ML20249B653
| ML20249B653 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/05/1998 |
| From: | DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20249B648 | List: |
| References | |
| 50-341-98-07, 50-341-98-7, NUDOCS 9806240021 | |
| Download: ML20249B653 (7) | |
Text
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1eum:.w.m r.n m. s.x Detroit Edison 10 CFR 2.201 June 5,1998 NRC-98-0077 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D.C. 20555
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) NRC Inspection Report No. 50-341/98007 dated May 6,1998 1
Subject:
Reoly to Notice of Violation 50-341/98007-02 Enclosed is Detroit Edison's response to the Notice of Violation (NOV) contained in Reference 2.
Should you have any questions regarding this response, please contact Norman K.
Peterson, Director, Nuclear Licensing, at (734) 586-4258.
Sincerely, e
h i
Enclosure i
cc: Regional Administrator, Region 111 B. L. Burgess G. Harris A. J. Kugler L
M. V. Yudasz, Jr.
l Region 111 Wayne County Emergency Management Division l
9906240021 990618
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PDR ADOCK 05000341 WN O 8 g a
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i NRC-98-0077 Page 2' bec: S. Booker -.
.G. Cerullo
. D. Cobb J. Davis.
R. Delong R. Eberhardt P. Fessler R. Gaston D. Gipson L. Goodman -
T. Haberland K. Howard E. Kokosky A. Kowalczuk R. Laubenstein L. Layton J. Moyers W. O'Connor, Jr. -
N. Peterson J. Plona B. Sheffel W. Terrasi T. Thomas [NSRG - 190 TAC]
W. Tucker P. Wiltse Information Management [140 NOC]
Institute of Nuclear Power Operations NRC Chron File Barbara Lewis [ Utility Data Institute]
OSRO Secretary (280 OBA]
. Production Information Center [104 OSB]
Routing Copy
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-Enclosure to 1 NRC-98-0077 Page 1 of 5 '
Renly to Notice of Violation 98007-02 Statement of Notice of Violation:
Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering activities recommended in ~ Appendix A of Regulatory Guide 1.33, Revision j
2, February 1978.-
- Regulatory Guide 1.33, Appendix A, recommends that safety-related activities covered by written pmcedures include radiation protection procedures for access control to radiation areas including a Radiation Work Permit (RWP) system.
Fermi 2 Radiation Protection Conduct Manual, MRPO4, Revision 4," Accessing and Working in the Radiologically Restricted Area," step 4.5.4 requires that staff sign the access sheet to acknowledge understanding and compliance with RWP instructions and step 4.5.4.a. requires that staff not deviate from the RWP unless specific authorization is obtained from Radiation Protection.
a.
Instruction 3.C. of RWP 98-1048, Revision 2, " Room Cooler PMs, Lube RWCU Motors, Change 'B' Pump Oil, Adjust RHR Hanger, Repair P1IF193 Reachrod, Rework P11F342, Repair / Replace 'A' Pump Union, and Replace RTD and Cable," requires stay time tracking for entry into locked high radiation areas.
b.
Instmetion 2. of RWP 98-1016, Revision 0, " Lube Oil Systems: Maintenance, Repairs, Surveillance, Filter Change-out, and Component Cleaning," requires that radiation protection be present for a system breach.
Contrary to the above; On January 20,1998, two mechanical staff entered the north reactor water cleanup room, a.
a locked high radiation area, without stay time tracking, and this deviation was not.
authorized by Radiation Protection.
b.
On March 30,1998, a mechanical maintenance worker breached the lube oil system and removed the N3000F048A valve without radiation protection being present, and this deviation was not authorized by Radiation Protection.
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L C Enclosure to -
Pagi ;of 5.
- Reason For The Violatio_gi a.
The cause of the failure of the Mechanical Maintenance workers to notify Radiation Protection (RP) before entering a Locked High Radiation Area (LHRA) and the failure to follow the Radiation Work Permit (RWP) in regard to stay time tracking was procedural and RWP inadherence. A contributing factor was an incomplete Maintenance Pre-Job Briefing on RWP requirements.
On January 20,1998, two Mechanical Maintenance workers were assigned a job in the North Reactor Water Cleanup (RWCU) Pump Room, which is designated as a LHRA.
The workers proceeded to the RP control point to review and sign onto Job Specific RWP 98-1048 in accordance with Radiation Protection Conduct Manual, MRP04, " Accessing and Working in the Radiological Restiicted Area." By signing the RWP access sheet, the workers acknowledged that they understood the requirements of the RWP. The workers then attended a Maintenance Pre-Job Brief to review the Pre-Job Briefing Checklist, which did not require a discussion of RWP requirements. The workers obtained the required dosimetry and the HiRad key to the North RWCU Pump Room in accordance with Radiation Protection Conduct Manual, MRP06, " Accessing and Control of High Radiation, Locked High Radiation and Very High Radiation Area." When the workers arrived at the Nonh RWCU Pump Room there was an RP technician in the room and one outside the room. The workers entered the room and were shown the dose rates in their work areas. The outside RP technician assigned stay time to the workers. The workers completed theirjobs and exited the area. Dosimetry was reset and the North RWCU Pump Room HiRad key was transferred to another worker.
Later on that same day, the workers retumed to the Radiologically Restricted Area (RRA) access desk before reentering the North RWCU Pump Room to complete anotherjob. RP reset their dosimetry and the workers informed the RP Supervisor that they were retuming to the North RWCU Pump Room. Both workers were still signed onto RWP 98-1048. When the workers arrived at the North RWCU Pump Room, they noticed that there wear no RP technicians present. The workers entered the room and began working.
Shortly after the workers entered the room, RP noticed that they had not been notified by the workers and immediately sent out a RP technician to investigate. When the RP technician anived at the room, he discovered the two workers and escorted them to the RRA access desk.
Investigation of the incident revealed that the workers were aware that RP notification
' was required before entering the room, but they thought that the steps taken at the RRA access desk ' ere sufTicient notification to RP. The workers were also confused with the w
meaning of stay time tracking and were unaware that a RP technician was required to be
- present to perform stay time tracking in accordance with Radiation Protection Conduct
' Manual, M.RP06.
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Eo-Enclosure to NRC-98-0077 l
Page 3 of 5 ~
L l-b.
The cause of the failure of the Mechanical Maintenance worker to notify Radiation Protection (RP) of a system breach and removal of a valve without RP being present to conduct a system breach survey was procedural inadeherence. A contributing factor was
~
an incomplete Maintenance Pre-Job Briefing of RWP requirements.
On March 31,1998, mechanical maintenance workers were assigned the task of removing a drain valve (N3014D008) from the Main Turbine Lubricating Oil Thrust Bearing South l
Strainer. The purpose of the valve removal was to check for blockage in the valve and/or ~
l in the piping at the valve. The workers received a Maintenance Pre-Job Briefing and were instructed to report to RP to determine RWP requirements, in accordance with MRP(4, " Accessing and Working in the Radiological Restricted Area." ' RWP 98-1016 requires RP to be present to conduct a survey in conjunction with breaching the Lube Oil System. The Maintenance Pre-Job Brief Checklist did not require a discussion of RWP requirements. One of the workers proceeded to the tagging center with the understanding that he would meet his partner in the Mechanical Break Area and then proceed to the RRA access desk to sign onto the RWP. When the worker left the tagging center, he neglected to return to the RRA access desk to sign unto RWP 98-1016 and proceeded to the Lube Oil Cooler Room and began work. When thejob was completed, the worker left the RRA and encountered his partner. The worker realized that he had not signed onto the RWP and did not contact RP for the system breach. The worker proceeded immediately to RP to selfidentify the incident.
Corrective Spos That Have Been Taken and the Results Achieved a.
When the RP technician discovered the two workers performing ajob in the room without an assigned RP stay time, the workers were immediately escorted to the RP access desk. A Condition Assessment Resolution Document (CARD) was initiated, access to the RRA was denied and the worker's dosimetry was retained in accordance with Radiation Protection Conduct Manual MRP08,"RRA Access Denial / Reinstatement." The maintenance workers electronic dosimetry read 3 and 10 millirem. This event was discussed with the workers at an accountability meeting in accordance with MRP08. Dosimetry was reissued and RRA access was reinstated on January 30,1998.
The incident was determined by plant management to meet the criteria set forth by the Fermi 2 Error Free Day Program. The incident was self-identified by plant management to meet 3 of the 13 categories for an error free day reset. Site-wide awareness of the incident was communicated via the Fermi 2 Daily Plant Status Repon and the Fermi 2 Daily Update on January 23,1998.
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- Enclosure to NRC-98-0077 Page 4'of 5
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The Mechanical Maintenance worker immediately reponed to the RRA access point to report the incident to RP. A CARD was initiated and access to the RRA was denied in accordance with Radiation Protection Conduct Manual MRP08,"RRA Access Denial / Reinstatement," however, his dosimetry was not retained because the worker self l
identified the incident and reported it directly to RP. The worker's RRA access was I
reinstated on March 31,1998 after the worker received counseling as required by MRP08, Section 4.1.3.
Maintenance Pre-Job Brief Checklist, MDI-002, was revised and approved on April 30, 1998. The revised checklist includes a summary section which includes a checklist for the supervisor to ask the workers questions about the work request, RWP requirements and radiological conditions', opportunity for workers to ask questions, and questions regarding human performance tools.
- Maintenance _ work package preparation /walkdown checklist, MDI-012, was revised and
. approved on May '27,1998 to include verification of RWP requirements.
The incident was determined by plant management to meet the criteria set forth by the Fermi 2 Error Free Day Program. The incident was self-identified by plant management to meet 1 of the 13 categories for an error free day reset. Site-wide awareness of the incident was communicated via the Fermi 2 Daily Update on April 1,1998 and the Fermi 2 Daily Plant Status Report on April 2,1998.
i Corrective Stens That Will Be Taken To Avoid Further Violations The Superintendent of Mechanical Maintenance and the General Supervisor, RP a.
Operations conducted initial informal training sessions for Mechanical, Electrical, and I&C Maintenance personnel on RP definitions including stay time tracking and LHRA, and Radiation Protection Conduct Manual MRP06, Enclosure A," Key Custody Requirements." The initial training sessions were conducted in March 1998, with follow-up continuing training sessions scheduled for the third quarter of 1998.
The Superintendent of Mechanical Maintenance and the General Supervisor, RP Operations conducted initial informal training sessions for Mechanical, Electrical, and I&C Maintenance personnel on Lessons Leamed from the incident.' Topics discussed included consequences of failing to notify RP prior to entry and the importance of a detailed Maintenance Pre-Job Briefing. The initial Lessons Leamed training sessions were conducted in March 1998, with follow-up continuing training sessions scheduled for the third quaner of 1998.
l Enclosure to 4
. Page5 of 5 b.
Initial Lessons Leamed meetings will be conducted for Mechanical, Electrical, and I&C
. Maintenance personnel to discuss the importance of good communication between the supervisor and the workers during Pre-Job Briefs. Pre-Job Briefs should be conducted in
- such a manner to promote dialogue between the two parties and in an area that is free from distractions to allow the exchange ofinformation to occur without interruptions.
The meeting will also discuss management expectations with supervisory personnel to reinforce the importance of Pre-Job Briefs and package walkdowns. The initial Lessons Learned meetings will be completed by June 25,1998, with follow-up continuing training ~
sessions scheduled for the third quarter of 1998.
- Date When Full Comnliance Will Be Achieved RWP requirements were no longer applicable when the workers exited the RRA; -
- a.
therefore, full compliance was achieved on January 20,1998.
b.
RWP requirements were no longer applicable when the worker exited the RRA: therefore, full compliance was achieved on March 31,1998.
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