ML17334B735
| ML17334B735 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/15/1998 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-315-98-06, 50-315-98-6, 50-316-98-06, 50-316-98-6, AEP:NRC:1285, NUDOCS 9804220313 | |
| Download: ML17334B735 (22) | |
Text
CATEGORY REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)'CESSION NBR:9804220313 DOC.DATE: 98/04/15 NOTARIZED: YES DOCKET ACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315
.50-33,6 Donald C.
Cook Nuclear Power Plant, Unit 2, "Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
RECXP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 980305 ltr re violations noted in radiation C
protection insp repts 50-315/98-06
& 50-316/98-06.Corrective actions:counseled workers
& RP on proper use of electronic A
dosimeters
&,deactivated RWP 98-1040-02'.
DISTRIBUTION CODE:
IE06D COPIES RECEIVED:LTRj ENCL
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SIZE:
/0 TITLE: Environ
& Radiological (50 DKT)-Insp Rept/Notice of Violation ResponsE NOTES:
RECIPIENT ID CODE/NAME PD3-3 PD INTERNAL: AEOD/TTC NMSS/SFPO 06F18 NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME STANG, J FILE CE NRR/DRPM/PERB OE DIR RGN3 FILE 01 COPIES LTTR ENCL 1
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ERNAL: NOAC NUDOCS FULLTEXT 1'
1 1
NRC PDR D
U NOTE TO ALL NRIDSN RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 II TOTAL NUMBER OF COPIES REQUIRED:
LTTR 13 ENCL 13
J L'~'l 4l
Indiana Michigan Power Company, 500 Ci;cie Dn~e BUchanan. Ml 49107 1395 INblANA MICHIGAN PQWER April 15, 1998 AEP:NRC:1285 Docket Nos.:
50-315 50-316 U.
S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-Pl-17 Washington, D.C.
20555-0001 Gentlemen:
Donald C.
Cook Nuclear Plant Units 1 and 2
RESPONSE
TO NRC ROUTINE RADIATION PROTECTION ZNSPECTION REPORT NOS.
50-315/98006(DRS);
50-316/98006(DRS)
AND NOTICE OF VIOLATION This letter is in response to a letter from John A. Grobe, dated March 5,
- 1998, that forwarded a
The violations of NRC requirements were identified during an inspection conducted from February 9,
1998, through February 13, 1998.
Three violations were identified associated with procedural adherence.
The first violation was associated with two workers who entered an extreme high radiation area with their electronic dosimetry turned off.
The second violation concerned the failure to follow procedural requirements when a
worker contaminated with a hot particle received two alarms from the security gate house monitors
'and did not call radiation protection.
The third violation concerned workers who failed to follow the requirements of their radiation work permit.
In addition, two apparent violations were identified associated with a transportation event.
A notice of violation was not issued for these apparent violations; however, we were requested to respond to each apparent violation.
Our response to the three violations is provided in attachment 1 to this letter.
Attachment 2 contains our response to the apparent violations.
Sincerely, r/~
/
E.
E. Fitzpatrick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THI
/ 5
- DAYOF, 1998
/vlb Attachments J.
A. Abramson A. B. Beach MDEQ -
DW Ec RPD NRC Resident Inspector J.
R.
Sampson My Commission Expires
<Ai~.CE hL BICKEFIS Notary Pohc, Bernen County, M My Commission Expires Feb. 16, 2001 9804220313 980415 PDR ADOCK 050003l5 G
ATTACHMENT 1 TO AEP:NRC: 1285
RESPONSE
TO NRC ROUTINE RADIATION PROTECTION INSPECTION REPORT NOS.
50-315/98006 (DRS); 50-316/98006 (DRS)
Attachment 1 to AEP:NRC: 128S Page 1
During an NRC inspection conducted from February 9,
- 1998, through February 13, 1998, violations of NRC requirements were identified.
Zn accordance with. the "General Statement of Policy and Procedure for NRC Enforcement Actions", NUREG-1600, the violations are listed below, followed by our response.
Following the specific responses to the violations is a general response to the issue of contractor training and declining radiation worker performance.
NRC Violation No.
1 Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation protection.
Donald C. Cook Nuclear Power Plant Procedure No. 12 THP 6010 RPP.120, Revision 0,
"Zssue and Control of Dosimetry",
a procedure for personnel radiation protection, step 5.3.3.a.
requires, in part, that care must be exercised by the individual using an ED (electronic dosimeter) to confirm that it is operating properly by ensuring that it is ON prior to RCA (radiologically controlled area) entry.
Contrary to the
- above, on November 6,
- 1997, two radiation workers entered the RCA without confirming that their EDs were on, when in fact, the EDs were turned off.
This is a Severity Level ZV Violation (Supplement ZV).
B.
Donald C.
Cook Nuclear Power Plant Procedure No.
"Radiation Work Permit Program, "
a procedure for personnel radiation protection, step 4.1.1
- requires, in.part,, that all personnel are responsible for understanding and complying with the requirements of the posted revision of the RWP (radiation work permit).
RWP Number 981040, revision 02, "U1F98
& U2F99/U-1 fc U-2 Upper Containment Maintenance,"
task 2, describes anti-contamination clothing requirements including wearing double gloves in the ice condenser area.
Contrary to the above, on February 12, 1998, radiation workers signed onto RWP 981040 were performing work in the Unit 1 lower ice condenser area without wearing double gloves.
This is a Severity level TV Violation (Supplement IV)."
Res onse to NRC Violation No.
1A Admission or Denial of the Alle ed Violation We admit to the violation as cited in the NRC notice of violation.
I,
Attachment 1 to AEP:NRC:1285 Page 2
2.
Reason for the Violation The cause of this violation was ineffective training of contract personnel.
On November 6,
- 1997, two contract workers entered the unit 2 regenerative heat exchanger room to prepare for.welding to be performed.
After a few minutes, both workers discovered their electronic dosimeters (EDs) were turned off, notified RP, and left the regenerative heat exchanger room.
The workers were working under a radiation work permit (RWP) that had several different tasks.
Each task required different dose rate and accumulated dose settings.
This is done by having the radiation worker log
~ into the Prorad
- system, then having a radiation protection technician (RPT) adjust the dose and dose rate settings using an Alnor dosimetry reader (ADR). After logging into the Prorad system" and verifying that their EDs were on, the two contract workers gave their EDs to a contract RPT to adjust the dose rate and accumulated dose settings using an ADR.
- used, hut was not adequately trained on their use.
During the adjustment process, the ADR had, in fact, turned off the EDs.
Upon removal from the ADR, the.EDs were not checked by the RPT to verify that they were still on.
The workers did not expect that the ADR would turn off their EDs and therefore, did not verify that'hey were still on prior to entering the radiologically controlled area.
3.
Corrective Action Taken and Results Achieved The workers identified that their EDs were not on, exited'the regenerative heat exchanger
- room, and notified radiation protection (RP).
The workers and RP were counseled on the proper use of EDs.
4.
Corrective Actions to Avoid Further Violations The preventive actions for this violation are as follows.
~
An operator aid for the use of the ADR was completed on December 1,
1997.
Training regarding use of the ADR was incorporated into.
the continuing training program.
Training will be completed by June 30, 1998.
5.
'ate When Full Com liance Will Be Achieved Full compliance was achieved on November 6, 1997, after the workers involved were counseled on the proper use of EDs.
Res onae to NRC Violation No.
1B 1.
Admission or Denial of the Alle ed Violation We admit to the violation as cited in the NRC notice of violation.
IS li
Attachment 1 to AEP:NRC:1285 Page 3
2..
Reason for the Violation The cause of this violation was ineffective training and oversight of contractor personnel.
On February 12, 1998, while observing work being performed in the lower ice.condenser, NRC inspectors identified several contract workers who were not wearing two sets of gloves as required by their RWP.
The workers stated that this practice had been occurring for two to three weeks.
Corrective Action Taken and Results Achieved RWP 98-1040-02 was deactivated by RP an'd work on this job stopped.
I Corrective Actions to Avoid Further Violations Preventive actions for this violation are as follows.
5.
The RP supervisor discussed the expectation that all personnel follow procedures and RWP requirements with the work group supervisor.
The RP supervisor discussed these expectations with the project management and installation services (PM&ZS)
- manager, the PM&ZS production supervisor, and the contract site manager.
Tailgate meetings were held with craft supervision emphasizing the expectation that all RWP requirements be met prior to reactivating the RWP.
Date When Full Com liance Will Be Achieved.
Full 'compliance was achieved on February 12, 1998, after the workers involved were counseled on literal compliance with RWPs.
NRC Violation No.
2 II2 ~
Technical Specification 6.8.1 requires that procedures be established, implemented and maintained covering activities referenced in the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, revision 2, February 1978.
Appendix "A"
of Regulatory Guide 1.33, revision 2,
February
- 1978, step 7.e.(4) recommends that procedures be established governing contamination control activities.
Donald C. Cook Nuclear Power Plant Procedure No.
2 PMP 6010 RPP.300, revision 8,
"Contamination Control Program,"
a Regulatory Guide 1.33 recommended procedure, 'tep 5.3.4,
- describes how to use a walk through portal-mon9.tor, and requires, in part, that if a contamination alarm is received a second (validation) count can be performed; and if a second (VALZD) contamination alarm is received then notify RP
.(radiation protection) and wait in 'the immediate area until RP arrives.
Contrary to the above, on November 10,
- 1997, an individual alarmed a walk through portal-monitor twice, but did not
1
Attachment 1 to AEP:NRC:1285 Page 4
notify radiation protection or wait in the immediate area until radiation protection personnel arrived.
This is a Severity Level ZV Violation (Supplement XV)."
Res onse to NRC Violation No.
2 1.
Admission or Denial of the Alle ed Violation We admit to the violation as cited in the NRC notice of violation.
2.
Reason for the Violation The cause of this violation was ineffective training of contractor personnel.
1 On November 10,
- 1997, a worker exited the protected area through the security gate house portal monitors.
The worker alarmed the monitors
- twice, then went through again and passed the third time.
The worker was not aware at that time that he was required to notify RP if the monitor alarmed twice.
Procedure No. 12 PMP 6010.RPP.300 provides the corrrect alarm response process.
- However, this worker's actions suggest that the process is not effectively communicated during the short qualification class.
'A video of correct monitor response is presented 'n the full qualification class.
During the shorter qualification class, this video is not used.
The instructor states the correct process, but the class handout does not give clear direction consistent with the verbal instructions.
Corrective Action Taken and Results Achieved The worker was counseled concerning the proper action to take when portal monitor alarms are encountered.
The particle was removed and a dose assessment was performed.
Corrective Actions to Avoid Further Violations The preventive actions for this violation are 'as follows.
~
Appropriate contract employees were briefed regarding the incident.
~
Training material regarding portal monitor alarm response will be evaluated by April 22, 1998.
Corrective actions"will be completed by May 15, 1998.
~
A method to inform workers of the required response in the event of a
second alarm was put in place on April'0, 1998.
Date When Full Com liance Will Be Achieved.
Full compliance was achieved on November 10, 1997, after the worker was counseled on the proper action to take in the event of a portal monitor alarm.
k
Attachment 1 to AEP:NRC:1285 Page 5
General Res onse to the Violations In each case there was an issue with the proper training of contract radiation workers.
In aggregate, this suggests a decline in radiation worker performance.
Therefore, we are also pursuing the following additional actions to avoid further violations on a broad basis.
A self-assessment will be performed to identify potential weaknesses in the radiation worker program.
This will be completed by June 15,
- 1998, and will develop scheduled actions for program improvement as necessary.
A review of contractor training for compliance with PMI-5080, "Administration of Contractors", will be performed.
This review will be completed by June 1,
1998.
II f,
if 'I ii
ATTACHMENT 2 TO AEP:NRC: 1285
RESPONSE
TO APPARENT VIOLATIONS IN NRC INSPECTION REPORT NOS. 50-315/98006; 50"'316/98006
Attachment 2 to AEP:NRC:1285 Page 1
NRC A arent Violation No.
1 "49 CPR 172.200 requires, in part, that each person who offers a
hazardous material for transportation shall describe the hazardous material on the shipping paper in the manner required by this subpart (subpart C).
The failure to include shipping papers is an apparent violation of 49 CFR 172.200 (EEZ 50-315/98006-01 and 50-316/98006-01)."
Contrary to thi's, on January 26, 1998, a shipment left Cook Nuclear Plant without the proper shipping papers.
NRC A arent Violation No.
2 "49 CPR 172.600 requires, with exceptions not applicable here, that no person may offer for transportation, accept for transportation,
- transfer, store or otherwise handle during transportation, a
hazardous material unless emergency response information conforming to subpart G-of 49 CFR Part 172 is immediately available for use at all times the hazardous material is present.
Pursuant to 49 CPR 172.101, radioactive material is classified as hazardous material.
The failure to include the emergency response information with the shipment is an apparent
.violation of 49 CPR 172. 600 (BEI 50-315/98006-02 and 50-316/98006-02)
Contrary to this, on January 26,
- 1998, a shipment left the Cook Nuclear Plant without the proper emergency response information.
Res onse to A arent Violations Reason for the A
arent Violation The cause of these apparent violations was
,poor communication.
On January 26,
- 1998, a truck from a contract trucking firm arrived on site to pick up a shipment of two packages that contained coolant pump oil coolers. and air coolers.
These components had been surveyed and were determined to be radioactive material, surface contaminated objects:
codes 7, UN2913, SCOII.
The boxes were loaded onto the truck and the placards were positioned to indicate the type of cargo.
The contract trucking firm's driver was instructed to wait for the radioactive shipping manifest (RSM) to be given to him by.the radioactive material control personnel.
The RSM would be available once the outgoing radiological surveys of the loaded truck were complete.
While the surveys were being done, our shipping and receiving personnel added a
non-radioactive drum of oil to the shipment.
A copy of the shipping
- memo, containing a brief description of the oil coolers, air coolers, and the drum of
- oil, was presented to the driver for his signature.
The driver signed the memo, and received a copy of it.
Although the memo described the materials being shipped, it did not state that the coolers were contaminated materials.
The driver mistook the shipping memo for the RSM and because the shipping memo did not indicate contaminated materials,
f Il l
Attachment 2 to AEP:NRC: 1285 Page 2
repositioned the truck placards.
The driver then left the site without the required RSM package.
The violations have been reviewed and the safety significance of both is negligible.
Emergency instructions that would have been supplied by the plant are similar to instructions found in the "North American Emergency
Response
Guidebook".
The driver had a copy of the guidebook in his possession, and emergency response organizations (e.g.,
law enforcement and fire) keep a copy in their response vehicles.
The onboard packages were marked as "Radioactive-SCO",
and in the event of an accident, the driver and first responders could have referred to the guidebook to obtain the correct emergency instructions.
The paperwork would have supplied the driver specific information relative to the shipment, such as radiological survey
- results, nuclides, and activity
- present, and instructions for maintaining the shipment as exclusive use.
Even with the required paperwork, the shipment would have been transported exactly as it was between Cook Nuclear Plant and Toledo, except for the lack of radioactive placarding.
The radiological condition of the transport vehicle was well within the limits listed in 49 CFR 173.441 and 443.
Corrective Ste s Taken and Results Achieved When it was discovered that the driver had left site without the
- RSM, the dispatch office for the trucking firm was contacted and a copy of the RSM was faxed to them.
They located the driver and instructed him to pull over and wait for the RSM paperwork to be delivered.
The RSM paperwork was delivered to the driver and the truck placards correctly positioned.
The driver proceeded to the delivery site, with full paperwork and without further incident.
Corrective Ste s to Avoid Further Violations 4 ~
To prevent further occurrences of thi's type, all personnel who deal with drivers of radioactive material shipments will be required to review the documentation of the event, with emphasis placed on the potential for a driver to mistake a
shipping memo for an RSM.
A policy has been adopted requiring that drivers who are picking up radioactive material shipments from locations other than inside the protected area or at the radioactive materials storage building (RMSB) will be escorted at all times.
Zf the driver is inside the protected
- axea, he is physically prevented from leaving by the security fences.
When at the
- RMSB, he is already escorted by radioactive materials control personnel.
This will provide reasonable assurance that a driver will not leave the site until in possession of the RSM.
Date When Full Com liance Will Be Achieved Full compliance was achieved on January 26,
- 1998, when the shipping papers and emergency response information was delivered to the driver.