ML20236V800
| ML20236V800 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/28/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-338-98-03, 50-338-98-3, 50-339-98-03, 50-339-98-3, 98-403, NUDOCS 9808040215 | |
| Download: ML20236V800 (8) | |
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e VIRGINI A EuccriuC ANI) POWE R COW'A N Y Ricsim>Nin, Vino:Nir 232r,1 July 28, 1998 U. S. Nuclear Regulatory Commission Serial No.98-403 Attention: Document Control Desk NAPS /JHL R2 Washington, D. C. 20555 Docket Nos.
50-338 50-339 License Nos.
NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPAlf NORTH ANNA POWER STATION UNITS 1 AND i INSPECTION REPORT NOS. 50-338/98-03 MJD 50-339/98-03 REPLY TO A NOTICE OF VIOLATION We have reviewed your letter of June 29,1998, which referred to the inspection
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conducted at North Anna Power Station from April 19,1998 through May 30,1998, and l
the associated Notices of Violation which were reported in Inspection Report Nos. 50-l 338/98-03 and 50-339/98-03. Our reply to the Notices of Violation is attached.
in the letter transmitting the Notice of Violation, concern was expressed regarding a
personnel errors, including a failure to correctly perform an independent verification.
Personnel errors are always of a concern to us and, in particular, those involving inadequate independent verification. The individuals involved in this violation have received remedial training and the lessons learned were discussed with the Operations Department.
No new commitments are intended as a result of this letter. If you have any further l
questions, please contact us.
Very truly yours, k\\
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James P. O'Hanlon Senior Vice President - Nuclear Attachment 4
9008040215 900728 PDR ADOCK 05000338 G
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' U. S.' Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station I
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REPLY TO NOTICES OF VIOLATION INSPECTION REPORT NOS. 50-338/93-03 AND 50-339/98-03 NRC COMMENT During an NRC inspection conducted on April 19 through May 30,1998, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
A.
Technical Specification 6.8.1 requirer in part, that written procedures be established, implemented and maintained covering the activities referenced in the applicable procedures recommended in Appendix A of NRC Regulatory Guide 1.33, Revision 2,1978. Paragraph 1.c of Appendix A to Regulatory Guide 1.33 requires procedures for equipment control (e.g., tagging).
Tagging record 2-98-RH-0003 for the Unit 2 Residual Heat Removal System required the Reactor Water Storage Tank Line Drain Valve 2-RH-53 to be opened with a red danger tag attached and independently verified by a second operator.
Contrary to the above, on April 13,1998, tagging record 2-98-RH-0003 was not properly implemented. An operator opened and placed a red danger tag on Outside Recirculation Spray Pump Drain Valve 2-RS-53 instead of valve 2-RH-
- 53. In addition, a second operator who performed the independent verification function failed to identify that the wrong valve had been opened and tagged.
This is a Severity Level IV violation (Supplement 1).
B.
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented and maintained covering the activities referenced in the applicable procedures recommended in Appendix A of NRC Regulatory Guide 1.33, Revision 2,1978. Paragraph 7.e of Appendix A of NRC Regulatory Guide 1.33 states that the licensee should have written radiation protection procedures.
10 CFR 20.1501 requires that each licensee shall make or cause to be made, surveys that (1) may be necessary for the licensee to comply with the regulations I
and (2) are reasonable under the circumstances to evaluate (i) the extent ef radiation levels, (ii) concentrations or quantities of radioactive material, and (iii) the potential radiological hazards that could be present.
Virginia Power Administrative Procedure VPAP-2101, " Radiation Protection Program," Revision 12, Section 6.6.9.a, specifies that equipment and material exiting a radiation control area shall be surveyed to minimize the potential spread of contamination and to assure contaminated material will not be inadvertently released to uncontrolled areas. Section 6.6.9.a.1 further specifies that items that are being free released from the radiation controlled area shall be monitored for radioactive contamination and that no item may be released for unrestricted use if monitoring indicates the presence of contamination.
Contrary to the above, on April 27, 1998, the licensee failed to perform an adequate survey of a camera prior to releasing the camera from the radiation controlled area, in that, the survey that was performed failed to detect the presence of radioactive contamination on the camera.
This is a Severity Level IV violation (Supplement I).
I REPLY TO NOTICE OF VIOLATION A 1.
REASON FOR THE VIOLATION The reason for the vioW on was personnel error on the part of the operators involved in the tagout of drain valve 2-RH-53.
The operator performing the equipment tagout failed to accurately identify and l
place the tagout on the proper component.
The operator performing the l
independent verification function failed to identify and correct the tagout error. In both cases the operators did not place enough emphasis on attention to detail i
during the tagging evolutions.
Circumstances pertaining to the event are provided below.
On April 13,1998, an operator was dispatched to tagout drain valve 2-RH-53.
The tagout was inadvertently placed on drain valve 2-RS-53. A second operator was dispatched to perform an indepedent verification that the tagout had been correctly performed.
The operator performing the independent verification function did not identify that the tagout was placed on the incorrect component.
On April 18,1998, an operator was dispatched to clear the tagout from 2-RH-53.
When the operator arrived at 2-RH-53, the valve was closed, the pipe cap was installed and there was no danger tag on the valve. This was noted on the working copy of the tagging record. The operator reported this condition to his supervisor. Another operator was dispatched to 2-RH-53 to independently verify that the tagout was removed, the valve was closed and the pipe cap was installed.
On April 27,1998, operators were preparing for the performance of periodic test 2-PT-64.1.1, Outside Recirculation Spray Pump 2-RS-P-2A and discovered that drain valve 2-RS-53 was danger tagged open with a tag that was intended for 2-RH-53.
The operators brought the discrepancy to the attention of their supervisor. Research was performed to ensure that the tagout was no longer i
active. The tagout was subsequently cleared.
A contributor to the tagout error was the similarity of mark numbers and the physical location of the drain valves. Mark numbers 2-RS-53 and 2-RH-53 are very similar. Further, these drain. valves are located in the Unit 2 Safeguards Building approximately ten feet apart from each other.
2.
, CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 3
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The tag-out for 2-RH-53 that was inadvertently placed on 2-RS-53 was verified f
as no longer being active and the tag was cleared. 2-RS-53 was closed and a J
pipe cap was installed. A station deviation report was initiated to document the event.
The operators involved in the event received disciplinary action. The operators were also provided remedial training at the tagging laboratory to reinforce proper tagging and independent verification techniques.
The lessons learned were discussed with the Operations Department.
In addition, the lessons learned from this event were incorporated into Licensed Operator Requalification Program (LORP) training.
A drawing change request has been implemented to change the mark number designation of 2-RH-53 to 2-RH-61 because valves 2-RH-53 and 2-RS-53 have only one letter difference in their mark number and the valves are located approximately ten feet apart. This will minimize the likelihood of similar human performance events with these valves in the future.
3.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.
4.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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j REPI Y TO NOTICE OF VIOLATION B 1.
REASON FOR THE VIOLATION The reason for the violation was personnel error.
On May 4,1998, operations personnel contar5d the ALARA group to check out a camera to take photographs at Surry Power Station. An ALARA Technician agreed to meet the operations personnel outside the Security Building with a camera. When the technician reached the Security Building, the camera was given to another employee who was proceeding through the exit portal
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contamination monitor.
The camera was subsequently placed in a briefcase and taken to Surry. The following morning, a Health Physics Technician at Surry placed the camera in a radiation monitor before the operations personnel entered the radiological controlled area (RCA) with the camera.
The monitor alarmed and further surveys of the camera were performed. An area of fixed contamination of 8000 2
dpm/20 cm was identified on the camera strap.
Follow-up surveys of the operations personnel and the briefcase used to transport the camera indicated no contamination.
North Anna's RCA unrestricted release procedures (i.e., procedure HP-1032.040, Contamination Surveys) and policies require that released items be frisked using a RM-14 monitor with a pancake probe or tool monitor at the personnel decontamination area. Final release of an item from the RCA must be completed and confirmed with the RM-14 or SAM-9 as specified by step 6.5 of HP-1032.040. HP-1032.040, step 6.5 permits small hand carried items, except for hand tools, to be monitored by the worker. The procedure does not require hand carried items be logged on the Unrestricted Release Survey Log.
A definitive release date and time could not be established for release of the camera from the RCA because there was no requirement to log the information.
Therefore, it is not conclusively known how or when the camera was contaminated.
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2.
. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The camera was secured and returned to North Anna Power Station where it was properly decontaminated.
The contamination survey procedure has been enhanced to add an additional method of monitoring. If a piece of equipment or item is suitable for monitoring with the SAM-9 radiation monitor (i.e., fits inside the monitor) then the monitor will be used prior to release. Currently there are SAM-9 monitors at the main exit of the radiological control area.
To enhance personnel knowledge, this event has been included in Health Physics continuing training.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER I
VIOLATIONS No further corrective actions are required.
4.
THE DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED j
Full compliance has been achieved.
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