IR 05000254/1997009: Difference between revisions

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| number = ML20198F350
| number = ML20198F350
| issue date = 08/07/1997
| issue date = 08/07/1997
| title = Ack Receipt of 970724 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-09 & 50-265/97-09 on 970701
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-09 & 50-265/97-09 on 970701
| author name = Grobe J
| author name = Grobe J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Line 11: Line 11:
| contact person =  
| contact person =  
| document report number = 50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9708130021
| document report number = 50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9708130021
| title reference date = 07-24-1997
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 2
| page count = 2
Line 18: Line 19:


=Text=
=Text=
{{#Wiki_filter:+ .
{{#Wiki_filter:+
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August 7. 1997 Mr. Site Vice President Quad Cities Station Commonwealth Edison Company 22710 206th Avenue North Cordova, IL 61242
August 7. 1997 Mr. Site Vice President Quad Cities Station Commonwealth Edison Company 22710 206th Avenue North Cordova, IL 61242


==Dear Mr. Kraft:==
==Dear Mr. Kraft:==
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97009(DRS);
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97009(DRS);
50-265/97009(DRS))
50-265/97009(DRS))
This wM acknowledge receipt of your letter dated July 24,1997, in response to our letter dated July 1,1997, transmitting a Notice of Violation for an event where two workers were locked in the Unit 2 drywell, a poated locked high radiation area, on May 15 1997. In your response, you indicated that the affected procedures were being revised and that workers would be trained regarding the requirements. We have reviewed your corrective actions for the v!olations and have no further questions at this time. These corrective actions will be examined during future inspections.
This wM acknowledge receipt of your letter dated July 24,1997, in response to our letter dated July 1,1997, transmitting a Notice of Violation for an event where two workers were locked in the Unit 2 drywell, a poated locked high radiation area, on May 15 1997. In your response, you indicated that the affected procedures were being revised and that workers would be trained regarding the requirements. We have reviewed your corrective actions for the v!olations and have no further questions at this time. These corrective actions will be examined during future inspections.


Sincerely, i
Sincerely, i
original signed by J. M. Jacobson 1 John A. Grobe,' Director Division of Reactor Safety Docket Nos. 50 254; 50-265
original signed by J. M. Jacobson
  '
 
Licenses No. DPR-29; DPR-30     '
John A. Grobe,' Director Division of Reactor Safety Docket Nos. 50 254; 50-265
i Enclosure: Ltr dtd 7/24/97 E. i
'
      !
Licenses No. DPR-29; DPR-30
Quad Cities to U';NRC See Attached Distribution DOCUMENT NAME: G:DRS\QUA08_7.DRS To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment /encio,sure "N" = No copy OFFICE Ritt g Rill c., Rlli Ag Rlli g g l NAME NShah:Jp @) GShear s*D 4pu JGrot$ WV M (n N fd 4 DATE 08/f/97 08/5/97 08q10,7) ' 08/ /[/97
'
  ~
i Enclosure:
Ltr dtd 7/24/97 E. i
!
Quad Cities to U';NRC See Attached Distribution DOCUMENT NAME: G:DRS\\QUA08_7.DRS To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
"E" = Copy with attachment /encio,sure
"N" = No copy OFFICE Ritt g Rill c.,
Rlli Ag Rlli g g l
NAME NShah:Jp @)
GShear s*D 4pu JGrot$ WV M (n N fd 4 DATE 08/f/97 08/5/97 08q10,7) '
08/ /[/97
~
9708130021 970807 PDR ADOCK 05000254
9708130021 970807 PDR ADOCK 05000254
    .
.
ll gp/
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_
 
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ - _ - _ _ _, _ _ - _.
.:
.-
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E. Kraf t


_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ - _ - _ _ _ , _ _ - _ .
August 7, 1997 cc w/ encl:
.: .-            !
T. J. Malman, S4:nlor Vice President, Nuclear Operations Division D. A. Sager, Vice President,'
            -,
- Generation Support H. W. Keiser, Chief Nuclear
E. Kraf t        2  August 7, 1997 cc w/ encl: T. J. Malman, S4:nlor Vice President, Nuclear Operations Division D. A. Sager, Vice President,'
:
  - Generation Support H. W. Keiser, Chief Nuclear         :
Operating Officer L. W. Pearce, Station Manager C. C. Peterson, Regulatory Affairs Manager
Operating Officer L. W. Pearce, Station Manager
,
            ,
-
C. C. Peterson, Regulatory Affairs Manager       -
1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing
1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing         ;
;
Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission J. R. Bull, Vice President, General & -
Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission J. R. Bull, Vice President, General & -
Transmission, MidAmerican Energy Company Distrib'ation:
Transmission, MidAmerican Energy Company Distrib'ation:
Docket File w/enct   Rlli PRR w/ encl   A. B. Beach, Rlil w/enct PUBLIC IE 01 w/enci   - SRis, Quad Cities,. J. L, Caldwell, Rlli w/enci ,
Docket File w/enct Rlli PRR w/ encl A. B. Beach, Rlil w/enct PUBLIC IE 01 w/enci
OC/LFDCB w/enci     Dresden, LaSalle w/onci   Rlli Enf. Coordinator w/enci '
- SRis, Quad Cities,.
LPM, NRR w/enci   TSS w/enci   R. A, Capra, NRR w/ encl.
J. L, Caldwell, Rlli w/enci
,
OC/LFDCB w/enci Dresden, LaSalle w/onci Rlli Enf. Coordinator w/enci
'
LPM, NRR w/enci TSS w/enci R. A, Capra, NRR w/ encl.


DRP w/enci   DRS w/ encl   CAA1 w/enci 3 DOCDESK w/ encl          ~
DRP w/enci DRS w/ encl CAA1 w/enci


, - ,. a    .-  - , , , n -._n, . , ~ - , _,
DOCDESK w/ encl
_ . , , .,
~


      - . - ..
,
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4)u,iit ( nin (.rns r.nine M.ition 22 io 2tu in uenue sonn i onlin .t il bil e 2 4' 4:1
a
'Iri 4t rust 4-2241 ESK-97-149 July 24,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Document Control Desk Subject: Quad Cities Station Units I and 2; l   NRC Docket Numbers 50-254 and 50-265:
.-
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-._n,
.
, ~ -,
_,
_.,,
.,
 
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< omm,ou ann i a,.n i omp.m3
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4)u,iit ( nin (.rns r.nine M.ition 22 io 2tu in uenue sonn i onlin.t il bil e 2 4' 4:1
'Iri 4t rust 4-2241 ESK-97-149 July 24,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk Subject:
Quad Cities Station Units I and 2; l
NRC Docket Numbers 50-254 and 50-265:
;
;
NRC Inspection Report Numbers 50-254/97009
'
'
NRC Inspection Report Numbers 50-254/97009 and 50-265/97009.
and 50-265/97009.


Reference: M. Leach to E. S. Kraft, Jr. Letter dated July 1,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning inadequate Radiological Controls.
Reference:
M. Leach to E. S. Kraft, Jr. Letter dated July 1,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning inadequate Radiological Controls.


This letter contains the following commitments:
This letter contains the following commitments:
1. Incorporate in QCAP 0620-01,"High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area. The procedure will be revised by August 29, 1997. (NTS # 254-100-97-00901.01)
1. Incorporate in QCAP 0620-01,"High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area. The procedure will be revised by August 29, 1997. (NTS # 254-100-97-00901.01)
2. As a result of the discussion in Attachment B (inspector request for additional information), any reference to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area Access. (NTS # 254-100-97-00901.02)
2. As a result of the discussion in Attachment B (inspector request for additional information), any reference to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area Access. (NTS # 254-100-97-00901.02)
o Ju'l 'O r i nicom comrun)     S7 O bCk C b
Ju'l o'O r i nicom comrun)
S7 O bCk C b


_ ___.___ _
_
,:
___.___ _
. , .
.,.
ESK 97149 2  July 24,1997 If there are any questions or comments concerning this letter, please refet them to Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, ext. 3609.
,:
ESK 97149


Respectfully, b' -
July 24,1997 If there are any questions or comments concerning this letter, please refe them to t
Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, ext. 3609.
 
Respectfully, b'
-
E. S. Kraft, r
,
,
E. S. Kraft, r Site Vice President l Quad Cities Station l Attachments: (A) " Response to Notice of Violation" l   (B) " Request for AdditionalInfonnation" i
Site Vice President l
cc: A. B. Peach, Regional Administrator. Region III R. M. Pulsifer, Project Manager, Nr.R
Quad Cities Station l
  - C. G. Miller, Senior Resident Inspector, Quad Cities W. D. I.eech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center
Attachments: (A) " Response to Notice of Violation" l
  . Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
(B) " Request for AdditionalInfonnation" i
A. B. Peach, Regional Administrator. Region III cc:
R. M. Pulsifer, Project Manager, Nr.R
- C. G. Miller, Senior Resident Inspector, Quad Cities W. D. I.eech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center
. Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
M.- E. Wagner, Licensing, Comed ram
M.- E. Wagner, Licensing, Comed ram


-
-
*
*
* ''
''
*
ATTACHMENT A Response to Notice cf VI:liti:n ESK 97-149 Page1 of1 STATEhENT OF VIOLATION (NRC IR 97-009-01):
ATTACHMENT A Response to Notice cf VI:liti:n ESK 97-149 Page1 of1 STATEhENT OF VIOLATION (NRC IR 97-009-01):
NOTICE OF VIOLATION 10 CFR 20.1601(d) requires that the licensee establish the controls required by paragraphs (a) and (b) of this section in a way that does not prevent individuals from leaving a High Radiation Area.
NOTICE OF VIOLATION 10 CFR 20.1601(d) requires that the licensee establish the controls required by paragraphs (a) and (b) of this section in a way that does not prevent individuals from leaving a High Radiation Area.
Line 104: Line 161:


ACTIONS TAKEN:
ACTIONS TAKEN:
1. The Timekeeping CRPT was notified and released the Operator from the U2 Drywell/ Bull Pen.
1.
 
The Timekeeping CRPT was notified and released the Operator from the U2 Drywell/ Bull Pen.


2.
2.
Line 110: Line 169:
The two CRIrrs involved in the event were denied access to RPAs until the investiga-tion could be completed.
The two CRIrrs involved in the event were denied access to RPAs until the investiga-tion could be completed.


3. The CRFrs involved were disciplined, with one being released from duties at the sta-tion.
3.
 
The CRFrs involved were disciplined, with one being released from duties at the sta-tion.
 
4.


4. Other LHRAs were evaluated for egress capability.
Other LHRAs were evaluated for egress capability.


- ACTIONS TO PREVEh"r FURTHER OCCURRENCE:
- ACTIONS TO PREVEh"r FURTHER OCCURRENCE:
Line 122: Line 185:
Full compliance was met on May 15,1997 when the individual was released from the Drywell.
Full compliance was met on May 15,1997 when the individual was released from the Drywell.


_   _
_
_


_ -- _ __
_
' *
-- _ __
  '
'
*
*
ATTACHMENT B t   Request fsr Additi:n:1 Infarm ti:n ESK 97-149 Page1 of1 In the evaluation for compliance of other LHRAs with the requirements of 10 CFR 20 1601(d), the controls used at the IB RHR room during HPCI operation were found to be incorrect. During HPCI operation, the Reactor Building Basement area on the affected unit is normally controlled as a LHRA. The egress point used was formerly controlled with a chain and pad lock. The RIrr would lock himself in the area with the key. The RP department concluded that this practice could lead to personnel being locked in the area if the PET lost the key or was injured. Dead bolts with latches that allow opening from the inside without a
'
*
ATTACHMENT B t
Request fsr Additi:n:1 Infarm ti:n ESK 97-149 Page1 of1 In the evaluation for compliance of other LHRAs with the requirements of 10 CFR 20 1601(d), the controls used at the IB RHR room during HPCI operation were found to be incorrect. During HPCI operation, the Reactor Building Basement area on the affected unit is normally controlled as a LHRA. The egress point used was formerly controlled with a chain and pad lock. The RIrr would lock himself in the area with the key. The RP department concluded that this practice could lead to personnel being locked in the area if the PET lost the key or was injured. Dead bolts with latches that allow opening from the inside without a key were ordered. Until the dead bolts could be installed, RP decided to use a flashiag light and posting to control the IB RHR room entrance. Th4 decision was based upon the in-
'
'
key were ordered. Until the dead bolts could be installed, RP decided to use a flashiag light and posting to control the IB RHR room entrance. Th4 decision was based upon the in-terpretation of the procedure that RP could control this LHRA with a flashing light and post-ing. RP did not want to lock the area because of the safety concern. This interpretation lead to the incorrect usage of the flashing light to control the LHRA.
terpretation of the procedure that RP could control this LHRA with a flashing light and post-ing. RP did not want to lock the area because of the safety concern. This interpretation lead to the incorrect usage of the flashing light to control the LHRA.


I l
I l
Line 137: Line 204:
RP came to this conclusion due to a seal being placed on the door, indicating that no one had attempted to or accessed the area.
RP came to this conclusion due to a seal being placed on the door, indicating that no one had attempted to or accessed the area.


To prevent the incorrect usage of a flashing light to control LHRAs in the future, any refer-l ence to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area j Access. (NTS # 254-100-97-00901.02).
To prevent the incorrect usage of a flashing light to control LHRAs in the future, any refer-l ence to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area j
Access. (NTS # 254-100-97-00901.02).
}}
}}

Latest revision as of 04:54, 24 May 2025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-09 & 50-265/97-09 on 970701
ML20198F350
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 08/07/1997
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kraft E
COMMONWEALTH EDISON CO.
References
50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9708130021
Download: ML20198F350 (2)


Text

+

.

August 7. 1997 Mr. Site Vice President Quad Cities Station Commonwealth Edison Company 22710 206th Avenue North Cordova, IL 61242

Dear Mr. Kraft:

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97009(DRS);

50-265/97009(DRS))

This wM acknowledge receipt of your letter dated July 24,1997, in response to our letter dated July 1,1997, transmitting a Notice of Violation for an event where two workers were locked in the Unit 2 drywell, a poated locked high radiation area, on May 15 1997. In your response, you indicated that the affected procedures were being revised and that workers would be trained regarding the requirements. We have reviewed your corrective actions for the v!olations and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, i

original signed by J. M. Jacobson

John A. Grobe,' Director Division of Reactor Safety Docket Nos. 50 254; 50-265

'

Licenses No. DPR-29; DPR-30

'

i Enclosure:

Ltr dtd 7/24/97 E. i

!

Quad Cities to U';NRC See Attached Distribution DOCUMENT NAME: G:DRS\\QUA08_7.DRS To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure

"E" = Copy with attachment /encio,sure

"N" = No copy OFFICE Ritt g Rill c.,

Rlli Ag Rlli g g l

NAME NShah:Jp @)

GShear s*D 4pu JGrot$ WV M (n N fd 4 DATE 08/f/97 08/5/97 08q10,7) '

08/ /[/97

~

9708130021 970807 PDR ADOCK 05000254

.

ll gp/

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

.:

.-

-,

E. Kraf t

August 7, 1997 cc w/ encl:

T. J. Malman, S4:nlor Vice President, Nuclear Operations Division D. A. Sager, Vice President,'

- Generation Support H. W. Keiser, Chief Nuclear

Operating Officer L. W. Pearce, Station Manager C. C. Peterson, Regulatory Affairs Manager

,

-

1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing

Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission J. R. Bull, Vice President, General & -

Transmission, MidAmerican Energy Company Distrib'ation:

Docket File w/enct Rlli PRR w/ encl A. B. Beach, Rlil w/enct PUBLIC IE 01 w/enci

- SRis, Quad Cities,.

J. L, Caldwell, Rlli w/enci

,

OC/LFDCB w/enci Dresden, LaSalle w/onci Rlli Enf. Coordinator w/enci

'

LPM, NRR w/enci TSS w/enci R. A, Capra, NRR w/ encl.

DRP w/enci DRS w/ encl CAA1 w/enci

DOCDESK w/ encl

~

,

-

,.

a

.-

-,,,

n

-._n,

.

, ~ -,

_,

_.,,

.,

-

.

-

..

< omm,ou ann i a,.n i omp.m3

4)u,iit ( nin (.rns r.nine M.ition 22 io 2tu in uenue sonn i onlin.t il bil e 2 4' 4:1

'Iri 4t rust 4-2241 ESK-97-149 July 24,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:

Document Control Desk Subject:

Quad Cities Station Units I and 2; l

NRC Docket Numbers 50-254 and 50-265:

NRC Inspection Report Numbers 50-254/97009

'

and 50-265/97009.

Reference:

M. Leach to E. S. Kraft, Jr. Letter dated July 1,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning inadequate Radiological Controls.

This letter contains the following commitments:

1. Incorporate in QCAP 0620-01,"High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area. The procedure will be revised by August 29, 1997. (NTS # 254-100-97-00901.01)

2. As a result of the discussion in Attachment B (inspector request for additional information), any reference to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area Access. (NTS # 254-100-97-00901.02)

Ju'l o'O r i nicom comrun)

S7 O bCk C b

_

___.___ _

.,.

,:

ESK 97149

July 24,1997 If there are any questions or comments concerning this letter, please refe them to t

Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, ext. 3609.

Respectfully, b'

-

E. S. Kraft, r

,

Site Vice President l

Quad Cities Station l

Attachments: (A) " Response to Notice of Violation" l

(B) " Request for AdditionalInfonnation" i

A. B. Peach, Regional Administrator. Region III cc:

R. M. Pulsifer, Project Manager, Nr.R

- C. G. Miller, Senior Resident Inspector, Quad Cities W. D. I.eech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center

. Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)

M.- E. Wagner, Licensing, Comed ram

-

ATTACHMENT A Response to Notice cf VI:liti:n ESK 97-149 Page1 of1 STATEhENT OF VIOLATION (NRC IR 97-009-01):

NOTICE OF VIOLATION 10 CFR 20.1601(d) requires that the licensee establish the controls required by paragraphs (a) and (b) of this section in a way that does not prevent individuals from leaving a High Radiation Area.

Contrary to the above, on May 15, 1997, the licensee failed to provide an individual an exit from the Unit 2 Drywell, which was a posted Locked High Radiation Area controlled per 10 CFR 20.1601(a) and (b).

This is a Severity Level IV violation (Supplement IV).

l

'

REASON FOR VIOLATION:

The cause of the event was determined to be a personal performance problem on the past of the Contract RFr (CRPT), who as the LHRA Timekeeper, failed to verify all personnel had exited the LHRA prior to locking it down.

ACTIONS TAKEN:

1.

The Timekeeping CRPT was notified and released the Operator from the U2 Drywell/ Bull Pen.

2.

The two CRIrrs involved in the event were denied access to RPAs until the investiga-tion could be completed.

3.

The CRFrs involved were disciplined, with one being released from duties at the sta-tion.

4.

Other LHRAs were evaluated for egress capability.

- ACTIONS TO PREVEh"r FURTHER OCCURRENCE:

Incorporate in QCAP 0620-01, "High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area.

The procedure will be revised by August 29,1997. (NTS # 254-100-97-00901.01).

DATE WHEN FULL COMPLIANCE WILL BE MET:

Full compliance was met on May 15,1997 when the individual was released from the Drywell.

_

_

_

-- _ __

'

'

ATTACHMENT B t

Request fsr Additi:n:1 Infarm ti:n ESK 97-149 Page1 of1 In the evaluation for compliance of other LHRAs with the requirements of 10 CFR 20 1601(d), the controls used at the IB RHR room during HPCI operation were found to be incorrect. During HPCI operation, the Reactor Building Basement area on the affected unit is normally controlled as a LHRA. The egress point used was formerly controlled with a chain and pad lock. The RIrr would lock himself in the area with the key. The RP department concluded that this practice could lead to personnel being locked in the area if the PET lost the key or was injured. Dead bolts with latches that allow opening from the inside without a key were ordered. Until the dead bolts could be installed, RP decided to use a flashiag light and posting to control the IB RHR room entrance. Th4 decision was based upon the in-

'

terpretation of the procedure that RP could control this LHRA with a flashing light and post-ing. RP did not want to lock the area because of the safety concern. This interpretation lead to the incorrect usage of the flashing light to control the LHRA.

I l

No unauthorized access to the LHRA had occurred during the usage of the Dashing light.

RP came to this conclusion due to a seal being placed on the door, indicating that no one had attempted to or accessed the area.

To prevent the incorrect usage of a flashing light to control LHRAs in the future, any refer-l ence to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area j

Access. (NTS # 254-100-97-00901.02).