ML20216F272
| ML20216F272 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/23/1987 |
| From: | Hosey C, Kuzo G, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20216F207 | List: |
| References | |
| 50-424-87-35, IEC-81-07, IEC-81-7, NUDOCS 8706300837 | |
| Download: ML20216F272 (10) | |
See also: IR 05000424/1987035
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NUCLEAR REGULATORY COMMISSION:-
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101 MARIETTA STREET, N.W.. SulTE 2900
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ATLANTA, GEORGIA 30323
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Jim 2 31987
-Report No._: ;50-424/87-35-
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. Licensee: . Georgia' Power Company'-
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-P..O.. Box 4545
Atlanta, GA' 30302.
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Docket Nos.: 50-424~
License Nos.:
NPF-68-
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Facility Name: Vogtle
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Inspection Conducted: .May 18-22, 1987
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Inspectors: '
N
R. E. JWeddingtorO
Date Signed
4,bh1ni
23 h 1993
G.-B.Kgzo.
Date Signed
- Approved by: kA')
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C. M. Hosey, Sectidn Chief
Date Signed
' Division of Radiat' on Safety and Safeguards
SUMMARY
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Scope:
This special unannounced inspection was . conducted in the areas ' of
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allegation followup and startup shield verification radiation surveys.
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Results:: Two violations were . identified: -(1) failure to conduct adequate
startup : shield verification radiation surveys and (2) failure to Ldocument.
corrective actions for deficiencies.
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REPORT DETAILS
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1.
Persons. Contacted
Licensee Employees
- T. Greene, Plant Manager
- P. R. Bemis, Manager, Engineering, Maintenance and Operations and
Radiological Safety
- S. C. Ewald, Manager, Radiological Safety
- A. E. Desrosiers, Health Physics Superintendent
- W. C. Gabbard, Senior Regulatory Specialist
- K. W. Whitt, Generation Engineer
- D. Smith, Construction Engineer
- D. Smith, Superintendent, Nuclear Operations
- C. C. Miller, Superintendent of Outages and Planning
- R. M. Odom, Supervisor, Nuclear Safety and Compliance
- P. D. Rushton, Training and Emergency Preparedness Manager
- J. N. Roberts, Emergency Preparedness Supervisor
- L. E. Mayo, Emergency Preparedness Specialist
- R. M. Bellamy, Plant Support Manager
- W. F. Kitchens, Operations Manager
- W. E. Mundy, Quality Assurance Supervisor
- D. F. Hallman, Chemistry Superintendent
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- P. H. Burwinkel, Engineering Supervisor
- C. E. Belflower, Quality Assurance Site Manager
- J. M. Randolf, Plant Engineer
- S. R. Edwards, Operations Engineer
- G. R. Frederick, Quality Assurance Engineering Supervisor
- M. Griffis, Maintenance Manager
- W. L. Burmeister, Operations Supervisor, Startup
J. Brenenborg, Health Physics Foreman
G. Fussell, Health Physics Specialist
I. Kochiri, Health Physics Specialist
B. Turpin, Startup Test Supervisor, Shield Surveys
M. Sheibani, Nuclear Safety and Compliance
K. Duquette, Health Physics Foreman
Other licensee employees contacted included cunstruction craftsmen,
engineers, technicians, operators, and office personnel.
Nuclear Regulatory Commission
- J. Rogge, Senior Resident Inspector
J. Livermore, Senior Resident Inspector (Construction)
- R. Schepens, Resident Inspector
- Attended exit interview
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2.
Exit Interview (30703)
The inspection scope and findings were summarized on May 22, 1987 with
those persons indicated in Paragraph 1 above.
The following issues were
discussed in detail:
(1) an apparent violation concerning inadequate
shield verification surveys (Paragraph 4) and (2) an apparent violation
concerning failure to document corrective action (Paragraph 6).
Licensee
representatives acknowledged the inspection findings and took no
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exceptions.
The licensee did not identify as proprietary any of the
materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Radiation Protection - Startup (83521)
10 CFR 20.201(b) requires surveys to be made as may be necessary to comply
with 10 CFR Part 20 and are reasonable under the circumstances to evaluate
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the extent of radiation hazards that may be present.
Final Safety
Analysis Report (FSAR) Sections 14.2.3 and 1.9.68.1 commit the licensee to
conformance with Regulatory Guide (RG) 1.68, Initial Test Programs for
Water Cooled Nuclear Power Plants, August 1978.
RG 1.68, Appendix A,
Section 5.b.b requires the performance of neutron and gamma radiation
surveys at 50 and 100% power levels to establish the adequacy of shielding
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and to identify high radiation zones as defined in 10 CFR Part 20,
Standards for Protection Against Radiation.
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The inspector discussed with licensee representatives the administrative
organization and scheduling of the Unit 1 startup test program.
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Operations Manager had overall responsibility for the startup test program
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during power ascension.
The Operations Supervisor, Startup and the Shift
Test Directors were responsible for ensuring the performance of the test
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programs.
Individual startup tests were conducted by test supervisors who
reported to the Shift Test Directors.
A radiological survey test
supervisor was temporarily reassigned from the health physics group to
develop and implement the startup radiological survey procedures.
The
inspector reviewed the Test Supervisor's training records and determined
that he had completed the licensee's startup test supervisor training and
qualification program.
The inspector reviewed and discussed the following radiological protection
and startup survey procedures with licensee representatives:
SUA-03, Startup Shift Test Director and Test Supervisor Qualification
Checklist, Rev.1, December 3,1986.
1-600-05, Biological Shield Survey, Rev. 2, February 5,1987.
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4300-C, Radiation Surveys, Rev. 2, July 10, 1986.
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43500-C, Health Physics Instrument Calibration and Control Program,
Rev. 13, May 14, 1987.
The procedures designated the establishment of Radiation Base Point (RBP)
locations in the containment and auxiliary buildings.
For each RBP
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procedures required gamma and neutron measurements.
The inspector
interviewed health physics technicians who had conducted the 50% power
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plateau shield survey.
Survey personnel stated that they had performed
direct gamma and neutron surveys at contact for each RBP and had then
backed away from the wall and had rotated 360 degrees while holding the
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survey meter at waist height.
They then walked to the next RBP while
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observing their survey instruments.
Surveys of horizontal shield
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surfaces, for example, flooring above pipe chases in the Auxiliary
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Building, were not conducted.
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The inspector reviewed the startup radiation survey data sheets which
documented the survey results.
In addition to the 50% power level,
surveys had been conducted prior to startup to establish a background
baseline and had been performed during power ascension at the less than
5%, 30%, and 75% power levels. The final 100% power level survey had not
been performed at the time of the inspection.
Each of the surveys had
been reviewed by the Test Supervisor and signed off that the results were
acceptable and that power ascension could proceed.
The inspector discussed with licensee representatives the criteria that
had been used in developing the startup survey procedures.
Licensee
representatives stated that they were not familiar with any vendor shield
verification survey procedures or any industry standards on the subject.
The inspector reviewed with licensee representatives ANSI /ANS 6.3.1-1980,
Program for Testing Radiation Shields in Light Water Reactors, which
provides detailed guidance on the performance of shield surveys.
The
surveys performed by the licensee had been generally exposure control
measurements and had not been adequate to verify shield integrity.
As
recommended by the ANSI standard, such a shield survey would include
comprehensive patterned surveys between RBPs on vertical shield surfaces,
surveys of horizontal shield surfaces within and external to containment,
and extrapolation of survey results to rated full power.
The inspector
stated that startup shield verification surveys were necessary not only
for exposure control purposes, but also to verify proper construction and
integrity of the shield, to identify improper routing or lineup of
systems, to identify discrepancies in the FSAR radiation zone maps, and to
evaluate the effect of any identified discrepancies on equipment
qualification and post accident assumptions.
The inspector informed
licensee representatives that failure to perform adequate shield
verification radiation surveys was an apparent violation of
10CFR20.201(b)(50-424/87-35-01).
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5.
Allegation Followup (99014)
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Allegation (RII-87-A-0054)
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On or about March 19, 1987, a health physics technician and two I&C
technicians entered containment.
They were not notified that the
incore detectors would be moved.
The technician recognized the
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hazard and evacuated containment.
The incident was not noted in the
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HP shift. log book nor was it reported to licensee management or the
NRC.
Discussion
The inspector discussed the alleged event with licensee
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representatives and reviewed related documents such as survey records
and log books.
Procedure 55006-C, Movable Incore Detector System Operating
Instructions, Revision 2, March 9,1987, was the procedure used for
core flux mapping.
The procedure required that the Operations Shift
Supervisor and Health Physics foreman be notified and that they give
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prior approval for the withdrawal of the moveable incore detectors
from the core.
The procedure also required that the HP foreman and
Shift Supervisor record in their log books the date and time approval
was given.
The inspector reviewed a copy of the procedure that had
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been completed on March 19, 1987. The procedure was signed by the HP
Foreman and Shift Supervisor indicating that approval had been given
to withdraw the incores and that appropriate log book entries had
been made.
The inspector reviewed the HP Foreman's log book. There
was an entry that the incore detector movement had been approved.
There was an entry later that morning that a HP technician and two
ISC technicians had unknowingly entered containment while the
detectors were being moved.
The inspector interviewed the HP foreman and technician involved in
the event.
The HP foreman had apparently forgotten to inform the
technician of the flux mapping activities when he had briefed the
technician of the support required by the two I&C technicians.
The
technician stated that while he was passing by the flux drive units
in containment, a portable radiation monitor alarmed and he observed
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that his radiation survey meter was pegged on the low scale.
He
immediately directed the I&C personnel from the area. The technician
stated he did not quantify the dose rates by the drive units because
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he wanted to immediately clear the personnel from the area.
He
stated he did make a measurement just outside the area and he
recalled it was approximately 200 millirem / hour.
The inspector
reviewed the dosimetry records for the personnel involved and
determined that 2 millirem had been the highest exposure received
during the entry.
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10 CFR 20.403 and 10 CFR 50.72 detail-the reporting requirements for
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. incidents -and 10 CFR 20.405 for overexposures and excessive levels
and concentrations.
The inspector determined that.the event did not
meet any of the NRC reporting criteria and had not been reported by
the licensee.
Conclusion
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The allegation was. partially substantiated in that an event as
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described did occur.
No violations or deviations were identified.
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b.
Allegation (RII-87-A-0048)
The alarm setpoints on the IPM-7A personnel contamination monitors
are not set correctly.
Personnel can leave the plant with levels of
contamination that exceeds federal guidelines.
The monitor is
calibrated for large area sources (i.e., 200 or 300 cm2). Most skin
contaminations occur over smaller areas.
NRC guidance (Notice 8107)
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and the manufacturer recommend that 100 cm2 be used.
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-The allegation also included the following concerns:
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Portal monitors at the last exit are lucky to catch
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3,000,000 dpm.
The calibration program allows instruments' to sit on'a shelf
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indefinitely and still be "in calibration."
Procedure violations are committed by top management.
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The health physics group is grossly understaffed.
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The inspector reviewed the licensee's operation and calibration
procedure for the IPM-7 contamination monitor-(Procedures 43531-C and
43631-C) and discussed the use of the monitor with licensee
representatives.
The inspector determined that the monitors were
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being calibrated using a 100 cm2 source, but that 200 and 300 cmr
surface areas were being used in calculating the alarm setpoints.
The licensee acknowledged that the detectors efficiency would vary
with source size and stated that they would evaluate standardization
of the source size for calibration and alarm setpoint calculations.
They also stated they were still in the process of evaluating the
optimum alarm settings for the monitors.
Records reviewed by the
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inspector -indicated the alarm settings had been reduced by
approximately 50 percent since November 1986.
The current alarm
setpoints were below the vendor recommendations for the hand detector
and above the recommendation for the foot detector.
However, there
are no regulatory. criteria specific to alarm setpoints on personal
contamination monitors.
IE Circular 81-07:
Control of Radioactively
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Contaminated Material, which was cited by the alleger, is not
applicable in this case.
The Circular concerns criteria for release
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of. radioactive' contamination. on material and equipment to
unrestricted areas and. states that contamination monitoring using
portable . survey instruments or laboratory measurements should be
performed with instruments and techniques necessary to detect
5,000 dpm/100 cm2 total and .1,000 'dpm/100 cm2 removable beta / gamma
contamination.
' These criteria, however are not applicable to
personnel. contamination monitors.
The. inspector performed tests with the.IPM-7 monitor to evaluate how
its sensitivity compared to that of a frisker with a pancake probe.
The inspector obtained an approximately 10,000 dpm Co-60 100 cm2 source
from the licensee and entered the monitor four times with the' source
placed on. top of 'the head, held between- the legs, and in the front
and back trouser pockets. -In each test the IPM-7 failed to detect
the source. The inspector then held the pancake probe directly_above
the source and could not .obtain a detectable increase above
background.
The inspector then asked the licensee to make up a low
activity contamination smear and was given an approximately 5,000 dpm
smear in a . planchet.
The activity on the smear was comprised of
Co-58 (83%), Mn-54 (16%) and Co-60 (1%).
The inspector taped the
source .in nine locations (top of the head, cheek, chest, hand,
abdomen, back, knee, back- of thigh and bottom of. the . shoe).
Contamination was' detected'on three of.the tests (the hand, bottom of
the shoe and the abdomen when the abdomen was pressed _ against the
detectors).
The monitor did not alarm on the other test locations.
The abdomen location was checked a second time standing normally in
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the monitor and it did not alarm.
The inspector surveyed the smear
with the frisker and determined that the activity was readily
detectable using a. pancake probe.
The ' inspector determined, based on the test results, that the
contamination monitor may not be as efficient for . detecting point
source contaminants on personnel as a ' carefully performed survey
using a pancake' probe under certain conditions.
As discussed
previously, the licensee was still in the process of refining their
alarm set points and stated that the optimum setting may not have yet
been obtained. The inspector discussed with licensee representatives
the importance of establishing the monitors sensitivity. to point
sources since personnel exposures from small point source
contaminants on the skin have been a recent industry problem.
The
inspector determined that the licensee's contamination monitoring
program at the present time was adequate considering the relatively
few contamination areas in the -facility and the low levels of
contamination ' present, provided that the licensee conclude their
evaluation of the monitors in a reasonable period of time and that a
satisfactory level of detection (i.e., comparable to a frisker) for a
point source contaminants can be achieved.
This matter will be
reviewed during subsequent inspections (50-424/87-35-03).
In regard to the other concerns, the inspector determined the
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following:
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The facility exit portal monitors, PMC-4Bs are in fact not as
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sensitive as the IPM-7 (they are source checked with 5 uCi
Cs-137 source which is equivalent to 11,000,000 dpm).
However
they are not intended and are not used as primary contamination
control . instruments and it is standard practice within the
industry to have instruments of comparable sensitivity in these
locations.
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Inspection Report 50-424/87-18 discussed the licensee's practice
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of rat counting days against an instrument's calibration interval
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while it was in a storage location.
The inspector reviewed
licensee
Procedure 43500-C,
Health
Physics
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Calibration and Control Program, Revision 13, May 14,1987. The
procedure had been changed to state that an instrument's
calibration interval ran continuously from the day it was
calibrated.
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The inspector could not evaluate the allegation concerning
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procedure violations by management due to a lack of specificity.
However, no problems of this type were noted during this
inspection.
Inspection Report 50-424/87-18 discussed the licensee's staffing
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levels and identified that additional personnel may be needed to
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support startup. The inspector determined through reviewing the
health physics staffing and observing the number of activities
requiring health physics support that the licensee's resources
were being strained and that barely a minimum number of
personnel were available to support activities.
Licensee
representatives stated that priority action was being taken to
obtain an additional 13 health physics technicians and a health
physics operations supervisor. During the inspection, a foreman
and two technicians were sent from the licensee's Hatch facility
to support the activities in progress.
Conclusion
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The allegation was partially substantiated as discussed above.
No
violations or deviations were identified.
c.
Allegation (RII-87-A-0073)
The tool monitor at the controlled area exit is not sensitive enough
to detect contamination on material being released from the area.
The monitor is particularly inefficient for smearable activity that
may be on material.
Discussion
The inspector reviewed the calibration and operation of the tool
monitor with licensee representatives.
The inspector checked the
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. tool monitor with the. low level sources that had been-used with the
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personal. contamination monitor.
The monitor alarmed on every test'
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.regardless of geometry or various hand carried items placed on; top.of-
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.the source. .The inspector determined that for the items checked, the
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. monitor was -as sensitive as a direct survey with a pancake probe,,.
which is- considered ' adequate to release material from a controlled
area.
Conclusion-
The' allegation was- not substantiated.
No violations or deviations -
were identified.
d.
Allegation (RII-87-A-0074)
During a spill in the Unit 2 Turbine Building, a worker observed that'
a named individual of the health physics group appeared to be
unfamiliar with his duties.
Discussion
The inspector determined that the named individual . was a- member of
the health physics staff who did not normally have operational health
physics responsibilities, but had gone to the area to L assist the
other health physics personnel. The inspector was present during the
same period of time and did not observe any inappropriate actions by
the health physics personnel involved with the. . spill.-
The.
individual's qualifications were reviewed and the inspector
determined that the individual was qualified to conduct the tasks he-
had been observed performing.
Conclusion
The allegation was not substantiated.
No violations or deviations
were identified.
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6.
Organization and Management Controls (83722)
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10 CFR 50, Appendix B, Criterion XVI requires that measures be established
to assure that conditions adverse to quality are promptly identified and
corrected.
The identification of significant conditions adverse to
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quality, the cause of the condition, and the corrective action taken shall
be documented and reported to appropriate levels of management.
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FSAR Section 17.2.16 states that approved plant procedures shall be
written to ensure that conditions adverse to quality, failures,
malfunctions, deficiencies, defective materials and equipment and
nonconformance on safety-related systems are promptly identified,
documented,-and corrected.
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During the review of the containment entry while flux mapping event the
inspector discussed with licensee representatives the documentation of
events and corrective actions for identified problems.
Licensee
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Procedure 00150-C, Deficiency Control, Revision 5
February 20, 1987,
described the licensee's documentation and corrective action program for
all types of problems including radiological ones.
Problems were routed
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to the Shift Supervisor to initially review for significance and
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reportability, then to Nuclear Safety and Compliance (NSAC) to further
assess significance and complete distribution to the responsible group for
corrective action.
The inspector reviewed Deficiency Card 1-87-948 which
had been written on the flux mapping event.
The description of the
problem included a statement that there had been a potential for radiation
overexposure, but NSAC had written in the assessment portion that the
event was not significant and could not have resulted in a violation of
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technical specifications.
The section for corrective actions stated that
there was no deficiency and that changes to the program were not required.
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The inspector discussed this deficiency card with health physics
management.
The health physics group had taken a numbe,P of corrective
actions, including development of a containment pre-entry checklist which
required verification of the incore detector status prior to entry, which
had not been documented.
The inspector stated that the licensee's
documentation of the flux mapping event had not been adequate. The record
was incomplete in that the event was not fully described (i.e., dose rates
encountered, exposures received, sequence of events, etc.), the assessment
of significance was inappropriate and the corrective actions actually
taken were not documented.
The inspector determined that there appeared
to be a programmatic problem with deficiency reporting within the health '
physics group.
There had been approximately 1,500 deficiency cards
written in 1986 and 1987, yet only 17 were health physics related.
Several health physics personnel had stated to the inspector that they did-
not document deficiencies because it created additional paperwork since
they would likely be requested to answer the deficiency card. Failure of
the licensee to adequately document the flux mapping event and the
corrective actions taken was identified as an apparent violation of
10 CFR 50, Appendix B, Criterion XVI (50-424/87-35-02).
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