ML20247G650
| ML20247G650 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/15/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-310, NUDOCS 8905310032 | |
| Download: ML20247G650 (6) | |
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o em VIRGINIA ELECTRIC AND POWER COMPANY RICilMOND, VIRGINIA 23261 W. L. STEWART SENIOR VICE PRESIDENT -
POWER i
U. S. Nuclear Regulatory Commission SerialNo 89-310 Attn: Document Control Desk NAPS /MLB/bgp Washington, D. C. 20555 Docket No.
50-338 50-339 License No.
NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/89-05 AND 50 339/89 05
. REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of April 17,1989 which referred to the inspection conducted at North Anna on March 20,1989 through March 24,1989 and reported in Inspection Report Nos. 50-338/89-05 and 50-339/89-05. Our responses to the Notices of Violation are attached Programs and initiatives to address the concern over adherence to radiological controls are discussed in Attachment 1. As discussed with you on April 26,1989, several additional events have occurred since this inspection report was completed, and the discussion in Attachment 1 encompasses these events.
We have no objection to this correspondence being made matter of public record. If you have any further questions, please contact us.
If you have further questions, please contact us.
Very truly yours, Li W. L. STEWART Attachments:
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8905310032 890515
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U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station
RESPONSE TO THE NOTICES OF VIOLATION REPORTED DURING THE NRC EEN MARCH 20. 1989 AND MARCH 24. 1989 INSPECTION REPORT'NOS 50 338/89 05 AND 50-339/89-05 NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on March 20-24,1989, a violation of NRC requirements was identnisu. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:
10 CFR 20.203 specifies posting, labeling and control requirements for radiation areas, high radiation areas, airbome radioactivity areas and radioactive material areas.
Technical Specification 6.12.1 requires that in lieu of the " control device" or "atarm signal" required by Paragraph 20.203(c)(2) of 10 CFR 20, each high radiation area in which the intensity of radiation is greater than 100 mrem /hr but less than 1,000 mrem /hr shall be barricaded and conspicuously i
posteu as a high radiation area and entrance thereto shall be controlled by requiring issuance of a radiation work permit. Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:
(1) A radiation monitoring device which continuously indicates the radiation dose rate in the area l
l (2) A radiation monitoring device which continuously integrates the radiation dose rate in the areas and alarms when a preset integrated dose is received. Entry into such areas with this monitoring l
device may be made after the dose rate levels in these areas have been established and personnel have been made knowledgeable of them.
(3) An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over 1
I the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the f acility Health Physicist in the radiation work permit.
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. e s.
Contrary to the above, the bcensee failed to comply with these requirements in that:
- a. On August 25,1988, a Quality Assurance inspector and work crew were found in the Unit 1 Auxiliary Building piping penetration area, a posted high radiation area, without a radiation monitoring device and without health physics coverage.
- b. On November 26,1988, an operator was' found in the Waste Solids Area, a locked high radiation area, without a radiation monitoring device and without health physics coverage.
- c. On January 16, 1989, two contractor engineers were discovered in the Unit 2 piping penetration area, a posted high radiation area, without a radiation monitoring device and without health physics coverage.
- d. On March 15,1989, various members of a contractor rigging crew were noted entering a posted high radiation area in Un'it 2 containment without a radiation monitoring device and without health physics coverage.
This is a Severity Level IV violation (Supplement IV).
..y Hg3EONSE TO VIOLATION 1
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated with the exception of example a. The work crew did have a radiation monitoring device in the Unit 1 Auxiliary Building piping penetration area and the Ouality Assurance inspector entered the high radiation area thinking the individual was a Health Physics technician.
2.
REASON FOR THE VIOLATION A self assessment of station Deviation Reports and HP Department Radiation Problem Reports relating to RWP compliance was made in order to determine root cause. The root cause was identified as being due to 1) management acceptance of casual worker attitudes in the RCA and 2) the lack of individual accountability.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Each of the specific events were investigated including the three additional events. The corrective action for example a was to clearly identify Health Physics Technicians that are authorized to provide meter coverage. The corrective action for examples b, c, and d, and the three additional events included appropriate counseling, retraining, and disciplinary actions. For example b, the locked door was enhanced to prevent opening without a key. To address the root cause, additional management actions have been taken. These actions included:
a) Enhancing self assessment capability to provide timely indication of adverse trends and the effectiveness of corrective actions. Specific activities include 1) implementing a detailed and systematic process for investigation of radiological events,2) assignment of a corporate Radiological Protection Assessor to provide oversight and assessment of radiological controls, and 3) initiation of OA Surveillance (performance based) of radiological work practices.
b) Enhancing radiological work practices by 1) developing and implementing task specific radiological work practices 2) contractor action plans for RWP compliance, and 3) upgrading, from a human factors standpoint, areas of the Radiation Protection Program that workers routinely interface with (e.g., upgraded Radiological Status Boards and Radiation Survey Maps, standardized postings, computerized RWPs, and provided digital display and alarming dosimeters).
c) Clarified and enhanced management standards and expectations for RWP compliance and accountability of both the individual worker and his supervisor.
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- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l~
A workshop will be developed and held to train supervisory personnel on the management expectation for Good radiological work practices and how to recognize good work practices.
A lifetime exposure policy will be implemented to minimize the allowable exposure to personnet. This will provide even greater incentives on the part of workers and management to implement the ALARA concept to minimize personnel exposures.
Ongoing management programs such as " Coaching" and "Self Checking" (see response to IR 88-31 dated January 23, 1989) and commitment to Advanced Radiation Worker Training and Quality Maintenance Teams will be continued. Also, self assessment of the Radiological Protection Program will be made periodically to determine effectiveness and the need for additional corrective action.
The currently ongoing continuing Training Programs will be used to provide feedback to personnel on failures to fully adhere to RWP events. Case studies will be developed as appropriate to support this training.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The lifetime exposure policy will be implemented by July 31,198? and the supervisory workshop 3 will be completed in 1989.
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