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)

See also: IR 05000220/1986008

Text

r 1 NMP-19742 NIAGARA MOHAWK POWER CORPORATION.iihhhTih, NIAGARA i~~i iMOHAWK 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." 8b082b0081

Sb0814 PDR ADOCK 05000220 8<DR

.a Ji

Pagy-2-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."

r

~~Page-3-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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