ML20035H559
| ML20035H559 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 04/21/1993 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035H551 | List: |
| References | |
| 50-458-93-12, NUDOCS 9305050269 | |
| Download: ML20035H559 (17) | |
See also: IR 05000458/1993012
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APPENDIX B
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-458/93-12
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Operating License: NPF-47
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Licensee: Gulf States Utilities
P.O. Box 220
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St. Francisville, Louisiana 70775
Facility Name:
River Bend Station
Inspection At:
River Bend Station Site, St. Francisville, Louisiana
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Inspection Conducted: March 29 to April 2, 1993
Inspectors:
A. D. Gaines, Radiation Specialist
L. L. Coblentz, Senior Radiation Specialist, Region V
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Approved:
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Blaine Murray,'Caief
ilities Inspection
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Programs Section
Inspection Summary
Areas Inspected:
Special, announced followup inspection of corrective actions
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for radiological control problems regarding control and surveys of radioactive
waste resulting from outage activities.
The inspection included a review of
changes, training and qualifications, internal exposure control, external
exposure control, audits and appraisals, surveys and monitoring, and
radioactive materials and contamination controls.
Results:
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A new Director-Radiological Programs was appointed, but he did not meet
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the qualification requirements. This was identified as a violation
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(Section 2.1).
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Integrated training, team building training, and incorporating radiation
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practices in regular craft training were very good (Section 2.2).
Communication among the radiation protection personnel was improved
(Section 2.2).
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9305050269 930430
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Airborne surveys were re.--asentative of the workers breathing zone
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(Section 2.3).
The failure to post a scaffolding that could have provided entry to a
posted High Radiation Area was identified as a violation (Section 2.4).
Quality assurance audits and surveillances were good and identified
items which were corrected promptly (Section 3.1).
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Radiological Deficiency Reports identified problem areas and followup
corrective actions were good (Section 3.1).
The trending of the problems identified in the Radiological Deficiency
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Reports and taking immediate action when the trending warranted was very
good (Section 3.1).
Changes to procedures were appropriate (Section 3.2).
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The licensee identified the failure of four individuals to follow the
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procedure for personal contamination monitoring when exiting the
radiological controlled area.
This was identified as a noncited
violation (Section 3.3).
There was improvement in the control of radioactive materials, but
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two examples of a failure to survey were identified as a violation
(Section 3.4).
Summary of Inspection Findings:
Violation 458/9312-01 was opened (Section 2.1).
Violation 458/9312-02 was opened (Section 2.4).
A noncited violation was identified (Section 3.3).
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Violation 458/9312-03 was opened (Section 3.4).
Violations 458/9233-01, -02, -03, -04, -06, -07, -08, -09, -10,
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-11, -12, -13, -14, -15, -16, and -17 were closed (Section 4).
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Unresolved Item 458/9235-02 was closed (Section 5.1),
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Attachment:
Attachment - Persons Contacted and Exit Meeting
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DETAILS
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1 BACKGROUND INFORMATION
1.1 Previous Inspection History
NRC Inspection Report 50-458/92-33 documented inspection findings for the
inspection conducted October 7-16 and October 19-23, 1992.
This Inspection
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Report identified 17 violations involving radiation surveys, radiation
protection procedures, and the transfer of radioactive material recipient.
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.The most significant of the violations included the failure to survey or
conduct adequate surveys of bags containing radioactive waste material, the
failure to conduct adequate radiation and airborne surveys during maintenance
activities, the failure to survey material released from the facility to an
offsite scrap yard, and the failure to adhere to plant procedures regarding
posting and restricting access to high radiation areas.
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Since the inspections, the licensee had performed numerous corrective actions,
both immediate and long term.
1.2 Licensee Corrective Actions
The following are some of the corrective actions implemented by the licensee
since the October 1992 inspection:
In the area of general radiation protection controls the licensee had:
Installed a new scanning system with bar codes for entry into the
radiological controlled area.
Established a Radiation Protection Technician Advisory Committee.
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Developed a radiation protection Turnover / Briefing Checklist.
Reiterated to all personnel the procedural requirements pertaining
to performance deficiencies in handling radioactive material.
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Improved the checklist for Maintenance Management Field Observations.
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Established Standing Instruction 92-0014 which requires the use of
extremity monitoring when unpacking any primary valve.
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Assigned a radiation protection foreman to the maintenance department to
coordinate plans for the week and to improve scheduling of work so the
radiation protection department does not become overloaded.
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Improved the radiation protection technician evaluation process by
writing a more thorough checklist.
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Established a peer visit and an industry visit for evaluation of the
radiation protection program.
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Established a trending program for Radiological Deficiency Reports and
Personnel Contamination Reports.
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In the area of training the licensee had:
Started retraining all radiation workers on radioactive material
controls, including bagging instructions, specific controls for tools,
and ALARA instructions when transporting radioactive material.
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Trained radiation protection personnel on air sample techniques.
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Required radiation protection personnel to read lessons learned on air
sampling, inadequate surveys, inadequate control of the oil storage
room, failure to control high radiation areas, tagging requirements, and
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clarifying the scope of miscellaneous surveys.
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Provided radiation protection personnel with team-building training.
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Started integrated training, which incorporates radiation protection
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practices in craft specific training along with the attendance of
radiation protection personnel at the training.
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Incorporated radiation protection Turnover / Briefing Checklist into
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training for radiation protection technicians.
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Sent Lessons Learned for various violations to the Training Department
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for incorporation into training modules.
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Retrained and tested radiation protection personnel on radioactive
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material control and tagging, as well as on procedural violations, air
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sampling, and other radiation protection aspects.
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In the area of radwaste minimization and radioactive material control the
licensee had:
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Established a material / housekeeping task force.
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Locked radiological controlled area roll up doors, with the keys being
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controlled by radiation protection for better control.
Established Standing Instruction for handling radioactive material in
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the radwaste building, concerning storage and validation surveys.
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Improved the shift routine checklist to survey suspect areas for drums,
bags, and LSA boxes.
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Established Standing Instructions that:
Increased the frequency of radwaste building 106-foot elevation surveys.
Specified radiation protection coverage for packing removal for
hazardous systems.
Required all radioactive material containers to be tagged when sealed,
including those located inside a contamination zone.
Stated that procedures "should" specify the normal, expected way of
doing business.
Stated that radiation protection technicians must be present to survey
material removed from a contamination zone.
Stated that radiation protection technicians must document surveys
taken.
Established Temporary Instruction 93-0003 to require that radiation
protection personnel survey all scrap metal and lock it up for removal
from the protected area.
Established Standing Instruction for performing survey documentation for
containers removed from contamination zones reading >100 mr/hr.
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Improved quality assurance audit to focus on control of radioactive
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material by moving the 1994 audit scheduled for August, back to April
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1994 to coincide with the outage.
Designated a radiation protection foreman to supervise decontamination,
radwaste, and hot shop personnel.
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Removed all meter trained decontamination personnel from the meter
. qualification list.
Provided friskers to tool room personnel and established a temporary
instruction for frisking all returned tools to the cold tool room.
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Ordered remote monitoring e~quipment for use in monitoring bulk
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materials, such as scaffolding, during high volume output times (such as
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post-outage).
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Added plant cleanup activities to Refueling-5 outage master punchlist,
which will add a mid-outage cleanup event and a 30-day cleanup event at
the end of the outage and extending beyond the end of the outage.
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2 OCCUPATIONAL RADIATION EXPOSURE (83750)
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The licensee's occupational radiation exposure program was inspected to
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determine compliance with 10 CFR Part 20 and with the licensee's Technical
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Specifications.
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2.1 Changes
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Since the last NRC inspection (Report 50-458/92-33), only one major
organizational change has occurred. On February 16, 1993, the licensee
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appointed a new Director-Radiological Programs.
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Technical Specification 6.3.1 states, in part, that each member of the unit
staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for
comparable positions, except for the Director-Radiological Programs who shall
meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
Regulatory Guide 1.8, September 1975, states, in part, that the Radiation
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Protection Manager should be an experienced professional in applied radiation
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protection at nuclear facilities dealing with radiation protection problems
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and programs similar to those at nuclear power stations. The Radiation
Protection Manager should have a Bachelor Degree or the equivalent in a
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science or engineering subject, including some formal training in Radiation
Protection. The Radiation Protection Manager should have at least 5 years of
professional experience in applied radiation protection and at least 3 years
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of this professional experience should be in applied radiation protection work
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in a nuclear facility dealing with radiological problems similar to those
encountered in nuclear power stations, preferably in an actual power station.
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After reviewing the individual's qualifications, it was concluded that he did
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not meet the experience criteria of Regulatory Guide -1.8.
It was determined
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that the new Director-Radiological Programs had prior nuclear navy experience
and had worked at River Bend for several years in' various positions; however,
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he had not worked as a full-time health physicist during his career nor had he
directed the work activities of radiation protection personnel at a power
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reactor.
In particular, the individual did not possess the 3 years of
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professional experience in applied radiation protection work at a nuclear
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facility dealing with radiological problems similar to those encountered in
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nuclear power stations.
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The failure to designate an individual as the Director-Radiological Programs
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that meets or exceeds the requirements of Regulatory Guide 1.8, September
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1975, is considered a violation of Technical Specification 6.3.1
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(458/9312-01). On April 19, 1992, the licensee issued a memorandum approved
by the Plant Manager, which designated a fully Regulatory Guide 1.8 qualified
individual to serve as the Radiation Production Manager through two refueling
outages (RF-6).
The licensee's actions are considered adequate to address the
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issues regarding the duties and responsibilities for the qualified Radiation
Protection Manager.
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2.2 Training and Qualifications of Personnel
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As noted in Section 1.2, the licensee as part of their corrective actions have
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provided radiation workers, radiation protection technicians, and radiation
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protection management with new training.
The inspectors discussed the_
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training with individuals, reviewed lesson plans, and attended a part of the
training for control of radioactive materials that was provided to all
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radiation workers.
In general, the training that was provided was high quality and covered
appropriate topics.
In particular, the integrated training, the team building
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training, and incorporating radiation practices in regular craft training were
very good and should be very helpful in improving the licensee's program.
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The licensee had started a weekly morning communication meeting to help foster
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better communication between radiation protection management and technicians.
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The inspectors attended the meeting and noted that the discussions helped open
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the lines of communication.
Later discussions with radiation protection
technicians indicated that communication with management had improved since
the meetings began and after the team building training.
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2.3 Internal Exposure Control
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The inspectors observed work performed under Radiation Work Permit 93-0014.
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The work entailed cutting out and replacing Valves ICNDV56 and ICNDV53. The
radiation protection technician was required to perform an airborne survey.
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The inspectors observed the technician perform the survey and noted that the
survey was performed appropriately and was representative of the workers'
breathing zone.
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2.4 External Exposure Control
On March 31, 1993, during a tour of the radwaste building 106-foot elevation,
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the inspectors noted scaffolding with a ladder next to the wall of the resin
solidification and processing area. The door to the processing area was
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locked and posted as a Very High Radiation Area. At the top of the ladder was
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a gate which was posted "0BTAIN RP APPROVAL PRIOR TO ENTRY." The inspectors
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contacted the Radiation Protection Supervisor to obtain approval to enter and
survey the area at the top of the ladder. The supervisor accompanied the
inspectors to the top of the scaffolding. A survey of the area indicated that
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the radiation levels near the top of the wall of the resin solidification and
processing area were approximately 2 mR/hr. The inspectors noted and
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discussed with the supervisor that a person could with this scaffolding in
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place, and without much trouble, step on the wall and then step down on a
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piece of equipment to gain entrance to the resin solidification and processing
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area. This would provide entry into-an area posted as a Very High Radiation
Area. The inspectors inquired as to the purpose of the scaffolding.
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supervisor indicated that the scaffolding was used for technicians to be able
to use a teletector radiation survey instrument to monitor radiation levels of
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the resin cask without the need to enter the very high radiation area during
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solidification and processing of resin.
The inspectors noted that the
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scaffolding had a tag that indicated it had been erected in September 1991.
The area where the scaffolding was located was not in a high traffic area, and
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the supervisor stated that there had been no entries made into the resin
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solidification area by way of the scaffold.
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A survey was performed in the resin solidification and processing area. The
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survey results indicated that the highest radiation levels were from a bagged
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and tagged sample that had radiation levels of 800 mR/hr on contact and
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60 mR/hr at 18 inches. These levels indicated that the area at that time
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could have been posted as a High Radiation Area, since the radiation levels
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were not greater than 1000 mR/hr. The licensee leaves the area posted as a
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Very High Radiation Area due to the fact that when processing resin the
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radiation levels are likely to meet the criteria. The licensee stated that
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the area in front of the scaffold was barricaded and posted as a high
radiation area when resin was processed.
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The licensee took immediate corrective actions by enclosing the top part of
the scaffolding to prevent access to the top of the wall. They added
radiological rope and attached the following posting to the wall: DANGER, VERY
HIGH RADIATION AREA, CONTAMINATED AREA, AB0VE AND BEYOND WALL. The licensee
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also toured the plant for other High Radiation Areas or Very High Radiation
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Areas where relatively easy access could be obtained to the area of concern
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without crossing a barrier. They identified two possible high radiation areas
that could be entered by climbing over handrails. One could be entered by
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climbing over the handrail and climbing down on piping to enter the area.
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the other, a person could not enter the area but could get across the parallel
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plane of the entrance gate below.
In both insta:ces they posted the handrail:
"High Radiation Area Below."
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Technical Specification 6.8.1 a. states, in part, that written procedures
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shall be established, implemented, and maintained covering the applicable
procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978. Section 7.e.(1) of Appendix A states, in part,.that there
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should be written radiation protection procedures that cover _ access control to
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radiation areas.
Procedure RPP-0005, Revision 98, " Posting of Radiologically
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Controlled Areas," Section 7.3.2.2.a. and b. states, in part, that to post to
restrict access to a High Radiation Area the RP technician will post the _ area
such that the area is completely enclosed by a physical barrier and place
signs bearing the radiation symbol and the words " CAUTION" or "HIGH RADIATION
AREA" on all sides of the barrier to form a conspicuous boundary. The
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inspectors discussed with the licensee that since the resin processing area ~,
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at the time, did not have radiation levels greater than 1000 mrem /hr, that
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posting the gate at the top of the scaffold with a high radiation area sign
would have been sufficient to restrict access to the area. The failure to
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adhere to Procedure RPP-0005 and post a High Radiation Area is a violation of
Technical Specification 6.8.1.a. (458/9312-02). This violation is similar to
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Violation 458/9233-14 identified in NRC Inspection Report 50-458/92-33, except
that in the previous violation there was a high radiation area at the top of
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the ladder.
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2.5 Conclusions
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A violation was identified in that the new Director-Radiological Programs did
not meet the qualifications of Regulatory Guide 1.8, September 1975.
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Integrated training, team building training, and incorporating radiation
practices in regular craft training were very good. Communication among the
radiation protection personnel was improved. Airborne surveys that were
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observed were representative of the workers breathing zone. The failure to
post a scaffolding that could have provided entry to a posted High Radiation
Area was identified as a violation.
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3 CONTROL OF RADI0 ACTIVE MATERIALS AND CONTAMINATION, SURVEYS, AND MONITORING
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(83726)
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The licensee's program for control of radioactive materials and contamination,
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surveys, and monitoring was inspected to determine compliance with 10 CFR
Part 20 and with the Technical Specifications.
3.1 Audits and Appraisals
The inspectors reviewed six quality assurance surveillances that were
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performed since the inspection in October 1992. The quality assurance
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surveillances were good quality and focused on the problem areas identified in
NRC Inspection Report 50-458/92-33.
In particular, the surveillances reviewed
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the problems with surveys and control of radioactive materials and corrective
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actions for the violations. The surveillances identified a few concerns which
were promptly corrected. The surveillances noted improved performance in the
areas reviewed.
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The inspectors reviewed Quality Assurance Audit 92-10-I-PCON/RWMP performed
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October 26 through November 6, 1992, which covered the Process
Control /Radwaste Programs. The audit was comprehensive and included technical
personnel on the audit team. The audit had no findings but noted four-
improvement recommendations. These items were that radwaste procedures were
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lengthy and sometimes confusing, the Radwaste Department should be furnished
with a dedicated radiation protection staff, the large volume of material that
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was free released and still stored on site should be reduced, and there should
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be more emphasis placed on volume reduction and waste minimization. As noted
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previously in Section 1.2, the audit in 1994 that will review the radiation
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protection program will be moved to coincide with the refueling outage. The
licensee stated that this would afford an opportunity to perform a performance
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based audit on the control of radioactive material during an outage and to
better assess this activity.
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The inspectors reviewed selected Radiological Deficiency Reports for 1993.
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The reports identified appropriate problems and corrective actions were good.
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As noted in Section 1.2, the licensee has started to trend the problems
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identified in the reports. As a result of an upward trend of Radiological
Deficiency Reports that were for untagged bags containing radioactive-
material, the licensee on February 12, 1993, performed an inspection of the
radiological controlled area. The inspection identified and corrected
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additional instances of untagge Sags.
Later that week, the licensee met with
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the Senior Resident Inspector and reported their findings. The trending of
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the Radiological Deficiency Reports and taking immediate actions when the
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trending warrants was seen as a very good enhancement to the licensee's
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program.
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3.2 Changes
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The inspectors reviewed numerous changes in procedures that were performed
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since the October 1992 inspection. The changes to the procedures should
result in program improvements.
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3.3 Surveys and Monitoring
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The inspectors reviewed Unresolved Item 458/9235-02, which was documented in
Inspection Report 50-458/92-35, dated March 5, 1993. The item involved four
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contract workers who may have deliberately exited the radiological controlled
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area in an unauthorized manner.
Specifically, the four individuals were
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observed by a security officer to have exited the radiological controlled area
in Tunnel C and to have entered the normal switchgear building. This place of
exit was not the required exit location for the radiological controlled area
and was not furnished with personal contamination monitoring equipment.
The licensee performed good immediate corrective actions, as identified in NRC
Inspection Report 50-458/92-35 and were continuing the investigation to
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determine whether the correct individuals were identified and whether they -
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intentionally violated the barrier.
During the current inspection, the
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inspectors reviewed the licensee's completed investigation. The investigation
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determined that the licensee had identified the individuals but could not
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determine whether they had intentionally violated the barrier, because the -
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individuals never admitted the violation. The licensee terminated the four
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individuals involved.
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Technical Specification 6.8.1 a. states, in part, that written procedures
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shall be established, implemented, and maintained covering the applicable
procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
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February 1978. Section 7.e.(2) of Appendix A states, in part, that there
should be written radiation protection procedures that cover radiation
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surveys.
Radiation Protection Procedure RPP-0043, Revision 4, " Personnel
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Contamination Monitoring," Section 1.3, states, in part, that all personnel
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exiting Radiologically Controlled Areas containing contaminated areas shall
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monitor themselves for contamination. On January 27, 1993, four individuals-
exited the radiological controlled area in an unauthorized manner in that they
did not monitor themselves for contamination. Therefore, the failure to
perform personal contamination monitoring upon exiting a radiological
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controlled area is considered a violation of Technical Specification 6.8.1.a.
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However, this violation will not be cited because the licensee's efforts in
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identifying and correcting the violation meet criteria specified in Section
VII.B.2 of Appendix C to 10 CFR Part 2.
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3.4 Radioactive Materials and Contamination Controls
The inspectors noted improvement in the control of radioactive material.
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However, during tours of the radiological controlled area the inspectors found
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two instances of radioactive material in bags that had not been surveyed and
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l abeled. The inspectors determined that both instances were of minor safety
significance. On March 30, 1993, the inspectors found an untagged bag which
contained quick disconnects on a table in the hot machine shop decontamination
room. The disconnects were surveyed later and found to have fixed
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contamination levels of 3,000 dpm. On April 1, 1993, while performing a
survey of the radwaste building, the inspectors discovered a red bag that
contained radioactive material that had not been surveyed and labeled.
Subsequent surveys by the licensee indicated contact radiation levels of
25 mrad /hr of beta radiation and 26 mR/hr of gamma radiation. The radiation
levels of the bag at 18 inches was less than 2 mR/hr.
The red bag contained
oil absorbent pads and was found on the 65-foot level of the radwaste building
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behind the LWS-PIA pump room door. The licensee was not able to determine who
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put the bag there or when it was placed there but believes the pad came from
under the LWS-PIA pump which was posted as a contamination zone.
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10 CFR 20.203(f) requires that each container of licensed material shall bear
a label identifying the radioactive contents. The label shall also provide
sufficient information to permit individuals handling the containers or
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working in the vicinity to take precautions to avoid or minimize exposures.
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In the two examples above, the licensee did not comply with 10 CFR 20.203(f)
in that the bags had not been labeled.
The failure to properly label the two
bags is a violation of 10 CFR 20.203(f) (458/9312-03).
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3.5 Conclusions
Quality assurance audits and surveillances were comprehensive and identified
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items which were corrected promptly.
Radiological Deficiency Reports
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identified appropriate problems and corrective actions were good. The
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trending of the problems identified in the Radiological Deficiency Reports and
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taking immediate action when the trending warranted was very good.
Changes to
procedures were appropriate. The licensee identified the failure of four
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individuals to follow the procedure for personal contamination monitoring when
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exiting the radiological controlled area. This was identified as a noncited
violation. There was improvement in the control of radioactive materials.
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Two examples of a failure to survey were identified as a violation.
4 FOLLOWUP ON CORRECTIVE ACTIONS FOR VIOLATIONS (92702)
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4.1
(Closed) Violation 458/9233-01 - Failure to Conduct Airborne Surveys That
Were Representative of the Workers Breathing Zone
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This item involved the failure to perform an airborne survey that was
representative of workers' breathing zone. The licensee performed corrective
actions described in their response dated January 27, 1992, to the violation
which included the development of a procedure for the use of lapel air
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samplers, the review of lessons learned by all radiation protection
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technicians, and a special training session on air sampling was 3rovided to
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all radiation protection technicians.
The inspectors also obserted a job that
required an air sample to be performed and noted that the air sample was
representative of the workers breathing zone. The inspectors verified the
corrective actions and found them to be satisfactory to close the violation.
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4.2 (Closed) Violation 458/9233-02 - Failure to Conduct Radiation Surveys of
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Packing Material
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This item involved packing material that was not surveyed to evaluate the
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extent of the radiation hazard before it was removed from the work area and
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placed in a trash receptacle at the reactor building 131-foot elevation
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step-off pad. The licensee performed corrective actions described in their
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response dated January 27, 1992, to the violation which included the review of
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lessons learned by all radiation protection technicians, integrating
radiological precautions into maintenance training, development.of an RP
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Turnover / Briefing Checklist, updating the radiation protection task list to
include spot checks of packaged material, increasing the frequency of surveys
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on the 106-foot level of the radwaste building, and requiring radiation
protection technicians to be present to survey and tag material removed from
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contamination zones. The inspectors verified the corrective actions and found
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them to be satisfactory to close the violation.
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4.3 (Closed) Violation 458/9233-03 - Failure to Conduct Radiation Surveys of
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the Oil Waste Storage Room
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This item involved the failure to perform a radiation survey of the oil waste
storage room prior to allowing individuals to work in the room after radwaste
had been stored in the room. The licensee performed corrective actions
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described in their response dated January 27, 1992, to the violation which
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included the review of lessons learned by all radiation protection technicians
and increasing the frequency of surveys on the 106-foot level of the radwaste
building.
The inspectors verified the corrective actions and found them to be
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satisfactory to close the violation.
4.4
(Closed) Violation 458/9233-04 - Failure to Conduct a Radiation Survey of
a Trash Baq That Contained Radioactive Resin Samples
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This item involved the failure to perform a radiation survey of a trash bag
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containing radioactive resin samples prior to placing the bag in a low
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specific activity storage box. The licensee performed corrective actions
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described _in their response dated January 27 -1992, to the violation which
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included the review of lessons learned by all radiation protection
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technicians, locking of the low specific activity storage boxes,
disqualification of survey meter trained deconners, requiring radiation
protection technicians to be present to survey and tag material-removed from a
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contamination zone, and improvements in the radiation protection oversight
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program.
The inspectors verified the corrective actions and found them to be
satisfactory. However, the inspectors did identify a violation (458/9312-03)
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during this inspection period that was similar to this violation. This
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violation will be closed, and future corrective actions will be tracked under
V:olation 458/9312-03.
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4.5
(Closed) Violation 458/9233-06 - Failure to Perform Adecuate Radiation
Surve_ys
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This item involved two examples of the failure to perform proper radiation
surveys. During a walkdown radiation survey, a radiation protection
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technician discovered a trash bag containing radioactive material that was not
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surveyed and a bag containing a choker that was missurveyed.
The licensee
performed corrective actions described in their response dated January 27,
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1992, to the violation which included the review of lessons learned by all
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radiation protection technicians; locking of the low specific activity storage
boxes; disqualification of survey meter trained deconners; requiring radiation
protection technicians to be present to survey and tag material removed from a
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contamination zone; increased frequency of surveys on the radwaste building
106-foot elevation, the hot machine shop, and maintenance laydown areas; and
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improvements in the radiation protection oversight program.
The inspectors
verified the corrective actions and found them to be satisfactory.
However,
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the inspectors did identify a violation (458/9312-03) during this inspection
period that was similar to this violation. This violation will be closed and
future corrective actions will be tracked under Violation 458/9312-03.
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4.6 (Closed) Violation 458/9233-07 - Failure to Perform a Radiation Survey of
a Sling Prior to Release to the Protected Area
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This item involved the release of a sling to outside the protected area that
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was not surveyed for radioactive contamination. The licensee performed
corrective actions described in their response dated January 27, 1992, to the
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violation which included the review of lessons learned by all radiation
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protection technicians, changing of the procedure to require all material
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(except personal items and items that would not routinely be used in the
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radiological controlled area) leaving the protected area to be surveyed for
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contamination, addition of ;ld tool room radiation surveys to radiation
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protection's routine task list, and locking the radiological controlled area
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rollup doors. The inspectors observed radiation protection technicians
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perform an appropriate survey of a sling for contamination prior to release
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outside the protected area.
The inspectors verified the corrective actions
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and found them to be satisfactory to close the violation.
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4.7 (Closed) Violation 458/9233-08 - Failure to Perform a Radiation Survey of
a Sling Prior to Release from the Radiological Controlled Area
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This -item involved the release of a sling from the radiological controlled
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area that was not surveyed for radioactive contamination. The licensee
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performed corrective actions described in their response dated January 27,
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1992, to the violation which included the review of lessons -learned by all
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radiation protection technicians, addition of cold tool room radiation surveys
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to radiation protection's routine task list, and locking the radiological
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controlled area roll up doors. The inspectors observed radiation protection
technicians perform appropriate surveys of articles for contamination prior to
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release from the radiological controlled area. The inspectors verified the
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corrective actions and found them to be satisfactory to close the violation.
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4.8 (Closed) Violation 458/9233-09 - Failure to Adequately Document
Radiological Surveys
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This item involved the failure of a radiation protection technician to
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properly document a radiological survey. The licensee performed corrective
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actions described in their response dated January 27, 1992, to the violation
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which included the review of lessons learned by all radiation protection
technicians and the issuance of a standing instruction to the radiation
protection technicians on the importance for one-line documentation of surveys
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of trash bags reading greater than 100 mR/hr. The inspectors verified the
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corrective actions and found them to be satisfactory to close the violation.
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4.9 (Closed) Violation 458/9233-10 - Failure to Sign Out a Radiation Survey
Instrument
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This item involved the failure of a radiation protection technician to sign
out a radiation survey instrument that was used to perform required radiation
surveys. The licensee performed corrective actions described in their
response dated January 27, 1992, to the violation which included the review of
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lessons learned by all radiation protection technicians and the monitoring of
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radiation survey instrument sign-out logs by radiation protection management.
The inspectors verified the corrective actions and found them to be
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satisfactory to close the violation.
4.10 (Closed) Violation 458/9233-11 - Failure to Properly Transport a Trash
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Bag with High Radiation Levels
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This item involved a bag of trash that was tagged < 2mR/hr on contact but had
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radiation levels of 14,000 mR/hr that was not transported by the requirements
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for material that caused a high radiation area. The licensee performed
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corrective actions described in their response dated January 27, 1992, to the
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violation which included the review of lessons learned by.all radiation
protection technicians and the change of policy to prohibit trash generated
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from maintenance activities from being placed in personnel contamination
barrels at contamination zone exits. The inspectors verified the corrective
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actions and found them to be satisfactory to close the violation.
4.11
(Closed) Violation 458/9233-12 - Failure to Post a High Radiation Area
This item involved the failure to post as a high radiation area a low specific
activity storage box that had radiation levels at 18 inches of 130 mR/hr due
to a trash bag that had not been surveyed and a trash bag that had been
improperly tagged.
The licensee performed corrective actions described in
their response dated January 27, 1992, to the violation which included the
,
review of lessons learned by all radiation protection technicians; locking of
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the low specific activity storage boxes; disqualification of survey meter
trained deconners; requiring radiation protection technicians to be present to
survey and tag material removed from a contamination zone; increased frequency
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of surveys on the radwaste building 106-foot elevation, the hot machine shop,
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and maintenance laydown areas; and improvements in the radiation protection
oversight program.
The inspectors verified the corrective actions and found
them to be satisfactory to close the violation.
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4.12 (Closed) Violation 458/9233-13 - Failure to Post a High Radiation Area
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This item involved the failure to post as a high radiation area a ladder that
was left standing in the radwaste building. The radiation levels at the top
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of the ladder were 100 mR/hr. The licensee performed corrective actions
described in their response dated January 27, 1992, to the violation which
included the review of lessons learned by all radiation protection technicians
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and locking up all ladders in the radwaste building and putting them under
radiation protection control. 'The inspectors verified the corrective actions
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and found them to be satisfactory. However, the inspectors did identify a
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violation (458/9312-02) during this inspection period that was similar to this
violation.
This violation will be closed and future corrective actions will
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be tracked under Violation 458/9312-02.
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4.13 (Closed) Violation 458/9233-14 - Failure to Provide Appropriate
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Personnel Monitorina Equipment
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This item involved the failure to provide mechanics that removed packing on
Valve 23A with extremity dosimetry. The licensee performed corrective actions
described in their response dated January 27, 1992, to the violation which
included the review of lessons learned by all radiation protection technicians
and the issuance of a standing instruction that required the use of extremity
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monitoring for primary valve unpacking.
The inspectors verified the
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corrective actions and found them to be satisfactory to close the violation.
4.14 (Closed) Violation 458/9233-15 - Failure to Provide Appropriate
Personnel Monitorina Ecuipment
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This item involved the failure to supply appropriate personnel monitoring
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equipment to individuals who transported a bag of radwaste on their back. The
licensee performed corrective actions described in their response dated
January 27, 1992, to the violation which included the review of lessons
learned by all radiation protection technicians and instructing radiation
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workers in methods to minimize exposure while transporting radioactive
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material. The inspectors verified the corrective actions and found them to be
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satisfactory to close the violation.
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4.15 (Closed) Violation 458/9233-16-- Failure to Perform an Adequate
Radiation Survey
This item involved the failure to perform adequate surveys of scrap material
that was released from the protected area and transferred to a scrap dealer.
The licensee performed corrective actions described in their response dated
January 27, 1992, to the violation which included the review of lessons
learned by all radiation protection technicians, performing comprehensive
surveys of all laydown areas and scrap yards on site, additional surveys of.
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scrap material before leaving River Bend Station, use of a locked box by
radiation protection personnel to control scrap material and assure monitoring
prior to removal from the protected area; and the locking of the plant
radiological controlled area roll up doors to control material entry and
removal. The inspectors verified the corrective actions and found them to be
satisfactory to close the violation.
4.16 (Closed) Violation 458/9233-17 - Failure to Dispose of Licensed Material
Properly
This item involved the disposal of licensed material to an unauthorized
recipient. The licensee performed corrective actions described in their
response dated January 27, 1992, to the violation which included the review of
lessons learned by all radiation protection technicians; performing
comprehensive surveys of all laydown areas and scrap yards on site, additional
surveys of scrap material before leaving River Bend Station, use of a locked
box by radiation protection personnel to control scrap material and assure
monitoring prior to removal from the protected area, and the locking of the
plant radiological controlled area roll up doors to control material entry and
removal. The inspectors verified the corrective actions and found them to be
satisfactory to close the violation.
5 FOLLOWUP (92701)
5.1
(Closed) Unresolved Item 458/9235-02 - Failure to Perform Personal
Monitoring for Contamination Before Exitina the Radiological Controlled
Area
This item was identified in NRC Inspection Report 50-458/92-35 and involved
four individuals who may have deliberately exited the radiological controlled
area in an unauthorized manner.
The unresolved item was reviewed and
determined to be a violation (Section 3.3).
Therefore, this unresolved item
is considered closed.
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ATTACHMENT
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1 PERSONS CONTACTED
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l.1 Licensee Personnel
- D. L. Andrews, Director Quality Assurance
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- R. L. Biggs, Supervisor, Operations Quality Control
- J. W. Cook, Senior Technical Specialist, Licensing
- L. A. England, Director, Nuclear Lic ensing
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- C. L. Fantacci, Supervisor Radiologicc1 Engineering
- C. Fisher, Quality Assurance Engineer
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- D. E. Freehill, Assistant Plant Manager, Outage Maintenance
- K. D. Garner, Licensing Engineer
- W. C. Hardy, Radiation Protection Supervisor
- D. O. !!artz, Outage Director
- T. W. Knight, Co-op, Licensing
- D. N. Lorfing, Supervisor Nuclear Licensing
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- I. M. Malik, Supervisor Operations Quality Assurance
- J. C. Maher, Licensing Engineer
- W. H. O' Dell, Director Radiological Programs
- S. R. Radebaugh, Assistant Plant Manager, Maintenance
- J. P. Schippert, Plant Manager
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- A. D. Wells, Radiation Health Supervisor
1.2 NRC' Personnel
- H. F. Bundy, Reactor Inspector
- M. E. Murphy, Reactor Inspector
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- M. Rur,yan, Reactor Inspector
- A. Singh, Reactor Inspector
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- W. Smith, Senior Resident Inspector, River Bend Station
- B. Vickrey, Reactor Inspector
- T. F. Westerman, Chief, Engineering Section
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1.3 NRC Contract Personnel
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- A. N. Fresco, Research Engineer
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- M. R. Holbrook, Principal Investigator
- K. Sullivan, Engineer
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- Denotes personnel that attended the April 2, 1993, exit meeting.
In addition
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to the personnel listed above, the inspectors contacted other personnel during
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this inspection period.
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2 EXIT MEETING
An exit meeting was conducted on April 2, 1993. During this meeting, the
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inspectors reviewed the scope and findings of the special inspection. The
licensee did not identify as proprietary, any of the materiais provided to, or
reviewed by, the inspectors during the inspection.
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