ML20097D653
| ML20097D653 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/01/1992 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206110070 | |
| Download: ML20097D653 (9) | |
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Duke hurn Company MS nTKW6 Catawba Nudear Generation Department
. Yke President 4300 Concord hbad (8031831-3205 0f(ke 1prk, SC29715 '
(803)S313426 h t DUKEPOWER
-June 1,'1992 U.S.
Nuclear' Regulatory Commission ATTN: Docenent Control Desk Washington, D.C.
20555
Subject:
Catawba Nuclear Station Docket Nos. 50-413 and 50-414 Reply to a Notice of Violation NRC _ Inspection Report 410 /'22-09 and 50-414 /92-09 Atached is Duke' Power's response.to the two (2) Level IV violations cited in the Notice of Violation by subject Inspection Report dated
.May 4, 1992.
The two. (2): violations ' involved lack of procedural compliance which had'the potential to' lead to personnel overexposure and the spread of contamination, as' well as inadequate communication and inattention to detail leading to a system alignment deficiency in the Nuclear Service-Water System.
Very truly yours, bb OC M.S. Tuckman Attachments 1
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U.S. Nuclear Regulatory Commission June' 1, 1992
'Page 2 xc:
S.D.
Ebneter Regional Administrator, Region II R.E.
Martin, ONRR W.T.
Orders Senior Resident Inspector
U.S.
Nuclear Regulatory Commision June' 1, 1992
'Page 3 bxc:
R.L.
Gill R.O.
Sharpe M.E.
Patrick A.V.
Carr NCMPA-1 NCEMC SREC PMPA Group File:.CN-815.01 (92-09)
Document Control: 815.01 I
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DUKE POWER COMPAU*l
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REPLY TO A NOTICE OF VIOLATION 413,414/92-09-01 3.
On April 1,
- 1992, during the performance of PT/0/A/4400/01.I ano PT/0/A/4400/01M, Safety personnel failed to we.sh the fire extinguisher in Roor 217 of the Auxiliary Building even though a marker wc s used to initial and date the inspection tag.
This is a Severity Level IV violation.
RESPONSE
1.
Reason For Violation Both Safety technicians f ailed to proceed to the nearest whole body monitor upon exiting a
RCZ due to inadequate proficiency / lack of attention to detail regarding Station Directive 3.8.3 (Contamination Prevention,
- Control, a: d Decontamination Responsibilities). Also, while one of the Safety technicians was performing a hand frisk of hand-held equipment utilized inside the RCZ, he was distracted by an alarm on a nearby whole body monitor. This contributed to unintentionally performing an inadequate frisk of the hand held items.
The Standing Radiation Work Permit (SRWP) was not read as required because the Safety technician, planning to enter the RCZ, assumed that the dress requirements were the same as the previous month's inspection. The other Safety technician, not planning to enter the RCZ, assumed that his peer had properly read and understood the SRWP.
Both Safety techn!-ians were not conscientious to fol-lowing procedures regarding the proper wrapping and bagging of potentially contaminated equipment, upon exiting the RCZ (Station Directive 3.8.8, Radiological Work Practices, Section 4.2.2).
The fire extinguisher in Room 217 was not weighed per PT/0/A/4400/011 ( Annual Maintenance and Inspection of Portable Fire Extinguishers) because the Safety technician performing the inspection perceived that weighing the extinguisher could cause an airborne contamination problem. Plans were to weigh the fire extinguisher following a discussion with Radiation Protection personnel regarding the potential for airborne contamination.
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413,414/92-09-01 Tect ' cal Specification 6.8.1 requires in part that written pro-res be established, implemented and laaintained coveriag the uut'tities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, including:
Station Directive (SD) 3.8.3, Contamination Prevention, Control, and Decentamination Responsibilities, Section 4.4, requires personnel exiting contaminated Radiation Control Zones (RCZ) perform hand and foot contamination check with a hand held frisker prior to leaving the local area and then proceed to the contaminated side of the change room to perform 4
a whole body survey.
Sta*! m Directive 3.8 8. Radiological Work Practices, Section 2.1.3, requires all employees to be responsible for reading and complying with posted Standing Radiation Work Permits q
(SRWP).
In addition, Section 4.4.2, ir.atructs personnel who have been in a contaminated RCZ to wr?
materials upon exiting to prevent the spread of contami m ion.
L Procedures PT/0/A/4400/01I, Annual Maintenance and Inspection of Portable Fire Extinguishers, and PT/0/A/4400/01M, Moni.hly 45 Visual inspection of Fire Hose Stations,
- require, in the Limits and Precautions sections, that plant fire e::tinguishers be weighed to ensure their reliable performance.
Contrary to the above:
1.
On April 1, 1992, two Safety personnel failed to perform a hand and foot frisk or whole body survey upon exiting a contaminated RCZ. This contributed to one of the individuals exiting the Radiation Control Area with an undetected hot particle on his skin resultir.g in a calculated overexposure of 29.9 Ron 2.
On April 1,
- 1992, two Safety perscnnel entered a
contaminated RCZ without reading or complying with the associated SRWP and upon exitilig the RCZ, failed to properly bag material be.ng removed.
This had the potential to contribute to the spread of contamination.
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DUKE POWER COMPANY
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REPLY TO A NOTICE OF VIOLATION 413,414/90*J9-01 2.
Corrective-Actions Taken and Results Achieved On April 8, 1992, and May 13, 1992, both Safety technicians comoleted additional General Emoloyee Training (Unescorted Access) on radiation protectimi to enhance tueir awareness of radiological work practices.
On April 2,
1992, all Safety Department personnel received training on Ste'Jion Directives 3.3.3 (Contamination Preventien, Control, and Decontamination Responsibilities),
3.8.8 (Radiological Work Practices), and participated in a group discussion regarding proper procedural adherence.
On April 3,
1992, the subject fire extinguisher in Room 217 which was not initially weighed per PT/0/A/4403/01I on April 1,
1992, was found to be contaminated by Radiation Protection personnel and was decontaminated. On April 6,
1992, this extinguisher was weighed per PT/0/A/4400/011 and was verified to meet the acceptance criteria as specified by the procedure.
on May 20, 1992, a small article monitor (SAM) was placed in-service at tho Materinls Access Poi.it (MAP) which will automatically monitor Le nd held items for contam.ination prior to exit.
3.
Correctj.ve Actions to be Taker} to Avoid Further ViolatioAs The Safety Group is scheduled to receive annual crew demonstration on radiation protection practices utilizing a mock-up which reflects actuti plant conditions.
Scheduled training dates are June 16 and June 23, 1992.
Additional emphasis on contamination issues will be provided to station personnel during annual radiation protection training.
The initial completion of this training for all station personnel is scheduled to be completed by November 1, 1993.
4.
p_ ate of Ful_1 Compliance Duke Power will be in full compliance on June 23, 1992.
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/414, 92-09-03 Technical Specification 6.8.1 requires in part that written procedures be established, implemented and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, including:
Operations Management Procedure (OMP) 2-18, Tagout Removal and Restoration *R&R) Procedure, Section.3.2, requires that the R&R record sheets shall be used by operations personnel to provide information to be used to ensure plant conditions are l
maintained as necessary to safely perform work.
Operations P.anagement Procedure (OMP) 1-8, Authot. tty and Redponsibilities of Licensed Reactor Operators and Licensed Senior Reactor Operators, requires that the Control Room SRO keep himself and his staff informed c.f all evolut!ons that may affect the operation of the plant.
Contrary to the above:
1.
On March 17, 1992, R&R 02-556, the block tagout for controlling maintenance activities on the Nuclear Service Water (RN) System, was inadequate in that it failed to provide steps or cautions to ensure proper RN valve alignments were performed.
This resulted in the operation of the 2A RN Pump without adequate minimum flow protection.
2.
On March 17, 1992, the Control Room SRO failed to follow OMP 1-8, in that he did not adequately inform his staff of the necessary plant alignment to support a plant evolution involving the RN System that led to the 2A RN Pump not having adequate minimum flow protection.
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/414, 92-09-03
RESPONSE
1.
B_9_ason For V(9bGjpp This incident is attributable to Management Deficiency.
One Management Deficiency existed due to the lack of a task specific document.
During this evolution, three separate work documents were used to perform this task.
Two other Management Deficiencies existed due to less than adequate verbal instructions and insufficient supervision.
The Shift Supervisor did not communicate the complete work package with all shift personnel, therefore, the information available to the shift was in several fragments.
Also, the Control Room SRO and Shift Supervisor were occupied with a large number of TSAIL (Technical Specification Action Item Log) entries required for this evolution, therefore, they were not available to the control room staff to assist in the work activity.
2.
Corrective Actions Taken and Results Achieved Operations Management issued a communication package directing shift management to include all shift personnel in job briefings
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for major work activities. Also, Operations Management spoke with each shift concerning this incident to reinforce management's expectations for thorough communications and the role / responsibilities of the Control Room SRO. The communication package and shift briefings were completed April 28, 1992.
Since the communication packages have been put in place and the shift briefings have been held, no additional problems with thin type of evolution have been noted.
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413/414, 92-09-03 3.
Corrective Actions to be Taken to Avoid Further violationg a)
Operations will revise OP/0/A/6400/06C to incorporate the required equipment isolation / alignments necessary for this activity by August 1, 1992.
b)
Effective June 1,
- 1992, it will be standard practice to develop tailgate packages for major work activities that outline the scope of work, required _ procedure alignments, affected Technical Specifications and other special precautions needed.
4.
p_ ate of Full Compliance Duke Power will be in full compliance August 1, 1992.
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