ML17187B041
| ML17187B041 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/02/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17187B040 | List: |
| References | |
| 50-237-97-10, 50-249-97-10, NUDOCS 9707080060 | |
| Download: ML17187B041 (16) | |
See also: IR 05000237/1997010
Text
U.S. NUCLEAR REGULATORY COMMISSION
Docket Nos:
Licenses No:
Reports No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9707080060 970702
ADOCK 05000237
G
REGION Ill
50-237; 50-249
50-237/9701 O(DRS); 50-249/9701 O(DRS)
Commonwealth Edison Company
Dresden Nuclear Station, Units 2 and 3
6500 N. Dresden Road
Morris, IL 60450
May 19-23, 1997
R. Paul, Senior Radiation Specialist
R. Glinski, Radiation Specialist
Gary L. Shear, Chief, Plant Support Branch 2
Division of Reactor Safety
EXECUTIVE SUMMARY
Dresden Generating Station, Units 2 & 3
NRC Inspection Reports 50-237/97010; 50-249/97010
This announced inspection included a review of the licensee's performance,
specifically an evaluation of the effectiveness of the radiation protection program.
Three violations of NRC requirements were identified, one concerning inadequate
high radiation area (HRA) controls,. another concerning the lack of an evaluation to
determine radiological conditions in an area in which a person received an intake of
radioactive material, and one which involved the failure to meet a station training
requirement.
A self revealing event occurred where two workers could not exit from a
posted and controlled HRA because a contract radiation protection
technician (APT) failed to erisure all workers were out of the HRA before
locking the door allowing egress. The dose rates in the room in which there
was no egress were less than one mrem per hour (Violation Nos. 50-
237 ;249-97010-01 (DRS) (Section R1 .5).
A self revealing event in which a worker received a slight intake of
radioactive material occurred because the licensee failed to perform an
evaluation of the radiological conditions in the area he was working. The .
investigation/assessment of the event identified several weaknesses and
poor worker performance. The immediate corrective actions were
appropriate (Violation Nos. 50-237;249-97010-02(DRS)) (Section R1 .6).
The overall RP training program was well implemented. A violation was
issued for the failure to follow a training procedure related to initial training
on a new instrument (Violation Nos. 50-237;249-97010-03(DRS).
Refueling outage dose (D3R14) was well controlled. Rework, which had
been a cause of significant dose during previous outages, was reduced. The
station's improved work process program radiologi~al controls, and ALARA
initiatives were instrumental in reducing rework and outage dose.
Conservative actions were taken for all work where the potential for alpha
airborne contamination was possible (Section R1 .2).
With the exception of some discrepancies noted with the calibration and test
results of alpha monitoring equipment, the overall calibration and test
program for alpha monitoring, the whole body frisker, the whole body
counter and tool monitoring equipment was well implemented (Section
R1 .4) .
Report Details
Plant Support
R 1
Radiological Protection and Chemistry (RP&C) Controls
R 1 . 1
Control of Radioactive Materials and Radiological Surveys
a.
Inspection Scope (83750)
The inspectors reviewed the control of radioactive materials and the posting of
radiological hazards within the radiologically controlled area (RCA) and RCAs
outside the power block. The inspectors made frequent tours of the radiologically
posted areas and reviewed radioactive material labelling and radiological postings.
b.
Observations and Findings
During these tours, the inspectors noted good control and labelling of radioactive
materials. The inspectors found high and very high radiation areas to be posted and
controlled in accordance with NRC requirements.
During one tour of the reactor buildings, the inspectors noted discrepancies
between some areas which had postings identifying "no loitering, high radiation
field" signs and other areas with about the same general radiation field levels that
did not have similar postings. The inspectors further noted that the licensee did not
have any specific criterion to be used for posting of areas with elevated dose rates.
This matter will be reviewed by the licensee who intends to develop guidelines
concerning posting of those areas. Verification of radiation levels in the reactor
buildings was performed and the inspectors found they were comparable to those
posted.
c.
Conclusions
Tours of the RCA and outside the power block identified that, with the exception of
elevated dose rate area discrepancies inside the reactor building, that areas were
properly posted and that radioactive material was properly controlled.
R1 .2
Unit 3 Outage Dose Control and ALARA Implementation
a.
Inspection Scope (83750)
The inspector reviewed the licensee's radiological controls, dose reduction/ALARA,
and work practices for the D3R 14 refueling outage. The inspection consisted
primarily of in-plant observations, attendance at pre-job meetings, review of records
(ALARA plans, radiation work permits (RWPs), work packages, etc), discussions
with workers and discussions with members of the work control groups. The
following high dose jobs were observed in progress (either remotely or on location):
2
b.
.,
reactor water cleanup (RWCU) system pipe replacement
RWCU removed pipe and heat exchanger shipping activities
removal of waste activities associated with the RWCU
refuel floor work activities.
aspects of the control rod drive (CAD) removal activities.
Valve work activities
Drywell work activities
Observations and Findings
During a recent NRC maintenance team inspection of work activities during D3R 14
it was found that the licensee effectively implemented ALARA controls. The
findings of the inspection are documented in Inspection Report Nos. 50-10/97007,
50-237 /97007, and 50-24 7 /97007. During that inspection it was noted that
ALARA tools implemented for the outage included the use of additional shielding,
RWCU chemical decontamination, and the incorporation of lessons learned from
previous outages which effectively mitigated the effects of the increased dose
rates. In addition, major outage activities were assigned a manager/overseer who
was responsible for developing and implementing the ALARA plans and for ensuring
effective radiological controls were used, good oversight by radiation protection
personnel and sufficient coordination between working groups occurred, and that
there were good radiological controls established for Unit 3 drywell, RWCU, and
refuel floor work activities.
As of May 23, 1997, the licensee had accrued about 180 rem with about eighty
five percent of the scheduled work completed. At that point the overall outage
dose was expected to meet the revised goal of 245 rem. The dose goals were
based on previous similar work and included the dose for added work scope,
rework, and emergent work of about 30 percent of the projected dose, most of
which was due to added scope. The added scope was due primarily to work that
was found to be required after post shut down surveillances were performed,
. however, there appeared to be sufficient planning and preparation time to provide
RP input and implement ALARA initiatives before the added work began. The
licensee's efforts to reduce the amount of rework which contributed to significant
station dose during previous outages, were effective during D3R 14. Contingencies
w.ere in place for the major dose producing jobs and RP was involved in the planning
process.
The inspectors observed that the RP department maintained close oversight of
outage tasks and dose was effectively controlled as a result. Although there were
some observations of persons loitering and of poor radworker practices (Inspection
3
c.
Report Nos. 50-10/97007, 50-237197007, and 50-249/97007), there was
considerable improvement from previous outages.
Roles and responsibilities of individuals were clearly discussed at the pre-job
meetings and special instructions were prepared for those jobs observed by the
team. The RP staff clearly communicated RWP requirements, dose and dose rate
alarms, and radiological hold points. In general, the inspectors observed good
radiation worker (radworker) practices and workers properly donned and removed
protective clothing and demonstrated a good knowledge of electronic dosimetry
alarm setpoints. The licensee provided additional support at the Drywell step-off-
pads which were effective in improving worker performance and correcting errors.
Workers demonstrated good awareness of radiological conditions and appropriate
use of low dose waiting areas.
The inspectors also noted that because the licensee found alpha contamination on
smears taken in the Unit 3 main steam top valve and some other areas, it
implemented conservative actions for all work in those areas and on certain
systems. Increased air samples and smears were taken for condenser work, main
steam line valve (MSIV) work in the X area, drywell MSIV work, isocondenser work,
and high pressure cooling injection (HPCI) work. ALARA/Total Effective Dose
Equivalent (TEDE) reviews were performed and respirators were worn until
conditions existed such that it would not be ALARA/TEDE to wear them. In
addition the inspectors found that the licensee has been aggressive in, identifying
those areas of the station with the highest probability for alpha contamination, in
identifying the alpha isotopes, and in developing a program to reduce and control
the alpha contamination.
Conclusions
The licensee's measures to control Unit 3 outage (D3R14) dose were effective. The
licensee effectively used past outage work critiques to apply lessons learned to
existing work. Rework, which had troubled the station during previous outages was
markedly reduced through better planning, supervisory oversight, and work control.
During outage work evolutions, workers generally demonstrated good radiological
practices, and aggressive measures to control the potential for alpha radiation
airborne activity, were taken. Pre-job ALARA meetings ensured workers were
aware of radiological requirements, and specific work contingencies.
R1 .3
Radiation Work Practices
a.
Inspection Scope (83750)
The inspectors reviewed the licensees initiatives to prevent and control poor
radworker practices which had been a continuing problem, especially during
refueling work outages.
4
b.
Observations and Findings
The inspectors observed general radiation worker practices of those personnel
working in the Unit 3 drywell and the RWCU. Radiation worker practices observed
included, personal monitoring techniques, use of protective clothing, dosimetry
placement (thermolumenescent dosimetry (TLDs) and electronic dosimeters (EDs)),
ALARA practices (use of low dose zones, controlling crew size), working conditions,
understanding general and specific area dose rates and RWP requirements, and
station housekeeping.
c.
Conclusions
The inspectors found that other than the poor radiation work practices that were*
observed and documented in Inspection Report Nos. 50-10/97007, 50-237197007,
and 50-249/97007, radworker practices have generally improved from those noted
during previous outages. Initiatives such as the greeter program, increased
emphasis on worker responsibility, first line supervisory oversight, and stronger RP
control point oversight were instrumental in reducing poor radworker practices.
R1 .4 . Facilities and Equipment
a.
Inspection Scope (83750)
The inspectors reviewed the operation and calibration methodology for the whole
body friskers, tool monitors, and the portable alpha counting detectors. The
inspection included a walk down of the whole body friskers, independent testing of
whole body frisker and tool monitor alarms and set points, observation of
radioactive source condition, and review of procedures, detector operability history,
and calibration and test results.
b.
Observations and Findings
The calibrations and instrument tests were performed as required. Frisker alarms
were nominally set at about 5000 dpm with detector efficiencies at about 10 to 15
percent. The gamma portal whole body frisker can detect down to about 50
nanocuries cobalt-60 at about a 90 percent confidence level. Calibration and test
methodology is technically sound for all detectors inspected, and availability of
monitors is high, running at about 90 percent. Several new whole body friskers
were noted to be onsite but were not yet operable. The purchase of the monitors is
part of a long term program to generally upgrade radiation monitoring equipment.
The licensee hired a contractor to review and upgrade calibration procedures for all
portable hand held detectors. The inspectors found that several of the alpha
standards appeared degraded; the licensee was aware of those conditions and new
standards (alpha and beta-gamma) had been ordered. There did not appear to be
any significant difference between the observed and expected output of the
degraded standards.
Several discrepancies were found in the alpha counting equipment calibration and
5
Several discrepancies were found in the alpha counting equipment calibration and
maintenance program logs. The inspectors noted that the record for one of the
alpha detectors showed about a 50 percent different detection efficiency using one
calibration source compared to the use of others. The inspectors subsequently
learned that the licensee had previously observed the same discrepancy, and as a
result identified and disposed of a defective alpha source. The licensee's
investigation of this matter found that the defective source had not been
electroplated and was producing about one half of its original radioactive output,
which in this case resulted in a conservative error. The inspectors had not observed
similar defective sources during the inspection.
c.
Conclusions
Several equipment calibration and maintenance program log discrepancies and an *
error in the use of an alpha calibration source were identified. However, the overall
calibration and maintenance program for those monitors reviewed was well
implemented, and the monitors were noted to have good operability history.
R 1 . 5
High Radiation Area Event
a.
Inspection Scope (83750)
The inspectors reviewed the circumstances associated with a self revealing event in
which workers were prevented from exiting a posted and controlled high radiation
area (HRA). The inspection included a review of the licensee's investigation, and a
review of applicable procedures and documentation.
On April 21, 1997, electrical maintenance (EM) personnel were working in the Unit
2 drywall, which was designated as a locked high radiation area (LHRA). The
entrance and egress into the drywall was through the personnel hatch which was
accessible only through the drywall anteroom. During normal operation the drywall
personnel hatch is posted as a very high radiation area (VHRA) and locked.
Because Unit 2 was in a forced outage, the controls were removed from the
personnel hatch and the door leading into the anteroom was posted as a LHRA and
controlled with a lock. On April 1, the anteroom was unlocked while the EMs were
performing their work and a RPT was assigned to perform duties as the LHRA
attendant. The attendant was responsible for ensuring all regulatory requirements
for HRA controls were implemented.
During the day, numerous entries into and out of the area were made. At about mid
afternoon, four of the EMs exited the area and the RPT thought they were the last
group of EMs working in the drywall. Based on a discussion the *RPT had with the
EMs, the RPT felt confident that everyone was out of the drywall. The RPT did not
enter the drywall to verify that all workers had left and after a few minutes he
placed the lock on the hasp of the door leading into the anteroom. The RPT then
left the area to find a person to verify that the anteroom door was locked. Shortly
after the RPT left the area another drywall worker tried to exit through the anteroom
door but was unable to because the door was locked from the outside. One of the
6
EMs who had exited the drywell earlier saw the lock on the door moving and
discovered two workers were locked inside the anteroom. After RP was informed
of this condition the door was unlocked and the workers left the area. Dose rates in
the anteroom were less than 1 mrem/hour. The workers were in the anteroom for
about 1 2 minutes and their personal exposure for the day was 37 mrem and 48
mrem, respectively. Failure to provide individuals an exit from the locked and
posted LRHA is a violation of 1 O CFR 20. 1601 (d) which requires that the licensee
establish the controls required by this section in a way that does not prevent
individuals from leaving a HRA. (Violation 50-2371249-97010-01)
The causes of the event included the failure of the RPT to ensure that all personnel
that entered the area exited the area, and the failure to establish a written log or
some other mechanism to track personnel entry into the LHRA; the RPT tried to
maintain a mental log of entries.
Corrective actions taken to prevent recurrence included the development of a
method to ensure tracking of personnel accountabiliW for LHRANHRA entries,
physical verification to ensure all personnel have exited from the HRAs, and a
station wide review of all HRAs to determine the status of accessibility for egress of
all HRAs.
c.
Conclusions
The inspectors concluded that the licensee's investigation and immediate corrective
actions were appropriate. Several problems were identified including, the RPT in
attendance failed to ensure there were no persons remaining in the drywell before
locking the door I and there was no mechanism in place to track workers entry and
egress from the HRA. A violation was identified for failure to allow egress from a
locked HRA.
R1 .6
Intake of Radioactive Material During Decontamination Work in the Unit 2 Torus
Basement
a.
Inspection Scope (83750)
The inspectors reviewed the circumstances surrounding a self revealing event in
which a worker had a intake of radioactive material during decontamination work in
the Unit 2 basement. The review consisted of interviewing workers involved in the
job, reviewing the licensee's preliminary investigation and reviewing applicable
procedures and documentation.
b.
Observations and Findings
On May 4, 1997, a contract station decon technician (CDT) was performing
decontamination activities in the trench area of Unit 2 torus bays 9 and 10 and part
of the non-trenched area of bay 11. The work consisted of wetting the material,
using a scraper and/or rags to remove the contaminated material, and then
7
collecting it into a plastic bag. The CDT wore protective clothing including vinyl
pants, double rubbers and gloves and safety eye glasses.
After completing the job, the worker alarmed a personnel contamination monitor at
the RP control point prompting an investigation by the licensee. The licensee's
evaluation concluded that the worker had received an intake of radioactive material
resulting in a committed effective dose equivalent (CEDE) of 5 mrem and a total
effective dose equivalent (TEDE) of 22 mrem. The inspectors independently
reviewed this evaluation and agreed with the dose estimate.
The inspectors independent review agreed with the licensee's conclusion that the
root cause was the failure to properly evaluate the job. Specifically, the contract RP
supervisor was aware of a 500,000 dpm/100 cm2 area in bay 11, but failed to
recognize that an ALARA briefing was procedurally required at these contamination
levels. The failure to perform this briefing, resulted in the licensee's failing to
consider additional controls for the job, including continuous RPT coverage, air
sampling or engineering controls. Additionally, the CDT used a routine survey map
which did not include surveys of the trenches in bays 9 and 10. Subsequent
surveys of these areas identified smear results ranging up to 1 . 5 million dpm beta-
gamma and 1,800 dpm alpha.
A significant contributing cause was poor communications between the contract RP
supervisor, CDT foreman, CDTs and contract RPTs. The contract RP supervisor
instructed the CDT foreman to decon the trench area of bay 11 in the Unit 2 torus
basement. However, the foreman instructed the CDTs to decon the trench areas in
bays 9 and 10 instead of bay 11. After the first CDT completed his inspection of
bays 9 and 10, he left to obtain a vacuum cleaner for the job, (the second CDT
never entered the torus for this inspection because he was the outman). At about
the time the first CDT left the area and found that a vacuum cleaner was not
available, he was removed from the job and reassigned to perform fire watch duties.
Subsequently, the second CDT was assigned to the torus job, but without receiving
a turnover from the first CDT. Because there was no RPT control point in Unit 2,
the second CDT discussed this job with an RPT at the Unit 3 control point.
Although this RPT was unfamiliar with the Unit 2 basement conditions and was not
told by the CDT of the job specifics, the RPT did not question the CDT or
investigate the job. This evolution occurred without licensee oversight indicating a
weakness in the control of contractor activities.
Poor communication was a contributing cause for a previous violation for a similar
event documented in Inspection Report Nos. 50-237/249/96009. Specifically, in
that event, the duty RP shift supervisor (RPSS) was not informed of the scope of
work activities and job scope changes. Although none of the corrective ac1ions for
this event would have prevented the torus decon event, the inspectors concluded
that the previous corrective actions were weak because they were not sufficiently
broad enough to prevent similar events from occurring. The licensee planned to
evaluate this observation during the development of corrective actions for this
event.
8
Immediate corrective actions for this event included instructing all RP and decon
personnel that evolutions performed in either unit that does not have a dedicated RP
control point, be discussed at the station RP desk.
The failure to perform an ALAR A review to evaluate the radiological hazards that.
could be present is a violation of 10 CFR 20. 1501, which requires that surveys be
conducted to ensure compliance with the regulations in part 20. Because an
ALARA review was not accomplished, the licensee did not perform a thorough
radiological survey of the actual work areas and did not evaluate other appropriate
ALARA controls to assure compliance with 10 CFR 20.1201(a)(1)(i), which limits
the total effective dose equivalent to 5 rems per year. (Violation
50-237 /249-97010-02)
c.
Conclusions
The licensee's weak oversight, worker's lack of familiarity and knowledge of station
requirements, and work conditions caused a personal intake. Contributing to the
root cause was poor communication and contact between all persons involved in
this event. One violation was identified for the failure to perform an adequate
survey to ensure 10 CFR 20. 1201 dose limits.
R4
Staff Knowledge and Performance in RP&C
R4. 1
Implementation of the Greeter Program
a.
Inspection Scope (83750)
The inspector interviewed RP staff, reviewed RP policies, and observed performance
regarding implementation of the greeter program during D3R14.
b.
Observations and Findings
In late 1996, the licensee initiated a greeter program to improve ALARA practices
by ensuring radworker understanding of radiological conditions in their specific work
areas and of station requirements for working in radiologically posted areas (RPAs).
The workers were challenged by personnel at the main access control points before
entering the RCA. For D3R 14, the station trained individuals with no nuclear
experience to function as greeters. These individuals received N-GET training and
instruction from ADM-10 . .The program was described in RP Policy Memo ADM-10,
Rev. 01.
The inspectors observed greeters at the main access control points and noted that
the greeters maintained a log of personnel that demonstrated insufficient
knowledge. Personnel refused entrance to the RPA by greeters were subsequently
denied access to the APA, and the access was restored only after a meeting with
RP management. The greeters generally quizzed workers from ADM-10 guidance.
However, the inspectors identified that the greeters were not routinely reminding
workers of high radiation area control responsibilities and the responsibility to return
9
the work area to the "as found" condition. The greeters stated that they had not
been instructed to ask these questions. The failure to train greeters to remind
workers of responsibilities for high radiation areas and housekeeping was contrary
to commitments made to the NRC in letters dated January 13 and February 26,
1997. RP management indicated that these commitments applied during plant
operation, but not outage activities. The inspector discussed with RP staff that the
letters did not state this restriction and RP stated that greeters would receive
instruction to challenge workers in these two issues.
The overall success of the greeter program was demonstrated by the fact that 70% *
( 114/153) of RP deficiencies identified in April 1997 were attributed to greeters.
Observation of greeter activities and interviews with RP staff further indicated that
radworkers were sufficiently aware of their responsibilities.
c.
Conclusion
The greeter program successfully identified numerous outage personnel who lacked
sufficient knowledge or preparation for work in the RPA. The inspectors observed
that greeters were not instructed to implement commitments made to the NRC and
this issue will be reviewed as an Inspection Follow-up Item. (IFI
50-237,249/97010-04)
RS
Staff Training and Qualification in RP&C
R5.1
Training for Contract Radiation Protection Technicians (CRPTs)
a.
Inspection Scope (83729)
The inspectors interviewed Professional Training Center (PTC) staff, contract
radiation protection technicians (CRPTs), and RP supervisors (RPS) regarding the
training and qualifications required for CRPTs working D3R 14. The inspectors also
reviewed training procedures, lesson plans, and records.
b.
Observations and Findings
The inspectors noted that the procedure for processing CRPTs (NRP 5000-4, Rev.
2) stated that prospective CRPTs should attend Core training, must pass a ComEd
approved Health Physics Theory Test (80%), and receive 80% or higher on the
standardized Northeast Utilities HP Theory Test. After On-the-Job (OJT) training
with RP instrumentation, the individuals were required to pass a radiation detection
meter reading test and successfully complete two survey scenarios, one of which
covered a routine RP survey and the other which addressed a personnel
contamination event.
The inspectors noted that the classroom training covered the practical aspeGtS of
over 60 CAPT activities. Then, OJT was conducted by both PTC and corporate
Com Ed staff. Training records indicated that prospective CRPTs received the full
training program in accordance with the PTC instructions prior to working in D3R 14.
10
The records also revealed a failure rate of 8% for prospective CRPTs, with most
failures occurring on the written tests. Individuals who failed the test were denied
employment at the station. Although documentation for each TPE failure was
required by PTC core training instructions, the PTC did not document the first TPE
failure.
Interviews with RPSs and CRPTs working in D3R14 indicated that the CAPT training
adequately prepared the workers for outage tasks. In addition to the tasks covered
in the PTC training, CRPTs were also trained for other instrumentation and tasks. A
CAPT qualification matrix was maintained by an outage coordinator to document
this information and to. ensure that only qualified CRPTs were assigned to specific
tasks.
c.
Conclusion
The training for prospective CRPTs was comprehensive and well implemented. One
discrepancy was noted in the training documentation.
R5.2
Continuing Training for Dresden RPTs
a.
Inspection Scope (83750)
The inspector interviewed training and RP personnel, and reviewed site training and
evaluation documentation regarding the APT continuing training program for new
instrumentation.
b.
Observations and Findings
Continuing APT training consisted of classroom instruction, OJT, and TPE. Within
the training program, a Radiation Protection Training Advisory Committee (APT AC),
composed of RP and training staff, met monthly to review training needs.
Regarding new instrumentation, classroom instruc.tion was optional, however, the
The inspector reviewed lesson plans and instructions contained in the training
program. Training Department Instruction, "Conduct of On-the-Job Training and
Evaluation" (TDl-206, Rev. 10), stated that OJT and TPE are separate processes,
and that the evaluator is not to guide, prompt, or coach the trainee during TPE.
Interviews with training instructors and coordinators, evaluators, and RPTs indicated
that plant staff understood the distinction between OJT and TPE.
Review of training for new RP instrumentation indicated weaknesses in
. communication and documentation. Training records demonstrated that the initial
performance evaluations for the PASSPORTPersonal Alarm (which measures air
quality in confined spaces) were conducted from October 1995 to January 1996.
A review of training records for six RPTs revealed that only three of the training files
contained the sign-off sheets which showed successful completion of the training.
However, the Person Course History List from the Training Administration System
11
listed completed PASSPORT training only for the RPT files which did not have the
sign-off sheet. None of the training records had the PASSPORT information in the
training file and on computer file. This was a weakness in the recordkeeping for
completed training.
An evaluation conducted by the licensee regarding the initial PASSPORT training
determined the following:
The RPTAC meeting minutes for March 1995 failed to document the TAC's
intention that an evaluation phase be required for PASSPORT training, and
this failure to document the need for an evaluation provided RP trainers with
inadequate guidance;
Although electronic records indicated that RPTs received this training, the
lack of hardcopy PASSPORT evaluation records indicated that training staff
failed to complete the documentation required by TOI 702, "RPT Continuing
Training";
Eight of the nine RPTs interviewed by the licensee did not recall any
evaluation phase for PASSPORT training.
The licensee's evaluation concluded that the initial PASSPORT training consisted of
instruction and OJT, without any subsequent evaluation (TPE). The failure to
conduct an evaluation for the PASSPORT was contrary to TOI 206 (OJT Trainer and
Evaluator Qualification) which stated that evaluations of task performance must be
conducted .in a consistent and objective manner to ensure that the required
knowledge and skills have been acquired by the trainees. In addition, TOI 702
required that the training program structure include Performance Training which
evaluates the trainee's ability to actually perform a task. The failure to conduct
PASSPORT evaluations was a procedural violation of Training Department
Instruction (TOI) 206 which required evaluations of trainee task performance. The
licensee has subsequently conducted OJT and TPE for the PASSPORT in
accordance with training instructions. Although problems with PASSPORT training
were identified, no safety problems associated with the use of this instrument
occurred and the RPTs were confident in their ability to use the instrument.
(Violation 50-237 /249-97010-03).
The licensee evaluation further noted that although training for several other tasks
was conducted in accordance with TD ls and TAC review, the TAC did not review
training for the IPM-90 whole body monitor. Interviews indicated that RP staff
procured and trained RPTs to source' check the IPM-90 without the knowledge of
the training department. Subsequently, RPTAC minutes for December 20, 1996,
stated that all RPTs would be disqualified from the IPM-90 until the proper OJT/TPE
was completed.
This was another example of the communication weakness which
existed between the training and RP departments.
To improve the training program, the licensee is considering a task qualification
system rather than the current position qualified system. This would allow the plant
12
to qualify and disqualify RPTs for individual tasks rather than all tasks collectively.
In addition, RP management recently added Line Management Observation (LMO) to
the RPT training program. LMO consisted of first line RPSs accompanying RPTs
during performance of routine and non-routine tasks and evaluating the RPT
performance. To date, the RPS staff has not identified any adverse trends in RPT
performance.
c.
Conclusions
Although weaknesses were identified, the training department and RP staff
generally conducted continuing training for RPTs in accordance with station
practice$. One procedural violation was identified for failure to conduct evaluations
during the initial PASSPORT training. In addition, weaknesses in training
documentation and communication were identified.
RS
Miscellaneous RP&C Issues
R8.1
(Closed) Violation (50-237,249/96006-07(DRS), LER 96-010: failure to perform
'
Technical Specification required monthly analysis for tritium on the Unit 1 Main
Chimney, Units 2/3 Main Chimney, and Reactor Building Vent Stack samples. Due
to personnel error, the lack of an operational liquid scintillation counter, and an
inconsistent Pre-Define method to control sampling and analysis, the licensee failed
to complete the required monthly tritium analyses from June 1995 to May 1996.
The licensee analyzed the chimney and stack samples on June 20 and 21, 1996
and the 1995 Annual Radiological Environmental Operating Report and the
applicable Semiannual radioactive Effluent Release reports were revised. In
addition, the Pre-Define was revised to require completion of the analysis prior to
being signed and the analysis of the tritium samples was added to the Chemistry
Technician assignment sheet. This item is closed.
R8.2
(Closed) Violation 50-237;249/97010-03: failure to conduct Task Performance
Evaluations for initial PASSPORT training. Interviews with $taff and review of a
licensee evaluation and training records revealed that the initial training for the
operation of the PASSPORT Personal Alarm, conducted from October 1995 to
January 1996, did not include an evaluation phase. Evaluations of personnel were
required to ensure that the required knowledge and skills have been acquired by the
trainees.
Subsequently, the licensee trained plant RP staff on the use of the PASSPORT by
conducting the OJTffPE phases with the appropriate sign-offs. The inspector's
review of training records and interviews with staff showed that the PASSPORT re-
training was successfully conducted from December 1996 to February 1997. This
item is closed.
13
...
V. Management Meetings
X1
Exit Meeting Summary
On May 23, 1997, the inspectors presented the inspection results to licensee
management. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was
identified.
14
..
- .
PARTIAL LIST OF PERSONS CONTACTED
Com Ed
M. Heffley, Station Manager
F. Spangenburg, Regulatory Assurance Manager
C. Howland, Radiation Protection Manager
J. Moser, ALARA Manager
L. Aldrich, Assistant RPM
J. Hill, Lead Radiation Protection Supervisor
M. Friedmann, Lead Health Physicist
J. Kuczynski, Internal Dosimetry Health Physicist
L. Jordan,
INSPECTION PROCEDURES USED
IP 83750:
Occupational Radiation Exposure
Opened
50-237;249/97010-01
50-237;249/97010-02
50-237;249/97010-03
50-2371249/97010-04
Closed
50-2371249-96006-07
50-2371249-97010-03
Discussed
None.
ITEMS OPENED, CLOSED, AND DISCUSSED
Failure to provide egress from a HRA (Section R1 .5)
Failure to provide an adequate evaluation (Section R1 .6)
Failure to follow requirements of training procedure
(Section R5. 1) *
IFI
Verify actions taken to ensure implementation of
commitments made to NRC (Section R4. 1)
Failure to complete the required monthly tritium analysis
for Units 1 ,2, 3 Chimney and Units 2/3 Reactor Building
stack samples from June 1995 to May 1996
Failure to conduct Task Performance Evaluations for
PASSPORT air quality monitor
15