ML20066G726
| ML20066G726 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/25/1991 |
| From: | James Fisicaro ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 0CAN019108, CAN19108, NUDOCS 9101280183 | |
| Download: ML20066G726 (6) | |
Text
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- -. Operations w m en n m 7.s tm.9.:..:.ww January 25, 1991 OCAN019108 C. S. Nuclear Regulatory Commission Document Control Desk Mall Station P1-137 Washington, 11. C. 20555
Subject:
Arkansas Nuclear One - Units 1 and 2 Docket Nos. 50-313/50-368 License Nos. DPR-51 and NPF-6 Response to Inspection Report 50-313/90 '9; 50-368/90-34 s
Gentlemen:
Pursuant to the provisions of 10CFR2.201, attached is the responso to the violation Identified durlag the inspection of activities related to ine,'equato ! calth physics practicos associated with maintenance work on Coro Flood System check valvo CF-1B.
Should you have any q.
2tions, please call me at 501-964-8601.
Vory truly yo':*,
l wJ hk" James Fialcaro Managor, Licensing JJF/DWB/mmg Attachment l
9101280183 91012"' 3 i
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Mr. Robert Martin U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 21st e W. Alexion W-roject Manager, Region IV/ANO-1 U. J. Nuclear Regulatory Commission NPR Mail Stop 11-D-19 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 NRG Senjor Resident Inspector Arkanscs Nuclear One - ANO-1 & 2 Number 1. Nuclear Plant Road Russellville, AR 72801 Hs. Sherl Peterson NRR Project Manager, Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 11-B-19 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852 0
11 l
U.S. NRC 4
Page 1 January 25, 1991 i
surveys 10 CFR Part 20.201(b) requires that each licensee shall make or cause to be made such surveys as may be necessary to evaluate the extent of radiation hazards that may be present.
Contrary to the abova, on October 31. 1990, the licensee did not perform an adequate survey to evaluate the extent of the radiation hazard inside of Valve CF-1B.
This is a Severity Level IV violation (Supplement IV) (313/9039-01; 368/9039-01).
B.
Instructions to Workers 10 CFR Part 19.12 requires that individuals working in the restricted area shall be kept informed of radiation in the restricted area and precautions or procedures to minimize exposure.
Contrary to the above, on Octobet 31, 1990, an individual working on Valve CF-1B was not kept informed of the radiation levels inside the valve or proper procedures to minimize exposure.
This as a Severity Level IV violation (Supplement IV) (313/9039-02; 368/3039-02).
Response to Violation ANO has evaluated both of the stated violations and has combined the response. The following response addresses violations 313-368/9039-01 and 313-368/9039-02.
(1) Reason _for the violation A post incident investigation determined the root cause of the violations to be failure of personnel to follow approved radiation protection procedures.
Upon disassembly of CF-1B on the evening of October 31,1990, the
. health physics technician assigned continuous coverage for the job failed to adequately determine the radiological conditions of the newly exposed internals of the valve body. This was required by the governing Radiological Work Permit (RWP) and station administrative procedures 1000.031, " Radiation Protection Manual," section 6.2.8 (revision 13) and health physics implementing procedure 1622.007, " Job Coverage," section 8.3 (revision 8).
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U.S. NRC Page 2 January 25, 1991 The second entry was conducted late on the evening of October 31, 1990.
No review of the radiological conditions of the work area, as required by 1000.031, " Radiation Protection Manual," Attachment I section III.A.3 (revisicn 13), was conducted by either the workers or the second health physics technician assigned to provido continuous coverage.
The second-health physics technician failed to verify or establish the radiological conditions at the work sito prior to work commencing.
No survey for hot particles was conducted on either entry as specified on the RWP.
The investigation also identified several contributing factors:
A.
The pro-job briefing for the work on CF-1B was inedequato.
Communications betwoon the work group and health pnysica personnel concerning the exact nature of the work to be performed on the second entry was not fully understood by either the health physics supervisor assigning coverago, or the health physics technician assigned to the coverage.
B.
The RWP writton to control the work on CF-1B was als inadequato in several respects:
- 1) it did not contain current job specific radiological survey information, nor specific radiological guidance for work on CF-1B, 2) the RWP was written to include work on systems-of varlod radiological hazards.
Servico Water System, Core Flood System, and Douay lleat System valves and hanger' vero all addressed by the one RWP, 3) the RWP was written to al:
the most rolaxed controls rather than the conservativo approach of stipulating the most stringent controls. This had tl.a offect of placing an over-reliance on the health physics technician't ability to determino and implement the proper controls, and 4) the RWP was written based on out-dated general area surveys versus up-to-dato component specific surveys.
C.
One health physics technician was assigned continuous coverage on two valve work siten simultaneously.
Thorofore, sufficient attention was not provided to both work sites even though the two work sites woro located in the same immediate vicinity.
D.
There was poor communication betwoon the health physics technician, the mechanic, and the QC inspector (all contract employons) during the job. The mechanic failed to notify the health physics technician of the nood to clean the internals of the valve body and the health physics technician failed to instruct the mechanic and the QC inspector to delay the start of work pending survey performance.
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U.S. NRC Page 3 January 25, 1991 (2) Corrective steps _taken and results achieved:
Work on CF-1B was immediately stopped by the second health physics technician upon discovery of the 25 R/hr rag used to clean the valve body internals. Additionally, all primary system component maintenance was temporarily suspended pending investigation.
Radiological conditions of CF-1B and the work area were establishei An incident debriefing which included management personnel and the Individuals involved was conducted the night of the incident.
The purpose of the debriefing was to discuss the causes and consequences of the incident and to formulate actions to prevent this, or similar incidents, from recurring in the future.
The practice of allowing work on one RWP for maintenance on multiple valves was temporarily suspended.
Component specific RWPs were generated.
The general practice of allowing one technician to routinely provide continuous coverage for more than one job location simultaneously has been discontinued.
The permission of upper icvol radiation protection management must be obtained to permit the use of one technician on two jobs for continuous coverage.
This information has been conveyed to the health physics operations staff during periodic staf f meetings.
Hochanical maintenance personnel were briefed.
the importance of clearly communicating the exact nature of work to be performed to health physics personnel, the importance of knowing rad.ological conditions of their work area before beginning work, and the potential for high radiation levels from objects or debris removed from primary systems.
The two health physics technicians directly involved in this incident received counseling regarding the' failure to perform surveys required by the procedure and the RWP.
Health physics supervisors were counseled on the inadequate job performance associated with-valve CF-1B.
Specifically, the following areas were addressed:
- 1) the need to obtain specific surveys on components and work areas prior to release for work; 2) writing.RWPs.
with specific survey data and instructions on components to be worked;
- 3) communicating adequately with the workers to ensure that all-personnel understand the specific activities to be performed; and
- 4) ensuring adequate continuous coverage is provided when the RWP specifies continuous health physics coverage.
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. U.S. NRC-Page 4 January 25, 1991 The RWP process has been evaluated and guidelines issued which address the_following:
- 1) the use of component specific up-to-date survey information for preparing job specific RWPs; 2) restricting job specific RWPs to_ components and areas with like radiological characteristics, area conditions, and job scope; 3) stipulation of worse case radiological protection requirements based on the nature und' scope of the job to be performed;
- 4) stipulation of job coverage coquirerents on the RWP to reduce reliance on the job coverage technician for determining the applicable requirements;
- 5) the requirement to attach a copy of the job specific survey used to write or revise the RWP to the posted copy of the RWP to allow workers access to information concerning the radiological conditions of their work site; and 6) specific guidance on the conduct of pre-job briefings.
A memorandum which included radiological work practice guidelines for radiation workers was distributed plant wide to convey " lessons learned" as a result of this, as well as other, events which occurred during refueling outage IR9.
. (3) Corrective steps that will be taken to prevent recurrence:
A -copy of the incident investigation will be incorporated into general
. employee training (GET) and health physics technician " lessons learned" lesson plans for training to be provided during calendar years-1991 and 1992. The lesson plan revisions will be completed by Juno 1, 1991.
(4) Date of full compliance:
Interim compliance was achieved on November 2, 1990, following the establishment of radiological conditions of CP-1B and the work area,
.the distribution of additional guidance for the preparation of RWPs, and the counseling of the health physics technicians and supervisors.
Full compliance was achieved by January 24, 1991, following the completion of briefings to Units 1 and 2 mechanical maintenance personnel and the issuance of formal additional guidance for the preparation of RWPs.
The corrective _ steps outlined in section 3, above, will provide further assurance that the lessons learned from this incident are communicated plant wide.
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