ML19351A470

Responds to NRC 891025 Ltr Re Violations Noted in Insp Repts 50-266/89-22 & 50-301/89-21.Corrective Actions:Training Module for Contractor Health Physics Personnel Enhanced to Include Discussion of High Radiation Area Requirements

ML19351A470
Person / Time
Site:	Point Beach
Issue date:	12/08/1989
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-89-174, NEL-89-155, VPNPD-89-644, NUDOCS 8912180140
Download: ML19351A470 (10)

Text

m m= 7r o my o , 'y 4 ..

/ h.  !  !~

e l Wisconsin; l jfhDCfnC4 i

+, POWER COMPANY:  ;

D '

R . 23(W Mctygon, Po. Box 2046. Mdwodee. W153201 (414)221-2345 1

. VPNPD 6 4 4

!; LNEL-89-lS5

. x p" December-8, 1989L 10CPR2.201 ,

cU.S. Nuclear Regulatory Commission

. Document Control Desk Mail'Scation Pl-137 Washington, D.C. 20555 E

Gentlemen: _

DOCKET NOS. 50-266 AND 50-301 REPLY iPO NOTICE OF VIOLATION EA 89-174 y POINT BFACH NUCLEAR PLANT, UNITS 1 AND 2

)- ,

,' By l'tter e dated October 25, 1989, the NRC Region III' staff transmitted a Notice of Violation' involving three ronditions fidentified during the inspection conducted at the Point Beach Noclear/ Plant'during the period from July 25 through August.24, ,i 1989. The results of that inspection were reported in NRC LInspection Reports No. 50-265/89022.and No. 50-301/89021, which were transmitted-to us by letter dated August 30,'1989. The violations identified in those inspection reports and described

'in the Notice of Violation involve: .(1) the failure to meet Technical Specification requirements regarding high radiation area entry control procedures and (2) the failure to comply with l- a TMI confirmatory crder regarding.the requirement to maintain a procedure to-adequately measure inplant airborne radiciodine under postulated accident conditions. These violations were discussea at the enforcement conference. held in your offices on September 6, 1989. A report of that conference was included as an enclosure to the October 25 letter.

Wisconsin Electric agrees that the conditions identified in the referenced correspondence have been properly classified as three

Severity Level IV violations. Our discussions on each of these

? ' violations, including the corrective action for each, are

,1 provided in the attachments to this letter.

E As you are aware, due to the extent of activities necessary to complete the extended Point Beach Unit 2 outage, we were unable to complete our response to this notice within the 30 days specified. We requested and received, through Mr. Greenman of the Region III staff, a two-week extension to complete this response.

8912180140 891208 '

Db ADOCK-05000266 PDR ,

O- PD" f \

il subsMaryoflikvnshi Dieqv Cmwahbn

y m .

}l..n: 5 z

iMi@ -.y

'WO. hc., ~ ~

s,1,-

, a , J, e s - . t,, A . --

s ,s. . -, ,

i .

u.. ,

[h,iU. , . S- 8[- i ,

• ii . ~

,y < y +

-; m ;;. A, >>  :.

>m>

o s pq:, , p-. ; , '

'l y

, ,4

--e+ -, " , ,

s' r.

b_' > Wti;gy n* ' '

/\

i 4

p w

R v. . - '

y; q.

.o s . 'g 1.g.y s ;

s_ -

t .. .,- .tc WW"1 Mu <B l _ DocumentIControl(DeskU ,

?? '. 1 iDecemberE8Q1989: , r-

++4O p ;..

lPa9el2;- -

.~t ggg#4 % ,%

,t 9,..;. ;:;

)

t i

4 ;;' + . 4~

+is+< .

.. &. 'l , . , 4 If-y'oughave)any-questions!concerning,thisiinformat_ ion,-p eas'e-J,mf C - -

1 JA,* -contact: us.- ,o w.

h

,;c

': :Veryitruly;you$s, n f-t/..

u rf,. , .,

2- a , , ,

ya i

g& "l , '

[C.iW.l Fay.

• ffi '; , %VicelPresident:.. s f' s

Nuclear Power (y Lalg.

1 3

c. v . .

f D; a .  ; Copy 4to NRC! Regional Administrator, Region.,III .

P,' -NRC. Resident. Inspector'

' ' ~

- o :i

' il, I'[af. i !, * '

> ' ; jt l

l _'

)

\

s yb

> > + ,

1 , 3  ?,

f g l' ?

^

( $.'

, [ c.-

< I s , t

)

n' l'

'. .l l . S '.

-.[. y

. - ~i: > ' , ' . s ,

N l

'g:

s h

,1.

.r"h Q.

L-, ,

l ';

1 t' l

d :.

I G' , , l 1

s(

.l l

1 l

l

\: -

4

. i.  :

. ]#

,!, r _ ;

t.

^p.

• t s t -j (;; -

1

'. 'j .,6 h- yl. ..

{

-, . - . - . , , . . _ . . - , . . , , , - , . ,. ~ ,

p ,

- ~

W. o-

.W

' REPLY TO NOTICE OF VIOLATION EA 89-174 2n h

5

)., DOCKET NOS. 50-266 AND 50-301-POINT BEACH NUCLEAR PLANT 1 -.o Technical Specification-15i6.8 requires that the plant be g operated in accordance with approved proc,edures.

A. Health _ Physics Procedure No. HP 3.2.3, RCA Radiation Area and High Radiation Posting Requirements, requires that high; radiation areas be suitably barricaded.

Contrary to tbt above, on April'11 and 14, 1989, the high radiation area rope barrier at the step-off pad for the Unit 1 Regenerat3ve Heat Exchanger Cubicle was found not to be suitably barricaded in that a portion of the barrier rope had been improperly. moved intc the high radiatioa area..

This is a repeat of previous (non-cited) violations- I involving degraded High radiation Area barriers.

This is a Severity Level IV violation.

B. Health Physics Procedure No. HP 2.5, Radiation Work Permit, states that a Radiation Work Permit (RWP) is required for entry into an area posted as "High Radiation Area, RWP Required" and that any individual o

entering.a high radiation area shall be provided with or accompanied by at least one of;the following: a radiation monitoring instrument-that continuously indicates the radiation dose rate in the area; a radiation monitoring device which continuously integrates the radiation dose and alarms when preset dose is received; or coverage by an individual qualified in radiation protection who is equipped with a radiation monitoring device.

Contrary to the above, on Apri'l 17, 1989, three individuals entered an 2rea of the 06-ft south walkway to the spent fuel pool, which was posted as "High Radiation Area, RWP. Required," even though this area was not authorized by their RWP, and they did not have the required dose monitoring dtvices nor were they accompanied by an individual. qualified in radiation protection who was equipped with a radiation monitoring device.

This is a Severity Level IV violation.

Description and Cause The Unit 1 regenerative heat exchanger cubicle is located on the 21' elevation-of the containment building. The cubicle is maintained as a locked, high radiation area due to the presence of' radiation exposure rates in excess of 100C millirem per hour inside the cubicle. A lead shielded door i

,7  ; , -

g

(: h

7 . ,.m C 7'

~ ~

- Tis:u%d to controlitecpas to tho cubielo cnd:is uand1to;

(

jt

,* ... reduce the-radiation'that-emanates from-the cubiclo-into.ths.

ndjacent general area walkway.

At theLstart of our' Spring 1989 Unit.1' refueling outage, exposure ratesiin excess _ofc100 millirem _per hour were1 measured'on the outside and uncontrolled area of the

-regenerative heat1 exchanger cubicle shield door. Exposure rates on contact with the shield door were measured at approximately 130 millirem per hour.' Exposure rates of:100 F' Lmillirem were measured.at a distance of_3-4 feet from the outside surface of'the shield door. Mear red exposure rates

~

, infexcess of 100 millirem per hour required that a high-radiation rope barrier be.placed near the cubicle entrance approximately 4 feet from the cubicle' door. The placement of this-radiation rope barrier reduced the width of a frequently used walkway to'about 3 feet. The radiation.

rope barrier which restricted the size of the walkway was secured by'stanci.ons bolted ~to the~ walkway floor-grating.

On April 11, 3989, the stanchion used to position the rope barrier was.found-to have been moved approximately 18 inches closer to the regenerative heat exchanger-cubicle door.

With the stanchion moved inward, the exposure-rates were .

measured at 120 millirem per hour at the new location of the rope barrier. The stanchion was immediately returned to its j

. original position to ensure'that exposure rates of 100 l

s millirem per hour at this location were properly barricaded and posted. During an investigation of the event that followed, an operator came forth and indicated that he had moved the stanchion in ordar to permit a tool cart to pass l- -through the walkway. The operator indicated that it was his

~

Lintention to return the stanchion to its proper position but

~

that he:had forgotten. The operator was counseled and

-advised that his actions were not acceptable.-

On April 14, 1989, this same stanchion was found degraded.  !

.The stanchion supporting the high radiation-rope barrier was =!

found bent over, causing.the burriert to be moved inward.  ;

This condition allowed access to anounbarricaded area with {

exposure rates to approximately 120 millirem per hour at i accessible areas of the walkway. The: stanchion'and barrier l were immediately returned to their proper position to ensure that the area of the walkway with exposure rates in excess j

j of 100 millirem per hour was properly barricaded. j These two events were caused by an apparent disregard for a the importance of high radiation barriers on the part of  ;

som' employees. A contributing causo was the fact that the '

barrier restricted the flow of personnel and equirment through a heavily traveled walkway. The movement of equipment-through the narrowed walkway created a significant potential to cause the stanchion or barrier to be degraded.

i 10n April 17, 1989, three Operations personnel were observed entering an area that had been barricaded and posted as a high radiation area. The area was located on the auxiliary i building 66' elevation walkway that leads to the spent fuel

-c Il

5 t'4 pool. This1cros was pootcd'af e high-radiction crea due to 6 ';_~

transient dose rates experienced.in-this area during fuel-movement. The three operators had just completed fuel-7.

1 movement work activities and were exiting the spent fuel area. The posting on the radiation barrier indicated that a

, , radiation work permit was required and that there was to be-no entry ?uring fuel movement. Since the operators had just complet.;c fuel movement activities and were aware that fuel movement was not in progress, they interpreted the sign and Lbarricade to no longer be applicable-and proceeded to enter the posted area. The health physics technologist that {

4 observed this action immediately advised the refueling j superv.isor and other involved operators that_ entry into this l

, posted area was not permitted unless authorized by a specific radiation work permit. The refueling supervisor concurred and agreed to use an alternate' route for access to or egress from the spent fuel pool area. The refueling l supervisor was later provided additional-counseling about the event, and the Superintendent-operations was informed.

This event was caused by an apparent disregard for the

.importance of high radiation barriers by these personnel.

Contributing to:this event were inadequate or confusing instructions on the posting.that was attached to the barrier controlling access to this transient refueling high radiation area.

These three events were identified by Wisconsin Electric personnel and documented as nonconforming conditions.

Although the events resulted in violations of applicable procedures and-related Technical Specifications, the events did not significantly compromise the radiological safety of the personnel involved or other plant personnel. -

Corrective Action' The following corrective actions have been completed in response to the violations:

A. Training sessions were conducted during the months of August and September for those plant personnel that.have authorized access to the radiation controlled zone. The training sessions included a review and discussion of the following items: 1) a summary of the federal regulations which apply to the control of high radiation areas, 2) a summary of PBNP Technical Specification 15.6.11 which specifies plant-specific high radiation area control and entry requirements, 3) a summary of the high radiation-area procedure and technical specification violations which occurred at PBNP during the years of 1988 and 1989,

4) a discussion of the consequences of the failure to conform to applicable regulations, 5) a discussion of each employee's responsibility and obligation to conform to applicable high radiation area regulations and procedures, and 6) a discussion of management's intolerance for the purposeful disregard of radiation area barriers or procedures. Although the focus of the training session was a discussion of high radiation area

.*i rdquir:mente, an rmphacio wne. alto plic:d on crch

~

employee's' responsibility to conform to all health physics and radiological _ protection procedures and practices.

The majority-of the training sessions were conducted and.

information was presented-by either the Superintendent- ,

Health _ Physics or the' General Superintendent-Operations.

The number of employees attending each training session was purposefully kept small, between 10-15 attendees, to facilitate a more focused discussion of the information.

Newly hired nuclear plant operator trainees and employees who'were unable to attend a session in August or

+

September have attended makeup sessions during the months of October through December. The last makeup session was completed on December 8, 1989.  !

p U" B.' On September 14 and 15, 1989, the Superintendent-Health Physics prepared a video tape training session. The video tape contained a summary and discussion of the same material that had been provided to plant personnel as described above in Corrective Action A. This video tape was incorporated into the General Employee Training (GET) Program. Beginning on September 18, 1989, this video tape was presented to contractor employees hired to support our Unit 2 refueling outage as part of the GET-program. The tape was presented during each GET session for the duration of the Unit 2 refueling outage.

C. The training module for contractor health physics personnel was enhanced to include a specific discussion of high radiation area requirements. This training session ~was conducted by the Superintendent-Health Physics on September.21, 1989, and the session was attended by all the_ contractor health physics technicians hired to support the Unit 2 refueling outage.

D. Contractor employees that-were already onsite and therefore_were not required to attend General Employee Training prior to the start of the Unit 2 refueling outage were required to attend a special training session on high radiation area requirements. The Superintendent -Health Physics conducted these training sessions on September 21, 22, 24, and 25, 1989. These sessions were also attended by Wisconsin Electric maintenance personnel brought-to PBNP from a local service center to supplement our maintenance staff for the Unit 2 refueling outage. Those few contractor employees that were unable to attend any of the sessions conducted by the Superintendent-Health Physics received training by attending a showing of the prepared video tape on either September 21, 26, or 28, 1989.

L

e -

V, , '

a

>E. Tha SupSrint$ndant-H001th Physieg; conducted cn'informn -

p _s tional tsession_with health physics management and'repre-sented personnel ~on September 15, 1989, to review

. program enhancements and corrective actions which were committed to during the September 6, 1989, enforcement  ;

conference. Instructions were provided to.these personne1'regarding their responsibilities associated i with the implementation of the program enhancements and corrective actions.

F. The plant manager issued a memo to all plant personnel on September 19, 1989, which reinforced each employee's i responsibility to ccnform to applicable regulations, ,

procedures, and practices which are used to control high i radiatien areas. The memo described the consequences j that may result from an employee's disregard for radia . {

tion barriers. The memo also reemphasized the need to j conform to all health physics practices and procedures.

t G. Enhancements were made to radiation barriers which are  ;

used inside containment.during refueling outages. A modification was completed during the recently completed- ,

Unit 2 refueling outage which installed swinging gates 9 at the entrances to the pressurizer cubicle,-reactor cavity, and at the containment 8' elevation entrance

' route to the steam generator and reactor coolant pump I cubicles. A similar modification was completed on Unit I during the 1989 spring refueling outage. This f modification eliminated the need to use troublesome rope i barriers that had been used in the past to control j access to these areas.

Portable. swinging gates were also procured =ano used during the Unit 2 refueling outage to control access at the entrance to transient or temporary high radiation areas. These swinging gate barriers automatically swing  !

back li o position therefore reducing t he possibility of an employee exiting an area'and inadvertently failing to return a rope ~ barrier to its required position.

H. The Superintendent-Health ~ Physics issued a' memo to all plant and contractor health physics personnel on September 26,-1989, which provided' instructions on practices which~were to be implemented during the Unit 2 refueling outage. The following instructions were provided to health phytics personnel. 1) Radiation work permits written for work to be conducted inside a high radiation area were to include special instructions regarding radiation barrier control responsibilities, 2) signs and postings used to identify high radiation barriers were to have clear and understandable s instructions, and 3) pre-job briefings were to include a reminder of each employee's responsibility regarding radiation barriers.

I. Procedures which ere used to establish refueling high radiation area barriers were revised. Procedure HP 3.2.3 was reviced and issued on August 18, 1989.

l ~' -

7-e-p

'</

'Procedero HPz9.5 was renumbared cnd iccued as ravised

, Procedure HP 3.2.8 on August 18, 1989. These procedures-provide clarifying guidance to health physics personnel on how to post refueling barriers. Procedure-HP 2.5 was revised and issued on August 18, 1989.. This procedure clarified the_ radiation work permit restrictions for entry into refueling high radiation areas. On August 17, 1989, the Superintendent-operations issued a night order which advised operations personnel that these revised procedures were to be-issued and requested that u the revisions be reviewed. ,

J. A training needs. analysis was submitted for operations b _ personnel. As a result of this analysis, a copy of revised procedure HP 2.5 was placed into the Unit 2 Operations Group Fuel Motion Training book. The fuel motion training book is located in the control room, and is required to be reviewed by operations personnel prior to start of refueling operations. ,

K. The Plant Manager issued a memo to all plant personnel on November 7, 1989,.which summarized the events which lead up to the September 6, 1989, enforcement conference and Notice of Violation. This memo summarized the inspection reports which were associated with this Notice of Violation. The purpose of the memo was to have each employee _ understand the seriousness of failure to comply with high radiation area control regulations and procedures. This memo also again emphasized the importance of adhering to all health physics procedures.

L. The " Nuclear Plant Point" neweletter is issued by the Plant Manager to all plant employees. The newsletter is used as a vehicle to advise personnel of industry events. Newsletters that were issued on August 22, September.7, October 5, and November 30 summarized health physics events that had occurred at other facilities-which resulted in civil penalties or fines.

These events included high_ radiation barrier violations and nonconformances to radiation work permit and other health physics procedures. The Plant Manager urged all plant employees to ensure that similar events and violations do not occur at PBNP.

M. A modification request has been issued to provide additional shielding at the Unit I regenerative heat exchanger cubicle. This will eliminate the need to place a temporary radiation barrier outside of the cubicle door and therefore prevent recurrence of those events that occurred during the last Unit 1 refueling outage on April 11 and 14, 1989. We expect to complete this modification during the 1990 Unit 1 refueling outage. A similar modification is not required for Unit 2.

, . , yw - - --

+.; -m .

RS RruitaLAchinvndt n

~

. Satisfactory results have been achieved'due to the

completion of theseJcorrective actions. During our Ur.it'2 ,

refueling. outage there werefno' technical specification-violations caused by;the willful or careless disregard for '

D Lhigh'radiationLbarriers.  ;

y All corrective actions have been completed-with tNe

~

exception of the shielding modification.to the' Unit 1 ,

Regenerative Heat Exchanger cubicle, as identified in i Corrective Action Item M. This modification will be completed during the11990 Unit 1 refueling outage.- Full compliance will be achieved upon completion of this-modification.-  ;

t

2. 10 CFR-50.54(h) states-that the licensee shall be subject to the provisions of the rules, regulations, and' orders of the' :l Commission.- -

On July 10, 1981,.the Commission issued an Order confirming the licensee's commitments on certain Post-TMI related

issues._ The Order requires,-in part, that the licensee satisfy.the specific requirements described in the Attachment to the Order no later than 60-days after the ,

effective date of the Order. The Attachment to the-Order 1 requires the licensee for NUREG-0737 Item III.D.3.3,

" Improved Inplant Iodine-monitoring", to have available means to accurately meacure airborne-radiciodine inplant a during an accident. NUREG-0737, " Clarification of TMI EAction Plan Requirements", October 1980, states that these-means shall= include procedures.

Contrary to the above,..from_approximately 1984 to March 15, 1989,-the licensee failed'to havefspecific procedures to evaluate inplant air samples under predicated accident conditions for accurate airborne radiciodine determination.

This is a Severity Level IV viola' tion.

cause This violation was caused by inappropriate management oversight in failure to provide a new or revised precedure for promptly measuring inplant radiciodines under postulated accident conditions when the use of a single channel analyzer was discontinued in 1984. The new methodology is superior to that which was used in the original procedure; however, the new methodology was not adequately addressed in

'the procedures. A contributing factor was a weakness in the licensee's commitment tracking system which does not incorporate all commitments documented in NRC Confirmatory Orders, specifically those for which no corresponding NRC Safety Evaluation Report was issued.

i gg ,

(;

- 0. t ni Corrnctivi Action V );; ~

y t'

O In May-1989,, Wisconsin Electric initiated a review of the

- methodology.and current procedures for the determination of in plant radioiodine air concentrations. During this review, it was_ determined that the radiological staff-has the knowledge and appropriate engineering tools to complete the calculations necessary for such a determination. The review al'so recognized that the ability to provide for a rapid estimation of in-plant airborne radioiodine concentrations would be enhanced by development of a new Emergency Plan Implementing Procedure (EPIP). The technical analysis and calculations required to develop this new EPIP i was initiated'in June 1989. Results'of this work were completed.in August 1989,with the generation of tabular data relating filter cartridge contact dose rea" dings to I-130,  !

'l-131, I-132, I-333, I-134, and I-135 air concentrations at '

various times aft'er shutdown following a postulated design

, basis accident. The EPIP necessary to utilize and interpret these data tables, which includes a worksheet to assist in completing the calculations, was completed in late August and approved on September 5, 1989. The EPIP was issued for_ o i use on September 15, 1989. We believe that we are in full a compliance with this item as of that date. i In order to avoid further violations of this nature and to address the weakness identified in our commitment _ tracking ,

i system, the WE licensing group has initiated a complete review of all items identified in the NUREG-0737 TMI Confirmatory Order letters' dated July 10, 1981 and1 March 14, 1983. We have identified over sixty line item requirements j- from NUREG-0737 which were addressed by 'these confirmatory l orders and we have initiated a review of each of those items in order to develop commitment " packages" for each of those j items based on our correspondence from and to the NRC  !

regarding each topic. These commitments will then be I reviewed by the Nuclear Power Department engineer considered l most knowledgeable on the. item to. verify and-confirm that i these commitments have been and continue to be satisfied.

The licensing' group'will then revise the commitment tracking data base, as necessary, to ensure each commitment is adequately identified in our tracking system. It is our expectation to complete this process for the NUREG-0737  :

Confirmatory Orders items by May 1, 1990.

I s

l l- i 1

l q

l J