ML20212A404
| ML20212A404 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/16/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Myers L CENTERIOR ENERGY |
| References | |
| 50-440-97-10, NUDOCS 9710230293 | |
| Download: ML20212A404 (2) | |
See also: IR 05000440/1997010
Text
..
- _ _ .
._
_ _
_
_ _ _
_. _
.. _
_ . _ _
_.
'
Q LC
.
October 16, 1997
'
Mr. Lew W. Myers
Vice President - Nuc! ear
Centerior Service Company
P.O. Box 97, A200
,
Perry, OH 44081
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-440/97010(DRS))
.
Dear Mr. Myers:
This will acknowledge receipt of your letter dated September 27,1997, in response to
>
our letter dated August 29,1997, transmitting a Notice c.f Violation for the failure of operations
-
personnel to follow a procedure goveming the control of radioactive material. We have
!
reviewed your corrective actions for the violation and have no further questions at this time.
These corrective actions will be examined during future inspections.
i -
Sincerely,
Original Signed by John A. Grobe
4
i
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosure:
Ltr dtd 9/27/97 L. W. Meyers
Perry to USNRC
See Attached Distribution
\\
DOCUMENT NAME: G:DRS\\PER10W7.DRS
k
v.
. . , .e im m
. m.i. m
w.,
e . co .,~, .nma
....oc
c . co.v.,,,n.n.en
..oem.m.
"N" = No copy
OFFICE
Rlli
E Rlli
c
Rlli
/ ,, ]
Rllla f, /V
l
NAME
KSelburg:jo kNS
GShear 646
GWrightW
Jdro#W
DATE
10/fl97
10/6797
10/1N97
10/1497
'
OFFICIAL RECORD COPY
s
hkfhfkg, f,gfl'f
9710230293 971016
- a
i
ADOCK 05000440
G
-
--
.
.
.
- .
. - - .
- - - . .
. _ _ . -
. -
...-
-
.
-
-
_
O'.
L. W. . Meyers --
2
October 16, 1997
.
cc w/o encl:
H. L. Hegrat, Manager, Regulatory Affa'rs
T. S. Rausch, Director, Quality and
Personnel Development
R. W. Schrauder, Director, Parry
Nuclear Engineering Department
W. R. Kanda, General Manager,
Nuclear Power Plant Department
'
N. L. Bonner, Director, Nuclear
Maintenance Department
H. W. Bergendahl, Director, Nuclear
Services Department
cc w/ encl:
Terry L. Lodge, Esq.
State Liaison Officer, State of Ohio
Robert E. Owen, Ohio Department of Health
C. A. Glazer, State of Ohio -
Public Utilities Commission
Roy P. Lessy, Jr., Esq.
Distribu' ion:
Docket File w/o enci
Rlli PRR w/ercl
Rlli Enf. Coordinator w/enct
PUBLIC IE-01 w/enct
SRI, Perry w/enct
TSS w/enci
OC/LFDCB w/enci
LPM, NRR w/enci
DOCDESK w/encI
DRP w/ encl
A. B. Beach, Rill w/ encl
CAA1 w/ enc!
DRS w/enci
J. L. Caldwell, Rlli w/enci
.
y
- . . . _ , , .
m...
-
.-.
.
- - -.
--.
_.
._
'
.
CENTERIOR
ENERGY
1%wer Generation Group
Perry Nuclear Poeur Plant
Mad Address-
216 280 6916
Lew W. Myers
10 Carner Road
P.a Bos97
FAX: 216-280-8029
Voe President
Perry, ohso 44061
Perry, oH 44081
September 27.1997
PY-CEl/NRR 2217L
United States Nuclear Regulatory Commission
Document Control Desk
Washington, DC 20555
Perry Nuclear Power Plant
Docket No. 50-440
Reply to a Notice of Violation
Ladies and Gentlemen:
.
.
2nclosed is the reply to the Notice of Violation contained in NRC Inspection Report 50-440/97010 for-
the Perry Nuclear Power Plant (PNPP), which was transmitted by letter dated August 29,1997. He
Notice of Violation addressed the failure of operations personnel to follow a procedure governing
control of radioactive material.
Please note that as part of the corrective action investigation for this item, PNPP management recognized the
need to reinforce expectations regarding radiation work practices. As a result, a summary of expectations was
provided site wide for review at a series of special meetings, nese meet ,gs were held with on-site company
4
and contractor personnel during the current refueling outage. ne intent of these meetings was to deliver a
consistent message to appropriate work groups, including operations, regarding safe work practices at PNPP.
Managers participated in these meetings to stress the importance of meeting management expectations for
working safely,
ifyou have questions or require additional information, please contact Mr. Henry L. Heg
t,
Manager - Regulatory Affairs, at (440) 280-5606.
Very truly yours,
for Lew W. Myers
Enclosure
cc:
NRC Region Ill Administrator
NRC Resident Inspector
NRC Project Manager
j& C30 l3 T
N//
- -~ - - -- -
- -. -.- - _ . - -
. - - - - . . - - - -
.~ - - - -
, .
4
PY-CEl/NRRc2217L
Enclosure
.
,
Page l of 3
,
!
REPLYTO A NOTICE OF VIOLATION
i
1
-
)'
VIOLATION 97010-01
i
-
1~
Restatement of the Violation
,
L
5
During an NRC Inspection conducted from July 28,1997, through August 1,1997, a violation ofNRC
'
requirements was identified. In accordance with the "Oeneral Statement of Policy and Procedure for NRC
i
Enforcement Actions," NUREG 1600, the violation is listed below:
n
a
Technical Specification 5 A.l.a requires, in part, that procedures / instructions'shall be established,
implemented, and maintained for the applicable procedures recommended in Regulatory Ouide 1.33,
,
!
Revision 2, Appendix A, February 1978,
i
ll
Regulatory Guide 1.33, Revision 2, Appendix A, February 1978, lists typical safety-related activities -
l
that should be covered by written procedures including (Step 7.eA) procedures for contamination
i
control.
,
,
- _
Perry Operations Man'ual Plar.t Administrative Procedure PAP-0515, Revision 8, Tontrol of
[
Radioactive Material," Step 5.8.1 a, requires, in part, that material produced through operation of the
i
plant be controlled as radioactive material if survey results indicate levels of removable
,
i
contamination in excess of 1000 dpm (16.7 Bq) per 100 cm beta-genma contamination.
2
>
j-
I
Perry Operations Manual Plant Administrative Procedure PAP-0515, Revision 8, " Control of .
g
. Radioactive Material," Step 6.6A.10, requires, in part, that personnel at the Perry plant use
-
radioactive material with loose, external surface contamination only in contaminnend areas or in -
l
areas anticipated to become contaminated, leave radioactive material in posted contaminated work
1
areas during work activities, and prior to remeing material from posted contaminated areas package
material with loose external contamination in clean, yellow bags, or other suitable container.
,.
.
l
Contrary to the above, on July 30,1997, a one inch rubber fill and vent hose with removable surface
contamination of 2000 disintegrations per minute por 100 square centimeters (dpm/100_cm ) was
2
identified outside of a contaminated area and was not contained in a clean, yellow bag, or other
y
suitable container.
i-
.
nis is a Severity Level IV vic!stion (Supplement IV).
>
k
Backaround
i
De violation is accepted as written. A Perry Nuclear Power Plant (PNPP) radiation protection supervisor
identified a contaminated hose which was not appropriately contained in accordance with plant procedures.
i
Specifically, a one inch potentially contaminated fill and vent hose was laying on the floor with one end in
- the floor drain, a posted contaminated area, and with the other end open on the floor, He open end was not
,
_
_
-_ begged or capped, and a radiological survey on this end of the hose identified loose surface contaminstion of
[
' 2000' disintegrations per minute per 100 square centimeters (dpm/100 cm') beta-gamma. His hose had been
[
- left by operations personnel after performing a fill and vent operation.
,.
.
4
i ~
.-. .
.
. ..
_
..
.
PY-CEl/NRR-2217L
.
Enclosure
Page 2 of 3
Reason for the Violation
PNPP operations personnel failed to follow procedures governing control of radioactive material. Leaving
potentially contaminated material outside of a contaminated area without containing the material, in a bag or
other suitable method, was contrary to the requirements of Plant Administrative Procedure (PAP)-OSI S,
" Control of Radioactive Materia'."
The Root Cause of this event was determined to be personnel error. The hose should not have been left in
the area after the conclusion of work activities. The individual (s) using this hose failed to ersure that the
work area was clean of all tools and material at the completion of thejob. The ends of this hose should have
been controlled to prevent the spread of.:ontamination at the time it was disconnected from the system.
Additic ially, it was determined that n anagement expectations with respect to radiation worker practices
were not properly implemented.
Corrective Stens Taken and Result' Achieved
immediate corrective actions takers were as follows.
A Health Physics Technician bagged the end of the hose and performed a contamination survey to
ensure contamination had not spread.
v
s
ne operations superintendent issued a daily instruction describing the problem and emphasizing the
e
importance of good radiation worker practices. Rese items were also discussed during shift turnover
meetings.
Operations Section personnel walked down other Operations hose storage locations to ensure proper
=
storage.
Operations Shift Supervisor crew activity log was modified to promote in-field observations of activities
within contaminated areas.
Operations requested the Radiation Protection Section (RPS) to begin performing routine surveys of
hoo stations, attend crew briefings, and provide in field observations of Operations Section personnel
performance.
Corrective Steps that Will be Taken to Avoid Further Violations
Operations and RPS personnel met to discuss potential improvements in general radiation work practices,
including hose control and storage. The following actions, which are addressed under the PNPP Corrective
Action Program, were developed.
RPS will develop guidelines for controlling the ends of contaminated hoses. Operations and maintenance
personnel will train to the guidelines developed by RPS for controlling the ends of contaminated hoses.
Additionally, expectations regarding housekeeping and radiation worker performance are being reinforced.
Operations and Maintenance personnel will review lessons learned during continuing training or safety
meetings to reinforce expectations regarding communication with RPS. This will include discussing the use
of hoses for draining systems and notifying RPS to perform the required surveys in support of the work
activities.
_ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - -
- -
-
-
-
' ~
- .
'
'
,'
PY-CEl/NRR-2217L
Enclosure
Page 3 of 3
Date When Full Compliarne Was Achieved
Full compliance was achieved on July 30,1997, when a 11ealth Physics Technician bagged the end of the
'
hose and performed a contamination survey which co firmed that contamination had not spread.
1
The following table identifies those actions which are considered to be regulatory commitments. Any other
actions discussed in this document represent intended or planned actions, are described for the NRC's
information, and are not regulatory commitments. Please notify the Manager- Regulatory Affairs at the
Peny Nuclear Power Plant of any questions regarding this document or any associated regulatory
comtritments.
COMMITMENTS
-
I
None '
s
s
.
e