IR 05000333/1998002
| ML20237C148 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/14/1998 |
| From: | David Lew NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Michael Colomb POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| 50-333-98-02, 50-333-98-2, NUDOCS 9808200258 | |
| Download: ML20237C148 (3) | |
Text
- - _ _ _ - _ _ - - - _ _ _ _ _ - _ _ _ _ _ _ _-___-_ - __ _ _ _ . _
. ,
August 14, 1998 Mr. Michael Site Executive Officer New York Power Authority
.
James A. FitzPatrick Nuclear Power Plant Post Office Box 41 Lycoming, NY 13093
Dear Mr. Colomb:
Subject: NRC Integrated Inspection Report No. 50-333/98-02and Notice of Violation This letter refers to your August 3,1998 correspondence, in response to our July 2,1998 tetter.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, Original Signed by:
David C. Lew, Chief Projects Branch 2A Division of Reactor Projects Docket No. 50-333
~
9808200258 980814 PDR ADOCK 05000333 G PDR .,
OFFICIAL RECORD COPY IE:01 L --
.- -_---_-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -- . _ _ . _ _ _ _ _ _ _ _ _ .
,
n'
s Michael i cc:
C. Rappleyea, Chairman and Chief Executive Officer E. Zeltmann, President and Chief Operating Officer R. Hiney, Executive Vice President for Project Operations J. Kr'ubel, Chief Nuclear Officer and Senior Vice President H. P. Salmon, Jr., Vice President of Nuclear Operations W. Josiger, Vice President - Engineering and Project Management
,
'
J. Kelly, Director.- Regulatory Aff airs and Special Projects T. Dougherty, Vice President - Nuclear Engineering R. Deasy, Vice President - Appraisal and Compliance Services -
R. Patch, Director - Quality Assurance G. C. Goldstein, Assistant General Counsel C. D. Faison, Director, Nuclear Licensing l K. Peters, Licensing Manager (- T. Morra, Executive Chair, Four County Nuclear Safety Committee cc w/ copy of Licensee's Response Letter:
Supervisor, Town of Scriba C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law P. Eddy, Director, Electric Division, Department of Public Service, State of New York G. T. Goering, Consultant, New York Power Authority J. E. Gagliardo, Consultant, New York Power Authority E. S. Beckjord, Consultant, New York Power Authority F. William Valentino, President, New York State Energy Research and Development Authority J. Spath, Program Director, New York State Energy Research and Development Authority
!
l l
l l
!
. - - _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ - _ _ - - - - -
<
.
Michael Distribution w/ copy of Licensee's Response Letter:
B. McCabe, RI EDO Coo.dinator S. Bajwa, NRR J. Williams, NRR
,
M. Campion, R1
'
R. Correia, NRR l F. Talbot, NRR Nuclear Safety Information Center (NSIC)
PUBLIC NRC Resident inspector Region i Docket Room (with concurrences)
Inspection Program Branch, NRR (IPAS)
D. Lew, DRP J. Rogge, DRP P. Kaufman, DRP R.Junod,DRP DOCDESK i
! ,
!
!
)
l I
l DOCUMENT NAME: A:\RL9802.FTZ l
'
To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" =
C py with attachment / enclosure "N" = No copy )
, : OFFICE Rl/DRP l Rl/DRP j NAME GHunegs DLew
, [b b b DATE 08(4/98 08//y/98 OFFICIAL RECORD COPY !
l l
L_____-------.___ _ _ _ _ _ _ I
_ _ _ _
- _ - - - - . __ _ - _ _ _ - - - - _ _ - _ _ _ _ - - _ - - - - - - . - - _ - _ - - _ _ . - - - _ _ _ _ - - - _ _ _ _ . _ - - _ _ _ _ _ _ . - - _ - - _ _ _ - _ _ - - - - - _ _ _ _ - - - _ _ _ _ _ _ _ _ - _ _ - _ _ _
Nucleir Pow:r PI:nt 268 Ld3 Roid PO Box 41 Lycoming, New York 13093 l 315 342-3840
- > NewYorkPbwer wenaei J. coioma
& Authority s te execut>ve omcer
.
August 3,1998 JAFP-98-0246 United States Nuclear Regulatory Commitsion httn: Document Control Desk i liail Station P1-137 l
'Nashington, D.C. 20555 SUBJECT: James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Reply to Notice of Violation l NRC Intearated inspection Report 50-333/98-02 l
Deer Sir:
In accordance with the provisions of 10 CFR 2.201, Notice of Violation, the New York Power Authority submits a response to the notice transmitted by your letter dated July 02,1998. Your letter refers to the results of the integrated inspection conducted from April 20,1998 through May 31,1998 at the James A. FitzPatrick Nuclear Power Plant. 1
Attacb/nent 1, Reply to Notice of Violation, provides the description of the violations, reasons for the vioistions, the corrective actions that have been taken and results achieved, c.orrective actions to be taken to avoid further violations, and the dates of full compliance.
There are no commitments contained in this submittal.
if you have any questions, please contact Mr. Arthur Zaremoa, Licensing Manager, at (315) 349-6365. .
l Very truly yours, I Michae STATE OF NEW YORK l COUNTY OF OSWEGO Subscribed and sworn to before me l MJC:GJB:las This '3 day of Au e 1998.
\ l CC: next page O vu n hit
"
(%d Attachments as stated Ndtary Ptiblic NANCY B.CZEROW
"
ou$t Ni,wri$ $ _,- * -
co 0 & MA/ V W-<f'
. YU W W v v l h o
a
-
\
l cc: Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
'
Office of the Resident inspector
, U.S. Nuclear Regulatory Commission l P.O. Box 136 Lycoming, NY 13093 Joseph Williams, Project Manager Project Directorate 1-1 l Division of Reactor Projects - 1/II l U.S. Nuclear Regulatory Comrnission Mail Stop 14 82 Washington, DC 20555 -
l Attachments: Reply to Notice of Violation l
,
I
!
!
!
,
I
- .
l I
l i
f l i l
!
l
i i l
.j
. __ _ ._
,
i
, ..
Attichment 1 R: ply to N:tica cf Viol:ti:n 98-02 I
Page 1 of 15 VIOLATION A )
i Technical Speci'i:~~ tion 6.8(A)2 requires, in part, that written procedures and administrative policies shall be established, implemented and maintained that are recommendedin Appendix A of Regulatory Guide 1.33, November 1972. Appendix A
- of Regulatory Guide 1.33 requires procedures for combating emerget.ns and other l significant events and administrative procedures for safe plant operation. Administrative Procedure (AP)-12.03, Administration of Operations, Revision 12, requires that operators shall observe a hierarchy for plant operating procedures and that emergency operating procedures (EOPs) and EOP support procedures (EPs) have the highest ,
priority. EP-1, EOP Entry and Use, Revision 2, requires, in part, that actions taken per other plant proceduies shall not contradict or subvert actions specified by the EOPs.
Contrary to the above, on May 1,1998, actions taken per otherplant procedures contradicted actions specified by the EOPs. Specifically, operators had entered EOP-3, Failure to Scram, which directed that operators execute EP-3, Backup Control Rod Insertion. Instead of entering EP-3, Abnormal Operating Procedure (AOP) 1, Reactor Scram, was entered. AOP-1 provided a different mitigation strategy than the directions in EP-3.
I ADMISSION OR DENIAL OF THE VIOLATION The Authority agrees with the violation.
REASON FOR THE VIOLATION The cause for this violation was personnel error.
During the post trip sequence following the 05/01/98 manual scram, six control rods could not immediately be verified "fullin" on the full core display, and Emergency Operating Procedure EOP-3, " Failure to Scram" was entered. Three of the six rods were verified inserted following replacement of burned out light bulbs in their associated full core display modules. Shortly after, the three rods with unknown positions were given momentary " insert" signals. The three rods then indicated " full-in" and EOP-3 was exited. Abnorrnal Operating Procedure AOP-1, " Reactor Scram" was utilized to i provide the momentary insert signals to the three control rods instead of Emergency Procedure EP-3, " Alternate Rod insertion" as directed by EOP-3.
l l
!
._ _
- _ - _ _ _ _ _ _ _ - _ _ _ ___-_____-__-_ ___ _ _ _ _ - - _ _ _ _ __-___
'
, - l l
l Attzchment 1 R: ply to N:tica cf Vi l: tion 98-02 l Page 2 of 15 REASON FOR THE VIOLATION (cont.)
The Shift Manager (SM) and the Control Room Supervisor (CRS) were confronted with the rapid decision and conservative response to insert a manual scram. In response to ,
the urgency of the conditions evolving, the SM was also aware that a rapid response was needed to provide a control rod insert signal while being attentive to the concern about reactor pressure vessellevel, pressure and bottom head cooldown rate. With that urgency in mind, and realizing that a control room operator was using AOP-1, the SM directed the operator to provide a control rod insert signal.
l s
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
Prior to plant startup from the resulting forced outage, all on shift operators were briefed to use EP-3 as directed by EOP-3 for insert signals to control rods.
- AOP-1, section C.3 titled " Control Rod Insertion (Only one Control Rod is not full in and EOP-2 is Being Executed)" has been revised to clarify that this section is !
applicable to only one control rod while in EOP-2. I i
. The use of the correct procedure (EP-3 versus AOP-1) was reviewed during Licensed ,
Operator Requalification Training, j RESULTS ACHIEVED Based on observations of many simulator ATWS scenarios involving EOP-3 by Operations Management, it is concluded that this error is an isolated case, and that corrective actions taken have been effective in preventing recurrence.
CORRECTIVE ACTIONS TO BE TAKEN
- A self-assessment will be performed to assess the transition from AOP to EOP and EOP support procedure use, as well as effectiveness of corrective actions associated with this event. Scheduled Completion Date March 30,1999 DATE WHEN FULL COMPLIANCE WAS ACHIEVED l
Full compliance was achieved on May 08,1998, prior to startup from the forced outage.
l I
_ _ _ _ _ _ _ _ _
i i
'
..
l ,
Attachm:nt 1 R: ply to N: tics cf VI:lIti:n 98-02 Page 3 of 15
'
VIOLATION B.1 Technical Specification 6.8(A)2 requires, in part, that written procedures and
\
administrative policies shall be established, implemented and maintained that are recommendedin Appendix A of Regulatory Guide (RG) 1.33, November 1972.
Section 1.b of Appendix A of RG 1.33 includes administrative procedures covering authorities and responsibilities for safe operation and shutdown. Also,10 CFR 50.4 l defines operator as any individuallicensed to manipulate a control of a facility, and a l senior operator as any individuallicensed to manipulate the controls of a facility and to direct the licensed activities oflicensed o.oerators.
Contrary to the above, as of April 24,1998, Administrative Procedure AP-12.03,
" Administration of Operations," Revision 11, was not established adequately in that in Step 6.11.2 providedinstructions allowing the on-shift operator to direct the licensed activities oflicensed operators without a senior operator license.
l
'
ADMISSION OR DENIAL OF THE VIOLATION The Authority agrees with the violation.
REASONS FOR VIOLATION The cause for this violation was a less than adequate procedure development.
Specifically, during the development of AP-12.03, the statement describing the duties and responsibilities of the Senior Nuclear Operator (SNO) inappropriately and unfortunately used the word " directs" in describing SNO duties and assignments.
The JAF operations command and control structure functions such that on!y the Shift Manager (SM) or Control Room Supervisor (CRS), who are senior reactor operators (SROs), direct the licensed activities of licensed operators. This concept is taught during initial operator license training and emphasized during licensed operator continuing training. The JAF operations command and control function is in, and remains in, compliance with 10 CFR 50.4 requirements.
I
i
-
i .
j Attachmint 1 Riply to N:tica cf VI:lition 98-02
Page 4 of 15 l
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN l
. Administrative Procedure AP-12.03, " Administration of Operations" has been '
revised to define the responsibilities and authority of the Senior Nuclear Operator ]
(SNO) to assure procedure definition is consistent with current JAFNPP Operations i individual roles and responsibilities and the Operations Department command and control structure.
I + A review of Chapter 13.2, " Organizational Structure and Responsibilities" of the )
Final Safety Analysis Report (FSAR) identified a similar wording error associated I with listing responsibilities for Senior Nuclear Operators. An FSAR Change Package
,
has been initiated to correct and clarify Chapter 13, Section 13.2.2.
RESULTS ACHIEVED The procedure revision has provided clarification and description of SNO duties and I responsibilities consistent with JAFNPP Operations Department. command and control functions.
CORRECTIVE ACTIONS TO BE TAKEN None l DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on April 22,1998 following the completion of the revision to Administrative Procedure AP-12.03.
.
t -
,
l
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - - - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
. ..
Attichm:nt 1 Rsply to N tica cf Viol;ti:n 98-02 Page 5 of 15 VIOLATION B.2 Technical Specification 6.8(A)2 requires, in part, that written procedures and administrative policies shall be established, implemented and maintained that are recommendedin Appendix A of Regulatory Guide (RG) 1.33, November 1972.
Section 6.d of Appendix A of RG 1.33 includes abnormal operating procedures for the loss of coolant flow.
Contrary to the above, as of April 24,1998, abnormaloperating procedure AOP-8,
" Loss of Coolant Flow," was not established adequately in that the power to flow map portion of the procedure was inconsistent with operator aid number 24 and reactor analysts procedure RAP-7.3.16.
ADMISSION OR DENIAL OF THE VIOLATION The Authority agrees with the violation.
l REASONS FOR VIOLATION The cause for this violation was an inconsistent presentation of information between an Operations Department procedure and a Reactor Engineering procedure.
A difference was noted between the power / flow (P/F) map contained in Attachment 2 of Abnormal Operating Procedure AOP-8 and the power / flow maps shown in Reactor l
'
Analyst Procedure RAP 7.3.16, " Plant Power Changes" and Operator Aid number 24.
The difference was caused by how the information was graphically displayed, and could have resulted in misinterpretation of written procedural guidance for operation in various areas of the P/F map. A review of the two versions of the P/F map and a review of the two associated procedures found rio incorrect or inappropriate operator guidance for l safe plant operation. .
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
- Procedure changes and P/F map upgrades have been made to clarify operator j actions and to augment the guidance for operation in the various regions of the P/F l map. Operator Aid number 24 has been included as a posted attachment to AOP-8.
!
l
- - _ _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _ _ - _ _ - _ - _ - _ - _ _ - _ _ _ _ _ _ - _ - _ _ _ - _ .
..
. ..
Att: chm:nt 1 RIply to N tics cf VI:Inti:n 98-02 Page 6 of 15 RESULTS ACHIEVED e The two procedures and Operator aid identified in the violation have received human factor enhancements to provide users consistency and clear guidance for plant operation while using the P/F map.
CORRECTIVE ACTIONS TO BE TAKEN None DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on May 06,1998 following revisions to AOP-8, RAP- ')
7.3.16 and Operator Aid number 24. 1
!
l l
s I
l l
l l
. - _ _ _ _ _ - _ _ _ _ - _ _ - _ - - _ _ _ _ _ - - _ - _ - _ _ - _ _ - _ _ _ _ _ _ _ _-
Attrchmsnt 1 l
R: ply to Notics of Vialiti:n 98-02 l
l l
Page 7 of 15 VIOLATION C I l
'
10 CFR 50.54(i-1) requires that the facility licensee shallhave in effect an operator requalification program which must as a minimum, meet the requirements of 55.59(c).
10 CFR 55.59(c) requires, in part, that in lieu of paragraph (c)(4) of this section, the Commission may approve a program developed by using a systems approach to training (SA T). 10 CFR 55.59(c)(4) requires, in part, that the facility licensee requalification l program shallinclude comprehensive written examinations and annualoperating tests l which determine areas in which retraining is needed to upgrade reactor operator and )
l senior reactor operator knowledge. The facility licensee SA T based program relies on security agreements to duplicate examination material from week-to-week during an examination cycle and ensure materialis not divulged.
'
Contrary to the above, from March 30 to April 24,1998, the facility licensee l l administered the annual operating test to licensed operators in a manner in which I l examination test item sample selection was not sufficiently comprehensive such that needed retraining determinations could be made. Specifically, examination content was duplicated over a 4-week period.
l ADMISSION OR DENIAL OF THE VIOLATION The Authority agrees with the violation. Additiona!!y, the Authority provides clarification for the dates listed for the administration of the annual operating test as contained in the cited violation. Dates for the exams were March to June 1997 and March to June 1998,
REASONS FOR VIOLATION The cause for this violation was procedure deficiency.
The guidance and requirements contained in procedure TP-5.07, " Licensed Operator Requalification Examination Development and Administration" were less than adequate.
Measures were in place (Comprehensive Exam Sample Plan and Operating Exam Sample Plan) for establishing exam materials based on multiple inputs including materials from the prior requalification period. However, the procedure did not emphasize or contain specific guidance to assure that sufficient variance of operator examination materials j (dynamic simulator scenarios, Job Performance Measures, and written examination) )
were developed and administered during annual operating tests to licensed operators. l This less than optimum test sample size could have resulted in not sufficiently l determining areas in which retraining may be needed to upgrade reactor and senior reactor operator knowledge. ;
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ .
l
,
, ..
Attachm:nt 1 R: ply to N:tica cf VI:lttion 98-02
!
l t
Page 8 of 15 REASON FOR THE VIOLATION (cont.) {
During the most recent examination cycle,7 dynamic simulator scenarios were ia.tially developed to examine the 6 crews and 4 staff teams. Additionally,19 Job Performance Measures (JPM)s were administered. Each crew was evaluated on 2 dynamic simulator scenarios.
i )
l l CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
Three additional scenarios and one additional JPM were added to the 1998 LOR l exam sample plan to address the less than sufficient test item sample selection.
- Training procedure TP-5.07 has been revised to provide additional guidance and controls for the development and administration of comprehensive written annual j operator license exams to ensure there are sufficient different scenarios. l RESULTS ACHIEVED The completion of the revision to training procedure TP-5.07 has provided assurance that operator test materials are being developed and administered in accordance with the Code of Federal Regulations.
'
C_QRRECTIVE ACTIONS TO BE TAKEN i None l
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
.
l Full compliance was achieved on July 15,1998, following the revision to Training procedure TP-5.07.
I l
l
l
,
-_ - -__- _ __ - - _ -__ _ - _ - _ _ _-- _ __ ___- -__ _ _ . _ _ . _ _ _ .
'
.
Attichm:nt 1 Riply to Nctica cf VI:liti:n 98-02 l
l Page 9 of 15 I
VIOLATION D.1
l 10 CFR 55.59(a)(2)(ii) requires, in part, that the operating test will require the licensed
{
\ senior reactor operator to demonstrate the ability to perform the actions necessary to
^
l accomplish a comprehensive sample of items specified in part 55.45(a)(2) through (13)
inclusive to the extent applicable to the facility.
[
l 10 CFR 55.45(a)(2) requires, in part, licensed operators demonstrate the ability to l operate the facility between shutdown and designated power levels.
Contrary to the above, from January to March 1997 and from January to March 1998, the facility licensee administered the annual operating test to operators that did not l l demonstrate on a sampling basis their ability to operate the facility between shutdown and designated power levels. Further, the FitzPatrick training Procedure TP-5.07, " LOR l Examination Development and Administration," Revision 3, Step 7.5.8 was not adequate in that low power or shutdown operations were excluded from the annual operating test. \
!
I ADMISSION OR DENIAL OF THE VIOLATION l The Authority agrees with the violation. Additionally, the Authority provides clarification for the dates listed for the administration of the annual operating test as {
contained in the cited violation. Dates for the exams were March to June 1997 and l March to June 1998.
!
l REASONS FOR VIOLATION
The cause for this violation was inadequate procedure development. Training procedure TP-5.07, revision 3 stated that ".. Iow power operations or shutdown conditions are not normally selected for the operating exam." The statement has been traced to procedure revision 0, however, its origin is unknown.
The Examiner Standard (ES) is cited as a reference for procedure TP-5.07, with various sections of the procedure containing direct quotes from the ES. Section ES-6.04 is titled " Dynamic Simulator Requaiification Examination" and discusses the requirements for preparing and administering dynamic simulator requalification operating tests.
.
Numerous sections of this Standard appear in TP-5.07 for the development of the l simulator examination. However, Section 6.01 of the Examiners Standard (Conduct of NRC Requalification Examinations) also contains requirements for the conduct of dynamic simu;ator examinations. The requirement for low power scenarios is in an Attachment of ES section 6.01 and does not appear in ES section 6.04.
.
Att chm:nt 1 R: ply to N tica cf Viol: tion 98-02 Page 10 of 15 REASONS FOR VIOLATION (cont.)
r it is concluded that during development and subsequent TP-5.07 revisions, procedure I
writers / reviewers failed to adequately identify and include requirements from all sections of the ES for implementation into TP-5.07.
'
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
- Training procedure TP-5.07 has been revised to include each elements of 10 CFR 55.45(a)(2) through (13) in the operating examination sample plan.
,
-
RESULTS ACHIEVED The completed changes to procedure TP-5.07 have provided assurance that JAF's Licensed Operator requalification examination processes are in compliance with the Code of Federal Regulations.
CORRECTIVE ACTIONS TO BE TAKEN None DATE WHEN FULL COMPLIANCE WAS ACHIEVED
>
Full compliance with 10 CFR 55.45(a) and 10 CFR 55.59(a)(2)(ii) was achieved on Juiy 15,1998 following the revision to Training procedure TP-5.07.
.
I I
l i
I
(
I i
j l
!
I
. .~
Attichmint 1
! Riply to N:tica cf Vinl:ti:n 98-02 Page 11 of 15
VIOLATION DJ l
l 10 CFR 55.59(a)(2)(ii) requires, in part, that the operating test will require the licensed senior reactor operator to demonstrate the ability to perform the actions necessary to accomplish a comprehensive sample ofitems specified in part 55.45(a)(2) through (13)
inclusive to the extent applicable to the facility.
10 CFR 55.45(a)(11) requires, in part, the licensed reactor operator to demonstrate the ability to execute the emergency plan.
j Contrary to the above, from January to March 1997 and from January to March 1998, operating tests administered did not require licensed senior reactor operators fulfilling the role of the controlroom supervisor to demonstrate on a sampling basis their ability to execute the emergency plan.
ADMISSION OR DENIAL OF THE VIOLATION !
The Authority agrees with the violation. Additionally, the Authority provides clarification for the dates listed for the administration of the annual operating test as contained in the cited violation. Dates for the exams were March to June 1997 and i March to June 1998, i REASONS FOR VIOLATION
This violation resulted from an incorrect interpretation of the Code requirements contained in 10 CFR 55.49. This error resulted in the failure of the operating tests, administered to licensed senior reactor operators (SROs) fulfilling the role of the control room supervisor (CRS), to demonstrate on a sampling basis the CRS 's ability to execute the emergency plan. I 10 CFR 55.59(a)(2)(ii) directs that the operating test will require the reactor operators (ROs) and SROs to demonstrate an understanding of, and the ability to perform, the l actions necessary to accomplish a comprehensive sample of items specified in 10 CFR 55.45(a)(2) through (13). 10 CRF 55.45(a)(2) section (11) requires a .
l demonstration of knowledge of the e-plan, including, as appropriate, the RO's or SRO's responsibility to decide whether the e-plan should be executed and duties under the plan assigned.
l l
- _ _ _ _ - - _ _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ . _ _ _ _ _ _ _ .
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l AttachmInt 1 )
R: ply to N tics cf Vi:liti:n 98-02
]
Page 12 of 15 REASONS FOR VIOLATION (cont.)
A review of the LOR examinations administered during 1998, indicated that 8 from a total of 19 CRSs had met the 10 CFR 55.45(a)(2)(11) sample requirement. This was accomplished when crew rotations required that the CRS fill the role of Shift Technical Advisor (STA). One of the evaluated functions of the STA is to " provide independent assessment of plant conditions, EOPs, and e-plan, and consult the Shift Manager as appropriate." However, the 8 evaluated CRSS were not on shift CRSs.
It was the understanding and belief of the lead JAF examiner that a comprehensive campling was being obtained, that sufficient e-plan classifications were being performed to determine if this area would require retraining to upgrade RO and SRO knowledge (as required by 10 CFR 55.59(c)(2)), and that the requirements of the Code of Federal Regulations were being met. A comprehensive sampling of SROs demonstrating their ability to execute the e-plan was thought to have been obtained since all Shift Managers and some of the staff CSRs were being evaluated.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN
- Training procedure TP-5.07 has been revised to include senior reactor operator evolutions involving Emergency Plan classification and execution, j
,
I RESULTS ACHIEVED l
The completed changes to procedure TP-5.07 have provided assurance that the LOR examination processes are in compliance with the Code of Federal Regulations. I CORRECTIVE ACTIONS TO BE TAKEN
.
None DATE WHEN FULL COMPLIANCE WAS ACHIEVED i
Compliance with 10 CFR 55.45(a) and 10 CFR 55.59(a)(2)(ii) was achieved on July 15, 1998 following the revision to Training procedure TP-5.07.
- - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l . *
!
! AttichmInt 1 I Riply to Nstics of Vi:liti:n 98-02 Page 13 of 15 i
VIOLATION E 10 CFR 71.5(a) requires that a licensee who transports licensed material outside of the site of usage, as specifiedin the NRClicense, shallcomply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT)in 49 CFR 170 through 189. 49 CFR 173.421(a)(2) specifies that for shipment of excepted packages the radiation levelat any point on the extemal
- surface of the package does not exceed 0.005 millisievert per hour (0.5 mihrem per hour).
'
Contrary to the above, on March 17,1998, a B-25 box containing high efficiency particulate HEPA hoses was classified and shipped off-site as an exceptedpackage while the radiation levels on contact with five of the six sides of the B-25 box exceeded 0.5 millirem per hour and with a maximum contact reading of 1.8 millirem per hour.
ADMISSION OR DENIAL OF THE VIOLATION j The Authority agrees with the violation.
REASONS FOR VIOLATION The reason for this violation was personnel error. Personnel involved in the shipment
'
failed to perform an adequate survey and failed to assess the shipment classification.
Three items (two high efficiency particulate (HEPA) units and a B-25 box containing HEPA hoses) were surveyed in preparation for shipment to Niagara Mohawk's Nine Mile Point Unit 2 nuclear plant for use during their refuel outage. The survey results indicated that each item exceeded 0.5 millirem /hr at contact, with the highest contact dose rate being 1.8 rnillirem/hr on the B-25 box. The original shipment plan intended the three items to be placed inside>a sealed container (sealland container), which would
- constitute a package. In the planned configuration, the sealland's external surface radiation levels were expected to be less than or equal to 0.5 millremlhr on contact l allowing the package to be classified and shipped as Radioactive Material, Excepted l Package-Limited Quantity of Material,7, UN2910.
!
.
!
l l
t
___ _
_ _____ __ -___ ___-___- _-_-__-__-_-__ - __-_-- -_-__
. <
)
Attschthint 1 Riply to Nctics cf Vi:liti:n 98-02 Page 14 of 15 l REASONS FOR VIOLATION (cont.)
A JAF radiation protection (RP) technician prepared the paperwork on 3/12/98 in accordance with the original shipment plan. The technician was expecting to receive a sea / land container on that day, which would be used to transport the three items. The paperwork package included a vehicle survey with expected dose rates based on the three items being placed inside the sea / land container, it also included the shipment
{
classification (limited quantity shipment,1 excepted package) as well as the survey of the three items to be placed inside the sea / land container. The shipping attendant who was to load the sea / land indicated to the RP technician that he may not be able to load the B-25 Box into the sea / land. The sea / land container did not arrive at JAF before the end of work on Friday,3/13/98. The RP technician who had prepared the paperwork j was scheduled to be off site the following week and the shipment paperwork was left !
on his desk. The RP technician did not communicate the difficulty of loading the B-25 j Box into the sea / land container or how it could affect the shipment classification. This '
was a less than adequate turnover.
The next week when the sea /Isnd arrived on site, the shipping attendant loaded the two HEPA units into the sea / land container and placed the B-25 Box on the back of the flatbed. The shipping attendant informed the second RP technician of the changed ;
shipment configuration.
l The second RP technician performing the shipment retrieved the paper work filled out by the RP technician the week before. The technician verified the dose rates indicated on the vehicle survey included in the paper work, but failed to obtain contact readings on the packages, as required for a limited quantity package shipment. The technician brought the paperwork to the acting Shipping Radiological Supervisor and informed this supervisor that the original shipment plan had changed and that the B-25 box was placed on the back of the flatbed trailer. The supervisor reviewed the paperwork, including the vehicle survey, which showed dose rates less than 0.1 millirem /hr at the plane of the vehicle. He reviewed and signed the survey of the three individualitems, but did not question the contact dose rates on the B-25 box as it relates to dose rate limits for a limited quantity package.
Factors that contributed to this violation were:
- A vehicle survey form was filled out prior to loading the sea / land. Expected dose rates of the package were recorded, based on the B-25 bcx bCog placed in the sea / land container.
- The individuals involved failed to clearly communicate the change made to the original shipment configuration and reassess the shipment classification based on l the change.
l
- _ - _ - _ _ - _ _ _ _ _ - _ - _ - _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ _ - _ _. _ - _ _
-
.
Att: chm:nt 1 I Riply to Nntico of Vinistian 98-02
'
Page 15 of 15 REASONS FOR VIOLATION (cont.)
- An incorrect survey form was filled out for the shipment which indicated dose rate j verification at the plane of the vehicle instead of contact readings on the package.
l The survey misled the technician who completed the shipment on the location of the dose rates required for the shipment.
- A questioning attitude was not maintained by the team performing the shipment.
CORRECTIVE ACTIONS THAT HAVE BEEN TAKEN I e The B-25 box was immediately removed from the flatbed trailer and the trailer was shipped.
- The shipping personnel involved were counseled on closely inspecting and verifying l shipping papers. In addition, personnel were counseled to not complete survey l information based on expected shipment configurations.
l
- Dose limits associated with various shipment classifications required by regulations were reviewed with shipping personnel.
.
- As of 7/17/98, radioactive shipments not going through the warehouse require prior l RES Manager notification and approval. All shipment radiation surveys and i checklists that require supervisory review shall be witnessed during performance by a Radiological Supervisor. This will be effective until the RES Manager determines
- it is no longer necessary.
l l RESULTS ACHIEVED
!
l Shipping personnel are aware of the mistake made and clearly understand the dose l limits for different shipment types.
i Shipping personnel recognize the need to stop and reassess shipping documentation and classification when deviating from original intent of shipments.
j A determination was made that the documentation of this survey information, prior to l
the survey being performed, was an isolated case.
l , CORRECTIVE ACT;ONS TO BE TAKEN l None.
' DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved 3/18/98 when the shipment was corrected, l