IR 05000285/1989004

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)

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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.

Inspector:

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H. Chaney', Senior Radiatiorf Specialist Date Facilities Radiological Prdtection Section

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89 Approved:

. 6aer, Chief

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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

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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 l

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

l R. Cords, RP Technician 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

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• 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:

Open Item Title See Paragraph

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28$'8904-03 Verification of Personnel Quarterly Exposure - NRC Form 4, 5.c l

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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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-4 (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 Department organization, first line supervisor authority, staffing, lack

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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

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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 I

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

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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.

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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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-6-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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-7-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.

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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.

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The appropriate access control and monitoring will be specified on the Radiation Work Permit (RWP) required. for entry into high radiation areas.

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Health Physics must be aware that you are to enter the area and the reason for the entry.

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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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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 l.

were reviewed:

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

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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.

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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

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employee.in accordance with 10 CFR Part 20.408.

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

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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

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

their employment at FCS in accordance with the instructions in

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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 H

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employment or having their dosimetry terminated that had access to

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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)

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No deviations were identified.

I 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

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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

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control points established in the auxiliary building were inspected.

No violations or deviations were identified.

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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:

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(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

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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

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

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-12-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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-13-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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