ML20199H861
| ML20199H861 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/28/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20199H799 | List: |
| References | |
| 50-285-97-20, NUDOCS 9802050137 | |
| Download: ML20199H861 (18) | |
See also: IR 05000285/1997020
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-285
- License No.: - DPR 40
Report No.: 50 285/97-20
Licensee: Omaha Public Power District
Facility: Fort Calhoun Station
Location: Fort Calhoun Station FC-2-4 Adm.
P.O. Box 399, Hwy, 75 - North of Fort Calhoun
Fort Calhoun, Nebraska
Dates: December 7,1997, through January 17,1998
l Inspectors: W. Walker, Senior Resident inspector .
V Gaddy, Resident inspector -
D. Graves, Senior Project Engineer
Approved By: W. D. Johnson, Chief, Project Branch D.
ATTACHMENT: Supp'ier;ientalInformation
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9902050137 970128 7 *
G -ADOCK 05000295 j
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EXECUTIVE SUMMARY
Fort Calhoun Station -
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- NRC Inspection Repori 50-285/97 20
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Operations ;
L *- . In general, the conduct of operations was professional and safety-conscious, with clear .f
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~ and thorough turnovers conducted (Section 01.1and 01.2).
-. The licensee maintained good control of operator sids (Section O2.2).
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'. Operations memorandums were being used, in effect, to implement procedure changes -
.without being processed in accordance with administrative requirements (Section 03.1).
Maintenance
. No preventive maintenance order existed to ensure periodic testing of a fan'requimd for
altemate cooling of the. control room (Section 02.2).
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. A sparger will be installed at the diesel-driven fire pump suction. The sparger li intended '
i- to prevent sand accumulation in the pump (Section M2.1).
Engineenng
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. The inspectors concluded that the maintenance rule audit was thorough and that the .
maintenance rule program improvement action plan was adequate (Section E7.1).
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. Failure to maintain adequate trisodium phosphate in containment resulted in an
. inadequate amount of trisodium phosphate to neutralize the postaccident sump water
following an accident (Secticn E8.1). ,
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Plant Support
.- Two licensee personnel entered the radiologicel controlled area without proper dosimetry
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Reoort Details
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Summarv of Plant Statua
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The Fort Calhoun Station began this inspection period at 100 percent power and maintained that
i level until December 20,1997. On December 20/1997, power was reduced to 95 percent to
l perform a Technical Specification required surveillance for moderator temperature coefficient.
L On December 21,16. 7, a power ascension began with 100 percent power attained on
December 22,'1997. - The plant remained at 100 percent power throughout the remainder of the
inspection period.'
l. Operations j
- 01 - Conduct of Operations
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01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
ongoing plant operations, in general, the conduct of operations was professional and
..U safety conscious; specific events and noteworthy observations are detailed in the-
p- . sections below.
j 01.2 Shift Tumovers
' The inspectors noted that shift tumovers and midshift briefings were good. Control room !
personnel reviewed the control room logs, walked down control room panela, and .j
discussed the status of equipment during tumovers. The shift supervisor held good
. briefings for the shift crews. Operators remained cognizant of plant conditions during the
tumovers and briefings.
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O2 Operational Status of Facilities and Equipment
02.1- Review of Eauioment Taaouts (71707)
The inspectors reviewed the following tagouts: I
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. Serial Number 98-0010, Repair of Seal Leak on Main Feed Pump FW-4C
. ' Seri::l Number 98-0015, Remount of Diesel Driven Auxiliary Fire Pump
The inspectors found all tags were on the proper components and that components were
in the required tagged position. Housekeeping was observed to be good.
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- 02.2_ Control of Operator Aids
a. Inanection Scone (71707)
The inspectors walked down a sample of operator aids throughout the plant to assess
- how these sids were being controlled.
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- b. Observations and Findinas -
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The inspectors performed a walkdown of inel equipment that the licensee had identified
as being operator aids. -- An operator aid was defined as information including sketches,
graphs, procedures, drawings, prints, and other documents used to assist operators in -
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. performing assigned duties.- This equipment was controlled by Standing Order S0-0-41,
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" Control of Operator Aids and Emergency Equipment." Based on a sample of equipment
walked down, the inspectors concluded that, with few exceptions, operator aids were
l being properly controlled.
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- While inventorying the alternate shutdown panel lockers, the inspectors and a licensed -
operator noted that one of five flashlights required for Abnormal Operating ' . .
Procedure AOP-06, " Fire Emergency," implementation was not functional. ~ Also 3 of .
12 door chocks required by Abnormal Operating Procedure AOP-13, " Loss'of Control
Room Air Conditioning," were missing from the lockers. These chocks were used to prop
open doors to assist in control room cooling in the event normal control room cooling was -
lost.- The inspectors verifed that the deficiencies documented above were corrected,
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The inspectors also verified that the attemate control room fan required by Abnormal -
Operations Procedure AOP 11 was in its designated location. This fan provided an
option for cooling the control rum in the event normal cooling was lost. The inspectors z
asked if there was a preventive maintenance order for the attemate control room fan to
ensure it was maintained in a reliable condition. The maintenance manager stated there -
was not a preventive maintenance order that periodically verified the attemate control
room fan was capable of cooling the control room, ' In response to the inspectors'
= questions, the licensee initiated a preventive maintenance order to test the fan on a
yearly basis. The fan was scheduled to be tested during the week of January 26,1998.
The inspectors questioned the licensee conceming the last time the fan had been tested.
tThe licensee indicated that the fan was last tested in the spring of 1995, however, the
licensee could not locate any test documentation.
- c. Conclusions
in general, the licensee maintained good control of operator aids throughout the plant.
The inspector identified a weakness in which the attemate control room fan, required by .
. Abnormal Operating Procedure AOP-13 to cool the control room, did not have a
- preventive maintenance order to ensure it was periodically tested and verified
operational.
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03 : Operations Procedures and Documentation
03.1 Review of Onorations Memorandumai71707)
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- a, Scope of Inspection
The inspectors reviewed ths active Operations Memorandums to determine whether they
provided the appropriate document to direct operator actions.
- bl Observations and Findings
On October 16,1997, the licensee discovered that the Updated Safety Analysis Report,
Section 8.4, stated that the capacity of the emergency station batteries in the two
separate dc systems was adequate for instrument and control power for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
following a design basis accident. A review of documentation by the licensee determined
, that no calculation supported the 8-hour capacity of the station batteries. This was- ,
reported to the_ NRC on October 17,1997, and in Licensee Event Report 97-015 dated i
November 17,=1997.
D Subsequently, the licensee _ issued Operations Memorandum 97-11 regarding operator
actions to take during a design basis accident that would ensure that sufficient battery -
g: capacity was available to meet design requirements. The memorandum required that, if
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the plant was in a condition such that the Emergency Operating Procedures were
implemented, and the battery charger supply to either dc bus was lost, tho' operators
were to minimize de loads in accordance with Emergency Operations - ,
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Procedure / Abnormal Operations Procedure, Attachment 6, " Minimizing DC Loads." The :-
inspectors questioned the licensee regarding whether it was appropriate to direct
emergency operator actions using an operations memorandum instead of _ making a
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procedure change or revision to the emergency operating procedures. The licensee :
stated that_ the operations memorandum process was controlled by Standing Order
Procedure SO-O-13, " Operations Memorandums" Standing Order Procedure SO-O-13
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defines * Operations Memorandums," as documents which communicate operational'
limitations, instructions,'and/or other items of interest from management to the operating
staff. - The memorandum may be more conservative or restrictive than existing
procedures, but cannot allow less conservative or restrictive operations.
- The inspectors reviewed the active operations memorandums to determine the scope of
operator guidance provided and discussed with the licensee what controls were placed
on memorandum initiation and approval.- The initial review of eight active memorandums
was begun in the previous inspection period.
Observations regarding specific operations memorandums are discussed below.
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b.1 Operations Memorandum 95-05
This memorandum directed operators to conduct evolutions to raise low pressure safety
injection header pressure, if it dropped below a specified value, to prevent potential
formation of nitrogen voids in the safety injection piping. This condition was documented
in Licensee Event Report 97-017. The required operator actions included cycling of the
low pressure safety injection loop isolation valves,
b.2 Operations Memorandum 97-06
This memorandum stated that, if MS-291 or MS-292, air assisted secondary system
safety valves, were the preferred reactor coolant system heat removal path during a
transient and they failed to fully open when required, the operators were to perform heat
removal using one of three listed alternatives,
b.3 Operations Memorandum 97-07
l This memorandum described the procedure that should be used to manually trip
breakers during a fire which resulted in evacuation of the control room. These actions
were in addition to the steps called for in Procedure AOP-06, " Fire Emergency,"
regarding breaker tripping during a control room evacuation,
b.4 Operations Memorandum 97-08
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This memorandum related to the inoperability of Main Steam Line Radiation
Monitor RM-064. During implementation of the Emergency Plan, the memorandum
directed operators to use a radiation monitor other than RM-064 for the purpose of dose
assessment. RM-064 was the normal monitor used for that purpose. If procedures
necessary to assist in the determination of a leaking or failed steam generator tube were
implemented, the operator was directed by the memorandum on how RM-064 should be
placed in service to provide radiation level trending information,
b.5 Operations Memorandum 97-11
This memorandum directed that, in the event the plant was in an Emergency Operating
Procedure, and the battery charger to either DC Bus is lost, the operators were to
minimize de loads per Attachment 6 to the Emergency Operating Procedures and
Abnormal Operating Procedures. This memorandum was canceled following a revision
to the Emergency Operating Procedures on November 18,1997.
b.6 Procedural Requirements
The Updated Safety Analysis Report, Section 12.3.1. " Operating Procedures and
Operating Instructions," stated that plant operations are conducted in accordance with
written operating proceoores and operating instructions. Section 12.3.2," Emergency
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and Abnormal Operating Procedures," stated that plant operation during abnormal
conditions are conducted in accordance with written Emergency Operating Procedures
and Abnormal Operating Procedures.
Standing Order SO-O-1, " Conduct of Operations,' Revision 36, Section 12.1.2,
" Procedure Adherence,'sts'.ed that performance of an activity without referring to the
procedure does not relieve the individual from responsibility for performing the activity in
accordance with the latest revision of the approved procedure.
Standing Order SO-G-30, " Procedure Changes and Generation,' identified the prowss
by which plant operating procedures were revised or created. Operations
Memorandums are not listed as one of the documents covered by this procedure.
Standing Order S0-0-13, " Operations Memorandums," provided the guidaace for
initiation and revision of operations memorandums. Section 5.1.3 of Standing Order SO-
O-13 states that a review of the operating manual shall be conducted during the
generation phase of the Operations Memorandum to ensure that appropriate guidance is
given in all applicable operating procedures or instructions and that changes to affected
procedures will be in accordance with Standing Order G-30.
The Operations Memorandums referenced above directed operator actions in addition to,
i or different from, those required by plant procedures. Those memorandums, in effect,
constituted changes to the referenced procedures, or generation of new procedures,
without implementing the requirements of Technical Specification 5.8.2 or Standing
Order SO-G-30 regarding procedure changes or generation. Most significantly, Standing
Order S0-0-13 did not require a 10 CFR 50.59 screen or evaluation that would normally
be required of a procedure change or new procedure generation. The use of operations
j memorandums to direct operator actions, especially in the case of emergency operating
} procedures, abnormal operating procedures, and emergency plan procedures, precluded
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important steps or information, contained in the operations memorandum but not in the
reference procedure, from being included in plant procedures. This, in turn, introduced
the vulnerability that these r3 quired steps or actions may not get performed during
periods of high stress such as those that may be present when thosc procedures are
being implemented. Implementing changes to plant procedures without following the
prescribed process is a violation of Technical Specification 5.8.2 (50-285/9720-01).
c. Conclusion
Operations memorandums that directed operator actions in addition to actions contained
in existing plant procedures constituted procedures, or changes to procedures, that had
not been orocessed in accordance with the administrative requirements regarding
procedure changes and generation.
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II. Maintenance
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M1 Conduct of Maintenance
M1.1 General Comments
a. Insoection Scooe (62707)
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Repair of component cooling water pump casing vent valve,
g . DG 1 relay replacement,
. Toxic gas rr snitor tape replacement,
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Repair of diesel fire pump discharge check valve.
b. Observations and Epshags
The inspectors found the work performed under these activities to be professional and
thorough. All work observed was performed with the work package present and in active
use Maintenance technicians were experienced and knowledgeable of their assigned
tasks. The inspectors frequently observed supervisors and system' engineers monitoring
job progress, and quality control personnel were present when required by procedure.
c. Conclusions
The maintenance activities observed were conductad in a controlled and professiona!
mar,ner.
M1.2 Surveillance Activiti.g3
a. Insoection Scoce (61726)
The inspectors observed all or portions of the following surveillance activities:
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SE-ST-AFE-3005," Auxiliary Feedwater Pump FW-6, Recirculation Valve, and
Check Valve Test.= " Revision 14;
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IC-ST-1 A-3003, " Raw Water instrument Air Accumulator Check Valve Operability
Test," Revision 7;
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IC-ST-AFW-0001, " Auto Initiation of Auxiliary Feedwater Functional Check of
Initiation Circuits," Revision 18;
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CH-FT-01-67718, " Functional Testing of B Steam Generator Blowdown Station
Conductivity Sensor CE-67718," Revision 1;
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. EM ST ESF.0001, ' Quarterly Engineered Safety Features Offsite Power Low
Signal (OPLS) Sensor Check,' Revision 7,
b. Qhagryations and Findinas
Surveillance activities were generally completed thoroughly and professionally.
c. Conclusions
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The surveillance activities observed by the inspectors were completed in a controlled
manner and in accordance with procedures.
M2 Maintenance and Material Condition of Facilities and Equipment
M2.1 Diesel-Drivfga Firs Pumo Failure
a. lDagaglion Scone (62707)
The inspectors followed up on diesel driven fire pump sanding issues.
b. Observations and Findinos
On January 5,1998, the diesel-driven Pe pump was declared inoperable to perform
Surveillance Test OP-ST FP-000.D, " Fire Protection System Inspection and Test."
During the test, the discharge valve of the pump was shut and tiow was discharged to
the pump suction well. Following the approxlinate 30-minute pump run, the discharge
valve was opened and the fire protection system was ryescurlzed using the jockey
pump. During system repressurization, the jockey pump could not repressurize the
system. The licensee suspected that the discharge chsck val.'s was not properly seated
and water was leaking by the check valve through the pump. Since the system could not
be repressurized, the diesel-driven pump remainod inoperable.
On January 7 maintenance parsonnel disassembled the check valve and verified that
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sand prevented the check valve from properly seating Maintenance personnel removed
approximately 6 to 7 gallons of sand from around the check valve flapper.
- On January 8, the licensee performed Surveillanco Procedure OP-ST FP 0001D to show
that the pump was operable following maintenance on the check valve to remove the
i sand. When the pump received a start signalit failed to start. Operations personnel
present at the pump stated that the pump shaft started to rotate and then stopped. A
second attempt was made to start the pump, but this time the shaft did not turn.
Operations personnel backed out of the procedure and a maintenance work request was
written to troubleshoot the pump.
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On January 9, during troubleshooting, maintenance personnel determined that the pump
would not start because of sand accumulation in the pump suction. The pump was
disassembled and the sand was removed.
Normally, during the monthly surveillance test of the motor-driven pump, the flow path
was from the discharge of the motor-driven pump through 12 inch and 8 inch piping to
the discharge tunnel back to the river.
The normal monthly surveillance flow path for the diesel-driven fire pump was from the
discharge of the pump through a 2.5-inch pipe to the pump suction well. Engineering
personnel suspected that the smaller diameter piping used during testing the diesel,
driven pump may not be adequate to ensure that the piping was thoroughly flushed. On
January 10, during the operability test following the January 9 maintenance, the licensee
changed the flow path to direct flow through the 12-inch and 8-inch piping used to test
the motor-driven fire pump. The operability test was successful using this flow path.
Following the surveillance, the discharge check valve was disassembled and inspected
and no sand was noted. The diesel-driven fire pump was then declared operable.
The system engineer informed the inspectors that the pump would be run weekly for a
period of time and the surveillance test procedure was being changed to reflect the new
discharge flow path. Following the weekly pump runs, the check valve was to be
inspected for sand. The system engineer also stated that a modification tr ?nstall a
sparger at the pump suction was scheduled for February 1998.
c. Conclutioni
The system lineup used for testing the diesel-driven fire pump may have contributed to
sand accumulation at the suction of the pump. The licensee plans to install a sparger on
the pump. The sparger is intended to prevent further sand accumulation problems,
M8 Miscellaneous Maintenance issues
M8.1 (Closed) Insoection Follow-Un item (IFI) 50-285/9608-01: replacement of Jacket water
temperature control valve. This item remained open to allow the licensee to determine
why the vendor changed the dimensions of a critical quality element without informing
the licensee. Specifically, the vendor changed the dimensions of the jacket water
temperature control valve of the diesel generator. Also, the item remained open to allow
the licensee to address why a material discrepancy notice report was not initiated in a
more timely manner to document the nonconforming condition.
The licensee determined that the installed jacket water temperature control valve was
manufactured using a drawing dated April 1959. The replacement part was
manufactured using a drawing dated May 1983. In the late 1970s, the dimensions for
both the upper and lower valve cases were changed, however, the overall valve
dimensions remained the same. Although the dimension changed, the part numbers
remained the same.
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The licensee stated that the reason for the delay in initiating the material discrepancy
notice report was unclear guidance as to when a material discrepancy notico report
should be initiated. The guidance was changed to require that a material discrepancy
notice report be initiated at the time of discovery of a nonconforming condition.
Since the replacement part would not fit, the licensee tagged the replacement part with a
material discrepancy notice report and stated that the part would remain in the
warehouse until the material discrepancy notice report evaluation resolved the problem.
M8.2 (Closed) Insoection Followuo item 50-285/9707 03: component cooling water leak. This
item was opened following a leak in the component cooling water system following a cut
made in an isolated section of piping while performing a modification to abandon the
waste evaporator. The inspector reviewed Condition Report 199700479 which
documented the event, evaluation, and subsequent corrective action. The work was
determined to have been properly controlled. The isolation valve that had been closed to
provide system isolation did not completely close. The failure of the valve te obtain
complete closure was determined to be the result of sand that had built up in the valve
seating area because of opening and closing ef the raw water to component cooling
, water system interface valves in past years. The previous testing methodology had
allowed raw water, including any entrained sand, to be introduced into the component
cooling water system. The waste evaporator had not been operated since the early
1980's and the component cooling water supply and return lines associated with the
waste evaporator had not been routinely cleaned or tested. The testing methodology for
l the interface valves was changed in 1990 such that raw water would not be iritroduced
into the component cooling water systam, Since that time, no indication of valve fouling
due to residual sand buildup had been observed in other parts of the system. The
inspector also verified that procedure revisions were made to add component cooling
water to the list of systems that required briefings prior to work if single valve isolations
were to be used.
Ill. Enaineerina
E1 Conduct of Engineering
E7.1 Maintenance Rule Quality Assurance Audit
Between November 3 and 8,1997, the licensee performed a quality assurance audit of
the implementation and effectiveness of the maintenance rule program. The audit was
primaH!y ceducted by contract personnel with a member of the licensee's quality
assurance organization serving as the audit team leader. The inspectors noted that the
contractors were industry personnel with experience in maintenance rule implementation
and witii probabilistic risk analysis. The inspectors noted that the audit was thorough
und self-entical. The audit team concluded the following about the Fort Calhoun
- Station's implementation of the maintenance rule:
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. The structure and current status of the probabilistic risk analysis was not
commensurate with the needs for the maintenance rule. This has delayed fine
tuning and verification of the performance criteria.
. The monitoring approach implemented by the Fort Calhoun Station will not
adequately highlight troublesome systems for expedited attention.
. Previous internal maintenance rule assessments did not subject the program to
challenges expected today and may have given management an unjustified
sense of comfort.
. Integration of the maintenance rule into the daily routine has not been achieved
and the maintenance rule was viewed as a separate and decentralized issue of
regulatory compliance.
. Training of personnel who are responsible for the implementation and integration
of the maintenance rule program has not been adequate or effective.
. The processing of information, monitoring, trending, goal setting, and the
updating of procedures must be expedited to assure that timely decisions can be
made.
. Management oversight and cognizance of the maintenance rule had been weak
and needs to be strengthened.
. Because the plant has a sound framework of the maintenance rule program in
place, and has an effective data base for monitoring the performance of system,
structures, and components, the audit team believed that a short term upgrade
plan can bring the maintenance rule program up to date.
In response to the audit conclusions, the licensee developed a maintenance rule
program improvement action plan to address the above areas and other areas needing
improvement. The action plan was scheduled to be completed prior to the beginning of
the 1998 refueling outage. The inspectors concluded that the maintenance rule audit
was thorough and that the maintenance rule program improvement action plan was
adequate to resolve deficiencies identified during the audit.
E8 Miscellaneous Engineering issues
E8.1 (Closed) Licensee Event Reoort (LER) 50 285/95-08: failure to maintain adequate
trisodium phosphate inside containment due to a calculational error. On December 4,
1995, the licensee determined that, at the beginning of the last several plant operating
cycles, the amount of trisodium phosphate in the containment was not sufficient to
neutralize the postaccident containment sump water to a ph of 7.0.
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Subsequently, the licensee performed an operability evaluetion wh!ch determined, for
current conditions, that the amount of trisodium phosphate inside containment was
adequate for maintaining a ph of 7.0 or greater.
The licensee took the following corrective actions:
. Appropriate calculations and analysis were performed to ensure that a sufficient
amount of trisodium phosphate in the containment sumps was available so that a
neutral ph for each operating cycle can be achieved following a loss-of-coolant
accident;
. Based on the revised calculations, additional trisodium phosphate was placed in
the containment during the September 1996 refueling outage;
. A Technical Specification amendment was submitted to reflect the requirements
for increased trisodium phosphate in the containment based on the revised
calculations and analyses;
. The updated safety analysis report and design basis document were scheduled
to be corrected during the next scheduled update;
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. Training was provided to chemistry and operation personnel on the document
changes and modifications;
. Chemistry Procedure CH ST-CH-0002, * Phosphate Basket inspection,' was
revised to ensure that the new Technical Specification requirements for trisodium
phosphate were properly verified, and;
- To ensure the quaritity of trisodium phosphate in the containment continues to be
adequate for future operating cycles, the calculations and analyses used to
determined the quantity of trisodium phosphate in containment will be reviewed
as part of each operating cycle's core reload analysis.
Failing to maintain the Technical Specification required trisodium phosphate in
containment which would ensure that a ph of 7.0 or greater could be achieved following a
loss of-coolant accident is a violation. This nonrepetitive, licensee identified and
corrected violation is being treated as a noncited violation consistent with
Section V 11.B.7 of the NRC enforcement policy (50 285/9270-02).
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IV. Plandupport .
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R1 Radiological Protection and Chemistry Controls
R1.1 Tours of Radiolnalem!IV Controlled Areas
a. Inanection Scone (71750)
The inspectors performed frequent tours of the radiologically controlled area and
observed work practices of plant personnel,
b. Obseryall00s and FindlD91
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During this inspection period, the inspectors made frequent tours of the radiologically
controlled area. Radiation protection personnel were observed performing their duties in
a professional manner, Personnel performing maintenance in the radiologically-
controlled area were observed to be following all requirements of their radiation work
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permit.
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While touring Room 6 (Charg ng Pump Room) on December 24,1997, the inspectors
noted that the high radiation and contaminated area rope boundary around Charging
Pump CH-1C had fallen. The inspectors informed radiation protection personnel and the
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boundary was restored. Radiation protection personnel determined that duct tape had
been used to hold the rope ends that formed the boundary. The heat generated from the
operating charging pump caused the glue on the tape to melt and the rope boundary fell
down. The licensee initiated a condition report to document this occurrence. As part of -
the corrective action to close the condition report, the licensee was evaluating whether
the use of duct tape to establish radiation areas and contaminated areas was
appropriate.
c. Conclusl2DA
The inspectors identified a poor work practice in which duct tape was used in an elevated
temperature environment to construct a boundary around a high radiation area and
contaminated area. Plant workers exhibited good radiation protection practices.
R1.2 EDkjes into the Radioloolcally Controlled Area Without Electronic Dosimetry
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a. Insoection Scoos (71750)
The inspectors followed up on two instances in which security personnel entered the
radiologically controlled area without electronic dosimetry.
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b. Observations and Findinoj
On January 1,1998, a security officer entered the radiologically controlled area without
an electronic c:osimeter (ALNOR). The purpose of the entry was to perform fire door
checks. On January 10, another security officer entered the radiologically controlled
area without an electronic dosimeter. The purpose of this ent'y was to respond to a
security alarm. Neither of the security officers entered high radiation areas. Both of
these instances were identified by the licensee. In each instance, the officers were
excluded from the radiologically controlled area.
During interviews with the individuals involved, the licensee determined that one
individual needed additional radiation protection training.
As a corrective action, the officers involved were given verbal warnings and counseled
by licensee management. The occurrences were also discussed on plant human
performance day. The licensee identified three contributing causes for these
occurrences. The licensee stated that the occurrences were caused by lack of
personnel accountability, training deficiencies, and an unclear expectation for obtaining
electronic dosimetry by security officers. Security management Indicated that the
expectation for obtaining electronic dosimetry was being clearly defined. The radiation
protection manager indicated that they were considering reevaluating general employee
training to ensure that all plant workers are aware of the licensee's expectations with
regard to electronic dosimetry usage.
The inspectors reviewed Standing Order SO-G-101, ' Radiation Worker Practices," and
noted that Step 5.3.2F required personnel that entered the radiologically controlled area
be monitored with a direct reading or electronic dosimeter. Entering the radiologically
controlled area without a direct reading or electronic dosimeter is a violation. This
nonrepetitive, licensee-identified and corrected violation is being treated as a noncited
violation consistent with Section Vll.B.1 of the NRC Enforcement Policy
(50-285/9720-03).
c. Conchliions
A lack of personnel accountability, training deficiencies, and unclear expectations for
obtaining electronic dosimetry by security officers were identified as being contributing
causes for security personnel entering the radiologically controlled area without
electronic dosimetry. The actions taken by the licensee appear to be adequate to ensure
that entries into the radiologically controlled area are made with proper dosimetry.
V. Management Metilngs
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management on
January 20,1998. The licensee acknowledged the findings as presented.
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The inspectors asked the licensee whether any materials examined during the inspection !
period should be considered proprietary, No proprietary information was identifed. .
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ATTACHMENT l
SUPPLEMENTAL INFORMATION -
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- PARTIAL LIST OF PERSONS CONTACTED
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Licensee
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D. Buell, System Engineer
D. Dryden, Station Licensing Engineer
S. Gebers, Manager, Radiation Protection
B. Mierzejewski, Systems Engineer ,
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R. Phelpi,, Manager, Station Engineering
C. Schaffer, System Engineer
J. Sefick, Manager, Security
R. Short, Manager, Operations
4
INSPECTION PROCEDURES USED ,
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IP37551: Onsite Engineering
- IP 61726
- Surveillance Observations
IP 62707: Maintenana Observations
IP 71707: Plant Operations
IP 71750: Plant Support Activities
ITEMS OPENED. CLOSED. AND DISCUSSED i
Opened
50-285/9720-01 VIO use of operations memorandums to implement procedure
changes (Section 03.1)
,
Closed
50-285/9608-01 IFl replacement of Jacket water temperature control valve
(Section M8.1)
50 285/9707 03 IFl component cooling water leak (Section M8.2)
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50-285/9508 LER failure to maintain adequate trisodium phosphate inside
containment (Section EB.1)
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Opened and
Closed
50-285/9720-02 NCV failure to maintain adequate trisodium phosphate inside
containment (Section E8,1) _
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50 285/9720-03 NCV entry into the radiologically controlled area without electronic
l dosimetry (Section R1.2)
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