ML20141E187

Insp Rept 50-219/85-35 on 851021-1201.Violation Noted: Failure of QC & Maint Const & Facilities to Follow Procedures & Identify Various Discrepancies as Discussed in Paragraph 1.D

ML20141E187
Person / Time
Site:	Oyster Creek
Issue date:	01/24/1986
From:	Blough A, Urban R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141E140	List: ML20141E133 ML20141E158 ML20141E187
References
50-219-85-35, NUDOCS 8602250146
Download: ML20141E187 (15)

See also: IR 05000219/1985035

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U. S. NUCLEAR REGULATORY COMMISSION  :

REGION I

Report No. 50-219/85-35

, Docket No. 50-219

) License No. DPR-16 Priority --

Category C-

Licensee: GPU Nuclear Corperation

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100 Interpace Parkway

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Parsippany, New Jersey 07054

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Facility Name: Oyster Creek Nuclear Generating Station .

, Inspection At: Forked River, New Jersey

Inspection Conducted: October 21 - December 1, 1985 [

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Participating Inspectors

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W. H. Bateman, Senior Resident Inspector I

J. F. Wechselberger, Resident Inspector

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Reviewed by:

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R. J( Urban, Reactor Engineer

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Approved by:

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A. R. RTough, Chief, Reactor Projects Date

Section IA

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Insoection Summary:

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Routine onsite inspections were conducted by the resident inspectors (284

hours) of activities in progress including plant operations, outage planning, -

plant shutdown, outage work, plant startup, physical security, radiation

control, housekeeping, surveillances, and strike preparations. The inspectors

also attended a meeting to discuss the status of the hanger reinspection

, program, made routine tours of the control room and the power block, followed

i up an Unusual Event involving transportation of a potentially contaminated

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worker to a local hospital, evaluated Post Accident Sampling System (PASS)

operability, reviewed licansee requested emergency Technical Specification

changes, and evaluated implementation of the fire protection program.

Results:

As a result of inspections performed during the one month long "10M" outage,

five violations were identified:

(1) Failure of the GPUN welding program to incorporate AWS D1.1

requirements for structural welding into weld procedure

specifications as discussed in paragraph 1.A;

(2) Failure of Technical Functions to adequately design /specify weld

joint requirements for a structural weld as discussed in paragraph

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1.B;

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(3) Failure of QC and Maintenance Construction and Facilities (MCF) to

follow procedures as discussed in paragraph 1.C;

(4) Failure of QC inspectior,s to identify various discrepancies as

, discussed in paragraph 1.0; and

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(5) Failure of various onsite personnel to properly frisk carry-along

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items such as clip boards, drawings, and papers when leaving the

Radiation Control Area (RCA) as discussed in paragraph 4.

No new unresolved items were opened and no old open items were closed. The

inspectors' followup of the Unusual Event and a reactor scram did not identify

any significant problems. Licensee plans for coping with a strike were re-

viewed and problems resolved. Negotiations between union and management

resulted in a new contract without any job action. The hanger reinspection

program continued to progress with major emphasis shifting from inspections to

engineering evaluations of the as-found conditions. Unresolved questions in-

volving demonstration of PASS operability were being adequately pursued by the

licensee at the end of the report period.

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i DETAILS

! 1. Outage Activities

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! The 10M outage, scheduled for October 18, 1985 to November 18, 1985, was

-started and completed as planned. During this report period, the

, inspectors observed preplanning, plant shutdown, outage, and subsequent

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startup activities. The following positive observations were made:

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In general,. communications between various divisions were observed

I to have improved as compared to previous outages.

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Timely technical support from Tech Functions was observed to be

significantly improved.

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Maintenance, Construction, & Facilities (MCF) preplanning for system

and equipment outages helped Plant Operations in their efforts to

i properly and expediently tagout components as required.

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Job supervisors and QA/QC personnel were observed to be present in

j the field and involved in ongoing work activities.

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Procedures reviewed by the inspectors were generally acceptable with

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reasonable QC hold points established. ,

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Housekeeping degraded somewhat during the outage but'was restored to

an acceptable level prior to restart of the plant.

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Startup and Test personnel were aggressive and knowledgeable. They t

j were instrumental in identifying and resolving problems and, ,

,. therefore, played a key role in the overall success of the outage. '

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Tests of intake structure concrete samples indicated concrete

i strength exceeded design strength.

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preplanning of work activities by MCF and more detailed engineering

walkdowns' helped to avoid schedule slippages,

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Improvement in radiological controls and sampling enabled work without

l respirators in most areas of the drywell.

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Coordination between MCF and Security was good and eliminated

I potential security concerns, especially for work in vital areas of

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Remote controlled TV cameras were used to monitor drywell work

) activities without having to enter the drywell. This minimized the

l number of drywell entries.

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i The following inspector observations indicate areas that may require

f licensee evaluation to improve future performance:

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Workmanship problems were evident as discussed later in the

l violations.

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QC inspection problems were evident as discussed in the violations. _

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Quality and timelitiess of MCF paperwork for turnover was a problem

for.a time; however, it was corrected.

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More attention is needed to identify existing plant discrepancies as

3 j evidenced by loose and missing instrument line pipe clamps on RK01

., > and RK02 instrument racks after work on these racks was completed.

Existing discrepancies were also identified with an inadequately-

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supported cable tray and inadequate tie wrapping of cable in the same

vertical cable tray, i

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Previously leaking isolation condenser drain valves were replaced

with the same type of valve and leaked again after installation.

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The recently implemented radcon Dose Assessment System occasionally

slows dow'n entry intojthe RCA. The inspectors were delayed twenty

minutes orie evening when attempting to enter the RCA because the

system was out of service. Safety related work was ongoing in the

RCA at the time. It is important that inspectors and monitors,

whether from the licensee organization or from outside agencies,

have prompt access to plant areas to observe ongoing activities.

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Poor planning by GPUN licensing regarding the one interim and two

emergency Technical Soecification change requests resulted in ex-

cessive last minute licensing effort. More licensee planning is

required to avoid the need for emergency Technical Specification I

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A large number of FCRs were generated. However, only a small number

i of these FCRs applied to the RK01 and RK02 EQ work, which was well

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planned.

The following viciations were identified by the inspectors:

l (A) Visual inspection of the RK01 and RK02 instrument racks identified

! inadequate structural welds. In'particular, 1/2" thick by 2" wide

l pieces of carban steel plate were butted together without end

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preparation and joined using a seal weld along one 2" side. GPUN

drawings depicting rack structural work (Drawing SN15081.02-ES-04,

Rev. 3 for RK01 and SN 1508.02-ES-05, Rev. 3 for RK02), indicate the

! use of 59 1/2" long pieces of this plate to aid in structural

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reinforcement of.the racks. When the pieces were installed they

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were found to be 6" short. FCR C-039642 was issued to address this

problem and required that the stiffener be extended by welding a 6"

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long piece to the 59 1/2" long piece using a partial penetration

butt weld. Thus, welds were inadequate in that seal welds had been

used where partial penetration butt welds were specified.

Structural welding at Oyster Creek is done to the requirements of

AWS DI.1, Structural Welding Code, which requires an effective

throat of 3/16" for a partial penetration butt weld of 1/2" thick

material. Following the design and joint geometry requirements of

AWS D1.1 allows the use of AWS D1.1 inspection criteria which are

less stringent than ASME. When the inspector questioned site

welding personnel as to why a specific AWS DI.1 prequalified joint

geometry was not used to accomplish this weld, he was told the weld

procedure specification used to make this weld was qualified to ASME

Section IX and that joint geometry per Section IX is not an essential

variable. This argument was not consistent with the applicable re-

quirements of AWS D1.1 and indicated a problem with the GPUN welding

program. Additionally, the licensee specified the use of AWS inspec-

tion and acceptance criteria for the welds even though they did not

meet'AWS joint design criteria. The inspector subsequently reviewed

the GPUN welding program and concluded the program is designed to

meet the requirements of Section IX but does not address important

aspects of AWS DI.1, namely, the AWS essential variable of weld joint

geometry.

The failure of the GpVN welding program to address the requirements

of AWS D1.1 for structural welding activities is contrary to the

requirements of Criterion IX of 10 CFR 50 Appendix B and is a

violation. (219/85-35-01) It should be noted that the existing

GPUN welding program does address AWS D1.1 requirements for straight

tee joint fillet welds.

(B) Regarding the inadequate welds discussed in (A) above, the inspector

observed that engineering did not specify any weld details on FCR

C-039642 for the subject weld. In light of the fact that the welding

program did not address AWS D1.1 requirements, it was incumbent upon

engineering to specify the design requirements for the weld. This is

required by Attachment 1 to GPUN Standard MTWA-001, GPU System Weld-

ing Program and paragraph 4.2 of procedure 6150-QAP-7220.01, GPUNC

Welding Manual. Based on licensee statements to the NRC inspector,

apparently Stone and Webster was involved in the engineering and

assumed the GPUN welding program addressed AWS requirements. The

failure of engineering to specify design requirements for the weld is

contrary to the requirements of Criteria III and V of 10CFR 50

Appendix B and is a violation. (219/85-35-02)

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(C) Four examples of failure to follow procedures were identified as

follows:

3(1) A review of completed QC inspection records associated with

electrical EQ work on instrument rack RK01 disclosed that some l

of these records were inadequate in that it was not possible' to '

determine the specific inspection activities documented.

, The procedure governing the electrical work was A158-G1136.010,

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Rev. O, RK01 Rack Modifications - Electrical. QC assigned hold

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points in this procedure that involved the accomplishment of

multiple steps. When QC inspectors attempted to document

partial inspections of these hold points by writing Plant Inspec-

tion Reports (PIRs), instead of listing.the actual activities

inspected, in some cases they only referred to the QC hold point

number. Consequently, it was not possible, using all the avail-

able documentation (i.e. hold point numbers, pIRs, data sheets t

and procedures) to determine if all required inspections had

been done. Examples of this problem and others are identified i

as follows:

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(a) PIR #11025 dated 10/30/85 stated work on QC hold point I

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85/3002 was partially completed. QC hold point 85/3002

l was assigned to step 6.8.3 in the governing procedure.

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Step 6.8.3 directed work be accomplish'ed in accordance

with Data Sheets 1,2,3, and 4. The QC-inspector did not

initial the data sheets or otherwise indicate which

l portion of the hold point was done.

(b) PIR #10920 dated 10/29/85 stated continuity and meggar

testing work was done on QC hold point 85/2996 on cable

l 63-NC-0750. QC hold point 85/2996 was assigned to step

j 6.7.3. Step 6.7.3 directed testing of wiring on Data

Sheet 5-2 steps 22-26. However, steps 22-26 do not

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involve cable 63-NC-0750. Additionally, no steps on Data

Sheet 5-2 were initialed by the inspector involved. 1

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(c) PIR #11166 dated 11/1/85 stated it was the final

inspection of QC hold point 85/3010. There were no other-

PIRs issued to document work to this hold point. This

hold point was assigned to step 6.10.3. Step 6.10.3

directed work to be accomplished as per Data Sheet 6. A

review of Data Sheet 6 indicated two inspectors completed

the required work. There should, therefore, have been an

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additional PIR against this hold point. Additionally, the

. subject PIR did not indicate test equipment used to perform

continuity and meggar testing. In fact, "N/A" was written

- in the space provided on the PIR te indicate test equipment

identification, thus, implying the required continuity and

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meggar testing was not accomplished.

(d) PIR #10799 dated 10/21/85 identified open items. A PIR is

not appropriate for document open items because there is no

method for closure.

(e) Steps 11 and 12 on Data Sheet 4 of the governing procedure

were reinitialed on 11/7/85 but a PIR was not written to

document this update.

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(f) PIR #11217 dated 11/4/85 stated activity was inspected on

i QC hold point 85/3005 but a review of Data Sheet 5-1

indicated the inspector's initials were not on the data

sheet. Additionally, this PIR allegedly documented work

on steps 18 and 19 of Data Sheet 5-2 as required by'QC

hold point 85/3009; however, the signoff date in the

governing procedure for these steps was 10/29/85, five

days before the PIR date.

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(g) PIR #10732 dated 10/29/85 was changed, after QC review and

acceptance of the work package, to clarify certain concerns

raised by the NRC inspector. Additionally, this.PIR was

apparently written to document the work required by QC hold

point 85/3009 (See PIR #11217 above), but it did not ,

describe the work activity.

(h) A PIR was not evident to verify QC witness of step 14 onLData

Sheet 5-1 required by QC hold point 85/3009.

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(1) A PIR was not evident to verify QC witness of step 24 on Data

Sheet 5-2 required by QC hold points 85/2993, 85/2996, and

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85/2997.

(j) PIR #11093 dated 11/2/85 did not refer to the QC hold

point to which it applied.

(k) Steps 9-11 on Data Sheet 6 were required to be witnessed

by QC per hold point 85/3010. They were initialed and

dated on 10/31/85, but a supporting PIR dated 10/31/85 did

not exist.

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Exhibit #6 of GPUN procedure 6130-QAP-7210.03, Rev. 3-00, QA-

Mod / Ops Inspection Program states:

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"Upon completion of the inspection activity...a PIR shall

be filled out documenting the inspections performed...

All rejectable inspections must result in the appropriate

documenting of the discrepancy in process."

Paragraph 5.3 of this same procedure requires that QC

supervision assure PIRs contain sufficient information to

provide evidence that the objectives of the inspection have

been met and items requiring a followup are identified and

documented in the appropriate manner. Each of the above noted

problems (a) through (k) represents an example of failure to

meet procedural requirements. (50-219/85-35-03)

(2) After MCF work completion and QC inspection of modifications to

instrument racks RK01 and RK02, NRC inspectors identified the

following discrepancies between procedure / drawing requirements

and as-built conditions that were not previously identified by

MNCR, FCR, or any other licensee documentation: (219/85-35-04)

(a) FCR C-039642 to drawings ES-04 and ES-05 specified a

partial penetration butt weld (described in Detail 1 (A)

above). MCF only made a seal weld and not the required

partial penetration butt weld.

(b) Drawings ES-04 and ES-05 required the use of 9/16"

diameter by 3/4" long slotted holes in pieces 6 and 16,

respectively. Round holes were used instead of the

required slotted holes, resulting in a bearing connection

in lieu of the intended friction connection.

(c) Bolting details on ES-04 and ES-05 show the use of a

washer under both the bolt head and nut. Washers were not

installed as required. Additionally, due to the approved

use of shorter bolts than specified on the material list,

examples of partial thread engagement of nuts on bolts

were observed.

(d) Fillet welds used to connect piece 3 to existing

structural steel as detailed in Section 1-1 on ES-04 were

required to be 3/16" in size. The fillet welds on the

front side of piece 3 were a maximum of 1/8" in size.

This problem resulted because piece 3 overlap to create

the proper geometry for a filler. weld was only 1/8".

(e) A three-valve manifold to level indicating instrument

LI-622-916 should have been installed such that V-130-220

was the low side isolation valve and V-130-219 was the

high side isolation valve. The 3-valve manifold was

installed upside down, such that the tagged

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valves were reversed and not in accordance with GPUN

Drawing 15081.02-CC-13, Rev. O, Instrument Rack RK01

Phase I Modification Piping Schematic.

(3) NRC review of welding records and the GPUN welding program

identified an example of a job supervisor not following

procedures. In particular, a weld repair record

associated with MNCR 85-233 and Short Form 31529 to repair

existing structural welds damaged during modification to

RK01, specified MCF Production hold points to verify

cleanliness, preheat, 'and interpass temperature prior to

and during the welding. Filler metal withdrawal authori-

zations associated with this weld repair indicated weld rod

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was issued to accomplish the repair on October'27,1985 and

October 28, 1985 but on different shifts. The only sig-

nature on the weld record was dated October 28, 1985. The

GPUN Welding Manual, 6150-QAP-7220.05, Rev. 0-00, in para-

graph 4.2 of Exhibit 4, requires that, " Work shall not

proceed beyond any hold point until the appropriate

approvals have been obtained." The job supervisor-on

second shift October 27, 1985 did not sign the production

hold points. (219/85-35-05)

(4) A review of the prerequisites associated with GPUN

procedure A15B-G1136.010, Rev. O, RK01 Rack Modifica-

tions-Electrical, and a review of plant conditions to

determine if the prerequisites were met, identified a

discrepancy. Paragraph 4.7.3 required that isolation

condenser vents and main steam isolation valves be closed

when secondary containment was required because of work

around the spent fuel pool. This prerequisite was not

met, nor was the procedure changed to delete it.

(219/85-35-06)

Based on an emergency Technical Specification (TS) change

granted to perform the EQ work defined by this and other

procedures with a similar prerequisite, it was not required-

by TS to implement this prerequisite. Had it been required,

the inspector questions how MCF could have effectively im-

piemented it, since it (1) involved controlling equipment

unrelated to the work activity and not under MCF jurisdic-

tion but (2) did not specify a tagout.

The above four examples of failure to follow drawings and

procedural requirements form a single violation of Criterion V

of 10 CFR 50 Appendix B.

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(D) QC inspection activities failed to identify the following

deficiencies:

(1) The undersized fillet welds discussed in paragraph 1.C.(2)(d) '

above were inspected and accepted by QC as documented on the

RK01 Structural Weld Record Sheet for Section 1-1 on drawing

ES-04.

(2) The seal welds used in lieu of the specified partial penetration

butt welds discussed in paragraph 1.A above were inspected and

accepted by QC as documented on the RK01 and RK02 Structural. 1

Weld Record Sheets for Sections 1-1 and 1A-1A.

(3) The inadequate bolting discussed in 1.C.(2)(c) above was not

identified by QC during final inspection activities. Although

QC did not have a specific hold point or inspection attribute

to verify proper bolting, they did have a specific hold point

to witness torquing of these bolts. This inspection point, in

addition to the final inspection of the completed rack work,

offered QC two opportunities to identify the discrepancies.

(4) The upside down 3-valve manifold discussed in paragraph

1.C.(2)(e) above was not identified by QC during final

inspection activities.

The failure of QC inspection activities to identify the four deficiencies

discussed above is contrary to the requirements of Criterion X of 10 CFR

50 Appendix B and is a violation. (219/85-35-07)

2. Operational Safety Verification

2.1 Control Room Safety Verification

Routinely throughout the inspection period, the inspector

independently verified plant parameters and engineered safeguard

equipment availability. The following items were observed: 1

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Proper Control Room manning and access control;

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Adherence to approved procedures for ongoing activities;

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Proper safety systems and emergency power sources valve and j

breaker alignment; and  ;

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Shift turnover. j

2.2 Review of Logs and Operating Records 1

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The inspector. reviewed, on a sampling-basis, the following logs and

instructions for the period October 21 to December 1,1985:

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Control Room and Group Shift Supervisor's Logs;

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Control Room and Shift Supervisor's Turnover Check Lists;

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Reactor and Turbine Building Tour Sheets;

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Equipment Control Logs;

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Standing Orders; and

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Operational Memos and Directives.

] The logs and instructions were reviewed to:

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Obtain information on plant problems and operations;

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Detect changes and trends in performance;-

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Detect possible conflicts with Technical Specifications or ,

regulatory requirements; .

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Assess the effectiveness of the communications provided by the

logs and instructions; and

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Determine that the reporting requirements of Technical

Specifications were met.

The reviews indicated the logs and operating records were generally

complete. No inspector concerns were identified.

2.3 The following were noted during the inspection period.

A. Reactor Scram

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On November 20, 1985 at 0853 the facility experienced a reactor

scram due to a main generator trip.. The generator tripped as a

I result of the "B" phase differential current relay tripping.

The turbine trip resulted from the generator trip and caus I

the reactor scram because turbine load was greater than the 40% <

bypass point.

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Approximately one minute after the' plant trip, the main steam

isolation valves (MSIVs) shut causing an MSIV isolation scram.

The isolation condensers were used ta control pressure with the

MSIVs shut. Reactor pressure was stabilized at approximately

400 psig. The isolation condensers were secured after the

MSIVs were opened. Plant operators performed well in

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stabilizing reactor water level and reactor pressure using the

reactor water cleanup system for letdown and the isolation

condensers for pressure control.

The licensee theorizes that the MSIV closure was'a result of an

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IRM range 10 switch contact makeupwhen the operator manipulated

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the switches attempting to place the IRMs in range 9. The

MSIVs will shut in range 10 if pressure'is less than the low

pressure bypass setpoint of 853 psig.

The licensee determined the "B" phase current transformer (CT)

to be faulty. Repairs were complete on November'23 and the

, reactor returned to power.

. B. Main Steam Line High Flow Sensors

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The main steam line high flow sensor, RE-22B, failed

surveillance testing on November 26, 1985 as a result of a

faulty micro-switch. A plant shutdown was commenced from 636

MWe in accordance with Technical Specification requirements',

but was halted at 565 MWe after the micro-switch was replaced.

The instrument was declared operable after completing a

successful calibration.

C. Diesel Generators

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During surveillance testing on November 11, the No. 2 diesel

generator (DG) tripped on reverse power, rendering it inoper-

able. Diesei generator No. I was already inoperable as a result

of battery replacement. The licensee halted the movement of any

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heavy loads over the spent fuel pool until'the diesel generators

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were returned to service. The No. I diesel generator was re-

turned to service on November 12 upon completion of its battery

replacement. The problem with the No. 2 DG was determined to be

a failure of the electric governor control box. It was replaced

and the No. 2 DG was returned to service.

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D. Reactor Water Level Instruments

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A five inch difference in 'the new reactor water level instru-

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ments (Yarway) has existed since the startup from the outage.

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This outage was to complete changes to the Yarway reactor water

level instruments, among others, for the purpose of environ-

mental qualification. Technical Functions has been assigned to

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investigate the disparity in the Yarway level indicators.

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E. Hanger Clamp Weld Cracks

During the inspection period' the licensee discovered cracks in

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a weld on a hanger clamp (elevation 51' of the reactor building)'

on the core spray booster pump discharge piping. The licensee

removed the hanger clamp and snubber while the plant was shut-

down and ground the weld to determine if any propagation of(the

cracks had occurred into the base metal. - After grinding the

weld off and using a liquid penetrant test, the licensee deter-

mined that remaining _ base metal indications were nonrelevant.

1 The snubber and hanger clamp were re-attached.

F. Low Reactor Water Level Channel Check

A license amendment was granted by Nuclear-Reactor Regulation

(NRR) in response to-the licensee request regarding reactor

water level instrumentation channel checks. These changes

(1) revised the channel check for the low reactor water level

instrumentation channels from daily checks for all channels to

daily for those channels with control room indication only and

(2) deleted the channel check for the low low reactor water level

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instrumentation channels. NRR raised additional ~ mrns

regarding the capability to verify low reactor watc level

instrumentation communication with the reactor vessel after

surveillance testing. The licensee provided administrative

controls to ensure that the instruments were properly returned

to service after surveillance. Further discussions with NRR

resulted in returning the instrument to service in a special

manner: the high side of the instrument is valved in to p;oduce

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a half trip signal, thus, verifying high side communication

with the vessel. The next step is to valve-in the low side of

the instrument, observe the trip to clear, thus,. verifying low-

side communication with the vessel.

3. Observation of Physical Security

During daily entry and egress from the protected area, the inspectors-

verified that access controls were in accordance with the security plan

and that security posts were properly manned. During' facility tours,.the

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inspectors verified that-protected area gates were locked or guarded and

that isolation zones were free of obstructions. .The inspectors examined

vital-area access points to verify that they were properly locked or

guarded and that access control.was in accordance with-the security plan._

During the 10M outage, penetration sealing work was accomplished _in the

4160 volt room which is a vital area. Grating preventing access into

this vital area had to be removed and then reinstalled as part of this

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. work activity. The inspectors observed that coordination between MCF and

i site security was effective in ensuring proper supplementary manning of

the 4160 volt room during the time the grating was removed.

No concerns were identified.

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4. Radiation Protection

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During entry to and exit from the radiologically controlled area (RCA), l

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the inspectors verified that proper warning signs were posted, personnel

entering were wearing proper dosimetry, personnel and materials leaving

were properly monitored for radioactive contamination, and that monitoring

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instruments were functional and in calibratic..7 Posted extended Radiation

Work Permits ,(RWPs) and survey status boards were reviewed to verify that

they were current and accurate. The inspectors observed activities in the

RCA to verify that personnel complied witt: the requirements of applicable

RWPs and that workers were aware of.the radiological. conditions in the

area. i

The one month 10M outage involved a substantial radcon personnel commit-

1 ment. The inspectors observed that, in general, radcon personnel were

responsive when called upon and were knowledgeable and helpful. Respira- I

tors were not required for most work activity in the drywell. Although

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this resulted in several cases of facial contamination, it was a definite

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improvement, in that work was generally accomplished more _quickly and,

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consequently, with less radiation exposure.

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Another improvement implemented during this outage, was the use of PCM-1

high speed personnel friskers. These friskers take approximately 20  ;

seconds to frisk each vertical half of.the body as compared to the admini- i

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L stratively controlled two minute frisk using a RM-14. On November 6, the

inspectors identified a problem associated with the use of the high speed

a friskers. In particular, personnel who had carry-along items in their '

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hands would frisk one half of their body while holding the items in the  !

hand not being frisked. Upon completion of the first half body. frisk, the

o individuals would turn 180 degrees, shift the items to the hand just frisked,

complete the second half body frisk, and then leave the RCA without frisking I

the carry-along items. This is contrary to the requirements of paragraph

7.2 of licensee procedure 915.26, Rev.2, Release Surveys, which states all

items leaving the RCA must be thoroughly surveyed. These inadvertent

, failures to frisk carry-along items appeared to be fairly widespread and

jj without thought on the part of individuals involved as to the potential

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for contamination on the material, much of which was paperwork that would

eventually become plant records. The control point Health Physics techni-

, cians were involved with dosimetry issuance and were not able~ to control

frisking practices. Although no actual contamination incidents were iden-

- tified as part of this event, contaminated records have been found outside

the RCA in the past. The failure of some personnel to comply with GPUN

procedure 915.26 when exiting the RCA with carry-along items is a violation. l

(219/85-35-08) i

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During this report period, an Unusual Event was declared when a potential-

ly contaminated worker was transported to a nearby hospital. The indivi-

dual involved sustained an injury, and based upon onsite medical advice,

was not moved to complete a whole body frisk. During transportation to

the hospital, the radiation survey of the individual was completed; it was

determined that the person was not contaminated. Shortly after this

determination was made, the Unusual Event was terminated.

5. Surveillance Testing

The inspector reviewed and witnessed portions of Procedure 629,3.003,

APRM Surveillance Test and Calibration, Rev. 13, dated 9/20/85, to

determine if each test was technically adequate, was performed at the

required frequency, and was under the control of the master surveillance

schedule.

No unacceptable conditions were identified.

6. Exit Interview

At periodic intervals during the course of this inspection, meetings were

held with senior facility management to discuss the inspection scope and

findings. A summary of findings was presented to the licensee at the end

of this inspection. The licensee stated that the subjects discussed at

the exit interview did not contain proprietary information.

Also, the inspectors acknowledged receipt of the licensee's November 7,

1985 response to Violation 85-23-01, involving the use of an incorrect

method for unbackseating a valve, and Violation 85-23-02, involving a

failure to adhere to procedural requirements during drywell inerting.

Although the responses contained adequate corrective action commitments,

part of the response to Violation 85-23-01 involved a detailed discussion

of event circumstances. When asked by the inspectors subsequent to the

exit meeting, licensee management indicated that the intent of that dis-

cussion was only to explain the thought processes of the individuals in-

volved; reconsideration or mitigation of the Notice of Violation was not

requested. The inspectors acknowledged this clarification and stated that

the corrective actions would be verified in a future inspection.

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