ML20216D480
| ML20216D480 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 03/09/1998 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-413-97-15, 50-414-97-15, NUDOCS 9803170080 | |
| Download: ML20216D480 (4) | |
Text
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IN Duke Power Company
+
l,7 j A Duke Energ Comny L%d Catawba Nudear Station 4800 Concord Road York, SC 29745 Gary R. Peterson (803) 831-425I omct t
Yur President (803) 831-3426 fax March 9, 1998 U.
S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555
Subject:
Duke Energy Corporation Catawba Nuclear Station Dockets 50-413 and 50-414 Reply to Notice of Violation (NOV)
Inspection Report 50-413, 414/97-15 Pursuant to the provisions of 10 CFR 2.201, attached is Duke Energy Corporation's response to a Notice of Violation dated' February 9, 1998.
Inspection Report 50-413, 414/97-15 identifies one Level IV violation regarding the failure to revise radiation work permits to reflect changes in dress due to changing plant conditions.
This violation was identified during an NRC inspection period between November 23, 1997 and January 10, 1998.
Duke Energy Corporation acknowledges this occurrence to be a violation of the requirements of Technical Specification 6.8.1.a and Procedure SH/0/B/2000/003.
If there are any questions concerning this response, please contact M.
S. Purser at (803) 831-4015.
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R.
Peterson
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Attachment l'
9003170080 980309 PDR ADOCK 05000413 G
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U.
S. Nuclear Regulatory Commission March 9, 1998 Page 2 xc:
Mr. Luis A.
Reyes Regional Administrator, Region II U.S.
Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth St.,
Suite 23T85 Atlanta, Georgia 30323 P.
S. Tam U.S.
Nuclear Regulatory Commission Office of Nuclear Reactor Regulation One White Flint North, Mail Stop 9H3 Washington, D.
C.
20555 D.
J.
Roberts Senior Resident Inspector Catawba Nuclear Station i
l l
Catawba Nuclear Station Reply to Notice of Violation Statement of Violation 50-413,414 / 97-15-06 Technical Specification 6.8.1.a requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A
)
to Regulatory Guide 1.33, Revision 2.
As referenced in i
Section 7.e(l), this includes radiation protecti~on procedures for access control to radiation areas including a Radiation Work Permit System.
Procedure SH/0/B/2000/003, Use of the Radiation Work Permit, Revision 00, Step 4.4.1 states that Radiation Work Permit deviations must be documented in a logbook and that changes that extend beyond one shift change must be documented in a revised radiation work permit.
Step 4.4.2 requires that a permanent radiation work permit revision be initiated when radiological conditions warrant permanent changes in protective clothing, equipment, or special instructions, j
Contrary to the above, between December 14 and December 19, changes to radiological conditions in the 1B residual heat removal pump room were not logged to reflect changes in dress requirements, and the radiation' work permit was not revised when the change extended beyond one shift.
As a result, workers entered a radiologically controlled area with higher than normal contamination levels without the appropriate dress category for those radiological conditions.
Response to NRC Violation 97-15-06 Reason for Violation Duke Energy Corporation acknowledges the violation.
This violation is attributed to failure to follow procedures.
RP Lead Technicians involved with the occurrence and those involved in the subsequent review indicated adequate knowledge of the procedural requirements.
This event has been characterized as a human performance issue rather than a programmatic issue.
Although the Radiation Work Permit (RWP) update did not occur as required by procedure, workers were adequately protected against the radiological hazards present.
There were no uptakes of radiological material, radiological
i s=
overexposures, or personnel contamination events associated with Residual Heat Removal Pump work.
Corrective Actions Taken and Results Achieved A cross reference of Job Access Forms (forms originated by crews requesting permission to work in restricted areas).for all outage related work areas (Upper Containment, Auxiliary Building, Lower Containment, and Steam Generators) were compared with RWPs to verify proper documentation for deviations to the RWP as required by Standard Procedure SH/0/B/2000/003, Use of the Radiation Work Permit.
The review identified other isolated instances of failure to properly document changes to an RWP or revise the RWP if a radiological condition change lasted greater than one shift as required by SH/0/B/2000/003. PIP 0-C97-4262 was initiated to document-the findings of this investigation.
All RWPs were reviewed and revisions were made to dress categories of affected RWPs as appropriate.
This is documented in the Immediate Corrective Actions section of the PIP.
Procedure SH/0/B/2000/003 provides adequate guidance for RWP deviations and revisions.
Employee Training Qualification System (ETOS) tasks RP-1001, RP-1102, and RP-2613 include RWP deviation and revision requirements as elements for task qualification.
Therefore, no revisions are necessary to these documents.
Corrective Actions to be Taken to Avoid Future Violations Requirements for RWP deviation and revision were reviewed with RP Lead Technicians and procedure use and adherence will continue to be an expectation.
Date of Full Compliance CNS is in full compliance.