ML20236W326
| ML20236W326 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 07/31/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Myers L CENTERIOR ENERGY |
| References | |
| 50-440-98-12, NUDOCS 9808050205 | |
| Download: ML20236W326 (2) | |
See also: IR 05000440/1998012
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July 31, 1998
Mr. Lew W. Myers
Vice President - Nuclear
Centerior Service Company
P. O. Box 97, A200-
Perry, OH 44081
SUBJECT:
NOTICE OF VIOLATION (NRC !NSPECTION REPORT 50-440/98012(DRS))
Dear Mr. Myers:
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This will acknowledge receipt of your letter dated July 22,1998, in response to our letter
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dated June 25,1998, transmitting a Notice of Violation associated with the failure to adhere to
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radiation protection requirements at the Perry facility. We have reviewed your corrective
actions and have no further questions at this time. These corrective actions will be examined
during future inspections.
Sincerely,
1
original signed by R.N. Gardner
John A. Grobe, Director
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
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Enclosure:
Ltr dtd 7/22/98 L. Myers
Perry to USNRC
See Attached Distribution
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cc w/o encl:
H. Hegrat, Manager
Regulatory Affairs
T. Rausch, Director, Quality '
and Personnel Development
- R. Schrauder, Director
Nuclear Engineering Department
W. Kanda, General Manager
Nuclear Power Plant Department
N. Bonner, Director, Nuclear
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Mainteitance Department
H. Bergendahl, Director
Nuclear Services Department
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cc w/ encl:
Ohio State Liaison Officer
R. Owen, Ohio Department
of Health
C. Glazer, State of Ohio
Public Utilities Commission
' Distribution:
Project Mgr., NRR w/enci
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J. Caldwell, Rlli w/enci
C. Pederson, Rlll w/onci
B. Clayton, Rlli w/enci
SRI Perry w/ encl
DRP w/ encl
TSS w/enci
DRS w/enct
Rlli PRR w/enci
PUBLIC IE-01 w/enci
Docket File w/enct
GREENS
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July 22,1998
PY-CEl/NRR-2304L
United States Nuclear Regulatory Commission
Document Control Desk
Washington, D.C. 20555
Perry Nuclear Power Plant
Docket No. 50-440
Subject: Reply to a Notice of Violation (NRC Inspection Report No. 50-440/98012)
Ladies and Gentlemen:
Enclosed is the Perry Nuclear Power Plant (PNPP) response to a Notice of Violation documented in
NRC Inspection Report 50-440/98012 (DRS), which was transmitted by letter dated June 25,1998.
Two violations of NRC requirements were identified. In accordance with 10 CFR 2.201, both
violations are being <* ;cepted as written.
If you have questions or require additional information, please contact Mr. Henry L. Hegrat,
Manager-Regulatory Affairs, at (440) 280-5606.
Very t ly yo s,
b
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Enclosure
ec: NRC Region III Administrator
NRC Resident Inspector
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NRR Project Manager
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PY-CEl/NRR-2304L
Enclosure
Page1of4
REPLY TO A NOTICE OF VIOLATION
During a NRC inspection conducted on June 1 - 5,1998, two violations of NRC requirements
were identified. In accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," NUREG-1600, the violations are listed below:
VIOLATION 1
Restatement of the Violation
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10 CFR 20.1902(a) requires that the licensee post each radiation area with a conspicuous
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sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION
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AREA."
Contrary to the above, as of June 2,1998, all access points to the general areas of the 623'
elevation of the Radwaste Building, a radiation area with a radiation dose rate of
approximately 10 millirem in one hour at 30 centimeters from a hose transporting
radioactive materials, were not posted with conspicuous signs bearing the radiation symbol
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and the words " CAUTION, RADIATION AREA." (50-440/98012-01)
This is a Severity Level IV violation (Supplement IV).
Violation 1 is accepted as written.
BACKGROUND
On June 2,1998, a NRC inspector discovered two potential access paths to a radiation area on the
623 foot elevation of the Radwaste Building that were not conspicuously posted. RP personnel -
promptly investigated the subject access paths and placed one additional posting and relocated an-
existing posting to ensure the radiation area was conspicuously posted. An investigation
determined that this area of the Radwaste Building had initially been posted as a radiation area on
April 7,1998, in support of oil separator sludge removal activities. The source of the radiation
was the sludge removal hoses which ran through the central walkway of the Radwaste Building.
The access paths not conspicuously posted were characterized as abnormal entrances to the
radiologically restricted area. The primary access paths to this area were conspicuously posted,
and appropriately designated on RP survey maps of the Radwaste Building. Consequently, the
Radiation Work Permit (RWP) dose limits assigned for entry to the area considered the radiation
levels from the hoses, and personnel dosimetry alarm setpoints would have precluded exceeding
administrative or regulatory dose limits.
REASON FOR THE VIOLATION
The RP technicians did not recognize the additional access paths as potential entryways into the
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radiation area. Also, the responsible supervisors failed to identify the inadequate posting during
the review process.
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PY-CEI/NRR-2304L
Enclosure
Page 2 of 4
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
On June 2,1998, the access path to the Radwaste Supply Fan Room from the Radwaste Control
Room, and the south entrance to the Radwaste Control Room were conspicuously posted as a
radiation area as required by 10 CFR 20.1902(a).
The RP technicians and supervisors were briefed by management during pre-shift briefings
regarding the radiation posting non-compliance, which included management's expectations
regarding posting of radiological areas.
CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS
The following actions are being tracked in accordance with the Corrective Action Program:
The ' lessons learned' from this event will be incorporated into RP personnel continuing and
contractor training, including management's expectations regarding posting of radiological areas.
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RP section management will develop a standing order to institute a peer checking mechanism for
RP technicians to review new and revised radiation area postings. This mechanism will provide
an additional level ot' confidence, thus reducing the probability for error.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance was achieved on June 2,1998, when the access path to the Radwaste Supply Fan
Room from the Radwaste Control Room, and the south entrance to the Radwaste Control Room
were conspicuously posted as a radiation area.
VIOLATION 2
Restatement of the Violation
Technical Specification 5.4.1 requires, in part, that applicable written procedures
recommended in Regulatory Guide 1.33, Revision 2, Appendix A, be established,
implemented, and maintained. Regulatory Guide 1.33, Appendix A, recommends that
procedures covering access control to radiation areas, including a radiation work permit
system, be established and implemented.
Procedure PAP-0512 (Revision 5), " Radiation Work Permit Program," addresses access
control to radiation areas, including a radiation work permit system, and requires, in part,
that radiation workers wear dosimetry specified by the radiation work permit, health
physics personnel, or radiological postings at all times while inside a radiologically
restricted area.
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Radiation Work Permit Nos. 980003 (Revision 0),980047 (Revision 0), and 980051
(Revision 4), specify dosimetry requirements as "M-G DRD" [ electronic dosimeter) and
"TLD" (thermoluminescent dosimeter).
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PY-CEl/NRR-2304L
Enclosure
Page 3 of 4
Contrary to the above, on May 4 - 21,1998, an individual, conducting radiologically
restricted area entries under radiation work permits Nos. 980003,980047, and 980051, did
not wear a thermoluminescent dosimeter. During this period, the health physics statTand
the radiological postings did not provide any exception to weaf.ng a thermoluminescent
dosimeter. (50-440/98012-03)
This is a Severity Level IV violation (Supplement IV).
Violation 2 is accepted as written.
BACKGROUND
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On May 21,1998, it was discovered that an engineering technician had entered a radiologically
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restricted area (RRA) without a thermoluminescent dosimeter (TLD). Upon discovery, the
technician's access to the RRA was restricted and an investigation was initiated. The
investigation determined that on April 28,1998, the technician failed Radiological Controls
Training (RCT). As a result of this failure, the TLD had been removed from technician's site
security badge and written notification of this action was placed with the badge. On April 30,
1998, the technician successfully completed RCT, but failed to obtain a TLD from the radiation
Emtection staff prior to entering the RRA. Between April 30 and May 21, multiple entries were
made into the RRA without a TLD; however, the engineering technician's radiation dose was
being monitored by a Merlin Gerin (MG) electronic dosimeter. Therefore, the potential did not
exist for the technician to receive any unmonitored radiation dose.
REASON FOR THE VIOLATION
The engineering technicir.n failed to verify that the appropriate dosimetry requirements were met
prior to entering the RRA, as required by PAP-0512," Radiation Work Permit Program."
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
The technician was counseled on the importance of using self-checking techniques when entering
the RRA or when performing radiological work.
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CORRECTIVE STEPS TO AVOID FURTHER VIOLATIONS
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The following actions are being tracked in accordance with the Corrective Action Program:
The engineering technician will discuss the lessons learned from this event during a Plant
Engineering section meeting.
Lessons learned from this event will be discussed during continuing training for RP section
personnel, and ir.corporated into PNPP's RCT for all plant personnel.
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DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance was achieved on May 21,1998, when the technician exited the RRA.
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PY-CEI/NRR-2304L
Enclosure
Page 4 of 4
The following identifies those actions which are considered to be regulatory commitments. Any
other actions discussed in this document represent intended or planned actions, are described for the
NRC's information, and are not regulatory commitments. Please notify the Manager - Regulatory
Affairs at the Perry Nuclear Power Plant of any questions regarding this document or any associated
COMMITMENTS
None.
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