ML17285B188: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
 
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 988<3000 George Wash/ngton Way~Rfrhland, Washlngton 893$2 April 11, 1990 602-90"074 Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C, 20555 Gentlemen:
{{#Wiki_filter:WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 988 < 3000 George Wash/ngton Way ~ Rfrhland, Washlngton 893$ 2 April 11, 1990 602-90"074 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn:   Document Control Desk Hail Station Pl-137 Washington, D. C,       20555 Gentlemen:


==Subject:==
==Subject:==
NUCLEAR PLANT NO.2, OPERATING LICEHSE NO.NPF-21 HRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
NUCLEAR PLANT NO. 2, OPERATING LICEHSE NO. NPF-21 HRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington     Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
V ery truly yours, G.D.Bouchey, Director Licensing 8 Assur ance JDA/bI<Attachments cc: JB Hartin-NRC RV NS Reynolds-BCPIER RB Samworth-NRC DL Williams-BPA/399 ,NRC Site Inspector-901A APPENDIX A During an NRC inspection conducted on January 29,-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.
V ery truly yours, G. D. Bouchey,     Director Licensing   8 Assur ance JDA/bI<
In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A.10 CFR 20.201,"Surveys.," states in part: (a)'As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...Mhen appropriate, such evaluation includes.;.measurements of levels of radiation or concentrations of radioactive material present.(.b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.
Attachments cc:     JB Hartin   - NRC RV NS Reynolds - BCPIER RB Samworth - NRC DL Williams - BPA/399
Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.
      ,NRC Site Inspector - 901A
This is a Severity Level IV violation (Supplement IV), Val i f Viola n The Supply System acknowledges the validity of this violation.
The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential For the spread of contamination.
Furthermore, radiological surveys taken by the technician were not performed or'recorded in accordance with established procedures.
A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.


Appendix A Page 2 of 2 s Tak n R 2.3.2.3.In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis.was performed for this violation.
APPENDIX A During an NRC inspection conducted on January 29,- February 2, 1990, and February 12 - 16, 1990, a violation of NRC requirements was identified.                In accordance with the "General Statement of Policy and Procedure for NRC          Enforcement  Actions,"
Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.
10 CFR Part 2, Appendix C, (1990), the violation is listed            below:
Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
A. 10 CFR  20.201, "Surveys.," states      in part:
to be T k n I This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings, A complete gob and task analysis was recently.completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.a e Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.
(a) 'As used in the regulations in this part, "survey" means                an evaluation of the radiation hazards incident to...presence                  of radioactive        materials...Mhen    appropriate,      such    evaluation includes.; .measurements of levels of      radiation  or  concentrations  of radioactive material present.
AccELERATED DIAklBU'noN DE M 04sTRAQloN sYsTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)" CESSiON NBR!9004200708 DOC.DATE: 90/04/ll NOTARIZED:
(.b)  Each    Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
NO DOCKET ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION BOUCHEY,G.D.
Contrary to the above,        on January 10, 1990, individuals were permitted to handle    filter    elements  without prior or concurrent surveys of the levels of beta      radiation.      Subsequent  surveys found removable levels of radioactive contamination from the        filter elements ensuring up to 200 mrad per hour    of  beta  radiation.
Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
This is    a  Severity Level IV violation (Supplement IV),
Val  i        f Viola      n The Supply System acknowledges the validity of this violation.            The reason for the violation was personnel performance based in that                the Health Physics Technician involved failed to take appropriate actions to reduce the potential For the spread of contamination. Furthermore, radiological surveys taken by the technician were not performed or 'recorded in accordance with established procedures.
A contributing factor for this violation        was  that the pre-job coordination and  briefings were less than adequate.
 
Appendix A Page 2 of 2 s   Tak n R In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR) for this event, a formal Root Cause   Analysis . was performed for this violation.           Several recommendations for improvements were identified and included I) evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2) providing for increased supervisory overview of Health Physics work coverage.
: 2. All   scheduled Radiation Work Permits     (RWPs) are currently being reviewed by Health Physics supervision     prior to implementation.
: 3. Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
to be T k n I
This violation and the results of the formal Root Cause Analysis will   be discussed during Health Physics Technician meetings,
: 2. A complete gob and task analysis was recently .completed for the Health Physics Technician Training Program. The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based) rather than theory based. Another improvement,     that relates specifically to this violation, is that the new program will include training         on the fundamentals   and expectations of providing job coverage.
: 3. An   overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.
Included in the evaluation will be a review of the pre- and post-job review process.
a e Although the Supply System is currently in     full compliance, the overall evaluation of the Health Physics Program (as     it relates to work planning) will be completed by October I, 1990.
 
AccELERATED             DIAklBU'noN                         DE M 04sTRAQloN           sYsTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)"
CESSiON NBR!9004200708                         DOC.DATE:   90/04/ll   NOTARIZED: NO             DOCKET ACIL:50-397   WPPSS Nuclear Project, Unit 2, Washington Public                       Powe   05000397 AUTH. NAME           AUTHOR               AFFILIATION BOUCHEY,G.D.       Washington Public Power Supply System RECIP.NAME           RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)


==SUBJECT:==
==SUBJECT:==
Responds to NRC 900312 ltr re violations noted in Insp Rept 50-397/90-01.
Responds     to NRC                 900312 ltr re violations noted in Insp Rept 50-397/90-01.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL j SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIIB DEDRO NRR/DLPQ/LPEB10 NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS2 RES/DSR/HFB/HFS EXTERNAL: LPDR NSZC COPIES LTTR ENCL 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 SAMWORTHPR AEOD AEOD/TPAD NRR SHANKMANPS NRR/DOEA DZR 11 NRR/DRIS/DIR NRR/PMAS/ILRB12 OE DIR REG PILE 02 RGN5 PILE 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/'D S h NCTE'IO ALL"RIES" RECIPZENIS'LEASE HELP US K)RE&#xc3;)CE HASTE!CXNZACI'IHE DOCUME&#xc3;7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24  
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL                             j SIZE:     3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation                           Response NOTES:
RECIPIENT                          COPIES            RECIPIENT           COPIES ID CODE/NAME                       LTTR ENCL        ID CODE/NAME        LTTR ENCL            /'
PD5 PD                                 1    1      SAMWORTHPR              1    1 INTERNAL: ACRS                                     2   2     AEOD                    1     1 AEOD/DEIIB                              1   1     AEOD/TPAD              1     1 DEDRO                                    1   1     NRR SHANKMANPS          1     1 NRR/DLPQ/LPEB10                          1   1     NRR/DOEA DZR 11         1    1 NRR/DREP/PEPB9D                          1    1      NRR/DRIS/DIR           1    1 NRR/DST/DIR SE2                          1   1     NRR/PMAS/ILRB12        1     1 NUDOCS-ABSTRACT                          1   1     OE DIR                  1     1 OGC/HDS2                                1   1     REG PILE      02      1     1 RES/DSR/HFB/HFS                          1   1     RGN5    PILE 01              1 EXTERNAL: LPDR                                      1   1     NRC PDR                1     1 NSZC                                    1     1 D
S h
NCTE 'IO ALL "RIES" RECIPZENIS'LEASE HELP US           K)     RE&#xc3;)CE HASTE! CXNZACI'IHE DOCUME&#xc3;7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR                           24 ENCL   24


a+i WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O.Box 968~3000 George Washington Way~Richland, Washington 99352 April 11, 1990 G02-90-074
a+i WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 April 11,   1990 G02-90-074   "
" Docket No.50-397 U.S.Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D.C.20555 Gentlemen:
Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn:   Document Control Desk Hail Station Pl-137 Washington, D. C.       20555 Gentlemen:


==Subject:==
==Subject:==
NUCLEAR PLANT NO.2, OPERATING LICENSE NO.NPF-21 NRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990.Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
NUCLEAR PLANT NO. 2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.
Very truly yours, G.D.Bouchey, Director Licensing 8 Assurance JDA/bk Attachments cc: JB Hartin--NRC RV NS Reynolds-BCPItR RB Samworth-NRC DL Williams-BPA/399 NRC Site Inspector-901A 5000397 PDP ADQCK 050 Q Q(o APPENOIX A Ouring an NRC inspection conducted on January 29-February 2, 1990, and February 12-16, 1990, a violation of NRC requirements was identified.
Very truly yours, G. D. Bouchey,     Director Licensing   8 Assurance JDA/bk Attachments cc:   JB Hartin -   -NRC RV NS Reynolds -     BCPItR RB Samworth -     NRC DL Williams - BPA/399 NRC Site Inspector - 901A PDP   ADQCK     5000397 050 Q
In accordance with the"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, (1990), the violation is listed below: A~10 CFR 20.201,"Surveys.," states in part: (a)As used in the regulations in this part,"survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...When appropriate, such evaluation includes...measurements of levels of radiation or concentrations of radioactive material present.(b)Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.
Q(o
Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.
 
This is a Severity Level IV violation (Supplement IV).Validit of Violation The Supply System acknowledges the validity of this violation.
APPENOIX A Ouring an   NRC inspection conducted   on January 29 - February 2, 1990, and February 12 - 16, 1990,     a violation of NRC requirements was identified.               In accordance with the   "General   Statement of Policy   and Procedure   for   NRC Enforcement     Actions,"
The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential for the spread of contamination.
10 CFR Part 2, Appendix C, (1990),       the   violation   is listed   below:
Furthermore, radiological surveys taken by the technician were not performed or recorded in accordance with established procedures.
A ~   10 CFR   20.201, "Surveys.," states       in part:
A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.
(a) As used in the regulations in this part, "survey" means an evaluation of the radiation hazards incident to...presence of radioactive     materials...When       appropriate,       such       evaluation includes...measurements of levels of radiation or concentrations of radioactive material present.
Appendix A Page 2 of 2 Corrective Ste s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR)for this event, a formal Root Cause Analysis was performed for this violation.
(b) Each Licensee     shall   make   or cause     to   be made   such   surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Several recommendations for improvements were identified and included I)evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2)providing for increased supervisory overview of Health Physics work coverage.2.All scheduled Radiation Work Permits (RWPs)are currently being reviewed by Health Physics supervision prior to implementation.
Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation.         Subsequent     surveys   found     removable     levels of radioactive contamination from the       filter elements     ensuring   up to 200 mrad per hour of beta radiation.
3.Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
This is   a Severity Level IV violation (Supplement IV).
Corrective Action to be Taken 1.This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings.2.3.A complete job and task analysis was recently completed for the Health Physics Technician Training Program.The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based)rather than theory based.Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.Included in the evaluation will be a review of the pre-and post-job review process.Oate of.Full Com liance Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning)will be completed by October I, 1990.}}
Validit of Violation The Supply System acknowledges the validity of this violation.                 The reason for the violation was personnel performance based in that                     the Health Physics Technician involved failed to take appropriate actions to reduce the potential for the spread of contamination. Furthermore, radiological surveys taken by the technician were not performed or recorded in accordance with established procedures.
A contributing factor for this violation         was that the pre-job coordination and   briefings were less than adequate.
 
Appendix   A Page 2 of 2 Corrective Ste   s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR) for this event, a formal Root Cause   Analysis was performed for this violation.                   Several recommendations for improvements were identified and included I) evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2) providing for increased supervisory overview of Health Physics work coverage.
: 2. All scheduled Radiation     Work Permits   (RWPs) are currently being reviewed by Health Physics supervision       prior to implementation.
: 3. Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.
Corrective Action to     be Taken
: 1. This violation and the results of the formal Root Cause Analysis will   be discussed during Health Physics Technician meetings.
: 2. A   complete job and task analysis was recently completed for the Health Physics Technician Training Program. The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based) rather than theory based. Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.
: 3. An   overall   evaluation   of the Health Physics       Program   will   be performed to determine     if improvements need to be made   in assessing radiological considerations during the work planning cycle.
Included in the evaluation will be a review of the pre- and post-job review process.
Oate of. Full Com liance Although the Supply System is currently in       full compliance,   the overall evaluation of the Health Physics Program (as       it relates to work planning) will be completed by October I, 1990.}}

Latest revision as of 14:24, 29 October 2019

Responds to NRC 900312 Ltr Re Violations Noted in Insp Rept 50-397/90-01.Corrective Actions:Complete Job & Task Analysis Completed for Health Physics Technician Training Program & New Program Will Include Training on Fundamentals
ML17285B188
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/11/1990
From: Bouchey G
WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-90-074, GO2-90-74, NUDOCS 9004200708
Download: ML17285B188 (9)
v • d • e


Text

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 988 < 3000 George Wash/ngton Way ~ Rfrhland, Washlngton 893$ 2 April 11, 1990 602-90"074 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D. C, 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2, OPERATING LICEHSE NO. NPF-21 HRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Mashington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated Harch 12, 1990. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.

V ery truly yours, G. D. Bouchey, Director Licensing 8 Assur ance JDA/bI<

Attachments cc: JB Hartin - NRC RV NS Reynolds - BCPIER RB Samworth - NRC DL Williams - BPA/399

,NRC Site Inspector - 901A

APPENDIX A During an NRC inspection conducted on January 29,- February 2, 1990, and February 12 - 16, 1990, 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, Appendix C, (1990), the violation is listed below:

A. 10 CFR 20.201, "Surveys.," states in part:

(a) 'As used in the regulations in this part, "survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...Mhen appropriate, such evaluation includes.; .measurements of levels of radiation or concentrations of radioactive material present.

(.b) Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation. Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.

This is a Severity Level IV violation (Supplement IV),

Val i f Viola n The Supply System acknowledges the validity of this violation. The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential For the spread of contamination. Furthermore, radiological surveys taken by the technician were not performed or 'recorded in accordance with established procedures.

A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.

Appendix A Page 2 of 2 s Tak n R In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR) for this event, a formal Root Cause Analysis . was performed for this violation. Several recommendations for improvements were identified and included I) evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2) providing for increased supervisory overview of Health Physics work coverage.

2. All scheduled Radiation Work Permits (RWPs) are currently being reviewed by Health Physics supervision prior to implementation.
3. Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.

to be T k n I

This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings,

2. A complete gob and task analysis was recently .completed for the Health Physics Technician Training Program. The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based) rather than theory based. Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.
3. An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.

Included in the evaluation will be a review of the pre- and post-job review process.

a e Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning) will be completed by October I, 1990.

AccELERATED DIAklBU'noN DE M 04sTRAQloN sYsTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RZDS)"

CESSiON NBR!9004200708 DOC.DATE: 90/04/ll NOTARIZED: NO DOCKET ACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION BOUCHEY,G.D. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900312 ltr re violations noted in Insp Rept 50-397/90-01.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR I ENCL j SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL /'

PD5 PD 1 1 SAMWORTHPR 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMANPS 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA DZR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR SE2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1 REG PILE 02 1 1 RES/DSR/HFB/HFS 1 1 RGN5 PILE 01 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSZC 1 1 D

S h

NCTE 'IO ALL "RIES" RECIPZENIS'LEASE HELP US K) REÃ)CE HASTE! CXNZACI'IHE DOCUMEÃ7 CGHHKlL DESK, LISTS FOR DOCUMEKIS YOU DC@'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

a+i WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 April 11, 1990 G02-90-074 "

Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hail Station Pl-137 Washington, D. C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2, OPERATING LICENSE NO. NPF-21 NRC INSPECTION REPORT 90-01 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated March 12, 1990. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, the violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.

Very truly yours, G. D. Bouchey, Director Licensing 8 Assurance JDA/bk Attachments cc: JB Hartin - -NRC RV NS Reynolds - BCPItR RB Samworth - NRC DL Williams - BPA/399 NRC Site Inspector - 901A PDP ADQCK 5000397 050 Q

Q(o

APPENOIX A Ouring an NRC inspection conducted on January 29 - February 2, 1990, and February 12 - 16, 1990, 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, Appendix C, (1990), the violation is listed below:

A ~ 10 CFR 20.201, "Surveys.," states in part:

(a) As used in the regulations in this part, "survey" means an evaluation of the radiation hazards incident to...presence of radioactive materials...When appropriate, such evaluation includes...measurements of levels of radiation or concentrations of radioactive material present.

(b) Each Licensee shall make or cause to be made such surveys as...are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

Contrary to the above, on January 10, 1990, individuals were permitted to handle filter elements without prior or concurrent surveys of the levels of beta radiation. Subsequent surveys found removable levels of radioactive contamination from the filter elements ensuring up to 200 mrad per hour of beta radiation.

This is a Severity Level IV violation (Supplement IV).

Validit of Violation The Supply System acknowledges the validity of this violation. The reason for the violation was personnel performance based in that the Health Physics Technician involved failed to take appropriate actions to reduce the potential for the spread of contamination. Furthermore, radiological surveys taken by the technician were not performed or recorded in accordance with established procedures.

A contributing factor for this violation was that the pre-job coordination and briefings were less than adequate.

Appendix A Page 2 of 2 Corrective Ste s Taken Results Achieved In addition to the initial cause analysis performed as part of the Radiological Occurrence Report (ROR) for this event, a formal Root Cause Analysis was performed for this violation. Several recommendations for improvements were identified and included I) evaluating the Health Physics Program for enhancements in assessing radiological considerations during the work planning cycle, and 2) providing for increased supervisory overview of Health Physics work coverage.

2. All scheduled Radiation Work Permits (RWPs) are currently being reviewed by Health Physics supervision prior to implementation.
3. Increased emphasis is being applied in the area of supervisory overview of Health Physics work in progress to improve evaluation of personnel performance.

Corrective Action to be Taken

1. This violation and the results of the formal Root Cause Analysis will be discussed during Health Physics Technician meetings.
2. A complete job and task analysis was recently completed for the Health Physics Technician Training Program. The program, which is currently in the process of being revised, is being changed to be task-oriented (performance based) rather than theory based. Another improvement, that relates specifically to this violation, is that the new program will include training on the fundamentals and expectations of providing job coverage.
3. An overall evaluation of the Health Physics Program will be performed to determine if improvements need to be made in assessing radiological considerations during the work planning cycle.

Included in the evaluation will be a review of the pre- and post-job review process.

Oate of. Full Com liance Although the Supply System is currently in full compliance, the overall evaluation of the Health Physics Program (as it relates to work planning) will be completed by October I, 1990.

Retrieved from "https://kanterella.com/w/index.php?title=ML17285B188&oldid=1993535"