRI)/Mestinghouse
standardized
survey methods
covering ten locations
each in the hot and cold leg channel
heads,
with beta
and beta/gamma
measurements
at each point.
The licensee's
surveys prior to steam generator
maintenance
were
satisfactory.
The pressure
reduction of the gaseous
radwaste
system
during
RCS offgas
and the sources of noble gas
leakage
upon shutdown
both required further evaluation to confirm their root causes.
Res
onse to Alarms
The Senior
Resident
Inspector
informed the inspectors that
he had
received
several
telephone calls 'from workers
who had expressed
serious
concerns that improper actions
were taken in response
to Fuel
Handling Building (FHB) area radiation monitor (ARM) evacuation
alarms which occurred during fuel removal activities during the
period of October
15-18~
1989.
The Resident
Inspector discussed
the
calls with the licensee
s staff,
and further examination
and
inspection
was conducted
during the inspection.
ARM RE-58 is the
spent fuel pool
ARM and
RE-59 is the
new fuel storage
ARM.
The following licensee
records
and documents
were reviewed:
ARth RE-58 Chart Recorder
data for October 15-18,
1989.
Applicable licensee
procedures.
General
Employee Training (GET) related to plant alarm response
and evacuation.
Documents collected
by the licensee for their investigation of
the matter.,
Special
Mork Permit
(SMP) 89-00305-00,
"Fuel Transfer Activities
in Fuel Handling Building," dated October 13,
1989.
Final Safety Analysis Report
(FSAR) Section 11.4.2.3.
The applicable Technical Specifications,
Regulatory Guides,
and
10 CFR 19, were compared to licensee
actions,
and the
FHB was toured.
The matter
was also discussed
with personnel
who were responsible
for
fuel off-loading activities.
10 CFR 19.12, "Instructions to Morkers," states
in part:
1,
ing in or frequenting
any portion of. a
s'e...instructed
in the appropriate
response
le in the event
of- any unusual
occurrence
or
.t may involve exposure
to radiation or
.erial...."
ion (TS) 6.11, "Radiation Protection
Program,"
personnel
radiation protection shall
be prepared
the requirements
of 10 CFR Part 20 and shall
be
iined and adhered
to for all operations
involving
- ion exposure."
.nd Programs,"
states
in part:
procedures
shall
be established,
implemented
and
ing the activities referenced below:..."
ble procedures
recommended
in Aapendix
A of
Guide
(RG) 1.33,
Revision 2, 19'l8."
Appendix A, Section 5,
recommends
that abnormal,
=onditions should
be covered
by written
e
6 establish
the license conditions for
59.
The specified alarm setpoint is less
than
or both ARNs.
ACTION statements
30 and
32
ns to be taken
when the alarm/trip setpoint is
r monitor is. inoperable.
re,
Mindow AR PK11-10,
"FHB High Radiation,
es in part that operator action includes
sf the evacuation
horn, checking for actual
and notifying radiation protection personnel.
ining includes provision of the following
your area,
proceed
immediately to Access
rea of known low dose rate,
unless
instructed
adiation Protection Staff,
And inform the
adiation Protection Staff."
signed overall responsibility for refueling
ing licensee
procedures:
l Prerequisites"
ding Sequence"
. g Sequence"
!l<
Operating Instructions"
Additionally, OP B-8D requires that all critical personnel
participating in core unloading
be verified to have
been adequately
trained.
OP
B-BD S-1, sections 5.2.4, 5.2.5,
and 6. 1, state in part:
"If an evacuation
alarm occurs,
CORE ALTERATIONS shall
be
suspended
immediately and all personnel
shall
assemble
in the
main airlock.
The
PPE (Nuclear)
and Refueling
SRO shall
determine
the cause of the alarms
and the Refueling
SRO will
determine
the response
to be taken.
If it is determined that
no
hazards
to personnel
exist, evacuation
need not proceed
any
further..."
"If the Refueling
SRO or Power Production Engineer (Nuclear)
suspects
that continued operation will involve undue risk to
personnel
or equipment or will compromise
the T/S or license
provisions,
operations
wi 11
be suspended
pending resolution.-"
OP B-8D S-2, sections
5.3.5
and 6. 1, state
in part:
"If a Containment
Evacuation
alarm occurs,
CORE ALTERATION shall
be suspended
immediately
and all personnel
in containment shall
assemble
in the majn airlock.
The Power Production
Engineer
(Nuclear)
and Fuel
Loading
SRO shall determine
the cause of the
alarm and the
SRO will determine
the response
to be taken.
If
it is determined that
no hazards
to personnel
exist,
evacuation
need not proceed
any further..."
"At the start of each refueling shift, the Refueling
SRO shall
establish
communication with operators,
observers
and the
control
room and verify that all requirements
of STP IlA are
being met for Mode
6 operation
and core alterations.
A briefi ng
should
be conducted
reviewing containment
evacuation
alarms
and
procedures."
OP B-8G states
in part:
"The fuel handling
SRO should conduct
a tailboard prior to
starting that shift's fuel handling activities to ensure
each
member's
assignments
are
known and general
turnover from
previous shift's progress
are discussed.
The fuel handling
SRO should ensure all members
in the crew are
fami liar with possible
alarms
such
as containment
evacuation
alarm.
He should also assure
himself that each
member
understands
his response
upon activation of possible fuel
handling related alarms."
SMP 89-00305-00
required continuous radiation protection surveillance
during core-off-load operations.
The
SMP also required that
a
portable
ARM be
on the bridge crane during fuel movement.
The following observations
were
made regarding the above:
ARM RE-58 alarmed approximately
113 times between
October 15,
and October 18,
1989.
Of that number, illactually occurred
between
9: G9 a. m.,- PDT, October 17,
1989,
and 6:43 a.m.,
PDT,
October
18,
1989.
Licensee
procedures
noted above included
use of "permissive"
terms
and did not include any requirements
for shift briefings
of personnel
working in the
FHB during fuel removal activities.
Personnel
involved
>n fuel removal within the containment
were
briefed
as indicated in those procedures.
Personnel
involved in
fuel removal activities in the
FHB stated
they had not received
any such briefings.
OP B-8D required only the Nuclear Engineering
and
Operations/Fuel
Handling shift personnel
be adequately
trained
for their par t in fuel handl ing 'per ati ons.
Other personnel
involved in. fuel handling operations,
such
as Instrumentation
and Controls (18C), Radiation Protection
(RP), Maintenance,
and
others,
received
no training pursuant to
OP B-8D.
The inspector
noted that
OP B-8D training consisted of reading core-off-load
procedures.
The public address
(PA) system
was
used several
times
(much less
than illtimes) to inform personnel
regarding the
ARM RE-58
alarms.
No verifications of personnel
evacuation
pursuant to AR PK11-10
were
made.
No unexpected
radiation levels were detected
in excess
of 10
mr/hr, at which RE-59 was. set.
The alarm setpoints of RE-59, of
the
ARM on the
FHB bridge crane,
and
on an air monitor "SPING,"
were never exceeded.
Personnel. working in the
FHB stated to the inspector that:
they were unsure
regardin'g
who was responsible for fuel handling
activities in the
FHB.
personnel
calling the Control
Room after RE-58 alarmed
were
instructed to evacuate until the alarm could be verified.
The
IRC group verified that RE-58 was properly calibrated during
October 15-18,
1989.
The spent fuel pool surface cleaning tool,
or "skimmer," was not in operation during fuel handling
activities,
as it caused
a ripple on the pool surface which
distorted the view of the fuel handling equipment
and fuel
within the pool.
At an undetermined
time during October 17-18
1989, Operations,
RP,
and
I8,C personnel
reached
agreement
to consider
RE-58
and to enter the action statements
of TS 3.3.3. 1.
However, the alarm was not disabled.
RE-58 continued to alarm
11
at
a rate of approximately
8 to 14 times per hour.
Subsequently,
the licensee's
staff decided to evacuate
personnel
from the
FHB if the
ARM alarmed for over
30 seconds.
However,
this action was not communicated
to at least six individuals who
were involved in fuel handling activities.
At least four radiation protection technicians
and two quality
control inspectors
who did not call the Control
Room after RE-58
alarmed were, at various times, instructed either to ignore the
alarm or to evacuate.
The individuals providing such
instructions were, variously, the Shift Foreman,
RP personnel,
and quality control personnel'hese
conflicting instructions
caused
confusion
as to what action to take
when
RE-58 began
alarming frequently on October
17 and 18,
1989, for example:
Two statements
from different individuals indicated that Control
Room personnel
had been contacted
regarding the possibility of
making
a
PA announcement.
Both statements
indicated that
announcements
would not be
made for each
RE-58 alarm, but that
Control
Room personnel
informed them that personnel
should
evacuate
any time the alarm sounded.
RP personnel
stated that RE-58 alarms
appeared
to occur in
upward spikes with a background level
near
6 to 10 mr/hr.
A
comparison in the area of the detector with an ion chamber
survey instrument indicated
a dose rate of approximately 2.5
mr/hr.
The inspector
noted that RE-58 had
a logarithmic scale
meter,
which was difficult to read accurately.
RP personnel
further stated that the
RE-58 alarms could be heard in the Unit
area
on the 115'levation,
that none of the
workers there
responded
to the alarm,
and that
no
announcements
were
made during that time to alert personnel
regarding the alarms.
Again, personnel
contacting the Control
Room were instructed
to evacuate,
while personnel
who ignored
the alarms
were not challenged.
A log entry for 7: 10 a.m.
on
October 18,
1989, stated
in part:
"Continuous alarms are
starting to be ignored completely.
In 3 1/2 shifts
approximately
30 alarms.
No workers paid any attention.
This
seems
to be
a problem."
On the morning of October 18,
1989, the
RP Foreman
informed
Operations that
FHB fuel handling activities were being
suspended
until response
to RE-58 alarms
was resolved.
At that
time,
RE-58 was declared
and the licensee
formally
entered
the action statements
of TS 3.3.3. 1 and
TS Table 3.3-6.
The above observations
were discussed
with the licensee's
staff and
at the exit interview.
The inspectors
informed the licensee that
personnel
were confused -as to what action they should
have taken
during RE-58 alarms, that
OP B-86 and
AR PK11-10 were not adhered to,
and that the oth'er procedures
noted
above did not clearly address
responses
to
FHB
ARM alarms.
The licensee
acknowledged
the
observations
and stated that corrective action
had already
been
initiated, which would provide detailed instructions within those
12
procedures.
The licensee further stated that
a Design
Change
Package
(DCP) and Design
Change
Notice
(DCN) had been
issued to correct the
spiking
on RE-58.
Subsequent
discussion with the licensee
on November 8, 1989,
indicated that the
DCP/DCN for RE-58 had not been fully effective in
preventing spiking.
The licensee
stated that they were in the
process
of reviewinq calibration methods for RE-58.
They stated that
they felt that the instrument
was overly sensitive to low levels,
due
to the fact that the instrument is electronically calibrated
on a
logarithmic scale.
The licensee
stated that as further-corrective
action they were preparing
a TS amendment
request to allow the
setpoint to be changed for RE-58.
Failure to adequately instruct personnel
during the period when RE-58
was alarming appears
to be
a violation of 10 CFR 19. 12
(50-275/89-25-02).,
The licensee
acknowledged
the apparent violation
when informed by the inspector.
The findings concerning the RE-58
alarms
indicates
a need for the licensee
to strengthen
his program in
this area.
ations
RV-89-A-0056
An allegation
was received in the Region
V office from a licensee
contractor
whose services
were terminated for cause.
The contractor
alleged:
(1)
No action
was taken
when the alleger
and several
co-workers
passed
through
a portal monitor that alarmed.
This concern
had
been brought to the attention of supervision.
(2)
There
was
a five day delay in obtaining
a termination Mhole Body
Count.
An examination of the worker's concerns
disclosed that
he
had been
working inside
a radiologically controlled area
(RCA).
Upon',exiting
the area for a break the worker 'performed
a whole body survey with a
PCM-1B personnel
frisker.
Radiation protection personnel
at the
exit point notified the alleger's
supervisor
and Security that the
alleger would not be allowed to return to the
RCA because
of a
fitness for duty question.
Security proceeded
to escort the
individual off-site.
Two security guards
escorted
the individual to the Security Building.
At this point, all personnel
exiting from the protected
area
must
pass
through
a portal radiation monitor and
a security
badge
detection monitor.
The badge detection monitor had been set to alarm
if an individual inadvertently exited the Security Building with
his/her security badge.
13.
The inspectors
interviewed the Security Guards
who escorted
the
contract worker outside the Security Building, the co-workers
named
by the individual and the individual
s super'visors.
The following
information was disclosed:
(1)
An alarm occurred
as
one of the guards
escorted
the individual
completely outside of the Security Building with the guards
security badge
on.
The guard wanted to ensure that the
individual was outside of the licensee's
protected
area
boundaries.
This observation
was confirmed by the second
security guard
and another
guard
on duty at the security
badge
drop-off area.
None of the security guards
heard
a portal
radiation monitor alarm.
(2)
The co-workers
named
by the individual stated that they did not
hear
a portal radiation monitor alarm.
Also, the co-workers did
not exit the protected
area at the
same time that the individual
was escorted
outside the protected
area.
(3)
The individual's supervisor
stated that
he
had not been
informed
of a portal radiation monitor alarm
on the night in question or
on previous exits.
The supervisor stated that he had met the
individual and the security guard
on the outside of the Security
Bui 1 ding.
(4)
After exiting from the protected
area
the individual was
escorted to his automobile.
Consistent with licensee
procedures,
the individual was asked if he would consent to a
search of his car.
The individual refused.
Security responded
by confiscating his Car Pass
and escorting
him to the boundary
of the owner controlled area.
Prior to being released
the
individual was instructed'to
return the next day in order to
complete the termination process
and receive
a whole body count
as required
by licensee
procedures.
(5)
On the following day, October 5,
1989,
the individual'as
delayed at the entrance
to the owner-controlled
area
upon
returning to complete the termination process.
The individual
left the site after waiting approximately
two hours.
(6)
The individual was called
on October 6, 1989,
and was requested
to return to the site to complete the termination process.
The
individual requested
that his return
be delayed unti 1 Honday,
October 9, 1989.
(7)
The individual returned
on October 9,
1989,
received
a whole
body count
and completed
the termination process.
It should
be noted that regulatory requirements
do not specifically
address
the
need for performing
a whole body count upon termination
of employment.
Licensee
procedures
normally require whole body
counts
upon initial., employment,
annually thereafter
or whenever
an
individual is suspected
of inhaling/ingesting radioactive materia],
14
and
as quickly as possible
upon terminati.on of employment.
Licensee
procedures
do not establish
a specific time limit for performing the
termination whole body count.
The inspectors
concluded that any alarms
he'ard
by the individual.were
due to the security guards'ecurity
badges.
The inspectors
also
concluded that the delays prior to the individual's termination whole
body could have
been prevented
and/or reduced if the individual had
waited longer on October 5, l989, or
had agreed to return
on October
6, 1989.
The observations
above
were discussed
with the Radiation
Protection'anager
(RPM) and at the exit interview.
The
RPM informed the
inspectors
that the lessons
learned
from his
own personal
involvement
into this matter
and the inspectors'bservations
would be evaluated
'o determine if any improvements
could be
made.
No violations or
deviations
were identified.
This matter is closed.
RV-89-A-0064
An allegation
was received
by the Region
V office on October 27,
1989,
from two contract workers
who felt that they had
been
discriminated against for raising safety concerns
to their
super vision.
The individuals stated that they had been terminated
for refusing to perform their assigned
duties inside
an
RCA unti 1
some
concerns
they raised were resolved.
The individuals stated that they had recently
been hired as contract.
Electricians to support the refueling outage.
They added that they
had never worked in the nuclear industry before
and felt some of the
experiences
gained
from their initial entry into an
RCA, specifically
the'ontainment
building, did not appear to be consistent with what
they had learned at the licensee's
General
Employees Training class
which they had attended
several
weeks earlier.
The inspectors
informed the Electricians -to try to resolve their.
differences with their supervision
and with the licensee.
On the
discrimination issue,
the individuals were advised to file a
comp'faint with the Oepartment of Labor (DOL) and the licensee's
"Hot
Line" for safety concerns.
Both individuals agreed to try to resol've
their concerns
through the channels
recommended
by the inspectors.
The Electricians
had been assigned
to work with two electrical
engineers
tasked with testing the Gamma-Metrics
system inside the
containment building.
The Electricians'- supervisor
and the
electrical
engineers
briefed the Electricians prior to entry. into the
work area.
An electrical
engineer stated that both individuals
appeared
to be very concerned
about making their first entry into a
controlled area.
The engineer
stated that it took about two to three
hours to convince the individuals to make their first entry.
An examination of the concerns
identified by the Electricians
was
conducted
in parallel with an investigation
conducted
by the
15
Radiation Protection
Manager
(RPN),
and the
Electricians'upervisors.
The Electricians also maintained
a communication link
with the inspectors,
RPN and their supervision during the inspection.
The -concerns
raised
by the Electricians,
the inspection findings and
resolutions to the finding are
as folio>is:
Concern ¹1
Findinli 81
Resoluti on
Concern ¹2
~Fl nd I Il
Resolution
Concern ¹3
~Findin
The Special
Work Permit
(SWP) was
a month old and the
dose rates reflected
on the
SMP were not the
same
as
they were led to believe during the pre-work
briefings.
This concern
was partially substantiated
in that the
SMP was issued
approximately
one month earlier.
However,
the SMP's expiration date
was listed as
Oecember
31, 1989; therefore, it was still current at
the time of the inspection.
The
SMP also authorized
work to be performed in the refueling cavity as well
as the Gamma-Netrics
work assigned
to the
Electricians.
The high refuel>ng cavity dose rates
described
on the
SMP were mistaken
by the electricians
f'r the
dose rates
involved in the Gamma-Netrics
work.
The Electricians also obtained
dose rates
from a
co-worker rather than from radiation protection.
The
co-worker's
dose rate information was inconsistent
with that described
in pre-work briefings.
The
RPN stated that the
SMP would be modified to
separate
the Gamma-Netrics
work and the refueling
cavity work.
The
RPN encouraged
the Electricians to
contact himself or his staff if they had any questions
pertaining to radiation safety.
The electrical
engineer
had difficulty locating the
work area.
Also, they did not have the proper tools
upon arriving at the work area.
This concern'as
substantiated.
The engineer stated
that
he got confused
and took a wrong turn.
The delay
was minimal.
The engineer stated after starting the
job they ran into an unexpected
interference
which
required
a special tool.
Hone required.
There
was
some confusion
as to what dosimetry
was
required for the work.
This concern
was substantiated.
The dosimetry
requirements
for the Gamma-Netrics
and the reactor
cavity work (see
concern
1 above)
were not the
same.
This was reflected
on the
SMP.
However, the radiation
protection technician issuing the dosimetry
became
16
Resolution
Concern ¹5
~Findin
Resolution
Concern ¹6
~Findin
Resolution
Concern ¹7
confused for a moment until he was reminded of the
differences
by a worker,who was
a little more familiar
with requirements
prescribed
on the
SWP.
The
RPM directed his staff to be more observant of
SWP requirements
and assigned
the Gamma-Metrics
and
refueling cavity work to separate
SWPs
(See item ¹1
above).
The Electricians
observed
some horse play between
an
individual who had partially removed
'nti-contamination clothing and
a worker fully dressed
in anti-contamination clothing.
No undressing
procedures
were posted.
This incident was witnessed
by another individual.
The
RPM discussed
the concern with the Electricians
and his staff.
The
RPM requested
his staff assigned
to the exit point to be more observant.
The
commended
the Electricians for reporting the
observation,
stating that with 1600 entries
per day
some improper conduct is missed
by his staff.
Undressing
procedures
were posted at the exit point.
One of'he Electricians
dropped his Thermoluminescent
Dosimeter
(TLD) in a contaminated
area.
It was
re-assembled
and reported to a radiation protection
technician
(RPT) who returned it to the electrician in
a rude manner without surveying the
TLD.
This concern could not be substantiated.
The
RPM did discuss
the concern,with his staff
requesting that they be more sensitive to concerns
expressed
by workers.
The engineer elected
not to request
the presence
of
(}uality Control (gC) to witness
a test although the
work package stipulated that
gC witness the test.
The
engineer
stated that gC's presence
was unnecessary
since
he felt the test would fail.
~Findin
Resolution
This concern
was substantiated.
The engineer
had discussed
his intentions with gC
prior to performing the test
and agreed that it would
not be consistent with the
ALARA concept for
gC to
witness
a test which would be likely to fail.
The
test subsequently
failed.
The inspectors verified
that the work had not proceeded
beyond the procedural
gC "hold point."
17
Concern ¹8
A tool crib attendant
located inside the containment
building informed one of the Electricians that it was
difficult to read the tool number/size.
The
electrician expressed
this item as
an
ALARA concern.
This concern
was substantiated.
Discussions
were
held with two tool crib attendants
.
Each stated that
the lighting was marginally acceptable.
~Findin
Resolution
Several
additional strings of lighting were installed
in the tool crib.
Further discussions
with all involved personnel
disclosed that the
Electricians
were given the opportunity to discuss their concerns
with a radiation protection representative
prior to their dismissal.
The Electricians'upervision
informed the inspector that his staff
had asked the Electricians to talk to the Radiation Protection
Foreman
on shift.
The Electricians
agreed.
However,
as they were
walking to the Radiation Protection
Foreman's office, the
Electricians
decided
not to discuss their concerns with the Radiation
Protection
Foreman.
The Electricians'upervisor
dismissed
the
Electricians
upon learning that they were not willing to discuss
their concerns.
The Electricians
subsequently
held
a meeting with their supervision
and the
RPH during the inspection period.
They were able to resolve
their concerns
and returned to work before the end of the inspection
period.
The above observations
were discussed
with the
RPH and at the exit
interview.
The
RPM and management
attending
the exit interview
stated that many of the electrician's
concerns
were valid and were
considered
to be unacceptable
work practices.
The
RPH added that
appropriate
action will be taken to further evaluate
and correct the
weaknesses
that were identified.
The inspector
concluded that
no violations or deviations
had
occurred.
This matter is closed.
5.
~F~iil~iit
~
T~
Units
1 and
2 were toured extensively during the inspection.
Independent
radiation measurements
were
made using
NRC ion chamber
survey instrument
Model R0-2, Serial ¹022906,
due for calibration
on March 16,
1990.
The
inspectors
observed
the following:
Radiation monitoring equipment
was in current calibration.
a.
Work practices
were consistent with the
ALARA concept.
All personnel
observed
on tour were wearing proper dosimetry.
C.
18
d.
Posting
and labeling practice were consistent with 10 CFR 19. 11 and
20.203.
e.
During a tour conducted
on October 25, 1989, cleanliness
in
.radiologically controlled areas of the Unit 1 Auxiliary and Spent
Fuel Buildings was very poor.
Items lying unattended
in contaminated
areas
included plastic
and oily paper refuse,
used leather
and rubber
gloves,
various chemicals,
face shields
and welders
face shields,
and
tool s.
f.
Various electrical cords, ventilation
ducts
and tygon tubing drain
lines traversing both non-contaminated
and contaminated
areas
were
not secured
in a manner to prevent contamination of the non-
contaminated
areas.
Drain lines
used for draining contaminated
liquids were not consistently identified as containing radioactive
material.
g.
Two fire exits were blocked off.
h.
-Sparks resulting from welding were not adequately
monitored by an
assigned fire watch,
The assigned fire watch was performizg
a
grinding oper ation while the welding was in progress,
and was out-
of-view of the welding.
i.
A worker was wearing
a plastic face shield in the "up" position while
working on
a contaminated
RHR valve.
A Radiation Protection
Technician observing the operation
took no action to instruct the
worker to properly don the face shield unti 1 it was brought to his
attention
by the inspectors.
j.
Lighting was extremely poor in the Unit 1 primary sample
room and
completely absent
in the boric acid evaporation
room.
k.
Several
liquid effluent drain line/vent lines connected
to
polyethylene bottles were. found to be crimped.
Some of the
drain/vent lines serviced
contaminated
systems.
l.
An electrical
cord was coiled in a stairway leading to the 1-2
pump
room.
The cord created
a serious tripping hazard.
The
inspectors
noted that ample
room was available
to store the cord
without creating the tripping hazard.
The above observations
were immediately brought to the attention of the
licensee's
staff.
The inspectors verified that the licensee
took
immediate action to address
the inspectors'bservations,
with the
exception of observations
made near the completion of the inspection
period.
The inspectors
brought the above observations
to the licensee's
attention
during the exit interview.
The need for maintaining plant cleanliness
and
being sensitive
to similar observations
during tours conducted
by the
plant staff was emphasized.
The licensee's
performance
in this area
was
adequate
to meet regulatory
and procedural
requirements.
19
6.
Exit Inter view (30703)
The inspectors
met with the licensee
representatives
denoted
in paragraph
one at the conclusion of the inspection
on November 2,
1989.
The scope
and findings of the inspection
were summarized.
The licensee
was- informed
of the apparent violation, discussed
in paragraph
3.H,
and of the
. observations
made during facility tours,
discussed
in paragraph
5, above.
20