IR 05000302/1988003

Insp Rept 50-302/88-03 on 880105-07.Violations Noted.Major Areas Inspected:Review of Circumstances Surrounding Radiation Worker Entry Into High Radiation Area W/O Radiation Monitoring Device

ML20149G438
Person / Time
Site:	Crystal River
Issue date:	01/25/1988
From:	Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20149G418	List: IR 05000302/1988003 ML20149G415
References
50-302-88-03, 50-302-88-3, NUDOCS 8802180264
Download: ML20149G438 (6)

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... 9p Report flc.: 50-302/88-03 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Facility tiare: Crystal River Docket fic.: 50-302 License No.: OpR-72 Irspection Ccnducted: M arv 5-7, 1988 /

Inspector: / U ~/

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ApprcjWd,by:g C. M. Hosey, Section Chief //.2C [8 Date Signecf-

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< Ar Division cf Radiatien Safety and Safeguards ti SUMMARY Scope: This was a special, unar.rounced inspection to review the circumstances surrcunding a raciation worker's entry into a high radiation area without a radiction nonitoring device to continuously indicate the radiation dose rat Results: Twc violatiens were identified: (1) failure to have a radiatien dose rate instrument upon entry into a high radiation area, and (2) failure to prcvide and implement adequate procedures for prompt corrective action for radiation safety violatiens and failure to follow radiological control procedure PDR ADOCK 05000302 0 DCD

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REPORT DETAILS Persons Contacted Licensee Employees

• Bright, Assistant to the Vice President, Nuclear Operations

• J. Buckner, Specialist, Nuclear Compliance

• R. Clark, Health Physicist

• A. Frierd, Nucl?ar Staff Engineer

• P. Haines, Nuclear Licensing

• A. Kazemfa 6 Supervisor, Padiological Support Services

• M. Mann, Specialist, Nuclear Compliance

• P. Mc!'.ee, Director, Nuclear Plant Operations

• S. Robinson, Superintendent, Nuclear Chemistry and Radiation Protection

• W. Rossfeld, Manager, Nuclear Corpliance

• E. Sirpson, Director, Nuclear Operations Site Support

• D. Wilder, Radiation Protection Manager

• K. Wilson, Manager, Nuclear Licensing Other Organization W. Deas, Senicr Health Physics Technician, Applied Radiological Controls NRC Resident inspector

• T. Stetka

' Attended exit intertiew Exit Interview The inspection scope and findings were summarized on January 7, 1988, with these persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail an apparent violation for failure of an individual to have a radiation survey neter when he entered a posted high radiation area (Paragraph 4). Licensee representatives pointed out that the violation resulted from an individual's willful disregard of licensee controls and requirement During a telephone conversation en January 13, 1988, between F. N. Wright of the NRC and D. Wilder of Florida Pcwer Corporation (FPC), the licensee was informed that failure of the licensee to have a proceoure addressing the requirements for prompt cocrective action for licensee identified radiological safety violations would be considered a violatien of Technical Specification (TS) 6.1 No dissenting comments were received from the license Proprietary infcrmation is not contained in this repor . Licensee Action on Previous Enforcement Matters this subject was not addressed in the inspectio o

_, 2 4. Onsite Followup cf Licensee Event (93702)

On December 31, 1987, licensee representatives contacted the NRC Region 11 Facilities Radiation Protection Staff by telephone to report an apparent Technical Specification violatio The event, which was not reportable, involved a radiation worker who entered a high radiation area without dose rate instrumentation required by Technical Specification 6.12. The report was made as a courtesy to keep the region informed of current activities in the licensee's radiation protection progra The inspector reviewed applicable radiological survey records, radiation work permits, worker training records, Radiological Safety Investigation Reports (RSIRs), and licensee radiation protection procedures. The inspector toured the licensee's radiological control areas including the reacter containnent building and interviewed the health physics technician who observed and documented the Technical Specification violation. The licensee terminated employment of t!.e radiation worker who violated the Technical Specification requirements; thus, he was not interviewed by the inspecto On December 23, 1987, the licensee was in the final days of an extended On that date a refueling outage coordinator reactor building which had begRBC)(un inentered September 1987. containment the reactor building and checked with the reactor building health physics (HP)

technician for permissien to enter the "B" D-ring to look for reactor coolant pump oil leaks. The licensee's outage organization included several reactor building coordinators, working different shif ts, who were responsible for coordinating the outage maintenance activities in the reactor buildin The reactor building coordinator entered the containment building on Radiatien Work Permit R87-038 Radiation Work Permit (RWP) R87-0381 described requirements for inspection and supervisien of maintenance activities in the reactor buildin The special instructions section of the RWP required health physics notificatien prior to reactor building entry, excluded entry into posted high radiation areas with flashing lights without health physics approval, and required a dose rate meter for entry into high radiation area .

The reactor building health physics technician told the reactor building coordinator that entry into the "B" D-ring required a dose rate meter as

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the area was posted as a high radiation area. The posted high radiation area extended from the 180 foot elevation to the 95 foot elevation.

I General area dose rates up to 200 mrem per hour were accessible on the l 95 foot elevation with contact dose rates up to 350 mrem per hour on the B j steam generato 'he licensee had two additional high radiation areas, i roped off within the high radiation zone, for portions of A and B steam l generators having dose rates up to 3,000 mrem per hou These zones were i

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equipped with a flashing light to act as a warning device. The reactor building coordinator did not have a radiation dose rate survey instrument and told the health physics technician that he would not enter the high l

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o 3 radiation area. Approximately five minutes later the health physics wchnician, beginning a tour of the reactor building, observed the reactor building coordinator in the "B" D-ring area near one of the reactor

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coolant pump motors. The dose rate in the motor area was approximately 5 mrem per hour. The health physics technician observed the radiation worker in the posted high radiation area for about 10 minute The coordinator then descended to a lower platform near the reactor coolant pump seal where two instrumentation employees were working. The instrurentation persernel had a dose rate meter with them on the reactor ccolant pump seal plattorm. The Health Physics technician observed the reacter building coordinator in the area for another five minutes and continued with a tour of the reactor buildin The reactor building health physics technician exited the reactor building about thirty minutes later, notified his supervision of the incident, and initiated a radiological safety investigation repor The exact time the reactor building coordinator left the posted high radiation area was unknow Licensee representatives estimated his stay time to be about thirty minute The licensee documented the incident on RSIR 87-026 The report stated that the RBC had entered the "B" D-Ring without a radiation detection instrument which was required by his RKP 87-381 and the area postin Intentional failure to comply with the requirement was listed as the cause for RWP violation. The RSIR reported employee termination as the licensee's corrective action. The inspector detemired that the employee had been teminated on December 30, 198 Technical Specification 6.12.1 specified that in lieu of the "control device" or "alarm sigral" required by 10 CFR 20,203(c), a High Radiation Area in which the intensity of radiation is greater than 100 mrem / hour but

less than 1,000 nrem/ hour shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Pemit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation c'ese rate in the area. Two violations of Technical Specification 6.12.1.a. for failure to have a radiation instrument when entering a high radiation area, have been documented in NRC inspection reports in the last two years (50-302/86-06 and 50-302/86-26). On January 28, 1986, while touring the Auxiliary Building with a HP supervisor, the inspector observed a radiation worker dismounting a ladder in the Triangle Room. The door to

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the reem was locked and was posted, "High Radiation Area," "Contaminated

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Area," and "RWP Required for Entry." The inspector detemined that the radiation worker had been working in the area without a dose rate mete The worker stated that his total time in the area had been less than one minute. The inspector determined that the highest dose rate in the room had been 350 mrem per hour and that the worker had not been in the vicinity of this dose rat The licensee's corrective action for violation 86-06-01 consisted of removal of the individual from the high radiation area and disciplinary action by the individual's supervisor.

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b o 4 The cncrective action for violatien 86-26-05 was simila In this instance, two individuals who had entered a high radiation area without a dose rate instrurient left the area when they discovered that there was no health physics technician with a dose rate monitor in the area. The incident was discussed with the individuals by their superviso Failure of the worker who entered the "B" D-ring, a posted a high radiation area, on December 23, 1987, to have a radiation monitoring device to indicate the dose rate in the area was an apparent violation of Technical Specification 6.12.1 (50-302/88-03-01). The inspector also stated that although the violation was identified by the licensee, all the criteria for licensee identification in 10 CFR 2, Appendix C, were not met in this case because the corrective actions detailed in response to Violations 86-06-01 ard 86-26-05 had not been sufficient to prevent a recurrenc Technical Specification 6.11 requires that procedures for personnel radiation protecticn shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all cperations invciving personnel radiation exposur The inspector discussed the contract health physics technician's failure to require prompt compliance with Technical Specification 6.12. requirements with the technician who observed the worker in the high radiation area and licensee management. The technician knew the dose rates where the RBC was located were low (5-10 mrem / hour) and that the instrumentation personnel working on the reactor coolant pump seal platform had a survey instrument. The technician assumed that the RBC would not move to areas where dose rates were greater and would leave the arer. as soon as his inspection was completed. The health physics technician's actions were discussed with the radiation protection manage The inspector emphasized the importance of timely corrective action for radiological safety violation The licensee did not have a procedure addressing prompt corrective actions for radiological safety violatiens.

I Ir a telephone conversation on January 13, 1987, between the Radiation

Protection Manager and the inspector, the licensee was informed that failure to have precedural guidance addressing requirements for prompt corrective action when radiological safety violations are identified would be considered an apparent violation of TS 6.11(50-302/88-03-02).

Plant Procedure MTARP-7.0, Controlling Access to Radiographic Areas, l

Revision 5, states that when a radiography area is established only radiographers or persons authorized by the radiographers are permitted to enter the radiography Zon The inspector determined that the dismissed radiation worker had previously violated a radiographer's posted radiation area. The incident was documented in RSIR 87-20 On October 24, 1987, the RBC entered a radiographer's posted radiation areas to check on workers. The RBC had a survey instrument and was in the area a couple of minutes. The incident

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/c a 5 report described the RBC's failure to adhere to procedures and posting requirements as intentiona Corrective action included employee counseling for the individual who had entered the radiographer's high radiation area, discussion of radiographer's procedural requirements with other RBC's and the issuance of communication redios for radiographer Fcilure to adhere to radiological control procedures was identified as a second example of an apparent violation of Technical Specification 6.11 (50-302/88-03-02). The inspector also stated that although the violation was identified by the licensee all the criteria for licensee identification in 10 CFR 2, Appendix C were not met in this case because the corrective actions detailed in response to violations 86-06-01 and 86-26-05 had not been sufficient to prevent recurrence.

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