ML18038A199
| 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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