IR 05000397/1991010
| ML17286A930 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/12/1991 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9107230119 | |
| Download: ML17286A930 (10) | |
Text
Docket No.
50-397 Washington Public Power Supply System
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Box 968 3000 George Washington Way Richland, Washington 99352 Attention:
Mr.
G.
D. Bouchey, Director Licensing and Assurance SUBJECT:
WPPSS RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC INSPECTION REPORT NO. 50-397/91-10 Thank you for your letter dated June 12, 1991, in response to our Notice of Violation, dated May 15, 1991, informing us of the steps your have taken to correct the items which we brought to your attention.
Your corrective actions appear to resolve our concerns regarding the violations referenced in the subject report.
Your corrective actions will be verified during future inspections of your activities.
Your cooperation with us is appreciated.
Sincerely, Greg Yuhas, Chief Reactor Radiological Protection Branch bcc w/copy of letter dated 6/12/91:
Docket File Project Inspector Resident Inspector A. Johnson G.
Cook B. Faulkenberry J. Martin J..Zollicoffer M. Smith (w/o letter)
REGION Y/
DChaney Yuhas 7/(( /91 7/(gl91
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9107230119 910712 PDR ADOCK 05000397 G
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Y Rzccivcc WASHINGTON PUBLIC POWER SUPPLY SYSTEM PfQ JPH Q P.O. Bm968 ~ 3MO Geoq,e Wasbtngton Way ~ Rtcbland, Wasbtngton 5935~pi f5@ 3 June 12, 1991 G02-91-121 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Mail Station Pl-137 Washington, D. C.
20555 Gentlemen:
Subject:
.
NUCLEAR PLANT NO. 2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION REPORT 91-10 RESPONSE TO NOTICES OF VIOLATION The Washington Public Power Supply System hereby replies to the Notices of Violation contained in your letter dated May 15, 1991.
Our reply,'pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
In Appendix A, the violations are addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
Very truly yours, G.
D. Bouchey, 'tor Licensing 5 Assurance JDA/bk Attachments CC:
JB Martin -
NRC RV NS Reynolds - Winston
& Strawn PL Eng -
NRR DL Williams - BPA/399 NRC Site Inspector
- 901A
~ l h
APPENDIX A During an NRC inspection conducted April 8 - 20,'991, two viola4'ions'f NRC requirements were identified.
In accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions,"
CFR Part 2,.Appendix C
(1991), the violations are listed below:
A.
WNP-2 Technical Specification (TS) 6. 12. 1, states, in part, that "In lieu of the "control device" or "alarm signal" required by.
.
.
CFR Part 20, each high radiation area in which the intensity of radiation is greater than 100 mrems/h tmillirems per hour] but less than 1000 mrems/h shall be barricaded
.and conspicuously posted as a high radiation area..."
Also, TS 6. 12.2, states, in part, that:
"areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose greater than 1000 mrems shall be conspicuously posted..."
WNP-2 procedure 11.2.7. 1,
"Area Posting,"
paragraph 7.3,
"High High Radiation Area," requires, in part:
"areas with dose rates greater than 1000 millirem be barricaded, posted and at each access point post a
radiological symbolic sign stating
"HIGH HIGH RADIATION AREA..."
Contrary to the above, on April 15, 1991, (1)
the equipment hatch providing general access to the reactor containment drywell, with general area dose rates exceeding 100 millirem per hour, was not posted as a high radiation area; and (2)
an area adjacent to the shielding on reactor coolant recirculation pump "B" piping on the 501 foot elevation within the drywel1, with radiation dose rates exceeding 1000 millirem per hour was not posted as a High High Radiation Area.
This is a Severity Level IV Violation (Supplement IY)
Validit of Violation The Supply System acknowledges the validity of this violation.
Although flashing yellow lights and radiologica] barrier rope were installed, the areas noted were not posted as required.
This condition existed for approximately 30 minutes.
The reason for the violation was Lack of Attention/Concentration.
Personnel had recently completed installation of temporary shielding in the drywell portion of containment and Plant Health Physics Technicians were in the process of re-posting the area.
In this particular situation, a Contractor Health Physics Technician inadvertently removed the existing posting without ensuring that a High-High Radiation Area sign was posted at the equipment hatch entrance to the drywel i
'
Appendix A Page 3 of 3 Validit of Violation The Supply System acknowledges the validity of this violation The reason for the violation was Work Practices Less Than Adequate.
Slant Health Physics Technicians failed to verify that the, Iodine Sorbent Canister (GNR-I) shelf-life had not expired prior to issue on April 10, 1991 as required by procedure.
The labels on the canisters noted that the units had to be used prior to April, 1991.
Although.the out-of-date canisters were issued to Plant personnel, they were not actually used during reactor vessel head removal efforts.
Corrective Ste s Taken Results Achieved The canisters with the expired expiration date were immediately removed from the work area and replacement GNR-I canisters, with an expiration date of August, 1992, were issued.
In addition, all GNR-I'canisters in storage with the April, 1991 expiration date, and those which were near expiration (within two months),
were removed from the site.
Plant Health Physics personnel involved were counselled on expecta-tions pertaining to procedural compliance and a letter was issued to Health Physics Area Coordinators emphasizing the requirement to verify that GNR-I canister shelf-life has not expired.
Corrective Action to be Taken On an annual basis prior to the onset of maintenance and refueling outages, Plant Health Physics personnel will verify that the shelf-life for the GNR-I canisters is within useful life limitation requirements.
Date of Full Com liance Full compliance was achieved on April 17, 1991 when the out-of-date GNR-I Iodine Sorbent Canisters were removed from the work area and the replacement canisters were issue '
'
Appendix A Page 2 of 3 Corrective Ste s Taken Results Achieved 1.
The equipment hatch entrance to the drywell was immediately posted as a High-High Radiation Area as required..
2.
The individual involved was counselled on performance expectations, and also of the posting requirements contained in Plant procedures.
3; This violation and posting requirements were discussed with Health Physics Technicians in a staff meeting.
Personnel were also reminded that, in addition to radiological barrier rope and a
flashing yellow light, the drywell equipment hatch area shall be conspicuously posted with signs stating,
"High-High Radiation Area" and,
"Health Physics Escort Require'd For Entry."
orr ctive Action to be Taken No further corrective action is planned.
ate of ll Com liance
\\
Full compliance was achieved on April 15, 1999lmhen the equipment hatch entrance to the drywell was properly posted.
TS 6.11. 1, "Radiation Protection Program," requires that "Procedures for personnel radiation protection shall be prepared consistent with the requirements of
CFR Part
and shall be approved, maintained and-adhered to for all operations involving personnel radiation exposure."
CFR Part 20, Appendix A, Footnote "f" states that canisters and cartridges shall not be used beyond service-life limitations.-
MNP-2 procedure 11.2.11.4,
"Use of Respiratory Protection Equipment," requires, in part, that the Health Physics Technician issuing a
GHR-I canister (iodine sorbent canister for use with negative pressure respiratory protection equipment)
shall verify that for each canister used that the seal is intact, the canister shelf life has not expired, and the appropriate HSA label is attached to the GHR-I canister.
Contrary to the above, on April 17, 1991, ten GNR-I canisters were issued to workers for use during the reactor vessel head removal on the 606 foot elevation of the reactor building and the shelf life of the canisters had expired on March 31, 1991.
This is a Severity Level IV violation (Supplenent IV)
0