ML18068A374

Responds to NRC 980615 Ltr Re Violations Noted in Insp Rept 50-255/98-09.Corrective Actions:Stop Work Order Was Issued, Work Group Exited Containment,Debrief Held W/Work Group & Contract Workers Were Counseled Re Poor Radworker Practices

ML18068A374
Person / Time
Site:	Palisades
Issue date:	07/14/1998
From:	Thomas J. Palmisano CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-255-98-09, 50-255-98-9, NUDOCS 9807200372
Download: ML18068A374 (13)

Text

A CMS Energy"Company Palisades Nuclear Plant Tel: 616 764 2296 27780 Blue Star Memorial Highway Fax: 616 764 2425 Covert, Ml 49043 1llo11111* J. l'lllmluao Site Vice President July 14, 1998 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATIONS FROM INSPECTION REPORT 50-255/98009 NRC Inspection Report 50-255/98009(DRS) dated June 15, 1998, cited three violations. The violations involved the failure to properly post a high radiation area, lack of positive control over radiation controlled doors and instances of failing to comply with our radiation contr91led area access procedure. The violations involved contract staff hired to augment station personnel during our recent refueling outage. The violations were identified by Palisades Radiation Protection staff.

Consumers Energy agrees with the violations as written, with one minor correction to the supporting statements made in the Inspection Report, as explained in Attachment 2.

Consumers Energy is very concerned with the events which led to these violations.

Previous corrective actions to address high radiation posting violations focused on increasing sensitivity and awareness of radiological requirements *to Plant Health

• Physics (HP) technicians and radworkers. However, these actions were not broad enough in that they did not ensure that expectations were adequately communicated to contract workers.

- As a result--ofthe eve-nts ~hich occurred during the refueling outage, a multi-disciplinary I review team was formed to evaluate Radiation Protection program implementation. / O lO This team was tasked with performing a common cause analysis, determining root A 'ti causes and reviewing past corrective actions to determine effectiveness. An outside /

• ct1nsultan.t ~a.: ~r:ught in. as a,. member of the team and bench marking visits were 9807200372 iffl0714 ~ .

PDR ADOCK 05000255 ;_

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2 made to two other nuclear plants to validate proposed corrective actions. The results of the evaluation have been fac;tored into our violation responses, which are attached.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

Thomas J. Palmisano Site Vice President CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades

• Attachments

ATTACHMENT 1 CONSUMERS ENERGY COMPANY PALISADES PLANT .

DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/98009-04 FAILURE TO LOCK OR GUARD RADIATION CONTROLLED DOORS ACCESSING AREAS WITH RADIATION LEVELS IN EXCESS OF 1000 mrem/h 3 Pages

ATTACHMENT 1

. REPLY TO NOTICE OF VIOLATION 50-255198009-04 FAILURE TO LOCK OR GUARD RADIATION CONTROLLED DOORS ACCESSING AREAS WITH RADIATION LEVELS IN EXCESS OF 1000 mremlh NRC NOTICE OF VIOLATION During an NRC inspection conducted May 4 - June 1, 1998, three violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, violation 50-255/98009-04 is listed below:

1. Technical Specification 6. 7. 2 required, in part, that areas with radiation levels

• greater than or equal to 1000 mremlhr be provided with locked or continuously

• guarded doors to prevent inadvertent unauthorized entry.

Contrary to the above;

a. On April 29, 1998, the Radiation Controlled Door to the 607' Mainsteam Room in containment, with radiation levels ranging up to 5000 mremihr, was not locked and not guarded for several minutes (VIO 50-255/98009-04a).

b. On May 28, 1998; the Radiation Controlled Door to the Clean Waste Receiver Tank room, which provides access to the 607' catwalk with

.radiation levels ranging up to 1200 mremlhr, was. not locked and not guarded for approximately 30 minutes. (VIO 5~255/98009-04b).

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

CONSUMERS ENERGY RESPONSE Consumers Energy Company agrees with the violation as written.

BACKGROUND '

On April 29, 1998, a crew of three contract workers entered Containment to continue erection of scaffolding in the Main Steam Room on the 607' Elevation. The door to this area was locked and posted as a Radiation Controlled Door (RCD). The RCD is used

• to prevent unauthorized access to an area where general radiation levels greater than 1 rem/hr exist or-could-potentially exist:- A Health Physics (HP) Technician unlocked the RCD and escorted the workers to the work area, which was located in a low dose area (2-3 mrem/hr). After briefing the workers on the general area dose rates, the HP Technician left the area and ensured that the door was locked behind him. Shortly after 1

ATTACHM~NT1 REPLY TO NOTICE OF VIOLATION 50-255/98009-04 FAILURE TO LOCK OR GOARD RADIATION CONTROLLED DOORS ACCESSING AREAS WITH RADIATION LEVELS IN EXCESS OF 1000 mrem/h the HP Technician left, one of the workers determined that additional scaffolding material was needed, and that he needed to contact his supervisor. When he exited the RCD, he placed a role of duct tape between the door and the door jamb to hold it open, expecting to return in a minute or two. Two different HP Technicians arrived at the door a few minutes later and discovered the door propped open. One HP Technician entered the room to talk to the work group while the other HP Technician controlled the door. A Stop Work Order was issued and the crew was escorted out of containment.

• On May 28, 1998, a contract HP Technician and a plant electriCian entered the RCD

• into the Clean Waste Receiver Tank Room to access the Primary Coolant Pumps from the 607' catwalk; The HP Technician unlocked the door and entered the room first and the electrician closed the door. The HP Technician did not verify that the door was completely latched. After completing their work, the technician and electrician exited the area through a different door. Approximately 30 minutes later, an HP Technician on rounds discovered the RCD was closed, but not latched.

HP Procedure 2.5 normally requires double verification that RCDs are locked.

However,*the procedure allows a waiver of this requirement during refueling outages.

The requirement for double verification Of RCDs had been waived for Containment during the outage.

REASON FOR VIOLATION In the first example, coverage provided by the HP Technician was inadequate for work being performed behind an RCD. The expectation for maintaining positive control of an RCD was not clearly communicated to contract HP Technicians. In addition, radworker responsibilities related to locked RCDs were not discussed during the pre-job briefing.

In the second example, performance expectations were not met in that the HP Technician did not physically manipulate the door to ensure that it was closed. In addition, the requirement for double verification of RCDs had been waived for Containment during the outage.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED When the door was found unsecured on April 29, 1998, a stop work order was issued by the Duty HP and the work group exited containment. C&RS management held a debrief with the work group and the responsible contract radworker was denied

• 2

ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION 50-255/98009-04 FAILURE TO LOCK OR GUARD RADIATION CONTROLLED DOORS ACCESSING AREAS WITH RADIATION LEVELS IN EXCESS OF 1000 mrem/h Radiation Controlled Area (RCA) access for the remainder of the outage. C&RS management communicated to all HP Technicians, the expectation that all entries behind a RCD require direct or remote HP coverage with positive control over the RCD.

A Stand down Meeting was held with all HP Technicians to reinforce the above expectations.

• On May 28, 1998, and for the remainder of the outage, issuance of RCD keys was transferred from the HP Crew Leader to the Duty HP Supervisor. The Duty HP Supervisor provided a briefing to all HP Technicians, as they were issued a RCD key, outlining their responsibilities, including a check.to ensure RCD closure after entry and double verification of the RCD upon exiting. At the end of the outage, this responsibility was re-assumed by the HP Crew Leader. In addition, the double verification requirement for RCDs was reinstated. No additional problems have been noted.

• CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS

1. Expectations for HP Technicians maintaining positive control of RCDs, including

. . a check to ensure closure after entry, will become part of the radiological work *

• standards. Pre-job briefings, to include discussion of worker responsibilities for RCD control, as appropriate for the activity, will be performed prior to beginning work behind a RCD. *

2. Procedure HP 2.5 will be revised such that a waiver of the double verification requirementfor ensuring RCDs are locked upon exit, will no longer be allowed ..

PATE WHEN EULL COMPLIANCE WILL BE ACHIEVED Eull compliance for the first example was achieved on April 29, 1998, when the door was closed and locked.

Eull compliance for the second example was achieved on May 28, 1998, when the door .

was completely latched and locked.

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~*

ATTACHMENT 2 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/98009-05 FAILURE TO COMPLY WITH STATION PROCEDURA:L REQUIREMENTS FOR APPROPRIATE RADIATION PROTECTION PRACTICE 3 Pages

ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 50-255198009-05 FAILURE TO COMPLY WITH STATION PROCEDURAL REQUIREMENTS FOR APPROPRIATE RADIATION PROTECTION PRACTICE NRC NOTICE OF VIOLATION During an NRC inspection conducted May 4 - June 1, 1998, three violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, violation 50-255/98009-05 is listed below:

2. Technical Specification 6.4.1 requires, in part, that written procedures be established, implemented, and maintained covering activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.

Regulatory Guide 1.33, Appendix A, recommends that safety-related activities covered by written procedures include radiation protection procedures for access control to radiation areas including a radiation work pennit system.

Administrative Procedure No. 7. 13, Revision 7, "Radiation Controlled Area Access", describes requiref!lents for access control to radiation areas.

a. Attachment 1, "Individual Responsibilities for Proper Radiation Safety, or Administrative Procedure No. 7. 13, Revision 7, requires, in part, that all personnel working in the Radiation Controlled Area promptly obey "Stop Work" instructions of Radiological Services personnel.

b. Administrative Procedure No. 7. 13, Revision 7, "Radiation Controlled Area Access", requires, in part, that all personnel, entering the Radiation Controlled Area, log the entry for dose tracking purposes by following the instruction given by the computer tenninal.

Contrary to the above;

a. On May 19, 1998, two contract personnel, working in the Radiation Controlled Area, conducting incore instrumentation insertion on the upper.

guide structure failed to promptly obey the. "Stop Work" instructions of RadiologicaJ Services personnel (VIO 50-255198009-05a).

b. On May 22, 1998, a contract worker, who entered the reactor cavity, an

_.* __ _._._area_within the Radiation Controlled Area, to install lead shielding and -*

remove reactor heater blankets, did not log his entry for dose tracking purposes by following the instruction given by the computer tenninal (VIO 50-255198009-05b).

This is a severity Level IV violation (Supplement IV).

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ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 50-255/98009-05 FAILURE TO COMPLY WITH STATION PROCEDURAL REQUIREMENTS FOR APPROPRIATE RADIATION PROTECTION PRACTICE CONSUMERS ENERGY RESPONSE Consumers Energy Company agrees with this violation as written. However, Consumers Energy notes that the contamination levels identified in .the Inspection Report involved different radworkers not associated with this violation. Both individuals involved in this violation were contaminated around their faces and noses (300-800 ccpm) and ,one individual had contamination on his palm at 200 ccpm. The work associated with this violation was being performed in a high contamination area in tight quarters. However, the poor radworker practices exhibited by the individuals involved contributed to the location of the observed contamination.

BACKGROUND On May 19, 1998, two contract personnel involved in the final incore instrumention (ICI) insertion were working on the lower platform of the Upper Guide Structure (UGS). The work was being performed in a high noise area .. Durif'!g the work, a Contract Health Physics Technician (CHPT) wanted to stop the job because he observed poor radworker practices and suspected that the workers.had become contaminated. He shouted and used hand motions to communicate to the workers. The workers acknowledged the CHPT, however, they continued to work for approximately five minutes before exiting the area.

On May 22, 1998, a contract crew of five workers entered the reactor cavity to install lead shielding on the annulus and remove reactor head heater blankets. One of the

• - crew members intended to log into the Management Information System (MIS)

Terminal with a Remote Monitoring System (RMS) Electronic Dosimeter (ED).

However, the crew member prematurely removed the ED before it was properly logged in and failed to verify that his name appeared on the RMS monitoring screen. The job

.coverage HP Technician allowed the crew member entry into the cavity without verifying the worker was on the RMS screen. Approximately two hours later, the worker discovered that he could not log out of the MIS system because the ED had not been properly logged in.

. ~-~- - --~- -* -

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ATTACHMENT 2 REPLY TO NOTICE OF VIOLATION 50-255/98009-05 FAILURE TO COMPLY WITH STATION PROCEDURAL REQUIREMENTS FOR APPROPRIATE RADIATION PROTECTION PRACTICE REASON FOR VIOLATION Miscommunication between the contract HP Technician and the workers caused the first violation example. The contract HP Technician did not clearly communicate.that the work was to be stopped. The workers failed to promptly acknowledge* that the HP Technician was telling them to stop the work.

The reason for the second example is that the contract radworker did not comply with the established standard for logging into the MIS system. In addition, the contract*

radworker and the contract HP* Technician did not comply with the established standard for verifying that the radworker's name appeared on the RMS monitoring screen.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The two contract workers in the first example were counseled regarding the poor*

radworker practices and the failure to follow instructions from HP staff. The lead contract worker was denied access to the RCA for the remainder of the outage.

Expectations for following HP instructions were reiterated to the rest of the contract staff. A specific hand signal was designated for the remainder of the outage to communicate a stop work order in high noise areas.

The radworker who did not properly log in to MIS was counseled as to his responsibilities for use of Electronic Dosimetry. The expectations for coverage of workers on the Remote Monitoring System were recommunicated to all HP Technicians.

CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS Existing expectations for HP stop work orders will be reinforced to contract radworkers

. and contract HP Technicians. This will be accomplished by.enhancing the training required for RCA access. Additional monitoring and reinforcement ofstandards and expectations will be performed by Palisades management and supervisory staff.

DATE WHEN EULL COMPLIANCE WILL BE ACHIEVED

• Full compliance for the first example was achieved May 19, 1998, when the radworkers exited the RCA.

Full compliance for the second example was achieved May 22, 1998, when the radworker exited the RCA.

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ATTACHMENT 3 CONSUMERS ENERGY COMPANY PALISADES PLANT DOCKET 50-255 REPLY TO NOTICE OF VIOLATION 50-255/98009-06

• FAILURE TO POST THE REACTOR CAVITY HIGH RADIATION AREA

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• 2 Pages

(.I ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 50-255/98009-06

. FAILURE TO POST THE REACTOR CAVITY HIGH RADIATION AREA NRC NOTICE OF VIOLATION During an NRC inspection conducted May 4 - June 1, 1998, three violations of NRC

. requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, Violation 50-255/98009-06 is listed below:

3. 10 CFR 20.1902(b) requires that the licensee post each high radiation area with a conspicuous sign bearing the radiation symbol and the words "CAUTION,.

HIGH RADIATION AREA" or "DANGER, HIGH RADIATION AREA".

Pursuant to 10 CFR 20. 1003, a high radiation area means an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 100 mi/Iirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 cm from the radiation source

• or from any surface that the radiation penetrates.

Contrary to the above, from approximately 4:00 pm to 9:00 pm on May 27, 1998, the access ladder to the reactor cavity floor, with radiation levels of up to 150 millirem in an hour at 30 centimeters, was not conspicuously posted with a sign bearing the radiation symbol and the words "CAUTION, HIGH RAD/A TION AREA" or "DANGER, HIGH RADIATION AREA" (VIO 50-255198009-06).

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

CONSUMERS ENERGY RESPONSE Consumers Energy agrees with this violation as written.

BACKGROUND On May 27, 1998, at approximately 1600 hrs, a Contract Health Physics Technician (CHPT) changed the posting at the entrance to the Reactor Cavity from a five pocket sign containing High Radiation Area (HRA), High Contamination Area (HCA), and Airborne Area (AA) inserts to a single hard plastic High Contamination Area (HCA) sign.

This was being done because the five pocket signs are not allowed in Containment during power operations. Radiological conditions in the Reactor Cavity also required that a High Radiation Area (HRA) be posted*: While reviewing RadiologicarStatus Sheets at approximately 1900 hrs, a Duty.HP Supervisor noted that the Reactor Cavity entrance was not designated as a HRA on the Status Sheet. A Health Physics Technician verified that the access to the reactor cavity was not posted as a HRA. The area was immediately posted as a HRA.

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ATTACHMENT 3 REPLY TO NOTICE OF VIOLATION 50-255/98009-06 _

FAILURE TO POST THE REACTOR CAVITY HIGH RADIATION AREA REASON FOR VIOLATION The Contract Health Physics Technician who replaced the reactor cavity postings failed

.to self-check to verifiy that the correct postings were in place. This was identified as an individual performance issue.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The reactor cavity access was correctly posted as a High Radiation Area upon discovery. All other High Radiation Area postings in the plant were verified with no other errors noted.

CORRECTIVE ACTIONS REMAINING TO AVOID FURTHER VIOLATIONS In order to ensure compliance with posting requirements, a checklist will be used when a HRA posting is altered, to verify that the posting is correct upon completion of the task; or as an alternative, an on-the-spot double verification of the posting will be

• required.

PATE WHEN EULL COMPLIANCE WILL BE ACHIEVED Compliance was achieved when the reactor cavity access was correctly posted as a High Radiation Area on May 27, 1998;

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