ML20137M907

Quality Assurance Audit Rept QSL-OPS-95-22, Monthly Performance Monitoring Audit, Nov 1995

ML20137M907
Person / Time
Site:	Saint Lucie
Issue date:	01/10/1996
From:	Voorhees J, Walls J FLORIDA POWER & LIGHT CO.
To:
Shared Package
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References
FOIA-96-485 QSL-OPS-95-22, NUDOCS 9704080198
Download: ML20137M907 (53)

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FPL Nuclear Division .

m Quality Assurance Audit Report MONTHLY PERFORMANCE MONITORING AUDIT QSL-OPS-95-22 November,1995 i

4 Audit Team:

L. Bearror C. Norris R. Walcheski J. Walls l

L. W. Bladow l QA PSL 9704080198 970401 i

PDR FOIA BINDER 96-485 PDR

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JQQ-96-003 ,

January 10,1996 l

Page two '  :

St. Lucie Action Requests (STARS) have been generated for the above findings. In accordance with the FPL Quality Assurance Propeu, please ensure that the STARS which address these findings are l responded to'within 30 days of origination. ~As noted in QI'16 PPJPSL-2 response to STARS resulting from QA audit findings must include the following:

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1. The results.of review and investigation of the findings including identification of the probable root cause/ causal factors. >

2. Results of your examination of potential weaknesses in departmental self-assessment -

programs which may have impeded self-identification of the problem.

3. - A determination of the generic impact of the finding, i.e., whether it extends to other areas, j

systems, drawings, procedures, etc., or whether it is isolated to those examples cited in the audited report.

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4) Actions taken or planned to correct the findings identified and to prevent recurrence of the l deficiency. Corrective actions should address the causal factors and enhancements to the audited department's self-assessment program. i l

5. Date when full corrective action was or will be achieved. l

6. Identification of the individual (s) responsible for the corrective action.

For those corrective actions s. .J.. cannot be completed within 90 days from the audit report transmittal, the response shall (1) include an explanation why the action cannot be completed within E

90 days and (2) include both the cognizant Vice President (or Director where the Director is a direct report ofihe President - Nuclear Division) and the Vice President Nuclear Assurance on distribution. /

An evaluation should be made of the findings identified in this audit to determine reponability.

4 We smcerely appreciate the cooperation we received from your staff during the course of the audit.

Please contact me at extension 7111 or the respective QA contact if you have any questions. ]

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L. W. Bladow

, Quality Manager - PSLE

1 LWB/JTV/JJW/str-

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I Inter-Office Correspondence ,.

JQQ-96-003 To: J. Scarola Date: January 10,1996 From: L. W. Bladow Department: JNA/PSL

Subject:

Quality Assurance Audit OSL-OPS-95-22 Attached is the summary of Performance Monitoring activities completed during November and early December,1995 to assess the implenientation of the Quality Assurance Program at St. Lucie.

The following f'mdings are documented in this report and have been discussed with appropriate personnel and exited with PSL Plant Management.

Findine 1: Procedures for replacement of the Unit-2 wide range nuclear instruments did not provide for the conduct of Technical Specification required sealed source leak tests of the fission chambers within 31 days ofinstallation. Personnel involved with replacement activities were not cognizant of this requirement.

Findine 2: A. Review of the Special Nuclear Material Control Forms for the recent replacement of the excore fission chambers indicates that the fission chambers were transferred to the I&C Hot Shop, an area that is not authorized by procedure. This is a repeat finding.

B. Review of the Material Balance Report for the period 4/1/95 to 9/30/95 for St. Lucie Plant identified a discrepancy in the accounting of Special Nuclear Material as documented on NRC Form 741 and NRC Form 742.

C. The Special Nuclear Material Control Manual in use by Reactor Engineering was found to be out-of-date.

Findine 3: During several tours of the RCA and Containment it was determined that: 1) not all postings were shown on approved radiation and contamination surveys 2) not all instruments were being properly logged out. ,

Findine 4: Several discrepancies were identified regarding the administrative requirements for control of Equipment Clearance Orders.

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QUALITY ASSURANCE DEPARTMENT d AUDIT REPORT DISTRIBUTION i

AUDIT REPORT: OSL-OPS-95-22 PLANT / DEPARTMENT: St. Lucie Plant NUMBER OF FINDINGS: Four CNRB Additional Distribution R. J. Acosta - JNA/JB J. H. Goldberg - JEX/JB W. H. Bohlke - JPN/JB T. V. Abbatiello - JNA/PTN J. E. Geiger - JNA/JB L. W. Bladow - JNA/PSL D. A. Sager - VP/PSL-1 R. A. Symes - JNA/JB T. F. Plunkett - VP/PTN D. A. Culpepper - JPN/JB G. J. Boissy - JPN/JB QAD Files w/ Checklist & Audit Plan Cheryl Robinson - JNA/JB Dr. K. R. Craig - JPN/JB Health Physics & Chemistry Related Audits H. N. Paduano - JPN/JB Manager Nuclear Health Physics / Chemistry Dr. W. R. Corcoran (CNRB) Emergency Prenaredness Related Audits Manager - Nuclear Emergency Preparedness S. E. S'cace (CNRB)

Fire Protection Audits K. E. Gutowski - JNA/JB S. Martin, Risk Management Additional Distribution Nuclear Division Staff Related Audits D. H. West M. Miller ,

Nuclear Training Related Audits E. Weinkam Manager Nuclear Training J. Danek

11. Buchanan Ssturity Related Audits R. Olson

• Manager Nuclear Security J. West  !

C. Wood . Nuclear Materials Manacement Related Audits l W, Parks Director Nuclear Materials Management H. Mercer J. Marchese *Only Distribution outside the Plant for i Security Audits Containing Safeguards ges S i

O AUDIT REPORT QSI OPS-95-22 Page 2 of 28 i

Audit Location: St. Lucie Plant Date of Audit: November 1995 Audit Scope: This audit is a performance based evaluation of activities affecting quality, and provides verification that those activities are conducted in accordance with appropriate controls and requirements. Performance Monitoring was conducted for selected plant operating, maintenance and services activities to provide objective evaluation and qualitative verification that activities are !

being performed in accordance with specific technical and quality l requirements.

Audit Summary: Performance Monitoring reviews for the month of November 1995 were l primarily focused on plant activities conducted during the Unit-2 refueling outage. The following activities were reviewed; control ofin-plant equipment l clearance orders, Health Physics' activities, control of welding, corrective l action for Operator Work Arounds, a coordinated local law enforcement i security drill and Special Nuclear Material Controls. Good performance was j noted in the areas of field implementation of clearance order requirements, )

welding, the coordinated local law enforcement security drill and management of the program for resolution of Operz. tor Work Arounds.

Details are contained within this report. Compliance of plant personnel with radiological protection requirements was noted to be good. Three Findings are documented within this report. Finding 1 addresses inadequate procedures to ensure that sealed source surveys required by Technical Specifications ar'e conducted when performing maintenance on or installation of fission detectors. Finding 2 documents three separate deficiencies concerning requirements for control of Special Nuclear Material. Finding 3 documents procedural non-compliancer with regard to radiological surveys and logging of HP instrument usage. During the review of clearance orders. QA issued 3 PSL STARS that addressed problems with administrative aspects of the clearance order program. Finding 4 documents these deficiencies as a QA Finding.

A comprehensive corrective action effort is warranted for Finding 2. One of the deficiencies identified within the finding concerns storage of Special

6 AUDIT IEPORT QSL-OPS-95-22 Page 3 of 28 Nuclear Material in an unapproved location. This is a repeat Finding. This issue was previously identified in December 1994 (QA Audit 94-26 Finding 1). NRC Inspection report 95-12, dated 6/30/95, included a non-cited violation for failure to properly label Special Nuclear Material in accordance with 10CFR20 requirements. These examples, in addition to those cited in Finding 2 of this report indicate the need for increased management attention and site awareness of requirements applicable to the control of Special Nuclear Material.

Based on the activities and objective evidence audited, it was determined that the requirements of the QA Program are adequately addressed by procedures and that implementation of those procedures is effective. The Findings contained within this report identify specific areas where improvement is required to achieve additional program effectiveness.

Onerations:

PMON 95-065 was conducted to verify compliance with selected radiological protection requirements during the Unit 2 Refueling Outage. The areas examined included the following:

1. Radiation area posting, labeling and control.

2. Personnel dosimetry and entry into the RCA.

3. Control of the-issue of respirators by junior technicians (follow-up to previous QA deficiency)

4. Radiation Work Permit (RWP) compliance.

Within these areas, selected criteria of INPO 91-014 " Guidelines for Radiological Protection at Nuclear Power Stations" were examined.

This activity was performed by conducting tours of the Radiation Control Area (RCA) including the Unit 2 Containment Building. Additional reviews of RWPs, Radiation and Contamination surveys, Health Physics (HP) Logs, and HP Procedures were conducted. The auditor attended Generic Pre-job briefings, observed shift turnover, and interviewed HP technical personnel and supervision.

Plant personnel were observed to be using dosimetry properly, dressing out properly, and following applicable RWP requirements. Reports of personnel skin and clothing contamination were reviewed.

Four such reports generated during the pressurizer heater replacement were followed from initiation through completion. Using HPP-30 Appendix 8. " Assessment ofInternal Dose," applicable files were reviewed for completeness in accordance with the specified requirements. The files were found

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1 to contain necessary information. Assigned doses were traceable from applicable work sheets  !

through to the NRC Form 5s. It was also noted that in no cases were the established limits at St. l Lucie exceeded.

1 During a previous QA audit, the use of unqualified junior technicians to issue respirators was identified. During this outage, respirator issue was determined to have been performed by qualified personnel.

The performance of radiological surveys was examined for the following attributes:

1. Adequate periodicity of performance

2. Proper completion of survey forms including instrument information

3. Verification of required postings based on the survey results The result of this review indicated that in some cases smvey maps are not being updated to show all postings in the plant and that some postings were not made as a result of the survey information.

In addition, not all instruments used during radiation surveys were properly logged as required by procedure (See Finding No.3). STAR #951817 was written on 11/14/95 to obtain immediate corrective action.

With the exception of the finding listed above, the Radiation Protection Program is adequately implemented in the areas observed.

Perfonnance Monitor: J. Walls t

l PMON 95-066 was conducted to assess the adequacy and implementation of the process for l controlling In Plant Clearance Orders, OP-0010122. Audit results were obtained from a combination l of procedure and clearance order reviews as well as direct observation of Operations Department l activities supporting specific clearance orders selected for verification.

During this PMON, Equipment Clearance Order forms for both active and completed clearances were reviewed for procedural compliance. Operators were also accompanied while hanging and I releasing clearances to verify procedural compliance. Independent Verification activities were I observed, and found to be in complience with ADM- 17.06. Clearance tags were verified to be filled out, signed, and dated as required. Only one discrepancy was identified on tags reviewed. Tag #18 for ECO #2-95-09-284 had not been signed when hung. This was pointed out to Operations. and the discrepancy was rectified.

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E AUDIT REPORT QSL-OPS-95-22 Page 5 of 28 A review of INPO good practices for Tagging Procedures and Independent Verification was conducted during this Audit. Both the Clearance Procedure, OP-0010122. and The Independent Verification Procedure, ADM-17.06 were noted to be generally in line with the content of the INPO documents. One difference was noted concerning the review of clearances. Paragraph 7.10.1 of INPO 87-002, R1, calls for a weekly administrative review of clearances by a Licensed Operator.

This document states:

"This review will verify that the clearance index accurately reflects active clearance sheets. Additionally, this review will verify the continuing need for each clearance...

Clearances that cannot be verified as being needed will be brought to the attention of appropriate management personnel for disposition."

Currently, the clearance review directed by APl/2-0010125, and accomplished using Data Sheet

1. 28, is a monthly verification of clearance tags to insure correct component position, tag legibility, and tags properly filled out and signed. There is no direction to look into older clearances to determine if they are still needed.

During a review of older existing clearance orders on Unit One, ECO #1-95-05-026, for Radiation Monitors, written 5/9/95, was noted as being issued to the Unit l ANPS. The reason for the clearance was indicated as " Equipment abandoned in place." A review of the Abandoned Equipment Log showed these radiation monitors not listed as abandoned in accordance with procedure AP-0006041. Abandoned Equipment Program. A periodic review as described in the INPO guideline may have prompted a review of the status of this equipment.

As a result of this PMON, the hands-on portion of the clearance process was determined to be effectively implemented. The Administrative portion has opportunities for impr'ovement as reflected by the STARS discussed below.

During this PMON, several STARS were generated by the Auditor in response to deficiencies identified conceming the authorization list for clearance holders, an unsigned clearance tag in the field and the failure to review the Jumper and lifted lead log and the Equipment Out Of Service Log prior to initiating a clearance in accordmce with plant procedures. These issues are discussed as Finding 4.

In addition. STAR 952139 was written to determine the status of LCL Rad. Monitor Pnl. Ckt. #22.

Power Panel PP-109 which is on Equipment Clearance Order 1-95-05-026. The reason for the clearance is listed as " Equipment Abandoned in Place." This equipment is not contained in the abandoned equipment program.

Performance Monitor: L. Bearror

i AUDIT REPORT 1

QSL-OPS-95-22 Page 6 of 28 PMON 95-073 was initiated to review and evaluate implementation of St. Lucie Plant's corrective action program as applied to correction and reduction of operator workaround (OWA) items.

Specific attributes of the program evaluated included:

. Documentation of deficient conditions.

. Determination of root cause and corrective action to prevent recurrence where applicable.

. Tracking, follow-up, and close-out of resulting corrective action.

. Documentation of corrective action taken.

. Management oversight of the OWA program.

The results of this review and evaluation indicate that the backlog of open OWAs has steadily increased since August 1994. However recent increased attention and involvement by management personnel have effected improvements in tracking, statusing, scheduling, classifying and closing of OWAs. These improvements have been reflected in a reduced rate of increase in the backlog during September - November 1995. Approximately twenty additional OWAs of 104 that were open at the end of November, are scheduled for completion of evaluation or corrective action by the end of December 1995. He improvements described above and the management attention i being given to OWAs should result in continued reduction of the backlog; however, this program l is not currently defined in any plant procedures. Revisions to existing procedures should be l performed to add administrative guidance that will maintain an appropriate level of attention to l OWAs. -

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This evaluation was accomplished through reviews of the STAR database open OWA STARS, OWA closure documentation in the September - November 1995 timeframe. and by interviews of appropriate site personnel. Review of the STAR database revealed the previously described l increasing trend in the backlog of open OWAs. The backlog increased steadily from 9 items at the l end of August 1994, to 104 at the end of November 1995. During the months of September - l November 1995 the rate of the backlog increase dropped significantly as compared with previous months; in addition as described above, approximately twenty other OWAs are scheduled for l completion of corrective action or evaluations by year's end. This improvement may be attributed to:

. Use of a skyline database to provide an accurate and visual status of OWA items at lead team and daily STAR meetings,

. Inclusion of OWAs in the Significant Material Deficiency Reports that are distributed to management monthly, l

9, AUDIT REPORT QSL-OPS-95-22 I:PL Page 7 of 28 e improved definition and scope used to classify an item as an Operator Workaround,

• Completion of outage related items, and

. Increased management attention and support.

A revision to the definition and scope of an OWA was necessary to reduce the number of operator preference items being classified as operator workarounds. The definition of an OWA as delineated in AP-0010120 was determined by plant staff to provide too broad a scope and to allow classific. Mica of some deficient items as OWAs when they were actually operator preference items.

The use of these tools and continued emphasis by management should result in a continual decrease of the OWA backlog.

During review of the STAR database it was difdcult to determine the corrective action status of open items; however, this status is being accurately tracked and administered using a skyline database maintained by the Operations Support and Testing group. Since the Operations Support and Testing database is the primary tool used to administer the OWA program, Quality Assurance believes that the methods established for tracking the status of an OWA during corrective action implementation and follow up through item closure meets the requirements of the Qcality Assurance Manual, TQR 16.0.

A review of OWA STARS closed during September - Nove.mber 1995 indicated that the items where closed only after follow-up and concurrence by Operations supervision. Interviews with site personnel indicate general satisfaction with the closure actions taken. Where appropriate root cause was determined, steps to prevent recurrence were taken.

The above reviews indicate that management is aggressively pursuing correction of Operator Workarounds and the corrective action taken is concurred with by the Operations staff.

Perfom1ance Monitor: C. E. Norris PMON 95-75 was conducted to evaluate the St. Lucie Plant Special Nuclear Material Control Program. The criteria utilized included 10 CFR 70 and the NRC Inspection Procedure 85102

" Material Control and Accounting - Reactors." This evaluation was conducted through interviews, review of records and procedures. verification of data transfer and a physical inventori of accessible areas. The result of this review indicates that there is improvement needed to bring this program into compliance with requirements contained in the Code of Federal Regulations.

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AUDIT REPORT

{k'} QSL-OPS-95-22 Page 8 of 28 A walkdown and inventory of Special Nuclear Material (SNM) was conducted. This included a review of those areas that are authorized for the storage of SNM.10 CFR 70 requires that licensees designate Item Control Areas (ICA) in which physical and administrative controls are maintained.

At present there are 11 such areas authorized for storage of Special Nuclear Material. During this PMON, non-fuel SNM stored in these areas was accounted for by inspection or review of records.

The documentation used to record the movement of SNM was adequate on an overall basis, but a j specific review determined that on 4 occasions, SNM was documented to have been stored in the I&C Hot Shop, an area not authorized for storage of SNM. This is a repeat fmding and is documented in Finding 2 below.

Documentation of fuel movement was found to be adequate. Five new fuel bundles were selected ,

and tracked to the Unit 2 reactor during the present refueling using the Reactor engineering l procedures and the NRC 741 forms. The last 2 inventories for each unit were reviewed and found l to be adequate and have been performed within 12 months of each other as requi:ed'. An l independent core verification of the Unit 2 reactor after refueling was conducted by Quality Assurance. This check involves an observation by camera of the loc .on and orientation of each j fuel assembly and control element assembly, l A review of the Material Balance Report (NRC742) for the period 4/1/95 and 9/30/95 was performed to verify compliance to the requirements of 10 CFR 70. NRC 741 forms for the new PSL-2 fuel and 4 new wide range fission detectors were compared to the information contained in the Material Balance Report prepared by Reactor Engineering and Nuclear Fuels. The new fuel information was found to be satisfactory but the fission chamber information was found to be inaccurate. The report indicated that there were 14 grams of SNM provided to FPL from Gamma-Metrics but in fact there were 4 fission chambers of 7 grams each for 28 grams. See Finding 2 below.

St. Lucie Technical Spedfications for Unit 2 require a sealed source leak test within 31 days of installation for new wide range detectors in nuclear instrumentation. During the Unit -2 outage a review of plant records was conducted to verify that these leak tests had been performed. Records of these tests were not available when requested and there was uncertainty as to whether or not the tests had been performed. Subsequently,information was recovered by Health Physics which enabled the test results to be established. The requirement to perform these tests is not properly addressed by plant procedures. STAR 951973 was generated by QA to document this condition.

See Finding No.1 During this review the copy of the Special Nuclear Material Control Manual in Reactor Engineering was found to be out of date. See Finding 2.

Performed by : J. Walls

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O AUDIT REPORT QSL-OPS-95-22 Page 9 of 28 1

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Maintenance:

PMON 95-067 was conducted to review and evaluat'e welding activities for compliance with site procedures and the FPL Nuclear Welding Control Manual. This Performance Monitoring activity reviewed aspects of the site welding program and was specifically focused on the Unit 2, Cycle 9 refueling outage.

The conduct of this PMON involved random and periodic surveillance of field activities. In order to substantiate proper work prescriptions, qualifications and administrative controls, documentation such as procedures, permits, weld travelers, material requisitions, welder qualification reports, and NPWO packages was reviewed. In general, adherence to site procedures was verified for welding administrative and process controls.

Field welding was observed for Anchor Darling valve replacements, various secondary plant welding on the Feedwater system. Main Steam instrumentation, and structural welding. Tours were conducted of Construction Services and Mechanical Maintenance fabrication facilities. Tours were conducted of the weld material issue areas (F4 and Construction Services) for proper control and issue of weld rod. These areas were found to have weld material properly stored, segregated and identified.

Approved welder qualification lists were reviewed at applicable locations and verified to be current. Active material traceability listings were also present and stored material was verified to be contained in these listings. Copies of weld material issue slips (WMRRs) were properly maintained. Welding NPWO information was traced from sample weld issue slips to the work locations and found to be satisfactory. Weld rod was found to be properly controlled in the field.

NPWO packages reviewed at the work locations were found to include necessary welding documentation. Verification was performed that parameters specified by the Welding Procedure Specification (WPS) were maintained during welding. Review of welding activities and discussion with QC personnel verified that QC hold points are being adhered to.

The FPL Welding Control program was verified to be implemented by site procedures and welding activities were performed as required by these documents. No unsatisfactory conditions'were found as a result of this review.

Performance Monitor: R. J. Walcheski .

c AUDIT REPORT QSL-OPS-95-22 f:PL Page 10 of 28 Services /Enaineeriner PMON 95-074 was initiated to evaluate the St. Lucie Plant Security Force (SF) implementation  !

of activities to safeguard the plant during a Protected Area intrusion drill conducted at the plant site. These activities included: l 1

Drill control and evaluation.  !

l Determination of threat significance.

1 Direction and deployment of security force and response team personnel. 1 Initiation of the St. Lucie Plant Safeguards Contingency Plan.

Notification and request for support from the Local Law Enforument Agency. I Coordination of SF and LLEA activities.

Security Drill Initiation and Control The initiation and control of the drill was accomplished in a satisfactory manner. The Nuclear Plant Supervisor (NPS) was informed of the drill prior to its initiation in accordance with the requirements of Security Force Instruction 6. " Security Operations Office." Drill planning by the Security staff considered the safety of personnel both on and off the plant site. To reduce the, surprise to, and possible interference from bystanders, non-participating personnel in the area of the drill were informed by security training personnel that a security drill involving response by local authorities would be conducted. The drill involved pan of Big Mud Creek and required the use of a boat to contact and inform some of the non-participants. Security had previously arranged with Land Utilization for the use of a safety boat to patrol the creek prior to and during the initial stages of the drill. Use of a safety boat during drills involving the waters surrounding the plant site is considered a good practice.

Self Assessment Practices Security supervision was present throughout the drill and the follow up critique. Supervision actively participated in observation of the activity to determine where changes to response tactics.

plant physical characteristics and drill control could be made to improve physical security at the St.

Lucie Plant. This involvement by Security supersision is an excellent example of the effective use of a self assessment opportunity.

O AUDIT REPORT QSL-OPS-95-22 Page 11 of 28 j

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Security Force Effectiveness Direction of the Security Force by the Security Shift Specialist (SSS) and the Security Shift Operations Officer (SSOO) provided effective placement of the response teams. The teams were positioned between the adversaries and the vital areas of the plant as specified in the St. Lucie Plant Safeguards Contingency Plan and its implementing procedure SP-000627. This response provided sufficient delaying action to allow time for responding local law enforcement agencies to reach the site prior to a breach of protected or vital areas by outside intruders. Plant management personnel were periodically updated (simulated in some cases) on the event status by the SSS as required by SP-000627. This updating activity provided the Nuclear Plant Supervisor (NPS) with sufficient information to direct the operational response of the plant during the event. The SSS also acted as the Single Point of Contact (SPOC) for the site. Use of the SSS as a SPOC provided for a smooth and acct. rate transfer ofinformation to and from the LLEA.

The activities of the Security Force during the drill were conducted in accordance with the requirements prescribed in implementing procedures. The response capabilities demonstrated should be effective in preventing intrusion during an actual threat to the site by an outside adversary.

Performance Monitor: C. Norris Summarv of OC Surveillance Results:

A total of 57 QC Suneillances were conducted by plant QC during the month of November 19 unsatisfactory conditions were and documented on PSL STARS for Corrective Action. Details can be provided upon request.

O AUDIT REPORT QSL-OPS-95-22 Page 12 of 28 Findina No.1 Criteria: Unit 2 Technical Specifications Paragraph 4.7.10.2-C "Startup sources and fission detectors - Each sealed startup source and fission detector shall be tested within 31 days prior to being subjected to core flux or installed in the core and following repair or maintenance to the source or detector."

Finding: Procedures for replacement of the Unit-2 wide range nuclear instruments did not provide for the conduct of Technical Specification required sealed source leak tests of the fission chambers within 31 days ofinstallation. Personnel involved with replacement activities were not cognizant of this requirement.

Discussion: Replacement of all four channels of Wide Range Nuclear Instrumentation was pedormed during the PSL-2 outage. These excore detectors contain a fission chamber that requires a leak test as described in Unit 2 Technical Specifications within 31 days of maintenance or installation. (This is a Unit 2 specification only)

During preparations to install the A&C channel detectors an inquiry was made by QA regarding the fulfillment of the leak test requirement. Subsequent discussion j with Health Physics indicated that a survey had been performed of the B&D channel detectors upon removal from the warehouse but a leak test had not been completed i as outlined in HP-43 " Leak Testing & Inventory of Radioactive Sealed Sources." l Personnel interviewed were not cognizant at the time that the survey was performed that a Technical Specification surveillance was required. The sdrvey consisted of a  :

field survey and a general contamination survey. STAR 951973 was issued by'QA to document this problem. The A&C channel detectors were properly leak tested prior to installation. In-House Event 95-096 was initiated by the plant to investigate i this issue. It was later determined that the field survey and contamination survey  ;

that had been performed provided the information necessary required to verify a l satisfactory leak test. The surveillan:e documentation required by Technical  ;

Specifications was subsequently c mpleted. I Procedures applicable to the installation of detectors were reviewed. These procedures include: 2-lh1P-64.01 "Excore Neutron Detectors Removal and j Installation" and I&C 1200060 " Fission Chamber Acceptance Test." No reference to leak testing was found in I&C lh1P-64.01. The prerequisites for this procedure l require that procedure I&C 1200060 be completed. Procedure I&C 1200060 i indicates that a leak test is required on Unit 2 but does not indicate that this test is l a Technical Specification surveillance requirement.

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O AUDIT REPORT QSL-OPS-95-22 Page 13 of 28 Discussion with I&C Supervision indicated that procedure I&Cl200060 is no longer used because the new wide range detectors are made by a different manufacturer. Installation of the new detectors was performed using a Work Order generated from information contained in the detector changeout PC/M This document did not indicate the need for the source leak test. Compliarce with the requirements of this technical specification was through good fortu .. __.her than intent.

Recommendation:

1. Revise procedures applicable to installation and maintenance of nuclear instrumentation to ensure that sealed source leak test are initiated when required. Designate the applicable steps in these procedures with the asterisk used to denote Technical Specification requirements in plant procedures.  ;

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2. Provide necessary training to the personnel who perform nuclear instrumentation installation and maintenance activities. I l

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) AUDIT REPORT QSL-OPS-95-22 Page 14 of 28 Finding No. 2 Criteria: 10 CFR 70.58 Fundamental Nuclear Material Controls (d) Material Balance Areas (MBA) or item Control Areas (ICA) shall be established for physical and administrative control of nuclear material.

(1) Each MBA shall be an identifiable physical area such that the quantity of nuclear material being moved into or out of the MBA is represented by a measured value determined pursuant to paragraph (e) of this section.

(2) The number of MBAs shall be sufficient to localize nuclear material losses.  :

or thefts and identify the mechanisms. l (3) The custody of all nuclear material within any MBA or ICA shall be the respcnsibility of a single designated individual.

(4) ICAs shall be established according to the same criteria as MB As except that control into and out of shall be by item identity and count for previously determined special nuclear material quantities, the validity of which shall be assured by tamper safeing unless the items are' sealed sources" 1

AP 0010433 Special Nuclear Material Control Records and Reports Rev. 30 paragraph 8.7 l List of approved storage areas at PSL and the personnel responsible as custodians 10 CFR 70.53 Material Status Reports (a)(1) "Each liccnsee who is authorized to possess at any one time and location special nuclear material in a quantity totaling more than 350 grams of contained uranium-235. uranium-233 or plutonium, or any combination thereof shall complete and submit material balance reports as required by s 74.13(a)(1) of this chapter."

10 CFR 74.13 Material Status Report (a)(1) "Each licensee who is authorized to possess at any one time and location special nuclear material in a quantity totaling more than 350 grams of contained uranium 235 uranium-233 or plutonium, or any combination thereof shall complete 9

and submit to the commission ton DOE /NRC Form 742. Material Balance Report)

O AUDIT REPORT QSL-OPS-95-22 Page 15 of 28 material balance reports concerning special nuclear material received, produced, possessed, transferred, consumed, disposed of, or lost by it."

TQR 6.0 Document Control Para 6.3.2 "Each recipient of a controlled document is responsible for ensuring that the appropriate latest revision is being used" Finding: Three deficiencies relating to the requirements for control of Special Nuclear Material were identified:

A. Review of the Special Nuclear Material Control Forms for the recent replacement of the excore fission chambers indicates that the fissic-chambers were transferred to the I&C Hot Shop, an area that is not authorized by procedure. This is a repeat finding.

B. Review of the Material Balance Report for the period 4/1/95 to 9/30/95 for St. Lucie Plant identified a discrepancy in the accounting of Special Nuclear Material as documented on NRC Form 741 and NRC Form 742.

C. The Special Nuclear Material Control Manual in use by Reactor Engineering was found to be out-of-date.

Discussion: A. During the course of this PMON a review of Special Nuclear Material Control Forms was conducted. These forms document the movement and storage locations of SNM. A review of the forms, completed to track the location of the new Gamma-Metrics fission chambers (Wide range nuclear instrumentation), indicates that various chambers were logged as being located / stored in the I&C Hot Shop for periods ranging from 2 to 62 days.

This location is not a listed, approved location within AP0010433.

Quality Assurance Audit Report QSL-OPS-94-26 dated 12/20/94 identified a finding conceming storage of nuclear instrumentation containing Special-Nuclear Material in storage locations not approved by AP 0010433.

This is a repeat Finding. Corrective Action for the previous Finding was inadequate.

l

, AUDIT REPORT QSL-OPS-95-22 Page 16 of 28 l

B. A comparison of the NRC Forms 741 for the wide range detector assemblies  !

S/N #008. 009,010 and G! I received from Gamma-Metrics Inc. versus the l

, combined information prepared by FPL and recorded on NRC Form 742 for isotopic weights of Special Nuclear Material received during the reporting period was conducted. The Gamma Metrics detectors were listed as 7 grams isotopic weight each of U-235 on the Form 741 that accompanied the detectors to St. Lucie Unit 2 on 9/5/95. The material balance report (NRC l 742) for the period of 4/1/95 to 9/30/95 shows only 14 grams received from symbol XXS, which is Gamma-Metrics. The actual amount of material  !

received was 28 grams.

In this regard it is noted that the amount of new fuel received (1,384,571 grams isotopic weight) as listed on the NRC Form 741 was adequately carried forward by FPL to the NRC Fonn 742.

C. The SNM Control Manual in the possession of PSL Reactor Engineering l

was found to be out of date. The Reactor Engineering SNM Manual was l Revision 7. Revision 8 had been issued in July of 1995. No individuals l

currently within the Reactor Engineering organization were found to be j listed on controlled distribution for the SNM Manual. The previous Reactor '

Engineering Supervisor was still on controlled distribution. although not on St. Lucie Plant site.

Recommendations:

Note: A comprehensive corrective action elTort for this finding is warranted based on the repeat nature of some of the identified issues.

1. Conduct a review of the training of St. Lucie personnel who have SNM responsibilities to verify that they have received information necessary to maintain compliance with applicable regulations and site procedures.

2. Reviov areas approved for storage of SNM at St. Lucie for adequacy and completeness. Review plant practices and needs and consider establishing additional locations for storage if warranted.

3. Review the Material Balance Report NiiC Form 742 for the period 4/1/95 through 9/30/95 and amend as necessary. Review previous reports of this type to establish that the case described in this report isolated problem.

9 AUDIT REPORT QSL-OPS-95-22 Page 17 of 28

4. Place PSL Reactor Engineering on controlled distribution for the SNM Manual. Review AP 0010433 to ensure that the requirements of Rcvision 8 of the SNM Manual have been incorporated into this procedure.

S 6

l

/mhi i AUDIT REPORT Y# QSL-OPS-95-22 FPL Page 18 of 28 Finding No. 3 Criteria: 10 CFR 20.1531 General (a) "Each licensee shall make or cause to be made, surveys that-(1) May be necessary for the licensee to comply with the regulations in this part; and (2) Are reasonable under the circumstances to evaluate- .

(I) The extent of radiation levels; and (ii) Concentrations or quantities of radioactive material: and (iii) The potential radiological hazards that could be present.

(b) The licensee shall ensure that instruments and equipment used for quantitative radiation measurements te.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured."

HPP-20 Area Radiation and Contamination Surveys, Revision 1 )

Paragraph 7.1-4, j i

" Areas shall be posted and previously posted areas shall be updated by personnel performing surveys. Such postings and updating shall be noted on the survey maps and forms before the maps are approved."

Paragraph 5.3.

" Prior to use survey instrumems shalh 1

1. Bear a valid calibration sticker i

2. Pass a battery check

3. Pass a daily response check

4. Be logr,d out on the Instru nent Issue Log, Form HPP-13 A.1" Finding: During several tours of the RCA ana Containment it was determined that: 1) not all  !

postings were shown on routine (upda.ted) radiation and contamination surveys 2) not all instruments were being properly logged out.

9FPL AUDIT PIPORT QSL-OPS-95-22 Page 19 of 28 Discussion: During the Unit 2 refueling outage the Health Physics Department and Radiation Protection Program of St. Lucie Plant was monitored for compliance to applicable plant procedures and the Technical Specifications. This monitoring included tours of the Radiation Controlled Area (RCA) including the Reactor Containment Building (RCB). The tours consisted of review of selected Radiation and Contamination surveys, review of Radiation Work Permits (RWPs), attendance of pre-job briefings and walk down of the areas selected.

The following problems related to survey map postings were identified during this review:

1. Review of survey maps for the containment found that the survey map for the 18' Elevation did not provide all of the posting information required by procedure. This survey was conducted on 10/9/95 at 0415 and indicated a High. Radiation Area around the loop penetrations at the primary shield wall.

These areas cannot be locked. Technical Specifications allow conspicuous postings and flashing lights to be used for areas of this type. These measures were in place, however, the survey maps for this elevation did not indicate these methods of control. This condition was again noted on 10/31/95

2. On 10/28/95 a survey of the reactor head sitting on its mount indicated a contaminated area of 120,000 dpm/100cm sq. HPP-20 Area Radiation and Contamination Surveys: Paragraph 7.6-2-b states that "Any area containing removable contamination in excess of 100,000 dpm/100 cm sq. should be posted as Highly Contaminated Area." This area was not posted as recommended.

3. On 11/1/95 the following areas were found deficient based on the surveys and tour of the areas:

a. Postings for " Radiation Area" were not indicated on the survey form for HPSI/ Containment Spray Pump Room entry doors - general area fields in these areas are greater than 5mr/hr.

b. A " Contaminated Area /RWP Required" posting was not indicated on the survey form for the stainvay to 2B HPSI/ Containment Spray Pumps.

c. The 2B LPSI Pump Room survey did not indicate the following posting found during the tour; a roped off area with a stepoff pad

/3 AUDIT REPORT

(l '

QSL-OPS-95-22 FPL Page 20 of 28 l

was found posted as" Contaminated Area / RWP Required" for entry i next to the 2B LPSI Pump. l

d. The LPSI hallway to the piping tunnel was required to be posted as l a " Radiation Area." This area was in fact posted on the door, but the door was open not allowing the posting to be seen. The HP technician stationed nearby was notified of the problem and posted an additional sign over the doorway.

4. On 11/7/95 the RCA was toured and selected surveys were reviewed.

Surveys dated 11/5 I1/6 and 11/7/95 for the 18' & 23' elevation of the

]

Containment Building were reviewed. The results of the review indicated j additional examples of the problems noted above. l I

The following examples of non-compliance with the requirement to log instrument use on HPP-13A.1 were identified:

l

1. On 10/31/05 a review was performed of the Instrument issue Log. During this review ten instruments were found to have been logged back into the instrument issue log in over the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. One instrument had been logged out for three days. HP Shift supervision indicated that contractor technicians were allowed to check out the instruments for a period of time and not required to log them back in daily. It is not clear how daily source checks are performed and documented under these circumstances. Further review of the log identified that the same instrument was sometimes checked out by other personnel on or before being logged back into the system.

2. Teletector rate meters had only partial information entered in a copy of the log located in the M&TE lab in the Blowdown Building. No entries were made in the log in the M&TE issue area. The entries made included those for the battery check, source check calibration check and instrument serial number. The entries did not include the identity of the person using the instrument, location of use, and time that the instrument was logged in and out.

3. It was identified on 10/13/95 that two instruments (RO2A S/N 1794 &

2000) had Seen checked out on the 10/10/95 and had not been returned to the check ot;t area daily for a source check. The Health Physics Supervisor was notified of this problem. The Health Physics shift tumover was attended

OFPL AUDIT REPORT QSL-OPS-95-22 Page 21 of 28

.A (from days to peaks), this issue was discussed and corrective action was implemented by the next shift.

All of the above issues were brought to the attention of the HP shift supervisors upon discovery. STAR #951817 was issued during the audit to obtain immediate corrective action for some of the noted items.

Recommendations:

1. Reemphasize the procedural compliance requirements of QI 5 PR/PSL-1 with all HP personnel.

2. Review the training given to Health Physics personnel to determine the need for additional guidance on proper completion of survey maps.

i 1

6

4-

. AUDIT REPORT QSL-OPS-95-22 Page 22 0f 28 Finding No. 4 Criteria: OP 0010122 In-Plant Equipment Clearances Orders, Rev. 59,60,61.

Paragraph 4.18 l "Only personnel listed in accordance with Administrative Procedure 0010116 l "PersonnelAuthorized to Hold Clearances" shall be allowed to hold clearances."

Paragraph 5.17 "It is the operator's responsibility when executing the clearance order to enter the date, time, and sign the clearance order tags when hanging the clearance order." j l

Paragraph 8.1.5

" Prior to authorizing removal of safety related equipment from service, the NPS/ANPS/NWE shall review the Clearance Index. Out-of-Service Log and Jumper / Lifted Lead Log to determine if the redundant equipment has been removed fmm service." l Finding: Several discrepancies were identified regarding the administrative requirements for control of Equipment Clearance Orders. I Discussion: During the Unit 2 refueling outage the clearance control process was monitored for compliance with applicable plant procedures. The following discrepancies were identified:

1. A list of those personnel contained in the Work Control Group (WCG) computer program as having authorization to hold clearances was compared with the Operations Supervisor's Authorized Clearance Holders letter of 8/28/95 and temporary clearance holder authorization forms maintained by the WCG. It was identified that 14 individuals listed in the computer program as authorized to hold clearances did not have the necessary paperwork to confirm that authorization.

2. During a walk-down of E.C.O. #2-95-09-284, it was identified that tag #18 had not been signed when hung. Operations Supervision was notified of this condition and it was promptly corrected.

3. The procedure requirement to review the Out-of-Service and the Jumper / Lifted Lead Logs is not being accomplished prior to authorizing

9 AUDIT REPORT QSL-OPS-95-22 Page 23 of 28

- - -_..._. removal of safety related equipment when the clearance is generated by the WCG. This is due to the OOS and J/LL logs being maintained-separate from the WCG in the respective Control Rooms.

All of the above issues were brought to the attention of Operations Departrcent supervision. STARS 951654 and 951771 were issued during the audit to address issues #1 and #3 respectively. As mentioned above, Operations Department supervision was notified ofissue #2 when identified and corrective actions taken.

Recommendations:

This finding must be responded to in the manner described in the cover letter. The following recommendations are offered for your consideration.

1. Review Operating Procedure OP-0010122 to insure that all requirements are being met with regard to the WCG and their remote location from the Control Rooms.

2. Provide necessary training to personnel involved with the Equipment Clearance Order process.

1 l

l i

1 1

a-m o (k ), AUDIT REPORT QSL-OPS-95-22 Page 24 cf 28 Summary ofIndependent Technical Review (ITR) Activities l

This information is provided in accordance with T.S. 6.5.2.11.d. It is current for November 30, 1995.

I. Summary I No ITRs were complete / issued during November. Consequently, no items which warrant j CNRB attention were identified. i 1

I

11. The following ITRs are et rently in progress:

e 195-023 " Review of Operator Personnel Error Corrective Action"

• 195-022 "PSL Maintenance Rule Program" e 195-021 " Review ofINPO Significant Operating Experience Report (SOER) 95-1 and Assessment of Foreign Material Exclusion Program and Practices During the 1995 PSL Unit 2 Refueling Outage" e 195-020 " Assess the Adequacy of Operator Logs and Associated Log Keeping" e 195-018 Initial Review of LER 335/95-003 (Revision 1)," Automatic Reactor Trip During Turbine Overspeed Testing due to Personnel Error" e 195-012 " Review of NUREG/CR-6144. Evaluation of Severe Accidents during Low Power and Shutdown Operations at Surrey Unit 1" e 195-010 " Review of Plant Trip due to Personnel Error During Turbine Trip Test on PSL-1" (LER 335/95-003)

II. No ITR recommendations were issued during November.

8 AUDIT REPORT ,

QSL-OPS-95-22 Page 25 of 28 Audit Particinants:

Name Denartment/ Group PMON No.

C. Wood Operations 66 R. Lamb Operations 66 D. Emling Operations 66 J. Ifauger Operations 66 A. Kimpel Operations 66 B. Nicho'.s Operations 66 S. Sumners Operations 66 B. Jorgensen Operations 66 M. MacClellan Operations 66 T. Barnes Operations 66 G. Mulcahy Operntions 66 P. Fulford OPS Support & Testing 73 C. Wood Operations 73 P. Hileman Engineering 73 M. Williford Licensing 73 R. Olsen I&C 75 L. Hiegel I&C 75 H. Buchanan Health Physics 75 H. Mercer Health Physics 75 A. Wier Health Physics 75 R. McCullers Health Physics 75 L. Large Health Physics 75 V. Munee Health Physics 75 D. Cooper Health Physics 75 W. Mead Reactor Engineering 75 J. Rogers Reactor Engineering 75 W. Parks Reactor Engineering 75 R. Kline Reactor Engineering 75 T. James JPN Doc Cont 75 W. Woodard QA 75

'~

(ID, \

o

() g AUDIT REPORT QSL-OPS-95-22 Page 26 of 28 Audit

Participants:

i Name Denartment/ Group PMON No.

J. West Operations 75 J.Scarola Plant Manager 75 C. Burton Services Manager 75 C. Geier Mechanical Maintenance 67 G. Rodgers Mechanical Maintenance 67 D.Jacobs Mechanical Maintenance 67 R. Hawley Quality Control 67 i G. Ingram Quality Control 67 l J. Kunkle Construction Services 67 O. Mabry Mechanical Maintenance 67 W . W hite Security Supervisor 74 N. Miller SBI Project Manager 74 R. Czarnecki Security Operations Supervisor 74 S. Plantz Security Training Specialist 74 1

I i

AUDIT REPORT .

QSL-OPS-95-22 Page 27 of 28 Pre-Audit Notification:

Location: St. Lucie Plant Date: November 1,1995 Post-Audit coa (crencet Location: St. Lucie Plant Date: Jan g 4,1996 Summan of Post-Audit Conference:

The results of the Performance Monitoring activities inclusive of the findings and recommendations were discussed with the attendees. Personnel in attendance agreed that the findings were valid and that Corrective Action would be initiated.

Personnel in attendance were:

J. Scarola, J. West. W. Parks. H. Mercer. L. Bladow, J. Voorhees. J. Walls, L. Bearror Location of Audit:

St. Lucie Plant 4

l.. ,

$ f AUDIT REPORT QSL-OPS-95-22 Page 28 of 28 mumaammmmmmmmmmmmer -

Accomnanvine Auditors: J. Walls, L. Bearror, C. Norris, R. J. Walcheski Princinal Audit 5r: M ~

I'!# ~[d -

J. J. Wkis' ' Date Quality Assurance-PSL ls \

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Reviewed by: 1-10 %

. . Voorhees- Date A Supervisor - PSL i

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QUALITY ASSURANCE DEPARTMENT -

CORRECTIVE ACTION STATUS f:PL ITEM IDENTIFICATION Auda Report No, fW -OPS. 9fi-22 Finding No. 3 Report Dete: 1/10/96 ORGANIZATIONANDMDUAL RESPONSIBLE FOR RESPONSE:

Response Due Date: 2/10/96 REPORTABILITY:

The Mem 6dentifed above is/is not X potentially reportable en accordance with 10 CFR 21 or as a reportable occurrence (LER).

, [ LEAD AUDITOR 9

See paragraph 5.2.2.b of Ol 16 QAD 4 for instructions if the stem is potentially reportable in accordance with any to these recuirements.

STATUS:

(include: Date of Entry; Reference Objective Evklence if Any; Intals) 1/12/96 - Issued STAR # 960132, awaiting response 2/12/96 Received responce, review of responce has found it acceptable and follow up of the corrective action implementation will be performed dunnng the next refueling outage. The correctrve action was completed on 12/6/96 I

i l

I FINAL DISPOSITION:

Cicsed and Venfed. . . 2. M d

/ ' Lead Auditor" / QMe' p Revewed and /

Approved-QA Supervisor / Manager , Date I

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ST. LUCIE ACTION REPORT #

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k& fle1f46 N Q>r W NsM N N S " M ef S [$ W N u/  !

n In Department Head S10 *- Date I I l1 N Do 1 you require approval to dose? % Yes No m REVIEW / APPROVAL i

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4. Completion: 1 2 3 4 5 is item a mode hold? 1 2 3 3/1750 4 5 Train Swep >

j Priorny U(((( [ Yes hNo U 2[] ] '

Required Commitment Date: 1 OIib Assigned Outoge:

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tt) l Event initiator Code System Code Causal Factor Code '

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ST. LUCIE ACTION REPORT

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O M PM 95-065 NOTES 10/9/95 0800 - Toured RCA for posting of rad. matl. areas, locked high rad. areas in RAB are locked as required ( the doors were checked to be lockable and the lock functions to require a key from the outside but can be opened fonn the inside by the turn of a knob. this knob cannot be reached from the outside as checked on a few of the doors), tags on bags ( tags labeled, information on tags describe information as required, tags are as required ). The areas toured today were: Unit 2-RAB 19.5 ft elevation hallway, outside the u2 fuel building, the back yard includiig around the blowdown building, u2 containment maint. hatch area, ul RAB 19.5 ft elevation hallway, ul containment personnel entrance area, ul electrical penetration rooms. All areas were considered satisfactory.

Reviewed the results of the first surveys of the containment and found the Elevation 18 ft did not provide sufficient posting information as required by the procedure. This survey was conducted on 10/9/95 at 0415.

Obtained copies of the qualification ofjunior techs for further pmon of HP.

Also toured RCA on both units for use of TLD and Merlin Observed entrance of RCA for personnel use of check in stations- All observations were satisfactory.

1330 - Reviewed the 50.59 for refueling activities to correct the FSAR minor comments were I give to C. Wasik. This must be taken care of prior to mode 6. I 1300 Attended the generic pre-job briefing and verified the inclusion of use of safety gear in ,

contaminated areas to satisfy STAR # 951051 and signed off the QA check. l 1

DATE OCTOBER 10.1995 DAY SHIFT l 0800 - REVIEWED HPP - 20 R 1 for valid requirements for posting verification. The requirements are as follows: $ 7.1-4 " Areas shall be posted and previously posted areas shall be updated by personnel performing surveys. Such postings and updating shall be noted on the survey maps and forms before the maps are approved." Went to the RAB to review the latest surveys of the containment and found additional sttrveys that did not document verification of surveys. Talked to A. Wier about the issue and reviewed the procedure with I him. He agreed with my observation and started to contact the HP techs to reinforce the requirement with them. This issue will be continually monitored.

While at the HP area 1 verified the RWP fc our use is 95-3315. A copy is posted on our outage bulletin board.

Reviewed the following RWPS for consistency with the surveys and clothing requirements: I 95-3001-CEDM ductwork, 95-3013-open/close equipment hatch,95-3018-remove / replace pzr missile shield. 95-3111 xmitter calibrations, 95-3206-insp., test.PM MOVs. 95-3301-initial surveys, postings, job coverage, All were found to be satisfactory.

It was noted that the first hot particle control survey was conducted today on the lower cavity. No work was performed needing any further surveys for hot particles.

DATE OCTOBER 11.1945 DAY SHIFT 1

s 0730 Signed off the STAR for refueling 50.59. Checked on STAR for definition of deviation, the procedure went through FRG but has not been issued yet.

Updated checklists for outage.

1300 Toured the RCA on unit 2. Attention to work areas for compliance to HP requirements, postings, rad mati storage and locked high radiation areas. The areas toured were: unit 2 Rx containment building entrance,19.5 ft hallways, areas around the diesel generator buildings (both units), -0.5ft level hallways, HPSI/LPSI/Contamment Spray pwnp areas, both units drumming rooms and spent resin tank access.

Specific items observed include: temporary work area setup, postings, HP tech present locked high rad area doors, personnel dress out, logging out of containment, frisking of personnel items prior to leaving the RCA and available instruments were calibrated and date due is not exceeded.

Also checked the respirator issue log. Respirator issue today was performed by Moore, who was verified to be on the Junior training list and documented training for respirator issue was satisfactory, DATE: Oct. 12.1995 Day Received some INPO documents today from JUNO. The package includes an index of the latest publications. These documents will be checked and more information will be given out to everyone at a later date.

Toured the RCA for personnel properly displaying their dosimetry, posting and dress out.

Areas toured were: 43ft elev. of RAB ( boric acid mixing tk, resin storage and ventilation room), unit 2 drumming room, unit 2 hallway 19.5ft, unit I drumming room, unit 2 Containment entrance and back yard. All areas were satisfactory.

Checked respirator issue no resp. were issued today.

Unit 2 containment was closed for safe guards testing.

Date: October 13.1905 Day Shift 0730 - updating checklist to include INPO criteria.

1400 - Toured the RCA u2 for dosimetry use got to the hallway just inside the RCA when an emergency occurred inside the containment, a person had to be removed due to an apparent heat problem. The gentleman was helped out of the can and pc's were removed frisking indicated that he was not contaminated and he was taken out to the medical center for monitoring. Everything appeared to go satisfactory.

Observations in the area indicated personnel were using their dosimetry properly. Frisking of personnel items was assisted by HP. Personnel monitoring was by use ofIPM8.

U2 counting room was toured and review of the instrument check out log was conducted. It was noted that the log was complete except in the following area: Two instruments were checked out on the 10th of this month and were not retumed to the check out area dailv for  ;

source check. A. wier was notified of this problem and said he would take care of this issue. I attended the HP turn over from days to peaks and this issue was discussed and one person involved was on the next shift. The instruments in question are as follows: RO2A ser.#2000 1

2 l

I

o checked out 10/10/95 by Parker and the other RO2A ser.#1794 checked out on 10/10/95. This -

item will be followed up during the outage.

10/23/95 day shift Arrived about 0645. Reviewed log and toured the control room. Refueling going slow due to overload problems. Reviewed some TCs Specifically the one involving Multi-badging (2 405). Copied the TC and reviewed the FSAR to cc,nfirm the TC's 50.59 screening results. The review determined the TC to be satisfactory. Mini ARG at 1000.

Some time after lunch it was determined by operations that refueling would not progress without some review of the problem of overload occurring and holding up progress. Attended.

the meeting and the bottom line was they would write a PWO to take data using a calibraMd gauge to weigh the refueling grapple tool then pick up the TEST weight and take a ,

measurement. Then take the difference to determine the weight of the TEST weight and verify that the data in the procedure is accurate. It seems that we may be using dry weights in a wet atmosphere and the wet weight is .87 of the dry weight.

October 29.1995 Day Shift Arrived 0700. Checked in with Outage Management to fmd out the status. The Refueling Cavity is being drained. It seems that the plug handling tool for the hot leg plug was a problem and caused quite a delay.

The 62 ft elev. of containment is closed off for the time the cavity is drained. Not much else la going on in the CAN.

Toured the RCA to observe the work. Reviewed surveys and checked'on postings. Observed personnel wearing their dosimeters properly.'Instrtunentation available at the containment '

entry point and the HP station in the -5 ft level of the RAB were calibrated and the due date had not expired. I noted HP personnel in all areas of the RCA involved in the work activities.

The areas toured include: 19 8 and .5 ft elevation of the Unit 2 RAB, the entire "back yard" area including around the blowdown bid.,both drumming rooms. CCW, and diesel /RWT areas.

I identitied a problem with a survey performed on 10/28/95 of the_ Rx head setting on its ,

mount. The survey indicated an area of 120k dpm/100cm sq. HPP-20 R 1 " Area Radiation l and Contamination Surveys Pva. 7.6-2-b requires " Any area containing removable j contamination in excess of 1:a,000 dpm/100 cm sq. should be posted as Highly Contaminated l Area". This was not indicated on the survey sheet as required by para.7.1-4 " Areas shall be posted and previous posted areas shall be updated by personnel performing surveys." This was brought to the attention of A. Wier.

Also attended a meeting that provided a walk through of the work to be performed by BWNT to replace instrument nozzles and thermo wells. This included video tapes of their equipment being used on their mock up. HP introduced their day shift personnel that will be assigned to BWNT for the job. The meeting seemed to be helpful especially for HP to provided a good pre-job briefing and coverage of the job.

I 3

9 Verified that R.M. King who issued respirators this date was qualified to issue respirators using the list provided by J. Leifhelm.

10/30/95 Day Obtained copies of HPP-20 Area Radiation and Contamination Surveys and 0005737 HP Dept Training to continue with the verification of the survey and posting program Toured the RCA area on unit 2. Reviewed thee previous nights surveys in the CAN. There is still some question as to weather the surveys are verifying every posting or not. The next thing is to take the latest and walk down the entire CAN. Reviewed the respirator issue log, no respirators were issued this day. Reviewed the instrument issue log and found 10 instruments not logged back into the inst. issue in over 24 hrs. The oldest was 10/28/95. HPP-20 requires "i5.3 Prior to use survey inst. shall:... valid cal sticker...batt. check... Pass a daily resnonse source check... logged out on the inst. issue log" This is the second time I noticed this and both times an HP sup was notified. This time V. Munnee.( the other time was A.

Wier 10/13/95).

Discussed the problem of surveys and logging of instruments with J. Leifhelm. He indicated that the contractor HPs received training on HPP-20. He quoted parts of the training module and they were word for word from the. procedure.

Reviewed the FSAR for HP requirements and found some areas that require changing. They include references to MPC hrs and limits for using types of respirators. Also the fact that we have a common access to the RCA has changed. So I took a copy of each unit FSAR to HFB with a copy of the FSAR change form. I don't think these problems are major but should be looked at. Til check on them after the outage.

1300 Toured the CAN using the latest survey of 43 ft,18 & 23 ft. Found the 43 ft level to be  ;

as logged in the survey. The 18 & 23 ft levels had the boundaries as indicated on the survey but also there were high rad areas around the loops as they penetrate through the primary 1 shield wall with flashing lights. These were not verified on the survey. The areas of the safety injection trench appeared satisfactory except that the stairwell at the center of the bio shield wall was full of lead blankets with no posting. These items were discussed with A. Wier. He said that he would look into this and talk to me tomorrow after 0900.

Also as we left the 43ft to the 23ft at the maint hatch we were told to leave the area as a 70 R item was going to transit the area. There were no postmg or warning until we were in the area. On request we were told a filter was being moved out of the CAN. We continued the i

tour in other areas. Talked to A. Wier about this issue and he indicated that there was no prescribed method to conduct this a;:tivity but it should be conducted to minimize exposure. I consulted HPP-41R1 " Movement of Material and Equipment" and found that he was right.

In general movement in the CAN is difficult / congested. All major work is around the loops with no room. and this is the highest area of radioactivity. If,you are covering a job be careful and stay in low dose areas if possible.

4

Nov.1.1995 Day After review of yesterdays work it occurred that the posting in the containment 43ft level may not be proper in that the levels on the 62ft may require flashing lights in addition to the posting and the plug is removed for one of the RCPs giving another opening to the 62ft elev.

I'll check with A. Wier today.

0900 Met with Allen Wier to review the status of inst. issue and log maintenance. It appears that the log is not being completed when the insts are used. The log for the next day indicates issue of the same raeter with the proper checks so the problem is not checking the inst back in at the close of shift. In the case of the teletector the instruments are checked in the blowdown bldg and issued to the " field" this method is not in accordance with the procedure either. Allen agreed with the fact that this is a procedure problem but wanted to make sure that it was not considered a technical issue.

Obtained copies of the 18/23ft and 45ft elevation surveys to verify.that the surveys are being done with posting verification. The surveys were conducted at 0221 on 11/1/95 and contained postings that were observed yesterday when I toured the area.

Discussed the other posting concerns with A. Weir, which were the RCP plug area and should there be flashing lights at the stairs going to the 62ft. He is going to look at these areas and get back with me.

1300 Obtained copies of the surveys for .5ft RAB - Shutdown Hx, Pipe Tunnel, HPSI and Containment Spray Pumps, and LPSI Pumps. Reviewed the surveys for completion including instrument data, posting verification and survey results. Toured the areas to verify the posting requirements. The following discrepancies were discussed with Allen Wier: postings-for Rad.

area were not iqdicated on the survey for HPSI/ Cont. Spray Pump Room entry doors - general area fields are /5mr, Contaminated area /RWP required posting not indicated on survey form l for stair way to 2DHPSI/ Cont. Spray Pumps, Reactor Drain Pump area also not indicated as posted. 2B LPSI Pump Room survey did not indicate the postings found during tour- a roped J off area with stepoff pad was found with Contaminated Area and RWP required for entry, and 1 LPSI hallway required to be posted Rad. Area was posted on the door but the door was open not allowing the posting to be seen the HP stationed there was told and the posting was hung over the door. These items were discussed with A. Wier at the end of the day. He indicated that they would be addressed at the shift turn over. i 1

Obtained copies of the personnel contaminations at the Pzr. on 10/29/95 and will follow up on this activity.Left 1600.

November 2.1005 Day Shift Reviewed the contamination reports for 4 individuals working at the pzr. Talked to Barb  ;

Johnson about these reports and asked to see any additional docuraents. She indicated that the tiles for these would be complete by monday, and give her a call.

1300 Toured the RCA on both units. Reviewed the surveys for Unit 1 RAB. F surveys to be adequate except for l A LPSI. The survey 5mr indicated rad throughout field of the room and is not posted Radiation Area. It was indicated by A. Weir that the posting was on the door to the hallway. This is not acceptable because as the procedure HPP-20 says $7.1-5

. _ ,. .. . ~ _ . .- --. -

^

- 28"Enough survey points should be included to verify the way the room is' posted.", the i i hallway is not the boundary and the door must be posted. This will be another example of procedure compliance. ,

11/7/95 DAY SHIFT Toured the HP area of unit 2. Reviewed the surveys for 18'& 23 ft elevation of the CAN.

Still have problems with verifying the postings in the area of the survey, Checked the instrument check out log and found 4 inst. not logged on return.

l 11/20/95 Day Toured the containment 1000-1100. Noted such things as red flashing lights still functioning, lip stations still maned, postings in place and barriers in place. There was not much work ,

being performed, anywhere. Personnel in containment were observed in proper dress.

Obtained additional document review of the results of the dose assignment of 4 workers at the ,

' PZR. I need to review the entire file for each to verify dose assessment. maybe at end of outage. .

'i d

[

1 4

6 i

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET sheet i ar J

SUBJECT:

HEALTH Pli1 SICS - RWP COMP _LIA_NCE 4 AUDIT NO QSL-QP_S- ~ AUDIT DATE: .,QCIQREfL11ts - w

, REFERENCE CRITERIA: 10 CFR 20. HPP-1 R2_ELW=Han Work Permits M e

ITEM f EVAWATON COWNAENTS .

d

1. Verify that persons working under an RWP are: 15.10 l

1. Following the instructions contained on the RWP. 10/9/95 Toured RCA on both units for . use'of TLD and ,

l Merlin Observed entrance of RCA for personnel use of check in stations- AM observations were satisfactory.

2. Not knowingly vloiating the cor:ditions or Attended the generic pre-job briefing and verified the ,

instructions. inclusion of use of safety gear in contaminated areas to satisfy STAR S 951051 and signed off the QA check.

Reviewed the following RWPS for consistency with the ,

3. Attends required pre. job briefing prior to the surveys and clothing requirements: 95-3001.CEDM ductwork, start of work. 95-3013-openiclose equipment hatch,95-3018-removeireplace ,

pzr missile shield, 95-3111 xmitter calibrations, 95-3206-insp., test,PM MOVs, 95-3301-initial surveys, postings, Job

4. Not modifying the conditions or job description coverage, All were found to be satisfactory. ,

without the approval of job supervisor and HP and

( 'h / SW I NPS. f

. 1

5. Proper use of P.C.s and resp. equipment. 17.1-4

6. Notify HP of any spill or change in radiological  ;

conditions. i l

l DATE: i I APPROVED BY:

y' - - - - _ - -

~

/ . .

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

FPL QUALITY ASSUF%NCE DEPARTMENT AUDIT CHECK SHEET AUDIT NO._QSL-QPS- - s M L_or ,

ITEM g EVALUATION COMMENTS

2. a. Work Procedures INPO 91-014 10/9/95 Attended the generic pre-job briefing and verified (1) Planning Dec 1991 the inclusion of use of safety gear in contaminated areas to

. Planning the radiological aspects of work should satisfy STAR # 951051 and signed off the QA check.

be integrated into the stations work planning Reviewed the following RWPS for consistency with the i process and should be the responsibility of job- surveys and clothing requirements: 95-3001-CEDM ductwork, planning personnelin conjunction with radiological 95-3013-openiciose equipment hatch,95-3018-remove / replace protection personnel pzr missile shield, 95-3111 xmitter calibrations, 95-3206-'!

insp., test,PM MOVs, 95-3301-initial surveys, postings, job During outages, the radiological protection coverage, All were found to be satisfactory. t department should be involved actively with the 10/29195 Attended a meeting that provided a walk through conduct of the outage to be able to anticipate the of the work to be performed by BWNT to replace instrument i need and plan radiation protection activities nozzles and thermo wells. This included Video tapes of their !

minimizing their impact on outage tasks. equipment being used on their mock up. HP introduced their [

day shift personnel that will be assigned to BWNT for the t '

job. The meeting seemed to be helpful especially for HP to provided a good pre-job briefing and coverage of the job.

11/20T5 Day Toured the containment 1000-1100. Noted such '

things as red flashing lights still functioning, HP stations ;

still maned, postings in place and barriers in place. There was not much work being performed, anywhere. Personnel in containment were observed in proper dress.

I

3. b. Radiation Work Permits (RWP)

(1) General RWPs SEE ABOVE AND NOTES General RWPs, or an equivalent administrative control, should be u:ed to govern routine work such as plant inspections, operator rounds, or -

radiologica! protection technician surveys within the RCA. Radiological conditions for the areas l covered by general RWPs should be static or the RWP should address situations that could cause conditions to change. The type of work allowed ,

i under general RWPs should be outlined clearly for all radiation workers. Routine surveys performed in  ;

areas covered by general RWPs should be reviewed for evidence of conditions that have significantly ,

t changed, and the general RWP should be revised o .py, ov ...m. .

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET AUDIT NO.__QSL-OPS. .

sw _

E e

REFERENCE ITEM EVALUATON CORBRIENTS DETAlt. CRfTERIA l

~~

4. (2) Specific RWPs SEE ABOVE AND NOTES Specific RWPs should be used to control work in the RCA not covered by general RWPs. Specific RWPs should remain in effect only for the time needed to consplete the job. Surveys should be pecormed when radiological conditions are subject to change during the work and the RWP should be revised, as appropriate.

O m.___._ __m___ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ 1 _ - _ _ _

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET sheetJ._ot"2

SUBJECT:

HEALTH PHYSICS - PER$DNNEL. ENTRY INIOJHE_BCa._s AUDIT NO._QSL-QP_S _

bb AUDIT DATE: OCTOBERJ C i REFERENCE CRITERIA: 'HPP - 30 REV. 4. PERSONNELDONEORING Odib b *

~

REFERENCE' ITERA DETAILED CRITERIA EVALUATION CORMWENTS - ,

1. VERIFY THAT EACH PERSON WHO ENTERS THE 1 7.2-2 10/9/95 0800 Toured RCA on both units for use of TLD and RCA IS WEARING A TLD AND MERLIN. Merhn Observed entrance of RCA for personnel use of check -

in stations- All observations were satisfactory.

10/10/95 Observed entry of personnel into unit 2 RAB, and ,

proper use of merfin entry station. All personnel observed  !

were wearing the dosimetry properly.

10/12/95 Toured the RCA for personnel property displaying l their dosimetry, posting and dress out. Areas toured were:

43ft elev. of RAB ( boric acid mixing tk, resin storage and  !

ventilation room), unit 2 drumming room, unit 2 hallway l 19.5ft, unit 1 drumming room, unit 2 Containment entrance f and back yard. All areas were satisfactory.

19113/95 1400 - Toured the RCA u2 for dosimetry use got to .

the hallway just inside the RCA when an emergency I occurred inside the containment, a person had to be removed due to an apparent heat problem. The gentleman i was helped out of the can and pc's were removed frisking  :

Indicated that he was not contaminated and he was taken out to the medical center for monitoring. Everything i appeared to go satisfactory.  !

Observations in the area indicated personnel were using -

their dosimetry properly. Frisk *ng of personnel items was  !

assisted by HP. Personnel frisking was by use of IPM8. -

10/29/95 Toured the RCA to observe the work. Reviewed I

surveys and checked on postings. Observed personnel j wearing their dosimeters properly.

l I

i ,

O i

APPROVED RY: DATE:

f f

_____m. _ ,-.-. - -_ .__.

- .m m.. m - . - .- . - - - . _ . ~ . . _ _ _ - . - _ . - - _ . . -- _._._...-_..--.~..---.-.,-..,.-,-,-m _m. . . . , . . - ~ . _ . . - - - _ .m _ _ _ _ _ _ - . ,

FPL QUALITY ASSURANCE DEPARTMENT AUD7 CHECK SHEET sheet 2_of_2_

AUDIT NO._QSL-QPS- -

REFERENCE COMMENTS ITEM EVALUATION DETAIL CRITERfA

2. Verify that TLDs and Merlins are woin as described 17.2 4 in this procedure. The TLD is to be close to the Merlin and must be worn in the front of the body between the shoulders and the waste.

3. 2.a.(1)Whole body exposure INPO 91-014 l

Chap. lil l

l Each worker entering a radiologically controlled C. Guidelines

! area should be provided witti a primary dosimeter (TLD) capable of measuring the worker's whole body exposure.

l l

I .

- - _ -.. ~ ~ , , , , . - - ,

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET slJt_i_o M

SUBJECT:

_ Health Ehysics_use CLJuf1lor_Itchnicians_2_ AUDIT NO QSL-OPS- .b '[ b AUDIT DATE: October _1995 REFERENCE CRITERIA:___AERQQ5737 RgL_10 HP_RenLTraininna.Ernstam AVdX/ 9 [ d [

REFERENCE ITEM DETAILED CRITERIA EVALUATION COMMENTS

1. Verify that contractor technicians that do not meet 8.84-A Obtained a listing of junior techs and the training they the qualification criteria of ANSIIANS 3.1-1978 may recieved. This listing includes training as of 1016195 for be trained on specific tasks and limited to PSESI Junior Techs 13 of 14 personnel had training in performing only those tasks. respirator issue. This listing and any orther listings published by training will be used to verify the issued by names in the log.

10/11/95 Checked the respirator issue log. Respirator issue today was performed by Moore, who was verified to be on

2. Verify that tasks for which training has been given 8.84-B the Junior training list and documented training for shall be documented by examination or by ,

respirator issue was satisfactory.

completion of a verification of satisfactory 10/29/95 Verified that R.M. King who issued resplorators this completion form and maintained in the trainiing date was qualified to issue respirators using the lis*

files. provided by J. Leifheim.

APPROVED BY: AMF DATE: N, ,

y -

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET sheetroggl

SUBJECT:

. _ Heat,TH EHYSICS-IBANS!ENLHIGH BADiaTION AREAS _1 AUDIT NO._QSicQES- N AUDIT DATE: _ OCTOBER _1995 __

REFERENCE CRITERIA: 10 CEB 20 1NBCJnspectiort Manuallnspection Procedure 83822 A REFERENCE ,

ITEM DETAILED CRITERIA EVALUATION COMMENTS  !

1. 03.05 Posting, Labeling, and Control See Above 10/9/95 0800 Toured RCA for posting of rad. matt. areas, locked high rad. areas in RAB are locked as required ( the

a. Posting and Labeling. Inspect representative doors were checked to be lockable and the lock functions to areas to verify compliance; pay particular attention require a key from the outside but can be opened form the to" temporary" work areas that may be required for inside by the tum of a knob. this knob cannot be reached maintenance activity, newly established work areas, etc. Inspect a random sampling of containers in

[ 'from the outside as checked on a few of the doors), tags on bags ( tags labeled, information on tags describe information work or storage areas. as required, tags are as required ). The areas toured today -

were: Unit 2-RAB 19.5 ft. elevation halfway, outside the u2

b. Control fuel building, the back yard including around the blowdown r building, u2 containment maint. hatch area, u1 RAB 19.5 ft

1. Randomly select high radiation or very high elevation hallway, u1 containment personnel entrance area, radiation areas to verify that access is controlled in u1 electrical penetration rooms. All areas were considered accordance with regulations or license satisfactory.

requirements. Reviewed the results of the first surveys of the containment t p and found the Elevation 18 ft did not provide sufficient 1

2. Inspect areas where radioactive material is '

posting information as required by the procedure. This located or stored in an unrestricted area. survey was conducted on 10/9/95 at 0415.

jf 10/10/95 0800- A review of HPP-20 R117.1-4 " Areas shall

3. Review a random selection of radiation work f be posted and previously posted areas shall be' updated by .

! permits (RWPs) on file and those currently in personnel performing surveys. Such postings and updating effect. shall be noted on the survey maps and forms before the h maps are approved." Follow up of this activity will be

4. Review a random selection of records and conducted ( continued next page )

inspect work areas to determine compliance with controls.

APPROVED BY: / DATE: N [

V' '/' . .

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET y AUDIT NO._QSL-QES- -

S W 2__of 3

ITEM DETA L CR TERIA CMMS 1

2. An area should be ' posted ,and controlled as INPO-91-014 7 1130 followup review of recent surveys indicate posting' required by regulation. For transitory high radiation chapterill verification is still inconsistent. Review of recent surveys areas, such as moving a large source through the section C with A.Wier and review of HPP-20 indicates that this review I

RCA, the area need not be posted, but positive Guidelines of postings is not in compliance with the procedure and that control should exist using means such as a 3. Identification the_pmseduNuht. CEIL 20, A.

radiological protection technician in attendance. and Control of Wier is notifying HP techs to comply with the procedure.

Hot spots should be identified. Low dose rate areas Radiation This item will be followed during the outage.  ;

should be posted to identify areas where workers Sources  ;

can wait during short job delays. b. Postings and Reviewed the following RWPS for consistency with the l Use of Survey surveys and clothing requirements: 95.NMH-CEDM ductwork, ,

information 95-3013-openiciose equipment hatch, 95-3018- '

removelreplace pzr missile shield, 95-3111 xmitter calibrations, 95-3206-insp., test, PM MOVs, 95-3301-initial .

surveys, postings, job coverage, All were found to be  !

satisfactory. ,

it was noted that the first hot particle control survey was j conducted today on the lower cavity. No work was  :

performed needing any further surveys for hot particle. l 10/11/951300 Toured the RCA on unit 2. Attention to work >

areas for compliance to HP requirements, postings, rad mati storage and locked high radiation areas. The areas toured i were: unit 2 Rx containment building entrance,19.5 ft

~

i hallways, areas around the diesel generator buildings (both

. units), -0.5ft level hallways, HPSIILPSI/ Containment Spray pump areas, both units drumming rooms and spent resin  !

tank access.

I Specific items observed include: temporary work area setup, postings, HP tech present, locked high rad area doors,  :

personnel' dress out, logging out of containment, frisking of personnel items prior to leaving the RCA and available instruments were calibrated and date due is not exceeded.  !

10/12/95 Toured the RCA for personnel properly displaying their dosimetry, posting and dress out. Areas toured were:

43ft elev. of RAB ( boric acid mixing tk, resin storage and <

ventilation room), unit 2 drumming room, unit 2 hallway 19.5ft, unit 1 drumming room, unit 2 Containment entrance t 5W5%5 57EbFL JSE U. F%55 53 w== ---W DSE"C : Z'.' tUI J .

-. FPL QUALITY ASSURANCE DEPARTCENT AUDIT CHECK SHEET Sheet J_of AUDIT NO._ ORDES- - d. .

liEM "

DETA L CR TERIA 10/13/95 1400 - Toured the RCA u2 for dosimetry use got' to the halway just inside the RCA when an emergency occured inside the containment, a person had to be removed due to an apparent heat problem. The gentleman was helped out of the can and pc's were removedfrisking indicated that he was not contaminated and he was'taken out to the medical center for monitoring. Everything appeared to go satisfactory.

Observations in the area indicated personnel were using .

their dosimetry properly. Frisking of personnel items was assisted by HP. Personnel monitoring was by use of IPM8.

U2 counting room was toured and review of the instrument ,

' check out log was conducted. It was noted that the log was complete except in the fo4owing area:

l Two instruments were checked out on the 10th of this month '

and were not returned to the check out area daily for source check. A. wier was notified of this problem and said he "

t would take care of this issue. I attended the HP turn over from days to peaks and this issue was discussec8 A'd one <

person was on the next shift. The instruments I goestion are as follows: RO2A ser.#2000 checked out & JISS by i Parker and the other RO2A ser.#1794 checked out 'on 10/10/95. This item will be followed up during the outage.

10I29195 The 62 ft elev. of containment is closed off for the

( time the cavity is drained. Not much else is going on in the  ;

CAN.

Toured the RCA to observe the work. Reviewed surveys and i checked on postings. Observed personnel wearing their ,

dosimeters properly. Instrumentation available at the containment entry point and the HP station in the -5 ft level of the RAB were calibrated and ttie due date had not expired. I noted HP personnel in all areas of the RCA involved in the work activities.  !

. . _ _ - - , - - _ ., .- 4 --. . ~. . _ _ . .-_.m , . _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _

- FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET AUDIT NO._QSL-OES- )_'2,h sht3_otg)-

ITEM EVALUATION COSARSENTS .

DETA L CR ERIA The areas toured include: 19 ft and .5 ft elevation of the Unif 2 RAB, the entire "back yard" area including around the '

blowdown bid., CCW, and diesel /RWT areas.

. I identified a problem with a survey performed on 10/28f95 4

of the Rx head setting on its mount. The survey indicated an i area of 120k dpm/100cm sq. HPP-20 R 1 " Area Radiation and Contamination Surveys Para. 7.6-2-b requires " Any area containing removable contamination in excess of 100,000 dpm/100 cm sq. should be posted as Highly Contaminated Area". This was not indicated on the survey sheet as required by para.7.14 " Areas shall be posted and previous -

posted areas shall be updated by personnel performing -

surveys." This was brought to the attention of A. Wier.

I 10131195 0730 Toured the RCA area on unit 2. Reviewed thee previous nights surveys in the CAN. There is still some question as to weather the surveys are verifying every posting or not. The next thing is to take the latest and walk down the entire CAN. Reviewed the respirator issue log, no respirators were issued this day. Reviewed the instrument issue log and found 10 instruments not logged back into the inst. issue in over 24 hrs. The oldest was 10/28195. HPP-20 requires "15.3 Prior to use survey inst. shall:... valid cat sticker...batt. check Pass a das]y__ttSponse__E9HtEt chtsk. logged out on the inst. Issue log" This is the second .

time I noticed this and both times an HP sup was notified.

This time V. Munnee.( the other time was A. Wier 10I13195) i 1300 Toured the CAN using the latest survey of 43 ft,18 &

23 ft. Found the 43 ft level to be as logged in the survey. The 18 & 23 ft levels had the boundaries as indicated on the survey but also there were high rad areas around the loops as they penetrate through the primary shield wall with ,

flashing lights. These were not verified on the survey. The v - u. . ,..y L ,-- A-. u ..n.;. =; ;- =.

^

.. . ..e -_iv.y l

E _ _ _ __ _ __ _ _ _ _ _ __ _ _ _ _ _. _ _ _ - __. _ _ _ _- __ _ _ _ _ . . _ _ __ _ _

_. 4 - . . __ _ _ . . _ __ .

FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET '7 gg. sheet _5_or AUDIT NO._QSL.0%wf h ITEM

^ "

DETA L CR TERIA ,

except that the stairweN at the center of the bio shield wall ,

was full of lead blankets with no posting. These items were discussed with A. Wier. He said that he would look into this and talk to me tomorrow after 0900. Also as we left the 43ft to the 23ft at the maint hatch we were told to leave the area as a 70 R item was going to transit the area. There were no '

posting or warning until we were in the area. On request we were told a filter was being moved out of the CAN. We continued the tour in other areas. Talked to A. Wier about this issue and he indicated that there was no prescribed method to conduct this activity but it should be conducted to minimize exposure. I consulted HPP-41R1 " Movement of Material and Equipment" and found that he was right.

In general movement in the CAN is dificult/ congested. All major work is around the loops with no room, and this is the highest area of activity.

l 1111/95 After review of yesterdays work it occured that the l

I posting in the containment 43ft level may not be proper in '

that the levels on the 62ft may require flashing lights in addition to the posting and the plug is removed for one of the RCPs giving another opening to the 62ft elev. l*ll check with A. Wier today.

0900 Met with Allen Wier to revien the status of inst. Issue '

and log maintainance. It appears that the log is not being completed when the insts are used. The log for the next day ,

indicates issue of the same meter with the proper checks so the problem is not checking the inst back in at the close of '

shift. In the case of the teletector the instruments are checked in the blowdcwn bidg and issued to the " field" this method is not in accordance with the procedure either. Allen agreed with the fact that this is a procedure problem but "

wanted to make sure that it was not considered a technical issue.

Obtained copies of the 18123ft and 45ft elevation surveys to verify that the surveys are being done with posting '

verification. The surveys were conducted at 0221 on 1111/95 and contained postings that were observed yesterday when i ivoim; ii- .....

- . . . . - - _ - . _ - - _ - . . _ _ - . . . _ _ _ . _ _ _ _ _ _ _ _ . _ - - . _ - - - _ _ . _ - _ - _ _ _ - _ _ . - . _ _ _ _ _ _ - -- - , + - -- . .

e -.

' FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET Sheet . O_ct[ .

, AUDIT NO._QSL-OP_E 4

REFERENCE 1 TEM EVALUATION COMMENTS DETAIL CRITERIA ,

Discussed the other posting concerns with A. Weir, which' ,

were the RCP plug area and should there be flashing lights at the stairs going to the $2ft. He is going to look at these areas and get back with me.

1300 Obtained copies of the surveys for .5ft RAB -

Shutdown Hx, Pipe Tunnel, HPSI and Containment Spray Pumps, and LPSI Pumps. Reviewed the surveys for '

' comple'. son including instrument data, posting verification and survey results. Toured the areas to verify the posting requirements. The following discrepancies were discussed with Allen Wier: postings for Rad. area were not indicated on the survey for HPSIICont. Qpray Pump Room entry doors -

general area fields are 15mr, Contaminated arealRWP required posting not indicated on survey form for stair way to 2BHPSI/ Cont. Spray Pumps, Reactor Drain Pump area

' also not indicated as posted,2B LPSI Pump Room survey did not indicate the postings found during tour- a roped off area with stepoff pad was found with Contaminated Area and RWP required for entry, and LPSI hallway required to be posted Rad. Area was posted on the door but the door was open not allowing the posting to be seen the HP stationed

, there was told and the posting was hung over the door.

These items were discussed with A. Wier at the end of the day. He indicated that they would be addressed at the shift turn over.

Obtained copies of the personnel contaminations at the Ptr.

on 10129/95 and will follow up on this activity.

1112/95 Reviewed the contamination reports for 4 individuals working at the pzr. Talked to Barb Johnson about these reports and asked to see any additional documents. She indicated that the files for these would be complete by monday, and give her a call.

1300 Toured the RCA on both units. Fs tviewed the surveys for Unit 1 RAB. Found the surveys to be adquate except for 1 A LPSI. The survey indicated rad field of /5mr throughout .

the room and is not posted Radiation Area. It was indicated by A. Weir that the posting was on the door to the hallway.

This is not acceptable because as the procedure HPP-20

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FPL QUALITY ASSURANCE DEPARTMENT AUDIT CHECK SHEET l

AUDIT NO._QSL OPS- b -

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REFERENCE i

. liEM EVALUATION COGIERENTS l= DETAIL CRITERIA

! rwify the way the room is posted.", the hat'way is not tho' boundary and the door must be posted. This will be another example of procedure compliance.  ;

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