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)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORy INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9203190321 DOC.DATE: 92/03/12 NOTARIZED: NO DOCKET FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 0500022 50-410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 0500041 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 NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-1 PD 1 1 BR INKMAN,D. 1 1 BRINKMANiD 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/DSP/TPAB 1 1 DEDRO 1 1 NRR HARBUCKgC. 1 1 NRR MORISSEAUiD 1 1 NRR/DLPQ/LHFBPT '1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DER 1 1 OGC/HDS1 1 1 1 1 RGN1 FILE 01 1 1 EXTERNAL: EG&G/BRYCEgJ.H. 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, 0 ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

, ~ I NIAGARAMOHAWKPOWER 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 Nine Mile Point. Unit 2 Docket No. 50-220 Docket No. 50-410 DPR- 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,

/jj"L.c.(~r)j:a+C~

B. Ralph Sylvia

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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)

NIAGARAMOHAWKPOWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63 RESPONSE TO NOTICE OF VIOLATIONAS CONTAIjMED IN INSPECTION REPORT 50-220/92-05 VIOLATION5 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)

NIAGARAMOHAWKPOWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63 TO NOTICE OF VIOLATIONAS CONTAINED IN

'ESPONSE 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 (ROR ¹1-91-00-57) and breaking in the "break-to-enter" key box (ROR

¹1-91-00-56) were generated on December 16, 1991. Immediate c'orrective actions taken for ROR ¹1-91-00-57 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 ROR ¹1-91-00-56 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 ifradiation 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 MOHAWKPOWER CORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR-63 RESPONSE TO NOTICE OF VIOLATIONAS 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.

ATTACHMENT2.

(Page 1 of 3)

NIAGARAMOHAWKPOWER CORPORATION NINE MILE POINT UNIT 2 DOCKET NO. 50-410.

NPF-69 RESPONSE TO NOTICE OF VIOLATIONAS CONTAINED IN INSPECTION REPORT 50-410/92-05 VIOLATIO 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.

ATTACHMENT2 (Page 2 of 3)

NIAGARAMOHAWKPOWER CORPORATION'INE MILE POINT UNIT 2 DOCKET NO. 50-410 NPF-69 RESPONSE TO NOTICE OF VIOLATIONAS 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.

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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

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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

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responding to plant transients and Radiation Protection technicians to supply the appropriate

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radiological monitoring. This interface, once internalized, willbe a practiced emergency response and

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an evaluated portion of the simulator scenario. ~

ETTA(Page 3 HMBNT 2 of 3)

NIAGARAMOHAWKPOWER CORPORATION NINE MILE POINT UNIT 2 DOCKET NO. 50-410 NPF-69 RESPONSE TO NOTICE OF VIOLATIONAS 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.