ML20196E492
| ML20196E492 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/02/1988 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8812120015 | |
| Download: ML20196E492 (4) | |
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5 VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 88-101 RD 5, Box 169, Ferry Road, Brattleboro. VT 05301 0-ENGINE RIN OFFICE 580 MAIN STREET Bot. ton. M A 01740 (508) 779 4 711 December 2, 1988 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Document Control Oesk
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 88-239, Inspection Report No. 50-271/88-18, dated 11/4/88 4
Dear Sir:
Subject:
Response to InJpection Report 88-18, Notice of Violation During a special, radiological safety inspection conducted on October 5-7, 1988, one violation of NRC requirements along with certain programmatic weaknesses & c identified.
The following information is provided in response to the violation.
VIOLATION "Technical Specification 6.5.B states, in part, tnat radiation cont?ol standards and procedures shall be prepared, approved and maintained and mado available to all station personnel.
These procedures shali r,how permissible radiation exposure, and shall be consistent Hith the requirements of 10 CPR Part 20.
The radiation protectdon program shall be orgenized to meet the requirements of '40 CFR Part 20.
I Procedure AP 0502, Rev. 19. "Radiation Work Permits", Section 0.6, requires in part that all v#orking party personnel shall observe all potted and written instructions given by the work party superviuor and/or the assigned Chemistry and Health Physics i
representative.
Contrary to the above, on September 28, 1988, two Instrument and Control (!&C) technicians entered the "A" and "B" recombiner hallways in the Advanced Offgas (A00) building which were posted "High Radiation Area, RWP Required" without a Radiation Work Permit (RWP)."
RESPONSE
Immeoistely af ter learning of the problem, managemer)t conducted a series of meetings to determine the extent of the problem and the appropriateness of the ini*ial corrective actions.
As a result of those meetings, it was concluded that the corrective actions were adequate in ensuring immediate radiological M
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i VERMONT YANKEE NU'; LEAR POWER CORPORATION I
U.$. Nuclear Regulatory Commission December 2, 1988 Page 2 I
safety. However, we concluded that an additional investigation was needed to identify the root cause and to recommend long-term corrective actions.
.A n investigation team was assembled consisting of four individuals having var!ous backgrounds and expertise and having no direct involvement with the incident.
This team interviewed personnel directly and indirectly involved with the inc!-
dont to establish the pertinent facts and extent of the proolen.
Following the investigation, the team documented their findings in a report which was discussed and provided to the Plant Manager on October 24, 1988.
The investigation of the event revealed that the root cause of the viola-tion was human error in judgement. At the time of the event, before performing the surveillance, the technicians had forgotten the key, were annoyed with that situation and did not take the time to get the key.
They made the incorrect judgement that it would be a:ceptable to bypass the lock because they perceived the real hazard as small based on past experience with 1
radiation levels in the A00 recost;iner room hallways.
I We have reviewed the Inspection Report and conclude that it accurately j
reflects the incident and our corrective actions, consequently, that infor-mation will not be repeated here. With implementation of thsse corrective actions, we were in full compliance we,n our Technical Specifications.
The task force rtport contained a numt.er of recommendations involving procedure enhancements, bsrdwara changes, and management practices. While none of ther,e r
changes w:uld have prevented this event, they will be considered and disroci-i tioned by the Plant Minager by December 9, 1988 to improve cur future overall performance.
I The following inicrmation denribes the status of our efforts to address L
the or grammatic weaknesses identified in the Inspection Report.
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a.
An apparent disregard of eadiolgical physical and adminMrativt raf tty l
1 barriers existed.
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A lax attitude toward high radiation area controls by plant personnel including radiation protection management existed.
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The !&C technician and RP staff actions reflected an apparent weakness in l
the effectiveness of radiological safety training.
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1 Status I
Our investigation concluded that where there may have been a lack of sen-
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sitivity to certain conservative radiological controls, we found no evi-s dence that would indicate a loss of control of actual high radiation areas.
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Nevertheless, we rJcognize the need to ensure pg.'sonnel comply with al'.
l administrative controls and not allow individual discretion.
To address t
this concern, the following actions have occurred or are planned.
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e VERMONT YANKEE NUCLEAR POWER CORPORATION U.S*. Nuclear Regulatory Commission December 2, 1988 Page 3 4
The Plant Manager held a special plant staff meeting on October *, 1988 to briefly discuss the event and potential serious safety consequences.
The Plant Manager citarly stated that this behavior was unacceptable, and that any future events would be grounds for dismissal.
This ac,lon clearly communicated the seriousness of the event.
The Plant Manager has met individually with cach department to discuss the lock tampering incident. This 'is provided the opportunity for the Plant Manager to re-emohasize management's expectations with regard to administrative control compliance with specific mention of radiological controls.
Retraining of al'. I&C Department personnel in Radiation Protection require-ments has been initiated. This retraining and an evaluation of its effec-tiveness will be completed by December 31, 1988.
We feel that the corrective actions taken and those that are planned as docu e e-d in the task force report not directly associated with the vio;atiam along with the re-emphasis provided during the Plant Manager meetings discussed above, will address this concern, d.
Significant weaknesses were identifieo in procedures AP 0502, AP 0529, OP 0532, and DP 0537.
OP 0532 allows the Radiation Protection Assistant to give verbal permission to individuals to enter High Radiation areas without an RWP.
Status:
It should be noted that the procedure in effect at the time of the incident d:d not allow entry into an "actual" high radiation area without an RWP.
It did alloe the issuance of a key to a posted high radiation area with only ve.Lal authorization if the area was not an actual high radiation area.
To ensure personnel compliance with administrative controls, OP J432 was revised to clearly require the proper key, monitoring equipment and radiation work permit when entering any posted high radiation area.
AP 0502, "Radiation Work Permits", allows work in an area with dose rates as high as 100 mR/ hour without RWP authorization.
Status: We have reviewed our current threshold for RWP's and based on our preliminary assessment, we find that we have been able to account for a large percentage of total exposure received on RWP's.
It is our plan to more formally resiew the appropriatentss of our current prac-
' ice following the 1989 refueling outage.
This review will be completed by July 1989
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VERMONT YANKEE NUCt EAft POWER CORPORATION
.U.S'. Nuclear Regulatory Commission December 2, 1989 Page 4 AP 0529 and DP 0537 do not provide guidance for the timely notifica-tion of appropriate management prior to the processing of incident documentation.
Status: AP 0529 and DP 0537 will be reviewed and modified as nucessary to provide guidance for timely notification tu management by January 1989.
In the interim, the need for prompt wanagement notifi-cation has been discussed with Radiation Protection department manage-ments significant events are presented and discussed at the weekly department head meeting and additional oversight is being applied to t
this area.
We trust that the above information adequately responds to the concerns identified in the Inspection Report; should you have questions or desire to 4
review the investigation report at our facility, please do not hesitate to con-l ta';4 us, i
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION i
f/***g des- --
Warren P.
urphy y Vice President and Manager of Operations i
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/dm cc:
USNRC Regional Administrator, Region I USNRC Resident inspector, VYNPS l
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