ML18038A199

Responds to Violations Noted in Insp Rept 50-220/86-08. Corrective Actions:Formal Memo Issued to Radiation Protection Technicians Describing Survey Requirements to Ensure Adequate Evaluation of Surfaces

ML18038A199
Person / Time
Site:	Nine Mile Point
Issue date:	08/14/1986
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NMP-19742, NUDOCS 8608260081
Download: ML18038A199 (6)

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NMP-19742 NIAGARA MOHAWKPOWER CORPORATION

.iihhhTih, NIAGARA i~~iiMOHAWK THOMAS E. LEMPGES VCR PRESOENl~lf AR CENtllATAM 300 ERIK BQULEVAR0 WCST SYRACUSE, N.Y. i3202 August 14, 1986 Dr. Thomas E. Murley Regional Administrator United States Nuclear Regulatory Commission 631 Park Avenue King Of Prussia, PA 19406

Subject:

Response

to Inspection Report No. 50-220/86-08

Dear Sir:

Niagara Mohawk herein submits responses to each of two violations described in NRC Inspection 86-08 conducted at the Nine Mile Point Unit I Facility on May 19-24, 1986.

t Notice Of Violation Item 1

50-220/86-04-03)

The Inspection Report states:

"10 CFR 20.201 requires, in part, that each licensee make or cause to be made such surveys that are necessary and reasonable to comply with 10 CFR 20.

10 CFR 20.201 defines a survey as, among other items, an evaluation of the radiation hazards incident to the presence of radioactive materials

and, when appropriate, includes a physical survey of materials and measure-ments of concentrations of radioactive material present.

10 CFR 20.103 requires among other items, that respiratory protection equipment be used as specified therein.

10 CFR 20.103 also requires the use of engineering controls to minimize airborne radioactivity concentrations.

Contrary to the above, at about 4:30 p.m.

on March 28, 1986 necessary and reasonable surveys to ensure compliance with 10 CFR 20.103 were not made during lapping operations on 815 discharge bypass valve.

As a result appropriate respiratory protection equipment was not selected and used consistent with 10 CFR 20.103 (c)(1) requirements.

The two workers lapping the valve generated airborne radioactivity with a peak concentration of about 420 times the applicable concentration specified in 10 CFR 20 Appendix B exceeding the protection factor (50) of respirators used by the workers.

In addition, appropriate engineering controls, as required by 10 CFR 20.103(b)(1),

were not used."

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Pagy NMP-19742 Niagara Mohawk response:

In our review of this violation, we concur that the cause was the inadequate contamination survey performed prior to permitting flapping operations on f115 Recirculation Loop Bypass valve, though Radiation Protection Procedure S-RP-3 provides adequate instructions.

As a result of this, the following actions have been taken to prevent recurrence of an incident of this nature:

A formal memorandum was issued to all Unit I Radiation Protection Techni-cians on 5/21/86 describing the survey requirements contained in S-RP-3 relative to insuring adequate evaluation of contaminated surfaces prior to permitting flapping or similar operations.

In addition, the memoran-dum provided instructions related to decontamination activities, fixed contamination assessment methods, criteria for requiring respirators, and the proper use of engineering controls.

This memo has been read and understood by all of the above indicated technicians in accordance with Radiation Protection Instruction RPI-1.

2.

On 5/21/86, a Radiological Incident Report (RIR-21) was issued to sum-marize the investigation of this incident including appropriate measures to prevent recurrence.

This RIR was completed on 5/23/86.

3.

On 5/23/86, Radiation Protection Instruction RPI-1, "In House Radiation Protection Technician Reading Assignments and Training", was revised to require Chief and Backshift Radiation Protection Technicians to read, understand and initial the "RP Supervisor Log Book" prior to beginning activities on a tour of duty.

4.

The contractor technician responsible for the radiological control of this flapping operation failed'to follow approved procedures that specify survey requirements and conditions requiring the use of each type of respirator.

As a corrective measure, the technician was dismissed from the site and placed on 2 year probation by his employer.

Notice of Violation Item 2 50-220/86-08-01)

The Inspection Report staes:

"10 CFR 19.12 requires in part, that all individuals,working in or frequent-ing any portion of a restricted area be instructed in precautions and pro-cedures to minimize exposure and the purpose and function of protective devices employed.

Contrary to the above, on April 28,

1986, two workers, performing grinding and lapping operations in preparation for replacing reactor water clean-up'uction valve 33-02 (highly radioactively contaminated),

were provided inadequate instructions for the installation: and use of a glove bag.

As a result, air tools were used within the'ag. "'Air'exhausting into the bag caused the bag to lose,its integrity thereby subjecting the workers to airborne radioactivity concentrations of about 800.times the applicable 10 CFR 20 concentration values.

In.addition, -and as a.result, one of the workers sustained a,limited unplanned intake of airborne radioactive material."

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~ Page NMP-19742 Niagara Mohawk response:

l<e have reviewed the details of this violation and concur with your general finding that the cause can be attributed to the insufficiency of oversight and control of contractors.

As a result of.this, the following corrective actions have been completed to prevent recurrence of this incident:

1.

Site Radiation Protection Procedure S-RP-2, "Radiation Work Permit Pro-cedure",

and'-RP-7, "Incorporating ALARA Requirements into l(ork Planning and Instruction"; have been revised to require that essential job radio-logical controls specified by the ALARA Review are incorporated into the RNP as a condition for performing the specified work.

These procedure revisions also included requirements to insure uniform ALARA radiological controls were incorporated into Rl(P's as well as requirements strengthening the oversight and control of all station radiological control.activities.

2.

A review has been performed to insure that all Radiation Protection Chief Technicians are cognizant of the memorandum issued to them on 4/30/86 concerning the incorporation of essential job radiological controls into applicable Rl)P's.

This review has concluded that these personnel have

read, and understand, the memorandum.

All active RWP's issued prior to this incident were reviewed and revised, as applicable, to insure essential,job radiological controls were incorporated into the Rl(P as a condition for the specified work.

In addition to the above completed actions, additional actions are being taken or evaluated to further reduce the potential for incident recurrence.

Each of these items will be completed by December 31, 1986.

1.

Glove bags will not be used without proper ventilation and exhaust.

Pro-cedures for use have been drafted.

2.

The contractor's Health Physics liason position will be evaluated to determine whether it aids, or interferes with, the communication link between NMPC Radiation Protection and the contractor.

3.

This construction contractor's performance is being reviewed relative to continued use in nuclear station activities.

In summary, we believe we have taken all practicable corrective actions to insure these violations will not recur.

If there are additional concerns relative to these actions, please notify my office or Mr.

Ed Leach at 315-349-2439.

Very truly yours, Thomas ED Lempges Vice President Nuclear Generation

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