ML17278A301

Responds to NRC 850613 Ltr Re Violations Noted in Insp Rept 50-397/85-20.Corrective Actions:Procedure 1.3.27, Overtime Control Will Be Reviewed for Adequacy & Radioactive Matl & Area Labeling/Posting Requirements Will Be Reemphasized

ML17278A301
Person / Time
Site:	Columbia
Issue date:	07/11/1985
From:	SORENSEN G C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	MARTIN J B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17278A300	List: ML17278A301
References
NUDOCS 8507300259
Download: ML17278A301 (12)

See also: IR 05000397/1985020

Text

i!ECHVEQ'BC Washington

Public Power Supply System P.O.Box 968 3000 George Washington

Way Richland, Washington

99Pgf$609)873.6090

O'GIOtPg gE Docket No.50-3 7 July ll, 1985 Mr.J.B.Martin, Regional Administrator

U.S.Nuclear Regulatory

Commission

Region V 1450 Maria Lane, Suite 210 Walnut Creek, California

94596 Subject: NUCLEAR PLANT NO.2 LICENSE NO.NPF-21 NRC INSPECTION

REPORT 85-20 The Washington

Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated June 13, 1985.Our reply pursuant to the provisions

of Section 2.201, Title, 10 Code of Federal Pegulations, consists of this letter and Appendix A (attached).

In Appendix A, an explanation

of the violation is presented, the'orrective

steps taken with results achieved are outlined, and the date of full compliance

is specified.

Should you have any questions concerning

our response, please do not hesitate to contact me.G.C.Sorensen~~Manager, Regulatory

Programs GSC la Attachment

se 8>ose7 pubs s07soo~cv, osooo<9

Cl t/t I-~l j\~L l I I

Appendix A Appendix A Page 1 of 5 During an NRC inspection

conducted on May 29-31, 1985 violations

of NRC re-quirements

were identified.

The violations

involved adherence to Technical Specification

required proedures during a maintenance

outage involving posting of radiation areas, labeling of radioactive

material containers, work activi-ties within the drywell and control of overtime for chemistry and health physics technicians.

In accordance

with the"General Statement of Policy and Procedures

for NRC Enforcement

Actions", 10 CFR Part 2, Appendix C (1985)the violations

are listed below: A.Technician

Specification

6.2.2.f.2 states in part,"An individual

should not be permitted to work...more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7 day period...Any deviation...shall be authorized

by the plant manager...in accor-dance with written procedures

and with documentation

of the basis for granting the deviation".

Procedures

1.3.27 step 5.F states in part that any deviation shall be approved and documented

prior to approving the overtime.Contrary to the above requirements, two individuals

each worked 84'hours in seven consecutive

days prior to May 10, 1985 when the approval was documented.

In addition, the memorandum

approved by the Plant Manager dated May 10, 1985 containing

documentation

of the approval did not pro-vide the basis for granting the deviation.

These two individuals

worked 15 and 20 consecutive

12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days.This is a Severity Level V Violation (Supplement

I).Validity of Violation The Supply System concurs with the validity of this violation.

Increased management

and supervisory

attention in this area is warranted.

Corrective

Ste s Taken/Results

Achieved o A memorandom

was issued by Plant Management

to all Department

Managers/Supervisors

reinforcing

the requi rements of PPM 1.3.27.This letter specifically

identified

the need for prior authorization

of overtime deviations

and provided guidelines

for proper justification.

Corrective

Ste s To Be Taken@%o Plant Procedure 1.3.27,"Overtime Control" will be reviewed by the Plant Management

for adequacy.

r I

Date of Full Com liance Appendix A Page 2 of 5 Since issuance of the Plant Management

Memorandum

on overtime control, proper overtime authorization

and documentation

requirements

have been observed.The PPM 1.3.27 review will be completed during July, 1985 and any additional

corrective

action identified

at that time.V Technical Specification

G.ll.l states in part,"procedures

...shall be prepared consistent

with the requirements

of 10 CFR 20 and shall be...adhered to...".Plant Procedures

Manual (PPM)11.2.7.1,'Areas Post-ing'tates in part that all areas accessible

to personnel with exposure rates greater than or equal to 2.5 mrem/hr shall be posted at each acces-sible perimeter with the words'CAUTION-RADIATION AREA'nd PPM 11.2.14.3,'Storage of Radioactive

Material'tates

in part that the storage area shall be posted at any accessible

side with a"CAUTION-RADIOACTIVE

MATERIAL" sign and that each container shall also be labeled with the"CAUTION-RADIOACTIVE

MATERIAL" sign, the type of material and radiation levels at contact and three feet.Contrary to the above requirements

on May 30, 1985 the outdoor solidifi-cation work area was being used to store radioactive

material and: 1.Three steel boxes containing

compressed

radioactive

trash were not labeled at all regarding radioactive

material content;2.The storage area was not labeled at one accessible

side in that the two barrier ropes on one side of the area were both down, the sign with the radioactive

material posting was face down in sand and other posti ngs were not readily apparant;3.The area was not posted on any side as a radiation area'nd the measured radiation exposure rate at 18 inches from one container was 3.0 to 4.0 mr per hour.The above conditions

existed for about two hours prior to discovery by the NRC Inspector.

The exceptions

of 20.203 (f)(3)and 20.204 did not apply.This is a Severity Level IV Violation (Supplement

IV).Validity of Violation The Supply System concurs with the violation as stated.Corrective

Ste s Taken/Results

Achieved o The barrier was reestablished, containers

were provided with proper labels and the area was correctly posted as a radiation area.o A review of the circumstances

surrounding

this occurrence

was in-itiated and indicated this was a singular event rather than a pro-grammatic breakdown.

M Appendix A Page 3 of 5 The Health Physics (HP)Department

employee responsible

for these discrepancies

was counselled

on the necessity to follow Plant.Procedures.

The individual

was also reinstructed

on radioactive

material and area labeling/posting

requirements.

Corrective

Ste s To Be Taken~'Additionally

the radioactive

material and area labeling/posting

requirements

will be reemphasized

during a training cycle for Health Physics Technicians.

Date of Full Com liance The plant'is now in full compliance

and a six week training cycle for Health Physics Technicians

has commenced.

Tnis training cycle is sched-uled for completion

by August 16, 1985 and will reemphasize

labeling and posting requirements.

C.Technical Specification 6.8.1 states in part,"Written procedures

shall be established, implemented

and maintained

covering the activities

re-ferenced below: a.Regulatory

Guide 1.33...g.Fire Protection

Pro-gram Implementation".

RG 1.33 Appendix A, Item 9.C lists examples of safety related equipment for which procedures

should be prepared prior to beginning work.PPM 1.3.18,'Tool and Equipment Control Around Open Plant Systems's identified

by the licensee as a safety related procedure.

Tnis proce-dure, step 1.3.18.4.C

states that use of this procedure is mandatory for components

of the primary system when components

are opened for rework.Step 1.3.18.7, Procedure, states that tools shall be inventoried

and logged in and out oust e work area and that all tools and equipment shall be equipped with a lanyard.PPM 1.3.19, a licensee designated

safety related procedure prohibits the use of clay mineral sorbants in the power block (reactor building, tur-bine building).

Contrary to the above: l.On May 29, 1985, between 3PM and 5PM, work in progress on an open safety related portion of the primary system (inboard main feedwater check valve)was conducted without following procedure 1.3.18 in that tools were not logged, lanyarded or otherwi'se

controlled.

2.On May 29 and May 30, 1985, the use of prohibited

material (clay mineral absorbant)

was observed on the 572 foot elevation of the reactor building.This is a Severity Level IV Violation (Supplement

I).

Validity of Violation Appendix A Page 4 of 5 The Inspector was correct in his findings concerning

compliance

with Plant Procedure'1.3.18 and 1.3.19.The cause of these instances of non-compliance

was a fundamental

lack of awareness of the procedural

require-ments by the personnel involved.This occurred because of minimal emphasis on these procedures

during previous training.Corrective

Ste s Taken/Results

Achieved o As stated in the body of the inspection

report..."The Foreman took immediate steps to remove loose material from the vicinity of the work".In addition the Foreman initiated a"WNP-2 Tool and Equip-ment Inventory/Inspection

Sheet".This inventory/inspection

sheet was utilized for the remainder of the job resulting in the open sys-tem being"buttoned up" with assurance that system cleanliness

had been maintained.

o The clay mineral sorbent was removed from the Reactor Building.The sorbent was being used during operation of a pipethreader

and crafts using the pipethreader

were retrai ned on keeping sorbents out of the reactor building.Tnis requirement

was also clarified with all other crafts.o Plant Management

has contacted the Support Service Contractor

Man-agement to ensure that this issue receives proper emphasis by all craft organizations.

Corrective

Ste s To Be Taken o Work instructions

contained in Maintenance

Work Request'(MWR)

pack-ages are the Plant's primary method of implementing

tnese types of procedural

requirements.

It is the Supply System's perception

that engineers preparing the MWR work instructions

have not fully in-corporated

these types of procedural

requirements

into the MWR.Therefore, a multi-organization

committee has been instructed

to evaluate the Plant procedure governing MWR preparation

for possible improvements

with regard to work instruction

preparation

guidelines.

o Knowledgeable

craft personnel working to MWR instructions

are a second check for ensuring compliance

with these procedural

require-ments.Therefore, all Plant Maintenance

and Support Services Con-tractor craft personnel will be retrained in the requirements

of PPM's 1.3.18 and 1.3.19.o Both subjects discussed in this violation are considered"skill of the craft" knowledge wnich is proceduralized (Volume 10.2 series procedures

).Therefore, interfacing

generic procedures (e.g., PPM 10.2.7, Valve Troubleshooting, Handling and Repairs)will be reviewed for adequate cross referencing

of PPM's 1.3.18 and 1.3.19..

~~Appendix A Page 5 of 5 A plant procedure is currently being developed for control of chemicals in the plant.It is envisioned

that this procedure will include an adequate control mechanism that will help preclude future violations

of this nature.o The need for supervision

to conduct more frequent Plant inspections

during outages will be discussed during the"Lessons Learned" ses-sions,to be held following completion

of the current maintenance

outage.Date of Full Com liance o All identified

actions will be completed by 9/1/85.

~, t'