ML20083H458

Responds to NRC Re Violations Noted in IE Insp Repts 50-266/83-11 & 50-301/83-19.Corrective Actions:Drivers & Technicians Required to Keep Written Instructions on File & Westinghouse Health Physics Instructions Reviewed

ML20083H458
Person / Time
Site:	Point Beach
Issue date:	12/30/1983
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20083H440	List: ML20083H458
References
TAC-52693, TAC-52694, NUDOCS 8401130211
Download: ML20083H458 (4)

Text

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lHsconsin Electnc eowca couoaur 231 W. MICHIGAN, P.O. BOX 2046. MILWAUKEE, WI 53201 December 30, 1983 Mr. J. G. Keppler, Regional Administrator Office of Inspection & Enforcement, Region III U. S. NUCLEAR PEGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear-Mr. Keppler:

DOCKET NOS. 50-266 & 50-301 PESPONSE TO NBC, INSPECTION REPORT NOS. 50-266/83-11 & 50-301/83-19 POINT BEACH NUCLEAR PLANT, UNITS 1 & 2 Your letter dated November 30, 1983 forwarded Inspection Peport Nos 50-266/83-11 and 50-301/83-19 con-cerning the results of routine safety inspections conducted by Messrs. P. C. Lovendale and P. A. Paul from September 23 through November 20, 1983. Also enclosed with that letter was a Notice of Violation which discussed two items of apparent noncompliance with NFC requirements and a Notice of Deviation which discussed an apparent deviation from commitments which were made in previous correspondence with the NRC. Pursuant to the provisions of 10 CFR 2.201, Wisconsin Electric, as licensee for the Point Beach Nuclear Plant, hereby submits the following written reply to this Notice of Violation and Notice of Deviation.

The first item identified in the Notice of Violation I stated that, contrary to 49 CFR 173. 4 44 (c) , the drivers of spent fuel shipments from West Valley to Point Beach on two separate occasions were not provided with specific written instructions for maintenance of the exclusive use shipment controls.

The words " sole use" were checked off on the Radioactive Material Shipment Record includeo in the ship-ping papers sent with the shipments. In addition, begin-ning on November 13, 1983, the words "to be unloaded only by consignee" were written on the bill of lading included with the shipping paper. Our discussion with personnel at West Valley Nuclear Services indicated that they believed that these words were sufficient written instructions for maintenance of the exclusive shipment contro]. Nevertheless, to expand upon and clarify the Point Beach position, on 8401130211 840110 4 90b PDR ADOCK 05000266 G PDR NN

Mr. J. G. Keppler December 30, 1983 November 18, 1983, a copy of Point Beach Nuclear Plant form CHP-138, " Carrier / Driver Instructions for Radioactive Material -..

Shipment," was telecopied to the West Valley facility. Clear {-

enpies were later sent by mail. +

Subsequent to that date, the West Valley Nuclear Services representatives stated to us that these instruc- p-tions from Point Beach were given to the driver for the spent 1 fuel shipments from West Valley to Point Beach and the driver $

turned them in to the Tri-State office at Joplin, Missouri. @

However, the driver's instructions were not attached to the j shipping papers filed at Point Beach Nuclear Plant fnr two g West Valley shipments that arrived at Foint Beach Nuclear J Plant after November 18, 1983. Therefore compliance with the regulation could not be verified for those two shipments.

1 We have now instructed our technicians receiving 3-the shipments to obtain copies of the instructions for our (

files. All shipping papers received since December 4, 1983, J; include copies of the driver's instructions. The corrective j' action fulfills the commitments regarding the citation "

and establishes full compliance with the regulations, y 1

The second item of noncompliance identified in y the Notice of Violation concerns the licensee's failure to comply with Technical Specification 15.6.8, which requires g adhere >ce to plant procedures, during a high airborne 5-radioactive release in Unit 1 containment on November 3, }-

1933. Specifically, the citation states that the control $

room was not notified of the high airborne levels until after i the cortainment was evacuated.

4 This event occurred during plasma are cutting A=

of the Unit 1 "B" steam generator hot leg reactor cooling a piping. On November 2, 1983, the steam generator cold leg I had been successfv'_ly completed at 2150 hours0.0249 days <br />0.597 hours <br />0.00355 weeks <br />8.18075e-4 months <br />. During the cold leg cut, general area air samples exhibited no unusual

{,

or unexpected iodine airborne radioactivity. Ventilation I ducts used to draw suction directly over the cold leg cut 5 locations were repositioned to take suction directly over j the hot leg cut. The hot leg plasma arc cut wau initiated h at 0855 hours0.0099 days <br />0.238 hours <br />0.00141 weeks <br />3.253275e-4 months <br /> on November 3, 1983. At approximate]y 0920 hours0.0106 days <br />0.256 hours <br />0.00152 weeks <br />3.5006e-4 months <br />, $'

a continuous air monitcr on containment F3. 66', located next l to the "B" steam generator cubicle, alarmed. The continuous j ,

air monitor is conservatively set to alarm at 100 counts '

xbove the background ambient readinos. Health Physics tech- j nicians ilamediate ]y began to draw high volune air samples. An g announcement was made over the contractor page system for g personnel to evacuate containment. At the time of the evacu- ,

ation announcement, actual airborne concentrations were not 6 known. A general area high volume air sample extracted from 1 El. 66' was gross counted at 0935 hours0.0108 days <br />0.26 hours <br />0.00155 weeks <br />3.557675e-4 months <br />. The result exhibited ,

airborne concentrations greater than maximum permissible con- J centrations. The sample was forwarded to the PPNP chemistry y 9-

--. A

g Mr. J. G. Keppler December 30, 1983 lab for isotopic identification. A sectnd high volume air sample taken from El. 66' of containment was gross counted at approximately 0940 hours0.0109 days <br />0.261 hours <br />0.00155 weeks <br />3.5767e-4 months <br />. The results confirmed airborne concentrations above the maximum permissible concentration.

Special Order PBNP 83-06, " Westinghouse Steam Generator Peplacement Project Emergency Plan and Implementing Procedures," states that the control room will be notified of any containment general air airborne levels in excess of the maximum permissible concentration (MPC). At the time of confirmation of air concentrations in excess of MFC, all

- personnel had evacuated or were in the process of exiting containment. Health Physics supervisory personnel were actively evaluating the conditions. Preoccupation with assessment of the radiological condition and accountability of personnel delayed notification of the PBNP control room personnel. The control room was notified of the exces-sive airborne concentrations in containment at approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. Therefore, approximately 20 minutes had elapsed following confirmation of airborne concentrations in excess of 1 MPC before the control room personnel were notified.

An incident critique was conducted between WE Special Projects personnel and Westinghouse site management following the November 3, 1983, containment evacuation. Failure to notify PENP control room promptly was discussed during the critique. The requirement and importance of notifying the

. ' control room personnel of high airborne concentrations in con-tainment was reaffirmed. Craft labor superintendants were also reinstructed during a shift turnover meeting of the requirements to notify the control room personnel as required by the Westinchouse Steam Generator Peplacement Project (SGRP) Emergency Plan Imple-menting Procedures.

To avoid any further noncompliance with the Westing-house SGRP Emergency Plan Implementing Procedures, a Westing-house meno has been written and distributed to SGPP personnel reinstructing them in the requirements to notify the PBNP control room as required by the Emeraency Plan Implementing Procedures.

It is expected these corrective actions will achieve full com-pliance with the control room notification reanirements of the Westinghouse SGPP Emergency Plan Implementing Procedures.

The following is in response to the Notice of Deviation which stated that Westinghouse Health Physics Operating Instructions (HPOI's) did not receive the required review as stated in our letter to Mr. H. R. Denton, attention Mr. Robert A. Clark, dated February 22, 1983. In that letter we stated that Westinghouse anticipated adapting the health physics procedures contained in the Point Beach Health Physicc Administrative Control Policies and Procedure Manual. Deviatiers fron these procedures or health physics procedures developed by Westinghouse were to be subject to review and approval by nembers

4 Mr. J. G. Keppler Decemaer 30, 1983 of the UE Special Projects Division and the PBNP Manager's Super-visory Staff, when applicable. Our letter contained a flow chart depicting the procedure review process.

Each requested exception to e::isting procedures and neu health physics procedures developed by Westinghouse was reviewed by tite Special Projects Health Physics Coordin-ator. All of the procedural deviations and new procedures developed by Westinghouse were reviewed by the Health Physics Coordinator and forwarded to the Superintendent-EORS with

the exception of the Westinghouse Health Physics Operating

.. Instructions. The Health Physics Cperating Instructions y .

were developed to provide guidance to Westinghouse radiation exposure monitoring system (REMS) personnel. The instructions include guidance on the handling of paperwork required to support the operation of the PEMS and the actual operation of the REMS. These operating instructions were reviewed and approved by the WE Health Physics Coordinator.

The WE Health Physics Coordinator evaluated the content of these operating instructions and compared the content with existing PPNP procecures. Since there was no similar function or activity accomplished by plant health physics personnel governed by a procedure or a Health Physics Standing Order, the Health Physics Coordinator, functioning as a aroup head, classified the Westinghouse Health Physics Operating Instructions as being equivalent to PBNP Health Physics Standing Orders. In accordance 1 ,

with past practice, Health Physics Standing Orders have not required Manager's Supervisory Staff review.

The Westinghouse Health Physics Operating Instruc-tions are now being reviewed by the Superintendent-EQRS and members of PENP Chenistry & Health Physics Group. The operating

• instructions will be clasified and a determination made by January 31, 1984 whether plant Staff review and approval is required.

Any future health physics procedural deviations or new health physics procedures developed by West inghcuse will be reviewed by Special Projects personnel and wil) then be forwarded to the Superintendent-EORS for review to determine if Manager's Supervisory Staff revieu and approval is required.

The above actions are considered to be in accor-dance with commitments which were made to the NFC in our

letter to NPP dated Fehruc ry 22, 1983.

Very truly yours, Gv 4.

[O j /

C. W. Fay Vice President - Nuclear Power cc: NBC Resident Inspector