ML20217B887
| ML20217B887 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/01/1991 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 9103120264 | |
| Download: ML20217B887 (8) | |
Text
DhClaf MAR 01199)
.w Docket Nos. 50-325, 50-324 License Nos. DPR-71, DPR-62 Carolina power and Light Company ATTN: Mr.'Lynn W. Eury Executive Vice President Power Supply P. O. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT HOS. 50-325/90-43 AND 50-324/90-43 Thank you for your response of December 20, 1990, to our Notice of Violation issued on December 3, 1990, concerning activities conducted at your Brunswick facility.
We have examined your response and found that it meets the requirements of 10 CFR 2.201.
In your response, you state that you do agree that a violation of Technical Specification requirements for securing access to high radiation areas occurred on September 20, 1990.
However, your response denied that the violation resulted from failure to take adequate corrective actions for six previously identified violations occurring during the period of April 20,1989 and August 3, 1990.
After consideration of the bases for your denial of the cause for the violation, we have concluded, for the reasons presented in the enclosure to the letter, that the violation occurred as stated in the Notice of Violation. Based on the information provided in your response, we have concluded you have described adequate actions with regard to your corrective action program for locked high radiation area doors.
Therefore, no further response is required.
The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
We appreciate your cooperation in this matter.
Sincerely, Cum J. Philip Stohr, Director Division of Radiation Safety and Safeguard
Enclosure:
(See page 2) 9103120264 910301 PDR ADOCK 05000324
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Carolina Power?and Light-Company 2
Enclosure:
' Evaluations and Conclusions
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R. B. Starkey, Jr.
Vico President Brunswick-Nuclear Project P. O. Box 10429 Southport, NC 28461 J. L. Harness Plant General Manager Brunswick Steam Electric Plant P.'0 Box 10429 Southport, NC 28461 R. E. Jones, General Counsel Carolina Power & Light Company.
.P. O. Box 1551 Raleigh, NC 27602 Ms.-Frankie Rabon-Board of' Commissioners P. O. Box 249
- Bolivia, fH: 28422
'Dayne H. Brown, Director
. Division of Radiation Protection N. C. Department:of Environmental, Commerce & Natural Resources P.-0. Box 27687
-Raleigh,- NC 27611-7687
.H. A. Cole Spe'ial' Deputy Attorney General c
State of. North Carolina P; 0. Box 629 Raleigh, tK: 27602 Robert P. Gruber Executive Director
-Public Staff - NCUC i
P. D. Box 29520 Raleigh, NC 27626-0520 i
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(See page 3)
. Carolina Power and Light Company 3
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440cument Control Desk H. Christensen, R11 T. Le, NRR NRC Resident Inspector U.S. Nuclear Regulatory Commission Star Rte. 1, Box 208 Southport, NC 28461 l
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ENCLOSURE EVALUATIONS AND CONCLUSIONS On December 3,1990, a Notice cf Violation was issued for a violation identified during a' routine NRC inspection. CP&L responded to the Notice on
[
-December 24, 1990. The licensee's response agreed that a violation of t
Technical Specificction (TS) 6.12.2 requirements for controlling access to a high radiation area occurred on September 20, 1990, when a door to a high radiation area was found un-locked or controlled.' However, the licensee disagreed that the violation resulted from inadequate corrective actions for
-previously identified TS 6.12.2 violations concerning un-locked high radiation
- area doors. The NRC's evaluations and conclusions regarding the licensee's arguments are as follows.
l Statement of Violation
.10 CFR 50, Appendix ~ B, Criterion XVI, states that measures shall be established
- to assure that conditions adverse to quality, such as deviations, and p
nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the
~
l cause of the condition is determined and corrective action taken to preclude repetition.
L 10 CFR 20,203(c)(2)(iii) requires that each entrance or access point to a high radiation area shall be maintained locked except during periods when access to L
the area is required, with positive contruls over each individual entry, l
L Technical Specification (TS) 6.12.2 requires that each high radiation area, in which the radiation intensity is greater than 1,000 millirem per hour I
(mrem /hr), have locked doors to prevent unauthorized entry.
Contrary to the above,. adequate corrective actions were not taken to assure L
that violations of regulatory requirements, licensee TSs, and licensee procedures concerning entry and controls into high radiation areas, were I
corrected to preclude recurrence, as evidenced by the following:
1.
In March 1990, NRC ' Inspection Repcrt Nos 50-324, 325/90-06 identified a violation of regulatory and TS requirements for controlling access into l
high radiation areas having a whole body dose rate greater than 1,000 millirem per hour (mrem /hr) during the period of April 20, 1989 and January 21, 1990. Five examples of the violation were documented and four of the five violations were identified by the licensee.
(
2.
NRC Inspection Report Nos. 50-324, 325/90-34 documented a sixth example of failure to control access to a high radiation area within a 16 month period that.was identified by the licensee on August 3,1990.
i Enclosure-2 3.
NRC Inspection Report Hos. 50-324, 325/90-37 documented a seventh example j
of failure to control access to a high radiation area within a 17 month period that was identified by.the licensee on September 20, 1990.
Summayy,p,fj,icpgse_e Response The licensee's response agrees thet a violation of TS 6.12.2 requirements for access controls to high radiation areas occurred on September 20, 1990.
However, the licensee dises,ees with.the NRC's assessment that the corrective actions for previously identified TS 6.12.2 violations, reported in NRC inspection report 90-06, were not timely or adequate to prevent further violations. The licensee argues that the first six TS 6.12.2 violations and the seventh that occurred on September 20, 1990, were caused by different problems.
The response reported that the first six TS 6.12.2 violations were caused by personnel error and the seventh was a problem with a malfunctioning door and lock.
The. licensee's response reported that the corrective actions for the 90-06 violation were formulated to reduce personnel errors, specifically, personnel failure to verify high radiation areas were properly secure upon exit. The response also reported the corrective actions made to reduce personnel errors associated with proper security of high radiation areas had been effective, in that, there had not been any additional TS 6.12.2 violations resulting from personnel errors following ful1 implementation of those corrective actions on August 16, 1990.
The licensee reports that the seventh violation was not caused by personnel error.but by faulty equipment, specifically, a malfunctioning door frame and locking mechanism that appeared to be locked upon closure. The door would jam in it's frame, giving the feeling that the door was locked when it was really wasn't. The door latching mechanism was also found to be defective preventing automatic latch and lock upon closure.
The licensee argued that since the cause of the seventh violation (equipment) was different from-the six previous violations (personnel errors) the seventh violation was not a recurrence of the first six violations and was not indicative of failure to take adequate and timely corrective actions to prevent recurrence.
NRC_ Evaluation The NRC staff has carefully reviewed the licensee's response and has concluded that the response did not provide any information that was not already
-considered in determining the significance of the violation. The licensee's response implies that the first six violations of TS 6.12.2 requirements were exclusively catsed by personnel errors and that a seventh violation of TS 6.12.2 was caused by malfunctioning equipment. The licensee argues that since the causes were different, the NRC's violation of failure to take timely and effective correction to prevent recurring TS 6.12.2 violations was unfounded.
l.
Enclosure 3
i A combination of _ personnel errors and mechanical problems with doors and gates L
to high radiation areas was recognized by the licensee's staff before ti
. seventh violation occurred on September 20, 1990, as evidenced by the following:
During a routine NRC inspection conducted during January 29 through February 2, 1990, inspectors determined that licensee management was aware t
i that personnel errors and mechanical problems with high radiation area doors and gates were contributors to the previously identified TS 6.12.2 violations. As noted in the 90-06 Inspection Report issued March 8,1990, "In discussions with the inspectors, the manager of Environmental and i
Radiological Control (E&RC) stated that the investigations showed that several problems contributed to the events. In one case the design of the l
locking mechanism for a gate made it appear locked when in fact it was not. In several cases the locking mecha11sm was not functioning properly, or the doors / gates were left unlocke1 by personnel."
CP&L's Initial response to. the 90-06-01 violation, dated April 6,1990, reported that the five examples noted in the violation were due to a combination of personnel errors and mechanical problems with high radiation area door locking mechanisms. The same response also discussed each of the five violations and the following was noted for two of the violations.
The first example of the TS 6.12.2 violation discussed in the 90-06 report occurred on April 20, 1989, and involved a mesh gate located on Unit I turbine building 70 foot level. The licensee's response to the violation reported that the door was found to be mechanically malfunctioning due to a faulty lock set with a weak spring.
The fourth example of the 90-06-01 violation that occurred on January 5,1990, also involved another mesh gate on Unit 1 turbine building 70 foot elevation. The licensee's response to the violation reported that the investigation into the event concluded that this l
type of gate / door possesses a design deficiency in that these doors l
have a tendency to recoil off the door jams when slammed shut preventing the locking mechanism from engaging even though the gate appears to be closed.
Both gates in the first and Burth violations were similar to the seventh gate found unlocked on September 20, 1990. The seventh gate l
was located on Unit 2 turbine building 70 foot level.
Additionally, the April 6,
1990, response concluded that isolated personnel errors had contributed to each of the incidents described above.
The licensee also reported that the mesh gates were a problem in many of the incidents due to mechanical design deficiencies.
t
4 Enclosure 4
The April 6,1990, response reported the licensee's proposed corrective actions to prevent recurrence included a preventative maintenance program that was being established for applicable locked high radiation area doors, with the intent of ensuring proper operation of the doors. The response also reported that a Human Performance Evaluation (HPE) assessment would be performed to identify additional corrective actions which may include improved door design. The licensee committed in the above response to completing the HPE and develop the locked high radiation preventative maintenance program by June 1,
1990 and provide a supplemental response detailing the additional corrective actions determined necessary by June 20, 1990.
On June 29, 1990, the licensee reported that CP&L Nuclear Engineering Department was considering three cptions to eliminate design problems identified with various locked high radiation areas and would provide a
. supplemental response to the.NRC by August 17, 1990, detailing the results of the study'and proposed actions.
In the. licensee's supplemental response provided to the NRC on August 16, 1990, the licensee reported that design deficiencies relative to latched gates had been identified and the Nuclear -Engineering Department had been requested to determine the most feasible methods for eliminating the design deficiencies involving the latched gates. The licensee reported that following completion of the engineering packages, any proposed changes'would be evaluated and scheduled. The licensee's response reported that any additional work on the latched gates was considered to be an enhancement to the existing program, and would not be required to ensure compliance with TSs. The licensee reported that the real issue with door control lies not with poor doro design or closure devices, but rather with Lthe failure of individuals ush39 plant doors to verify tha; they are properly closed and latched.
The -licensee in interviews with NRC inspeticrs and in documentation to the
- NRC concerning the TS 6.12.2 violation a6 dressed in the 90-06 NRC Inspection Report, issued March 8,1990, clearly ino!cated that licensee management was aware that various mechanical problems with the gate / doors had contributed to the violations.
However, when the seventh example of the TS 6.12.2 violation occurred on September 20, 1990, the licensee had not established specific corrective actions ard a-completf on date for correcting mechanical problems with high radiation area-doors or getes, NRC Conc,lusion
=During the licensee's investigation of the initial TS 6.12.2 violation identified in April 1990, the licensee discovered equipment problems associated with locked high radiation area doors and gates. However, the licensee did not establish a corrective action plan or schedule to make equipment corrections to locked high radiation gates in a timely manner to prevent additional TS 6.12.2 violations. Failure to take adequate and timely corrective actions to correct previously identified problems with high radiation area doors to preclude continuing violations of TS requirements for controlling access to high ll
, - - - +, = - -
M
Enclosure 5
radiation areas, was identified as a. violation of 10 CFR 50 Appendix B, Criterion XVI, -Corrective Action. Recurring violations are of particular concern because the NRC expects licensees to learn from their past failures and to take effective corrective actions. The mechanical failure leading to the most recent violation was different from the mechanical failures leading to prior violations; however, they were sufficiently related to reaffirm the BSEP earlier door replacement decision, that was then later postponed.
For the above reasons, the NRC staff concludes that the violation occurred as stated and did arise from a prior corrective action failure.
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