ML20005E368

Responds to Violations Noted in Insp Repts 50-348/89-28 & 50-364/89-28 on 891002-06.Corrective Actions:All Piping Preparation for Inservice Insp Work in Containment Stopped & All Participants Assembled to Gather Facts on Incident

ML20005E368
Person / Time
Site:	Farley
Issue date:	12/28/1989
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9001050138
Download: ML20005E368 (3)

Text

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p E- AIIbama Power Opmpany

: 40 inverevst Cent r Parkway 1 Post Othee Box 1295 1-Birmingham. Alabama 35201 Telephone 205 B68-5581-L W. G. Hairston,111 senior Vlce President Nuclear Operations M3b3[Il3 NWCf December 28, 1989 '** So#"" *c'm srs*n Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555

SUBJECT:

. Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of October 2-6, 1989 RE: Report Number 50-348/89-28-01 50-364/89-28-01 Gentlemen:

This letter refers to the violation cited in the subject inspection reports which state:

"During the Nuclear Regulatory Comission (NRC) inspection conducted on October 2-6, 1989 a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C.(1989), the violation is i

listed below:

Technical Specification 6.12.1 requires that each high radiation area, in which the intensity is greater than 100 mrenVhr but less that 1,000 mrenVhr, shall be controlled by requiring the issuance of a radiation work permit (RWP) and be accompanied by one or more of the following: (a) a dose rate monitoring device that continuously indicates dose in the area, (b) a radiation monitoring device that continuously integrates dose and alarms at a pre-set point; or (c) a health physics technician, with a radiation monitoring device, that provides positive control over activities in the area and provides surveillance and surveys at the frequency designated by the facility health physics supervisor.

Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering activities referenced in Appendix A, of Regulatory Guide 1.33, Revision 2, 1978. Regulatory Guide 1.33, Appendix A, Section 7.e recommends that the licensee have procedures for access to radiation areas. Licensee procedure, FNP-0-M-001, Health

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Physics Manual, Section 4.1.1.7, requires an individual to know and follow requirements of the RWP used to control work.

Contrary to the above, a contract worker performing in service inspection work entered a high radiation area and an exclusion area in the Unit 1 containment building on October 5, 1989, without authorization from health physics.

O 9001050138 891228 l PDR ADOCK 05000348 y t G PNU if I ,

3 Nuclear Regulatory Commission December 28, 1989  !

Page 2 i mis is a Severity Level IV violation (Supploment IV)."  ;

Admission or Denial ne above violation' occurred as described in the subject reports.

Reason for Violation

- Wis violation was caused by singular personnel error in that the worker was inattentive to health physics postings on and around the steam- i generator (SG)-platform ladder.. Although he had permission to work in the i area where he intended to work, he did not have approval to use the SG  !

platform ladder which was posted as an exclusion area with a flashing red  !

light. j Corrective Actions Taken and Results Achieved l

1. All piping preparation for inservice inspection work in containment was stopped.

2. All participants were assembled to gather the facts on the incident.

3. We worker was suspended.  ;

Correct Ere Steps To Avoid Further violations  !

1. We worker-was required to re-attend the initial radiation worker training.

2. Training sessions on the definitions of "high radiation area" and

" exclusion area" were held for each FNP work group.

Date of Full Compliance December 15, 1989

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Analysis As requested in the NRC cover letter forwarding the notice of violation, events of December 1987 (50-348,364/88-02) and May 1989 (50-348,364/89-13) were reviewed for similarity and root cause.

We December 1987 event involved a contract worker entering an exclusion area (30 R/hr general area) without proper dosimetry, without an RWP and in violation of HP postings. He received 455 mrem during a 2-5 minute entry.

The May 1989 event involved a worker calling the HP Office to obtain approval to enter an RHR pump room without a high range dosimeter as required by RWP. The worker believed he had approval to deviate from the RWP requirements, but it was not logged in the HP Office. The worker received 10 mrem during his entry.

mis incident is different from the earlier events in that the worker had received approval from HP to work in the area where he intended to work

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Nuclear Regulatory Commission  !

December 28, 1989 p

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(outside of the exclusion area associated with the SG platform). The root I problem in this case was that the worker was inattentive to the conspicuous postings on and around the ladder he climbed.- In the post-incident critique it was established that the worker understood that he could not enter a high radiation area or exclusion area without approval, although he '

admitted that he could not define the two terms. As noted in the NRC Inspection Report, the worker stated that he did not see the postings or the flashing light. His' inattentiveness may have resulted from his assumption (incorrect) that he had approval from HP to utilize the SG platform ladder. nus, this incident is not considered to have been caused by a failure of the radiation worker training program, but by the inattentiveness of the worker.

Another difference between this incident and the earlier events was that the SG platform ladder and associated tent were under continuous '

surveillance of an HP technician (via closed circuit TV) to identify any unauthorized entries. This degree of positive control resulted in immediate identification of the unauthorized entry and removal of the worker.

The dose consequences of this incident were insignificant. The exclusion area and high radiation area boundaries were set conservatively in order to control access at the base of the ladder. In fact, the maximum dose rate below the SG platform (where the worker was located) was 80 mrem'per hour.

It is estimated that the worker received less than 1 mrom exposure during the incident.

Alabama Power Company recognizes the seriousness of workers violating radiation postings.- The following initiatives have been taken as long range, programmatic enhancements beyond the scope of this violation.

1. Human-factored postings using a red, octagonal (stop sign) format for exclusion area and a yellow, triangular (yield sign) format for high radiation area have been designed and ordered.

2. Acquisition of additional digital alarming dosimeters has been budgeted for 1990.

Affirmation l

I affirm that this response is true and complete to the best of my knowledge, information, and belief. The information contained in this letter is not considered to be of a proprietary nature.

l Respectfully submitted, L _

cd,b./U W l W. G. Hairston, III WGH:emb-5.10 cc: Mr. S. D. Ebneter Mr. E. A. Reeves Mr. G. F. Maxwell l

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