ML17284A448

Responds to NRC 880629 Ltr Re Violations Noted in Insp Rept 50-397/88-22.Corrective Action:Door Allowing Access to Area Closed & Locked Immediately After Determining That Tech Spec 6.12.2 Incorrect & Individual Involved Counseled

ML17284A448
Person / Time
Site:	Columbia
Issue date:	07/29/1988
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-88-170, NUDOCS 8808030292
Download: ML17284A448 (13)

Text

i~i WASHINGTON PUBLIC POWER SUPPLY SYSTHSRC P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 88AUG 1 s 2: t l July 29, 1988 G02-88-170 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mashington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF"21 NRC INSPECTION REPORT 88-22 The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated June 29, 1988. Our reply, pur-suant to the provisions of Section 2.201, Title 10, Code of Federal Regula-tions, consists of this letter and Appendicies A and B (attached).

In Appendix A, an explanation of our position regarding the validity of the violation is provided.. As requested by your transmittal letter, Appendix B consists of actions taken to assure that analyses of future operational events are more thorough.

Should you have any questions, please contact Nr. A. G. Hosier, Manager, MNP-2 Licensing.

Ver'y truly yours, J

Regulatory..Programs JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCPER .

RB Samworth - NRC DL Milliams - BPA NRC Site Inspector - 901A

Page 1 of 3 APPENDIX A During an NRC inspection conducted on June 6-9, 1988, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1987), the violations are listed below:

A. Technical Specification 6.12.1 states, in part:

"...each high radiation area in which the intensity of radiation is greater than 100 mrems/h but less than 1000 mrems/h shall be barri-caded and conspicuously posted as a high radiation area...

"...Any individual or group .of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a0 A r adiation monitoring device which continuously indicates the radiation does rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-grated dose is received..."

"c. A health physics qualified individual (i.e., qualified in radia-tion protection procedures) with a radiation dose rate monitoring device...""

Contrary to the above, on May 12, 1988, an individual entered an area on the 437'levation of the Radwaste Building, ~here the intensity of radiation measured up to 1000 mrems/h, without being accompanied or provided with the equipment specified above.

This is a Severity level IV Violation (Supplement IV).

Validit of Violation The Supply System acknowledges the validity of the violation.

Corrective Ste s Taken/Results Achieved The door allowing access to the area was closed and locked immediately following a determination that, the Supply System interpretation -of Technical Specification 6.12.2 was incorrect (see response to Item B).

2. The individual involved was 'ounseled by Super vision on the procedural compliance aspects of entering J

High Radiation Areas.

Appendix A Page 2 of 3

3. Operations department shift personnel were given supplemental instructions regarding posting and entry'equirements for high and high-high radiation areas. These instructions were admin-istered through shift safety meetings and completed by June 10, 1988.

4. The five week Operator Requalification Training Program, com-pleted on July 18, 1988, included a revised module addressing the requirements for entry into high and high-high radiation areas.

5. The applicable RWP (2-88-00004, Operations Department Routines) was revised to include a statement of the requirements for entry to High Radiation Areas.

Corrective Action to be Taken

1. 'raining material will be developed and presented during Oper ations 'epartment safety - meetings to emphasize the significance of posted areas and requirements of entry.

2. The General necessary, Employee Training module will be reviewed and, revised to ensure other personnel receive training if similar to that of Operations personnel. This commitment is made because of a Plant guality Assurance survey which was conducted to provide an indication ,of the level of knowledge of Plant personnel regarding radiation barriers. The results of the survey indicated that many of the survey population did not have a clear understanding of ".High" Radiation Areas, "High-High" Radiation Areas and Area Radiation Monitors {ARMS).

Date of Full Co liance October 31, 1988 B. Technical Specification 6.12.2 states, in part-

"...For individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in I hour a dose in excess of 1000 mrems~ that are located within large areas. such as the containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas; then that area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device..."

Contrary to the above, on June 8, 1988, an area existed within the

,Waste Collector Tank Room on the 437'levation of the Radwaste Build-ing. where the intensity of radiation accessible to a ma)or portion of the body measured up to 1450 mR/hr, and the 'room was provided with a door which was not locked nor had an enclosure which could have been reasonably constructed for the purpose of locking been installed.

This is a Severity Level IV Violation (Suplement IV).

Appendix A Page 3 of 3 Validi.t of Violation The Supply System acknowl edges the vali di ty of the vi ol ation.

However, it should be noted that a conscious decision was made to control access to the area by means of barricading, posting and a yellow flashing light, in lieu of locking the door or constructing an enclosure. The decision was based on our interpretation of Technical Specification 6.1.2 at the time, with the expectation being that sufficient controls were in place to control access.

Corrective Ste s Taken/Results Achieved The .door allowing access to the area was locked to fully comply with the intent of the Technical Specification.

Corrective Action to be Taken

1. PPM 11.2.7.1, Area Postin , will be revised to more accurately reflect the intent o ec nical Specification 6.12.2.

2. Health Physics personnel completed a Plant walkdown to identify areas accessible to personnel with dose equivalent rates in excess of 1000 mrem/hr. Three areas that are currently posted and barricaded, but not locked, were identified, including an overhead area of the 437'adwaste Building and the East and Mest RMCU Pump Valve Galleries on the Radwaste 467'evel..

The 437'evel overhead area is adequately posted and barricaded, not subject to routine or frequent entry, and an enclosure cannot reasonably be constructed to prevent entry. No changes are anticipated.

A Maintenance Work Request has been issued to install locking gates on each of the RMCU Valve Gallery Rooms on the Radwaste 467'evel. Completion sill establish full compliance with the Technical Specification.

Date of Full Co liance August 31 1988

Page I of I APPENDIX B As requested by your transmittal letter, the following is a description of those actions to assure that analyses of future operational events are more thorough.

1. Plant Procedure 1.3.48, "Root Cause Analysis," was recently approved (April 28, 1988) for use and presents five methods for evaluating Plant problems for the purpose of preventing recurrence.

2. The Licensing and Assur ance Directorate is currently in the process of staffing a dedicated Root Cause Analysis Group. The Supply System has committed to provide a copy of the action plan to the 'WC Resident Inspector describing implementation of group staffing and responsi-bil.ities by August 1, l988.

3, Plant Procedur e 11.2.19.1, "Investigation of Non-Reportable Radiological Occurrences," will be revised to include more specific guidance on performing root cause analyses for radiological occurrences.

Regarding the concern relating to frequency of system valve line-up verifications. System Oper ating Procedures (particularly those associated with radwaste operations) will be reviewed to identify those which should have a valve line-up performed prior to executing the procedure.

- - KFI'RIBUTION'EMONSTRATION" AC CZlZRATED. SYFI EM

'I, 1

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:8808030292 DOC.DATE: 88/07/29 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R

SUBJECT:

Responds to NRC 880629 50-397/88-22.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IE06D TITLE: Environ &

COPIES RECEIVED: LTR Q ENCL j SIZE:

Radiological (50 DKT)-Insp Rept/Notice of Viola won Respons D

B NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 1 SAMWORTH,R 1 1 INTERNAL: ACRS 2 2 AEOD/DOA 1 1 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 D NMSS/SGOB 4E4 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1

( NRR/DREP/RPB 10 NUBGGS.-

REG FIZZ RES/D RGN5 STRACT EPY FILE 01 RGN4 MURRAY,B 02 2

1 1

1 1

1 2

1 1

1 1

1 NRR/PMAS/ILRB12 OGC/HDS2 RES RES/DSR DEPY RGN2/DRSS/EPRPB 1

1 1

1 1

1 1

1 1

1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 D

D D

TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 26

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.o. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 July 29, 1988 G02-88-170 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF"21 NRC INSPECTION REPORT 88-22 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated June 29, 1988. Our reply, pur-suant to the provisions of Section 2.201, Title 10, Code of Federal Regula-tions, consists of this letter and Appendicies A and B (attached).

In Appendix A, an explanation of our position regarding the validity of the violation is provided. As requested by your transmittal letter, Appendix B consists of actions taken to assure that analyses of future operational events are more thorough.

Should you have any questions, please contact Mr. A. G. Hosier, Manager, WNP-2 Licensing.

Very truly yours, G. C. Sorensen, M ger Regulatory Programs JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth - NRC DL Williams - BPA NRC Site Inspector 901A 8808030292 880729 PDR ADQCK 05000397 PDC 9

Page 1 of 3 APPENDIX A During an NRC inspection conducted on June 6-9, 1988, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1987), the violations are listed below:

A. Technical Specification 6.12.1 states, in part:

"...each high radiation area in which the intensity of radiation is greater than 100 mrems/h but less than 1000 mrems/h shall be barri-caded and conspicuously posted as a high radiation area...

"...Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation does rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset inte-grated dose is received..."

"c. A health physics qualified individual .(i.e., qualified in radia-tion protection procedures) with a radiation dose rate monitoring device...""

Contrary to the above, on Nay 12, 1988, an individual entered an area on the 437'levation of the Radwaste 'Building, where the intensity of radiation measured up to 1000 mrems/h, without being accompanied or provided with the equipment specified above.

This is a Severity Level IV Violation (Supplement IV).

Validit of Violation The Supply System acknowledges the validity of the violation.

Corrective Ste s Taken/Results Achieved

1. The door allowing access to the area was closed and locked immediately following a determination that the Supply System interpretation of Technical Specification 6.12.2 was incorrect (see response to Item B).

2. The individual involved was counseled by Supervision on the procedural compliance aspects of entering High Radiation Areas.

Appendix A Page 2 of 3

3. Operati ons department t shi f personnel were gi ven suppl cmental instructions regarding posting and entry requirements for high and high-high radiation areas. These instructions were admin-istered through shift safety meetings and completed by June 10, 1988.

4. The five week Operator Requalification Training Program, com-pleted on July 18, 1988, included a revised module addressing the requirements for entry into high and high-high radiation areas.

5. The applicable RWP (2-88-00004, Operations Department Routines) was revised to include a statement of the requirements for entry to High Radiation Areas.

Corrective Action to be Taken

1. Training material will be developed and presented during Operations Department safety meetings to emphasize the significance of posted areas and requirements of entry.

2. The General Employee Training module will be reviewed and, if necessary, revised to ensure other. personnel receive training similar to that of Operations personnel. This commitment is made because of a Plant equal'ity Assurance survey which was conducted to provide an indication of the level of knowledge of Plant personnel regarding radiation barriers. The results of the survey indicated that many of the survey population did not have a clear understanding of "High" Radiation Areas, "High.-High" Radiation Areas and Area Radiation Monitors (ARMS).

Date of Full Com liance October 31, 1988 B. Technical Specification 6.12.2 states, in part:

"...For individual 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 in excess of 1000 mrems*** that are located within large areas, such as the containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device..."

Contrary to the above, on June 8, 1988, an area existed within the Waste Collector Tank Room on the 437'levation of the Radwaste Build-ing, where the intensity of radiation accessible to a major portion of the body measured up to 1450 mR/hr, and the room was provided with a door which was not locked nor had an enclosure which could have been reasonably constructed, for the purpose of locking been installed.

This is a Severity Level IV Violation (Suplement IV).

Appendix A Page 3 of 3 Validit of Violation The Supply System acknowledges the validity of the violation.

However, it should be noted that a conscious decision was made to control access to the area by means of barricading, posting and a yellow flashing light, in lieu of locking tHe door or constructing an enclosure. The decision was based on our interpretation of Technical Specification 6.1.2 at the time, with the expectation being that sufficient controls were in place to control access.

Corrective Ste s Taken/Results Achieved The door allowing access to the area was locked to fully comply with the intent of the Technical Specification.

Corrective Action to be Taken P N .2.7.1, ~A reflect the intent of Technical Specification 6.12.2.

2. Health Physics personnel completed a Plant walkdown to identify areas accessible to personnel with dose equivalent rates in excess of 1000 mrem/hr. Three areas that are currently posted and barricaded, but not locked, were identified, including an overhead area of the 437'adwaste Building and the East and West RWCU Pump Valve Galleries on the Radwaste 467'evel.

The 437'evel overhead area is adequately posted and barricaded, not subject to routine or frequent entry, and an enclosure cannot reasonably be constructed to prevent entry. No changes are anticipated.

A Maintenance Work Request has been issued to install locking gates on each of the RWCU Valve Gallery Rooms on the Radwaste 467'e;el. Completion will establish full compliance with the Technical Specification.

Date of Full Com liance August 31, 1988

Page 1 of 1 APPENDIX 8 As requested by your transmittal letter, the following is a description of those actions to assure that analyses of future operational events are more thorough.

1. Plant Procedure 1.3.48, "Root Cause Analysis," was recently approved (April 28, 1988) for use and presents five methods for evaluating Plant problems for the purpose of preventing recurrence.

2. The Licensing and Assurance Directorate is currently in the process of staffing a dedicated Root Cause Analysis Group. The Supply System has committed to provide a copy of the action plan to the HRC Resident Inspector describing implementation of group staffing and responsi-bil.ities by August 1, 1988.

3. Pl ant Procedure 11.2.19. 1, "Investi gati on of Non-Repor tab 1 e Radiological Occurrences," will be revised to include more specific guidance on performing root cause analyses for radiological occurrences.

Regarding the concern relating to frequency of system valve line-up verifications, System Operating Procedures (particularly those associated with radwaste operations) will be reviewed to identify those which should have a valve line-up performed prior to executing the procedure.