ML20236H658
| ML20236H658 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 06/30/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| References | |
| 50-331-98-07, 50-331-98-7, NUDOCS 9807070298 | |
| Download: ML20236H658 (2) | |
See also: IR 05000331/1998007
Text
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June 30, 1998
i
Mr. John F. Franz, Jr.
Vice President, Nuclear
IES Utilities, Inc.
200 First Street SE
P. O. Box 351
Cedar Rapids, IA 52406-0351
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-331/98007(DRS))
_
Dear Mr. Franz:
This will acknowledge receipt of your letter dated June 18,1998, in response to our
letter dated May 12,1998, transmitting a Notice of Violation associated with six violations
conceming the failure to properly adhere to radiation protection requirements at the Duane
Amold Energy Facility. We have reviewed your corrective actions and have no further
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. questions at this time. These corrective actions will be examined during future inspections.
Sincerely,
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Original Signed by Gary L. Shear (for)
John A. Grobe, Director
Division of Reactor Safety
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Docket No. 50-331
License No. DPR-49
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Enclosure:
Ltr dtd 6/18/98 J. Franz
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Duane Amold to USNRC
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cc w/o encl:
L. Root, President and
Chief Operating Officer
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G. Van Middlesworth
Plant Manager
K. Peveler, Manager
Regulatory Performance
cc w/ encl:
Chairperson, Iowa Utilities Board
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Alliant Uuhues
200 First Street sE
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Omce: 319.398 4411
www a!!iant-energy.com
June 18,1998
NG-98-1010
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Station PI-37
Washington, D.C. 20555-0001
Subject:
Duane Arnold Energy Center
Docket No: 50-331
Op. License No: DPR-49
Reply to a Notice of Violation Transmitted with Inspection Report 98007
File:
A-105, A-102
Dear Sir:
This letter and attachment are provided in response to the Notice of Violation transmitted
with NRC Inspection Report 98007. As per discussions with Region III, this response is
being submitted one week past the original due date.
In addition to the specific corrective actions discussed in the attached Reply to a Notice of
Violation, several other actions to further enhance performance in the Radiation Protection
area have been taken. The:e include increased Radiation Protection staff participation in the
Job Observation program, implementation of daily meetings between Radiation Engineering
)
staff and Health Physics staff, re-enforcement of management's expectations for use of the
corrective action program for personnel adherence to radiological controls, and re-
{
enforcement of expectations for strict compliance to radiological work requirements to all
site personnel.
These actions are intended to correct recently identified weaknesses
concerning Radiation Protection performance.
The following new commitments are being made in this letter:
Revise the procedure writers guide to require RP department review of new or revised
surveillance test procedures if the new procedure or procedure change could result in
the possibility of changing plant radiological conditions by October 1,1998.
Revise the Surveillance Test Procedure 46G034CY," Low Pressure Coolant Injection
Inject Check Valve Full Flow Test," to restrict access to the reactor building
northwest comer room, southeast comer room and affected areas of the torus room
and post those areas as high radiation areas prior to the performance of the test by
October 1,1998.
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June 18,1998
NG-98-1010
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Page 2 of 2
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Re-enforce the definitions of" Positive Health Physics Control,"" Continuous Health
Physics Coverage," and " Continuous Health Physics Monitoring," b'y September 1,
1998.
Review HPP 3104.07, " Diving Operations Within Radiological Areas," procedure
with respect to Industry Events that pertain to diving events, INPO 91-014, and
Significant Event Reports, and determine the appropriate job coverage requirements
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with respect to RG 8.38 and Information Notice 97-68 and revise procedures as
needed by September 1,1998.
Revise HPP 3104.07," Diving Operations Within Radiological Areas," to require the
appropriate radiological posting at the ladder to the torus water by October 1,1998.
Complete a review of training provided to incoming craft workers and contract RP
technicians concerning LHRA entries and take appropriate actions as necessary by
October 1,1998.
1
Complete a review of other chemistry department re-qualification tracking
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mechanisms and take appropriate actions as necessary by October 1,1998.
If you have any questions regarding this matter, please feel free to contact my office.
Sincerely,
!
I
ohn F.
an
Vice President, Nuclear
Attachment: Reply to a Notice of Violation Transmitted with Inspection Report 98007
cc:
R. Murrell
E. Protsch
D. Wilson
R. Laufer(NRC-NRR)
.G Paperiello-(RegfotrIII)-
NRC Resident Office
DOCU
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Attachment to
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NG-98-1010
Page 1 of 12
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IES Utilities Inc.
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Reply to a Notice of Violation
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Transmitted with Inspection Report 98007
VIOLATION 1:
10 CFR 20.1501(a) requires that each licensee make or cause to be made surveys that may be
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necessary for the licensee to comply with the regulations in Part 20 and that are reasonable
under the circumstances to evaluate the extent of radiation levels, concentrations or quantities
of radioactive materials, and the potential radiological hazards that could be present.
Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and
potential hazards incident to the production, use, transfer, release, disposal, or presence of
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radioactive material or other sources of radiation.
Contrary to the above, on April 4,1998, the licensee did not make surveys to assure
compliance with 10 CFR 20.1902(b), which describes the posting of high radiation areas.
Specifically, the licensee failed to adequately evaluate the radiological hazards incident to the
April 4,1998, low pressure coolant injection system full flow testing. The testing resulted in
radiation levels in the reactor building exceeding 100 millirem per hour in areas that were not
posted as high radiation areas.
This is a Severity Level IV Violation.
RESPONSE TO VIOLATION 1:
1.
REASON FOR THE VIOLATION
On April 4,1998, Surveillance Test Procedure 46G034CY, " Low Pressure Coolant
Injection (LPCI) Inject Check Valve Full Flow Test," was conducted. The purpose of
the test was to exercise the LPCI injection check valves to the full open and closed
position. The STP satisfies the ASME inservice testing requirements for the LPCI
inject check valves. The plant conditions for the test consisted of operating three
Residual Heat Removal (RHR) pumps through a single inject line for approximately
10 to 15 minutes. This method of satisfying the ASME requirements for the LPCI
inject check valves was a new test that had not been performed previously. Prior to
the performance, the test was planned and communicated to the appropriate plant staff
via plant meetings and the published outage schedule.
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After completion of the test (=1 hour), plant personnel in the affected areas identified
elevated radiation levels. These unexpected increases in area radiological dose rates
were promptly communicated to the appropriate Radiation Protection (RP) staff. A
review of this situation has determined the cause to be failure to adequately evaluate
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Attachment to
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NG-98-1010
Page 2 of12
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the effect of operational changes on radiological conditions within the plant as a result
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of pqrforming the LPCI full flow test.
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2.
CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED
As a result of the unexpected elevated radiation levels, immediate actions were taken
to restrict access to the affected areas and HP technicians were dispatched to perform
surveys of the affected areas. The resultant surveys indicated increased dose rates of
100 - 200 millirem per hour in the torus room and areas of the reactor building
southeast comer room. Consequently, the RP staff established high radiation area
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(HRA) boundaries and postings in the affected areas. A review of personnel dose
rate monitors of those in the areas affected determined that no unplanned exposures
resulted from the unexpected increase in area radiation levels.
To limit the increase in dose rates, the RHR system was operated with only one RHR
pump. The chemistry staff performed isotopic analysis of the reactor coolant which
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indicated a significant increase in the quantity of insoluble radioactive corrosion
products. Based on the chemistry analysis it was detennined that the elevated dose
rates were a result of an unexpected crud release from the vessel.
On April 6,1998, the RHR system was operated in a two pump configuration which
discharged through the common cross-tie into the 'B' recirculation loop. This
resulted in the system being flushed of the radioactive corrosion products and
subsequently, lowering the dose rates in the affected areas.
A solutions team was formed to thoroughly evaluate this issue and take action. Asa
result, it has been concluded that the exact mechanism causing the crud release is un-
identified, but it was related to operating the RHR pumps in the above stated new
configuration.
3.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
As a result of the failure to fully understand the radiological effect of the evolution
discussed above, actions have been initiated to revise the procedure writers guide to
require RP department review of new or revised surveillance test procedures if the
new procedure or procedure change could result in the possibility of changing plant
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radiological conditions. This will allow for determining possible controls necessary
to preclude a similar occurrence. These actions will be completed by October 1,
1998.
STP 46G034CY, " Low Pressure Coolant injection Inject Check Valve Full Flow
Test," will be revised to restrict access to the reactor building northwest comer room,
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NG 98-1010
Page 3 of 12
southeast corner room and affected areas of the torus room and post those areas as
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high radiation areas prior to the performance of the test by October 1,1998.
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Additionally, a Training Management Action Request (TMAR) has been initiated to
incorporate a review of this issue into RP and Operations continuing training. These
reviews will be completed by December 31,1998.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
1
Full compliance was achieved on April 4,1998, with the completion of the
radiological surveys and subsequent re-postings of the affected areas.
VIOLATION 2-A:
Technical Specification 6.9.1 requires, in part, that procedures for personnel radiation
protection be prepared consistent with the requirements of 10 CFR Part 20 and be adhered to
for all operations involving personnel radiation exposure.
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A.
Procedure ACP 1411.22 (Revision 6)," Control of Access to Radiological Areas,"
requires, in part, that personnel entering radiation areas and high radiation areas
)
obtain a radiation work permit, review the radiation work permit, and follow the
instructions and requirements set forth.
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Radiation Work Permit (RWP) 50380 Job Step 6 (Revisions 6 and 7) requires that if
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the ability to monitor dose rates is lost, the work be stopped until the monitoring can
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be reestablished.
Contrary to the above, on April 7-10,1998, the licensee performed diving evolutions
in the torus, a high radiation arca, under Radiation Wor' Permit 50380 Job Step 6,
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lost the ability to monitor dose rates, and did not stop the work until monitoring was
reestablished.
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This is a severity Level IV Violation.
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RESPONSE TO THE VIOLATION 2-A:
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1.
REASON FOR THE VIOLATION
During Refueling Outage (RFO) 15, several activities were underway in the torus that
required diving activities. These included Emergency Core Cooling System suction
strainer replacement and torus coating inspection and repair if needed.
These
activities were performed under a common ALARA Review (No.98-006) and RWPs
50380 and 50580. The RWPs required continuous monitoring (remote dosimetry) to
ensure that the divers' accumulated doses and dose rates were adequately controlled.
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NG-98-1010
Page 4 of12
However, the remote dosimetry telemetry hardware could not be configured to
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provide continuous monitoring. Specifically, due to inadequate telemetry signal, the
Electronic Dosimeters (EDs) used could not transmit the dose rates to the Health
Physics (HP) technicians once a diver submerged in the torus and therefore, prevented
continuous monitoring. As a result, the HP technicians established stay times for the
divers, which they incorrectly concluded was an equivalent for continuous
monitoring. Based on the anticipated radiation levels in a particular area, the HP
technician determined a stay time from 30 to 120 minutes depending upon the local
dose rates. This proved to be c.n adequate means of controlling exposures. However,
RWP 50380 job step 6 and RWP 50580 job step 5, stated that if the ability to monitor
dose rates was lost, work would be stopped until monitoring could be established.
The HP technician did not maintain continuous monitoring of the divers and
subsequently stop diving activities. Diving activities without full compliance with the
RWPs existed from April 7 to April 11,1998.
The reason for the violation is failure to properly adhere to the full RWP
requirements. The RWP was not properly adhered to due to a misunderstanding of
the definition of" Continuous Health Physics Monitoring" as it applied to the torus
divingjob.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
Upon discovery of the RWP non-compliance, the RWP was revised to clearly indicate
the method of dose tracking of the divers.
3.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
The following additional corrective actions are currently underway to improve the RP
department adherence to RWP requirements and improve RWP planning:
1. Re-enforce the definitions of " Positive Health Physics Control," " Continuous
Health Physics Coverage," and " Continuous Health Physics Monitoring," by
September 1,1998. This action will insure HP technicians fully understand their
responsibilities for RWP adherence.
2. Review HPP 3104.07, " Diver Operations Within Radiological Areas," procedure
with respect to Industry Events that pertain to diving events, INPO 91-014, and
Significant Event Reports, and determine the appropriate job coverage
requirements with respect to RG 8.38 and Information Notice 97-68 and revise
procedures as needed by September 1,1998.
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Page 5 of12
4..
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full compliance was achieved on April 11,1998 with the revision to the applicable
RWPs.
VIOLATION 2-B:
Technical Specification 6.9.1 requires, in part, that procedures for personnel radiation
protection be prepared consistent with the requirements of 10 CFR Part 20 and be adhered to
i
for all operations involving personnel radiation exposure.
B.
Procedure ACP 1411.22 (Revision 6)," Control of Access to Radiological Areas,"
requires, in part, that personnel entering high radiation areas obtain a radiation work
permit, review the radiation work permit, follow the instructions and requirements set
forth, and obtain a briefing by health physics personnel prior to entering the
area.
Radiation Work Permit No. 52 Job Step 1 (Revision 6), Routine Work &
Inspections in ras," requires, in part, that the user not enter high radiation areas.
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Contrary to the above:
(1)
On April 1,1998, two workers performed an evolution under Radiation Work
Permit No. 52 Job Step 1 and entered a high radiation area on the 780'
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elevation of the turbine building.
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(2)
On April 1,1998, two workers entered a high radiation area on the 780'
elevation of the turbine building and did not receive a briefing by health
physics personnel prior to entering the area.
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This is a severity Level IV Violation.
RESPONSE TO THE VIOLATION 2-B:
1.
REASON FOR THE VIOLATION
On April 1,1998, during preparations for an upcoming RFO, a decision was made to
move equipment from a radiation area (RA) of the turbine deck to an adjacent locked
high radiation area (LHRA). Prior to performing the job, information was given to
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the contract foreman for the job regarding the radiological conditions of the job.
However, the two workers who were assigned to completu the LHRA did not receive
an RP pre-job briefing. A contract HP technician was originally assigned to provide
the HP coverage and pre-job briefing. After discovery that this HP was not qualified
to receive LHRA keys, a separate technician was sent to cover the work without
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Attachment to
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Page 6 of12
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initially briefing the workers. Due to delays in preparations for thejob, the contract
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forerpan selected a different job for the originally assigned personnel. When all
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preparations were completed for thejob, two other contract workers were assigned to
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the movement of the equipment from the RA to the LHRA. The workers then-
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proceeded directly to the LHRA outer control point. The HP technician incorrectly
assumed that the workers had obtained the proper pre-job briefing and were on the
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correct RWP. The HP technician questioned the two workers as to whether they were
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assigned to the job and they replied in the positive. The workers involved failed to
identify the need to sign-on and comply with the RWP for the job to be performed in
the LHRA.
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During the job, continuous HP coverage was provided by the HP technician present.
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After the job was complete, it was determined that the workers EDs had alarmed on
dose rate and the workers were on the wrong RWP. A review of the exposure
received by the workers indicated that the workers received a dose well below that of
the co Tect RWP maximum exposure. - As a result, a fact finding meeting was
conducted to determine the cause of the incident. The thorough review conducted as
part of the fact finding meeting determined the following:
1) Prior to the LHRA entry, the two workers had not obtained a pre-job briefing with
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the HP staff as required by Administrative Control Procedure (ACP) 1411.22.
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2) The HP technician who covered the evolution failed to ensure that the workers
were properly briefed for thejob and were authorized to enter the LHRA.
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3) The two workers involved failed to follow the requirements of the RWP for entry
into the turbine area LHRA.' This was failure to follow the requirements of ACP
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1411.22.
The cause of the two examples of the violation are failure to follow procedures as a
result of a lack of attention to detail
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2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
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A fact finding meeting was conducted with all personnel involved and Duane Arnold
Energy Center (DAEC) management.
Appropriate personnel involved were
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counseled on th,e RP requirements for high radiation area entries.
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As a result of this and other human performance events that occurred early in the
RFO, a plant wide stand-down was held to re-enforce management expectations
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conceming procedure adherence, questioning attitude, and the need to properly self
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check.
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Page 7 of 12
Administrative Control Procedure (ACP) 1411.13, " Control Of LHRA's," has been
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revised to include the following specific guidance concerning LHRA control:
The entry to the area shall be controlled at all timesfrom the outside, when the
LHRA door is open and can not be locked.
You must not leave the area
unattended at any time with the door open and unlocked.
Only quahfied and authorized personnel are permitted in the area (LHRA
Authorization List)
a) You must verify they are on an approved RWPfor LHRA entry,
b) You must verify that they have received a pre-job briefing.
c) You must verify that they know the radiolcrgical conditions in the area.
Additionally, all HP technicians were briefed on this event and the associated
procedure changes.
3.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
A review of training provided to incoming craft workers and contract HP technicians
concerning LHRA entries will be conducted and actions taken as necessary by
October 1,1998.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on April 1,1998, when it was determined that the
workers did not receive any dose that would have exceeded the limitation of the
appropriate RWP for the HRA work, and therefore, meeting the intent of the RWP.
VIOLATION 2-C:
Technical Specification 6.9.1 requires, in part, that procedures for personnel radiation
protection be prepared consistent with the requirements of 10 CFR Part 20 and be adhered to
for all operations involving personnel radiation exposure.
C.
Procedure ACP 1411.22 (Revision 6)," Control of Access to Radiological Areas,"
requires, in part, that personnel entering high radiation areas obtain a radiation work
permit, and follow the instructions and requirements set forth.
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Page 8 of12
Radiation Work Permits Nos. 40010 Job Step 6 (Revision 3),33 Job Step 1 (Revision
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4) 53 Job Step 1 (Revision 6),10230 Job Step 1 (Revision 6), and 10051 Job Step i
(Revision 3) require, in part, that the user wear an electronic dosimeter!
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Contrary to the above:
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. (1)
On April 4,1998, a member of the operations staff entered the drywell, a
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posted high radiction area, under Radiation Work Permit No. 40010 Job Step
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6 (Revision 3) and did not wear an active electronic dosimeter.
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(2)
On April 5,6, and 8,1998, three individuals entered radiation areas under
Radiation Work Permits Nos. 33 Job Step 1 (Revision 4),53 Job Step 1
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(Revision 6), and 10230 Job Step 1 (Revision 6) and did not wear an active
electronic dosimeter.
(3)
On April 8,1998, an individual traversed the reactor building, a radiation area,
under Radiation Work Permit 10051 Job Step 1 (Revision 3) and did not wear
an active electronic dosimeter.
(4)
On April 14,1998, two individuals entered areas of the turbine and reactor
buildings, posted radiation areas, but the individuals had not obtained a
radiation work permit.
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This is a severity Level IV Violation.
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RESPONSE TO THE VIOLATION 2-C:
1.
REASON FOR THE VIOLATION
During RFO 15 several issues surrounding the use of EDs occurred. The reason for
the above discussed violations is failure to follow procedure. The cauces of the
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procedural non-compliance's has been attributed to less than adequate attention to
detail.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
Upon discovery, all the above examples were entered into the corrective action
process. Actions were taken to determine actual doses received. All doses were
within the amounts allowed by the applicable RWPs. All personnel involved were
counseled by management. Additionally, a person was temporarily assigned as a
' guard' at Turbine Building access to verify that all personnel entering the power
. block had an activated ED.
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Attachment 12
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NG-98-1010
Page 9 of12
A contributing factor to the above failure to follow procedure violations was the fact
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that an installed gate at access control (gate prevents access to the power block
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without an ED) was temporarily out of service without compensatory actions in place.
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Therefore, compensatory actions have been established to require a guard at the gate
if the gate is deactivated in the future. The purpose of this guard is to ensure that
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personnel entering the power block have an activated ED.
As a result of this and other human performance events that occurred early in the
RFO, a plant wide stand-down was held to re-enforce management expectations
conceming procedure adherence, questioning attitude, and the need to properly self
check.
3.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
All corrective actions to prevent recurrence have been taken.
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
Full compliance was achieved on April 14, 1998 when the dose received by the
personnel involved was determined to be below that specified in the applicable RWPs
and therefore meeting the intent of the RWPs.
VIOLATION 3:
10 CFR 20.1902(b) requires that the licensee post each high radiation area with a
conspicuous sign or signs bearing the radiation symbol and the words " Caution, High
Radiation Area" or" Danger, High Radiation Area."
Contrary to the above, on April 8-10,1998, the torus, a high radiation area with a dose rate of
approximately 600 to 800 millirem in one hour at 30 centimeters from filtration units, was
not posted with a sign bearing the radiation symbol and the words " CAUTION, HIGH
RADIATION AREA"OR" DANGER, HIGH RADIATION AREA."
This is a severity Level IV Violation.
RESPONSE TO VIOLATION 3:
I.
REASON FOR THE VIOLATION
The torus recoat project has been performed routinely for several cycles. During RFO
14 (October,1996) the issue of requiring a posting at the ladder to the torus was
discussed and reviewed. At that time,it was concluded that the exceptions to posting
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Attachment to
NG-981010
Page 10 of12
requirement found in 10 CFR 20.1903 applied to the conditions observed in the torus.-
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Specifically,10 CFR 20.1903 states that,
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'(a) A licensee is not required to post caution signs in areas or rooms containing
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radioactive materials for periods of less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, if each of the following
conditions is met:
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(1) ~ The materials are constantly attended during these periods by an
individual who takes the precautions necessary to prevent the exposure of
individuals to radiation or radioactive materials in excess of the limits
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establishedin thispart; and
(2) The area or room is subject to the licensee's control
The conditions in the torus were such that the water was only considered accessible
when the divers were dressed and ready to enter the water which started the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
clock. When the dive was secured (which is less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />), the area was
considered inaccessible and the posting requirement and/or exemption no longer
applied.
A log entry was made in 1996 stating the conclusion that the posting practice and
_.
controls in place were acceptable. This guidance was placed in the RWP folder for
the.1998 torus work by.the HP technician who performed the coverage in 1996.
When the potential posting discrepancy was identified by a contract HP technician in -
1998, the guidance given was to post the ladder going into the water. The basis for
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this guidance was that the diving operations took place over several shifts, not just
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day shift as had been the practice in previous outages. The reason for the violation is
the failure to recognize the limitations of 10 CFR 20.1903 exception (specifically, the
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8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> clause) and the use of past guidance which did not apply in this case.
In addition, follow-up conversations with the NRC have indicated that NRR does not
concur that the 10 CFR 20.1903 exemption applies in the conditions described above,
and there are no documented positions in NUREG/CR-5569, Health Physics Positions
Data Base regarding interpretation of 10 CFR 20.1903. As such, a contributing factor
may be that DAEC supervision mis-applied the exemption found in 10 CFR 20.1903.
2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
The ladder to the torus was properly posted as an HRA on April 10,1998.
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Attachment 13
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NG-98-1010
Page 11 of12
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
)
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HPP 3104.07," Diving Operations Within Radiological Areas," will be revised to
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require the appropriate radiological posting at the ladder to the torus water by October
1,1998.
4.
DATE WHEN FULL COMPLI ANCE WILL BE ACHIEVED
,
Full compliance was achieved on April 10,1998 with the proper posting of the HRA.
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VIOLATION 4:
Technical Specification 6.4.1 requires that a training program be established to maintain the
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overall proficiency of the operating organization, which consists of both retraining and
replacement training elements, and meet or exceed the minimum provisions outlined in
ANSI /ANS 3.1-1978.
Section 5.1 of ANSI /ANS 31.-1978 requires, in part, that a continuing training program be
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used for requalification training necessary to ensure that personnel remain proficient.
Procedure PCP 1.2 (Revision 9), "DAEC Chemistry Quality Control Program," requires, in
part, that each chemistry technician perform post accident sampling system surveillance test
procedures at least once every 2 years to remain qualified on the post accident sampling
system.
Contrary to the above, as of April 14, 1998, three chemistry technicians, who were
designated to operate the post accident sampling system (PASS), had not performed the post
accident sampling system surveillance tests since June 12,1995, November 17,1995, and
November 21,1995, respectively.
This is a severity Leve! IV Violation.
RESPONSE TO VIOLATIQN_41
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1.
REASON FOR THE VIOLATION
Chemistry technicians are required, by procedure PCP 1.2 to perform PASS
surveillance test procedures at least once every 2 years to remain qualified on the
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PASS. This fbifills the training requirements of commitments made to NUREG
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0737. Training records associated with the performance of the surveillance tests was
tracked in the chemistry foremen laboratory notebook. However, in April 1998, it
was determined that three chemistry technicians had not performed the required
PASS surveillance tests over the last two years and therefore, were not qualified on
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Attachment to
NG-981010
Page 12 of 12
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the PASS. The cause for this violation is less than adequate tracking of training re-
qualifications.
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2.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED
The qualifications of the three affected chemistry technicians on the PASS system
were suspended. A Training Management Action Request (TMAR) was initiated to
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develop an appropriate tracking mechanism for chemistry qualifications in regards to
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PASS.
This TMAR established a formal matrix for scheduling and tracking
chemistry technician qualifications for PASS. Additionally, the training has been
enhanced to require the performance of the PASS surveillance tests to be observed by
a member of the training department or a qualified chemistry foremen.
3.
. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER
VIOLATIONS
A review of other chemistry department re-qualification tracking mechanisms will be
conducted and appropriate actions taken as necessary by October 1,1998.
,
4.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
,
Full compliance was achieved on April 9,1998, when the qualification of the three
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affected chemistry technicians on the PASS system were temporary suspended.
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