ML20150A650
| ML20150A650 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/02/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| References | |
| NUDOCS 8803150365 | |
| Download: ML20150A650 (17) | |
See also: IR 05000348/1988002
Text
r --
,
,
. 6 4[
MAR 0 21988
Docket Nos. 50-348, 50-364
AJabamaPowerCompany
L4TTN: Mr. R. P. Mcdonald
Senior Vice President
P. O. Box 2641
Birmingham, AL 35291-0400
Gentlemen:
SUBJECT: ENFORCEMENT CONFERENCE SUMMARY
(NRC INSPECTION REPORT NOS. 50-348/88-02 AND 50-364/88-02)
This letter refers to the Enforcement Conference held at our request on
February 17, 1988. This meeting concerned activities authorized for your
Farley facility. The issues discussed at this conference related to the
potential for excessive personnel exposure as a result of the unauthurized
entry into an exclusion area /high radiation area. A summary, a list of
attendees, and a copy of your handout are enclosed,
it is our opinion that this meeting was beneficial and has provided a better
understanding of the inspect. ion findings, the enforcement issues, and the
status of your corrective actions. We are continuing our review of these
issues to determine the appropriate enforcement action.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10. Code of Federal Regulations, a copy of this letter and its enclosures
will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely,
J. Nelson Grace
Regional Administrator
Enclosures:
1. Enforcement Conference Summary
2. List of Attendees
3. Handout
cc w/encis: (See page 2)
8803150365 000302
PDR ADOCK 05000340
0 PDR
e
e- t
l
.- .
Ci f
!
' Alabama Power Company 2
,
I
cp w/encis:
Hil. O. Whitt, Executive Vice President
- D. Woodard, General Manager - :
Nuclear Plant.
G. Hairston, III, Vice President - :
@t!uclearSupport
LX W. McGowan, Manager-Safety Audit
and Engineering Review t
! tS/ Fulmer, Supervisor-Safoty
, Audit and Engineering Review
bgc w/encis:
LNRC Resident Inspector
'
'{
1 0 S Technical Assistant
. Reeves, Project Manager, NRR '
J
Occument Control Desk
State of Alabama
.
i l
f
1
'
!
t
!
, !
!
'
I
'
,
!
>
I I
'
kh kvolY&
RII RIl RI! R!l I R RI! R1 !
% C4lp
TCollins CHosey
dI?1L d!?!C
DCollins,WPStohr NDance
V Reye: G3 n Ins p!Er st
>
!
f
2/J/88 2/f/88 2//3 /88 2//r/88 2h L/88 2/0(/88 3/ / /88 / /88 [
'
b\S
4
h
I
i
>
_ . - - - . - .- -
.-
__ .. . ._ -_ . - _
!
. . .
, ;
1
.
i
,,RE 1
ECl
Enforcemer Conference Sumary ,
t.icensee: Alabama Power f pany
Facility: Farley
Docket Nos.: 50-348 and 50-364
Subject: Potential for Excessive Exposure as a Result of Unauthorized !
Entry into an Exclusion Area /High Radiation Area
i
An Enforcement Conference was held at the Region II office on February 17, ,
1988, to discuss the potential for excessive radiation exposure as a result of ;
an unauthorized entry into an Exclusion Area (areas with radiation levels in ;
excess of 1,000 mrem per huur)/High Radiation Area. i
t.icensee representatives discussed the sequence of events surrounding the entry ,
of a contreet laborer into the spent fuel pool demineralizer room and, using a :
mock-up, demonstrated the radiological controls that were in place when the
entry occurred. The licensee discussed the results of their investigation.
During this discussion, the licensee indicated that they disagreed with two
statements made in the NRC Inspection Report which discussed the event :
(Inspection Report 50-348/88-02 and 50-364/88-02). The licensee stated that !
the door at the access to Room 450 automatically locked when the door closed;
therefore, the door could not have been left unlocked. The licensee also '
stated that they had not intended that anyone enter the exclusion area in
Room 450/449; therefore, there was no need for a radiation survey to be
performed in the exclusion area entered by the laborer.
The licensee stated that they believed that the root cause for the event was [
the failure of the laborer to heed the radiological warning signs and controls
at the entrance to the exclusion area. In addition, the licensee discussed l
other contributing causes for the unauthorized entry. The licensee also j
'
discussed their temporary and permanent corrective actions to control access to
exclusion areas. ;
NRC representatives discussed the seriousness of the event and emphasized the
potertial for excessive exposures and the need to take action as necessary to
preclude such events. NRC representatives stated that the contributing causes i
of the event should include inadequate identification of Room 449 in that the !
'
laborer was unaware that when he entered tha exclusion area he was actually in
Room 449 rather than Room 450, the room he was assigned to decontaminate. l
,
NRC representatives also stated that the use o' the rope barrier and flashing I
light was inappropriate to secure access to the exclusion area, Farley [
Technical Specification 6.12.2 permits the licensee to rope off, conspicuously ,
post, and use a flashing light as a warning device for securing access to i
!
-__
_ - _ _ _ _ _ _ _ - _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
-
!
!
Enclosure 1 2 f
!
I
-
i
2 individual areas with radiation levels in excess of 1,000 mrem per hour that I
are located within large areas, such as PWR containment, where no enclosures i
, exist for purposes of locking, and no enclosure can be reasonably constructed !
i around the individual areas. NRC representatives stated it is the NRC position !
- that a locked barrier could have reasonably been constructed at the entrance to !
! the exclusion area, l-
1
..
I f
I
<
.
A
i
'
!
,
d
+
1 t
-
-
1
'
i
r
f
+
]
1
.
.
1
J
i
I
1
<
a
i
1
!
!._._-._____. . . _ _ . _ . _ _ _
. --- - . _ - . . _ . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ __ _ _ _ _
. ;. . . .
l
I
!
!
!
i
ENCLOSURE 2 I
list of Attendees
i
!
Alabau Power Corporai: ton !
P. Mcdonald, Senior Vice President i
G. Hairston, Vice President :
J. Woodard, Plant Manager :
J. McGowan, Manager, Safety Audit and Engineering Review f
C. Nesbitt Technical Manager ,
M. Mitchell, Health Physics and Radwaste Supervisor t
M. Graves, Health Physics Sector Supervisor
Nuclear Regulatory Comission
J. Nelson Grace, Regional Administrator .
L. Reyes Director, Division of Reactor Projects (DRP)
G. Jenkins, Director. Enforcement and Investigations Coordination Staff
i D. Collins, Chief. Emergency Preparedness and Radiological Protection Branch ;
(EPRP)
H. Dance, Chief. Project Section 18, ORP l
C. Hosey, Chief. Facilities Radiation Protection Section (FRP) EPRP L
T. Collins, Radiation Specialist, FRP, EPRP !
R. Shortridge, Radiation Specialist, FRP, EPRP l
M. Lauer, Radiation Specialist FRP, EPRP ;
L. Modenes, Project Engineer, DRP l
L.1rocine, Enforcement Specialist j
'
,
1
, -
! (
!
!
l
-
I
I
i
i h
I
!
_ - - - - - - - - - - - - - - . -
,
.
/~ ENCLOSURE 3
> ALABAMA POWER COMPANY
NRC ENFORCEMENT CONFERENCE
POTENTIAL OVEREXPOSURE INCIDENT OF 12-28-87
AGENDA
I. Opening Remarks J. N. Grace
II. Introductions R. P. Mcdonald
III. Event Description J. D. Woodard
IV. Analysis of Incident J. D. Woodard
V. Corrective Action J. D. Woodard
VI. NRC Inspection Report J. D. Woodard
VII. NRC Comments J. P. Stohr
T. R. Collins
VIII. Conclusion and Summary R. P. Mcdonald
J. D. Woodard
IX. Closing Comments J. N. Grace
.
i
v
._
~
.
..
.
.
.HIGH RAD AREA
(BARRICADE
w_ O o
VALVE ROOM -\ -
450 O
s N
\
u O -
_-
4 W p
3 ROPE ! " " ' '# "\ '"
J
EXCLUSION AREA
/ S"!;l
-
-
%
BARRICADE
l
j
DEMIN ROOM
449
p i
I
}q
-
l
>
i
SKIMMER .
.c
PUMP ROOM 448
.
O m S I
.
i v
,
445
SPENT FUEL POOL lA HX ROOM
-
g. '
.
-
l . .
'
l
CAUTION l
OVER
l WALL
! 3oRfhA6/4 l
ISoRikes
l HIGH
BADIATIO\l AREA !
! EXCLUSION AREA :
!
!
i
i
i
'
I
) I
! -
l D \
7 s ". 'A M
~
CAUTION
dek___ $ 4 MR/HR
DA H5~
eL-
HIGH
RADIATION AREA
-
SEE RWP FOR
ENTRY
- REQUIREMENTS
9
-_m- _ _.---____.-__m
-A - e y
e
CAUTION
TECH
DATE
8.A _
pga
_
20 SR/HR
"
jHR
5 ??L%w
HIGH
RADIATION AREA
EXCLUSION AREA
REQUIRES APPROVAL FROM THE ON CALL HEALTH
PHYSICS MANAGER FOR ENTRY.
ADMINISTRATIVE CONTROLS FOR ENTRYIN ACCORDANCE
WITH FNP-0-RCP-0.
1
I
I --
O
-
.
-
.
.
.
.
PRINCIPAL CAUSE
Hollinger crossed the exclusion area barricade which consisted of
three ropes (knee, waist and shoulder height), a flashing light
and an exclusion area sign (stating: HP Manager Approval Required
Prior to Entry, also stating dose rates). He made this entry
without an RWP and in disregard of radiation postings.
.
l
l
l
l
l
l .
@
. - - - . .
.. ..
-
.
!
CONTRIBUTING CAUSES
a. Davcon Laborers did not read and follow the RWP for Room
450. Davcon Foreman did not ensure that his crew complied
with the RWP while he was in direct control of their ;
actions.
b. Davcon laborers over-relied on health physics instnictions
rather than their own training and administrative controls.
c. Lack of accurate communications between workers and HP
Technician concerning conditions at the job site and work
requirements,
d. Inadequate knowledge and understanding of exclusion area and
high radiation area work requirements by Davcon personnel. I
e. Lack of specific training on exclusion areas.
.
i
.
l
l
l
TEMPORARY CORRECTIVE ACTION
1. Dosimetry for the Davcon Foreman and laborers was pulled.
2. Closed circuit TV cameras were set up to avoid the need to
enter Room 450 and Room 2450 (comparable area 'on Unit 2) on
a routine basis.
3. The doors to Room 450 and Room 2450 were established as
exclusion area boundaries.
4. All other jobs at FNP in the proximity of exclusion area
boundaries were reviewed for adequacy of radiation controls.
5. The doors to the Waste Gas Compressor Rooms and Waste Gas
Decay Tank Rooms were established as exclusion area l
boundaries, eliminating similar situations in which
exclusion area barricades were established inside high
radiation areas.
.
D
_ _ _ _ _
.
.
'
.
,
(
PERMANENT CORRECTIVE ACTION
1
1. Steps will be taken to provide additional assurance that contractor
l personnel, at all levels understand the significance of following
FNP radiological controls and feel free to question supervisory
instructions that appear to be in conflict with those controls.
2. The Davcon personnel were retrained by APCo and then counseled by
Davcon supervision.
3. Wherever possible, exclusion area bc. . ries in the Auxiliary
Building will be expanded such that access can be controlled by a
locked door. Design changes will be considered for all instances in
which exclusion area boundaries require frequent entries.
4. Keys to exclusion area doors were removed from all key rings except
for the Emergency key ring in the sole custody of the Shift ,
j Supervisor. l
.
5. The system for issuance of exclusion area keys was segregated from
that of other keys.
6. Training was conducted for each FNP work group (both APCo personnel
and contractors) in January,1988. This training has been
incorporated into the basic Radiation Worker Training and retre.ining
course.
-
@
.
-
.
INPO ROOT CAUSE ANALYSIS
1. Inaccurate or incomplete radiation survey.
2. RWP inadequate for the work to be performed.
3. Radiological protection technicians not reacting to changing
or unusual radiological conditions.
4. Workers not following procedures or exhibiting improper
radiological work practices.
5. Need for more involvement by the supervisor or foreman of
the workers.
.
e
~
@
~ .
_ _ _ - _ _ _ _ _ _ _ _ _
,
,
,
l
i
CONCLUSION
A. Hollinger received an administrative overexposure because he
followed what he thought were accurate verbal instructions
from health physics rather than following radiological
postings, procedures and training.
l
B. Hollinger did not receive a regulatory overexposure because .
he was conscious of the high radiation level, he worked
l quickly as instructed and checked his pocket ion chamber as
instructed.
i
1
.
.
t
.
- . ,. . .. .-
.
w. t
-
.
)
!
l
O jm.W~~ 1o E
O
~~~
I !!
l J i !{j t 15 .
It i
o c
l 6c c
l
3
00
f ' 3it
o d8,q -):- I k ' ' I
f,e.lt
..
a L
::
,
I
bo I-]~ri
'
! !;
o g
!, ,; [ ; g ,
}o
}
-.n - .)
,oooooo g
., , .
.
, , y
C x 00 jO I'
-
.
I
{
ll o j t= n i
!*
] a! lo j -
l
ro elo
5
5
, e }#113
-
.
1
-
a ! } r I
l :*jfgpl
'
lo .. g
'
l I
g og
! }~~ j j ; .. ,,
'
I M c .
b
j. *,, s
k l f '
f l ~f I
o
l}l l I !
li
,
Do o ~ ~ ~
\
o
,
,
.
L-L i p
; i
=
%)5ff
i r.
'
U l
j t g g g
jfl!
.__ i i
goc l' QAG I '
[ } '3 1 .
}}}
i ll i ni -
.. c
p
. .
.
l13n x
o I
! f1 j. .
l
0 a
l
EEE
jj
ij ;!}i '
'
l
j!
oa j
'
-
l13!
-
3
3j
.
11
O j _ss-
._ ,
co
,
j
-
m
, h,
I L i
iM 1 , i1 4
o 2
s ! !!
o .__ ..
! l 'j
O : 1 . !! {!
! I
~
.
,
.O i j h 5 '
j
b $} l I .! !
jo ay
.
3
. -$ . , i l l J .' oooo ., . 1 11!
- - - - - - - _
}}