ML20096G467
| ML20096G467 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/16/1996 |
| From: | Mueller J NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| NLS960002, NUDOCS 9601250187 | |
| Download: ML20096G467 (6) | |
Text
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COOPER NUCLEAR STATON
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P.O. BOX 90, BROWNVLLE NEBRASKA 84321
,Eamne.n Nebraska Pubh.c Power Distn. t rAx -
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NLS960002 January 16, 1996 Director, Office of Enforcement U.
S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555-0001 Gentlemen:
Subject:
Reply to a Notice of Violation; NRC Inspection Report No. 50-298/95-16; Cooper Nuclear Station, NRC Docket 50-298, DPR-46
Reference:
Letter from Mr. T.
P. Gwynn (USNRC) to Mr. G. R. Horn (NPPD),
dated December 15, 1995, NRC Inspection Report 50-298/95-16 and Notice of Violation.
This letter, including Attachment 1, constitutes Nebraska Public Power District's (the District's) reply to the referenced Notice cf Violation (NOV) in accordance with 10 CFR 2.201.
Inspection Report 50-298/95-16 documented 1
the results of an NRC inspection conducted from November 6-9, 1995, of the radiation protection program during the Cooper Nuclear Station (CNS) 1995 refueling outage.
The District admits to the violation and has completed all j
corrective actions that are necessary to return Cooper Nuclear Station (CNS) j to full compliance with regard to 10CFR50 Appendix B Criterion V.
The District notes that an item discussed in Section 2.5.3 of Attachment 2 of the referenced letter requires clarification. The text, it was stated that they were aware of this (no radiological ir.formational postings in the drywell] and were in the process of purchasing and installing green flashing lights, which would indicate areas of lower dose,"
was the result of a misunderstanding between the inspector and the Radiological Manager. The Radiological Manager was actually referring to placing such devices in the RCA outside the drywell for the stated purpose.
i We apologize for any confusion in this area.
Should you have any questions concerning this matter, please contact ny office.
Sincerely,
/
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M H. Muellf: :
S te Manager c
CCT 9601250107 960116
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Regional Administrator USNRC - Region IV Senior Project Manager USNRC - NRR Project Directorate IV-1 Senior Resident Inspector USNRC - Cooper Nuclear Station NPG Distribution l
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to NLS960002 P&ge 1 of 3 REPLY TO DECEMBER 15, 1995, NOTICE OF VIOLATION COOPER NUCLEAR STATION NRC DOCKET NO. 50-298,-LICENSE DPR-46 During NRC inspection activities conducted from November 6-9, 1995, one violation of NRC requirements was identified. The particular violation and the District's reply are set forth below:
" Criterion V of Appendix B to 10 CFR Part 50 states, in part, that activities affecting quality shall be prescribed by documented procedures, of a type appropriate to the circn?matances, and shall be accomplished in accordance with these procedures.
[1]
Procedure NTI 03, ' Revision to Training Materials, " Revision 16.0, states, in part, that revisions which modify the conte.sc of training materials shall be documented on a revision / change summary fom.
Additionally, Procedure NTI 03 states that the lead instructor shall review the draft revisions and changes, initial the revision / change summary fom, and fazvard it to the appropriate nuclear t raining supervisor for review and approval.
[2]
Procedure 9.3.4.8,
'Eberline Personnel Contamination Monitor Nodel PCN-1B, " Revision 5, Section 8.1. 4, sta tes, 'If the monitor alatus after recount, contact Radiological Protection for further evalua tion. '
'[3]
Procedure 9.1.6,
' Personnel Contamination," Revision 20.2, Section 6.1, sta tes, in part, 'An entry on CNS RP-8, POf Alarm Log, is required when two consecut:ive POf-1 alarms occur. " Procedure CNS RP-8, 'PCN Alaza Log,' requires such items to be recorded as: date and time of the contamination, name of the individual and location of the work area, and initial and final contamination, name of the individual and location of the work area, and initial and final contamination levels.
Contrary to the above,
[1]
On November 8, 1995, the inspector identified that in September 1995, training material lesson plans and site-specific radiation protection test material were changed without documenting the revisions on a revision / change sumary form, and without having the review of the lead instructor and without review and approval of the appropriate nuclear training supervisor.
[2]
On November 6, 1995, the inspector identified that two workers failed to follow Procedure 9.3.4.8 and Radiation Worker Training Student Text, in that, the workers did not contact radiation protection after alarming the personnel contamination monitor.
[3]
On November 6, 1995, the inspector identified that a radiation protection technician failed to follow Procedure 9.1.6, in that, the technician did not obtain and record infozmation such as: date and time of the contamination, name of the individual and location of the work area, and initial and final contamination levels. "
Admission or Denial to Violation The District admits the violation.
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Attachm:nt 1 to NLS360002 Page 2 of 3 Reasons for Violation 1.
This example is attributable to inappropriate assumptions and personnel error in failure to follow procedure.
The Contract Radiological Protection (RP) technicians were trained using the current revised RP procedures and updated exam questions. While not presented to the classes, the student text should have been updated in accordance with NTI-03.
The instructor was aware of NTI-03 requirements but incorrectly assumed without verifying that there was not an associated student text.
2.
This example occurred due to the mind set of the workers and personnel error in failure to follow procedure.
The workers were aware of procedural requirements but elected not to notify RP personnel, who were in the process of conducting shift turnover.
The workers felt they knew how to respond to the situation since they were involved with PCM alarms several times previously. This was outside of management expectations.
3.
This example resulted from personnel error in failing to follow procedure.
Prior to the identified example, RP Shop Guide #14 was distributed that stated, "An individual who alarms a PCM two consecutive times is considered contaminated," and " Release criteria and personnel decontamination must be performed in accordance with procedure 9.1.6,
' Personnel Contamination,' excluding Radon suspected contamination." RP personnel incorrectly assumed from RP Shop Guide #14 that if a worker alarmed the PCM once, they could decon the worker and after a successful second attempt the worker would not be considered contaminated.
This was outside of management expectations and the correct log entries should have been made in accordance with Procedure 9.1.6.
Corrective Steps Taken and the Results Achieved 1.
Training supervision counseled the instructor and lead instructor on procedural compliance and attention to detail. Training department personnel were informed of lessons learned from this violation during a training department staff meeting. Further, the contract RP training lesson plan was revised to delete the student text and replace it with the appropriate procedures. No additional actions are required to address this example.
2.
Meetings were held with CNS coordinators, turbine floor contract workers, and all RP staff to further communicate CNS expectations regarding RP procedures and work practices.
Additional RP staff was added to the turbine floor access / egress point, where this example occurred, to improve RP coverage at shift turnover.
3.
Surveys of the turbine deck area v..re completed to verify contamination levels below the minimum threshold and the PCM alarm log was filled out.
The RP staff was counseled on adherence to CNS procedure 9.1.6.
to NLS'960002 Page 3 of 3 i
Corrective Steps That Will Be Taken to Avoid Further Violations 1
The RP staff will conduct interviews with plant workers to ensure worker understanding of radiological procedural controls.
Lessons learned from these interviews will be incorporated into lesson plans as appropriate and be reviewed by the General Orientation Training effectiveness review committee.
l A CNS General Orientation Training training effectiveness review committee is evaluating the need for additional or enhanced explanations to workers on RP equipment alarms and employee responsibilities concerning these alarms.
The RP training effectiveness review committee is evaluating the need for additional training for RP personnel on their responses to alarms.
Date When Full Compliance Will Be Achieved The District is in full compliance with the requirements of 10 CFR Part 50, Appendix B,
Criterion V with respect to the identified procedure violations.
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LIST OF WRC COMMITMENTS ATTACHMENT 3 i
a-Correspondence No:NLS960002 The following table identifies those actions committed to by the District in this document.
Any other actions discussed in the submittal represent intended or planned actions by the District They are described to the NRC for the NRC's information and are not regulatory commitmen".s.
Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.
COMMITMENT COMMITTED DATE OR OUTAGE A CNS General Orientation Training training effectiveness review committee is evaluating the need for additional or enhanced explanations on radiological equipment alarms and employee responsibilities concerning these alarms.
The RP training effectiveness review committee is evaluating the need for additional training for RP personnel on their responses to alarms.
The RP staff will conduct interviews with plant workers to ensure worker understanding of radiological procedural controls.
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PROCEDURE NUMBER 0.42 REVISION NUMBER 0 PAGE 12 OF 16