ML20138F583

Responds to NRC Re Violations Noted in Insp Rept 50-309/96-14.Corrective Actions:Replaced Motor W/Motor Having Higher Capacity & Provided Verbal Communications Re Mgt Expectations on Response to Abnormalities

ML20138F583
Person / Time
Site:	Maine Yankee
Issue date:	04/25/1997
From:	Hebert J Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-309-96-14, JRH-97-100, MN-97-63, NUDOCS 9705060009
Download: ML20138F583 (3)

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MaineYankee RELI ABf,;J.ECTRICITY SINCE 1972 329 BATH ROAD + BRUNSWICK, MAINE 04011 * (207) 798-4100 ,

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April 25,1997 l

MN-97-63 JRH-97-100 l l

i UNITED STATES NUCLEAR REGULATORY COMMISSION .

Attention: Document Control Desk Washington, D.C. 20555

References:

a) License No. DPR-36 ( Docket No. 50-309 )

b) USNRC Letter to MYAPCo dated March 13,1997, Notice of Violation for NRC Inspection Report 50-309/96-14.

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Subject:

Reply to Notice of Violations Associated With NRC Inspection Report No. 50-309/96-14.

Gentlemen: ,

The attachments to this letter provides Maine Yankee's reply to the Notice of Violations contained in Reference (b). In attachments "A & B",we have restated the violations, provided our response and have addressed our actions taken and planned to prevent recurrence. Maine Yankee requested, and was granted, an additional 14 days to respond to this notice of violation. This extension had been approved by the Region through the Senior Resident Inspector.

Please contact us should you have any further questions regarding this matter.

Very truly yours, ames R. Hebert, Manager .

Licensing & Engineering Support Department JVW/mwr Attachments c: Mr. Hubert Miller t Mr. J.T. Yerokun /

Mr. D. H. Dorman ,, n g Mr. Patrick J. Dostie J M' Mr. Uldis Vanags 1 1

9705060009 970425 PDR ADOCK 05000309 G PDR, E

F V ATTACHM ENT "A" Violation "A" Technical Specification 3.13, Refueling and Fuel Consolidation Operations, requires in Part,"A.

Prior to each refueling a complete checkout shall be conducted on fuel handling cranes that will be used to handle irradiated fuel assemblies." Operations procedure 13-2, Fuel Handling in the Spent Fuel Pool, performs an operational check of the ability of the crane to raise and lower as a prerequisite to fuel movement.

Contrary to the above, on four occasions from January 7, through January 13,1997, problems were identified that invalidated this checkout. In each of these problems, the cause of the crane failure was not determined and the operability of the crane was not evaluated prior to the movement ofirradiated i fuel.

Maine Yankee Response:

Maine Yankee agrees with this violation. In the case of each of the failures Operations felt that the trouble shooting and resolution of the problem first by electrical maintenance then engineering was a adequate and that testing prior to fuel movement was adequate to prove operability. The l

reoccurrence of the problem indicated the problem was not well understood and the post failure testing was inadequate to demonstrate the problem had been corrected thus testing was inadequate

to meet the requirements of Technical Specification 3.13.

Immediate Corrective Actions:

l The immediate action which was successful in preventing the crane's circuit breaker from tripping was replacement of the motor with a motor having a higher capacity. The immediate corrective i action to address inadequate testing prior to continuing fuel moves in the Spent Fuel Pool was to provide verbal communications concerning Management's expectations on the response to abnormalities which occur during fuel moves in the spent fuel pool. This communication was given as part of a training session. Information of the circumstances of this violation and the Response to the Notice of Violation will be provided to operators who will be involved in refueling operations prior to upcoming refueling moves.

Corrective Actions Taken to Avoid Further Violation:

Longer term corrective actions will provide additional training and procedure changes as necessary to address the generic issue of functional testing and operability. 1) Changes will be made to Operations Procedure (OP) 1-200-2," EQUIPMENT OPERABILITY ASSESSMENT", to include equipment which is not safety class or QAR but has a Technical Specification or nuclear safety requirement. 2) Refueling procedures 13-2," FUEL HANDLING IN THE SPENT FUEL POOL",

13-3, " TRANSFER MACHINE AND UPENDER OPERATION", and 13-4, " REFUELING MACHINE OPERATION", will be revised to provide additional information conceming expectations for addressing off normal conditions. This will include an operability determination in accordance with (IAW) 1-200-1 ifwarranted. 3) Operators will be trained on lessons leamed from this event and the procedure changes. The procedure changes will be completed by June 01,1997.

A root cause is required on this event. Other corrective actions may be recommended from that root cause.

Full Compilance Date Full compliance was achieved on January 20,1997 when post maintenance functional testing of the l crane was satisfactorily completed in accordance with procedure 3.1.10," REFUELING SYSTEM INTERLOCK TEST", in support of Work Order 97-00284.

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ATTACilMENT "B" Violation "B"  !

Technical Specification 5.11.1, requires in pan that procedures for personnel radiation protection shall be implemented. Procedure 9-5-100, Contamination Control / Decontamination Program, Section 7.5.1, allows personnel to reach into contaminated areas for certain purposes and requires that personnel shall remove protective clothing prior to exiting contaminated areas.

Contrary to the above, on January 23,1997, a radiation worker failed to remove protective clothing <

from his hand prior to exiting the contaminated area around the high pressure safety injection pump,  !

P-14A.

Maine Yankee Response:

Maine Yankee agrees with this violation. Maine Yankee feels that the intent of the procedural step cited, the removal of"all protective clothing", refers to the situation of a worker in a full set of protective clothing fully within a contaminated area. Ilowever we agree that this step could also be applied to the situation described in the NOV. Radiation Protection management agrees that further clarification and communication of expectations was appropriate.

Maine Yankee recognizes that barring any other compensation orjustification, the repeated crossing of a contamination boundary with a gloved hand without removal of the glove or verifying it non contaminated prior to touching clean equipment is indeed a poor work practice. Although we feel that the intent of the procedure step cited is for the case of a worker in full protective clothing who has completely entered a contaminated area, we also recognize that the step could also be read to apply to the cited situation. Ilowever, the activity was performed under Radiation Protection cognizance and controls were adequate to prevent the actual spread of radioactive contamination..

s immediate Corrective Actions and Corrective Actions Taken to Avoid Further Violation:

Subsequent evaluation of this situation had determined that some programmatic improvements could be made to preclude future misinterpretations and/or inconsistencies in the application of radiological controls.

Accordingly, clarifications have been developed and communicated to the Maine Yankee Radiation Protection staff in the form of a Radiation Protection Guideline (RPG-0002). This RPG was issued on February 18,1997 and issued as Required Reading (97-033) on February 21,1997. As of April 17,1997, all Maine Yankee Technicians have signed off this Required reading.

Eull Compliance Date:

1 Full compliance was achieved on April 17,1997 when all Maine Yankee Radiation Protection Technicians had signed off the required reading of Radiation Protection Guideline (RPG-0001).

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