ML20236T700
| ML20236T700 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/22/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Patulski S WISCONSIN ELECTRIC POWER CO. |
| References | |
| 50-266-98-12, 50-301-98-12, NUDOCS 9807280342 | |
| Download: ML20236T700 (2) | |
See also: IR 05000266/1998012
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July 22, 1998
Mr. S. A. Patuisk!
Site Vice President
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Point Beach Nuclear Plant.
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'6610 Nuclear Road
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Two Rivers, WI 54241
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-266/98012(DRS);
50-301/98012(DRS))
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Dear Mr. Patuiski:
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This will acknowledge receipt of your letter dated July 13,1998, in response to our letter
L dated June 11,1998, transmitting a Notice of Violation associated with the failure to calibrate
emergency plan self-reading dosimeters in accordance with procedures, and the failure to
control keys for locked high radiation areas in accordance with Technical Specifications. We
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have reviewed your corrective actions and have no further questions at this time. These
corrective actions will be examined during future inspections.
Sincerely,
s/S.A.'Reynoldsj g
John A. Grobe, Director
Division of Reactor Safety
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Docket Nos.: 50-266;50-301
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Enclosure:
.Ltr did 7/13/98 S. Patuiski
Point Beach to USNRC
See Attached Distribution
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cc:
R. Grigg, President and Chief
Operating Officer, WEPCO
M. Sellman, Chief Nuclear Officer
M. Reddeman, Plant Manager
J. O'Neill,'Jr., Shaw, Pittman,
Potts & Trowbridge
K. Duveneck, Town Chairman
- Town of Two Creeks
B. Burks, P.E., Director
Bureau of Field Operations
Chairman, Wisconsin Public
Service Commission
S. Jenkins, Electric Division
Wisconsin Public Service Commission
State Liaison Officer
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Project Mgr., NRR w/enci
C.' Paperiello, Rlll w/enci
J. Caldwell, Rill w/enci
B. Clayton, Rill w/enci
- SRI Point Beach w/ encl
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TSS w/ encl .
DRS (2) w/enci
Rill PRR w/ encl
PUBLIC IE-01 w/enci
Docket File w/o enct
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DOCDESK (E-Mail)
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Scott A. Patutski
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6610 Nuclear Rd.
Two Rivers. WI 54241
Phone 920 755-6214
NPL 98-0576
July 13,1998
Document Control Desk
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U. S. NUCLEAR REGULATORY COMMISSION
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Mail Station PI-137
Washington, DC 20555
Ladies / Gentlemen:
DOCKETS 50-266 AND 50-301
REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION REPORT NOS. 50-266/98012 AND 50-301/98012
POINT BEACII NUCLEAR PLANT. UNITS 1 AND 2
In a letter from Mr. John Grobe dated June 11,1998, the Nuclear Regulatory Commission
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forwarded the results of r. radiation protection inspection conducted by your staff at our Poin'. Beach
Nuclear Plant. The inspection was conducted from May 18-22,1998. The inspection report
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included a Notice of Violation which identified two violations of NRC requirements.
We have reviewed the Notice of Violation and, purswmt to the provisions of 10 CFR 2.201, have
prepared a written response to the two violations requested by your letter of June 11,1998. Our
written response to these violations is included as an attachment to this letter.
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We believe that the attached reply is responsive to the Notice of Violation and fulfills the
requirements identified in your June 11,1998, letter.
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If you have any questions or require additional information regarding this response, please contact
me.
Sincerely,
Sh-
cott . Patulski
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I
ite Vice President
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Point Beach Nuclear Plant
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Attachment
cc:
NRC Resident Inspector
NRC Project Manager
NRC Regional Administrator
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Attachment to NPL 98-0576
Page1
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DOCKETS 50-266 AND 50-301
REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION REPORTS 50-266/98012 AND 50-301/98012
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POINT BEACH NUCLEAR PLANT UNITS 1 AND 2
During an NRC inspection conducted from May 18-22,1998, two violations ofNRC
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requirements were identified. Inspection Reports 50-266/98012 and 50-301/98012 and the
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Notice of Violation (Notice) transmitted to Wisconsin Electric on June 11,1998, provide details
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regarding the violations.
In accordance with the instructions provided in the Notice, our reply to the violation includes:
(1) the reason for the violation, or if contested, the basis for disputing the violation; (2) the
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corrective action taken and the results achieved; (3) corrective action to be taken to avoid further
violations; and (4) the date when full compliance will be achieved.
Violation 1:
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" Technical Specification (TS) No.15.6.11, " Radiation Protection Program," requires, in part,
that radiological control procedures be written and made available to all station personnel, and
shall state permissible radiation exposure levels. The radiation protection program shall meet the
requirements of10 CFR Part 20.
Health Physics Calibration Procedure HPCAL 1.28, a procedure required by TS 15.6.11 requires
in part, that self reading dosimeters (SRDs) will be checked for response (calibration) at the
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following frequencies: prior to initial use, when damage may have occurred and routinely in June
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snd December for the emergency plan SRDs.
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Contrary to the above, as of March 22,1998, two emergency plan SRDs, available for use in
emergency plan sampling kits, were not calibrated in December 1997, and had not been
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calibrated since June 1997 (VIO 50-266/98012-01(DRS); 50-301/98012-01 (DRS).
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This is a Severity Level IV violation (Supplement IV)."
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Resnonse to Violation 1:
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We concur this is a violation of NRC requirements as characterized in the inspection report.
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We performed a detailed review of the March 22,1998, event. In December 1997, Radiation
Protection (RP), in accordance with Emergency Plan (EP) procedures, changed out 603 self-
reading dosimeters (SRDs) in the emergency plan kits. During the changeout, a Radiation
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Protection Technologist (RPT) missed two of the SRDs. Lack of attention to detail by the RPT
was the root cause for this violation. Factors that contributed to the event included the large
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number of SRDs involved, a lack of management oversight of the activity, the storage
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methodology for EP equipment in the EP-designated lockers, the method by which SRD
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changeout is accomplished, and the fact that SRDs were being inventoried by quantity rather
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than by serial number.
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Attar.hment to NPL 98-0576
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The corrective actions taken in response to a previous similar violation were not effective in
preventing recurrence. A review of the previou; corrective actions revealed that we had focused
upon the specified quantity of SRDs needed to meet EP requirements, rather than directing our
focus on the individual SRDs and the physical location where each SRD is stored for EP use.
We also did not provide the additional management oversight needed to ensure that the
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corrective actions taken in response to the previous violation were effective in preventing
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recurrence. Accordingly, the corrective actions taken and planned, as described below, focus
upon the programmatic and process aspects of our SRD calibration program.
Corrective Actions Taken:
1.
The two SRDs identified to be out of calibration were replaced with calibrated SRDs on
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March 22,1998.
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2.
An inventory of all EP SRDs was completed on March 22,1998. No additional SRDs
were discovered to be out of calibration.
3.
In lieu of replacing SRDs on a one-for-one basis, two complete sets of SRDs have been
dedicated to EP so total replacement of SRDs will be accomplished.
4.
The dedicated EP SRDs are now being maintained in a physically separate location to
ensure proper SRD assignment. A new storage locker has been procured for this pu: pose.
5.
Each of the SRDs in the two sets of dedicated EP SRDs was color-coded on
July 10,1998, to improve visual recognition of the SRDs' calibration cycle.
6.
Inventory practices have been changed to control SRDs by serial number and EP kit
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location. In conjunction with the change in inventory practices, overall RP group
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calibration schedules and practices have been reviewed and revised (i.e., levelized) to
permit RP to focus on EP equipment during the months of June and December.
7.
The duties of the RP supervisor responsible for instrumentation have been expanded to
include direct responsibility and accountability for EP SRD changeout and program
oversight.
8.
A management team consisting of the EP and RP staff members has performed a follow-
up verification of the June 1998 EP SRD changeouts which was controlled as outlined in
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Corrective Action 5 above.
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The Quality Verification group performed an independent review of EP SRD changeouts
on June 26,1998.
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Corrective Actions to be Taken:
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There are no additional corrective actions to be taken.
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Attachm:nt to NPL 98-0576
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Date Of Full Comphnee:
Full compliance with NRC requirements was achieved on March 22,1998, when the two out of
calibration SRDs were replaced with calibrated SRDs.
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Violation 2:
" Technical Specification No.15.6.11, " Radiation Protection Program," requires that each
entryway to high radiation areas with dose rates greater than I rem per hour at 30 centimeters
from the radiation source or from any s' rface penetrated by the radiation, but less than 500 rads
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. per hour at I meter from the radiation source or from any surface penetrated by the radiation, be
conspicuously posted as a high radiation area and shall be provided with a locked door or gate
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that prevents unauthorized entry, and, in addition, that all such door and gate keys shall be
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maintained under the administrative control of the shift supervisor, radiation protection manager,
or his or her designee.
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Contrary to the above, on April 27,1998, a key allowing access to high radiation areas having
- dose rates greater than 1 rem per hour at 30 centimeters from the radiation source, but less than
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500 rads per hour at I meter, was not maintained under the control of the shift supervisor,
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radiation protection manager, or his or her designee. Specifically, a key which would allow entry
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into locked high radiation areas was left unattended on a contaminated area step-off pad in the
Primary Auxiliary Building and a locked high radiation area existed on the -5 foot elevation of
the Primary Auxiliary Building (50-266/98012-02(DRS); 50-301/98012-02(DRS)).
This is a Severity Level IV violation (Supplement IV)."
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Response to Violation 2 -
- We concur this is a violation of NRC requirements as characterized in the inspection report.
However, it should be noted for the record that this event occurred on April 24,1998, rather than
on April 27,1998, as indicated in the inspection report. Our investigation of this event revealed
' that on April 24,1998, two Radiation Protection Technologists (RPTs) were assigned to provide
health physics coverage of a boric acid evaporator filter changeout. 'Ihe boric acid evaporator is
located on El. 46' of the primary auxiliary building (PAB). One RPT was inside of the
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' contaminated area of the evaporator while the filter changeout was taking place. The RPT
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. bagged the filter to prevent the spread of contamination and transferred the bag to the second
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RPT, who was outside of the contaminated area.
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The second RPT t 4aspotted the bagged filter to an area on El. 46' called the " pillbox." The
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pillbox is a shielded aru that contains a high integrity container (HIC). This area is posted and
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controlled as a locked High Radiation Area (HRA) and a contaminated area. The second RPT
had protective clothing donned and was in possession of the HRA key. The RPT properly
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disposed of the filter in the HIC and relocked the HIC.
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The dose rate'at the top of the HIC was significantly less than 1 rem /hr. As the RPT was
removing his PCs, he placed the HRA key on the step-off pad inside of the contaminated area.
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Attachment to NPL 98-0576
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He had intended to retrieve the key with a clean glove and then to frisk the key. However, after
exiting the contaminated area and frisking himself, he forgot to retrieve the key. He returned to
the boric acid evaporator filter cubicle, retrieved the air sample that had been taken of the area
and transported the air sample to the counting room. The NRC inspector, who happened to be
performing a routine tour of the radiation control area, observed the unattended HRA key on the
step-off pad. The inspector notified an RP supervisor, who was in the area to observe the wn
changeout, of the discrepancy. The RP supervisor recovered and assumed control of the Hik
key.
A lack of attention to detail was determined to be the root cause for this event. A recent change
to our protective clothing practices may have contributed to the human performance aspects of
the event. Protective clothing practices were recently changed to require full unsuiting when
exiting a contaminated area. We consider this change to be necessary in order to improve our
contamination control program. In the past, an individual exiting a contaminated area would
have placed the HRA key in the pocket of his or her protective clothing, and would have
removed and discarded only booties and gloves.
Subsequent to the event documented as Violation #2 in the inspection report, another event
occurred that involving high radiation area key control. On June 24,1998, at approximately
1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br />, a set of keys on a ring was found laying on a countertop in the RP station directly
below the shift RPT lock box. The keys were immediately placed in the HRA key lock box. It
was subsequently determined that the key ring contained HRA Key #1, and that the identifier for
the key ring had been contaminated and subsequently disposed of the previous shift. Following
decontamination, the key ring and keys were locked in the shift RPT lock box. The NRC
resident inspector was notified of the event at approximately 1535 hours0.0178 days <br />0.426 hours <br />0.00254 weeks <br />5.840675e-4 months <br /> on June 24,1998, with
subsequent notification of NRC Region III representatives at 1539 hours0.0178 days <br />0.428 hours <br />0.00254 weeks <br />5.855895e-4 months <br />.
At the time of this event, the shift RPT lock box contained a number keys that were part of the
corrective actions being taken in response to the first key control event. One of the intended
corrective actions for the first HRA key event was the replacement of common locks with unique
locks for each locked HRA. Implementation of this corrective action had been delayed to ensure
it was not in conflict with existing Operations procedures. The unique keys were placed in the
shift RPT lock box for safe-keeping until implementation of the new key control program.
Our investigation into this event revealed that sometime during the morning of June 24,1998, the
shift RPT lock box had been opened to retrieve another key. It is suspected that the HRA Key #1
ring and keys fell out of the shift RPT lock box onto the countertop. At approximately
1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br />, an RP Supervisor noticed the keys on the countertop and immediately took control
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ofthem.
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This second event was determined to be a violation of Technical Specification 15.6.11. The
event was documented via Condition Report (CR) 98-2520. A root cause evaluation
(RCE 98-145) was performed to fully evaluate this event and to re-evaluate corrective actions
planned, but not yet fully implemented, as a result of the previous Technical Specification
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violation.
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Attachment to NPL 98-0576
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Corrective Actions Tah*=:
In response to the first HRA key violation, the following corrective actions had been
implemented:
1.
'All locked HRAs were inspected on April 24,1998, to ensure they were maintained as
locked.'
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2.
All HRA keys were inventoried and accounted for. This action was completed on
April 24,1998.
3.
Personnel were reminded of their individual responsibilities for control and
accountability of HRA keys. This action was performed on April 25,1998.
4.
Unique locks and keys for each HRA were procured and installed on June 24,1998.
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5.
A tag was placed on each HRA key to reinforce the user of the key of the responsibilities
and expectations associated with use and control of the HRA key on June 24,1998.
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Responsibilities were also assigned to the shift RPT to perform a shiftly key inventory
- and door verification.
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A unique lock was procured and installed on the shift RPT lock box. This key is under
the sole control of the shift RPT. A tag was placed on this key to reinforce the user of the
key of the responsibilities and expectations associated with use and control of the shift
RPT lock box key. These actions were completed on June 24,1998.
18.
Procedure HP.2.6,"High Radiation Area and Radioactive Source Key Control," was
revised and issued on July 9,1998, to reflect implementation of unique keys for each
. HRA. This revision incorporates a section defining individual personnel responsibilities
and management expectations for maintaining positive HRA key control. Additionally,
the procedure revision establishes requirements for an HRA key inventory to be
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doors that have been accessed for entry into HRAs.
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Training on revised procedure HP 2.6 was completed on July 10,1998.
Corrective Aetlans to be Taken:
None
pate of Full Compliance
Full compliance with NRC requirements was achieved on April 24,1998.
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