ML20246M997
| ML20246M997 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/14/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907190274 | |
| Download: ML20246M997 (6) | |
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VIRaINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 14, 1989 U.S. Nuclear Regulatory Commission Serial No.89-464
. Attention: Document Control Desk NAPS /DEO R1 Washington, D.C. 20555 Docket No. 50-338 50-339 License No. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY HQRTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/89-15 AND 50-339/89-15 REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of June 15,1989 which referred to the inspection conducted at North Anna on May 1,1989 through May 5,1989 and reported in Inspection Report Nos. 50-338/89-15 and 50-339/89-15. Our response to the Notice of Violation is attached.
Program changes to address the concern over adequate radiological surveys are discussed in Attachment 1. An additional event concerning an administrative overexposure has occurred since this inspection report was completed and the discussion in Attachment 1 encompasses this event. We are continuing to implement the Radiological Corrective Actions and Management Commitments discussed with you du.ing the Management Conference held on April 26,1989.
We have no objection to this correspondence being made matter of public record. If you have any further questions, please contact us.
Very truly yours, W. L. Stewart Senior Vice President - Power Attachment
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i RESPONSE' TO THE NOTICES OF VIOLATIOE RPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN MAY 1.1989 AND MAY 5.1989 INSPECTION REPORT NOS 50-338/89-15 ANO 50-339/89-15 o
NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted ori May 1-5, i
1989, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, 1
Appendix C (1989), the violation is listed below:
1 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Technical Specification 6.8.1 requires written procedures to be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, February 1987, requires written procedures for radiation surveys.
Health Physics Procedure HP-8.0.21, Required Non-Scheduled Radiological Surveys, dated September 11,1986, Steps 4.2.6. a and b, requires that when individuals are being escorted by health physics personnel, surveys should be performed sufficient to ensure personnel are aware of the radiation hazards in the area associated with the work activity.
Contrary to the above, the licensee failed to perform adequate surveys to evaluate the extent of radiation hazards that were present in the following two cases:
a.
On April 9,1989, a mechanic unexpectedly received an unplanned dose of 545 i
millirem while replacing the packing in two valves located in the Unit 2 "C" loop room and; b.
On May 1,1989, a maintenance foreman unexpectedly received an unplanned dose of 1,640 millirem to his left thigh while repairing the Unit 1 fuel transfer cart.
This is a Severity Level IV violation (Supplement IV).
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RESPONSE TO VIOLATION
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1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated. Each event is correctly described within the text of this inspection report.
2.
REASON FOR THE VIOLATION The root cause of these events were poor radiological work practices and controls in the RCA.
The cause of the April 9,1989 event was incomplete radiation survey. The source term was not clearly defined in the prejob survey with regards to the orientation of the worker necessary to complete the task. As a result of the required configuration to the source term, the worker's right elbow was exposed to a higher dose rate than predicted, resulting in a whole body exposure for the quarter exceeding the Virginia Power administrative limits. Also, the Health Physics contractor technician did not fully understand the administrative controls on exposure imposed by Virginia Power.
The cause of the May 1,1989 event was incomplete radiation survey of the exact jobsite and personnel error. The RWP used during this event was initially generated to replace the bushings on the transfer cart in the Unit 1 transfer canal.
During the initial evolution, the scope of the job changed.
The associated jobsites required for the change in job scope were not completely surveyed. in addition, no evaluation of the worker's position relative to the source term was made during the planning stage. While the worker was performing the bolt / clip repair he shifted his position, causing his dosimeter to alarm. Consequently, the exposure rate to the worker resulted in a whole body dose above the workers station administrative limit, but within the federal limit.
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3.
CORRECTIVE STEPS WHICH ~ HAVE - BEEN TAKEN AND THE l
RESULTS ACHIEVED j
A Radiological incident investigation Report was prepared for each event. The
- specific corrective action taken for each event and the programmatic changes which address the issue of prompt effective corrective actions are described below.
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The corrective action for the April 9,1989 event was to discuss the
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administrative exposure limits and emphasize closer control on work activities with the Health Physics personnelinvolved in the event.
Following the May 1,1989 event, the corrective actions taken for the previous
' event were re-evaluated. As a result, seven programmatic actions.were implemented via Health Physics Shift Instructions. These' instructions were discussed with each Health Physics shift during shift turnover and posted at the -
Radiation Work Permit (RWP) Writer's and Health Physics Shift Supervisor's desk.
The programmatic changes encompass work being conducted in j
Extreme High Radiation Areas and include:
1)
Requiring the signature of the Health Physics Supervisor for any RWP for a work area with greater than 15 R/hr (Extreme High Radiation Area).
2)
Requiring prejob briefs to be conducted by only HP supervisory personnel.
3)
Establishing visual and audio communications directly between the
' Health Physics technician (s) and the worker at the jobsite prior to beginning work.
4)
Using SNSOC approved procedures for all work activities.
5)
Performing a detailed survey of the jobsite which specifically evaluates the workers'. positions and orientations in the radiation field prior to issuing the RWP.
6)
Requiring the issuance of a stop work order if dose rates are 1.5 times greater than those specified in the RWP under which the work is being performed. At this time the crew and Health Physics personnel must re-evaluate the work activities and radiation field before restart is approved for the job. Only the Station Manager, Assistant Station Manager (s), or Superintendent of Health Physics can rescind such a stop work order.
7)
Requiring all work in the fuel transfer canal area to meet the above requirements.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTiiER VIOLATIONS
' The programmatic changes stated in Section 3 will be incorporated into Station l
Health Physics Procedures to avoid further violations.
The recommendations developed from the Radiological Incident Investigation
_ Report will be evaluated by management and implemented as appropriate.
l Each of these events ~ and any future significant radiological events will be covered in applicable continuous training programs and will be added to the list which is used to select significant radiological events to be covered in GET/GER training.
Maintenance procedures to control work in the fuel transfer canal area will be enhanced or developed.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The Health Physics Procedures will be revised by September 1,1989.
Maintenance procedures to control work in the fuel transfer canal area will be enhanced or developed by December 31,1989.
. Training on each of.these events will be covered in applicable continuous training programs by December 31,1989 and will be covered in the GET/GER programs for at least one year commencing September 1,1989.
6.
ADDITIONAL INFORMATION An additional administrative overexposure occurred on May 31,1989. During this event, a contract worker exceeded his administrative dose limit while conducting FOSAR (Foreign Object Search and Retrieval) work on the Unit 1 "C" Steam Generator. During the FOSAR work the camera became stuck and the worker placed his arm inside the steam generator in an attempt to dislodge the camera without notifying the Health Physics technician. This was contrary to the Health Physics technician's directions. The cause of this event was personnel error.
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