ML20149G513
| 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: |
| 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
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UNITED ST ATES
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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.:
Facility:
Farley 1 and 2
Inspectien Conducted:
January 4-6, 1988
Irspector:
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T. R. Collins
Date Signed
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Acccrpar'ying Persennel:
R. B. Shortridge
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Arcreved by:
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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.
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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.
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8802180287 880208
FDR
ADOCK 05000348
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REPORT DETAILS
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Pessons Contacted
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Licensee Empfb' vees
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- P. Farnsworth; Radwaste. Supervisor
.' 0,' Graves, Health Physics 5'upervisor
' $ Maddox, Training Supt / visor
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- g)!Kchell, Health Physics and Radwaste Superiisor
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- D. Morey, Assistant General Manager, Operations
>C. Wesbitt, Technical Superintendent
,?J.s06terholtz, Supervisor, 5'afety Audit Er ineering Review
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- B. Patton, Plant Health Physicist.
- J. Walden, Lead Auditoy
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- L. Ward, Maintenance Manager
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- L. Williams, Training Kinager
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- J. Woodard, General,yanager
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NRC Resident inspectors
- W. Bradford' '
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- N tjiller
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- Attended exit interview
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2.
Exit Interview (30703)
The inspection scope and findings were summarized on January 6, 1988, with
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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
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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.
b.
Licensee Corrective Actions
Licensee temporary corrective actions were as follows:
(1) processed
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the individual's TLD and assessed his exposure during the incident as
455 millirems; (2) the licensee verified that the individual who
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remained in the front part of Room 450 did not receive any
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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
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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
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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
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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
(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,
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
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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
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required a high range dosimeter the workers entered the area
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without the high range dosimeter.
Failure to obtain a special RWP for work to be performed in an
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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
(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
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an adequate survey to evaluate the radiation hazards that were
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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
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materials or of radiation in such portions of the restricted
area and in the purpose and functions of protective devices
employed.
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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).
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