ML20125E010

Discusses Enforcement Conference Conducted on 921120 to Discuss Recent Insp Findings.List of Attendees Encl.Util to Be Informed Separately of NRC Enforcement Decisions

ML20125E010
Person / Time
Site:	River Bend
Issue date:	12/10/1992
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Graham P GULF STATES UTILITIES CO.
References
EA-92-207, NUDOCS 9212160141
Download: ML20125E010 (76)

Text

. ., -

&Q0806 UNITED STATES -

. 7 _

.j .,  ?( NUCLEAR REGULATORY COMMISSION -

REGION IV

..g ff

~

1. 611 RYAN PLAZA DRIVE, SulTE 400 e AR LINGTON, T EXAS 760114064. -

-- ....* DEC' [ 0 SE Docket No. 50-458 License No. NPF-47 EA 92-207 Gulf States Utilities ATTN: P.-D. Graham Vice President (RBNG)

P.O. Box 220 St. Francisville, Louisiana 70775 Gentlemen:

This refers to the enforcement conference conducted at Region:IV's request in-the Region IV office on November 20, 1992, which was, attended by those on the <

. enclosed Attendance List. This conference was held to discuss recent-inspection -findings (NRC Inspection. Report 50-458/92-33), the apparent violations, their causes.:and your corrective actions. .You will .be informed separately of the =NRC's enforcement decision.

In accordance with. Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter'will- be placed in:

the NRC's Public Document Room.

Should you have any questions concerning this matter, we will be pleased-to discuss them with you.

Sincerely,

. Bill Beach, Director Division of Reactor Projects

Enclosures:

l.- Attendance List

2. . Licensee' Presentation cc w/ enclosure 1:

Gulf States Utilities ATTN: J. E. Booker, Manager-

' Nuclear Industry Relations P.O. Box 2951 Beaumont, Texas -77704

~

9212160141 0 921210 PDR ADOCK 05000458

_G; PDR- .g

f Gulf States Utilities Winston & Strawn ATIN: Mark J. Wetterhahn, Esq.

1401 L Street, N.W.

Washington, D.C. 20005-3502 Gulf States Utilities ATTN: Les England, Director Nuclear Licensing P.O. Box 220 St. Francisville, Louisiana 70775 Mr. J. David McNeill, III William G. Davis, Esq.

Department of Justice Attorney General's Office P.O. Box 94095 Baton Rouge, Louisiana 70804-9095 H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70806 President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 Cajun Electric Power Coop. Inc.

ATTN: Philip G. Harris 10719 Airline Highway P.O. Box 15540 Baton Rouge, Louisiana 70895 Hall Bohlinger, Administrator Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135

l Gulf States Utilities , bec to'DMB -(IE06) w/ enclosures 1 & 2 bec distrib. by RIV w/ enclosure 1:

J. L. Milhoan Resident inspector DRP Section Chief (DRP/C)

Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System DRSS-FIPS RSTS Operator Project Engineer (DRP/C) RIV File DRS Section Chief (DRP/TSS)

Senior Resident inspector, Cooper Senior Resider.t inspector, Fort Calhoun G. F. Sanborn, E0 J.Lieberman,OE,(MS: 7-H-5)

L. J. Callan: DRSS J. P. Jaudon, DRSS B. Murray, FIPS A. D. Gaines, FIPS 150016 RIV:FIPS C:FIPS E0 D:DRS D;6EP

• ADGaines:nh *BMurray *GFSanborn A(JCallan kBB)ach'

/ /92 / /92 / /92 \b/h92 12 / 6 / 9 2 -'

• Previously concurred.

Gulf States Utilities bec to DMB (IE06) w/ enclosures 1 & 2 bec distrib. by RIV w/ enclosure 1:

J. L. Milhoan Resident Inspector DRP Section Chief (DRP/C)

Lisa Shea, RM/ALF, MS: HNBB 4503 MIS System DRSS-FIPS RSTS Operator Project Engineer (DRP/C) RIV File ORS Section Chief (DRP/TSS)

Senior Resident Inspector, Cooper Senior Resident Inspector, Fort Calhoun G. F. Sanborn, E0 J. Lieberman, OE, (HS: 7-H-S)

L. J. Callan, DRSS J. P. Jaudon, DRSS B. Murray, FIPS A. D. Gaines, FIPS RIV:FIPS C:FIPS E0 D:DRS Dy@P

• ADGaines:nh *BMurray *GFSanborn kJCallan MBB)ach

/ /92 / /92 / /92 \/h92 b 12/6 /92

• Previously concurred.

e ENCLOSVRE 1 ATTENDANCE LIST Attendance at the Gulf States Utilities NRC Enforcement Conference on November 20, 1992, at the NRC Region IV Office.

LICENSEE E. M. Cargill, Director, Radiological Programs P. D. Graham, Vice President W. C. Hardy, Radiation Protection Supervisor D. Lorfing, Supervisor, Licensing C. R. Maxson, Human Performance Coordinator W. H. Odell, Manager Oversight J. P. Schippert, Plant Manager NRC J. L. Milhoan, Regional Administrator J. M. Montgomery, Deputy Regional Administrator A. B. Beach, Director, Division of Reactor _ Projects (DRP)

W. L. Brown, Regional Counsel J. S. Collins, Director, Division of Reactor Safety (DRS)

, *J. Del Medico, Enforcement Specialist E. J. Ford,. Senior Resident Inspector, Waterford 3 J. Gagliardo, Chief, DRP, Project Section C A. D. Gaines, Radiation Specialist, facilities Inspection Programs Section (FIPS)

! P. H. Harrell, Chief, DRP, Technical Support Section W. D. Johnson, Chief, DRP, Project Section A l B. Murray, Chief, FIPS, Division of Radiation Safety and Safeguards D. V. Pickett, Project Manager, Office of Nuclear Reactor Regulation G. F. Sanborn, Enforcement Officer l W. F. Smith, Senior Resident Inspector, River Bend Station ,

• Telephone communication during conference.

L i

L l

I'

ENCLOSURE 2 ENFORCEMENT CONFERENCE NOVEMBER 20,1992 GULF STATES LTILITIES COMPANY RIVER BEND STATION NRC INSPECTION REPORT 92-33 b

ENFORCEMENT CONFERENCE NOVEMBER 20,1992 GSU AGENDA OPENING REMARKS PHIL GRAHAM OVERVIEW OF APPARENT JOE SCHIPPERT VIOLATIONS VIDEO ORIENTATION WAYNE HARDY l

DISCUSSION OF APPARENT WAYNE HARDY VIOLATIONS HPES EVALUATION CRAIG MAXSON

SUMMARY

OF CORRECTIVE ED CARGILL ACTION CONCLUSIONS PHIL GRAHAM l

z w - - - - + _- --_----_--_-__-_____a. - - ----- - - - . ,_ _ - - - _

I

• River Bend Station is committed to excellence in the radiation protection program e Management standards and expectations e Individual accountability e Oversight e Demonstrated Improvement e Resource Commitment

• B33*MOV23A survey errors represent performance deficiencies

• -Radwaste material control program challenged during RF-4

~* Ongoing initiatives and corrective actions -

l l

l 3 .

Faihire to perform an-adequate survey of-Subsequent failure to aacking matenal from -adequately assign 333*MOV23A extremity dosimetry

(_14)

(-02A)

Y Subsequent Failure to >

Failure to perform an Properly document the adequate survey of the survey by an individual trash bag by an (-09A) individual

(-02B)

Subsequent failure to properly approve the

- transport of high rad.

material

(-11)

BS3*MOV23A uent raiture to  :

- subsehe Post t high rad. area Packin8 --(-12)

~

Subsequent failure to issue appropnate ~

_ dosimetry to decontamination personnel

(-15)

= . a.

4

h Other Survey Deficiencies .

1 Improper tagging of a bag containing a ,

contaminated sling by an individual Failure to properly tag a bag measuring 100mR/hr on contact

(-06)

Failure to sign out a survey instrument by an individual

(-10)

Failure to retag a collection of resin samples

-(- 0 4)

Failure to survey the oil L storage area  !

(-03) a

x Material Release  :

Improper release of a contaminated sling from the RCA

(-08) 1 Failure to' survey a contaminated ~ sling prior to release from the ,

protected area by an mdividual

. (-07)

Failure to perform an adequate survey of a piece of contaminated Disposal oflicensed steel prior to release material to an

. from the protected area unauthorized recipient

(-16) - (-17) ,

4 3

1 Apparent Violations for Additional Consideration Failure to conduct an adequate airborne survey

(-01) e Failure to control a high rad. area

(-13)

Failure to adec uately survey E12*F039C

(-05)

Failure to adequately document a survey of fuel building elevation

+113 by an individual

(-09B) 7

HADWADTE 106' SURVEY @F DAG @F PACKINS (DAG F@UND IN RADWAOTE @N .10/1/92)

DOSE RATES 4 to' AS MEASURED 5 9' IN MR/HR 6 8-8 7' Distance From Bag 10 s- Measured With A Ruler (IN FEET)

, 15 _ 5' 22 4' 35 3' 100 mr/hr 8 2-3g at 18 inches

. , ~.

~

12,000 MR/HR (GAMMA)

."ai?to ND Be!a 120 mr/hr 220 i at 18 inchea 8 0 3- Distance From Bag 25 4-18 Measured With A Ruler

• 5-DOSE RATES (IN FEET) 12 s' AS MEASURED 8- 7' lN MR/HR 6 8' 5

n 9' -

4 to'

1 l

Failure to Perform Adequate Survey of Packing Material Apparent Violation 458/9233-02-A Agree - Adequate survey was not performed Root cause:

• Disposition of packing was not specified e Poor turnover and briefing among technicians e Radiation protection personnel lost focus e Procedure and training not effectively implemented e RP did not meet expectations

( urrective Action:

Immediate e Generated a Radiological Deficiency Report to investigate the uptake e Assigned calculated extremity dose to workers e Counciled RP foreman Actions to strengthen radiological material control program o Integrate radiological work practices into:

Maintenance planning Maintenance training-e Lesson plan developed forjob coverage on primary system valves and pumps e Integrate lessons learned into RP continuing training ,

o Develop turnover /breifing sheets g

10

Trash' Bag Was Not SunreyedL to Evaluate Hazards Apparent Violation 458/9233-02 B -

Agree - Bag was not properb sun' eyed Root cause:

• Personnel error e Inadequate Survey

t. .OTTcCliVC .\Clion:

Immediate o Disqualified RP Technician

. e Remedial training initiated e Disciplined RP Technician Actions to strengthen the radioactive material control program o Initiated spot check surveys 1

[

l l

I Failure to Adequately Assign Extremity Dosimetry Apparent Violation 458/9233-14 .

Agree - Extremity dosimetry would have been appropriate considering the dose rate of the final ungs of packing

• Pre-job and during-job surveys of the 23A valve and its packing do not indicate the need for extremity dosimetry

• Dose calculations were made and extremity dose assigned once the dose rate of the last ring of packing was identified

• This incident is not mutually exclusive of the failure to perform an adequate survey of the packing material of 23A (Apparent Violation 458/9233-2-A).

Had the survey been performed, appropriate actions would have been taken

\t

Apparent Violation 458/9233-14 (Continued )

Root Cause e Disposition of packing was not specified e Poor turnover and briefing e Radiation protection personnel lost focus

• Procedure and training not effectively implemented t.orrective Actions e Dose calculations were made and extremity dose assigned to workers Actions to improve the program o Extremity dosimetry will be worn when repacking I

primary system valves 1

e Other valve work performed during RF-4 was reviewed to determine the adequacy of extremity dosimetry i

G

Subsequent Failure to Properly Document the Survey by an Individual Apparent Violation 458/923&O9-A Agree - Individual'did not document a survey Root Cause e Subsequent failure to survey 14R/hr trash bag (Had he known that the bag was 14R/hr, he would ,

have documented it as such)

M tions to strengthen program o Clarify scope of miscellaneous surveys and tagghig requirements

1 i

Subsequent failure to Properly Approve Transport of High Radioactive Trash Apparent Violation 158/923311 Agree - The Radiation Protection Supervisor did not aj)prOVC traI1 Sport Ol' greater l}lan 100rnR/ lir trasil '

Root Cause:

• Approval was contingent on proper survey and

tagging of the 14R/hr trash bag ~

w

l Subsequent Failure to Post a High Radiation Area l Apparenit Violatiori -158/923312 '

i Agree An unposted high radiation area did exist as a result of the improperly tagged bag Root ( ause e Proper posting of the area was contingent on measuring dose rates of greater than 100 mR/hr at 18 inches

( orrective Action

• Material tnmsferred to HRA when found e Complete detailed survey of suspected areas e Dose records of exposed personnel reviewed e Assigned dose to personnel e Disqualified RP Technician, initiated remedial training e Disciplined RP Technician e All plant TLDs reviewed e Audible response instruments e RP survey or escort required e Plant manager meets with RP technicians e Work site generated trash e RP technicians informed of problems 4,

w ,, , . - , -,p.--, y,. -- -

,e,p~ , . - , - - . - _% .-

w ,, w 7

l 1

Apparent Violation -158/9233-12 (Continued) e Requested QA Audit e Requested assist visits from peers e Requested assist visits from INPO e Established RP Enhancement Committee e Weekly communications meetings e Initiated HPES Investigation Actions to strengthen program o Procedures and training revised or developed e Lessons learned incorporated into continuing training e RPS training e Technician evaluations e MMFO's e Tests to evaluate procedure knowledge Evaluate recommendations for improvement e HPES e Radiological Programs < > Radwaste o Radiological Programs Enhancement Committee 17

l Subsequent Failure to Issue Appropriate Dosimetry to Decon Personnel '

Apparent Violation 458/9233-15 Agree - Dosimerty was not provided to n, initor the back of decon personnel Root Cause:

• Proper monitoring was contingent on proper survey and tagging of the 14R/hr trash bag

( .orrective Action:

• Corrective action is addressed in apparent violation 458/9233-12 a

Improper Tagging of a Bag Containing a l Contaminated Sling and Failure to Properly Tag a Bag Measuring 100 mR/hr i Apparent Violation 458/9233-06 Agree - Neither bag was properly tagged

• Both improperly tagged bags were identified during the performance of corrective actions initiated upon discovery of the 14R/hr bag

• Both bags were promptly tagged upon discovery

• The bag containing the sling was tagged by the same technician who:

• Improperly tagged the 14R/hr bag of waste e Failed to properly document the survey of the 14R/hr bag

• The inner bag containing the sling had been properly surveyed and tagged previous to its repacking

Apparent Violation 458/92334J6 (Continued)

Root Cause o Personnel error - Technician failure to follow procedure Correc "' Action e l'igiph ib RP technician e Reuwr and requalify the RP Technician Action to strengthen Radioactive Material Control Program o Require a radiation protection technician to be present to survey and tag material when it is removed from a C-Zone unless material is exempted by the RWP e Initiated frequent surveys of the Radwaste Building using G-M detectors with audible response ZO

1 Failure to Sign Out a Survey Instrument by an Individual Apparent Violation 458/9233-10 Agree -The radiation protection technician failed to sign out his survey instrument in accordance with procedure

• The technician who failed to follow procedure in this case was the same technician who:

• Improperly tagged a bag containing a contaminated sling

• Improperly tagged the 14R/hr bag of waste e Failed to properly document the survey of the 14R/hr bag Root cause o Personnel failure to follow procedure

( un ective .\ction e Discipline the RP technician e Retrain and requalify the RP technician

Failure to Retag a Collection of Resin Sample Bottles Apparent Wlation 458/92334)4 Agree - Bag was not properly surveyed or tagged Root cause:

• A radiation protection technician failed to follow procedure by allowing unauthorized personnel to remove materials from a GZone without a radiation protection technician present Corrective Action:

e Disqualified all meter trained deconners e Discipline the technician e Memos to staff during RF-4 l

l Actions to strengthen radiation material control program:

e Require a radiation protecdon technician to be l present to survey and tag material when it is removed l from.a GZone unless material is exempted by RWP e Initiated frecuent surveys of the Radwaste building using G-M detectors with audible responses L2.

Failure to Survey the Oil Storage Area Apparent Violation 458/9233-03 Tlie oil storage area was surveyed on Septeinber 30,1992.

h is indeterminate as to whether it was surveyed prior h> elltrY

• Statements of workers who entered the room substantiate that they requested permission to enter and they were informed of radiological hazards in the area prior to their entry

• The technician documented a survey of the room on September 30,1992 and specified in the remarks section that it was "to verify radiological conditions to allow access"

• The survey did not identify the 14R/hr trash e

Improper Release of a Contaminated Sling From the RCA Apparent Violadon 158,923M)8 Agree - The contaminated sling was apparently not adequatch stureyed for release

• The identity of the RP technician who released the sling is indeterminate Root cause:

o Personnel Error - Inadequatejob performance on the part of the RP technician releasing the sling (8affUCIIVt*Arti()ll:

o Comprehensive contamination survey of the cold tool room

\<" hoi 1(i etreie2: hen ihe Radi< > active .\laterial ( on':

- r2I alii:

o Contamination friskers provided to tool room personnel to allow checking of tools processed in and out of the c 'd tool room 5

a

1 Failure to Survey a Contaminated Sling Prior to Release From The Protected Area '

by an Individual Apparent Violation 458/9233-07 Agree - A sling with 100,000 dpm/ probe fixed contamination was released by a RP technician for use outside the protected area but within the owner controlled area

• The RP technician who released the sling was the same technician who:

• Improperly tagged a bag containing a contaminated sling (-06) e Improperly tagged the 14R/hr bag of waste (-02) e Failed to document the survey of the 14R/hr bag (-09A) e Failed to properly sign out his survey instrument (-10) l l

L a

.. . . . _ . . = _ _ . . . . - - - . _ _._-_-_. _-

1 l

i Apparent Violation 458/9233-07 (Continued)

Root Cause:

• Personnel Error- Failure of the RP technician to follow procedure Con criive Action:

e Disqualified RP Technician e Initiated remedial training e Discipline the RP technician e Oral board prior to requalification Action to strengthen the Radioactive Material Control I'1'OgTa n) e Revised procedure to require all material other than personal items leaving the protected area to be checked for radioactive contamination 2p

Failure to Perform an Adec uate Survey of a Piece of Contaminatec Steel Prior to Release From The Protected Area Apparent Wlation 458/9233-16 Agree - The contaminated steel was apparently not adequately surveyed for release

• The identity of the RP technician who released the steel is indeterminate Root Cause:

o Personnel Error - Inadequatejob performance on the part of the technician releasing the steel Corrective Action:

• Surveyed all laydown and scrap yards in the owner controlled area e Short term survey of all scrap material leaving the owner controlled area e Initiated an independent Human Performance evaluation study (HPES) 2.7

Apparent Violation 458/923.416 (Continued) i Action to strengthen theRadioactive Material Program e

Construct locked scrap box accessed by RP only e

Locked plant rollup doors, access controlled by RP e Require all materials, other than personalitems, to be checked for contamination before leaving the protected area e Evaluate and modify the " Green Tag" system o Evaluate and purchase interim storage containers for post outage radioactive material e Evaluate automated survey equipment e Provide GSU oversight of contract personnel performing release surveys oflarge amounts of material I

ZWA

Licensed Material Was Transferred to an Unauthorized Recipient Apparent Violation 458/9233-17 Agree - Licensed material was transferred to an unauthorized recipient

• In six years of operating experience this is the first -

incident of unauthorized radioactive material outside the owner controlled area

• Had an adequate survey (Apparent violation 458/9233-16) been performed, this violation would not have occurred Root Cause:

o Personnel Error - Inadequatejob performance on -

the part of the technician releasing the steel e

Apparent Violation 158/923M7 (Continued)

Action to strengthen theRadioactive Material Program o Construct locked scrap box accessed by RP only e Locked plant rollup doors, access controlled by RP e Require all materials, other than personal items, to be checked for contamination before leaving the protected area e Evaluate and modify the " Green Tag" system o Evaluate and purchase interim storage containers for post outage radioactive material e Evaluate automated survey equipment I

e Provide GSU oversight of contract personnel perfonning release surveys oflarge amounts of material l

l e,

1 Failure to Conduct Adequate Airborne Surveys Apparent Violation 458/9233-01 l Airborne surveys were representative of worker breathing zones

• Respirators were worn for the initial packing removal

• Considerations for the removal of respirators e Water was overflowing from the stuffing box e Dose rates on the first rings of packing were low e Air sample taken during initial packing remova) was <25% MPC

, o Removal of respirators would have speeded work completion and reduced worker exposure e Workers were wearing plastic and cotton-coveralls e Workers on previous entries exibited symptoms of heat stress l

• Faceshields were used after removal of respirators l

• Air sampler was located about 15 inches from work e Work to sampler distance measured by RP Tech e- Elevated airborne activity was identified on air sample taken during removal oflast packing ring

• Uptake apparently occurred due to localized puffs of activity e Sampler location verified during PO 92-03 30

.&-5 8d--.,$-M.sW-Ja-*.4m as h6-AJ4h4.Mu-E.A-.*h,-Aa--4-MJMuh.J.1--4a-'u4AWnh4--m-L.Aem-Ae a-44 4- 4 U Aaw h-..# 4 A--*14 4 # awuM. - J4 wm--JI.--&-.#a.Ji.+4 + + - - - - 4e4.----+h4mA-- s tu-aw.4 h*. Si

[

. g.

f -

r._

y w ' '

rg, t _

42 l ~

42 kk A E m X m V

/ 0y -

...-o a n ,. .

M i

L L

.,e -_

T f i' i- '

31 .

..-, - --.y- , - , - , ,r,.- ,.,4,

AIRBORNE ACTIVITY LEVELS DURING 23-A REPACKING n .

3!

8 .

di e s - 3 zg2- -

2 ..

y .

e .

l g 1. - .

F

(:

o.

Y ^

= =. = ,; ,

1140 to 1230 1405 to 1545 1715 2 1750 2E87102307 SAMPLE COLLECTION PERIOD 9/3/92 u

N

Failure to Control a High Radiation Area Apparent Violation 458/9233-13 A rea.sonable person would not have accessed the high radiation area above the ladder

• All accesses to the ladder were posted "NO ENTRY"

• An individual would '7ve had to use the ladder unsafely by standing on the top two steps in order to be exposed to higher dose rates

• In order to receive 100 mR to the whole body, an individual would have to stand in an unsafe position on the ladder for at least an hour i

• The walls adjacent to the ladder were clearly posted

" Danger -Very High Radiation Area"

• Strict enforcement of high radiation area controls will continue l~

l --

l l

e

1 Failure to Adequate Survey E12*F039C Apparent Violation 458/9233-05 The suneys performed to evaluate the radiological hazards associated with E12*F039C were adequate and included surveys of the valve packing i i

• Packing was blown from the 39C valve when the plant was at pressure and was lying on the valve stem  !

at the time ofinitial drywell entry on 9-11-92 l

• Initial radiological survey of valve included i measurements of I e- Smearable contamination on the valve stem, handwheel and the area around the valve e Highest gamma radiation levels on contact, j at 18 inches and in the valve's general area o i e- Highest beta radiation levels on contact, at 18 inches and in the valve's general area 34

Apparent Violation 458/923S05 (Continued)

• Consideration for worker protection e Respirators were worn e Extremity dosimetry was worn e The valve was wrapped in plastic to reduce beta radiation levels and minimize airborne radioactivity e Plastic and cotton coveralls and double rubber gloves were worn 35

i i

Subsequent Failure to Document a Survey l by an Individual- l l

Apparent Violation 458/9233-09-11 The survey documet tation was adequate

• RP technician posted area contaminated

• RP technician documented posting of area

• Survey reflected contamination levels

• Radiation survey was random

• Radiation surveys could have been useful '

• Performance deficiency - Not procedural Actions to strengthen program o Clarify documentation of miscellaneous surveys e Incorporate lessons learned into RP continuing training i

o L

i l

36

MIHHUTFF HUMAN PERFORMANCE ENHANCEMENT SYSTEM

_ IIIIIIH I Condition Report 92-0822 14 R/hr Bag Tagged Less Than 2 mR/hr liPES Inwaug.auon Commenced on Octota r 7, lW2 Condition Report 92-0859 Contaminated Steel Shipped to a Scrap Yard nets inw.suucon n.m n, no a ,.r. on.a , ..< n~2 37

Scope 1

(Condition Report 92-0822)

Look at the overall programs in place for the handling of radioactive material and waste at the programmatic level

- N 37

i a

l Scope P Condition Report 92-0859-To provide an independent investigation of the contaminated angle iron event with a focus on the human performance and behavior aspects.

-. , , ., - - - ...-,.-.,-- , < ~ - - - - - - - - - ~ - ' ' -

1 Observadons i

Radioacdve material control and handling appears to be adequate during normal operations  !

l The primary root cause for failure of the RP Technician to survey the bag resulted from:

e an inappropriate atdtude concerning his responsibihties e failure to follow established procedures The HPES evaluadon identified a few programmatic -

weaknesses as well as areas for program enhancements u

1 Program weaknesses were aggravated by e The increased volume of waste generated during RF-4 e Layoff of decon personnel prior to the actual end of the outage e Shortage of storage locations for radioactive matenal and waste .

e There was perceived pressure to move and process material prior to the pending plant startup

1 Program weaknesses e Accountability / ownership for radioactive material, tools and equipment

. Pre-planning for the storage of radwaste e Control of radioactive material during the end of RF-4 e General plant worker training on handling and 5 control of radioactive material (affects worker attitude and performance) e Spot check / veriScation surveys e P3 Awaste minimization e Upgrade equipment used for bulk surveys n

I Behavioral factors associated with bulk material surveys e Boredom o Tired / Fatigued e Perceived prusure to complete task e Inappropriate attitude concerning task External factors affecting behavior e Working conditions

. Equipment Suitability e Task interruptions 13

i Corrective actions and program improvements need to coordinate a number of factors:

1

• Improve radwaste minimization e Improve general radworker attitude about ec.ndling and control of material within the plant

. Ensure that plant housekeeping is maintained (expidite cleanup of C-Zones, general area cleanliness, removal of scaffolding and materials upon completion of work) e Improve pre-planning of radwaste storage and management e Innovative programs to provide accountability for reusable radioactive material and equipment e Upgrade to equipment suited for surveying large quantities of boards, hoses, scaffolding material and other various scrap material e Methods to minimize boredom and fatigue during the performance of repetitive tasks n

ADDITIONAL CORRECTIVE ACTION The plant manager met with Radiation Protection personnel and-discussed ,

professionalism and-standards and expectations for the department. He stressed personal accountability and responsibility for department employees.

Department- challenged by the Vice President to be the #1 - R.P.

Department in Region IV.

Establish weekly communications meetings with R.P. Management and-Technicians to bring problems and solutions out in the open.

INPO Assist Visit scheduled for January 11, 1993 through January 15, 1993 on outage related radioactive material control.

Peer evaluation by Corporate H.P. - Entergy Corporation.

R. P. Foreman assigned to supervise deconners, Radwaste and Hot Shop areas.

Scheduling team building training for the Radiation Protection Department to alleviate barriers between management and classified personnel.

Radwaste minimization plan produced.

Lock roll up doors to prevent intrusion of material into the RCA Evaluate interim storage so that material can be quickly processed _ from the RCA, stored and surveyed at a later time.

Evaluate the use of- another location for surveying and segregating-material. This area should have minimal background noise and radiation levels. Material could be batched into the facility from the' interim storage containers..

Y[

Provide additional automated survey equipment suited for survey of l boards, hoses, scaffolding material and v3rious scrap.

Formed Radiation Protection Program Enhancement committee to evaluate and recommend improvements.

Management will evaluate the recommendations of the enhancement committee. Expected completion date of 1/14/93.

During times when material is being processed from the .RCA, assign responsible individual for accountability and supervision of surveying and release of material.

f Personnel performing the surveys should be monitored and optimized rotation schedule developed to reduce boredom and fatigue. -

Continuation of Radiation Protection Technician committee as an advisory committee to Radiation Protection Management.

Broaden scope of QA surveillances to include material accountability in the RCA.

Task specific rad worker training will be incorporated into appropriate discipline training.

l 1 ,

I

l SERVICE WATER PIPING REPLACEMENT DURING RF-4 248 VALVES 1093.5 SQ FEET OF PIPING SURFACE AREA AMOUNT OF HOSE SURVEYED I DURING RF-4 3500 FEET OF HOSE Y

~~

rT"' - - - - -

NUMBER OF WORK ORDERS PERFORMED DURING RF-4 OVER 5000 WORK ORDERS'WERE WORKED DURING RF-4 l-OVER 3000 PM WORK ORDERS WERE WORKED DURING RF 4 -

_ _ _ . _ _ ~ _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - ^ - - - - ^ - - - - - - - - " - - - - - - - ~ ~ - - - - - ' ' ' '

l VOLUME OF RADWASTE GENERATED DURING REFUELING OUTAGES 44 j' _.

n.-

..g 1

l l

l i t

l WASTE PROCESSING t

NORMAL OPS RF-4 t

DEDICATED PERSONNEL t .; 8 24

.g , .._ . .

WASTE COMPACTOR USAGE- ! llf/i ; '

t .,, 2/ WEEK PCs PROCESSED . ;*14,500 StrS/WFJ.E

• PEAK 27,000 SETS / WEEK l

Tool Room Issued During RF-4 1

I l l l

Total Hot / Cold Tool Room Issues 88,000 l

Hot M&TE Issues Only 1,240  !

Hot ToolIssues Only 18,264 l

l l

AaageTod RoomTransacdonsper Month 7000 6500 " '

q .

6000 '

l gggg , ,..s ; ,:. ~ e :y. t c3 X5(" " kX-:,;, , '

l ,

5000 . z, b J

l s s 3.-

p.at n ,y . >

3500 ^ * '

3000  ? '

2500 ~ "# '

Normed Operations RF4

f STAFnNG IIVEIA .

NORMAL OPS RF-4 13 T EC-S (3.1) 23 80 73 TEC -S (' 8.' ) 5 25 J.7 TECHS / 0 23

_OCA _S DECO N N ERS 15 65 L

i 207 M E 5 6 8

^

SUPERVISORS 1 3 i

n-W

I TOTAL RP OUTAGE STAFFING l

u R.-2 7 :-3 7 :-L 64 75 ~ 33

• 1 1

a Includes 23 Returnees / 28 House Techs l

l l

A_7

TOTAL PERSOXNEL APPROVED FOR ACCESS INTO THE RCA i NORMAL OPS RF-4 1050 2800

l DECON PERSONNEL HET D OVER FOR PLANT CIRASUP i Date l Personnel 8/15 8/22 28 8/23 8/31 15 9/1 9/~3 5 9/14 9/30 2 10/1 Currert 0

CRD REBUILDS DURING RF-4 TOTAL CRDs REBUILT - 50

, MAN-REM EXPOSURE REMOVE / INSTALL > %PhD REBUILD

PRIMARYSYSTEM VALVE REPACKS (Since Startup)

RECIRC l 118: _.

u -

~

WCS (; 142

• 288 Total

• 61 were done during RF-4

u 1

1 SURVEY REQUESTS ARE EVALUATED

REFERENCE:

RSP-0200 / RSP-0009 '

• SURVEY REQUESTS ARE SUBMITTED BY CRAFT PERSONNEL AND EVALUATED BY RADIATION.

PROTECTION.

W RSP-0200, " RADIATION WORK PERhiYS",

CONTAINS GUIDANCE FOR EVALUATION :OF SURVEY REQUESTS AND RWP INITIATION.

• RSP-0009, "ALARA PROGRAM", PROVIDES FOR:

CONDUCTING A FORMAL ALARA REVIEW DN A TASK IF THE TASK MEETS THE SPECIFIED ALARA ACTION LEVEL.

i-i L

g-tt l .

1-  ;

PRE-JOB SURVEYIS CONDUCTED

REFERENCE:

RPP-0006

• A PRE-JOB SURVEY IS CONDUCTED THAT WILL IDENTIFY THE RADIOLOGICAL HAZARDS IN THE APPLICABLE WORK AREA.

THE FOLLOWING CONSIDERATIONS ARE SPECIFIED IN RPP-0006, " RADIATION SURVEYS",

EACH OF THESE ITEMS SHOULD BE ADDRESSED DURING THE PERFORMANCE OF A PRE-JOB SUR VEY..

A -13

A RWP IS GENERATED AND APPROVED FOR THE TASK:

REFERENCE:

RSP-0200 RSP-0200 CONTROLS THE APPROVAL AND; '

ROUTING OF RWP'S.

• FORMAL ALARA REVIEWS ARE CONDUCTED IF.

THE WORK ACTIVITY MEETS:THE APPLICABLE t

ALARA ACTION LEVEL.

MANAGEMENT APPROVAL OF RWP'S ARE CONSIS TENT WITH THE REL A TI VE RADIOLOGICAL HAZARDS OF THE TASK..

D-I+

PREWORK BRIEFING IS CONDUCTED BY CRAFT SUPERVISION:

REFERENCE:

ADM-0023, APPROVED RWP CRAFT FOREMAN CONDUCT A RWP REVIEW WITH THE INDIVIDUALS THAT ARE ENTERING THE WORK AREA. RWP REQUIREMENTS A.ND RADIOLOGICAL CONDITIONS ARE DISCUSSED.

t

.i " l

RWP REVIEW AND PREWORR BRIEFING IS CONDUCTED BY RADIATION PROTECTION:

REFERENCE:

APPROVED RWP

• RADIATION PROTECTION FOREMAN OR LEAD TECHNICIAN WILL BRIEF THE TECHNICIAN '

PROVIDING THE WORK COVERAGE ON SUR.VEY v

l EXPECTATION'S AND EXPECTED RADIOLOGICAL HAZARDS.

• THE TECHNICIAN PROVIDING THE COVERAGE l

AND THE LEAD TECHNICIAN NORMALLY WILL BRIEF THE CRAFT PERSONNEL ON THE RWP AND RADIOLOGICAL REQUIREMENTS, .

l n

VALVE PACKING IS REMOVED FROM THE VALVE:

REFERENCE:

RPP-0006, RSP-02I3 CONTINUOUS RP COVERAGE IS PROVIDED TO REMOVE PACKING FROM A PRIMARY SYSTEM. AIR SAMPLING IS SET UP IN THE WORK AREA IN THE BREATHING ZONE AND RUN ONLY DURING ACTUAL WORK TIMES. -

• A SURVEY IS CONDUCTED ON THE PACKING AS ITIS REMOVED

• HIGHLY RADIOACTIVE TRASHIS SEGREGATED FROM LOW LEVEL- WASTE AT THE WORK SITE.

• MATERIAL THAT CONTRIBUTES TO THE WORK AREA DOSE RATES IS SEGREGATED.

• RP HAS STOP WORK AUTHORITY O -17

RPP-0006 FOR GUIDELINES CONTAINS THE FOLLOWING PRECAUT PERFORMING SURVEYS DURING JOB COVERAGE:

• INCREASES RESULT OF IN WORKING AREA DOSE RATES AR ACCUMULATION OF HIGHLY RADIOACTIVE MATERIAL IN THE WORK AREA, VALVE PACKING MATERIA GASKETS, DECONTAMINATION MATERIAL, ETC.

• HIGHLY RADIOACTIVE DEBRIS AfA Y BE DIFFICU WHEN PERFORMING RADIATION SURVEYS WHERE RADIA TION LEVELS MASK THE DOSE RA TE CON THESE SMALL ITEMS.

• MAY CONS 7ITUTE A SIGNIFIGANT EXTREMITY, EXPOSURE POTENTIAL IF HANDLED.

CONSIDERATIONS DURING JOB COVERAGE SURVEYS

• BUILD-UP OF RADIOACTIVITY ON WORKERS GLOVES

• MONITOR DOSE RATES TO DETECT CHANGES IN DOSE RATES.

kd

i

• SURVEYS SHOULD BE PERFORMED AS A MINIMUM

.1. ON SYSTEM BREACH

2. AS WASTE AND/OR DEBRIS ACCUMULATE, ETC..

• INFORM WORKER OF PuiDIATION LEVELS-

• OBTAIN AIRBORNE SAMPLES IN BREATRING ZONE.

• PRIOR TO ENTRY, BRIEF WORKERS

1. CONDITIONS EXPECTED

2. AREAS TO BE AVOIDED .

3. AREAS AFFORDING-LOWER DOSE RATES v

4. DOSIME' iRY PLACEMENT TECHNICIANS PROVIDING CONTINUOUS COVERAGE SHOULD:

• VERIFY WORKERS-DOSIMETRY IS PROPERLY WOPN.

• ADVISE- WORKERS OF KNOWN OR POTENTIAL SPECIAL HAZARDS.

• DEFINE CONDITIONS / OCCURRENCES THATMAY REQUIRE T JOB TO STOP:

1. UNEXPECTED HIGH RAD LEVELS A-19

2. LACK 0F PROGRESS '

3. COMMUNICATIONS PROBLEMS

- 4. POOR- WORK PRACTICES

5. CHANGE IN WORK SCOPE.

e 4

9

.e.

l t

6-20 f

TRANSPORT OF HIGHLY RADIOACTIVE MATERIAL

REFERENCE:

RSP-0213 " CONTROL AND HANDLING OF RADIOACTIVE MATERIAL"

• HIGHLYRADIOACTIVE ITEMS ARE SEGREGATED AT-THE WORK SITE TO MINIMIZE EXPOSURE TO WORKEF9.

• ITEMS ARE TRANSFERRED TO A DESIGNATED STORAGE AREA AS'SOON A$ PRACTICABLE. t r

• NORMAL METHOD OF TRANSPORT VIA MECHANISM .

THAT PREVENTED CONTACT WITH BODY.-

• MA TERIAL ESCORTED BYA RADIA TION PROTECTION TECHNICIAN UNTIL PROPERLY STORED. -

b J :

RSP-0213 " CONTROL AND HANDLING OF RADIOACTIVE MATERIAL" CONTAINS GUIDANCE FOR TRANSFER OF HIG8LY RADIOACTIVE MATERIAL.

• > OR = TO 100 mR/hr AT CONTACT

• NOTIFY THE CONTROL ROOM

• DESCRIBE ROUTE TAKEN

• ENSURE THAT THE ROUTE IS CLEAR .'

• INFORM PERSONNEL ENCOUNTERED

• PERSONNEL- TRANSFERRING MATERIAL MAINTAIN THEIR-EXPOSURE ALARA

• CONSIDER -

1. TYPE OF PACKAGE.

2. RADIATION HAZARDS DURING TRANSPORT

, _3. AREA MATERIAL IS TO BE STORED 18" DOSE RATE > OR = TO 100 mR/hr r.

'GSU AND/ CONTRACT RADIATION PROTECTION TECHNICIANS -

RECEIVE TRAINING IN RELEASE OF MATERIAL FROM THE RCA AND PROTECTED AREA.

THE 'REQUIREhfENTS FOR- UNCONDITIONAL RELEASE- OF . .

RADIOACTIVE MATERIAL AT RIVER BEND

• THE PURPOSE AND REQUIREMENTS OF A GREEN TAG.

• THE DOCUMENTATION REQUIREMENTS

• RECORD SERIAL NUMBERS *

• SLRVEYS TO BE PERFORMED PRIOR TO UNCONDITIONAL RELEASE OF MATERIAL-FOR UNRESTRICTED USE.

• THE PROCESS OF UNCONDITIONALLY RELEASING' MATERIAL

• SURVEYS TO BE PERFORMED PRIOR TO CONDITIONALLY RELEASING MATERIAL FROM THE RCA

,- .i...~ _,;_._.~.__, . . . . . . . . , , - . . , ,,......_e ,. .. . , . .- , . , ,. . , , , . . . . . - , ,

UNCONDITIONAL RELEASE OF MATERIAL FROM THE RCA:

REFERENCESi RSP-0213, RPP-0006 ,

• SIATERIAL IS SURVEYED PRIOR TO RELEASE FROM THE RADIOLOGIC CONTROLIRD AREAS

• RSP-0213 AND RPP-0006 PROVIDE GUIDANCE ON PERFORMING SURVEYS MATERIAL FOR RELEASE FROM THE RCA RSP-0213 ' CONTROL AND HANDLING OF RADIDACTIVE MATEPJAL" PROVIDE.

GUIDANCE:

• SURVEY FOR TRANSFERABLE AND FIXED CONTAMINATION

• MASKING OF RADIOACTIVITY ON EQUIPMENT

• EVALUATE:

1. INACCESSIBLE SURFACES

2. ACCESS P0lNTS

3. ITEMS INTERNALS EXPOS:D TO RADIOACTIVE PROCESS FLUIDS

• PAY ATTENTION TO:

1. CREVICES

2. WHEELS i

3. DIFFICULT TO REACH AREAS

• DISASSEMBLE EQUIPMENT A 'Y

i

( RPP-0006 " RADIOLOGICAL SURVRl'S" PROVIDES GUIDANCE:

• EVALUA TE:

1. USING SMEARS

2. S1VABS

3. DIRECT SURVEl'S

• EVALUATE POTENTIAL FOR INACCESSIBLE SURFACES:

1. ITEMS SUCH AS GAUrES, HOSES, TUBING, ETC.

• DETERMINE \YHAT SYSTEM (S)

• EVALUATE \YHERE THE ITEM \VAS USED ,

• EVALUATE FLUSH \YATER

RELEASE OF AIATERIAL FRohl Tile PROTECTED AREA:

REFERENCE:

RSP-0213

" CONTROL AND HANDLING OF RADICACTIVE AfATERIAL" PROVIDES GUIDANCE:

• SIA TERIAL LEA VING THE PROTECTED AREA IS SURVEl'ED PRIOR T

• ITEAIS KNOWN OR SUSPECT REQUIRE A SURVEl' PRIOR TO RELEASE

• ALL ITEAIS REQUIRE A RELEASE TAG OR ACCOAIPANIED B1' A RADIATI PROTECTION REPRESENTATIVE

• VEHICLES WlHCH LOAD AIATERIAL ARE OF SPECIAL CONCERN

• AfATERIAL SUCH AS:

1. SCRAP WOOD

2. SCRAl' AfETAL

\

3. AflSCELLANEOUS TOOLS SHOULD BE CHECKED PRIOR TO LOADING

• IF AN ITEAf 15 KNOWN TO HAVE NQI BEEN IN A RCA AND NO REASON TO SUSPECT AN ITEh! HAS BEEN IN A RCA, AfAl' ISSUE A GREEN TAG ON TlHS BASIS:

EXCEPTIONS TO THE RELEASE TAG REQUIREnfENTS:

1. PERSONNEL ITEAf 2.

VEHICLES DELIVERING AfATERIAL PROVIDED NO ITEAfS ARE PICKED UP

3. PLANT VEHICLES THAT HAVE NOT ENTERED THE RCA 0-2Lo

, , , - , ,