ML20149G513

Insp Repts 50-348/88-02 & 50-364/88-02 on 880104-06. Violations Noted.Major Areas Inspected:Review of Circumstances Surrounding Unauthorized Entry of Licensee Personnel Into High Radiation Area

ML20149G513
Person / Time
Site:	Farley
Issue date:	02/08/1988
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149G470	List: ML20149G466 ML20149G513
References
50-348-88-02, 50-348-88-2, 50-364-88-02, 50-364-88-2, NUDOCS 8802180287
Download: ML20149G513 (8)

See also: IR 05000348/1988002

Text

a

o UNITED ST ATES

g"# " E c ,c, WUCLE AR REGULATORY COMMISslOM

-*' W a ', CEGION ll

I $ . .$ ' ' 0

101 M ARIETT A $T RE ET N W.

L I""p A7L ANT A. GEORGI A 30323

1 _e

.....

Report hos.: 50-348/88-02, 50-364/88-02

Licensee: Alabama Power Company

600 North 18th Street

Birmingham, AL 35291

Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8

Facility: Farley 1 and 2

Inspectien Conducted: January 4-6, 1988

Irspector: _ '. ' . h L r.. m .

T. R. Collins

L[J /)]

Date Signed

,

Acccrpar'ying Persennel: R. B. Shortridge

Arcreved by: # " ~.'^ 2/ ' 'M

t

C. M. hosey, Section Chief Date Signed

Divisien of Radiation Safety and St.feguards

SUMMARY

$cepe: This was a special, announced inspection to review the ciret.mstances

su rroundi r.t the unauthorized entry of licensee personnel into a h'gh radiation

area.

1

Results: Four violations were identified: (1) failure to adecuately cJntrol

access to a high radiation area, (2) failure to follow procedures (3) failure

to perform an adequate survey, and (4) failure to adequately instruct

individuals working in or frequenting a restricted area.

'

8802180287 880208

FDR ADOCK 05000348

0 DCD

s ~ .-

.

3 "

,

,,  ;. . 1

,

-

4 .-

l

3 *

.

'

N

-

.

,,8 A ./

.. ,

,

REPORT DETAILS

.

'. N A s

? 1,. Pessons Contacted e .

s

Licensee Empfb' vees -

. ,

s ,

• P. Farnsworth; Radwaste. Supervisor

.' ** 0,' Graves, Health Physics 5'upervisor

s ' $ Maddox, Training Supt / visor .

• g)!Kchell, Health Physics and Radwaste s Superiisor

• D. Morey, Assistant General Manager, Operations

>C. Wesbitt, Technical Superintendent

,?J.s06terholtz, Supervisor, 5'afety Audit Er ineering Review

"s *B. Patton, Plant Health Physicist.

• J. Walden, Lead Auditoy > '

.

• L. Ward, Maintenance Manager s

'

a

• L. Williams, Training Kinager s ,

, , *J. Woodard, General,yanager

NRC Resident inspectors

'

• W. Bradford' ' N

• N tjiller

'

',

~'

• Attended exit interview -

2. Exit Interview (30703)

The inspection scope and findings were summarized on January 6, 1988, with

'

those persons indicated- in Paragraph 1 above. Four violations were

' discussed in detail:, (1) failure to adequately control. access to a high

radiation area, (2) failure of personnel to follow RWP requirements to

. wear high range dosimeters in a high radiation / exclusion area, (3) failure

to' perform a radiation survey to determine the extent of radiation hazards

in th'e. high' radiation / exclusion area, and (4) failure to adequately

instruct individuals of the limitations and precautions for working in or

frequenting a restricted area. The licensee acknowledged the inspector

findings. However, the Plant Manager took exception to all findings. The

Plant Manager also stated the individual carelessly entered the exclusion

area to perform work and failed to comply with licensee controls which

placed the responsibility for the action on the individual and not the

licensee. The licensee did not identify as proprietary any of the

material provided to or reviewed by the inspector during this inspection.

3. Onsite Followup of the Unauthorized Entry to an Exclusion Area (93702)

a. Description of Events

On December 28, 1987, a licensee contractor was providing

decontamination support following the fifth refueling outage. The

. - . .. .

_

- . _ . ._ _ ._ _

. .- - - .- . - .

.

.

. 2

Radwaste Supervisor had provided a work list of rooms requiring

decontamination by the contract decon personnel to the Waste and

Decon Foreman. Of the ten rooms on the list, three rooms were known

by the licensee to be high radiation areas. However, these three

rooms were not identified on the list as high radiation areas. The

areas on the list were not identified as requiring special radiation

work permits (RWPs) or radiological controls and precautions.

The Waste and Decon Foreman gave the list of rooms requiring

decontamination to a contract decontamination foreman and issued him

a set of keys that would unlock doors to these areas. A health

physics (HP) technician was assigned to support the contract

decontamination foreman and his crew during the scheduled

decontamination activities.

One of the rooms on the list which contained high radiation areas was

Pccm 450 in the Unit 1 Auxiliary Building. Room 450 provided the

only access to Room 449, where the Spent Fuel Pool Demineralizer

(SFPD) was located. Room 449 and part of Room 450 were exclusion

areas, defined by the licensee as areas having radiation fields

greater than 1 Rem per hour (R/hr). The total exclusion area

composed of Room 449 and part of Poem 450 was barricaded by three

yellow and magenta ropes and a flashing red light located at the

exclusion area boundary in Rorm 450. Radiation fields in Room 449

ranged from 5 R/hr to 240 R/hr, with general area radiation fields of

approximately 30 R/hr. Radiation fields frem the exclusion area

boundary in Room 450 to the opening of Room 449 ranged from 0.16 to

5 R/hr.

The contract decontamination foreman unlocked the door to Room 450

and left the room unattended. Moments later, the HP technician

entered the room and noted the exclusion area while performing

surveys. The technician left the room unlocked and unattended.

Subsequently, contract decontamination personnel entered the room to

perform decontamination activities. One worker crossed the exclusion

area boundary and entered Room 449 and one worker stayed in the high

radiation area or the front part of Room 450. The laborer who

entered the exclusion area, Room 449, worked in an area approximately

five feet from the SFP demineralizer. Af ter approximately five

minutes, the laborer observed his low range dosimeter was offscale

and immediately exited the room and reported to a HP technician. I

b. Licensee Corrective Actions

Licensee temporary corrective actions were as follows: (1) processed 4

the individual's TLD and assessed his exposure during the incident as )

455 millirems; (2) the licensee verified that the individual who '

remained in the front part of Room 450 did not receive any )

significant exposure to radiation; (3) the workers were interviewed

by licensee management and statements concerning the event were

obtained from the two individuals who entered the room and the

l

,

- -

.

. 3

involved HP technician; (4) a closed circuit TV camera was installed

to preclude the need for operations personnel to enter Room 450 on a

routine basis; (5) the door to Room 450/449 in Unit 1 and

Room 450/449 in Unit 2 were locked and established as exclusion

areas; (6) Operations hold tags were placed on doors of exclusion

areas so that entry would require a written clearance (approval) to

remove the hold tags and approval by HP supervision and the shift

foreman on duty.

Licensee permanent corrective actions will be as follows: (1) The

contract decontamination foreman and the individuals entering the

exclusion area and high radiation area would be retrained and

counseled by their company's supervision; (2) wherever possible,

exclusion area boundaries will be expanded such that access can be

controlled by a locked door; (3) keys to exclusion area doors will be

removed from all key rings except those of Shift Supervisors (for the

purpose of Control Room evacuation); (4) the system for the issuance

of exclusion area keys will be segregated from that for issuance of

other high radiation area keys; (5) new locks will be installed on

exclusion area doors such that each door will have a specific key;

and (6) consideration will be given to increased health physics

coverage for contractor crews.

c. Inspection Results

The inspectors discussed this event with licensee representatives and

interviewed personnel who had been associated with the event. The

inspectors also reviewed records assembled by the licensee as part of

their investigation.

The inspectors reviewed a special survey of the spent fuel pool

demineralizer Room 450/449 performed after the event to determine if

the laborer was in a non-uniform radiation field and if multiple

dosimetry was required. The contact radiation levels on the SFPD

tank were 5 R/hr at the bottcm, 240 R/hr at the head level and

approximately 150 R/hr at 18" from the surface of the tank. This

survey was conducted on the side of the SFPD where the individual was

working. The inspectors concluded that the worker was in a

relatively uniform field of radiation and that the dosimetry provided

was appropriate.

The inspectors interviewed the contract decontamination foreman and

two laborers who entered Room 450/449 and determined: (1) that the

work was performed on a routine RWP in lieu of a required special

radiation work permit; (2) a pre-job briefing was not held and as a

result workers were not aware that the work would be performed in an

exclusion area; (3) they were not aware that the flashing red light

and triple barricade of yellow magenta rope designated an area

requiring special precautions; (4) the contract waste and decon

foreman was not sufficiently trained in radiological control

precautions and limitations for work in high radiation and exclusion

1

l

>

4 l

I

areas to have control of keys to these areas; (5) the workers and

forman were not aware of the contamination or radiation levels of the

areas in which they were working; (6) they were not aware that the

RWP under which they were working required a high range dosimeter for

entry; and (7) the contract decontamination worker who received

455 millirems during the incident exceeded the licensee's

administrative dose limit of 300 millirems per week.

The inspectors interviewed the HP technician involved in this

incident and determined the following: (1) he did not receive a

briefing upon assignment to support the decontamination activities;

(2) he was not aware of the radiation levels in the SFPD (Exclusion

Area) Room 449; (3) he was not aware that Room 450 contained an

exclusion area until he entered Room 450/449 to conduct a survey.

The inspector interviewed the Waste and Cecon Supervisor who issued

the keys to the contract decontamination foreman. Based on this

interview the inspector concluded that the supervisor was not aware

that any of the ten rooms listed to be decontaminated contained high

radiation or exclusion areas, or that the waste and decon foreman

should contact the health physics office prior to work in these areas

for a job briefing on the radiological conditions present.

The inspector concluded after discussions and interviews with

licensee personnel and review of the licensee's General Employee

Training (GET) program that; (1) the individuals that entered

Room 450/449 failed to read and comply with the RWP requirements

under which they were working; (2) the licensee failed to properly

train personnel in the limitations and precautions of an exclusion

area; (3) personnel were allowed to enter an exclusion area without

the performance of an adequate survey to evaluate the extent of the

hazards that were present; and (4) the licensee failed to provide

positive access control to a high radiation area to prevent

unauthorized entry.

d. Regulatory implications

(1) Technical Specification 6.12.1 requires that each high radiation

area in which the intensity is greater than 100 mrem /hr but less

than 1,000 mrem /hr shall be controlled by requiring the issuance

of a RWP and be accompanied by one or more of the following:

(a) a radiation monitoring device that continuously indicates

dose in the area, (b) a radiation monitoring devicc that

continuously integrates dose and alarms at a pre-set point; or

(c) a health physics technician with a radiation monitoring

device that provides positive control over activities in the

area and provides surveillance and surveys at the frequency

designated by the facility health physics supervisor.

Although an HP technician was assigned to the decontamination

effort, he did not provide positive control over activities in

_ -

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

5

the area. On December 28, 1987, licensee contract

decontamination workers entered Rooms 450/449 and failed to have

one of the above listed radiation monitoring devices on their

person or have a health physics technician provide positive

control over activities in this area. Failure of personnel

entering a high radiation area to have the required radiation

monitoring device or be accompanied by a health physics

technician was identified as an apparent violation of TS 6.12

(50-348,364/88-02-01).

(2) Technical Specification 6.12.2 requires that areas accessible to

personnel with radiation areas such that a major portion of the

body could receive in one hour a dose greater than 1,000 mrem /hr

shall be provided with locked doors to prevent unauthorized

entry.

On December 28, 1987, a HP technician was assigned to support

decontamination of areas in the auxiliary building. The

contract decontamination foreman requested the HP technician to

perfortr radiation surveys of Rooms 445, 448, and 450. Upon

entering Room 450/449, a high radiation / exclusion area, the HP

technician observed that the door to the room was unlocked and

unattended. Radiation levels within Room 450/449 were measured

to be approximately 150 R/hr at 18" from the SFPD. The licensee

elected to control access to this area by the use of a three

rcpe barricade, a flashing red light, and posting the area as an

exclusion area.

Technical Specification 6.12.2 only allows the use of a flashing

light as a warning device for large areas with dose rates in

excess of 1,000 mrem /hr, where no enclosure can be reasonably

constructed to prevent unauthorized entry. Room 450/449 had

dose rates up to 150 R/hr at 18" from the SFPD and no enclosure

existed for the purpose of locking. The inspector verified by

observation that the entrance to Room 450 could have been

maintained locked in order to prevent unauthorized entry.

Failure to maintain the high radiation area / exclusion area

locked or provide positive access controls over each individual

entry was identified as a second example of an apparent

violation of Technical Specification 6.12 (50-348,

364/88-02-01).

(3) Technical Specification 6.8.1 requires that written procedures

be established, implemented, and maintained covering the

activities referenced in Appendix A of Regulatory Guide 1.33,

Revision 2, 1978. Appendix A, Regulatory Guide 1.33,

Paragraph 7.e recommends that the licensee have procedures for

access control to radiation areas including a radiation work

permit system. Licensee Procedure, FNP-0-RCP-2, Radiation Work

Permit. Section 4.1 requires that a special radiation work

permit be issued for specific tasks to be performed for entries

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

__

.

- 6

into exclusion areas. In addition, licensee Precedure,

FNP-0-M-001, Health Physics Manual, Section 4.1 requires an

individual to know and follow the requirements of the RWP used

to control work.

The contract decontamination workers were given instructions

from their contract decontamination foreman to decontaminate

Room 450/449. The dose rates in Room 450/449 ranged from 5 R/hr

to approximately 150 R/hr at 18" from the source, thus requiring

that the area be controlled as an exclusion area. Since the

area was defined by the licensee as an exclusion area a special

RWP was required for work to be performed. The contract

decontamination workers were not informed of the dose rates or

of the special RWP requirements for entry into room 450/449.

However, the access to Room 450/449 was posted with a sign which

stated "special RWP required for entry." The two

decontamination workers entered the high radiation area in

Room 450 on routine RWP 87-0010, which was for the performance  ;

of routine decontamination of articles. Although RWP 87-0010 ,

required a high range dosimeter the workers entered the area j

without the high range dosimeter.  ;

Failure to obtain a special RWP for work to be performed in an i

exclusion area and failure to comply with RWP 87-0010

requirement to have a high range dosimeter for entry to a high

radiation area was identified as two examples of an apparent

violation of Technical Specification 6.8.1 (50-348,

364/88-02-02).

(4) 10 CFR 20.201(b) requires each licensee to make or cause to be

r.ade such surveys as (1) may be necessary for the licensee te

ccmply with the regulations in this part, and (2) are reasonable

under the circumstances to evaluate the extent of radiation

hazards that may be present.

On December 28, 1987, a decon worker entered Room 450/449, an

exclusion area, without a current survey performed to evaluate

the extent of radiation hazards that were present. In

discussion with the licensee exclusion areas are not routinely

entered to evaluate radiological conditions, therefore, the

licensee was not aware of the extent of radiation hazards that

were present in Room 450/449. The inspector was informed by a

licensee management representative that dose rates had been

measured previously up to 750 to 1,000 R/hr. Failure to perform 1

an adequate survey to evaluate the radiation hazards that were '

present in Room 450/449 was identified as an apparent violation

of 10 CFR Part 20.201(b) (50-348, 364/88-02-03).

(5) 10 CFR 19.12 requires that all individuals working in or

frequenting any portion of a restricted area shall be kept

informed of the storage, transfer, or use of radioactive

__- _

'.

.

7

materials or of radiation in such portions of the restricted

area and in the purpose and functions of protective devices

employed. ,

On December 28, 1987, a licensee contract decontamination worker

entered Room 450/449, a high radiation area (exclusion area),

Room 450/449, without being properly informed of the radiation

hazards that were present. Since a survey of the area had not

been performed and a preshift briefing held, the worker was not

aware of what the radiation levels were in Room 450/449. The

inspector determined through interviews that the individual was

unaware of the meaning of the controls, such as posting as an

exclusion area, a flashing red light, and a three rope

barricade. The inspector determined af ter review of the

licensee's GET program that the lesson plans for GET did not

address precautions and special requirements of exclusion areas

therefore, the licensee failed to properly train personnel on

the precautions and limitations of exclusion areas. The failure

of the licensee to inform the worker of the extent of the

radiation hazards present in the exclusion area and the failure

of the licensee to provide adequate training on exclusion areas

was identified as an apparent violation of 10 CFR Part 19.12

(50-348,364/88-02-04).

1

l

1