ML20199H861

Insp Rept 50-285/97-20 on 971207-980117.Violations Noted. Major Areas Inspected:Operation,Maint,Engineering & Plant Support

ML20199H861
Person / Time
Site:	Fort Calhoun
Issue date:	01/28/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20199H799	List: ML20199H794 ML20199H824 ML20199H861
References
50-285-97-20, NUDOCS 9802050137
Download: ML20199H861 (18)

See also: IR 05000285/1997020

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ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.:

50-285

- License No.:

- DPR 40

Report No.:

50 285/97-20

Licensee:

Omaha Public Power District

Facility:

Fort Calhoun Station

Location:

Fort Calhoun Station FC-2-4 Adm.

P.O. Box 399, Hwy, 75 - North of Fort Calhoun

Fort Calhoun, Nebraska

Dates:

December 7,1997, through January 17,1998

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Inspectors:

W. Walker, Senior Resident inspector .

V Gaddy, Resident inspector -

D. Graves, Senior Project Engineer

Approved By:

W. D. Johnson, Chief, Project Branch D.

ATTACHMENT:

Supp'ier;ientalInformation

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9902050137 970128 7 *

PDR -ADOCK 05000295

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EXECUTIVE SUMMARY

Fort Calhoun Station -

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- NRC Inspection Repori 50-285/97 20

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Operations

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. In general, the conduct of operations was professional and safety-conscious, with clear

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~ and thorough turnovers conducted (Section 01.1and 01.2).

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The licensee maintained good control of operator sids (Section O2.2).

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Operations memorandums were being used, in effect, to implement procedure changes -

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.without being processed in accordance with administrative requirements (Section 03.1).

Maintenance

No preventive maintenance order existed to ensure periodic testing of a fan'requimd for

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altemate cooling of the. control room (Section 02.2).

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A sparger will be installed at the diesel-driven fire pump suction. The sparger li intended '

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to prevent sand accumulation in the pump (Section M2.1).

Engineenng

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The inspectors concluded that the maintenance rule audit was thorough and that the

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maintenance rule program improvement action plan was adequate (Section E7.1).

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Failure to maintain adequate trisodium phosphate in containment resulted in an

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. inadequate amount of trisodium phosphate to neutralize the postaccident sump water

following an accident (Secticn E8.1).

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Plant Support

Two licensee personnel entered the radiologicel controlled area without proper dosimetry

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Reoort Details

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Summarv of Plant Statua

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The Fort Calhoun Station began this inspection period at 100 percent power and maintained that

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i level until December 20,1997. On December 20/1997, power was reduced to 95 percent to

l perform a Technical Specification required surveillance for moderator temperature coefficient.

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On December 21,16. 7, a power ascension began with 100 percent power attained on

December 22,'1997. - The plant remained at 100 percent power throughout the remainder of the

inspection period.'

l. Operations

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- Conduct of Operations

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01.1

General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of

ongoing plant operations, in general, the conduct of operations was professional and

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safety conscious; specific events and noteworthy observations are detailed in the-

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01.2

Shift Tumovers

' The inspectors noted that shift tumovers and midshift briefings were good. Control room

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personnel reviewed the control room logs, walked down control room panela, and

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discussed the status of equipment during tumovers. The shift supervisor held good

. briefings for the shift crews. Operators remained cognizant of plant conditions during the

tumovers and briefings.

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Operational Status of Facilities and Equipment

02.1- Review of Eauioment Taaouts (71707)

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The inspectors reviewed the following tagouts:

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Serial Number 98-0010, Repair of Seal Leak on Main Feed Pump FW-4C

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' Seri::l Number 98-0015, Remount of Diesel Driven Auxiliary Fire Pump

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The inspectors found all tags were on the proper components and that components were

in the required tagged position. Housekeeping was observed to be good.

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02.2_ Control of Operator Aids

a.

Inanection Scone (71707)

The inspectors walked down a sample of operator aids throughout the plant to assess

how these sids were being controlled.

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Observations and Findinas -

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The inspectors performed a walkdown of inel equipment that the licensee had identified

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as being operator aids. -- An operator aid was defined as information including sketches,

graphs, procedures, drawings, prints, and other documents used to assist operators in -

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. performing assigned duties.- This equipment was controlled by Standing Order S0-0-41,

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" Control of Operator Aids and Emergency Equipment." Based on a sample of equipment

walked down, the inspectors concluded that, with few exceptions, operator aids were

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being properly controlled.

While inventorying the alternate shutdown panel lockers, the inspectors and a licensed -

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operator noted that one of five flashlights required for Abnormal Operating ' .

Procedure AOP-06, " Fire Emergency," implementation was not functional. ~ Also 3 of .

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12 door chocks required by Abnormal Operating Procedure AOP-13, " Loss'of Control

Room Air Conditioning," were missing from the lockers. These chocks were used to prop

open doors to assist in control room cooling in the event normal control room cooling was -

lost.- The inspectors verifed that the deficiencies documented above were corrected,

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The inspectors also verified that the attemate control room fan required by Abnormal -

Operations Procedure AOP 11 was in its designated location. This fan provided an

option for cooling the control rum in the event normal cooling was lost. The inspectors z

asked if there was a preventive maintenance order for the attemate control room fan to

ensure it was maintained in a reliable condition. The maintenance manager stated there -

was not a preventive maintenance order that periodically verified the attemate control

room fan was capable of cooling the control room, ' In response to the inspectors'

= questions, the licensee initiated a preventive maintenance order to test the fan on a

yearly basis. The fan was scheduled to be tested during the week of January 26,1998.

The inspectors questioned the licensee conceming the last time the fan had been tested.

tThe licensee indicated that the fan was last tested in the spring of 1995, however, the

licensee could not locate any test documentation.

c.

Conclusions

in general, the licensee maintained good control of operator aids throughout the plant.

The inspector identified a weakness in which the attemate control room fan, required by .

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Abnormal Operating Procedure AOP-13 to cool the control room, did not have a

- preventive maintenance order to ensure it was periodically tested and verified

operational.

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03

Operations Procedures and Documentation

03.1

Review of Onorations Memorandumai71707)

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Scope of Inspection

The inspectors reviewed ths active Operations Memorandums to determine whether they

provided the appropriate document to direct operator actions.

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Observations and Findings

On October 16,1997, the licensee discovered that the Updated Safety Analysis Report,

Section 8.4, stated that the capacity of the emergency station batteries in the two

separate dc systems was adequate for instrument and control power for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />

following a design basis accident. A review of documentation by the licensee determined

that no calculation supported the 8-hour capacity of the station batteries. This was-

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reported to the_ NRC on October 17,1997, and in Licensee Event Report 97-015 dated

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November 17,=1997.

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Subsequently, the licensee _ issued Operations Memorandum 97-11 regarding operator

actions to take during a design basis accident that would ensure that sufficient battery -

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capacity was available to meet design requirements. The memorandum required that, if

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the plant was in a condition such that the Emergency Operating Procedures were

implemented, and the battery charger supply to either dc bus was lost, tho' operators

were to minimize de loads in accordance with Emergency Operations -

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Procedure / Abnormal Operations Procedure, Attachment 6, " Minimizing DC Loads." The :

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inspectors questioned the licensee regarding whether it was appropriate to direct

emergency operator actions using an operations memorandum instead of _ making a

1 procedure change or revision to the emergency operating procedures. The licensee :

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stated that_ the operations memorandum process was controlled by Standing Order

Procedure SO-O-13, " Operations Memorandums" Standing Order Procedure SO-O-13

defines * Operations Memorandums," as documents which communicate operational'

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limitations, instructions,'and/or other items of interest from management to the operating

staff. - The memorandum may be more conservative or restrictive than existing

procedures, but cannot allow less conservative or restrictive operations.

- The inspectors reviewed the active operations memorandums to determine the scope of

operator guidance provided and discussed with the licensee what controls were placed

on memorandum initiation and approval.- The initial review of eight active memorandums

was begun in the previous inspection period.

Observations regarding specific operations memorandums are discussed below.

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b.1

Operations Memorandum 95-05

This memorandum directed operators to conduct evolutions to raise low pressure safety

injection header pressure, if it dropped below a specified value, to prevent potential

formation of nitrogen voids in the safety injection piping. This condition was documented

in Licensee Event Report 97-017. The required operator actions included cycling of the

low pressure safety injection loop isolation valves,

b.2

Operations Memorandum 97-06

This memorandum stated that, if MS-291 or MS-292, air assisted secondary system

safety valves, were the preferred reactor coolant system heat removal path during a

transient and they failed to fully open when required, the operators were to perform heat

removal using one of three listed alternatives,

b.3

Operations Memorandum 97-07

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This memorandum described the procedure that should be used to manually trip

breakers during a fire which resulted in evacuation of the control room. These actions

were in addition to the steps called for in Procedure AOP-06, " Fire Emergency,"

regarding breaker tripping during a control room evacuation,

b.4

Operations Memorandum 97-08

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This memorandum related to the inoperability of Main Steam Line Radiation

Monitor RM-064. During implementation of the Emergency Plan, the memorandum

directed operators to use a radiation monitor other than RM-064 for the purpose of dose

assessment. RM-064 was the normal monitor used for that purpose. If procedures

necessary to assist in the determination of a leaking or failed steam generator tube were

implemented, the operator was directed by the memorandum on how RM-064 should be

placed in service to provide radiation level trending information,

b.5

Operations Memorandum 97-11

This memorandum directed that, in the event the plant was in an Emergency Operating

Procedure, and the battery charger to either DC Bus is lost, the operators were to

minimize de loads per Attachment 6 to the Emergency Operating Procedures and

Abnormal Operating Procedures. This memorandum was canceled following a revision

to the Emergency Operating Procedures on November 18,1997.

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Procedural Requirements

The Updated Safety Analysis Report, Section 12.3.1. " Operating Procedures and

Operating Instructions," stated that plant operations are conducted in accordance with

written operating proceoores and operating instructions. Section 12.3.2," Emergency

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and Abnormal Operating Procedures," stated that plant operation during abnormal

conditions are conducted in accordance with written Emergency Operating Procedures

and Abnormal Operating Procedures.

Standing Order SO-O-1, " Conduct of Operations,' Revision 36, Section 12.1.2,

" Procedure Adherence,'sts'.ed that performance of an activity without referring to the

procedure does not relieve the individual from responsibility for performing the activity in

accordance with the latest revision of the approved procedure.

Standing Order SO-G-30, " Procedure Changes and Generation,' identified the prowss

by which plant operating procedures were revised or created. Operations

Memorandums are not listed as one of the documents covered by this procedure.

Standing Order S0-0-13, " Operations Memorandums," provided the guidaace for

initiation and revision of operations memorandums. Section 5.1.3 of Standing Order SO-

O-13 states that a review of the operating manual shall be conducted during the

generation phase of the Operations Memorandum to ensure that appropriate guidance is

given in all applicable operating procedures or instructions and that changes to affected

procedures will be in accordance with Standing Order G-30.

The Operations Memorandums referenced above directed operator actions in addition to,

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or different from, those required by plant procedures. Those memorandums, in effect,

constituted changes to the referenced procedures, or generation of new procedures,

without implementing the requirements of Technical Specification 5.8.2 or Standing

Order SO-G-30 regarding procedure changes or generation. Most significantly, Standing

Order S0-0-13 did not require a 10 CFR 50.59 screen or evaluation that would normally

be required of a procedure change or new procedure generation. The use of operations

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memorandums to direct operator actions, especially in the case of emergency operating

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procedures, abnormal operating procedures, and emergency plan procedures, precluded

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important steps or information, contained in the operations memorandum but not in the

reference procedure, from being included in plant procedures. This, in turn, introduced

the vulnerability that these r3 quired steps or actions may not get performed during

periods of high stress such as those that may be present when thosc procedures are

being implemented. Implementing changes to plant procedures without following the

prescribed process is a violation of Technical Specification 5.8.2 (50-285/9720-01).

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Conclusion

Operations memorandums that directed operator actions in addition to actions contained

in existing plant procedures constituted procedures, or changes to procedures, that had

not been orocessed in accordance with the administrative requirements regarding

procedure changes and generation.

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II. Maintenance

M1

Conduct of Maintenance

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M1.1 General Comments

a.

Insoection Scooe (62707)

Repair of component cooling water pump casing vent valve,

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DG 1 relay replacement,

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Toxic gas rr snitor tape replacement,

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Repair of diesel fire pump discharge check valve.

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Observations and Epshags

The inspectors found the work performed under these activities to be professional and

thorough. All work observed was performed with the work package present and in active

use Maintenance technicians were experienced and knowledgeable of their assigned

tasks. The inspectors frequently observed supervisors and system' engineers monitoring

job progress, and quality control personnel were present when required by procedure.

c.

Conclusions

The maintenance activities observed were conductad in a controlled and professiona!

mar,ner.

M1.2 Surveillance Activiti.g3

a.

Insoection Scoce (61726)

The inspectors observed all or portions of the following surveillance activities:

SE-ST-AFE-3005," Auxiliary Feedwater Pump FW-6, Recirculation Valve, and

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Check Valve Test.= " Revision 14;

IC-ST-1 A-3003, " Raw Water instrument Air Accumulator Check Valve Operability

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Test," Revision 7;

IC-ST-AFW-0001, " Auto Initiation of Auxiliary Feedwater Functional Check of

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Initiation Circuits," Revision 18;

CH-FT-01-67718, " Functional Testing of B Steam Generator Blowdown Station

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Conductivity Sensor CE-67718," Revision 1;

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EM ST ESF.0001, ' Quarterly Engineered Safety Features Offsite Power Low

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Signal (OPLS) Sensor Check,' Revision 7,

b.

Qhagryations and Findinas

Surveillance activities were generally completed thoroughly and professionally.

c.

Conclusions

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The surveillance activities observed by the inspectors were completed in a controlled

manner and in accordance with procedures.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1 Diesel-Drivfga Firs Pumo Failure

a.

lDagaglion Scone (62707)

The inspectors followed up on diesel driven fire pump sanding issues.

b.

Observations and Findinos

On January 5,1998, the diesel-driven Pe pump was declared inoperable to perform

Surveillance Test OP-ST FP-000.D, " Fire Protection System Inspection and Test."

During the test, the discharge valve of the pump was shut and tiow was discharged to

the pump suction well. Following the approxlinate 30-minute pump run, the discharge

valve was opened and the fire protection system was ryescurlzed using the jockey

pump. During system repressurization, the jockey pump could not repressurize the

system. The licensee suspected that the discharge chsck val.'s was not properly seated

and water was leaking by the check valve through the pump. Since the system could not

be repressurized, the diesel-driven pump remainod inoperable.

On January 7 maintenance parsonnel disassembled the check valve and verified that

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sand prevented the check valve from properly seating Maintenance personnel removed

approximately 6 to 7 gallons of sand from around the check valve flapper.

- On January 8, the licensee performed Surveillanco Procedure OP-ST FP 0001D to show

that the pump was operable following maintenance on the check valve to remove the

sand. When the pump received a start signalit failed to start. Operations personnel

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present at the pump stated that the pump shaft started to rotate and then stopped. A

second attempt was made to start the pump, but this time the shaft did not turn.

Operations personnel backed out of the procedure and a maintenance work request was

written to troubleshoot the pump.

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On January 9, during troubleshooting, maintenance personnel determined that the pump

would not start because of sand accumulation in the pump suction. The pump was

disassembled and the sand was removed.

Normally, during the monthly surveillance test of the motor-driven pump, the flow path

was from the discharge of the motor-driven pump through 12 inch and 8 inch piping to

the discharge tunnel back to the river.

The normal monthly surveillance flow path for the diesel-driven fire pump was from the

discharge of the pump through a 2.5-inch pipe to the pump suction well. Engineering

personnel suspected that the smaller diameter piping used during testing the diesel,

driven pump may not be adequate to ensure that the piping was thoroughly flushed. On

January 10, during the operability test following the January 9 maintenance, the licensee

changed the flow path to direct flow through the 12-inch and 8-inch piping used to test

the motor-driven fire pump. The operability test was successful using this flow path.

Following the surveillance, the discharge check valve was disassembled and inspected

and no sand was noted. The diesel-driven fire pump was then declared operable.

The system engineer informed the inspectors that the pump would be run weekly for a

period of time and the surveillance test procedure was being changed to reflect the new

discharge flow path. Following the weekly pump runs, the check valve was to be

inspected for sand. The system engineer also stated that a modification tr ?nstall a

sparger at the pump suction was scheduled for February 1998.

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Conclutioni

The system lineup used for testing the diesel-driven fire pump may have contributed to

sand accumulation at the suction of the pump. The licensee plans to install a sparger on

the pump. The sparger is intended to prevent further sand accumulation problems,

M8

Miscellaneous Maintenance issues

M8.1 (Closed) Insoection Follow-Un item (IFI) 50-285/9608-01: replacement of Jacket water

temperature control valve. This item remained open to allow the licensee to determine

why the vendor changed the dimensions of a critical quality element without informing

the licensee. Specifically, the vendor changed the dimensions of the jacket water

temperature control valve of the diesel generator. Also, the item remained open to allow

the licensee to address why a material discrepancy notice report was not initiated in a

more timely manner to document the nonconforming condition.

The licensee determined that the installed jacket water temperature control valve was

manufactured using a drawing dated April 1959. The replacement part was

manufactured using a drawing dated May 1983. In the late 1970s, the dimensions for

both the upper and lower valve cases were changed, however, the overall valve

dimensions remained the same. Although the dimension changed, the part numbers

remained the same.

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The licensee stated that the reason for the delay in initiating the material discrepancy

notice report was unclear guidance as to when a material discrepancy notico report

should be initiated. The guidance was changed to require that a material discrepancy

notice report be initiated at the time of discovery of a nonconforming condition.

Since the replacement part would not fit, the licensee tagged the replacement part with a

material discrepancy notice report and stated that the part would remain in the

warehouse until the material discrepancy notice report evaluation resolved the problem.

M8.2 (Closed) Insoection Followuo item 50-285/9707 03: component cooling water leak. This

item was opened following a leak in the component cooling water system following a cut

made in an isolated section of piping while performing a modification to abandon the

waste evaporator. The inspector reviewed Condition Report 199700479 which

documented the event, evaluation, and subsequent corrective action. The work was

determined to have been properly controlled. The isolation valve that had been closed to

provide system isolation did not completely close. The failure of the valve te obtain

complete closure was determined to be the result of sand that had built up in the valve

seating area because of opening and closing ef the raw water to component cooling

water system interface valves in past years. The previous testing methodology had

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allowed raw water, including any entrained sand, to be introduced into the component

cooling water system. The waste evaporator had not been operated since the early

1980's and the component cooling water supply and return lines associated with the

waste evaporator had not been routinely cleaned or tested. The testing methodology for

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the interface valves was changed in 1990 such that raw water would not be iritroduced

into the component cooling water systam, Since that time, no indication of valve fouling

due to residual sand buildup had been observed in other parts of the system. The

inspector also verified that procedure revisions were made to add component cooling

water to the list of systems that required briefings prior to work if single valve isolations

were to be used.

Ill. Enaineerina

E1

Conduct of Engineering

E7.1

Maintenance Rule Quality Assurance Audit

Between November 3 and 8,1997, the licensee performed a quality assurance audit of

the implementation and effectiveness of the maintenance rule program. The audit was

primaH!y ceducted by contract personnel with a member of the licensee's quality

assurance organization serving as the audit team leader. The inspectors noted that the

contractors were industry personnel with experience in maintenance rule implementation

and witii probabilistic risk analysis. The inspectors noted that the audit was thorough

und self-entical. The audit team concluded the following about the Fort Calhoun

- Station's implementation of the maintenance rule:

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The structure and current status of the probabilistic risk analysis was not

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commensurate with the needs for the maintenance rule. This has delayed fine

tuning and verification of the performance criteria.

The monitoring approach implemented by the Fort Calhoun Station will not

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adequately highlight troublesome systems for expedited attention.

Previous internal maintenance rule assessments did not subject the program to

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challenges expected today and may have given management an unjustified

sense of comfort.

Integration of the maintenance rule into the daily routine has not been achieved

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and the maintenance rule was viewed as a separate and decentralized issue of

regulatory compliance.

Training of personnel who are responsible for the implementation and integration

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of the maintenance rule program has not been adequate or effective.

The processing of information, monitoring, trending, goal setting, and the

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updating of procedures must be expedited to assure that timely decisions can be

made.

Management oversight and cognizance of the maintenance rule had been weak

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and needs to be strengthened.

Because the plant has a sound framework of the maintenance rule program in

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place, and has an effective data base for monitoring the performance of system,

structures, and components, the audit team believed that a short term upgrade

plan can bring the maintenance rule program up to date.

In response to the audit conclusions, the licensee developed a maintenance rule

program improvement action plan to address the above areas and other areas needing

improvement. The action plan was scheduled to be completed prior to the beginning of

the 1998 refueling outage. The inspectors concluded that the maintenance rule audit

was thorough and that the maintenance rule program improvement action plan was

adequate to resolve deficiencies identified during the audit.

E8

Miscellaneous Engineering issues

E8.1

(Closed) Licensee Event Reoort (LER) 50 285/95-08: failure to maintain adequate

trisodium phosphate inside containment due to a calculational error. On December 4,

1995, the licensee determined that, at the beginning of the last several plant operating

cycles, the amount of trisodium phosphate in the containment was not sufficient to

neutralize the postaccident containment sump water to a ph of 7.0.

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Subsequently, the licensee performed an operability evaluetion wh!ch determined, for

current conditions, that the amount of trisodium phosphate inside containment was

adequate for maintaining a ph of 7.0 or greater.

The licensee took the following corrective actions:

Appropriate calculations and analysis were performed to ensure that a sufficient

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amount of trisodium phosphate in the containment sumps was available so that a

neutral ph for each operating cycle can be achieved following a loss-of-coolant

accident;

Based on the revised calculations, additional trisodium phosphate was placed in

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the containment during the September 1996 refueling outage;

A Technical Specification amendment was submitted to reflect the requirements

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for increased trisodium phosphate in the containment based on the revised

calculations and analyses;

The updated safety analysis report and design basis document were scheduled

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to be corrected during the next scheduled update;

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Training was provided to chemistry and operation personnel on the document

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changes and modifications;

Chemistry Procedure CH ST-CH-0002, * Phosphate Basket inspection,' was

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revised to ensure that the new Technical Specification requirements for trisodium

phosphate were properly verified, and;

To ensure the quaritity of trisodium phosphate in the containment continues to be

adequate for future operating cycles, the calculations and analyses used to

determined the quantity of trisodium phosphate in containment will be reviewed

as part of each operating cycle's core reload analysis.

Failing to maintain the Technical Specification required trisodium phosphate in

containment which would ensure that a ph of 7.0 or greater could be achieved following a

loss of-coolant accident is a violation. This nonrepetitive, licensee identified and

corrected violation is being treated as a noncited violation consistent with

Section V 11.B.7 of the NRC enforcement policy (50 285/9270-02).

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IV. Plandupport

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R1

Radiological Protection and Chemistry Controls

R1.1 Tours of Radiolnalem!IV Controlled Areas

a.

Inanection Scone (71750)

The inspectors performed frequent tours of the radiologically controlled area and

observed work practices of plant personnel,

b.

Obseryall00s and FindlD91

During this inspection period, the inspectors made frequent tours of the radiologically

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controlled area. Radiation protection personnel were observed performing their duties in

a professional manner, Personnel performing maintenance in the radiologically-

controlled area were observed to be following all requirements of their radiation work

permit.

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While touring Room 6 (Charg ng Pump Room) on December 24,1997, the inspectors

noted that the high radiation and contaminated area rope boundary around Charging

Pump CH-1C had fallen. The inspectors informed radiation protection personnel and the

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boundary was restored. Radiation protection personnel determined that duct tape had

been used to hold the rope ends that formed the boundary. The heat generated from the

operating charging pump caused the glue on the tape to melt and the rope boundary fell

down. The licensee initiated a condition report to document this occurrence. As part of -

the corrective action to close the condition report, the licensee was evaluating whether

the use of duct tape to establish radiation areas and contaminated areas was

appropriate.

c.

Conclusl2DA

The inspectors identified a poor work practice in which duct tape was used in an elevated

temperature environment to construct a boundary around a high radiation area and

contaminated area. Plant workers exhibited good radiation protection practices.

R1.2 EDkjes into the Radioloolcally Controlled Area Without Electronic Dosimetry

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a.

Insoection Scoos (71750)

The inspectors followed up on two instances in which security personnel entered the

radiologically controlled area without electronic dosimetry.

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b.

Observations and Findinoj

On January 1,1998, a security officer entered the radiologically controlled area without

an electronic c:osimeter (ALNOR). The purpose of the entry was to perform fire door

checks. On January 10, another security officer entered the radiologically controlled

area without an electronic dosimeter. The purpose of this ent'y was to respond to a

security alarm. Neither of the security officers entered high radiation areas. Both of

these instances were identified by the licensee. In each instance, the officers were

excluded from the radiologically controlled area.

During interviews with the individuals involved, the licensee determined that one

individual needed additional radiation protection training.

As a corrective action, the officers involved were given verbal warnings and counseled

by licensee management. The occurrences were also discussed on plant human

performance day. The licensee identified three contributing causes for these

occurrences. The licensee stated that the occurrences were caused by lack of

personnel accountability, training deficiencies, and an unclear expectation for obtaining

electronic dosimetry by security officers. Security management Indicated that the

expectation for obtaining electronic dosimetry was being clearly defined. The radiation

protection manager indicated that they were considering reevaluating general employee

training to ensure that all plant workers are aware of the licensee's expectations with

regard to electronic dosimetry usage.

The inspectors reviewed Standing Order SO-G-101, ' Radiation Worker Practices," and

noted that Step 5.3.2F required personnel that entered the radiologically controlled area

be monitored with a direct reading or electronic dosimeter. Entering the radiologically

controlled area without a direct reading or electronic dosimeter is a violation. This

nonrepetitive, licensee-identified and corrected violation is being treated as a noncited

violation consistent with Section Vll.B.1 of the NRC Enforcement Policy

(50-285/9720-03).

c.

Conchliions

A lack of personnel accountability, training deficiencies, and unclear expectations for

obtaining electronic dosimetry by security officers were identified as being contributing

causes for security personnel entering the radiologically controlled area without

electronic dosimetry. The actions taken by the licensee appear to be adequate to ensure

that entries into the radiologically controlled area are made with proper dosimetry.

V. Management Metilngs

X1

Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management on

January 20,1998. The licensee acknowledged the findings as presented.

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The inspectors asked the licensee whether any materials examined during the inspection

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period should be considered proprietary, No proprietary information was identifed.

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ATTACHMENT

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SUPPLEMENTAL INFORMATION

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- PARTIAL LIST OF PERSONS CONTACTED

Licensee

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D. Buell, System Engineer

D. Dryden, Station Licensing Engineer

S. Gebers, Manager, Radiation Protection

B. Mierzejewski, Systems Engineer

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R. Phelpi,, Manager, Station Engineering

C. Schaffer, System Engineer

J. Sefick, Manager, Security

R. Short, Manager, Operations

INSPECTION PROCEDURES USED

4

,

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IP37551:

Onsite Engineering

IP 61726:

Surveillance Observations

IP 62707:

Maintenana Observations

IP 71707:

Plant Operations

IP 71750:

Plant Support Activities

ITEMS OPENED. CLOSED. AND DISCUSSED

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Opened

50-285/9720-01

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use of operations memorandums to implement procedure

changes (Section 03.1)

Closed

,

50-285/9608-01

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replacement of Jacket water temperature control valve

(Section M8.1)

50 285/9707 03

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component cooling water leak (Section M8.2)

50-285/9508

LER

failure to maintain adequate trisodium phosphate inside

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containment (Section EB.1)

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Opened and

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50-285/9720-02

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failure to maintain adequate trisodium phosphate inside

containment (Section E8,1) _

50 285/9720-03

NCV

entry into the radiologically controlled area without electronic

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dosimetry (Section R1.2)

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