ML20202E076
| ML20202E076 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/28/1997 |
| From: | Barr K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20202D873 | List: |
| References | |
| FOIA-97-484 50-335-97-02, 50-335-97-2, 50-389-97-02, 50-389-97-2, NUDOCS 9802180061 | |
| Download: ML20202E076 (13) | |
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NUCLEAR REGULATORY COMMISSION
, , o REGION 11 101 MARlETTA STREET, N.W., SUITE 2900
$ ATLANTA, oEORGIA 3(BZH1CO February 28 1997 -- -
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SUBJECT:
RII 96 A 0192 - QUESTIONABLE HEALTH PHYSICS PRA -
N This refers to our letter dated September 26
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~ 'that'we would review the concern you expresse,d regarding release of1996,7 potentially proper contaminated water from the Radiation Control Area (RCA) without .
screening.
Our inspection regarding this matter has been completed and our fin' dings are documented in the enclosures to this letter. Based on the information provided, we were able to substantiate part of the allegation concerning the '
improper release of potentially contaminated oil and water.
regulatory requirements was identified. However, we were unable Onetoviolation of substantiate the concern that the oil and water separator was operated l improperly. Also, procedures were available to adequately control the material issue. This although someisprocedural allegation closed. enhancements were made in response to this This. concludes the staff's activities regarding this matter. If you have any questi.ns, at P.O. Boxyou 845,may contact Atlanta, me at 1 800 577 8510 or (404) 331 0335 or by mail GA 30301.
Sincer ly, 3
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Kenneth P. Barr, Chief .
Plant Support Branch . ,
Division of Reactor Safety / !
Cer_tified Hall No. L238 518 022 w RETURN RECEIPT REQUESTED
Enclosures:
- 1. Allegation Evaluation Report
- 2. Report Nos. 50 335/97 02 and 50 389/97 ~
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QUESTIONABLE HEALTH PHYSICS PRACT S !
This refer's to our letter dat'ed September 26, 1996, i hich we119dsed you
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c) that we would review the concern you expressed regar ng release of potentially contaminated water from the Radiation proper scre6ning. ntroVArea (RC % 31thout -
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Our inspection regarding this matter has bee completed and our findings are documented in the enclosures to this letter Based on the information provided, we were able to substantiate par of the allegation concerning the -
improper release of potentially contamin ed oil and water. One violation of .
regulatory requirements was identified . However, we were unable to *-
l substantiate the concern that the. oil,and water separator was operated improperly. Also, procedures were ailable to adequately control the . -
material although some pro,cedural, hancements were made.in response to this issue.
This concludes the staff's agt' ities regarding this matter. If you have any questions, you may contact me at 1 800 577 8510 or (404) 331 0335 or by mail at P.O. Box 845, Atlanta, 30301.
Sincerely,
~- '
/ Kenneth P. Barr, Chief ~
Plant Support Branch -
Division of Reactor Safety Certifie ' Hail No. Z 238 518 022 RETURN,ECEIPTREQUESTED .
En ,osures: 1. Allegation Evaluation Report
- 2. Report Ngs. 50 335/97 02 . . .
and Str389/97 02 bec w/encls: 0. Demiranda, EICS (Signed Letterhead & E Mail) a anfri ! Rff DRs Rff DRS Rf f ORP !
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NME FWight Kaarr CJulia DATE 02,J 77191 02 / / 91 02/$ 131 02 / $ 91 02 1 1 91 02 / / 91 COPY 1 k$) d) YES NO YI$ [NO) YES NO YES NO YES NO OttICl4 MELUKU COPY: t.105
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Febnaary 28, 1997 3
UESTIONABLE HEALTH PHYSICS PRACTICES
- N This refers to our letter dated September 26, 1996, in which we advised you that we would review the concern you expressed regarding releastrift' potentially contaminated water from the Radiation Control Area (RCA) without l proper scre,ening. _-
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.o Our inspect! ion regarding this matter has been complete & and our-findings are documented in the enclosures to this letter. Based on the information provided, we were able to substantiate part of the allegation concerning the improper release of potentially contaminated oil and water. One violation of regulatory requirements was identified. However, we were unable to i
substantiate the concern that the oil and water separator was operated' improperly. Also, procedures were available to adequately control the -
material although some procedural enhancements were made in response to this issue. This allegation is closed. .
This concludes the staff's activities regarding this matter. If you have any questions, you may contact me at 1 800 577 8510 or (404) 331 0335 or by mail at P.O. Box 845, Atlanta, GA 30301.
Sincerely.
(Original signed by K. P. Barr)
Kenneth P. Barr, Chief .
Plant Support Branch Division of Reactor Safety .
Certified Mail No. Z 238 518 022 .
RETURN RECEIPT REQUESTED .
Enclosures:
- 1. Allegation Evaluation Report '
- 2. Report Nos. 50 335/97 02
- and 50-389/97 02 bec7/encls: 0.Demirand,'EICS(SignedLetterhead&EMail) [
- For pervious concurrence see attached page
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- MMfurt* E COPIIS SM TO Ptatic'fvrturMT R00 i OFFitt RIf MS RI1 tR$ RI1:tRP
$1 GNAT 1JRE NAME FWright* h r CJulian*
DAYE 02 / / 97 h2/ L97 02 / / 97 02 / '/ 97 02 / / 97 02 / / 97 COPn YES NO YES ['NO) YES NO YES NO YE5 W YE5 NO Utt1Cl 4 Rd.URD COPY: EIC5
ALLEGATION EVALUATION REPORT ALLEGATION RII 96 A 0192 POTENTIALLY CONTAMINATED WATER FROM EMERGENCY DIESEL GENERATOR CATCHMENT IS RELEASED FROM RCA WITHOUT PROPER SCREEkING ST. LUCIE NUCLEAR PLANT DOCKET NOS. 50-335 AND 50 389 CONCERN:
- The conce ed individual expressed a concern about the following:
Potentially contaminated water from Emergency Diesel Generator (EDG) catchment is released from RCA without proper screening.
There were no health physics or chemistry procedures to control this material.
Improper use of oil separators, which are used to separate fuel oil and coolant from water.
DISCUSSION: Radiological Protection Controls The NRC inspection regarding the above concern is documented in NRC Inspectior Report Nos. 50 335/97 02 and 50 389/97 02, paragraph R1.2, 4
The inspectors reviewed licensee documentation, records of radiation surveys and sample analysis, Hechanical Maintenance (HH) and Radiation Protection (RP) procedures, and interviewed licensee personnel.
The inspector reviewed licensee Condition Report (CR) 96 2199 initiated August 2,1996, which was written for failure to comply with licensee procedures controlling release of material out of the RCA. On August 2, 1996.
Mechanical Maintenance (MH) personnel ) umped a wer and oil mixture from the Unit 2 diesel generator oil catchment )ox into 55 gal drums. The drums were to be taken to the turbine building where a separator was located for the
)urposes of separating the oil and water mixture. The te)arated water would
>e released into the site storm drains and the oil wculd x collected and placed into a used oil storage tank.
In accordance with licensee procedures the drums were required to be sampled and analyzed for radioactive contamination. If no radioactivity was detected in the samples, the drums could be removed from the RCA. On August 2, 1995.
HH personnel requested chemistry personnel samale the drums ard Health Physics (HP) survey the vehicle so it could leave the Radiological Control Area (RCA).
The drum samples were taken by chemistry and an HP technician surveyed the outer surfaces of the drums and the vehicle. The vehicle with the drums of oil and water mixture was permitted to leave the RCA before the drum saalple analysis were completed.
Enclosure 1
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RII 96 A 0192 Chemistry sent the results of the drum sample analysis to the HP department.
Later in the morning, at about 6:30 a.m., the HP Operations Su>ervisor analysis report and had the drums returned to the RCA. recognized the The HP Operations Supervisor actions. initiated a CR to investigate the problem and to develop corrective inspection, The drums have remained in the RCA during the January 27 31, 1997 Health Physics Procedure (HPP)
Revision 2, dated April 23, 1996 41, " Movement of material and Equi) ment,"
Health Physics personnel can exer,cise positive controlayof which materials anddescr equipment located in and leaving the RCA. Step 5.7 stated that t te free release of oil, liquids and bulk quantities 'f building or construction
, materials such as dirt and rock shall not be unconditionally released by use of gamma ray spectroscopy unless the samples are analyzed on a counting system and meet the environmental lower limit of deteruon limits contained in Chemistry Procedure C 200, Offsite Dose Calculation Manual.
Contrary to the above, on August 2, 1996, HP technicians permitted the free release of oil removed from the Unit 2 diesel generator catchment box without the analysis of samples to verify the oil did not contain radioactive material, prior to releasing the oil from the RCA was a violation of the licensee's ,
contamination control procedures.
In response to the violation the licensee held meetings with HP personnel to discus the issue. A policy letter was issued which required the HP technical supervisors to review and authorize the free release of radioactive materials from the RCA which are determined to be free of licensed material through the use of gamma spectroscopy analysis.
1996, to HP staff from the Radiation Protection Manager The(RPM).The letter policy letter w
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stated, " Approval of the release shall be by review and signature ap3roval of the radionuclide analysis report for the sam Tag after the RPM has signed the Blue Tag." ple and countersigning t1e Blue The licensee also revised General Maintenance Procedures 1 H 0018, Mechanical Maintenance Safety Related Preventative Maintenance Program, Revision 45 and 2 H 0018, Hechanical Maintenance Safety Related Preventative Maintenance Program, Revision 45. The revisions included HP signoffs for sampling and analysis of oil removed from oil catchment boxes.
There appeared to be several problems contributing to the violation. HP personnel failed to follow procedures for the free release of bulk materials:
there were poor communications between the Chemistry, HPs and HH personnel; and procedural guidance in HH instructions was poor.
The ins)ectors the turaine buildingwere unable oil to seaarate to and determine whether water mixtures the from theuse of the seaarators in Diesel Generator Building lad been improper. Emergency The licensee had not processed any 1996.liquid from the RCA in the separators foliawing the event on August 2.
separator Additionally, the RCA.
for use in the inspector lestned that the licensee had purchased a In the future, water from any oil and .;ater Enclosure 1
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RII.96.A.0192 separation will be processed by the Plant Radwaste Systems and the oil removed from the separator will be analyzed by gamma spectroscopy. If the oil it found free of radioactive contaminates it will be free released from the RCA.
This should eliminate the need to separate oil and water from the RCA outside the RCA in the future.
CGCLUSION:
" The inspector substantiated the inadequate survey concern and one violation of NRC requirements was identified. The inspector was unable to substantiate (1) tie concern that no health physics ot> chemistry procedures existed to control the material, and (2) the concern that the oil and water separator was operated improperly, i
This allegation is closed.
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4 Enclosure 1
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NUCLEAR REGULATORY COMMISSION S *'
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..... February 27, 1997 Florida Power and Light Company ATTN: Mr. T. F. Plunkett President Nuclear Division P. O. Box 14000 Juno Beach, FL 33408 0420
SUBJECT:
NRC INSPECTION REPDRT 50 335/97 02 AND 50 389/97 02
Dear Hr. Plunkett:
On January r'eactor 31, 1997, the NRC completed an inspection at your St. Lucie 1 an facilities.
ins >ection. The enclosed report presents the results of that wit 1 those members of your staff identified in the report.At the Areas examined during the inspection are identified in the report.Within these areas and represen,tative recorthe inspection consisted of selective examinations of pro activities in progress. ds. interviews with personnel, and observation of The enclosed Inspection Report identifies activities that violated NRC requirements that will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy.
of this letter and its enclosure will be placed in the NRC Room.
Sincer ly,
/ s Kenneth P. Barr, Chief Plant Support Branch Division of Reactor Safety Docket Nos. 50 335, 50 389 License Nos. DPR 67, NPF 16
Enclosure:
NRC Inspection Report cc w/ encl: See page 2
FPSL y cc w/ encl: Joe Hyers. Director J. A. Stall Site Vice President
' Division of Emergency Preparedness Department of Community Affairs St. Lucie Nuclear Plant 2740 Centerview Drive 6351 South Ocean Drive Tallahassee, FL 32399 2100 ft. Pierce FL 34957 H. N. Paduano, Manager Thomas R. L. Kindred County Administrator Licensing and Special Programs St. Lucie County Florida Power and Light _ Company 2300 Virginia Avenue P. O. Box 14000 ft. Pierce, FL 34982 Juno Beach, FL 33408 0420
~.
J. Scarola Plant General Manager 4
St. Lucie Nuclear Plant 6351 South Ocean Drive Ft. Pierce, FL 34957 ,
E. J. Weinkam Plant Licensing Manager St. Lucie Nuclear Plant -
6351 South Ocean Drive Ft, Pierce, FL 34957 H. S. Ross, Attorney Florida Power & Light 11770 US Highway 1 North Palm Beach, FL 33408 L
John-Tr Butler Esq.
Steel. Hector and Davis 4000 Southeast Financial Center Miami, FL 33131 2398 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahasseet FL 32399 0700
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U.S. NUCLEAR REGULATORY COMMISSION REGION 11 !
Docket Nos: 50 335, 50 389 License Nos: DPR 67. NPF 16 Report Nos: 50 335/97 02, 50 389/97 02 Licensee: Florida Power and Light Co.
Facility: St. Lucie Nuclear Plant, Units 1 and 2 Location: 6351 South Ocean Drive Jensen Beach, FL 34957 '
s Dates: January 27 31, 1997 Inspectors: F. Wright, Senior Radiation Protection Specialist G. Salyers, Emergency Preparedness Specialist '
Approved by: K. Barr, Chief. Plant Support Branch Division of Reactor Safety
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EXEClRIVE
SUMMARY
St. Lucie Nuclear Plant, Units 1 & 2 NRC Inspection Report Nos: 50 335/97 02, 50 389/97 02 This routine announced inspection of the licensee Radiation Protection (RP) program included aspects of the licensee's personnel dosimetry and contamination control programs.
Plant Suooort
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o Personnel were provided radiation monitoring devices in accordan:e with regulatory and licensee requirements (Section RI.1).
o The licensee centinued to improve controls for contaminated materials (Section R1.2).
o One Non Cited Violation (NCV) was identified concerning failure to survey potentially contaminated liquid released from the licensee's Radiation Control Area (RCA) (Section R1.2).
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Reoort Details IV. Plant Suooort R1 Radiological Protection and Chemistry Controls R1.1 Personnel Dosimetry Issuance (83750) a, inspection Scone Selected elements of the licenste's personnel dosimetry issuance progr were reviewed to verify 10 CFR Part 20 and licensee requirements for
- radiation monitoring were being implemented.
program was compared with the requirements of 10 CFR PartThe licensee 20.1502.
This progran myiew included observations made d of licensee records and procedures.
- b. Dbservations and Findinas The inspectors reviewed licensee personnel monitoring requirements specified inManual,"
Protection licenseeRevision procedures, 10 Health Physics (HP) 2,
- Radiation
- Personnel Honitoring.* Revision 6.and Health Physics Procedure (HPP) 30, The licensee defined " visitors," in Appendix 10. " Access to the RCA by Visitors " of HPP 30, as persons that required access into the RCA to perform short term work assignmersts and were not expected to receive more then 100 mrem exposure in a year. The inspectors evaluated the licensee procedures for monitoring " visitors" entering the RCA.
Thd licensee routinely issued Thermoluminescent dosimeters (TLDs) for occupational workers entering the RCA.
However, the licensee procedures permitted specifically authorized " visitors" to enter the RCA without a TLD provided the conditions specified in Apyndix 10, of HPP 30 were completed. The licensee's procedures permitted " visitors " which were non occupational workers, to enter the RCA without meeting all of the training and the monitoring requirements that occupational radiation workers were required to complete,
' Visitor" access in the RCA was restrictive. " Visitors" were not permitted access to high radiation areas, very hi airborne radioactivity areas, contan.inated areas,gh radiatinn areas, building, or spent fuel pool buildin reactor containment ,
Each " visitor" was assigned an Electronic Personnel Dosimeter (EPD)gs.while in the RCA and each " vi was escorted by a qualified radiation worker. The " visitor" dose as measured with the EPD was recorded on Form HPP 30,6. " Visitors RCA Entry Authorization." '
2 The inspectors verified that licensee
- visitors" entering the RCA were issued an EPD, their exposure recorded on Form HPP 30.6 exposure levii were within limits, and records were archived. The inspectors verified completed forms of HPP 30 were in the licensee's document control room he occupational dose limit of 500 mrem / term for declared pregnant workers apply only to women who receive occupational doses in the cours of employment in which the individual's assigned duties involve exposure The licensee utilized form HPP 30.7, " Access to thel
. Employees and Visitors," to document that a female had been provided a
__ copy of Regulatory Guide 8.13, " Instruction Concerning Prenatal Radiation Exposure."
The completed form also documented the " visitor" had read and understood reco"imendations of the Regulatory Guide 8.13 which informed a female of the potential health risks to an embryo / fetus from radiation exposure of the expectant mother. The inspectors noted that form10.
Appendix HPP 30,7 was not discussed or referenced in HPP 30, The inspectors inquired about the licensee's intent to have " visitors" review Regulatory Guide 8.13 since the title of Form HPP 30,7 included visitors.
The licensee reported that " visitors" were not occupational radiation workers and it was not nuessary for female
' visitors' to review Regulatory Guide 8.13. The inspectors concluded that there were no requirements for " visitors," as defined by the licensee's procedures, to review Regulatory Guide 8.13: however, informing non occupational female personnel of the risk to embryo / fetus from low levels of radiation would be a good practice. The inspectors communicated to licensee managenent that the title of Form HPP 30.7 implied that " visitors" were to use the form and comply with the requirements inconsistency.specified in the document, The issue was a procedural that the responsibilities for processing radiation workers and radiation workers
- visitor" into the RCA was not clearly defined in HPP 30. Licensee management stated the issues would be reviewed for additional clarification in procedural guidance.
As personnel entered the site, they obtained their assigned TLDs from the TLD storage racks in the security buildings. Personnel leaving the site returned their TLDs to the TLD storage racks prior to passing through the security exit portals. The licensee had been utilizing the process for approximately two years. The inspectors observed that a potential existed for someone to mistakenly remove another person's TLD from the TLD storage rack. The inspectors reviewed the licensee's controls to prevent an individual with the wrong TLD from entering the RCA.
The inspectors verified that the licensee's access control system required the worker to identify their TLD and RWP numbers prior to permitting the assignment of an individual administrative dose limits and the issuance of a functional EPD. The inspectors observed an HP technician test the RCA entry process at the RCA access control point by entering his TLD number, then scan the bar code on the inspectors TLD.
3 The access control system stopped the log in process and the system monitor indicated an error between the TLD number entered by the technician and the TLD number scanned.
individual to review and re enter the data.TheAtmonitor required that point, the be it would radiation worker's responsibility to determine whether they had the TLD s)ecificall T.D label. y assigned to them. The assigned individt,al's name is on the The ins)ector concluded that if an individual mistakenly removed the error priorwrong the to theirT.D from the entering the storage RCA. rack, the system would identify To enter the RCA with the
, incorrect TLD a worker would have to deliberately falsify access control information.
maintained a history of access errorsThe inspectors asked if the access co The licensee re
-- were not maintained because error mess. ages were common. Mostported of therecords errors resulted from a scanner failing to read all of the bar code or their TLD number.an individual striking a wrong number on the key pad while en Approximately 1,200 TLDs were issued at the site each month. At the first of the month. iew TLDs were issued and the previous month TLDs were collected.
in the racks at the end of the Themonth.The inspector reviewed licensee the maintained records for 1996, and noted that as the licensee personnel became accustom to de>ositing and removing their TLDs from the TLD storage racks, the numaer of TLD missing form the storage racks continued to decrease in 1996.
left TLDs on their hard hats or in their office. Host of the missing TLD we 3everal of these individuals were repeat offenders and corrective actions were taken toward the reaeat offenders by the licensee. In 1996, after the location of tae " missing" TLDs wcre resolved, the licensee had four (4)
TLDs that were lost out of approximately 14,400 issued.
Procedure HPP 30, Section 7.3, "EPD/TLD Discrepancy Investigations,"
required the licenset to investigate:
o Any monthly accumulated dose equal to or greater than 300 mrem in which the differential dose between the EPD and TLD is equal to or greater than 25 percent.
o Any monthly accumulated dose equal to or less than 300 mrem in which greaterthe thandifferential 60 mrem. dose between the EPD and TLD is equal to or The licensee performed investigations in 1996. approximately thirteen EPD/TLD discrepancy The inspector verified that the discrepancies were properly evaluated and appropriate dose assignments were made to radiation worker dose records.
During tours of the plant, the inspectors observed 3ersonnel wearing by the RWPs. appropriate monitoring devices on the location le body of t as specified l
4
- c. Conclusion The inspectors concluded that dosimetry issuance procedures were b '
implemented properly, individuals were using dosimetry correctly, and the verification measures within the RCA access control system were reasonable to prevent the unauthorized use of an individual's TLD, Possible improvenents in procedure HPP.30 were identified concerning access requirements for non. occupational radiation workers. However, no violations of regulatory requirements were identified.
R1,2 CM{tg]_oicontaminatedj9.terial (83750) a, irjsoection Scone i
The purpose of this inspection effort was to review implementation of licensee procedures for controlling clean and contaminated tools and radioactive contaminated materials.
This program review included the perfurmance of radiation and contamination surveys, observations made during facility tours, interviews with maintenance and rauiation review of licensee records and procedures. protection personnel, and b, Dbservations ardlindiDqi In 1996 the licensee experienced problems with tools having contamination in excess of the licensee's contamination limits. Tools were found outside the RCA with contamination above the uncondition relesse limits and tools were found inside the RCA hot tool rooms w contamination levels exceeding prescribed limits for use within the RCA.
The licensee had recently imple'nented additional contamination control
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- dea ~sures in response to cont 6mination control problems.and the inspectors reviewed the implementation and status of the various corrective actions.
To improve controls of tools and eq ipment leaving the RCA and tools within the RCA, the licensee had im lemented the following controls:
o Revision of the radiation survey policy to require Health Physics (HP) personnel to perform surveys of
- personal items" exiting the RCA:
o Assignment of a HP technician to monitor the primary RCA exit points on day shifts, Honday through Friday; o Use of video monitoring and recording equipment to monitor radiation workers exiting the Unit I and 2 RCA control points:
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- Increased clean tool room routine survey frequency from monthly to weekly:
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o Established a lower fixed contamination goal / limit of less than 10,000 dpm (direct frisk) for hot tool room tools; o
Cleanup, inventory and sorting of stockpiled tooling and equipment accumulated and stored following recent refueling outages; o
Reduce the amount of tools located in the RCA to permit a more thorough and efficient radiation and contamination surveys:
o Established a larger tool room to supply all the tools used in the RCA during non. outage periods:
o
. Assignment of a utility person to operate the tool room on day shifts, Honday through Friday; ,
o Established a Tool Task Team to address site tool control issues; and e
Conducted stand.down meetings with HP personnel to stress the importance of performing thorough unconditional release surveys.
While on site and during tours of the licensee's facilities, the inspectors looked for implementation of the licensee's corrective actions. In general, the ins)ectors found that the licensee was satisfactorily implementing tie aroposed corrective actions.
The ins)ectors observed that the num)er of uncontrolled tools, and the num)er of tools accessible to maintenance personnel within the RCA had been reduced.
HP technicians were assigned to monitor the primary RCA exits and were in the portal areas during da video monitoring equipment was operational. y shift and the licensee's The clean and hot tool rooms were inspected, Numerous radiation and
- contamination by the ins)ectors.surveys of tools and equipment in the facilities were made No contaminated tools were found in the clean tool room and t1e inspectors did not find any tools that exceeded the licensee's fixed contamination limits in the hot tool room. However, some confusion among the HP technicians concerning the fixed contamination limits for the hot tool room were observed. Several HP technicians reported the fixed contamination limits for the hot tool room were less than 10,000 dpm/ scan which was si mrem /hr limit stated in licensee the procedures.gnificantly below the 10 The ins)ectors found-several tools in the hot tool room at were in excess of tie 10,000 dpm/ scan, the highest being approximately 30,000 dpm/ scan. However, no tools were found in excess of the 10 mrem /hr limits specified in the licensee procedures. Technicians reported the tools the inspectors had found were in excess of hot tool room limits and the technicians removed the tools from the hot tool room. When this was brought to the httention of HP management the inspectors were informed that the 10,000 dpm value was only a guideline and not a limit. The inspectors reported to licensee management that the staff's understanding of the guideline or goal was not clearly evident as observed by their response to the inspectors findings. The inspectors reported that the purpose of the '
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6 guideline or goal should be clearly defined and understood by the HP staff. ;
The new hot tool room was larger, more organized and was generally controlled.
through Friday day shift.A utility worker was assigned to the facility on M The hot tool room door was locked with an electronic combination lock, but the combination appeared known to pl radiation workers and remained accessible to plant staff. The licensee and weekend shifts. continued to utilize an " honor system" for all work the
- honor system" was used twenty four hours per day.NR
- The inspectors improved but stillfound weak.the tool issuance and accountability process was that tool room personnel had been using to document The tool iss documentation was not orderly and the content and format of the information recorded was not consistent. In some cases there was no indication on the status or location of an issued tool.
system for toc) accountability had been planned during the previousA bar year, however, the process had not been implementation at the time of this inspection.
Many of the licensee's corrective actions for better control of contaminated material had been incorporated into written and controlled procedures.
However, the guidance for proper use of the hot tool room was not in controlled procedures. The guidance was documented in memorandums which were posted in several areas within the RCA .The advantages of describing owrations of the hot tool room in a plant.
document was discussed wit 1 licensee management. Howev had not determined that such a procedure was necessary.er, the licensee The inspectors reviewed selected Condition Re wrts (Crs) relating to the control of contaminated material. Licensee CT 96 2199 initiated August 2,1996, was written for failure to comply with licensee procedures controlling the release of potentially contaminated material out of the RCA.
The licensee's Emeroency Diesel Generators (EDGs)-are located within the licensee's RCA. Oil was periodically removed from the EDGs and collected into 55 gallon drums. Catchments in the EDG buildings which collected fluids such as oil and rain water were also periodically emptied into 55 gallon drums.
The drained fluids from the EDGs were considered any free of contamination, in that, they did not interface with mtential radiation contaminated systems. However, the EDG catc1ments were open to collect any fluids spilled in the EDG building and were not positively controlled. HP personnel analyzed and controlled the drained EDG fluids and the EDG catchment fluids differently.
When drained EDG fluids were released from the RCA. the HP procedures only required radiation and contamination surveys of the drums prior to their release from the RCA.
When the fluids from EDG
- catchments were released from the RCA. the HPs were required to sample the liquid contents to identify presence of any radioactivity.
7 Licensee procedure HPP 41, 'Hovement of Haterial and Equipment."
Revision 2, dated 04/23/96, personnel were to exercise described the means by which leaith Physics positive control of materials and equipment located in and leaving the 1CA.
following: The procedure, in part, required the o Step 5.1 Haterials and equipment removed from the RCA shall be properly surveyed prior to release from the area:
o Step 5.7 Free release of oil, liquids and bulk quantities of buildinc or construction materials such as dirt and rock shall n be unconditionally released by use of gamma ray spectroscopy
-- unless the samples are analyzed on a counting system and meet the environmental lower limit of detection limits contained in Chemistry Procedure C 200, Offsite Dose Calculation Hanual: and o Step 7.9 No material with a detectable activity shall be approved for unconditional release from the RCA.
Contrary to the above, on August 2, 1996 HP technicians aermitted the free release of EDG catchment fluids from the Unit 2 EDG auilding without first obtaining a gamma ray spectroscopy assessment of the drum fluids.
In August 1996, Hechanical Maintenance (HM) personnel pumped the contents of the Unit 2 EDG oil catchment box into 55 gallen drums that were loaded onto a flatbed truck. On August 2, 1996 HH requested Chemistry to sample the contents of the barrels in accordance with HH procedures.
Maintenance personnel also requested HP to survey the vehicle and drums in order to move the truck and its cargo outside the RCA, Chemistry personnel sampled the containers and HP personnel surveyed the exterior surfaces of the barrels and the truck. When the
- 16ntamination survey of the barrel surfaces was completed, HP survey personnel permitted the vehicle and its contents to exit the RCA. Later that morning chemistry personnel analyzed the samples for radioactivity and forwarded a copy of the analysis to HP operationa supervisor. At approximately 06:30 a.m., the HP operations supervisor recognized the catchment li procedures. quid had not been analyzed in accordance with licensee The truck and drums had been permitted to leave the RCA without a radiological assessment of the catchment fluids. The supervisor contacted HH and requested the vehicle and its contents be returned to the RCA. The HP staff initiated condition report 96 2199 to evaluate and correct the problems associated with the event.
Failure of HP yersonnel to properly analyze potentially contaminated liquids from tie RCA prior to authorizing their release from the RCA was identified as a violation 50 335/97 02 01,
- Failure to follow licensee procedures for survey and release of potentially contaminated material out of the licensee's RCA." This violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B of the Enforcement Policy.
1
8 In response 12/04/96 to: to the event, the licensee revised HPP.41 Revision 3 dated o
Better describe the counting capability and requirements for systems in liquids: used andto analyze low concentrations of radioactive material o
Limit the number of personnel authorized to approve the unconditional release of bulk materials.
The licensee also revised Unit I and 2 General Maintenance H 0018,
- Mechanical Maintenance Safety Related Preventative Haintenanc Related Preventative Haintenance Program," The revised Revision procedures added specific HF signoffs to:
o ,
Notify HP prior to commencing any oil pumriing operations in the RCA in order that contamination surveys of pumps, hoses, and drums can be made prior to the pumping operations: and o
Notify HP for sampling liquid from the oil catchment boxes, analyze samples for radioactivity and verify the liquid meets the criteria for uncontrolled release,as required by HPP 41.
The inspectors inquired about the disposition of the EDG fluids being released from the RCA. The licensee was taking the fluids from the EDG catchment to the turbint building for processing. The licensee utilized oil and water mixture. separators in the turbine building for the purposes of The separated water was routed into the site storm drains storage tank. and the oil would be collected and placed into a used oil '
po,nd located within the site's protected area.The storm drains em Followin 2,1996,g the premature release of the fluids out of the RCA on August the licensee decided to stop the release of EDG catchment fluids'from the RCA, and store the 55 gallon drums inside the RCA. The licensee had purchased an oil and water separator to separate the catchment fluids within the RCA. The water from the separation process would be be routed sampled to the for free plant radioactive waste systems and the oil would release.
The new separator had not been placed into .
service store theat the time fluids catchment of thewitinswetion and the licensee continued to 11n the RCA.
c, Conclusions As a result of the licensee's recent corrective action efforts, the inspectors concluded the licensee was continuing to im control of contaminated tools, equipment and material.plement better One non cited violation w6s identified concerning failure to follow licensee procedures for the survey and release of potentially contaminated material exiting the RCA.
1 9 X1 Exit Heeting Summary The inspectors
> resented the inspection results to members of-licensee management at tle conclusion of the inspection on January 31.1997. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
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10 PARTIAL LIST OF PERSONS CONTACTED ;
i Licensee ,'
4
~1 E. Benken, Licensirg Compliance Engineer ,
i H. Buchanan Health Physics Supervisor i B. Johnson, Dosimetry Supervisor J. Marchese, Maintenance Hansp r R. McCullers, Health Physics ,
J. Scarola, Plant General Man @agerrations Supervisor
! A, Stall, Site Vice President ,
L - - -
Dther licensee employees contacted included office o i
maintenance, chemistry, and health physics personne,l,perations, engineering, 1 4
+
. INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure -
ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50 335, 389/97 02 01 :
NCV Failure to follow licensee procedures for the release of potentially contaminated liquids from the licensee's Radiation Control Area (Section RI.2) '
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LIST OF ACRONYMS USED CFR Code of Federal Regulations CR Condition Report dm Disintegrations Per Hinute
' D)R EDG Demonstration Power Reactor Emergency Diesel Generators EPD FP&L Electronic Personnel Dosimeters Florida Power and Light HP Health Physics HPP Health Physics Procedures IP Inswetion Procedure HH Hec 1anical Naintenance NCV Non. Cited Violation NPF Nuclear Production Facility 4
' NRC Nuclear Regulatory Commission RCA RP Radiation Control Area
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ALLEGER 8 CONCERN N0
- ADDRass: ~
DOCENT N0:50-335/so-2st
.: DATE RcTD 10/3/08 NOME PMoME:( ) BurtoYxas l - WORK FRONE8( ) ,, TITLE _ , _
courIDantiaLITY angesst:0t Y m-M&MDETORY ADTIn" *T Y N l
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- I OLETI 111anar ~ o not know. tunt falt th .
- It wam unfalta.
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' FIERE IS IT LOCATED?
MIEM DID IT ocCURT i rug Is IwroLvmD/wIranssEo?
EDW/EEY DID IT OCCUR 7 m not wanto" I
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NRc to look into the nroblerna.
WERT EVIDEMCE CAN EE BraMTNED7_ Witnamnea _
DID TEE INDIVIDUAL REPRESS A CONCERN TO TEE LICENSEE 7 No. -he_' a concerned that thav vi11 f hrure out _ that he nada an allegation. ~
WHAT IS THE STATUS OF THE LICENSEE'S ACTIONS?_N/A ~
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Ask all above questions, do not leave any blanks. Complete one sheet for each issue. Forward this form tot nrT/ man. v.o. nor ads stianta. CA
,u101. Oo.not, retain any file copies subsequent to receipt by RAC.
RAC phoi.e numbers are 1404) 331-4193 & 331-4194.
PREPARED BYt D. Lanyl DATE PREPanung 10/3/96 9
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l September 26, 1996 Q
INDEXF0F CONCERNS i
_I it
- f. i
- - FACILITY 4 I 1 RII- 96-A--0192-e
NO. DESCRIPTION LOCATION ;
i 1/ POTENTIALLY CONTAMINATED WATER FROM EDG CATCHMENT IS Alleg Rpt RELEASED FROM RCA WITHOUT PROPER SCREENING, ALSO EXPRESSED CONCERN ON IMPROPER USF tv OIL SEPARATORS, Dele:
WHICH ARE APPARENTLY BEING USED TO SEPARATE FUEL OIL AND Page: .
COOL ANT FROM WATER. Para: 1 Hom:
4
- ACT10N: . LEAD DIVISION / BRANCH: ElCS TO CONTACT ALGR RE: REFERRAL TO l 3
LICENSEE, DRP (WITH DRS ASSISTANCE) TO REVIEW LICENSEE'S INVESTIGATION. 1 i
- CLOSI)RE
2/ Alleg Rpt l
Date:
Page:
)I ,
Para:
Item: .
< ACTION:
CLOSIJRE: - --
3/ Alleg Rpt 4 -
Date:
Page:
Para:
, item: ,
ACTION: '
CLOSilRE:
- 4/- Alleg Rpt Date:
- Page
Para: 1
- Item
i
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UCENSEE'8 IWESTIGATION WITH DR8 ASSISTANCE. EICS CONTACT ALOR. _
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DRS/PSB INSPECT BASED ON -
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Action 2 Acknowledgement Letter 9/2%6 9/26/96 *
, Deacdotion '
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INDEX OF CONCERNS Ril 1996-A 0192 Ril1994 A 0192 CONCERN 1 DESCRIPTION: POTENTIALLY CONTAMINATED WATER FHOM EDG CATCHMENT IS RELEASED FROM RCA WITHOUT PROPER SCREENING. ALSO EXPRESSED CONCERN ON IMPR3PER USE OF OIL SEPARATORS, WHICH ARE APPARENTLY BEING USED TO SEPARATE FUEL OIL AND COOLANT FROM WATER, The concemed individual expressed a co xern about the following:
Potentially contaminated water from Emergency Diesel Generator (EDG) catchnent is seieased from RCA without proper screening.
There were no health physka or chemistry procedures to control this material.
Imptopor use of oil separators, which are used to separate fuel oil and coo' ant from water, CLOSURE: The NRC inspection regt.rding the above ,oncem is documented in NRC Inspection Report Nos. 50-335/97 02 and 50 389/97 02, paragrsph Rt.2.
The inspectors reviewed licensee documentation, records of radiation surveys and sample analysis, Mechanical Maintenance (MM) and Radiation Protection (RP) procedures, and interviewed licensee personnel.
The inspector reviewed ;icensee Condition Report (CR) 90 2199 initiated August 2,1996, which was written for failure to comply with licensee procedures controlling release of material out of the RCA. On August 2,1999. Mechanical Maintenance (MM) personnel pumped a water and 03 mixture from the Unit 2 diesel generator olt catchment box into 55 gal drums.
The drums were to be taken to Se turbine building where a separator was located for the purposes of separating the oil and water mixture. The separated water would be released into the site storm drains and the oil would be collected and placed into a used oil storage tank,
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~
In accordance with heensee procedures the drums were required to be sampled and analyzed for radioactive contamination. If no radioactivity was detected in the samples, the drums could be removed from the RCA. On August 2,1996, MM personnel requested chemistry personnel sorriple the drums and Health Physics (HP) survey the vehicle so it could leave the Radiological Control Area (RCA). The drum samples were taken by chemistry and an HP technician surveyed the outer surfaces of the drums and the vehicle, The vehicle with the drums of oil and water mirture was pennitted to leave the RCA before the d um sample analysis were completed.
Chemistry sent the results of the drum sample analysis to the HP department. Later in the moming, at about 6:30 a.m., the HP Operations Supervisor recognized the drums had been released from the RCA prior to the drum sample analysis report and had the drums retumed to the RCA. The HP Operations Supervisor initiated a CR to investigate the problem and to develop corrective actions. The drums have remained in the RCA during the January 27 31, 1997 inspection.
Health Physics Procedure (HPP) 41
- Movement of material and Equipment,' Revision 2.
dated April't3,1996, described the licensee's process by which Heatth Physics personnel can exercise positive control of materials and equipment located in and leaving the RCA.
Step 5.7 stated that the free release of oil, liquids and bulk quantities of building or
. - e; i
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e lNDEX OF CONCERN 8 Ril-1996-A 0192
.)
constructen motorials such as dirt and rock shall not be unoanditionally released by use of comme rey spoetroconpy unises the temples are enelyzed on a counting erotem and rneet the envirornentallower limit of detection limits contained in Chemistry Procedure C-200, Offeite Does Calculeon Menuel. ;
Contrary to the above, on Au0ust 2,1996. HP techniciens permitted the free release of oil' ;
removed from tne Unit 2 dioeel generator catchment bos without the snelytis of semples to
{
verWy the pH did not contain radioactive motorial Failure of HP persorwel to analyse the -
contaminated oN semples prior to releasing the ou from the RCA was a vioisuon of the t
liconese's contamination control procedures -)
i in resporme to the vloisuon the licensee held meetings with HP personnel to checues the :
t leeue. A policy istler was leeued which required the HP technical supervincts to review and '
authorite the free rolenes of radioecove motorleic from the RCA which are determined to be i free of liconeed meterialitwough the use of pomme :; W+~ ;i analysis. The poNoy letter !
was deled October 4,1996, to HP staff from the Radiatlun Protection Manager (RPM). The -
letter stated,' Approval of the reisese shen be by review and signature approval of the redsonuchele snelysis report for the semple and countetsigning the Blue Tag afir*r the RPM ;
has signed the Blue Tog? i The licensee also revised General Maintenance Procedures 1 M 0018, Mechanical Maintonence Safety Related Proventative Maintenance Program, Revision 45 and 2 M-0018 -
Mechanical Maintenance Safety Related Preventative Maintenance Program, ReAsion 4 .
- The revisions included HP el0noffs for sempling end analysis of oil removed from oil catchment bones. ,
There oppsered to be several problems contributing to the violation. HP personnel failed to l follow procedures for the free release of bulk motorials; tiere were poor communications i
between the Chemistry HPs and MM personnel; and procedwal guidance in MM instructions ,
was poor.
J The inspectors were unebie to determine whether the use of the seperators in the turbirv3 building to separate oil and water mixtunes from tls Emergency Diesel Generator Building ;
. e hoo been improper. . The 16conese had not processed any hquid from the RCA in the !
separators following the event on August 2,1996. AddiHonelly, the insper. tor loomed that the licensee had purchened a separotor for use in the RCA. In the future, water from any oil and wolor separation win be processed by the Plant Radweste Systems und the oil remcved from the separator w6ll be snelyaed by gemme spectroscopy. If the oilis found free of rodeactive contaminates it will be free released from the RCA. This should ehminate the need to ;
separate oil and water from the RCA outside the RCA in the future. l r
'~ ;
CONCt.USiON: e i The inspector substantiated the inadequate survey concem and one tiolation of NRC r'
requirements was identified. The inspector was unable to substantiate (1) the concam thet no health physics or chemistry procedures existed to control the motorial, end (2) the concem that the oil and water separator was operated improperly.
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CASE NO: Ril-96 A 0192 FACILITY: ST. LUCIE OCCUPATIC EMPLOYER: FP&L
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/ DOL COMPLAINT: YES () NO ( /)
ERA NO: 01 INVESTIGATION: YES () NO (/)
01 CASE NO:
l ADDITIONAL INFORMATIONIOTHER CONTACTS I.
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- Plant employees tietng used to supeent tbg security force following the discovery of tesgering in keyJock switches are -
ret tralned for the activity. They have ret teen told What to look for, who to report to, or how terteport (redios were not estigned). , e ,_
WHAT l$ IHt"Rt0V!REMENT/V10LAtl0W7 Urtlear WtiLRf l$ li LOCAftD?
Selected locatione throughout plant.
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geginning 8/14/96.
WitQ 15 lWOLVED/VliWi$$[D?
@ liaW/M!it DID 11 OCCUR?
r[S w( $ (m Plan hostily put together, expectatione nevered transmitted to workers.
WHAT.EYJDIRCI CAN 8t ikAMlWED?
None other then interviews.
DID THE INDIVIOUAL EXPRfl$ A CONCERN 10 THE LICtW$tt?
Tee, their supervisor.'* Did not help. .
WW is THE STATU$ OF THE LICEN$tt's ACil0N$?
L{censee eventually developed a list of expectations, but ellegers stated that it was not detailed above and retterated that they were tot trained for the activity.
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Alleget ote eli.Ser thformed requeetofwri,ione Whc identity t e n eyprot,ection po!!cyt... v uv.x use the eneau a. sect to e ascenses/et.to evenett... v wu .mo Was the elleget inf ermed of Dot reporttag requirementet YKx k_
mId' _ogdgtyd s agu,e r seg e_Act,ivitn otheri (alRX asectet t ( Vender (c)_ Materiale i Ask all above questicos, do set leave any blante. Complete cae 6neet for each taeue, rotward this fers toi eJt/ sac, e.o. nov
( ets Atlaeta g 90901. Do not totata ar., file copies subsequest to receipt by SAC.
l IAC phone numbers a re (est) 891-4105_s 391-41o4.
l PREPARfD BYt Mark S. Miller DAtt PRtPARfD 8/15/96 l
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'ALLEGERWDDRESS: q (ni) CHANGE OF ADDRESSM.
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WORK PHONE:( )
WORK PHONE: ( )
CASE NO: Ril 96 A 0175 FACILITY: St. Lucie OCCUPATION: EMPLOYER: Florida Power & Light Company _f DOL COMPLAINT: YES ( ) NO (x) 01 INVESTIGATION: YES ( ) NO (Q ERA NO: 01 CASE NO: -
l ADDITIONAL INFORMATIONIOTHER CONTACTS .
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CASE NO: Ril 96 A-0175 FACILITY: St. Lucie
- OCCUPATION
- EMPLOYER: Florida Power & Light
! Company l DOL COMPLAINT: YES ( ) NO (x) 01 INVESTIGATION: YES () NO (4
- j ERA NO: 01 CASE NO: -
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,,, ADDITIONAL INFORMATIONIOTHER CONTACTS -
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CASE NO: Ril 96 A 0175 FACILITY: St. Lucie OCCUPATION: EMPLOYER: Florida Power & Light Company DOL COMPLAINT: YES ( ) NO (x) OlINVESTIGATION: YES () NO ([
ERA NO: 01 CASE NO: -
ADDITIONAL INFORMATION/OTHER CONTACTS .
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UNIT!D STATES '
' /'" gap 28sg% NUCLEAR REGULATORY COMM SSION
& $ REll0Nll
$ $= 101 MARitTTA STREET. N.W., Sulf E 2900 11
%, j' ATLANTA, GEORGIA 303:34190
- S&nMBER 29, 1996
. N,
SUBJECT:
ALLEGATION RE90RT III-96-A-0175 O (t ~7 o
) ". -
7f-This refers to-our ' letter dated August 23, 1996, in whf67tyou were informed that we had initiated an inquiry into the concern you reported with respect to failure to receive proper briefing on required actions in augmenting the security force at Florida -
Power and Light Company's St. Lucie facility. ,
Our review regarding this matter has been completed, and our -
findings are documented in the enclosure to this letter, based '
on the info:cmation provided, we were able to substantiate your concerns, however; there were no violations of regulatory requiremento noted.
This concludes the Staff's activities regarding this matter. If you have any questions, you may contact me at 1-800-577-8510 or (404) 331-5596 or by mail at P. O. Box 845, Atlanta, GA 30301.
Sincerely, s -
,, .4 M %
Paul E. Fredrickson, Chief ~
Special Inspection Branch Division of Reactor Safety -
Enclosures:
- 1. Allegation Evaluation Report '.
- 3. Portion of Inspection Report No. 50-335/389/96-16 Cettttied Mail Numbert P 257 835 252 -='
RETURN RECEIPT REQUESTED .
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l ALLEGATION EVALUATION REPORT ALLEGATION NUMBER RII-96-A-0175 FAILURE TO PROPERLY TRAIN INDIVIDUALS FOR SPECIAL DUTIES FLORIDA POWER AND LIGHT COMPANY
. 1 ALLEGATION:
Plant employees being used to augment the security force following the discovery of tampering with key lock switches are .
not trained for the activity. They have not been told what to l look for, who to report to, or how to report (radios were not assigned).
DISCUSSION: -
As a result of the lock tampering event on August 14, 1996, the licensee assigned Protection Services (PS) personnel to areas within the plant as a preventative measure to detect or prevent further tampering. On August 14, 1996, after approximately six hours PS personnel were replaced by individuals from the Maintenance Section. The inspectors observed these individuals during performance of their duties oi. August 15, 1996, and noted that they were walking or sitting in areas throughout the plant.
During discussion with these individuals they.related that they were not properly trained for this type function and had not received adequate instructions orior to being assigned these duties. The inspectors were informed by the licensee that initial 4y prior to being assigned observer duties that the individuals were verba]ly instructed to " observe personnel entering the area and that if anything appeared suspicious to notify security." A licensee supervisor stated that when his day shift personnel were being sent to post that he had informed them "to stay in their areas and to receive a briefing from the person they replaced." On August 15, 1996, the licensee provided the observers with a written flyer as instructions. The inspectors obtained a copy of the flyer and noted that it stated the following: " Question the activities that are going on in their area of surveillance / responsibility; ensure observations of these activities is frequent and random; ensure that the people working in these areas feel that they are under surveillance; this will ensure that the observers presence would prevent tampering with equipment; and, should the patrol of ficers/ observers encounter any personnel or activities thac do not appear proper, contact the Security Operations officer." The observers stated that although they had been provided written instructions that the instructions were not adequate. At approximately 5:30 p.m.,
August 15, 1996, the licensee deleted the observer function.
D C WSURE 1
- , . , 7. -: . -
' CONCLUSION:
Based on-the!information provided the allegation was substantiated, however; there were no: violations of regulatory requirements noted in this area. The. inspectors deteemined that the observer duties had been established by managemer.1 as an immediate_ action to potentially deter additional tampeting with
- equipment. It appears that. upper management had expected the individuals to receiva proper instructions before they were-assigned the additio.a1 duties, however; it appears that the expectations.were not conveyed to the supervisors and in their
-eagerness to follow management's direction to post observers-in the plant, they failed to ensure that proper instructions were provided. -
l
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UNITED STATES .
/pS 48v9*o,, NUCLEAR REGULATORY COMMISSION e p , MEIlON 11 l
e o 101 MA~,lETTA STREET. N.W., SUITE 2900 l ATLANTA. GEORGIA 3GI2M190
% , , , , , +# SEPTEMBER 29, 1996 _ __.
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lo cFR Z1pXdNM ~
lo CFIZ 2 *19'> @)((p)
% SUBJECT' ALLEGATION REPORT I-96-A-0175 T.
h .
~
This refers to our-letter dated August 23, IgtJ6, in wh M _you Q &e informed that we had initiated an inquiry into the concern you reported with respect to f ailure to receive proper briefing on required actions in augmenting the security force at Florida ~
Power and Light company's St. Lucie facility. ,
Our review regarding this matter has been completed, and our findings are documented in the enclosure to this letter, based -
on the information provided, we were able to substantiate your concerns, however; thers were no violations of regulatory requirements noted.
This concludes the Staff's activities regarding this matter. If you have any questions, you may contact me at 1-800-577-8510 or (404) 331-5596 or by mail at P. O. Box 845, Atlanta, GA 30301.
Sincerely, e ,
9 - d J s.v) A% _
Paul E. Fredrickson, Chief -
Special Inspection Branch Division of Reactor Safety .
Enclosures:
- 1. Allegation Evaluation Report ',
- 2. Portion of Inspection Report No. 50-3~6/389/96-16 Cert _ified' Mail Number.: Z 238 518 219 -
RETURN RECEIPT REQlfESTED ,
uuuun in (n.s rea.-d wn gn g Act. exem tions."7 #fin acccidan:e uith the Freadoin of int 08 FolA gj y l ,
WGEc)(CN '
-530
ALLEGATION EVALUATION REPORT ALLEGATION NUMBER RII-96-A-0175 FAILURE TO PROPERLY TRAIN INDIVIDUALS FOR SPECIAL DUTIES FLORIDA POWER AND LIGHT COMPANY ALLEGATION:
Plant employees being used to augment the security force following the discovery of tampering with key lock switches are not trained for the activity. They have not been told what to look for, who to report to, or how to report (radios were not assigned).
DISCUSSION: -
As a result of the lock tampering event on August 14, 1955, the licensee assigned Protection Services (PS) personnel to areas within the plant as a preventative measure to detect or prevent further tampering. On August 14, 1996, after approximately six hours PS personnel were replaced by individuals from the Maintenance Section. The inspectors observed these individuals during performance of their duties on August 15, 1996, and noted l that they were walking or sitting in areas throughout the plant, i
During discussion with these individuals they-related that they were not properly trained for this type function and had not received adequate instructions prior to being assigned these I duties. The inspectors were informed by the licensee that initially prior to being assigned observer duties that the individuals were verbally instructed to " observe personnel entering the area and that if anything appeared suspicious to notify security." A licensee supervisor stated that when his day shift personnel were being sent to post that he had informed them "to stay in their areas and to receive a briefing from the person they replaced." On August 15, 1996, the licensee provided the observers with a written flyer as instructions. The inspectors obtained a copy of the flyer and noted that it stated the following: " Question the activities that are going on in their area of surveillance / responsibility; ensure observations of these activities is frequent and random; ensure that the people working in these areas feel that they are under surveillance; this will ensure that the observers presence would prevent tampering with equipment; and, should the patrol officers / observers encounter any personnel or activities that do not appear oroper, contact the Security operations Officer." The observers stated that although they had been provided written instructions that the instructions were not adequate. At approximately 5:30 p.m.,
August 15, 1996, the licensee deleted the observer function.
i ENCIOSURE 1
- ._ - . . _. . _ . . . -_ ~ ..
.. .. e CONCLUSION:
Based en'the information provided the allegation was substantiated, however; there were no violations of regulatory requirements noted in this area. The inspectors determined that the observe.r. duties had been~ established by management as an immediate action to potentially deter additional tampering with equipment.- It appears that upper management.had expected the individuals to receive proper instructions before they were assigned the additional duties, however; it appears that the expectations were not conveyed to the supervisors and in their eagerness to follow management's direction to post observers in the plant, they failed to ensure that proper instructions were provided.
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9 UNITED STATES -
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NUCLEAR REGULATORY COMMISSION s O ^
REGION ll 7 o 101 MARIETTA STREET N.W., SUITE 2900 E j ATLANTA. GEORGIA 30323 0190
/ SEPTDiBER 29, 1996
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SUBJECT:
- ALLEGETION REPORTII-96-A-0175 --
.This refers to'our l'etter dated August 23,'1I96, in W111"th _ you were informed that we had initiated an inquiry into the concern you reported with respect to failure to receive proper briefing on requited actions in augmenting the security force at Florida _
Power and Light Company's St. Lucie facility. ,
Our review regarding this matter has been completed, and our _
findings are documented in the enclosure to this letter. based -
on the information provided, we were able to substantiate your concerns, however; there were no violations of regulatory requirements noted.
This concludes the Staff's activities regarding this matter. If you have any questions, you may ccntact me at 1-800-577-8510 or (404) 331-5596 or by mail at P. O. Box 845, Atlanta, GA 30301.
Sincerely,
+1 q . ; IN .
Pau E. Fredrickson, Chief "
Special Inspection Branch -
Division of Reactor Safety .
Enclosures:
- 1. Allegation Evaluation Report '.
- 2. Portion of Inspection Report No. 50-335/389/96-16 Certifie'd' Msil' Number: P 257 835 250 =
RETURN RECEIPT REQUESTED .
Informallo 1 in (M rGord Ned WB5 d9
^
ct a e IBedom of Information EDIA Y')o-th9 y .-
asnw w
4 ALLEGATION EVALUATION REPORT ALLEGATION NUMBER RII-96-A-0175 FAILURE TO PROPERLY TRAIN INDIVIDUALS FOR SPECIAL DUTIES FLORIDA POWER AND LIGHT COMPANY ALLEGATION:
Plant employees being used to augment the security force-following the discovery of tampering with key lock switches are not trained for the activity. They have not been told what to look for, who to report to, or how to report (radios were not assigned).
DISCUSSION: ^
- As a result of the lock tampering event on August 14, 1996, the licensee assigned Protection Services'(PS) personnel to areas
-within the plant as a preventative measure to detect or prevent further tampering, On August 14, 1996, after approximately six hours PS personnel were replaced by individuals from the Maintenance Section. The inspectors observed these individuals during performance of their duties on August 15, 1996, and noted that they were walking or sitting in areas throughout the plant.
During discussion with these individuals they.related that they were not properly trained for this type function and had not received adequate instructions prior to being assigned these duties. The inspectors were informed by the licensee that initialty prior to being assigned observer duties that the individuals were verbally instructed to " observe personnel entering the area and that if anything appeared suspicious to notify security." A licensee supervisor stated that when his day shift personnel were being sent to post that he had informed them ato stay in their areas and to receive a briefing from the person they_ replaced." On August 15, 1996, the licensee provided the observers with a written flycr as instructions. The inspectors
- obtained a copy of the flyer and noted that it stated the following: " Question the activities that are going on in their area of surveillance / responsibility; ensure observations of these activities is frequent and random; ensure that the people working in theae areas feel that they are under surveillance; this will ensure that the observers presence would prevent tampering with equipment; and, should the patrol officers / observers encounter any personnel or activities that do not appear proper, contact the Security Operations Officer." The observers stated that although they had been provided written instructions that the instructions were not adequate. At approximately 5:30 p.m.,
August 15, 1996, the licensee deleted the observer function.
ENCLOSURE 1
{
1
- . _ ,.- . - .-_.- . . _ ~ . . , , . . . . ~ - - . - . . . -. .. - .... _ _ .. . . . .- .- - - . . .
,:._r 4 .'e .
' '.- ' CONCLUSION i
. Based on the information provided the allegation was i
-substantiated, however; there were no' violations of regulatory requirements noted in this area. The~ inspectors determined that
- the observer duties had been estabJished by management as an
~ immediate action to potentially_ deter additional tampering with equipment. It appears that upper management had expected the !
- ' -individuals to receive proper instructions _before_they were.
assigned the additional duties,-however; it appears that the 7 expectations were not conveyed to the supervisors and in their
- eagerness to. follow management's direction to post observers in i the plant, they failed to ensure that proper--instructions were
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ALLEGATIONOREPORT" .
CASE FILE NO: 78-A - OC38_-
, ' ALLEGER CONCERN NO: ' ~~
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DATE RCVD: 2/Jr/ft i EMPLOYER ..-
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WHAT IS M 5$ AN ISSUE OFT SAFEGUARDS DRUGS FEtSIFICATION (CIRCLE ONE)
- DISCRIMINATION OTHER Ask all above questions, do not leave any blanks. Complete one sheet for each issue. Forward this form to: RII/RAC, P.O. BOI 845 Atlanta. GA_ '
30301. Do_not retain any file copies subsequent to receipt by RAC.
'RAC phon,e numbers are 14041 ,331-4193 & 331-4194.
i
+* ADVISE ALLEGERS OF THE 3 80 DAY DOL REPORTING REQUIREMENT FOR DISCRININATION COMPLAINTS - (INITIAL) YES , NO i --
11 fdP:MEMED:Mt..(A6D g 4 /-)f/(g7 DATE PREPARED: .2[27[M, fk in a:::dme with Me FMesum I 7'
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ALLEGATION REPORT ~
CONTINUATION. SHEET'
. 1 CASE FILE NO: /23-ff-A-CO3 $ FACILI m .ST UN./# '
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ADDITIONAL INFORMATION
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' UNITED STATES '
[m tsow%S NUCLEAR REGULATORY COMMISSION
' & REQeDN11 3 o 101 MARIETTA STREET. N.W., SUITE 2900 3 J ATLANT A. oEoRGIA 30323-0199 k / MAY 2, 1996 -
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Subject:
- Ril-96-A-00 f to cM 13Rc(m e
- OUTDATED PROCEDURES MAY BE USED FOR MAIRTENANCE l
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Ihis refers to our letter dated March 26, 1996, inwhicnyouwerEIEformed that we were continuing our review of the concerns you expressed on
' February 27, 1996, to Mr. Fred N. Wright of our staff regarding procedure control practices at the St Lucie Nuclear Power Plant.
Our review regarding this matter has been completed, and our findings are documented in the enclosures to this letter. Based on the information -
provided, we were able to substantiate your concerns partially. .
This concludes the staff's activities regarding this matter. If you have any questions, you may contact me at 1-800-577-8510 or by mail at P.O. Box 845, Atlanta, Georgia 30301.
Sincerely,
~ k - ld 0, %
h istensen, Chief
/
I
~L Maintenance ranch u Division _of Reactor Safety -
Enclosures:
- 1. Allegation Evaluation Report
- 2. Inspection Report No. 50-335,389/96-04 '
Certified Mail No. Z-238-555-250 -
RETURN RECEIPT REOUESTFD L
- '! Mica b tb i::::d was deleted
- a 3;Cordan:3 wdh the Freedom olInformation ACI. e tions 7/
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ALLEGAT10W EVALUATION REPORT ALLEGATION Ril-96-A-0035 0UTDATED PROCEDURES M7,Y BE USED FOR MAINTENANCE ACTIVITIES ST LUCIE NUCLEAR PLANT 00CKEf NOS. 50-335 AND 50-389 ALLEGATION:
The alleger stated that he had a concern related to procedure control practices at the St. Lucie Nuclear Plant. The alleger's concern was based on personal experience that outdated procedures are available for maintenance activity use procedure appropriate and that personnel revision. on backshifts may not be able to verify DISCUSSION: '
_ 4 1.
During observation of maintenance activities the inspector went with craftsmen to the north service building where they had been instructed to go to verify that the procedures they were using were the appropriate revisions. The requirement for the procedure user to verify that the correct revision of the procedure is found in paragraph 4.5 of Document Control Procedure No. Q16-PR/PLS-1 and the maintenance On work orders.
one occasion Revision 14 of Procedure M-0043, which the planner had furnished in the maintenance package, was found not to be the current revision and the index for all the procedures in the cabinet was not being maintained as instructed on the cover sheet of the index. The inspector also noted that the doors to the room where the procedure cabinets were kept had locks on them, which indicated that limited
" access could be established for this room. However, the inspector found that the index was not a control document and the procedures in the '
cabinets were control copies of the )rocedures. Therefore, the procedures superseded the index in tie order of use.
As a result of the aLove findings and questions addressed to management concerning the adequacy of document controls the licensee issued two STAR Action Reports (Nos. 960456 & 7). Management's attention was then focused on appropriate corrective actions and the following measures were implemented, 611 maintenance groups gow will use only one new centralized
-library in the North Service Building. This library has an attendant manning it and updating control procedures for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a day. The room where the library is located has also had the locks removed from the doors in order that no backshift personnel are excluded from using the facility.
V
, . o3-1 2
The document index cover sheet has been revised to insure that this uncontrolled document is not used for procedure status except on the date indicated on the cover sheet.
When planners now verify procedure revisions during the planning stage they will double stamp the procedure and only sign one verification block. This will require the user to also verify the procedure.
An up-to date procedure index will be established for all on-line computers by approximately August 1996. When this enhancement is fully-imalemented, the index will supersede all documents for establis11ng procedure status. All plant personnel will have access to the index at that time.
- 2. This issue was reviewed during an NRC inspection conducted March 25 29, 1996 and documented in Inspection Report No 50 335,389/96-04. This report is attached, and the specific allegation is addressed in general -
in paragraph M3,2
Conclusion:
The allegation was in part substantiated in that document control weaknesses were identified. -There were no violations or deviations from regulatory requirements because the inspector did not find any example were the control copies of the procedures in the cabinets were not the correct revision to i perform the work. In addition, the procedure user was required by Procedure No Q16-PR/PSL-1 (Document Control) to verify the correct revision and to reconcile any difference with the procedure before using it. The inspector observed that maintenance personnel knew these requirements and were conforming with to them. Corrective actions taken by the licensee however,
~ should provide significant improvements in the control of procedures.
~
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4 ENCLOSURE 1
ora iaf: DOM 562 4766 Feb 6 '98 11:25 P. 28 l
Mny 4,1996 .
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CASE NO: Ril-96 A.0036 FACILITY: St. lucie ,
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DOL COMPLAINT: YES () NO (/) Of INVESUGATION: YES () NO (/)
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