ML20097G707
| ML20097G707 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/12/1992 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206170248 | |
| Download: ML20097G707 (3) | |
Text
. _ _ _ _ _ -
GENERAL OFFICE
.m m P O. BOX 49, COLUMBUS, NEBRASKA 68602-0499
- Nebraska Public Power District "4"x%"#!%**
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r June 12, 1992 U.
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Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen
Subject:
NPPD Response to Inspection Report 50-298/92-06 (Reply to a Notice of Violation)
During an NRC inspection Londucted March 8, 1992, through April 18, 1992, one violation was issued for failure to meet the requiraments of the Special Work Permit procadure.
Following is a statement of the violation and our response thereto in accordance with 10CFR2.201.
Statement of Violation Technical Specification 6.3.4 states, in part, that radiation control procedures shall be maintained.
On February 17, 1992, licensee personnel failed to maintain radiation control procedures during entry into a heater bay, a high radiation area, to operate a system, as discussed below A.
Section VIII.C.1 of Procedure 9.1.1.4, "Special Work Permit," states, in part, that the individual in charge of the job is tesponsible to notify health physics prior to work start in a special work permit area.
Contrary to the above. a radiation control procedure was not maintained in that operations personnel entered a high radiation area to operate a plant system without prior notification to health physics.
B.
Section 8.1.4.1.c of Procedure 9.1.1.1,
" Radiation Protection at CNS",
states, in part, that the shift supervisor shall ensure that all work to be performed which involves known or potential hazards, has received review by health physics.
Contrary to the above, a radiation control procedure was not maintained in that operations personnel performed work in a high radiation area that involved potential radiological hazards and a review was not performed by health physica prior to initiation of the work.
This-is a Severity Level IV violation.
(supplement IV) (298/9206-02)
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' June 12, 1992 Page 2 Reason for violation Members of the operating crew entered the heater bay to investigate why-the-level in feedwater heaters A-3 and A-4 would not control automatically.
They discovered the air inlet filter to air operated valve CD-AOV-LCV61A (A-4 heater) had come apart causing the valve to fail open.
The Shift Supervisor, after assessing the situation, decided to take manual control of the heater levels by manually manipulating CD-Aov-LCV61A.'. The crew did not interpret this manipulation to be " Work" as described in Procedure 9.1.4, Protective Clothing (Anti-C).
The Shift Supervisor did not consider this evolution to pose a " Potential Hazard" because the evolution had been performed in the past with minimal personnel exposure and because the henter bay is part of the operator's daily.
rounds. Therefore, in his view, the health physics reviews called for in Procedure 9.1.1.1, Radiation Protection at CNS, wero not required.
In summary, the reasons for the violation were a difference in interpretation of the definition of " Work",
evolution to pose a " Potential Hazard".and the Shift Supervisor not considering this Corrective Steos and the Resultr Aehleved During a routine review of-Special Work-Permits, health physics noted an unusually high personnel exposure for several operators who made heater bay entries on February 17, 1992.
In older to determine the cause of this high exposure, a Radiological Safety Incident Report (RSIR 92-1) was generated and a multidisciplinary Root Cause Task Force was-appointed to investigate the incident.
The evaluation of this RSIR resulted in the recommendation of several action items to preclude recurrence.
Those items that have been completed are:
O Review of the existing Shift Supervisor and on-duty Health Physics technician communications technique.
O The procedural discussion of what' constitutes " Work" and what constitutes
" Tour and Inspection" has been clarified and moved from Procedure 9.1.4,-
j frotective Clothing-(Anti-C), to Procedure 9.1.2.4, Access Control-Radiological.
O The Division Manager Of Nuclear. operations has publicized " Maintaining a Questioning Attitude" by losuing a letter to all CNS personnel discussing chis event and the need for a Questioning Attitude.
In addition, discussions were held with the Shift Supervisor in charge at the time of this incident and the person providing on-shift health phycles The Division Manager Of Nuclear Operations,-as a result of these coverage.
conversations, issued a letter to the operations crew enforcing the importance.
of following procedures.
A similar letter was issued to the Radiological Department emphasizing the importance of maintaining'a questioning attitude toward unanticipated radiation exposures during plant evciniiana.
Corrective Stees Whleh Will Be Taken To Avoid Further Violations The following actions are in progress:
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U.
S. Nuclect Regulctory Commission June 12, 1992 Page 3 0
A discussion of what constitutes " Work" and what :onstitutas " Tour and s
Inspection" is being added to Procedure 2.0.1, operations Department Policy.
j 0
The Training Det ertment has been directed to perform the following A.
Incorporate this event into Industry Events training for both the operations and Radiological Departments, with emphasis on maintaining a
" Questioning Attitude.
a B.
Expedite the CNS ALARA program training currently scheduled.
C.
Upgrade the feedwater heater level control system training program.
4 Senior operations managemeat is in the process of conducting meetings with operations management and supervisory personnel (including shiit supervisors) emphasizing the importance and adherence to the questioning attitude concept.
j Date Station Operator Compliance Will Be Achieved NPPD is currently in compliance with the requiroments stated _in the violation.
The remaining corrective steps identified in the " Corrective Steos Which Will Be Taken To Avoid Further Violations" section will be completed-by August 31, 1992.
Should you have any questions concerning this matter, please contact me.
4 Sincerely, 4
h
. Horn Nu ar Power Group Manager Cooper Nuclear Station GRHacl-24B cc:
Regional Administrator U.
S. NRC - Region IV NRC Resident Inspector j
Cooper Nuclear Station i
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