ML20235K142

Insp Rept 50-285/89-04 on 890117-20.Four Apparent Violations Noted.Major Areas Inspected:Allegation Re High Radiation Area Incident on 890126

ML20235K142
Person / Time
Site:	Fort Calhoun
Issue date:	02/14/1989
From:	Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235K134	List: ML20235K132 ML20235K142
References
50-285-89-04, 50-285-89-4, NUDOCS 8902270010
Download: ML20235K142 (13)

See also: IR 05000285/1989004

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' APPENDIX

U'. S. NUCLEAR REGULATORY COMMISSION

REGION'IV

'NRC. Inspection Report: 50-285/89-04 License: DPR-40

Docket: L50-285

' Licensee: Omaha Public Power District (OPPD)

1623 Harney Street

-Omaha, Nebraska 68102

Facility Name: Fort Calhoun Station (FCS)

Inspection At: FCS Site, Fort Calhoun, Washington County, Nebraska

Inspection Conducted: January.17-20, 1989.

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Inspector: Zf

H. Chaney', Senior Radiatiorf Specialist Date

Facilities Radiological Prdtection Section

Approved: /257 2 89

R.f. 6aer, Chief

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Date

Facilities Radiological Protection Section

Inspection Summary

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Inspect 1on Conducted January 17-20, 1989 (Report 50-285/89-04)

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Areas Inspected: Routine, unannounced inspection of the radiation protection

program. An allegation was reviewed concerning a very high radiation area

(VHRA) incident. A review of the licensee's progress on completion of the

Radiation Protection Enhancement Program (RPEP) was also performed. The NRC

inspector also reviewed, in office, information received from the FCS NRC

resident inspector concerning a high radiation area incident that occurred on

January 26, 1989.

Results: Within the areas inspected, four apparent violations (failure to

submit accurate personnel exposure data information to the NRC, and tnree -

I examples of failure to follow procedures, see paragraphs 5.c and 5.d) were

l identified. No deviations were identified.

Significant improvement was noted in the licensee's responsiveness to NRC

initiatives. The licensee's efforts to improve communication between

plant management and plant staff are being emphasized by senior OPPD management.

-The licensee efforts to improve procedure compliance among plant staff is

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having moderate success.

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DETAILS j

1. Persons Contacted

OPPD-

• K Morris, Division Manager Nuclear Operations

+*W. Gates, Manager, Fort Calhoun Station

• G. Peterson, Assistant Manager, Fort Calhoun Station

• A. Bilau, Radioactive Waste Coordinator

• J. Bobba, Supervisor, Radiation Protection (RP)

• C. Brunnert, Supervisor, Operations, Quality Assurance

• A. Christensen, Field-Health Physicist 1

R. Cords, RP Technician l

C. Crawford, Respiratory-Protection Specialist

D. Jacobson, Supervisor Chemistry and RP

• R. Jaworski, Manager, Station Engineering

• D. Mathews, Supervisor, Station Licensing

A. Richard, Manager, Quality Assurance and Quality Control

• C. Simmons. Onsite Nuclear. Licensing Engineer ,

• K. Steele, Health Physics (HP) Special Services Coordinator

• M. Tesar, Supervisor Technical and General Employee Training-

Others

• P. Harrell, NRC Senior Resident Inspector

• T. Reis,-NRC Resident Inspector

J. Neely, Westinghouse Radiological Support Division

• J. Ferguson, Westinghouse Radiological Support Division

• Denotes those persons present at the exit meeting on January 20, 1989.

+ Denotes the January 31, 1989, briefing by the NRC resident inspector

concerning events that happened after the completion of the onsite

inspection effort.

In addition to the above noted individuals, the NRC inspector contacted

other licensee and contractor personnel during the inspection.

2. Open Items Identified During This Inspection

An open item is a matter that requires further review and evaluation by

the NRC inspector. Open items are used to document, track, and ensure

adequate followup on matters of concern to the NRC inspector. The

following open item was identified:

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Open Item Title See Paragraph

28$'8904-03 Verification of Personnel

Quarterly Exposure - NRC

Form 4, 5.c

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3. Followup on Previous Inspection Find ngs (92701)

(Closed) Violation (285/8721-02): Failure to Follow Radiation Protection

Procedures - This item was previously discussed in NRC Inspection

Report 50-285/87-21 and involved an equipment operator's entry into a VHRA

without a HP technician present as required by station procedures. The

NRC inspector examined the licensee's implementation of corrective actions

committed to in their Novembar 4,1987 (LIC-87-732) and February 18, 1988

(LIC-88-116) responses to the violation and Licensee Event Report

(LER) 87-26. LER 87-26 was closed out in NRC Inspection

Report 50-285/88-30. The licensee's corrective actions for this specific

event appear to be adequate. Continual procedural compliance problems

still exist, see paragraph 5.c.

(Closed) Violation (285/8805-02): Failure to Control Access to a VHRA -

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This item was previously discussed in NRC Inspection Reports 50-285/88-05

and 50-285/88-30 and involved the licensee's failure to adecuately control

VHRA doors. The NRC inspector examined the licensee's corrective action

commitments in the June 3,1988 (LIC-88-393) response to the violation,

the licensee's RPEP presented to the NRC at the Region IV office on

October 31, 1988, and the licensee's Safety Enhancement Program (SEP)

plan submitted to the NRC on December 9,1988 (LIC-88-1094). Since

corrective actions for specific aspects of this violation have also been

addressed in the FCS SEP (Items 51 and 55), and the SEP will be closely

monitored by the NRC to its conclusion, the two remaining corrective

actions (development of procedures for the VHRA lockset and key control,

and implementation of the RP Manual / Plan plus revision of FCS Operating

Manual, Volume VII) will be tracked via reviews of the SEP.

(Closed) Violation (285/8805-03): Lack of Key Control for VHRA Doors -

This item was previously discussed in NRC Inspection Reports 50-285/88-05

and 50-285/88-30 and LER 88-01 and involved the licensee's failure to

implement a VHRA door key control program as required by TS 5.11.2. The

NRC inspector examined the licensee's cerrective action commitments in the

June 3,1988 (LIC-88-393) response to the violation, the licensee's RPEP

presented to the NRC at the Region IV office on October 31, 1988, and the

licensee's SEP submitted to the NRC on December 9,1988 (LIC-88-1094).

The NRC inspector verified that the licensee had installed special door

locksets in doors to VHRAs and installed monitored door strikes with local

" door ajar" alarms. Only a few secondary VHRA accesses (hatch type) are

still secured with padlocks and hasps. The Field Health Physicist has

established control over all locksets/ keys to VHRAs and is in the process

of developing, in concert with the FCS Security Section, procedural

controls for the new locksets and keys. Only select Operations and HP

personnel have access to the VHRA keys. Since corrective actions for

specific aspects of this violation have also been addressed in the SEP

(Item 55), SEP commitments will be closely monitored by the NRC. The two

remaining corrective actions (hard wiring of VHRA door alarms into the

security system alarm stations and development of procedures for the VHRA

lockset/ key control program) will be tracked via the SEP.

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(Closed) Open Item (285/8805-07): Radiation Protection Staff Organization

and Position Descriptions - This item was previously discussed in NRC

. Inspection Reports 50-285/88-05 and 50-285/88-30, and %nvolved the RP

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Department organization, first line supervisor authority, staffing, lack

of agreement with the organizational charts in Section 5.0 of the TS, and

the lack of accurate position descriptions for RP staff positions. The

NRC inspector examined the. licensee's corrective actions as committed to

, in the licensee's July 6,1988 (LIC 88-514) response to the NRC's

concerns. The NRC inspector examined the licensee's progress in meeting

the commitments contained in the. licensee's RPEP presented to the NRC on

October 31, 1989. The licensee had made a TS submittal which identified

two new departments (RP and Chemistry), and established technical groups

within the RP Department. The NRC inspector reviewed the new RP

organization; staffing; alignment of the internal groups, including

supervisory assignments; and examined the new position descriptions for

selected RP staff positions. The position descriptions were found to

adequately describe functional responsibilities. The licensee is

aggressively pursuing the filling of key supervisory positions with

outside personnel (two out of the three senior RP supervisor positions

have been filled). Three technical positions (one Radwaste Supervisor and

two staff HP professional positions) and approximately eleven junior HP

technician slots remain to be filled. This item is also addressed in the

SEP (Item 52) which includes additional licensee identified goals to

improve this area.

(Closed) Open Item (285/8805-08): Lack of Comprehensive 4adiation

Protection Procedures - This item was previously discussed in NRC

Inspection Report 50-285/88-05 and involved the licensee's lack of

adequate RP program implementing procedures and a RP Manual. The NRC

inspector examined the progress in resolving this concern as committed to

in the July 6, 1988, response to the aforementioned NRC report. The

licensee expects to issue the FCS RP Plan in early February 1989, with

completion of-RP procedure revisions by July 31, 1989. This concern is

also addressed in the SEP (Item 51).

(Closed) Open Item (285/8830-01): Dosimetry System Reliability - This

item was previously discussed in NRC Inspection Report 50-285/88-30, and

involved the excessive down time experienced by the licensee's personnel

dosimetry system. The NRC inspector noted that the licensee had issued an

approved purchase order for the procurement of a new multi-element

thermoluminescent personnel dosimetry system. This system is scheduled to

be operational by December 31, 1989. This item is also addressed in the

SEP (Item 53).

4. Licensee Event Report Followup (92700)

(Closed) LER (88-001): Failure to Control a Very High Radiation Area - The

licensee described in this LER the circumstances surrounding the

investigation and corrective actions taken as a result of finding on

January 25, 1988, an improperly latched door to a posted VHRA (waste

disposal filtering room). The NRC inspector reviewed the licensee's

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investigation of the incident and the implementation of corrective actions

committed to in the LER. The licensee's root cause analysis appeared to

be adequate and the incident was evidently a result of lack of attention

to detail and compliance by a worker. The licensee's actions were

appropriate and effective in preventing additional occurrences.

5. Occupational Exposure, Transportation, and Shipping-(83750)

a. Changes

The licensee's progress in completing the reorganization and staffing

of the RP Department was inspected for compliance with the

requirements of TS 5.3.1 and 5.4; and the recommendations of industry

standard ANSI N18.1-1971.

The NRC inspector reviewed the current status of staffing for the

support of the RP Department and the hiring of a permanent RP Manager

(NRC Regulatory Guide 1.8 equivalent). The aforementioned items were

previously discussed in NRC Inspection Report 50-285/88-30. The

licensee hired the consultant that had been occupying the position ,

of Supervisor - RP since August 1988 to fill the permanent onsite RP '

Manager position. The licensee's progress in filling recently

created staff positions (supervisory, technical, and technician) is

satisfactory.

No significant changes have been made in the existing radiation

protection facility, but the licensee had initiated construction of

additional support facilities.

No violations or deviations were identified.

b. Training and Qualifications of New Personnel

The NRC inspector reviewed the accreditation status of the RP

technician training and qualification program. The licensee

received INPO accreditation in this area in April 1988. The NRC

inspector discussed with licensee personnel the expected start date

for qualifying new RP technicians and RP supervisors. The licensee

will begin this training following the training departments

relocation to the new onsite training facility in mid February 1989.

The NRC inspector also reviewed specialized training for respiratory

protection equipment (RPE) use and discussed the minimum training

requirements for various classifications of licensee employees.

No violations or deviations were identified.

l c. External Radiation Exposure Control

The licensee's external radiation exposure control program was

inspected to determine agreement with the requirements of TS 5.11,

10 CFR Parts 19.12, 19.13, 20.101, 20.102, 20.104, 20.105, 20.202,

20.203, 20.205, 20.206, 20.405, 20.407, 20.408, and 20.409.

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The NRC inspector examined.the newly installed. locks and alarm

systems for' control of VHRA doors. The NRC inspector discussed with

licensee representatives the need for ensuring that planned

procedures adequately cover lockset change out and alarms. . The NRC

inspector also performed confirmatory measurements of radiation and

high radiation areas and radiation hot spots.

Licensee Identified Violations

The NRC inspector examined personnel radiation exposure records that

included radiation exposure histories, quarterly radiation exposure

records, and authorizations to exceed administrative exposure limits.

The circumstances and official personne_1 radiation exposure records

involved in the special report submitted to the NRC nn December 19,

1988, " Failure to Fully Meet the Requirements of 10 CFR

Part 20.102(a)," were examined. This report dealt with the

licensee's inconsistent methodology in determining whether or not

personnel with breaks in employment and/or breaks in use of dosimetry

at FCS had received additional occupational exposures during these

breaks. As. stated by the licensee in the report, there was an

apparent violation of 10 CFR Part 20.101(b)(3) in that a written

signed statement of current quarterly occupational exposure to

support authorization for some personne' to exceed 1250 millirem

per quarter could not be located in all instances. The' licensee

confirmed, by interviews with previous dosimetry clerks and affected

workers, that this information was sometimes only verified verbally.

The licensee is currently developing plans for reviewing and updating

all personnel exposure records. The licensee has implemented

corrective actions to ensure that personnel fill out and sign a form

attesting to their occupational exposure during a calendar quarter

when not employed at FCS. This. matter would normally be considered a

violation of 10 CFR Part 20.101(b)(3) requirements. However, the NRC

Enforcement Policy, 10 CFR Part 2, Appendix C, states that a Notice

of Violation will generally not be issued for violations identified

by the licensee, if: (1) it was identified by the licensee; (2) it

fits in Severity Level IV or V; (3) it was reported, if required;

(4) it was or will be corrected; and (5) it was not a violation that

could reasonably be expected to have been prevented by the licensee's

corrective actions for a previous violation. This apparent violation

meets the criteria specified in 10 CFR Part 2, Appendix C (1988), and

is considered a licensee identified violation. This matter is

considered an open item pending further review of the licensee's

corrective actions. (285/8904-03)

Other Violations

L The following two examples of failures to comply with RP procedures

were identified during this inspection:

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TS 5'.11 requires that the licensee's procedures for personnel

RP be consistent with the. requirements of 10 CFR Part 20 and

approved, maintained, and adhered to for all operations involving

personnel radiation exposure.

Paragraph 3.2.2.1, Section 3.0, Volume VII of the FCS Operating

Manual requires, in part, that any individual permitted to enter a-

posted high radiation area (any area where a major portion of the

- body could receive greater than 100 millirem-in one_ hour, but less

than 1000 millirem in one hour is considered a high radiation area

and posted as such) shall be provided with or accompanied by one or

more of the following:

1. Continuous HP technician coverage.

2. Individuals trained-in RP procedures and precautions may enter

-and perform required tasks after an initial survey has been

. performed.and they are made knowledgeable of the dose rates in

the area. These individuals must wear a radiation monitoring

device which continuously integrates the dose rate in the area

and alarms at a pre-set integrated dose.

3. The appropriate access control and monitoring will be specified

on the Radiation Work Permit (RWP) required. for entry into high

radiation areas.

4. Health Physics must be aware that you are to enter the area and

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the reason for the entry.

5. Entrance must be controlled by issuance of a RWP.

Furthermore, paragraph 3.2.2.2.2 requires, "that individuals entering a

VHRA (dose rates greater than 1000 millirem per hour), even though

they may be a qualified HP technician and equipped with proper

dosimetry and radiation monitoring instruments, a second person

shall always accompany the person entering."

1. On January 17, 1989, the Supervisor Radiation Protection (SRP)

brought to the attention of the NRC inspector the results of a

licensee investigation into a VHRA incident that had occurred

on January 8, 1989. The SRP stated that a contract HP

technician had been left alone in a VHRA (reactor coolant pump

and steam generator cubicle bay) after providing HP coverage for

two pipefitters. When the pipefitters exited the work area, they

locked the access door (one of two) behind them as they left.

In order to exit the area, the HP technician had to climb up and

out the top of the bay via the second access door (see

paragraph 6.0 of this report).

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2. The NRC resident inspector was informed by the licensee on

January 26, 1989, that at approximately 11:30 a.m. that day., a

contract electrical maintenance' craftsman was found inside of a

posted high radiation area (within the Safety Injection Pump

Room of the auxiliary building) without an integrating dosimeter

and without the knowledge of the RP staff. The contract

electrician was in the company of an OPPD electrician when the

observation was made by the FCS Radwaste Coordinator during a

tour of auxiliary building radiological areas. The two

electricians had been inspecting fire / smoke alarms and had

signed in on RWP 89-006-2, " Routine Electrical Duties." The RWP

specified contacting the HP staff for area.information and that

a "Xetex" .(integrating dosimeter) was required for entry into

high radiation areas. The entrance to the Safety Injection Pump

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Room (Room 22) was conspicuously posted with appropriate entry

prerequisites. The licensee subsequently determined that the.

OPPD electrician had also entered a posted high radiation area

on January 23, 1989, when working with another OPPD electrician.

The licensee determined that both OPPD electricians had entered

the same posted high radiation area (SI Pump Room) on

January 23, 1989, without alarming-dosimeters. The FCS Manager

suspended further work (at approximately 3:00 p.m. on

January 26,1989) within radiologically controlled areas,

excluding required operations, HP, . and chemistry functions

in the auxiliary building,. until further investigation; and .

plant staff briefings and remedial training could be completed.

The licensee has experienced two similar violations involving high

radiation. areas and VHRAs, and the failure to follow RP procedure

requirements during the past 12 months (see NRC-Inspection i

Reports 50-285/88-05 and 50-285/88-42).

The failure to comply with RP procedures is considered an apparent

violation of TS'5.11. (285/8904-01)

No deviations were identified.  ;

d. Internal Radiation Exposure Controls

The licensee's program for control of internal exposure was inspected

to determine compliance with the requirements of 10 CFR Part 20.103

and the recommendations of RG 8.15 and NUREG-0041.

The NRC inspector examined the status of the licensee's development

of new respiratory protection program implementing procedures.

The NRC inspector reviewed RPE training activities. The NRC

inspector also examined the licensee's general area airborne

radioactivity sampling program. The following procedures

were reviewed:

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.. .HP-5, " Collection and Analysis of Air Samples," Revision 7

. .HP-13, " Continuous Air Monitoring Instrument Operation,"

Revision 3

. HP-14, " Counting Instrument Operation," Revision 6

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The following apparent violations were identified during the

inspection.of this area:

.TS 5.11. requires that the licensee's procedures for personnel RP be

consistent with the requirements of 10 CFR Part 20 and approved,

maintained, and adhered'to for all operations involving personnel. '

radiation exposure'.

L 10 CFR Part 50.9 requires, in part, that information provided to the:

Commission (NRC) by a licensee shall be complete and accurate.in all

material aspects.

10 CFR Part'20.408 requires, in part, that licensee's shall' transmit

to an employee upon termination of employment with the licensee or

upon termination of work at the licensee's facility information as to

the results of monitoring of an employee for exposure to radiation

and radioactive materials.

10 CFR Part 20.409 requires., in .part, that the licensee shall'also

transmit to the NRC the same information as transmitted to the

employee.in accordance with 10 CFR Part 20.408.

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NRC Generic Letter 85-08 (May 23,1985) requested that the licensee

voluntarily use the standard NRC Form 439 for submitting exposure

data for termination reports. Instructions for completing NRC

Form-439 specifically state that "The time to be covered by this

report is that period of employment or work assignment in your

facility (s) which ended with the most recent termination and was not

interrupted by any previous termination during which personnel

monitoring was required . . . ." Part III of NRC Form 439

specifically requires that Item 12 be checked, in the box provided,

if the licensee had not performed monitoring for exposure to

radioactive material. Any monitoring results are entered in Item 13.

The licensee has been submitting such reports to the NRC since before i

May 23, 1985. j

The licensee utilizes whole body counting (WBC) for determining the

degree of an individual's exposure to radioactive materials while '

employed at FCS. The licensee routinely performs WBC of

employees / contractors prior to their entry into radiologically

controlled areas. This initial monitoring is for determining the

" base line" radioactivity.in an individual. This initial / base line

monitoring would only identify radioactive materials that an

individual would have been exposed to prior to employment / visit at 3

FC S ., The licensee also conducts periodic WBC of individuals during  !

their employment at FCS in accordance with the instructions in l

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licensee procedure HP-1. There are four classifications df-WBC:

(1) new hire (base line), (2) routine (annual), (3) termination,- and

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(4). investigative (due to exposure to radioactive materials). The

termination count is for personnel terminating employment at FCS.

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On January 17, 1989, during a review of personnel radiation exposure

records, the NRC inspector determined that the licensee had routinely

indicated on radiation exposure termination reports (licensee form

FC-285 that is equivalent to NRC Form 439) sent to individuals and

the NRC that personnel were monitored for internal radioactivity and

the results were'"No detectable activity." This information was

entered in item 13 of Part III of the licensee's termination report.

A random examination of records (approximately 25 inactive files)

showed that approximately 50 percent of the individuals _had not been

given a final WBC and, therefore, the statement "No detectable o

activity" is an inaccurate' statement. The licensee does not have in

place an effective program to ensure that all personnel terminating

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employment or having their dosimetry terminated that had access to ,

radiological areas are whole body counted. Current FCS procedures

(HP-1) require WBC on1 termination of employment; however, several

records with inaccurate data were of personnel that only had their

. dosimetry pulled and were still working at FCS. Therefore, many

terminating (dosimetry and employment) individuals are not whole body

counted. The submitting of inaccurate information to the NRC.is

considered an apparent violation of 10 CFR Part 50.9. (285/8904-02)

.The failure to perform WBC on terminating workers per HP-1 is also

another apparent violation of TS 5.11 involving a failure to follow

procedures' .

(285/8904-04)

No deviations were identified.

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e. Control of Radioactive Material, Contamination, and Radiological

Monitoring

The licensee's programs for the control and survey / monitoring of RAM

were reviewed for compliance with the requirements of TS 5.11 and ,

10 CFR Parts 19.12, 20.4, 20.5, 20.201, 20.203, 20.205, 20.207,

20.301, 20.401, and 20.402.

The NRC inspector examined the licensee's radiological survey program

involving prework/RWP review, work activity monitoring, storage

areas, ;hange rooms, lunch and meeting rooms, contractor service

facilities, radiological control points, and material being released

from radiologically controlled areas- . Temporary work areas and

control points established in the auxiliary building were inspected.

No violations or deviations were identified.

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6. Allegation Followup (99024) ,

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Background  ;

On January 17, 1989, the NRC received an allegation (RIV-89-A-0007)

concerning a January.8, 1989, VHRA incident involving a contract HP

technician. The alleger's concerns were communicated to both the

Resident Inspector and Region IV. The concerns involved the possible i

cover-up of a-RP incident. The alleger's concerns-'were: '

(a) That licensee management did not consider the incident to be a

violation of the procedure for VHRA control contained in Volume VII

of.the Plant Operating Manual.

(b) That the incident report issued by the Field Health. Physicist on

January 9,1989, and used for briefing of HP technicians on the cause

of the incident to prevent a recurrence, was inaccurate as to.the

cause of the incident.

(c) Disciplinary ection was not consistent with previous disciplinary

actions for similar events.

Discussion.

This allegation involves the apparent violation discussed in paragraph 5.c

concerning a. contract HP technician being left alone in a VHRA. The

licensee had based the decision that no violation occurred on the

statement made by the contract HP technician that was left in the VHRA.

The disciplinary action taken against the contract HP technician was

significantly less than that taken against other FCS employees and

contract workers for similar events that had occurred within the past

12 months. The licensee's documented disciplinary action referenced the

fact that there were conflicts in the statements of persons involved in

the incident. The licensee maintained that no violation occurred since

the subject HP technician, when recognizing the situation (supposedly

through no fault of the subject HP technician), immediately exited the

area.

On January 18 and 19, 1989, the NRC inspector interviewed six of the seven

persons that were directly involved with or had first hand knowledge about

the incident. The contract HP technician (CHP), field health physicist, and

the SRP were also interviewed.

Statements made during these interviews depicted a scenario that had the

CHP technician preplanning the coverage.of two jobs within the. reactor  !

containment steam generator / reactor coolant pump (SG/RCP) bay VHRA. The l

CHP technician would enter the SG/RCP bay through a lower access with one  !

of two pipefitters. When this job was completed, the CHP technician

would have one of the pipefitters exit the bottom and the CHP technician

f would climb up to the upper access door, which was previously opened for

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this purpose, with the other pipefitter and pick up the other workers

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waiting to enter the area. This would satisfy the two persons rule for a

CHP technician inside of a VHRA. This would allow the CHP technician to

expediently provide coverage without having to exit the areas and redress

l in protective clothing and RPE. Other HP technicians in the immediate

area assumed this was the scenario, but were not provided information

that the CHP technician would actually exit the upper access with the

other pipefitter. The CHP technician's plan was conveyed to the shift HP

Crew Chief, as is done prior to any VHRA entry, by another HP technician.

However, according to the two pipefitters and other area HP technicians,

the scenario was not conveyed to them. When the CHP technician reached

the upper access to the SG/RCP bay, another HP technician (acting as

VHRA access control over the upper access) informed the CHP technician

that the subject CHP technician was in violation of procedures. The CHP

technician then apparently stated "does anyone else know." Also, the two

pipefitters statements describe that the CHP technician ordered.them to

exit the lower level access and lock the door behind them, after waiting

to observe the CHP technician climb up the SG/RCP bay ladder towards the

upper exit. The CHP technician's statement conflict with the

aforementioned statements by other HP technicians and the pipefitters.

The NRC inspector also determined that FCS management did not interview

several of the HP technicians knowledgeable with the incident or the

pipefitters until some time (several hours) after issuance of the

preliminary report of the incident. Two HP technicians directly

knowledgeable of the events before and following the incident were not

interviewed and had voiced their opinion to the Field HP that the

preliminary report conta'ned several errors. The preliminary report was

not retracted.

The NRC inspector informed the licensee at the January 20, 1989, exit

meeting that evidence appears to indicate that the subject CHP technician

actions could have caused the incident to occur and that the preliminary

report of the incident was not sufficiently accurate in all aspects to

preventing future violations. The NRC inspector also noted to the

licensee that apparently too much pressure on meeting productivity goals

is being generated by the maintenance staff when HP technician support is

at a reduced state.

Finding

All three allegations were substantiated. However, there does

not appear to be any cover-up of the incident. The licensee's conduct

regarding the three areas of the allegation do not involve regulatory

matters, but do reflect a weakness on the licensee's ability to evaluate

and initiate corrective actions that will prevent a future recurrence of

violations and instill confidence in management decisions.

Item (a): Substantiated. The licensee did not classify the incident as

constituting a violation of procedures /TS 5.11. However, the licensee did

inform the NRC of the incident, and NRC has identified this as an

apparent violation elsewhere in this repert.

_ - _ _ _ _ - _ _ _ _ - _

_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ ,

.

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Items (b) and (c): The licensee, as of January 23, 1989, had initiated a

review of the NRC inspector's findings and their (licensee) earlier

investigation concerning the January 8, 1989, incident to determine if

corrective actions are adequate to prevent a recurrence of the event.

This allegation is considered closed.

7. Exit Interview

The NRC inspector met with licensee representatives identified in

paragraph 1 at the conclusion of the inspection on January 20, 1989. The

NRC Resident inspector met with the licensee representatives identified in

paragraph 1 on January 31, 1989, concerning matter discussed in

paragraph 5.c(2) of this report. The NRC inspectors summarized the scope

and findings of the inspection.

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