ML20246D255
| ML20246D255 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 07/03/1989 |
| From: | Trevors G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CNSS896747, NUDOCS 8907110271 | |
| Download: ML20246D255 (3) | |
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'U. S. Nuclear Regulatory Commission Attention: Document Control Desk
-Washington, DC -20555
Subject:
NPPD Response to Notice of Violation - NRC Inspection Report No. 50-298/89-16 Gentlemen:
This letter is written in response to your letter dated June 5,.1989, transmitting Inspection Report 50-298/89-16. Therein you indicated that certain of-our activities were in violation of NRC requirements.
'Fc11owing is a statement of the violation and our. response in accordance with 10CFR2.201.
STATEMENT OF VIOLATION Failure To Follow Procedures TS 6.3.4 requires that " Radiation Control Procedures'shall be maintained and made available to all station personnel.- These procedures shall show permissible radiation exposure, and shall be consistent with the requirements of 10CFR20."
-Health Physics Procedure 9.2.3.Section VIII.B.1 requires an instrument and/ smear survey prior to removal of equipment and tools from a controlled area.
Contrary to the above, the NRC inspector observed, on May 4, 1989, an individual pass a section of electrical conduit from a controlled area in the Residual Heat Removal Heat Exchanger Room A to an individual outside the controlled area without first performing or having performed a survey to determine the level of radioactive contamination on the conduit.
' Additionally, the NRC inspector observed, on the same day, unsurveyed sections of steel hangers which were partially removed from the controlled area in Residual Heat Removal Heat Exchanger Room B.
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U.S.' Nuclear Regulatory Commission July 3, 1989 Page 2 REASON FOR THE VIOLATION NPPD agrees that the events described in this violation occurred as written.
Both events were the result of poor judgement and inadequate attention to detail by the contractor craft personnel involved. The individuals involved with the first event (Residual Heat Removal Heat Exchanger Room A) were interviewed on May 4, 1989, by the CNS Health Physics Supervisor.
The individuals acknowledged awareness of the radiological survey requirements necessary for removing equipment from a contaminated area, as emphasized in General Employee Training (GET). The individual (s) involved with the second event could not be identified. However, it can be assumed that they were also aware of the radiological survey requirements necessary for removing equipment from a contaminated area, since successful completion of GET is required for all personnel prior to entering a contaminated area.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The individuals involved in the first event were immediately restricted from handling radioactive material and working in radiologically contaminated areas until such time as they had been counseled by the Health Physics Supervisor and had successfully completed remedial GET - Radiation Protection. These actions were completed by May 10, 1989, at which time the individuals were allowed to return to working in radiologically contaminated areas.
Regarding the second event, the Health Physics Supervisor reviewed this event with the Health Physics Staff on May 5, 1989.
This review precipitated a rigorous plant walkdown of outage activities to ensure that contamination control practices were being adhered to.
This walkdown was completed on May 5, 1989.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Health Physics Supervisor discussed these events at the CNS/ outage maintenance contractor supervisors' planning meeting and stressed the importance of practicing proper contamination control principles and ensuring appropriate radiological surveys are conducted prior to removing equipment from radiologically contaminated areas.
The Outage and Modifications Manager conveyed to the Outage and Modifications staff and the CNS/ outage maintenance contractor craft j
supervisors the concerns expressed by CNS management over the control of radioactive material as described in this violation.
More frequent surveillance of contract workers in radiologically l
controlled areas were implemented by the Health Physics Staff to ensure l
contamination control practices and policies are being adhered to.
This increased frequency continued until startup and subsequent reduction of contractor manpower from the 1989 Refueling Outage.
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U.S. Nuclear Regulatory Commission July 3, 1989 Page 3 o
The actions listed above were completed on May 10, 1989.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The corrective steps noted have been implemented on the dates specified herein, with full compliance achieved by May 10, 1989.
If you have any questions regarding this response, please contact myself or G. R. Horn at the site.
Sincerely, G. A. Trevors Division Manager of Nuclear Support GAT:j s/sg cc:
U. S. Nuclear Regulatory Commission Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station I
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