ML17285B403
| ML17285B403 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/30/1990 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 9008070077 | |
| Download: ML17285B403 (6) | |
See also: IR 05000397/1990010
Text
JU'
0 f990
Docket No.
50-397
Washington Public Power
Supply System
P.
O.
Box 968
3000 George
May
Richland,
Mashington
99352
Attention:
Mr.
G.
C. Sorensen,
Manager
Regulatory
Programs
Gentlemen:
Thank you for your letter of July 6,
1990, in response
to our Notice of
Violation and Inspection
Report
No. 90-10,
dated
June 8, 1990,
informing us
of the steps
you have taken to correct the items which we brought to your
attention.
Your corrective actions will be verified during a future
inspection.
Your cooperation with us is appreciated.
Sincerely,
I
n
~
l.'-//
A. Richards,
Chief
Reactor Projects
Branch
bcc w/copy of ltr. dated 7/6/90:
Docket File
Resident Inspector
Project Inspector
G.
Cook
B. Faulkenberry
J. Martin
J. Zollicoffer
bcc w/o copy of ltr. dated 7/6/90:
M. Smith
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WASHINGTON PUBI IC POWER SUPPI,Y SYSTEM
~ RC
P.O. Box 968
~ 3000 George Washington Way
~ Richland, Washing
93S2
lt
July 6,
1990
G02-90"120
Docket No. 50-397
U. S. Nuclear Regulatory
Commission
Attn:
Document Control
Desk
- Hail Station Pl-137
D.
C.
20555
Gentlemen:
Subject:
NUCLEAR PLANT NO. 2,
OPERATING LICENSE NO. HPF-21
NRC INSPECTION
REPORT 90-10
RESPONSE
To NOTICE OF. VIOLATIOH
The
Public
Power
Supply
System
hereby
replies
to the
Notice of
Violation contained in your letter dated
June 8,
1990.
Our reply, pursuant
to
the provisions of Section
2 '01, Title 10,
Code of Federal Regulations,
consists
of this letter and Appendix A (attached). ~
~
In Appendix A, the violation is addressed
with an explanation of our position
regarding validity, corrective action
and date of full compliance.
. Very truly youy.s,
G.
D. Bouchey,
Di
or
Licensing
h Assurance
JDA/bk
Attachments
CC:
JB Hartin -
HRC
RV
HS Reynolds
-
BCP&R
RB Samworth -
NRC
DL Williams - BPA/399
HRC Site Inspector
- 901A
APPENDIX A
During an
NRC inspection
conducted
on April 9 - Hay 13,
1990
a violation of NRC
requirements
was identified...jn accordance. With the.".General
Statement of Policy
and
Procedure
for
NRC
Enforcement
Actions,"
Appendix
C,
the
violation is listed below:
Section 6. 12 of the WNP-2 Technical Specification,
"High Radiation Areas," states
that each
area in which the intensity of radiation is greater
than
100 mrem/hr
but less than 1000 mrem/hr shall
be barricaded
and conspicuously posted
as
a High
Radiation Area.
Contrary to the
above,
on
Hay 13,
1990,
the
access
doorway to residual
heat
removal
heat
exchanger
room "lA" on
the
548 ft. elevation
of the
reactor
building,.which contained radiation levels
up to 180 mrem/hr,
was not barricaded
and conspicuously
posted
as
This is
a Severity Level
IV Violation (Supplement I).
Yalidit of Violation
The Supply System
acknowledges
the validity of this violation.
The reason for
the violation was
personnel
performance
based
in that the Contractor
Health
Physics Technician involved failed to replace the barrier as required following
removal of equipment from the heat exchanger
room.
The barrier had been wrapped
up
and
tucked
behind
the
door to the
heat
exchanger
room to facilitate the
'removal
and survey of equipment following work during the annual maintenance
and
refueling outage.
A formal Root Cause Analysis (including an events
and causal
~
~
~
factors review) was performed which determined that the technician involved had
been
moving the equipment to
a lower background
area for surveying,
and forgot
to reinstall the barrier upon leaving the area.
The room was not properly posted
for a period of approximately
10 minutes.
The
Supply
System
recognizes
the
importance
of
adherence
to radiological
controls,
and
implementation
of the Health
Physics
Program is
an
area
which
requires. additional management attention at WNP-2.
Plant Hanagement is currently
developing
a response to a Plant guality Assurance Surveillance Report"which will
address this area of concern.
Corrective Ste
s Taken Results
Achieved
2.
3.
The posting
was immediately restored to the correct position.
The
Contractor
Health
Physics
Technician
involved
was
counselled
on
radiological posting requirements
and performance
expectations.
As
a
result
of
previous
radiological
posting
violations,
several
improvements
have
since
been
made
in this
area.
All line
managers
reporting to the Plant Hanager
have trained their personnel
on radiologi-
cal control requirements,
and the General
Employee
and Advanced Radiologi-
cal Training Modules
have
been revised to include additional
emphasis
on
radiological control requirements.
Appendix
A
Page
2 of 2
Primary
emphasis
for improvement will continue
to
be directed
toward
training personnel
on the importance of understanding
and complying with
the fundamentals
of the Health Physics
Program.
Corrective Action to be Taken
This violation and the formal root cause analysis will be discussed
during
Health Physics Technician safety meetings.
Further
improvements
have
also
since
been
implemented
with regard
to
radiological postings.
These improvements,
which were made in April 1989,
included providing additional radiological
postings
at the entrances
to
several. radiologicglly posted
areas,
unless
there
were restraints, which
. prevented
tbe
addbtional
posting.
These
additional
postings
are
independent of the access barrier.
Since this action has
been taken, the
number of posting problems identified has been significantly reduced (only
two posting violations, have occurred since the changes
were made).
These
two violations were 1) a self-identified posting problem with an
RWCU room
which occurred during Hay 1989,
and 2) this
NOV where the barrier was left
down, at the entrance
to the
RHR Heat Exchanger
Room.
'
Another
improvement
is
that
NRC
Notices
of Violation
and
in-house
Radiological Occurrence
Reports are discussed
in the training programs for
Supply System
and Contractor Health Physics Technicians.
This particular
.viol,ation..has
been
added to the'ist of those topics to be covered in the
training
program
to further
emphasize
the
importance
of attention
to
detail.
2.'s
stated in the referenced letter, increased
emphasis will continue to be
applied
in the
area of Health
Physics
supervisory
overview of work in
progress
to improve evaluation of personnel
performance.
Date of Full
Com liance
Full
compliance
was
achieved
when
the
posting
was
restored
to the
correct
'position...