ML18038A502

Provides Response to NRC Violations Noted in Insp Repts 50-220/92-05 & 50-410/92-05.Corrective Actions: Accountability Meeting Held W/Personnel Directly Involved to Provide Insight Into Reasons for Event

ML18038A502
Person / Time
Site:	Nine Mile Point
Issue date:	03/12/1992
From:	Sylvia B NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NMP1L-0649, NMP1L-649, NUDOCS 9203190321
Download: ML18038A502 (16)

See also: IR 05000220/1992005

Text

ACCELERATED

DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORy

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)DOCKET 0500022 0500041 NOTES: ACCESSION NBR:9203190321

DOC.DATE: 92/03/12 NOTARIZED:

NO FACIL:50-220

Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha AUTH.NAM" AUTHOR AFFILIATION

SYLVIA,B.R.

Niagara Mohawk Power Corp.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)" SUBJECT: Provides response to NRC violations

noted in Insp Repts 50-220/92-05

&50-410/92-05.Corrective

actions: accountability

meeting held w/personnel

directly involved to provide insight into reasons for event.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response RECIPIENT ID CODE/NAME PDl-1 PD BRINKMANiD

INTERNAL: ACRS AEOD/DEIIB

DEDRO NRR MORISSEAUiD

NRR/DLPQ/LPEB10

NRR/DREP/PEPB9H

NRR/PMAS/ILRB12

OE DER EXTERNAL: EG&G/BRYCEgJ.H.

NSIC COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME BR INKMAN, D.AEOD AEOD/DSP/TPAB

NRR HARBUCKgC.

NRR/DLPQ/LHFBPT

NRR/DOEA/OEAB

NRR/DST/DIR

8E2 NUDOCS-ABSTRACT

OGC/HDS1 RGN1 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1'1 1 1 1 1 1 1 1 1 1 1 1 1 1 0 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

,~I

NIAGARA MOHAWK POWER CORPORATION/NINE

MILE POINT, P.O.BOX 63.LYCOMING, NY 13093/TELEPHONE

(315)349-2882 B.Ralph Sylvia Executive Vice President Nuclear March 12, 1992 NMP1L 0649 United States Nuclear Regulatory

Commission

Document Control Desk Washington, DC 20555 Nine Mile Point Unit 1 Docket No.50-220 DPR-Nine Mile Point.Unit 2 Docket No.50-410 NPF-Gentlemen:

SUBJECT: RESPONSE TO NOTICES OF VIOLATION-NRC COMBINED INSPECTION

REPORT NOS.50-220/92-05

AND 50-410/92-05

Attached is Niagara Mohawk Power Corporation's

response to the Notices of Violation contained in the subject Inspection

Report dated February 11, 1992, (Attachments

1 and 2).We share your concerns addressed in the Inspection

Report, and feel that our corrective

actions have appropriately

addressed the root cause and recurrence

of these violations.

If you have any questions concerning

this matter, please contact me.Very truly yours,/Yr~/jj"L.c.(~r)j:a+C~

B.Ralph Sylvia Executive Vice President-Nuclear BRS/RM/NS/lmc

ATTACHMENTS

xc: Mr.T.T.Martin, Regional Administrator, Region I Mr.W.L.Schmidt, Senior Resident Inspector Mr.R.A.Capra, Director, NRR Mr.D.S.Brinkman, Senior Project Manager, NRR Mr.J.E.Menning, Project Manager, NRR Mr.L.Nicholson, Chief, Reactor Projects, Section 1B Records Management

92031'70321

920312 PDR ADOCK 05000220 PDR

ATTACM4ENT

1 (Page 1 of 3)NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT UNIT 1 DOCKET NO.50-220 DPR-63 RESPONSE TO NOTICE OF VIOLATION AS CONTAIjMED

IN INSPECTION

REPORT 50-220/92-05

VIOLATION 5 22 2-05 10 CFR 50.36 (a)states in part that each license authorizing

operation of a production

or utilization

facility will include Technical Specifications.

Plant Technical Specification 6.12 states in part that for High Radiation Areas, the area be conspicuously

posted and entrance be controlled

by requiring issuance of a Radiation Work Permit.Any individual

or group of individuals

permitted to enter the area shall be provided with or accompanied

by: a radiation monitoring

device which continuously

indicates radiation dose rates, or;a radiation monitoring

device which continuously

integrates

the radiation dose rate in the area and alarms when a preset integrated

dose is received, or;an individual

qualified in radiation protection,,with

a radiation dose rate monitoring

device.Contrary to the above, on December 16, 1991, three members of the licensee's

Operations

Department

entered the South Condenser Moisture Separator Room on the 277'levation

of the Turbine Building, a posted High Radiation Area, without being on a Radiation Work Permit, and without a dose rate meter, an alarming dosimeter, or accompanied

by a Radiation Protectio'n

technician

with a meter.This is a Severity Level IV violation (Supplement

IV).I.THE REASONS FOR THE I LATION Niagara Mohawk admits to the violation as stated.Operations

personnel are covered by an extended Radiation Work Permit (RWP)if they meet the qualifying

conditions

for such permit.However, one of the prerequisites

to the application

of an extended RWP, obtaining a radiation monitoring

device, was not met.The Station Shift Supervisor (SSS)failed to obtain a radiation monitoring

device or Radiation Protection (RP)support prior to entrance into a High Radiation Area.The root cause for this event is personnel error due to Operations

personnel not following station procedures, which are based upon the above cited Technical Specification.

Specifically, Generation

Administrative

Procedure GAP-RPP-08,"Control of Transient, High, and Locked High Radiation Areas," Section 3.2, was not followed.Operations

personnel did not have monitoring

capability

such as a radiation monitoring

device, an alarming dosimeter, or a person qualified in RP procedures

possessing

a radiation dose rate monitoring

device before entering the locked High Radiation Area.Also, better availability

of portable radiation monitoring

equipment assigned to Operations

in the control room through appropriate

controls would have allowed the proper entry into the locked High Radiation Area.The SSS attempted unsuccessfully

to get a portable radiation monitoring

device before entering the High Radiation Area.

ATTACHMENT

1 (Page 2 of 3)NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT UNIT 1 DOCKET NO.50-220 DPR-63'ESPONSE TO NOTICE OF VIOLATION AS CONTAINED IN INSPECTION

REPORT 50-220/92-05

I 2.C RRE T E STEP TAKEN AND THE ULTS ACHIE ED Radiological

Occurrence

Reports (ROR)for entering the locked High Radiation Area without a radiation monitoring

device (ROR¹1-91-00-57)

and breaking in the"break-to-enter" key box (ROR¹1-91-00-56)

were generated on December 16, 1991.Immediate c'orrective

actions taken for ROR¹1-91-00-57 were for Radiation Protection

to survey the South Condenser Moisture Separator Room area, document dosimetry readings from Operations

personnel, and verify that doses received were within Reg'ulatory

limits, Niagara Mohawk guidelines, and posted values at the gates.Each person who entered the area recorded an exposure of 10 mrem on an extended RWP log.The follow-up radiation survey identified

a general area radiation exposure rate, in the travel path Operations

took, of less than or equal to 450 mr/hr.Immediate corrective

actions taken for ROR¹1-91-00-56

were to contact Security I&C to replace the key box glass and have Radiation Protection

audit and account for the keys in the"break-to-enter" key box.An accountability

meeting was held with personnel directly involved to provide insight into the reasons for this event.The SSS was coached by Operations

management

regarding compliance

with applicable

procedures

and impact on Technical Specifications.

Also, to provide immediate access to a radiation monitoring

device for Operations

in the control room, a radiation monitoring

device station has been provided in that location.The Assistant SSS has single point accountability

for return and issue of radiation monitoring

devices as part of shift turnover.Additionally, a radiation monitoring

device has been located atop the emergency key box in the SSS office for the exclusive use of the SSS or designee during emergency entry into High Radiation Areas.These actions have alleviated

the radiation monitoring

device availability

problem that contributed

to the violation.

3.CORRE TIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS

A Lessons Learned Transmittal

has been generated for the Unit 1 event and has been distributed

to Nuclear Division senior management

personnel, Unit 1 and 2 Operations

and Unit 1 and 2 Radiation Protection.

This will allow Operations

and other branch departments

to understand

the significance

of this violation.

Operations

will also present shift training to Operations

crews to emphasize this event and the Lessons Learned, including the overriding

requirement

to comply with Technical Specification

requirements

and station procedures.

The shift training will also include instructions

that if radiation monitoring

devices become unavailable, Radiation Protection

will be notified and no entry made into a High Radiation Area until applicable

procedures

and requirements

have been fulfilled.

Radiation Protection

personnel will be involved with this shift training.

ATTACHMENT

1 (Page 3 of 3)NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT UNIT 1 DOCKET NO.50-220 DPR-63 RESPONSE TO NOTICE OF VIOLATION AS CONTAINED IN INSPECTION

REPORT 50-220/92-05

RRE T E STEPS T BE TAKEN TO A ID FURTHER I LATI (cont.)The Radiological

Occurrence

Report process will be replaced by the Deviation/Event

Report (DER)process to allow for a higher level and more immediate management

review.The DER procedure is being revised to provide a process which will allow dissemination

of events, such as the Unit 2 High Radiation Area entry, between both units in a more timely manner.This procedure revision will be completed by March 31, 1992, with training to be completed by April 30, 1992.4.DATE HE LL MPLIANCE WAS A HIEVED Full compliance

was achieved on December 16, 1991, when doses received by Operations

were determined

and found to be within regulatory

limits after surveys were performed by Radiation Protection.

ATTACHMENT

2.(Page 1 of 3)NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT UNIT 2 DOCKET NO.50-410.NPF-69 RESPONSE TO NOTICE OF VIOLATION AS CONTAINED IN INSPECTION

REPORT 50-410/92-05

VIOL ATIO 5 1-05 10,CFR 50.36 (a)states in part that each license authorizing

operation of a production

or utilization

facility will include Technical Specifications.

Plant Technical Specification 6.12 states in part that for High Radiation Areas, the area be conspicuously

posted and entrance be controlled

by.requiring issuance of a Radiation'ork

Permit.Any individual

or group of individuals

permitted to enter the area shall be provided with or accompanied

by: a radiation monitoring

device which continuously

indicates radiation dose rates, or;a radiation monitoring

device which continuously

integrates

the radiation dose rate in the area and alarms when a preset integrated

dose is received, or;an individual

qualified in radiation protection, with a radiation dose rate monitoring

device.Contrary to the above, on October 23, 1991, five members of the licensee's

Operations

Department.entered the Northeast and Northwest Condenser Area on the 277'levation

of the Turbine Building, a posted High Radiation Area, without being on a Radiation Work Permit, and without a dose rate meter, an alarming dosimeter, or accompanied

by a radiation"protection

technician

with a meter.This is a Severity Level IV violation (Supplement

IV).1.THE REASONS FOR THE VIOLATION Five Operations

personnel entered the Northeast and Northwest Condenser area on the 277'levation

of the Turbine Building on October 23, 1991, in response to a loss of condenser vacuum condition.

This area is a locked High Radiation Area and entry is controlled

by procedure S-RAP-RPP-0801,"High Radiation Area Monitoring

and Control" (formerly S-RPIP-3.8).

The Operations

personnel who entered the area are qualified as self monitors, and as such were authorized

to enter under an Extended Radiation Work Permit (RWP)as provided for in Administrative

Procedure AP-3.3.2,"Radiation

Work Permit." One member of the team entering this area was carrying a radiation monitoring

device as required by Technical Specifications

and Radiation Protection

procedures.

The condenser bay entry was monitored via a remote camera monitor by a Radiation Protection

Supervisor

in the area.The operator carrying the radiation monitoring

device became involved in responding

to the loss of vacuum and failed to devote the proper attention to performing

radiation surveys.The Radiation Protection

Supervisor

determined

that an adequate radiation survey was not performed by the operator carrying the radiation monitoring

device, nor did he inform the other operators" of radiation levels.The reason for the inadequate

survey has been determined

to be a personnel error due to a failure to follow procedures.

Upon exiting the High Radiation Area, personnel completed the required log entries for the Extended RWP.

ATTACHMENT

2 (Page 2 of 3)NIAGARA MOHAWK POWER CORPORATION'INE

MILE POINT UNIT 2 DOCKET NO.50-410 NPF-69 RESPONSE TO NOTICE OF VIOLATION AS CONTAINED IN INSPECTION

REPORT 50-410/92-05

2.RRE T E TEPS TAKE D THE RES LT A HIE ED The immediate corrective

actions were to have Radiation Protection

personnel verify radiation levels in the area and verify that doses received were within Regulatory

limits, Niagara Mohawk guidelines

and values posted at the gates.All personnel entering the area recorded an exposure of less than or equal to 5 mrem on an extended RWP log.The Plant Manager, Operations

Manager, and Radiation Protection

Manager, were all notified of the event.A Radiological

Occurrence

Report'(ROR)

was written to track and document the event and any corrective

actions generated.

An accountability

meeting was held with all personnel directly involved, to provide insight into the~~~~reasons for the event.Participants

discussed the procedural

requirements

for and the importance

of personnel radiation monitoring

in High Radiation Areas.In addition, they discussed the need for Operations

and Radiation Protection

to work as a team to promote safer plant operations.

Further, the control of keys that allow entry into locked High Radiation Areas (XH Keys)has been shifted from the Station Shift Supervisor (SSS)to the Radiation, Protection

office.This will facilitate

Operations

personnel coordination

with Radiation-Protection

technicians

during response to plant transients.

An emergency XH Key has been staged in the SSS office along with an emergency use only radiation monitoring

device.These may be used if a condition were to develop where immediate access to a High Radiation Area is required.3.CORRE TIVE STEPS TO BE TAKEN TO AVOID THER VIOLATI NS The Operations

Manager will discuss with Operations

personnel the Radiation Protection

requirements

for operators to enter a High Radiation Area, stressing that during an emergency, the preferred response is to involve Radiation Protection

personnel if available.

He will also stress that when utilizing the self-monitoring

technique, personnel will determine radiation levels in all accessed areas, and ensure all other personriel

in the area are made aware of these radiation levels.Operations

Training will be integrating

Radiation Protection

interfaces

into appropriate

training and evaluated simulator scenarios.

This will promote teamwork that allows operators to focus on~~~~~~responding

to plant transients

and Radiation Protection

technicians

to supply the appropriate

radiological

monitoring.

This interface, once internalized, will be a practiced emergency response and an evaluated portion of the simulator scenario.

ETTA HMBNT 2 (Page 3 of 3)NIAGARA MOHAWK POWER CORPORATION

NINE MILE POINT UNIT 2 DOCKET NO.50-410 NPF-69 RESPONSE TO NOTICE OF VIOLATION AS CONTAINED IN INSPECTION

REPORT 50-410/92-05.

4.DATE WHE FULL COMPLIANCE

AS ACHIEVED Full compliance

was achieved on October 23, 1991, when doses received by Operations

were" determined

to be within Regulatory

limits after surveys performed by Radiation Protection.