ML20073P607
| ML20073P607 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 05/15/1991 |
| From: | Beckham J GEORGIA POWER CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9105220125 | |
| Download: ML20073P607 (14) | |
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HL-1599 001540 May 15, 1991 Director, Office of Enforcement U.S. Nuclear Regulatory Commissien ATTN: Document Control Desk Washington, D.C. 20555 PLANT HATCH - UNITS 1, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENAlli Gentlemen:
In response to your letter of April 15, 1991, and in accordance with the provisions of 10 CFR 2.201, Georgia Power Company is providing the enclosed response to the Notice of Violation associated with NRC Inspection Report 91-05.
A copy of this response is being provided to NRC Region 11 for review, in the enclosure, a transcription of the NRC violation precedes GPC's response.
in addition to the enclosure, a check in the amount of Fifty Thousand Dollars ($50,000) is enclosed in response to the civil penalty.
Sincerely,
'h/
[J.T.Beckham,Jr.
JKB/cr Enclosures cc:
(See next page.)
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Geolgi;1 Power U.S. Nuclear Regulatory Commission May 15, 1991 Page Two cc: Georaia Power Cqmpan.y Mr. H. L. Sumner, General Manager - Nuclear Plant Mr. J. D. Heidt, Manager Engineering and Licensing - Hatch NORMS U.S. Nuclear Reaulatory Commission. Washinoton. D.C.
Mr. K. Jabbour, Licensing Project Manager - Hatch U.S. Nuclear Reaulatory Commission. Reaion 11 Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident inspector - Hatch 700715
ENCLOSURE 1 PLANT HATCH - UNITS 1 AND 2 NRC DOCKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 VIOLATION 91-05-01 AND GPC RESPONSE VIOLATION 91-05-01
" Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Paragraph 1.b of Appendix A of Regulatory Guide 1.33 states that the licensee should have procedures that establish the authorities and responsibilities for safe operation.
Licensee Administrative Control Procedure, Plant Operations, 30AC-0PS-003-0S, Revision 10, dated August 31, 1990, states in step 8.2.4 that no activity will be performed in the Main Control Room that might affect operations unless the Shift Supervisor and Operator approve such activities.
Contrary to the above requirements, on February 11, 1991, an individual operated the TIPS from the Main Control Room without the approval of the Shift Supervisor and Operator.
This is a Severity Level III violation (Supplements I and IV).
Civil Penalty - $50,000" Response to Violation 91-05-01 Admission or denial of violation:
GPC admits a procedure violation occurred.
Specifically, procedure 42CC-ERP-015-0S, "00-1 and 00-2 NUMAC TIP OPERATION,"
steps 7.2.1 and 7.2.2, were not performed correctly.
GPC maintains that the unauthorized traversing incore probe (TIP) operation, which occurred on February 11, 1991, did not create either a substantial exposure or the substantial potential for significant personnel exposure.
The event was identified by GPC, thoroughly investigated by GPC, and evaluated and determined not to represent a reportable condition. As described in the Enforcement Conference, Health Physics (HP) personnel used approved and appropriate procedures to perform the decontamination surveys.
Additionally, the HP personnel involved in this event had been trained to perform surveys by alternating dose rate readings and samples.
Both personnel training and procedures provide necessary and sufficient barriers and protection to prevent a significant personnel exposure when considering hypothetical entries into the TIP room concurrent with unauthorized TIP operation.
l HL-1599 El-1 1.
ENCLOSURE 1 (Continued)
VIOLATION 91-05-01 AND GPC RESPCNSE GPC does not understand the basis for the NRC's determination that a substantial potential for overexposure existed.
During the Enforcement Conference, the NRC stated that GPC's non-reportability determination of the event which concluded that no substantial potential existed was not in question.
- Further, the NRC's belief that personnel could have been performing work in the area and be exposed to very high dose rates, creating a substantial potential for overexposure, is based on an NRC inspector's observation of "a
survey" performed by an HP Supervisor.
- However, the observation was not related to a survey and was, in fact, performed for a different purpose during a later time pariod in which the TIP machines were physically tagged out of service.
Based on GPC's investigations of the inspector's observations, the following is the situation that occurred.
The subject survey was allegedly performed without the HP Supervisor having continuous access to the dose rate meter, thereby eliminating the capability to rapidly determine changing radiological conditions. The noted observation appears to refer to the activity wherein an HP supervisor, accompanied by an NRC inspector, was measuring distances from the TIP room door to various pieces of equipment for the ourpose of verifying GPC's dose rate calculations.
During this activity, no actual entry into the TIP room was made; however, the TIP room door was unlocked and opened in order to perform the measurements from the door frame. As stated, the purpose was to obtain measured distances, not to perform a room dose rate and contamination survey.
The NRC inspector's observation actually refers to when the HP supervisor was removing the door key from his pocket in order to unlock the TIP room door in order to make the above stated measurements.
Inspection Report 91-05 references an NRC inspector's belief concerning the performance of a room survey without continuous access to a dose rate meter. This belief, which was based on an interview with the HP Technician who performed the predecontamination survey of the Unit 1 TIP room, is incorrect.
The inspection report states,
... an NRC inspector observed a Health Physics Supervisor perform a radiation survey first and then perform a task after putting the meter down." The inspector apparently misunderstood the discussion with the HP Technician, because the survey was performed in a manner consistent with the approved method.
Compliance with approved procedures and training under various scenarios is additionally ensured given the high-radiation area access controls applicable to the TIP rooms.
At Plant Hatch, a color-coded key is used to alert employees of the level of potential hazard to be encountered upon entering a specific area. Orange-tagged keys are used to indicate areas where very high radiation levels may exist and/or radiological conditions l
HL-1599 El-2 l
ENCLOSURE 1 (Continued)
VIOLATION 91-05-01 AND GPC RESPONSL may undergo significant, rapid change.
Procedure 62RP-RAD-016-0S designates the Unit I and Unit 2 TIP rooms as orange-tagged key areas. The only other orange-tagged key area at Plant Hatch is the Clean-Up Phase Separator Tank room.
Given the TIP room classification, it is reasonable to conclude personnel possess, at all times, a heightened awareness for compliance with approved methods and good radiological practices when entering the orange-tagged areas.
In a further attempt to validate the position that a substantial potential for overexposure did not exist, GPC developed a probabilistic evaluation that considered hypothetical overexposure scenarios.
The analysis considered the following two assumptions:
1.
Personnel are preparing to enter the TIP room with TIP movement in progress or about to commence.
2.
Personnel are preparing to enter the TIP room with TIP movement in progress or about to commence, Main Control Room communications are
- failed, and the TIP is more likely to be stopped in the room outside the shield.
Additional assumptions regarding the failure to take dose rate readings prior to entry, and/or the failure to hear TIP or ball valve operation, were input into the evaluation. As discussed in the Enforcement Conference held on March 14, 1991, the results confirmed that no credible, substantial potential for overexposure existed.
Reason for violation:
i The event involved two different work activities.
In the first work-activity, the individuals involved were in the process of troubleshooting an intermittent problem with TIP reading input to the process computer.
The procedural notifications involving this work had been made earlier in the day.
Prior to 11:00 CST on 2/11/91, werk was temporarily susoended to begin an activity involving the Unit 2 rod worth minimizer (RWM).
The vendor technician resumed work on the process computer interface problem incorrectly and assuming earlier procedural notifications were still in effect.
This assumption was incorrect because the Reactor Engineer had informed Operations personnel that they were leaving for lunch and, j
consequently, TIP movement activities were suspended.
The second activity involved a predecontamination survey of the Unit 1 TIP i
room.
This activity was unrelated to the TIP computer interface problem.
I The HP technician that was to perform the predecontamination survey l
correctly notified the Operations personnel in the control room.
Operations personnel were aware that the Reactor Engineer and STA had not returned from lunch and, therefore, gave HP permission to perform the survey.
l HL-1599 El-3
ENCLOSURE 1 (Continued)
VIOLATION 91-05-01 AND GPC RESPONSE Operation of the TIP, without prior notification of the Shift Supervisor and Health Physics, was caused by cognitive personnel error on the part of the vendor technician.
It should be noted that prior to the event, this individual successfully completed and passed the General Employee Training course which provided detailed instruction on the prohibition of equipment manipulations unless specifically instructed by Operations or appropriate GPC personnel to do so.
The individual operated the TIPS in violation of existing administrative controls.
Procedure 42CC-ERP-015-0S, "00-1 and 00-2 NUMAC TIP Operation,"
permits the shift technical advisor, or a re%ctor engineer, to operate the TIP.
The technician did not meet these qualifications and, therefore, should not have independently operated the TIP. As a result, control of potential TIP room entry was not adequately coordinated with TIP movement.
A contributing cause for the inadequate communications between the involved parties was a less-than-adequate t,ging and clearance mechanism for ensuring restricted TIP operation while personnel enter the TIP room.
Corrective steos which have been taken and results achieved:
1.
The vendor technician has been disciplined regarding the significance of his actions and the requirements for strict procedural adherence.
2.
In order to assure communications regarding restricted TIP operation during personnel access into the TIP room, an operating order has been issued to require the access doors be tagged with a clearance while TIPS are in operation.
Alternatively, the TIP panel will be tagged with a clearance while the access doors are in use.
3.
Appropriate procedures have been revised to require a separate Radiation Work Permit requiring digital alarming dosimeters for rooms with orange-tagged keys.
Corrective steos which will be taken to avoid further violations:
The appropriate Operations and Health Physics procedures will be revised to incorporate the requirements of the operating order.
In addition, the Operations procedures governing operation of the Unit I and Unit 2 TIP systems will be revised to require that the keys needed to operate the TIPS be removed and the TIPS be placed in an inoperable condition when the TIPS are not in use (following a 24-hour decay time after use).
The keys needed to operate the TIPS will be controlled such that Shift Supervisor approval will be necessary to obtain them.
HL-1599 El-4 J
ENCLOSURE 1 (Continued)
VIOLATION 91-05-01 AND GPC RESPONSE Health Physics procedures governing high radiation area access control will be revised to require personnel requiring access to the TIP room go to the Main Control Room to verify a clearance has been placed on the applicable TIP system, obtain a subclearance on this clearance in order to prevent its being released before personnel exit the TIP room, and obtain the TIP keys from the Main Control Room with the permission of the Shift Supervisor.
Personnel then will be required to exchange the TIP keys for the TIP room door keys controlled by Health Physics.
The necessary procedure revisions will be effective by 6/15/91.
Until the revisions are effective, the operating order, previously described, will remain in place.
Date when full comoliance will be achieved:
Plant Hatch is presently in full :ompliance with the applicable regulations and procedural requirements regarding the control of equipment manipulations in the control room.
HL-1599 El-5 j
ENCLOSURE 2 PLANT HATCH - UNITS 1 AND 2 NRC 00CKETS 50-321 AND 50-366 OPERATING LICENSES DPR-57 AND NPF-5 yl0LATION 91-05-02 AND GPC RESPONSE VIOLATION 91-05_Q1
" Technical Specification 6.12.1 requires that in lieu of the " control device" or " alarm signal" required by " Paragraph 20.203(c)(2) of 10 CFR 20,"
each high radiation area in which the intensity of the radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of a Radiation Work Permit (RWP).
any individual or group of individuals permitted to enter each such areas shall be provided with or accompanied by one of the following:
1.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
2.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated mse is received.
Entry into such areas with this monitoring device Lay be made after the dose rate level in the area has been established and personnel have been made knowledgeable rf them.
3.
An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device.
This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the facility Health Physics (HP) supervision in the RWP.
Contrary to the above, in the following examples, individuals entered a high radiation area without either a radiation monitoring device which continuously indicated the radiation dose rate, or a radiation monitoring device which continuously integrated the radiation dose rate in the area and alarmed when a preset dose rate was received, or an individual qualified in radiation protection procedures equipped with a radiation dose rate monitoring device:
(a) On August 29, 1990, a maintenance mechanic and a carpenter entered the Unit 2, Fuel Pool Cooling Heat Exchanger Room.
(b) On November 9, 1990, two maintenance workers entered the Unit 1 Reactor Building hallway near the Fuel Pool Heat Exchanger Demineralizer Panel.
This is a Severity Level IV violation (Supplement IV)."
HL-1599 E2-1
I' ENCLO W c!, @
inued)
VIOLATION Mc h ;,e pearance of the door for mechanical ability to prevent entry without tie use of a key, 2.
Operation and tightness of the outer door knob.
3.
Operation and tightness of the inner door knob.
4.
Ensuring the door will unlock using the inner door knob.
5.
Ensuring the door locking plungers move in and out freely with use of the inner door knob.
6.
Ensuring the plunger plate and door jamb strike plate are secure and all screws are intact.
7.
Ensuring the hydraulic door closing mechanism is functioning properly, if applicable.
8.
Ensuring the door will lock without use of the key.
HL-1599 E3-2
ENCLOSURE 3 (Continued)
VIOLA 110N 91-05-03 AND GPC RESPONSE 9.
Ensuring the door does not bind with door frame when closing.
- 10. Ensuring the cover is in place covering plunger mechanism.
Doors that open inward do not need a plunger cover if the door frame prevents tampering.
- 11. Ensuring the wire mesh type doors have upper and lower peard plates installed.
Renon for violation:
These events were caused by a failure of personnel to ensure the subject doors were properly closed and locked after unlocking the doors to perform their duties. As noted previously, mechanical problems with the doors have contributed to these events.
Corrective steqs which have been taken and results achieved:
As a result of these events, form HPX-0537, Key Sign Out form, from procedure 62RP-RAD-016-05, "High Radiation Area Access Control," has been revised.
A signature block and a note were added to the form.
The signature block serves to document, by signature of the person receiving the key, that he/she has read and understands the following added note:
By signing out this High Radiation Area Key, I understand that I am responsible to ensure the door is locked each time 1 enter or exit the door.
I understand if the door or any door for the area is found unlocked and I was the last person to sign out the key then I will be held responsible for the 10 CfR 20 and Technical Specification High Radiation Area Control Violation.
By virtue of this form revision, HP technicians who sign out keys used to access high-radiation area doors are reminded continuously and immediately of their responsibility to ensure high-radiation area doors are locked and the consequences for failure to do so.
I HL-1599 E3-3 i
U4 CLOSURE 3 (Continued) y101A110N 91-05-03 AND GPC RESP 0fiS[
Corrective sini_which will be t1LCIL.12_LYpid furthin.ylglillent:
GPC is in the process of evaluating improvements to the eatertal condition and/or design of the high-radiation area doors.
Upgrades or replacements, i.e.,
improved iocksets,
- frames, and doors, will be completed, as appropriate, by 12/31/92.
This schedule is dependent upon delivery schedules for replacement components, as many of the doors are special orders.
Qate when full comoliage will be achieved:
Plant Hatch presently is in full compliance with appitcable regulations and procedural requirements regarding the control of high radiation area doors.
HL-1599 E3-4
.