ML20217J150
| ML20217J150 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/26/1998 |
| From: | Zinke G Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-309-97-09, 50-309-97-9, GAZ-98-27, MN-98-35, NUDOCS 9804300173 | |
| Download: ML20217J150 (5) | |
Text
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4 MaineYankee P.O. BOX 400
- WISCASSET. MAINE 04578 * (207) 882-6321
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April 26,1998 i
MN-98-35 GAZ-98-27 i
UNITED STATES NUCLEAR REGULATORY COMMISSION Attention:
Document Control Desk Washington, D.C.
20555
References:
(a) License No. DPR-36 (Docket No. 50-309) 7 l
(b) USNRC Letter to MYAPCo, dated March 26,1998, NRC Integrated Inspection Report 50-309/97-09 and Notice of Violatio'n
Subject:
Reply to Notice of Violations Associated with NRC Inspection Report No. 50-309/97-09 Gentlemen:
The attachment to this letter provides Maine Yankee's reply to the Notice of Violations contained l
in reference (b). Included in this response is the reason for each violation, corrective actions / actions to prevent recurrence and the full compliance date.
l We agree with your report that states that some operations were performed in an excellent manner, yet there were some instances of poor worker performance and oversight during the inspection period. In addition to the corrective actions described in the response to these violations, Maine Yankee has taken action to not only improve individual worker performance, but also improve control and supervision of activities, including the oversight of contractors.
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Please contact us should you have further questions regarding this matter.
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l Very truly yours, George A. Zinke, Dir or Nuclear Safety & Regulatory Affairs Department Enclosure c:
Mr. Hubert Miller
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Mr. Ron Bellamy Mr. Richard A.Rasmussen
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Mr. Michael K. Webb Mr. Patrick J. Dostie Mr. Michael T. Masnik
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vJV'*g Mr. Uldis Vanags 9804300173 980426 PDR ADOCK 05000309 G
MaineYankee REPLY TO NOTICE OF VIOLATIONS i
ylolation "A'_'
Technical Specification 5.8.2 requires, in part, that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, (Revision 2), dated February 1978. Regulatory Guide 1.33, (Revision 2), dated i
February 1978, recommends in Appendix "A", Section 9, Procedures for Performance of Maintew.nce. Maine Yankee Procedure 5-58-1, Cavity Seal Ring Installation, steps 5.3.1.f and g, required the air regulator outlet valve and the test device relief valve isolation valve to be closed.
Contrary to the above, on January 5,1998, the air regulator outlet valve and the test device relief valve isolation valve were not closed as specified by the procedure. The omission of these procedure steps left the air source aligned to the test rig during the air drop test. Leakage of air from the air source could have affected the results of the test.
l Maine Yankee Response:
Maine Yankee agrees with this violation. Procedure 5-58-1, Cavity Seal Ring Installation, was not l
l followed correctly. The worker relied on past experience rather than direct reference to the l
procedure. Subsequent to identification, the cavity seal ring leak test was re-performed in accordance with the procedure, with satisfactory results.
The Maine Yankee corrective action process was entered and a barrier screen was performed. The l
apparent cause of this event was failure to properly follow the approved procedure and inadequate work supervision.
Immediate Corrective Actican The cavity seal ring leak test was te-performed in accordance with the procedure. The test gauges and relief valves were removed and calibrated satisfactorily, as required by the procedure.
l The worker was counseled by the Maintenance Department Manager on the need and requirement to maintain focus and attention to detail. Expectations for work supervision were reinforced to the Lead Plant Mechanic assigned to thisjob. The Mechanical Maintenance Supervisor was assigned as a coach for the Lead Plant Mechanic, and an additional qualified crane operator was assigned for the rest of thejob.
Corrective Actions Taken to Avoid Further Violation:
Maintenance Department personnel were briefed on this problem and reminded of the need for attention to detail, lack ofcomplacency and the use of STAR (Stop, Think, Act and Review). A low j
tolerance for repeat violations was stressed. As of January 6,1998, Maintenance management has been assigned to daily tours of containment to observe activities during periods of significant containment work.
The Maine Yankee management team was briefed on the event, causal factors, and the corrective actions on January 6,1998.
In order to ensure that significant evolutions conducted during Maine Yankee's decommissioning receive adequate management oversight, Procedure 0-06-9, CONDUCT OF INFREQUENTLY PERFORMED TESTS AND EVOLUTIONS, was revised on February 12,1998 to broaden the scope of which evolutions require additional management oversight. The procedure now requires a management designee, responsible for evolution oversight and problem resolution, for any significant change or evolution associated with maintaining Spent Fuel Pool cooling / level, and for i
any significant or complex radiological evolution.
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O Fun Cc--u. ace Date:
Full Compliance was achieved on February 12,1998, when all corrective actions identified in the
- Condition Report w6re completed and Procedure 0-06-9 was revised.
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t MaineYankee Violation "B":
Technical Specification 5.11.1, requires, in part, that procedures for personnel radiation protection shall be prepared. Procedure 9-5-100, Contamination Control / Decontamination Program, provides specific requirements. Section 7.3.1 requires that personnel shall not reach into contaminated areas except as specifically authorized. Section 4.15.1.i requires personnel to comply with specific radiation protection instructioc regarding contamination controls. Radiation Protection Guideline (RPG)-002, Working Across Contaminated Area Boundaries, provides instructions that require gloves to be changed whenever removing hands from the contaminated area.
Contrary to the above, the following examples of failures to comply with procedure 9-5-100 were observed.
- 1) On January 26,1998, workers installing equipment on an instrument rack reached into areas posted as contaminated without specific authorization to do so and without appropriate protective clothing.
- 2) On January 27,1998, a worker exiting a contaminated area reached back into the area to retrieve some papers without specific authorization to do so and without appropriate protective clothing.
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- 3) On February 5,1998, a worker draining water from the internals of check valve FP-12, failed to remove his gloves upon removing his hands f om within the contamination area.
l Maine Yankee Response:
Maine Yankee agrees with this violation. All three incidents involved workers disregarding the controls associated with contaminated area boundaries, and represent a failure in fundamental Radworker skills. These actions could have resulted in the spread of contamination and were violations of procedural requirements.
In the first event, workers encountered an area where there was Rad tape on the floor along a trench, but no postings or rope. The workers assumed that the tape signified that only the trench was contaminated, so they reached across the boundary into an instrument rack they needed to work on.
Work was stopped and Condition Report 98-22 was initiated. The apparent causes of the event were determined to be:
(1) The use of tape on the floor was not a good choice for a contaminated area boundary.
Though it does not violate procedures when the use of a rope boundary is impractical, it is not a good work practice.
(2) It was unclear to the workers if the posting was meant to signify that the trench was contaminated or ifit also included the area above the trench.
(3) The workers continued to work even though they had questions about the radiological conditions of their work area..
The second incident involved a worker removing his protective clothing after leaving a contaminated area, reaching back into the area to retrieve his papers, and frisking them himself. Only a qualified RP technician can release material from a contaminated area. Condition Report 98-25 was initiated, with the conclusion that a lack of attention to detail was the cause.
The third event involved a worker trying to drain a leakage catch bag that was close to failing. In i
the process he forgot to remove his gloves, as required, when he took his hands out of the j
contaminated area. CR 98-37 was written for this incident. It also pointed to a lack of attention to detail, as well as, failure to follow the STAR principle as causes of the event.
MaineYankee Immediate Corrective Actions:
For the first incident, the following immediate actions were taken:
- 1) Stopped work on the instrument rack until the boundary issue was resolved.
- 2) Radiation Protection resurveyed the area and reduced the boundary to just the trench.
They also ensured that no spread of contamination occurred.
- 3) Discussed the incident with the workers and their Supervisor to express concern for the workers lack of attention to detail.
After the second event, the worker was stopped and counseled on the importance of attention to detail by RP and QA personnel.
For the third incident, the Shift Manager was notified of the challenge to the leak containment device. The RP coverage technician was notified of the improper work practice of the worker removing his hands from a contaminated area without removing his gloves. The check valve flapper
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was opened allowing the accumulated water to proceed through system piping to a low point drain.
This action stopped the leakage. RP personnel counseled the worker on proper radiological practices.
Corrective Actions Taken to Avoid Further Violation:
For the first event, the RP technicians were briefed on Management expectations for boundaries and discussed when the use of tape only would be acceptable. The Radiation Protection Departmental guidelines conceming working over (through) a contaminated area boundary were also discussed with the RP technicians..
The second incident was discussed at the contractor moming meeting on February 3,1998, to communicate that attention to detail is important and to stress the observance of radiological postings.
The third event was also discussed at the contractor moming meeting with the workers on February 9,1998. The use of STAR and team building were reinforced. RP Supervision provided a Health Physics perspective on radiation boundaries and barriers. The Radiation Protection Manager reviewed the event with the RP technicians on February 5,1998.
l Full Compliance Date:
Full compliance occurred on February 26,1998 when all the corrective actions of these events were i
completed.
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