BSEP-90-0565, Responds to Violations Noted in Insp Repts 50-324/90-06 & 50-325/90-06.Corrective Actions:Personnel Counseled on Closure of Locked High Radiation Area Doors & Preventive Maint Program Established for Reactor & Turbine Bldg Gates

Responds to Violations Noted in Insp Repts 50-324/90-06 & 50-325/90-06.Corrective Actions:Personnel Counseled on Closure of Locked High Radiation Area Doors & Preventive Maint Program Established for Reactor & Turbine Bldg Gates

ML20063Q153
Person / Time
Site:	Brunswick
Issue date:	08/16/1990
From:	Harness J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-90-0565, BSEP-90-565, NUDOCS 9008200147
Download: ML20063Q153 (3)

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Carolms Power & Light Company Arunswick Nuclear Project P. O. Box 10429 Southport, N.C. 28461 0429 August 16, 1990 FILE: B09-135100 10CFR2.201 SERIAL: BSEP/90 0565 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 BRUNSVICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50 325 AND 50 324 LICENSE NOS. DPR 71 AND DPR 62 SUPPLEMENTAL RESPONSE TO A NOTICE OF VIO1ATION Centlemen:

The NRC issued to Carolina Power and Light Company a NOTICE OF ' VIOLATION concerning locked high radiation area boundary violations at the Brunswick Steam .

Electric l'lant (BSEP) in NRC Inspection Report 50 325/90 06 and 50 324/90 06.

In the Company's June 29, 1990 response, CP&L committed to provido a supplemental response by August 17, 1990. The attached response fulfills that commitment. t Very truly yours, IM M J. L. Harness, Ceneral Manager  !

Brunswick Nuclear Project '

TH/th Enclosure cc: Mr. S. D. Ebneter Mr. N. B. Le '

BSEP NRC Resident Office l

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BSEP 90 0565 Page 1 ATTACRMENT 1 SUPPLEMENT TO NOTICE OF VI01ATION Carolina Power and Light Company is extremely dissatisfied with the frequency of locked high radiation area doors found unsecured during the last year at the Brunswick Plant. In order to make significant improvement, strong programmatic actions 1ere taken to preclude recurrence of these incidents.

Environmental and Radiation Control (E&RC) and Operations personnel received special counseling on their responsibilities to confirm the proper closure of the locked high radiation area doors they pass through.

These personnel, which are the primary users of locked high radiation area doors, received this counseling through Real Time Training and management directive (both verbal and written).

ELRC Procedure 0040, " Locked High Radiation Area Key Control," was revised to provide centralized issuance of locked high radiation area door keys by the E&kC group.

with the Operations Previously, group issuing keysthese keys were issued to Operations primarilyInby R&RC, personnel.

addition, a verification form was developed to accompany each locked high radiation area key whenever a worker checks a key out. This form provides improved accountability radiation area door by/sherequiring he a worker accesses, and to also document each locked document his/her high verification that the door was properly locked af ter each entry / exit.

This form is being implemented on an interim basis, and its continued use will be evaluated following completion of any additional corrective actions that may result from the Human Perfor. nance Assessment discussed below.

A Preventive Maintenance program was established for the Reactor Building and Turbine Building gates that are self locking, with the intent of ensuring proper operation of these doors. These doors have been involved in the majority of the door incidents.

For a six month period following the implementation of these latest programmatic improvements, there were no incidents of high radiation area doors being unlocked. On August 3, 1990, a high radiation door was found to be open during a routino check by Heelth Physics. The open door was found a short period of time af ter the door was left open, demonstrating the effectiveness of the mitigating accians instituted by the plant. The verification form initiated by E&RC enabled the plant to very quickly determine the individuals involved, and  !

s to subsequently determine that personnel error, inadequate verification, was the reason for the door being left open. Appropriate disciplinary actions have been taken with the involved personnel, independent of the above items, a Human Performance Evaluation (HPE) assessment  !

was performed on the high radiation door evcnts relative to this violation.

Based on this assessment, design deficiencies relative to the latched gates have been identified. CP&L's Nuclear Engineering Department (NED) has been requested  !

to determine the most feasible methods for eliminating the design deficiencies involved with the latched gates. Engineering of the necessary changes to the latched gates is ongoing. Following completion of the engineering packages, any proposed changes will be evaluated and scheduled in accordance with the site Nuclear Prioritization Process.

The work on these gates is considered to be an enhancement to the programmatic chany,es that have been made. CP&L feels that full compliance has been achieved on this issue, irrespective of upcoming changes to the latched gates. The real issue with door control lies not with poor door design or closure devices, but rather with the failure of individuals using plant doors to verify that they are

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BSEP 90-0565 Page 2 ATTACHMENT 1 SUPPLEMENT TO NOTICE OF VIOLATION closed and latched. Reliance on automatic closure devices alone to control a door required to be shut and latched is not an acceptable practice. .i To ensure this philosophy is stressed to site personnel, a memorandum was issued on August 12, 1990, delineating this philosophy. To further stress this point, the Brunswick Training Unit will include this information in General Employee Training / General Employee Retraining (CET/GER) programs. In addition, Plant ,

Management and Security personnel have been requested to monitor personnel use  !

of doors during normal plant tours..  :

Personnel accountability for the quality performance cf tasks by individuals and

• their supervision has been reinforced to site personnel by plant management. ,

Individuals are being held personally accountable for their actions relative to  !

the closure of these doors, as demonstrated by the August 3,1990 event. l Based on the effectiveness of the programs establiabw since the issuance of this I violation in both the prevention of these deficiencies and the effectiveness and timeliness of discovery of the deficiencies, CP&L conaders the BSEP program for the control of high radiation area doors te ne in compliance wIth the requirements of the Technical Specifications. Any additional work on the latched i gates is considered to be an enhancement to the existing program, and is not  ;

required to ensure compliance with Technical Specifications. BSEP management .

l feels that only by the attention of each individual can proper door control be assured.

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