ML20195D192
| ML20195D192 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/17/1988 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-88-059, CON-NRC-88-59 VPNPD-88-327, NUDOCS 8806230062 | |
| Download: ML20195D192 (4) | |
Text
Wisconsin Electnc POWER COMPANY 231 w Mchgon. Po, Box 2046. Maosee. m 53201 (414)221 2345 VPNPD-88-327 NRC-88-059 June 17, 1988 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station Pl-137 Washington, D.
C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 INSPECTION REPORT 50-266/88013(DRSS);
50-301/88012(DRSS) - VIOLATION 266-88013-02 POINT BEACH NUCLEAR PLANT This is in response to your letter dated May 18, 1988 regarding inspections conducted during the period April 18 through 22, 1988 of activities at Point Beach Nuclear Plant.
The inspection report identified a violation of approv.a plant procedures.
The violation identified involved nonconformance to radiological area posting requirements as delineated in procedure HP 3.2, "Posting of Radiological Areas".
The violation occurred during initial refueling activities conducted during our recently completed Unit i refueling outage.
VIOLA'.? ION
SUMMARY
The violation identified in the inspection report resulted from circumstances associated with improper posting and control of transient radiation areas while performing fuel assembly transfers.
Nonconformance to provisions of PBNP procedure HP 3.2 occurred during the transfer of fuel assemblies on April 19 and 20, 1988.
Prior to fuel movement on April 19, 1988, Health Physics Standing Order (HPSO) 34, "Fuel Movement," was completed by plant Health Physics personnel.
HPSO 34 specifically delineates those areas in containment and the auxiliary building which require radiation postings or physical barriers to prevent personnel access to transient radiation areas created during fuel movement.
The posting and barricading requirements in HPSO 34 were conservatively determined based upon past refueling outage survey data.
The requirements delineated in HPSO 34 have proven successful in past outages for providing positive control of transient dose rate areas created during fuel assembly transfers.
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RESPONSE TO NRC NOTICE OF VIOLATION June 16, 1988 Page 2 l
When fuel is moved, radiation emanates from the transfer canal through an approximate 2-inch gap between the containment wall and the El. 66' containment floor, creating a transient dose rate on El. 66' of containment.
Dose rates of up to 6000 millirem per hour are observed for approximately 10 seconds as the fuel assembly is transferred.through the transfer canal.
The transient high dose rate area is restricted to a small area immediately adjacent to the containment wall, which is generally not occupied.
In accordance with procedure HP 3.2, the transient dose rate area on El. 66' was posted, roped off, and a flashing red light installed to prevent entry to the area prior to fuel movement on the merning of April 19, 1988.
The night shift refueling supervisor regarded the flashing red light as a distraction and suggested the red flashing light be removed.
A Health Physics technologist removed the flashing red light from service and expanded the rope barrier to provide better access control of the area.
During an inspection of the containment refueling floor the following morning (April 20, 1988), the procedurally required flashing red light was discovered inoperative.
During the time j
the red light was not operating, fewer than ten irradiated fuel asF9mblies P9fe sent through the fuel transfer system.
In response to this deficiency, the adequacy of radiological postings and physical barriers used to control access to all areas that may be affected by fuel movement was reviewed.
1 To facil. tate extensive surveys to verify posting and barrier 2
adequacy, a fuel assembly was held stationary in the transfer canal under controlled conditions.
Holding the assembly stationary at various positions in the transfer tube permitted a careful verification of previously posted and barricaded areas.
Additional surveys did however identify two areas in the auxiliary building with transient radiation fields in excess of 100 millirem per hour that were not previously identified or posted.
These two additional areas were identified on the El. 46' and 66' of the auxiliary building adjacent to the spent fuel pool.
CORRECTIVE ACTIONS TAKEN The two areas identified in the auxiliary building that previously had not been controlled as transient dose rate areas in excess of 100 millirem per hour were immediately posted and controlled in accordance with procedure HP 3.2.
This was accomplished by expanding controlled boundaries that had previously been positioned adjacent to these areas.
-. - - -. ~
RESPONSE TO NRC NOTICE OF VIOLATION June 16, 1988 Page 3 The transient high radiation field area created on the El. 66' of containment was attenuated by the installation of temporary lead shielding in the gap between the containment wall and the refueling elevation floor.
This shielding significantly reduced the transient dose rates and eliminated-the need for high rad area controls, including the flashing red light, during the remainder of the Unit 1 Spring outage refueling activities.
An informational session has been conducted with Health Physics staff members to discuss the control and posting deficiencies associated with this event.
Specifically, the requirements of Technical Specification 15. 6.11, "Radiation Protection Program,"
and procedure HP 3.2 were reiterated.
ADDITIONAL CORRECTIVE ACTIONS AND COMPLIANCE DATES High radiation area posting and labeling requirements currently outlined in procedure HP 3.2 are more conservative than posting requirements in PBNP Technical Specification 15.6.11.
This conservative inconsistency may have caused confusion regarding the requirement to have a flashing red light to preclude unauthorized entry into areas with dose rates greater than i
1000 millirem per hour.
Procedure HP 3.2 will be revised to more clearly define Technical Specification requirements and 10 CFR 20 posting and control requirements.
This procedure will be revised by August 15, 1988.
Formal retraining on the proper control and posting of high i
radiation areas will be provided to Health Physics supervision and technologists by October 1, 1988.
Although the planned training is broader than the specific concern over high radiation areas caused by transfer of irradiated fuel, the training will occur prior to the next scheduled fuel transfer from Unit 2 containment.
The scheduled training will emphasize procedural and regulatory requirements for the control of high radiation areas.
Health Physics Standing Order 34 and associated checklist CHP-160 will be revised by October 1, 1988, to include the requirement to post the two previously unidentified transient dose rate areas on the El. 46' and 66' of the auxiliary building prior to fuel movement.
HPSO 34 will also be revised to provide a more detailed description of the location where each required boundary is to be staged prior to fuel movement to ensure the boundaries are properly positioned.
s-RESPONSE TO NRC NOTICE OF VIOLATION June 16, 1988
"'ge 4 The transient high radiation dose rate area, that has in the past been created in containment during refueling on the El. 66' refueling floor, will be reduced during future refueling _ outages by utilizing temporary or permanently installed shielding.
The shielding will be installed to attenuate the radiation streaming through the structural gap between the transfer canal and the containment El. 66' floor.
Operations refueling procedure RP-lC, "Refueling," will be revised to include additional precautionary steps to ensure positive control of transient dose rates during fuel movement.
The procedure will require, as an initial condition to fuel movement, a verification that shielding is positioned to attenuate the radiation fields emanating from the transfer canal through the containment wall and containment El. 66' floor gap.
Procedure RP-1C will also be revised to include a requirement that the first irradiated fuel assembly that is transferred through the refueling canal will be held in a stationary position in the transfer canal under controlled conditions for a sufficient amount of time to allow Health Physics' personnel the opportunity to verify the adequacy of radiation area postings and physical barricades.
These revisions to procedure RP-lC will be completed by October 1, 1988.
If you have any questions or require additional information regarding our response to this violation, please contact us.
1 Very truly yours, c
[lfy -
C. W. Fay 4 Vice President Nuclear Power Copies to NRC Regional Administrator, Region III NRC Resident Inspector