IR 05000309/1996012

Ack Receipt of 970107 & 0425 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-309/96-12 & 50-309/96-14.Security Violation Involving Control of Safeguards Info Discussed

ML20151L975
Person / Time
Site:	Maine Yankee
Issue date:	07/31/1997
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Sellman M Maine Yankee
References
50-309-96-12, 50-309-96-14, NUDOCS 9708080097
Download: ML20151L975 (3)

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UNITED STATES NUCLEAR REGULATORY COMMISSION f

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475 ALLENDALE ROAD k, KING oF PRUsstA, PENNSYLVANIA 19406-1415

• • • • • July 31, 1997 Mr. Michael President Maine Yankee Atomic Power Company 329 Bath Road Brunswick, Maine 04011 SUBJECT: NRC INSPECTION REPORT NOS. 50-309/96-12 AND 50-309/96-14 - REPLY

Dear Mr. Sellman:

We have reviewed your letters dated January 7, and April 25,1997, providing your responses to the Notices of Violation transmitted in our letters dated December 9,1996, and March 13,1997.

Regarding the violation involving a failure to maintain the primary vent stack (PVS)

sampling system operable, we understand that the PVS was returned to service shortly after the problem, and that the associated procedure was revised to prevent recurrence.

Regarding the security violation involving control of safeguards information, we note the numerous actions you have taken to prevent recurrence of these types of events. With regard to the violation involving control of contamination, your programmatic enhancements appear appropriate to clarify management expectations and procedural requirements regarding contamination control. Finally, regarding the violation involving proper testing of the spent fuel pool crane, and based on the recent problems encountered with the same equipment during core offload, it would appear that your corrective actions might not have been fully effective. This issue is currently being reviewed by the NRC resident inspectors and the results of that review will be documented in a future inspection report.

Thank you for informing us of the corrective and preventive actions documented in your f letters. These actions will be examined during future inspections of your licensed I programs.

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Your cooperation with us is appreciated.

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Sincerely, f

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9700000097 970731 PDR ADOCK 05000309 G PDR HlRINlltMMIgls

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I Michael i Distribution w/cy of Licensee Response Ltrs:

Region 1 Docket Room (with concurrences)

, Nuclear Safety Information Center (NSIC)

! PUBLIC NRC Resident inspector D. Screnci, PAO C. Cowgill, DRP R. Summers, DRP D. Bearde, DRP W. Dean, OEDO S. Varga, NRR l D. Dorman, PM, NRR

! M. Callahan, OCA R. Correia, NRR F. Talbot, NRR D. Screnci, PAO N. Sheehan, PAO Inspection Program Branch, NRR (IPAS)

DOCDESK (INSPECTION RPTS)

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MaineYankee REll ABLE ELECTRICITY SINCE 1972 329 BATH ROAD e BAUNSWICK MAINE 04011 * (207) 798 4100 January 07,1997 MN-97-06 JRH-97-06 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555 References: a) License No. DPR-36 ( Docket No. 50-309 )

b) USNRC Letter to MYAPCo dated December 08,1996, Notice of Violations for NRC Inspection Report 50-309/96-12 Subject: Reply to Notice of Violations Associated with NRC Inspection Report No. 50-309/96-12 Gentlemen:

The attachments to this letter provides Maine Yankee's reply to the Notice of Violations contained in Reference (b). In attachments "A & B", we have restated the violations, provided our response and have addressed our actions taken and planned to prevent recurrence. Also included, in attachment "B", is Maine Yankee's response to section S t.l.c, of Reference (b), pertaining to the narrow scope of previous corrective actions.

Please contact us should you have any further questions regarding this matter.

Very tmly yours, xm 0 {< Y

' James R. Hebert, Manager Licensing & Engineering Support Department i

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Attachments

c: Mr. Hubert Miller l Mr. J. T. Yerokun l Mr. D. H. Dorman l Mr. Patrick J. Dostie Mr. Uldis Vanags l

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ATTACHMENT "A" Violation "A" Technical Specification 5.8.a.3, states in pan that, Monitoring, Sampling and Analysis of radioactive gaseous effiuent is in accordance with 10 CFR 20.106 and with the methodology and parameters in the Off-Site Dose Calculation Manual. The ODCM requires process system operability.

Contrary to the above, on October 4,1996, Maine Yankee personnel disabled the Primary Vent Stack Air Particulate and Gas Monitoring system making it inoperable for a period of approximately one hour due to a deficient procedure and/or operator error when the nonnal primary vert stack sampling system was retumed to service without the iodine and particulate filter cartridges irstalled thereby rendering the system inoperable.

Maine Yankee Response:

On October 1,1996, the primary vent stack (PVS) high range particulate, gas, halogen, and

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particulate filters were taken out of service to allow station Instrument and Controls (I&C)

technicians to repair the PVS air paniculate detector (APD). Alternate sampling was invoked to compensate for the loss of halogen and paniculate filters. This consisted of removing the normal halogen and paniculate filters and operating an alternate filter cartridge. The normal station practice is to remove the filters from the normal cartridge and reinstall them in the alternate cartridge.

On October 4,1996, the normal sampling system was returned to service in accordance with procedure 1-12-8, " Primary Vent Stack Air Paniculate and Gas Monitor". The procedure did not specifically direct operators to reinstall the filters from the alternate canridge into the normal cartridge. The error was discovered by Chemistry personnel checking the normal lineup. The normal PVS sample system operated without halogen and particulate filters for 49 minutes.

Immediate Corrective Actions:

The halogen and particulate filters were removed from the alternate cartridge and placed in the

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normal cartridge. A Temporary Procedure Change was written on October 4,1996, to ensure that Chemistry has installed the halogen and paniculate filters in the normal filter housing when shifting from auxiliary PVS sampling to normal PVS sampling.

Corrective Actions Taken to Avoid Further Violation:

The Temporary Procedure Change was incorporated into Procedure 1-12-8 during PORC meeting 96-076 on November 7,1996. Procedure 1-12-8 was reviewed in its entirety. Whereas the procedure is adequate to prevent a reoccurrence, funher enhancements are being made to the procedure.

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Full Compliance Date:

Full compliance was achieved on October 4,1996, when the halogen and paniculate filters were reinstalled in the normal filter cartridge. (The normal PVS sample system operated without halogen and particulate filters for 49 minutes.)

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ATTACIIMENT "B" Violation "B" The NRC approved Maine Yankee Security Plan and 10 CFR 73.21.d(2) require in part, that while unattended, Safeguards Information shall be stored in a locked security container.

Contrary to the above, on October 17, 1996, Safeguards Information was left unattended for approximately two hours on a desk in the security office inside the protected area.

Maine Yankee Resnonse:

The event description constituting the above violation is correct. The type of Safeguards Information (S.I.) that was left unattended normally is transported by Security' Officers, wearing it around their neck, to the weapons room, inventoried by a supervisor and placed in a safeguards locker. In this case the destination was to the Administrative Secretary for destruction, the officers did not deliver them in a red envelope as the procedure states, and the material was not readily identifiable on the desk when the secretary left for the day.

Immediate Corrective Actions:

1. Security made an evaluation for compensatory measures and reportability immediately on discovery of the uncontrolled Safeguards Information.

2. Compensatory measures were implemented until it was determined that the Safeguards Information was not compromised.

Corrective Actions Taken to Avoid Further Violations 1. Reinforcement training on the handling and transporting of Safeguards Information was provided to all Security Personnel. The annual requirement for this training has been

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changed to semi-annual. Initial Training Comoleted 11/30/1996

I 2. Reinforcement training on adherence to security procedures has been provided and will continue to be reinforced on a quarterly basis. Comoletion ofInitial Training by 1/15/97 l 3. Heighten the Security Force awareness that a questioning attitude is always needed and the must maintain a global view of their surroundings. A STAR (Stop, Think, Act, Review)

Program has beer initiated. Comoletion by 2/28/1997 4. Evaluate significant security incidents and corrective actions implemented since 1990 to ensure that they are still applicable, have been implemented uniformly, and have been effective. Review to be comoleted by 2/28/1997 5. Disciplinary action was administered.

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Full Compliance Date:

Full compliance was achieved on Oct. 17,1996, when the Safeguards Information was properly controlled and compensatory measures were implemented.

Maine Yankees Response to the Trend of Safeguards Information Incidents:

The two reportable items mentioned in the notice to violation (Inspection scope 71750) pertained to drawings found in the 345 Yard Relay House which dated back to the 1979 time frame and a copy of the Security Training & Qualification (T&Q) plan in the corporate office which dated back to the 1981 time frame. Corrective actions taken in regards to these two matters were:

1. A thorough review was performed to insure that no funher drawings were uncontrolled. This was completed in July of 1993 with no other uncontrolled drawings being discovered since that review.

2. A thorough review of all security related correspondence and documentation dated between Jan.1,1976 and December 31,1984 was completed in August of 1996 with no concerns being identified to date.

The loggable events mentioned in the Notice of Violation ( Inspection Scope 71750) involved unsecured and uncontrolled safeguards lockers and information. The long term corrective actions taken to address these concerns are as follows:

NOTE The intent is to reduce the number of safeguard repositories and handlers to the extent possible, understanding that these numbers may change over time.

1. Reduce the number of safeguard repositories.

• As of 9/30/96, 5 of 11 have been eliminated.

Another will be eliminated by 1/31/97.

2. Reduce the number of personnel handling Safeguards Information.

Security Personnel, rather than Operations Personnel, are now making revision changes to the Control Rooms copy of Security Procedures.

(Complete)

a Reduced the full time access list to Safeguards Information from 63 - 31.

This does not ' include Contract Security Personnel. (Complete)

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a Assign expiration date to individuals who need temporary access to Safeguards Information. (Complete)

3. Provide semi-annual Safeguards Information handling training to all repository custodians and individuals on the active access list. (Initial Training Completed)

The Contract Security Force is receiving quarterly training.

4. Review security documents and insure just Safeguards Information is being controlled as Safeguards Information. Completion Date 1/31/97.

a Rewrite security procedures to incorporate lesson plans, Security Operating Procedure's (SOP's), performance evaluations and decontrol procedures that do not contain Safeguards Information. Completion Date 1/31/97.

Evaluate the need for handling safeguard event logs, daily logs and shift schedules as Safeguards Information. Completion Date 1/31/97.

Response Matrices will be eliminated. Completion Date 1/15/97.

5. Require repository custodians to have a method of recognizing that their repository is open before leaving their work station. Completion Date 1/31/97. (Signs, obstructions, etc.)

6. Provide an easily identified paper that will be used whenever possible for Safeguards Information to be printed on. Completion Date 1/31/97. (Safeguards Information printed in red as the header and footer and a red stripe on the two remaining borders of the paper.) ,

7. All Safeguards Informa: ion is being transported / hand carried in a red safeguards envelope. (Mailing is still dual envelope process)

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., i MaineYankee RELIABLE ELECTAICITY SINCE 1972 i

I 329 BATH ROAD a BRUNSWICK, MAINE 04011 + (207) 798-4100 i

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April 25,1997  !

MN-97-63 - JRH-97-100  !

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UNITED STATES NUCLEAR REGULATORY COMMISSION ,

Attention: Document Contml Desk  !

Washington, D.C. 20555 j References: a) License No. DPR-36 ( Docket No. 50-309 )  !

b) USNRC Letter to MYAPCo dated March 13,1997, Notice of Violation for NRC Inspection Report 50-309/96-14.

.i Subject: Reply to Notice ofViolations Associated With NRC Inspection Report No. 50-309/96-14. :

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Gentlemen:

' The attachments to this letter provides Maine Yankee's reply to the Notice of Violations contained in Reference (b). In attachments "A & B",we have restated the violations, provided our response and !

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have addressed our actions taken and planned to prevent recurrence. Maine Yankee requested, an.J was granted, an additional 14 days to respond to this notice of violation. This extension had been approved by the Region through the Senior Resident Inspector.

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Please contact us should you have any further questions regarding this matter.

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I Very truly yours, ,

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ames R. Hebert, Manager l

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Licensing & Engineering Support Department  !

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. Attachments

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Mr. Hubert Miller j Mr. J.T. Yerokun j Mr. D. H. Dorman

Mr. Patrick J. Dostie

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Mr. Uldis Vanags -

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ATTACHMENT "A" Violation "A" Technical Specification 3.13, Refueling and Fuel Consolidation Operations, requires in Part, "A.

Prior to each refueling a complete checkout shall be conducted on fuel handling cranes that will be

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used to handle inadiated fuel assemblies." Operations procedure 13-2, Fuel Handling in the Spent Fuel Pool, performs an operational check of the ability of the crane to raise and lower as a j prerequisite to fuel movement.

Contrary to the above, on four occasions from January 7, through January 13,1997, problems were identified that invalidated this checkout. In each of these problems, the cause of the crane failure was

. not determined and the operability of the crane was not evaluated prior to the movement ofirradiated fuel.

Maine Yankee Response:

Maine Yankee agrees with this violation. In the case of each of the failures Operations felt that the trouble shooting and resolution of the problem first by electrical maintenance then engineering was adequate and that testing prior to fuel movement was adequate to prove operability. The I reoccurrence of the problem 'edicated the problem was not well understood and the post failure testing was inadequate to demonstrate the problem had been corrected thus testing was inadequate to meet the requirements of Technical Specification 3.13.

Immediate Corrective Actions:

The immediate action which was successful in preventing the crane's circuit breaker from tripping was replacement of the motor with a motor having a higher capacity. The immediate conective action to address inadequate testing prior to continuing fuel moves in the Spent Fuel Pool was to provide verbal communications conceming Management's expectations on the response to abnormalities which occur during fuel moves in the spent fuel pool. This communication was given as part of a training session. Information of the circumstances of this violation and the Response to the Notice of Violation will be provided to operators who will be involved in refueling operations prior to upcoming refueling moves.

Corrective Actions Taken to Avoid Further Violation:

Longer term corrective actions will provide additional training and procedure changes as necessary to address the generic issue of functional testing and operability. 1) Changes will be made to Operations Procedure (OP) '-200-2, " EQUIPMENT OPERABILITY ASSESSMENT", to include equipment which is not satuy class or QAR but has a Technical Specification or nuclear safety requirement. 2) Refueling procedures 13-2," FUEL HANDLING IN THE SPENT FUEL POOL",

13-3, " TRANSFER MACHINE AND UPENDER OPERATION", and 13-4, " REFUELING MACHINE OPERATION", will be revised to provide additional mformation concerning expectations for addressing off normal conditions. This will include an operability determination in accordance with (IAW) 1-200-1 if warranted. 3) Operators will be trained on lessons leamed from this event and the procedure changes. The procedure changes will be completed by June 01,1997.

A root cause is required on this event. Other corrective actions may be recommended from that root cause.

Full Compliance Date Full compliance was achieved on January 20,1997 when post maintenance functional testing of the crane was satisfactorily completed in accordance with procedure 3.1.10 " REFUELING SYSTEM INTERLOCK TEST", in support of Work Order 97-00284.

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ATTACHMENT "B" Violation "B"  !

Technical Specification 5.11.1, requires in part that procedures for personnel radiation protection  !

shall be implemented. Procedure 9-5-100, Contamination Control / Decontamination Program, Section 7.5.1, allows personnel to reach into contaminated areas for certain purposes and requires that personnel shall remove protective clothing prior to exiting contaminated areas.

Contrary to the above, on January 23,1997, a radiation worker failed to remove protective clothing j from his hand prior to exiting the contaminated area around the high pressure safety injection pump,  ;

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Maine Yankee Resnonse i '

Maine Yankee agrees with this violation. Maine Yankee feels that the intent of the procedural step cited, the removal of"all protective clothing", refers to the situation of a worker in a full set of protective clothing i l fully within a contaminated area. However we agree that' this step could also be applied to the situation described in the NOV. Radiation Protection management agrees that further clarification and communication of expectations was appropriate.

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Maine Yankee recognizes that barring any other compensation orjustification, the repeated crossing of a i contamination boundary with a gloved hand without removal of the glove or verifying it non contaminated ,

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prior to touching clean equipment is indeed a poor work practice. Although we feel that the intent of the procedure step cited is for the case of a worker in full protective clothing who has completely entered a ,

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contaminated area, we also recognize that the step could also be read to apply to the cited situation. However,

the activity was performed under Radiation Protection cogmzance and controls were adequate to prevent the ,

actual spread of radioactive contamination..

l Immediate Corrective Actions and Corrective Actions Taken to Avoid Further Violation:

I Subsequent evaluation of this situation had detennined that some progranunatic improvements could be  !

, made to preclude future misinterpretations and/or inconsistencies in the application of radiological controls. l Accordingly, clarifications have been developed and communicated to the Maine Yankee Radiation Protection staff in the form of a Radiation Protection Guideline (RPG-0002). This RPG was issued on February 18,1997 and issued as Required Reading (97-033) on Febmary 21,1997. As of April 17,1997, all Maine Yankee Technicians have signed off this Required readmg. s Full Compliance Date: l Full compliance was achieved on April 17,1997 when all Maine Yankee Radiation Protection Technicians had signed off the required reading of Radiation Protection Guideline (RPG-0001). i

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