IR 05000293/1977031
| ML20136B308 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim, 05000471 |
| Issue date: | 05/12/1978 |
| From: | Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Galligan T BOSTON EDISON CO. |
| Shared Package | |
| ML20136B279 | List: |
| References | |
| NUDOCS 7909040541 | |
| Download: ML20136B308 (1) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
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Region I M $79 ,,
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Report No. _50-293/77-31 -
50-293
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Docket,No.
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C Category _
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Priority _
R License No. __ OPR-35 Boston Edison Comoany Licensee: .
800 Bov1ston Street 02199 Boston Massachusetts Pilcrim Nuclear Power Station, Unit 1 Facility Name: _
Inspection at: Plymouth, Massachusetts ovemb r 2,*3., 1977 inspection conducted: / ' -
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date signed Invectors:
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" n. 'g, Radiation Special ~ t
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h 1 - it [% _
- 4 oW e ma cate signed
% L. inonus, Radiation 5pectahsti
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data signed
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cate signed Approved by: hJ. Knapp, Chief, Radiabfbn Support g Section FF&PS Branch
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O Inspection Summary:
28-30, 1977 (Report No. 50-293/77-31)_
O Inspection on NovemberSpecial, unannounced inspection of the Radia Areas Inspected _:
Program, 23, particularly as it relates to the personnel 1977. d observa- over November review tions.
of procedures, review of records, independent 28,1977,5:00PM-7:30PM).
regularhours(November Results:
21 inspector-hours oninsite by the following areas:(infraction - failure to maintain personnel instruct to failureexposu
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Paragraph 2); (infraction - failure to accordance with 10 CFR 20.101 h4);
personnel in accordance with 10 CFR 19.12. Paragraph 3); (inf C, .
follow procedures in accordance with Techn
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Paragraph 5).
gggy[
Region I Fom 12 (Rev. April 77)
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DETAILS 1. Persons Contacted
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- P. McGuire, Manager, Pilgrim Nuclear Power Station (PNPS)
- R. Swetnam, Senior Radiological Health and Safety Engineer (PNPS)
- M. Naughton, Chief Technical Engineer (PNPS)
- R. Tis, Public Relations, Boston Edison Company (BEco)
V. Stagliola, Radioactive Waste Coordinator (PNPS)
R. O'Neil Maintenance Supervisor (PNPS)
A. Richards Health Physics (HP) Technician (PNPS)
J. Walker, Foreman, Crouse Company
.ne inspector also talked with and interviewed several other per-
" sonnel in the course of the inspection including members of the Hea*.h Physics (HP) staff and Yankee Nuclear Services - Dosimetry.
n m * denotes those personnel present at the management exit interview conducted November 30, 1977.
2. Event Description On November 23, 1977, two contractor personnel (Repairman A; Re-paiman B) (Crouse Company), were assigned to repair valve CV-13B LA located in the Clean Waste Process Room (Radwaste Floor Elevation -
i foot), on the top of Clean Waste Receiver Tank T-3018. The g inspector noted that the Clean Waste Process Room was posted as a
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High Radiation area and locked in accordance with Technical Speci-fication 6.13. A radiological survey performed November 21, 1977 O to support the valve repair operation indicated that radiation levels were between 150 and 1000 mrem per hour and surface contami -
O nation levels were approximately 100,000 dpm per 100 cd. Entry and work in the area was controlled by Radiological Work Permit (RWP) 77-1204 " Clean Waste Tank Room - Repair CV-13B Valve" dated November 21,1977.
The following details reflect information provided to the inspector from interviews with various personnel who were associated with the
, job evol,ution.
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- Event Chronolooy Event Description _
Approximate Time The personnel associated with this 1045-1110 event (Repaimen A and B, Crouse
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Foreman, Maintenance Supervisor, HP Engineer, and HP Technician) gathered at the step-off pad comon to both.
the Clean Waste Process Room and the Sludge Tank Receiver Room (see Figure 1). Since none of the personnel knew where valve CV-138 was located within the Clean Waste Process Room, direc-tions were solicited from the Rad Waste Coordinator who was in the vicinity. The Coordinator explained c>. .
the location of the valve usino a MS survey map for reference, and indi-cated the position of service outlets ki and the tank configuration. The
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within the dotted lines in the lower k. ' o -- right hand corner of Figure 1. The wording appearing on Figure 1 was not present in the survey map shown to the workers. It is apparently at m this point that all personnel mistook the entrance to the Sludge Tank N Receiver Room for the entrance to
- the Clean Waste Process Room (the rooms are adjacent to each other but o the entrances were not identified),
and after the Coordinator left the o area the personnel apparently assumed that door "A" (Figure 1) was the access to the Clean Waste Process Room, since it was most visible from the step-off pad.
I 1110-1112 Repairmen A and B. in accordance with ,
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the provisions of RWP-77-1204 for entering the Clean Waste Process I Room, used the key given them by the I HP Engineer to unlock the access to the Sludge Tank Receiver Room (door
"A").
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NOTE: On December 7,1977, the Maintenance Supervisor stated to the inspector in a telephone conversation that he knew the distinction between the two rooms but had left the area prior to the Repairmen A and B entering the Sludge Tank Receiver Room (door "A"); and therefore did
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not observe the error.
Upon entering, Repaimen A and B de-termined that they could not locate the service outlet and returned to the step-off pad for further infoma-o tion.
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v The HP technician inquired at the Rad 1112-1113 Waste Control Room (Figure 1) as to
the location of the outlets and was told that they were located four (4)
feet either side of the tank vault
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t' access ladder. The technician con-( veyed this infomation to Repairmen A
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and B.
Lo Repairmen A and B, re-entered the cy ' 1113-1115 Sludge Tank Receiver Room and deter-
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mined that the service outlets were not located as previously described.
O Repairman B climbed the tank vault access ladder and found that there o was a locked gate (gate "C", Figure 1) on the top of the vault wall.
Repaiman B noted that there was a service outlet on the other side of the gate. The repairmen returned to the step-off pad to inform personnel
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of the locked gate.
An apparent short discussion took 1115-1116
- place between the personnel at the step-off pad concerning the gate (gate "C"), at the conclusion of
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which the HP technician gave the Repairmen his "Hi-Rad" key to use to open. the gate.
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The repaimen re-entered the Sludge 1116-1121 -
Tank Receiver Room; and Repaiman B ;
apparently tried the key on the locked gate (gate "C") and found that it did not fit the lock. However,
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Repairman B found that the chest-hich gate could easily be opened by re ch-ing over and operating the kn % from the other side, which he d'd.
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NOTE: The HP Enginen stated to the inspector on Nove#.,er 30 and December 6, 1977, that shortly after the Repaimen re-entered the room he had left the area and did not witness any
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further actions on the part of the y ren;rmen. At this point Repairmen A and B contend, upon opening gate cd "C", Repairman A returned to the step-off pad and infomed the personnel
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there that the "Hi-Rad" key did not
- fit the lock, but that Repaiman B had defeated the locked gate and that they intended to enter; and that the
' personnel at the control point concurred M with this intention and Repaiman A g returned to the Sludae Tank Receiver
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Room. On November 29 and December 5,
_ 1977, the HP technician denied to the inspector that he was informed of the o fact that the locked gate had been defeated. On December 5, 1977, the O
Crouse foreman stated that he did not recall such a connunication occurring.
Both repaimen explored the tank room and detemined that the tank was not as described by the Rad Waste Coordinator; and that there was no valve at the location previously indicated. Both repairmen left the room and returned to the step-off pad.
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. Upon notifying personnel at the step-off pad that they could not locate the valve, the HP technician made a l
routine check of the 0 to 1 Roentgen self-reading dosimeters of both personnel and found them to be off- ;
scale. The HP technician then ordered both personnel to exit the area and report to the Yankee Nuclear Services office (onsite) for immediate TLD read-out.
Both repaimen reported to the Yankee Nuclear Services officeThe (onsite) for TLD read-out at 1140.
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T Repaiman A - 2.910 rem, whole body dose, gama
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- Repaiman B - 3.561 rem, whole aody dose, gama '
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The inspector noted that 10 CFR 20.101(b)(1) " Ex f- body exposures not to exceed 3 rem per calendar quarterThe providing ( the specifications of 10 CFR 20.101 (b)(2) and (3) are met.
m inspector verified that the subject specifications and that this wer the regulatory limit of 3 rem per calendar quarter: (77-31-01)
N item constituted noncompliance with 10 CFR 20.101(b).
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The inspector further evaluated the TLD dosimeters worn by Repairmen o A and B and noted that the devices were the standard type badgesT developed by the Harshaw Chemical Company.
o a plastic holder containing two (2) TLD cards (G two TLD-700 chips and the NG-67 card contained one each of the TLD-600 and TLD-700 chips.
The inspector observed from the record (Form E-5.1) of the licens contracted dosimetry service (Yankee Nuclear Services) that the following values were generated from the individual's TLD dorimeters:
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Chip 1 Chip 2 Card Type _
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3.156 rem 2.910 rem 4tepairman A G-7 3.029 rem NG-67 3.181 rem 3.651 rem 3.561 rem Repairman B G-7 3.354 rem NG-67 3.563 rem Upon reviewing Yankee Nuclear Services' procedure MC-4 "TLD Manu System 2000 - Evaluation of TLD Readout Results" the inspector found that providing certain specifications are met, the whole body dose to be assigned to an individual is taken from the value exhibited The inspector axamined the dosimetry records by Card G-7, Chip 2.of other individuals at the station and found that th tions of this procedure appeared to be consistently applied.
to In the case of Repairman A, the inspector noted tr t the Card G-7.
T Chip 2 exhibited the only value that did not exceed the regulatory limit as set forth in 10 CFR 20.101.
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Upon interviewing representatives of the licensee Yankee Nuclear Services, and Harshaw Chemical Company on December 5, 6 and 7.
1977, the inspector found that excluding policy and procedural
{- practices, and considering also the shielding configurations that are presented by the TLD dosimeter holder (badge) and the over-lapping TLD cards, there appeared to be no sound technical basis to supporting the contention that the Card G-7, Chip 2 provides the N best measurement of an individual's whole body exposure.
~ The inspector noted from these conversations that all four o chips appear to be capable of exhibiting equally vali o- i.e., gama; and observed in the application-of. statistical analysis, .
that these measurements are indicative of a center of a distribu tion (the central tendency) which provides the best estimate of the dose received and is expressed by the arithmetic mean of the measure-ments, i.e., 3.069 rem, which exceeds the applicable regulatory.
limit as set forth in 10 CFR 20.101.
The inspector indicated that pending re-evaluation by the licensee, (77-
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Repaiman A's dose estimate would be considered unresolved.
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3. Instructions to Workers The inspector noted that 10 CFR 19.12,." Instructions to Workers,"
requires the licensee to inform all individuals working in restricted areas of the location and presence of radioactive raterial and ,
radiation; and to instruct such individuals of the health protec-tion problems associated with exposure to such material and radia-tion, including precautions and procedures to minimize exposure.
Through interviews with the personnel involved in the overexposure event of November 23, 1977, and B were not instructed as to the location of the entry to the Clean Waste Process Room nor were they instructed to avoid In the adjacent, similar entry to the Sludge Tank Receiver Room.
addition, the entries to the two rooms were not marked in a manner v that would permit a distinction between them.
v The inspector noted that such instruction was necesse.ry to miniri;e
" exposure in view of the fact that the rooms, though similar in arrangement, had distinct differences in radiation levels (i.e.
Clean Waste process Room:
area and approximately 1 rem per hour at certain contact points.
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.( Sludge Tank Receiver Room:
15 rem per hour general area and ap-proximately 200 rem per hour at certain contact points).
Ln The inspector further observed that the Rad Waste Coordinator, in W
explaining the arrangement of the Clean Waste Process Room (See Paragraph 2), used a survey map entitled "Radwaste EL-l', Clean
- Waste Area" which depicts only the Clean Waste Process Room, neglect-Therefore, o ing entirely the adjacent Sludge Tank Receiver Room. Re
- the presence of the Sludge Tank Receiver The Room and its location Repairmen were not o relative to the Clean Waste Pro' cess Room.
informed of the radiation intensities within the Sludge Tank Re-ceiver Room.
The inspector identified this failure to instruct the Repairmen sufficiently to assure that-they entered the area where they w'ere assigned to work (an area which had been surveyed and for which an RWP had imposed appropriate protective measures) represented non-compliance with 10 CFR 19.12. (77-31-05)
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(. R1diolocical procedures d the During the course of this inspection, the insp
" Clean Wste Tank Room . . ."
pemitted by 'RWP 77-1204:
6.1-012. " Access to High Radiation Areas" 6.1-020, " Health Physics Guidelines" 6.1-022 " Radiation Work Permit" 6.1-110 " Health Physics Training Program"6.2-0 Except as noted below, the operation appeared to have been ducted in accordance with these procedures.
The inspector noted that Technical Specification i 6.11. " R Protection" states, " Procedures for personnel radiation pro Pert v shall be prepared consistent with the requirements of 10 CFR
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20, and shall be approved, maintained and adhered to for tions involving personnel radiation exposure".
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Procedure 6.1-012 " Access to High Radiation Areas" states following: d
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M-Section F.2- Areas greater than 1000 mre
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Section F.4 - Areas greater than 10,000 mrem per hour shal locked with an additional padlock.
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23, 1977, the Sludoe t
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The inspector determined that on November o
a ' Receiver Tank Room, an area which the ra locked in accordance with procedure 6.1-012.
ht The inspector noted that failure to educed.
follow had a padlock been used to secure the Sludge Tank Rece l the potential for overexposure would have been significant l The inspector identified this item as noncompliance wi't Specification 6.11. (77-31-03) d the inspector observed that the licensee ha On November 28, 1977, secured the Sludge Tank Receiver Room with a padlock procedure 6.1-012.
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5. Surveys During the course of this review, the inspector noted that after .
the 77-1204, overexposure event associated with the work permit 23,1977, at 1530, personnel entered the Clean 13B. On November Waste Process Room and completed the operation permitted by RWP 77-1204.
The inspector noted that the survey conducted at 1530 on November 23, 1977, in the Clean Waste Process Room, ind{cated loose surface contamination levels of 120,000 dpm per 100 cm ; and radiation levels as high as 1000 mrem per hour at contact with valve CV-13B.
- It was observed by the inspector such measurements were indicative
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of levels sufficient to create the potential for airborne radio-T activity, os The inspector noted that 10 CFR 20.103, " Exposure of individuals to
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concentrations of radioactive material in a restricted area",
requires, in part, that suitable measurements of concentrations of radioactive materials in air be used for detecting and evaluating ( airborne radioactivity in restricted areas.
Contrary to this requirement, the inspector determined that the to licensee did not perform any measurements to detect or evaluate N radioactive materials in the air of the Clean Waste Process Room o November 23, 1977 during the. period of time that personnel were
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working to repair CV-13B. '
O The inspector identified this item as noncompliance with 10 CFR O 20.103. (77-31-04) .
' -The inspector noted that the personnel involved in the operation were wearing respiratory protection equipment pursuant to 10 CFR i
20.103, and that air samples taken in the room subsequent to this finding indicated activity to be less than values listed in 10 CFR l 20, Appendix B. Table I, Column I.
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i 6. Exit Interview _
j The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on November 30, 1977. The inspector summarized the scope and findings of the in-with the exception of the spection as presented in this reportitem of noncompliance pertainin personnel in accordance with 10 C.FR 19.12, which was brought to l(
l the licensee's attention on January 14, 1978. .,l
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In a telephone conversation on December 5, 1977, NRC Region I
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management discussed the findings of this report with Boston
- Edison Company corporate management.
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Figure 1 RAD-WASTE FLOOR
ELEVATION - 1 U L.' 9
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T-307B
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C.U. SLUDGE RCVR TANKS ;
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SLUDGE TANK CD RW FILTER l
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RECEIVER .
SLURRY -
ROOM '
T TANK ,
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& M T- 316 y .=i
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ELEVATOR- STEP-OFF -
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CLEAN WASTE l I
ll PROCESS PUMPS C.U. SLUDGE -
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es RANSFER PUMPS _
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STAIR
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CLEAN WASTE
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RCVR TANK
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RA> WASTE PROCESS ROOM !
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CONTROL i ROOM !
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CV-13B
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Boston Edison Company .
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Enforcement llistory Relating to Radiation Protection .
5-12-76 to 11-30-77 Docket No. 50-293 Occurrences ~ldentified
. License No. DPR-35
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since May 9, 1976 Nonconfonnance Text and Licensee Response _
Documentation _ 1
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10 CFR 20.101(b)(1), " Exposure of individuals to radiation in IE:I Inspection No. A. restricted areas," requires you to limit, during any calendar A
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76-12 quarter the dose incurred by individuals in restricted areas to Letter dated 7/9/76 3 rem.
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Contrary to this requirement, an individual working in a re-
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stricted area was allowed to receive a whole body dose of
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3.127 rem during the second calendar quarter of 1976, as re-
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ported by your letter dated June 8,1976.
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This item of noncompliance is recurrent in that two employees were exposed ~ to 3.47 rem and 3.15 rem respectively duri ,
, July 2, 1975. 1 B.
20 CFR 20.203(b) and (c) " Caution signs, labels, signals and controls" requires that each radiation area and each high radiation area to be conspicuously posted as such.
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Contrary to this requirement, six radiation areas f5 in which a major portion of the body could receive a dose in excess j o
mrem in one hour and nine high radiation areas in which ma or portion of the body could receive a dose in excess of 100 mrem in one hour were not posted as such during May 21 to 26, 1976.
These were located in the Reactor Building, Radwa bine Building.
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Enforcement History 2 C. Technical Specification 6.138 requires that cac.. high radiation
' 1 area in which the intensity of radiation is greater than 1000 mrem /hr have locked doors to prevent unauthorized entry into such areas and the keys to be maintained under the administrative con-trol of the watch engineer on duty.
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l 1. Contrary to the above, on May 6,1976, the doors to the Rad- i waste Demineralizer Room and the A and B Radwaste Air Filter n Rooms were found closed but unlocked and unmanned. Results of the most recent surveys of radiation levels in these areas
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indicated levels in excess of 1000 mrem /hr.
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2. Contrary to the above, on May 22, 1976, the area under the reactor vessel was found unlocked and unmanned and the most recent surveys in this area indicated levels in excess of i ,
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1000 mrenVhr. .
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i * 3. Contrary to the above, on May 24, 1976, the personnel access
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door to the Drywell was found unlocked and unmanned from 11:50 (
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- a.m. to 12:30 p.m., and the most recent surveys within this
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area indicated levels in excess of 1000 mrem /hr. "
4. Contrary to the above, on May 25, 1976, the watch engineer on
' duty from 8:00 a.m. to 4:00 p.m. had no control over 8 keys
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reported lost prior to that date without assurance that none n are kept by unauthorized personnel.
5. Contrary to the above, on May 25, 1976, a contractor employee was found to have entered a high radiation area containing radioactive waste containers reading greater than 1000 mrem /hr.
The individual entered through a door which had been left un-
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locked and his entry was not authorized by an RWP.
This item of noncompliance is recurrent in that a similar item18, of 1975.
non- ,
compliance was cited in the Notice of Violations issued August
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Enforcement History i;
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D. Technical, Specification 6.11 requires that procedures be '.
prepared and adhered to for all operations involving per-sonnel radiation protection. Procedure RP 6.5.5 developed
, (RWP),
pursuant thereto requires that Radiation Work Pem.
be issued for all work involving radiation e n sures greater
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than 100 mrem per hour or airborne activity res f ring use of
. respiratory equipment or entry into an area of unknown condi- o
tion. The procedure requires the Health Physics representa-tive to perform radiological surveys as necessary and record n ('
l' the results on the IMP, and it requires that each member of a work party sign the permit before he enters the work area,
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! af ter complying with all instructions on the completed RWP.
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1. Contrary to the above, on May 24, 1976, a contractor em-
!, Pl oyee was allowed to enter the -13 ft level of the Rad-waste Building without signing RWP 768 and without com-
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plying with instructions on the RWP to wear a protective
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hood to tape the openings of his protective clothing.
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2. Contrary to the above, on May 21, 1976, no survey was made j "A"' Reactor Cleanup Pump Room for beta radiation in the i wherein three contractor's employees were allowed to work
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without eye and exposed skin protection until a 220 mrad /hr l level of beta activity was found on their protective i *
clothing. O.
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3. Contrary to the above, on May tank 21,1976, a contractor containing em-water having ployee was allowed to enter f a concentration of 3.1 X 10- uCf/mi without issuance of
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a RWP or performance of surveys necessary to evaluate the l radiation hazard in the tank, .
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! This item of noncompliance is recurrent in that an item of noncompliance relating to failure to follow procedures was cited in a Notice of .
! Violations issued August 18, 1975.
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Enforcement llistory
E. 10 CFR 19.12. " Instructions to workers," requires that all individuals working in a restricted area be instructed in pre-cautions or procedures to minimize exposure and that they be instructed to observe the appilcable proced: es of the
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Commission's regulations.
Contrary to this requirement on May 24, 1976, a worker ac-cumulated a 30 mrem dose as he sat waiting for 3' minutes in a n '.
radiation area. The worker stated that he was awu a of the radiation field but that he had remained in Als location be-
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cause he had been instructed to wait there rat.ier than at a
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- nearby location where the exposure rate was much lower.
Licensee Response The licensee accepted the five items of noncompliance and his'
Letter dated response was complete. ,
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7/23/76 and
- Revision No. 1 I
dated 8/9/76 * 1 IE:I knspection A. 10 CFR 20.201(b) requires each licensee to make or cause to be made surveys as may be necessary to comply with the regula-No. 76-27 Letter dated tions in 10 CFR 20.
11/10/76 Contrary to 10 CFR 20.201, an adequate air samplin9 pro-25, 1976, to 1. n'
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gram was not conducted I' rom June 1 to Augustassure the limits of 2 ducting decontamination operations under the76-1125, 76-1066, control of the following Radiation Work Permits; 76-1139, 76-1143, 76-1188, and 76-1190.
2. Contrary to 10 CFR 20.201, adequate air samples were not taken on September 22, 1976, to insure the limits of 20.
103 were not exceeded in the vicinity of workers on the
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reactor refueling floor during the decontamination of small tools and equipment. ,
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Enforcement History 5
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3. Contrary to 10 CFR 20.201 radiation surveys were not made .
on the roof of the turbine building to evaluate the radia-
tion hazard to personnel due to the presence of the radio-i active material in the turbine building.
]
B. Technical Specification 6.2.B.4 specifies an individual qualified
,
in radiation protection procedures shall be on site when fuel is in the reactor. '
j Contrary to Technical Specification 6.2.B.4 there wt . no individual l'
qualified in radiation protection procedures on site during the mid-night watch from September 19, 1976 to September 23, 1976.
- C. Technical Specification 6.11 specifies procedures for pct innel
.
radiation protection shall be prepared consistent with the require-ments of 10 CFR 20 and shall be approved, maintained, snd adhered
>
to for all operations involving personnel exposure.
-
1. Contrary to HP Procedure 6.2, Section 4, developed pursuant to
[ Technical Specification 6.11, written approval from the HP en- .
- gineer and an individual's supervisor was not obtained prior to
! exceeding 1300 mres/ week on four separate occasions during the
{
' period from March 1 to April 30, 1976.
i 2. Contrary to HP Procedure 6.5, Section 5.4.b radiological surveys m
i
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were not conducted in areas covered by weekly RWPs nor were radio-
.
Iogical conditions entered on the weekly RWPs during the period from January,1976 to September,1976.
l This item was recurrent in that a siellar item of noncompliance was found in May, 1976.
D.
10 CFR 20.102('c)(1) specifies the licensee to obtain reports of an individual's previously accumulated occupational dose when com-pleting an NRC-4 form prior to exceeding the exposure limits speci-fled in 10 CFR 20.101..
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Enforcement Hist ry ,
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Contrary to 10 CFR 20.102(c)(1) an individual was allowed to exceed the limits of 10 CFR 20.101 during the third Quarter ,
of 1976 without obtaining records of his previous occupa-
'
tional exposure.
The licensee accepted the four items of noncompliance and l.icensee Response his response was complete.
letter dated 12/6/76 2 A.
Technical Specification 6.13 requires that each High Radia-IE:I Inspection No. tion Area 'in which the intensity of radiation is greater 77-07 letter than 100 mrem /hr but less than 1000 mrem /hr be barricaded dated 5/24/77 and conspicuously posted as a High Radiation Area and en- m trance thereto be controlled by issuance of a Radiation Work Pemit and by any individual or group of individuals .
. : permitted to enter such areas be provided with a radiation
- , monitoring device which continuously indicates the radia-
'
- In addition, each High Radiation tion dose in the area.
Area in which the intensity of radiaticn is greater than 1000 mrem /hr be subject to the above reovisions and have locked doors to prevent unauthorized ..try into such areas and the keys be maintained under the administrative control of the Watch Engineer.on duty.
,
1. Contrary to the above, on March 31,19 7. the Fuel Pool Cooling and Heat Exchanger Room ?.3d radiation levels greater than 100 mrem /hr and entry into the area was
,
not controlled by a Radiation Work Pemit.
2. Contrary to the above, on March 31, 1977, the door i 7 to the Chemical Tank and Treated Water Tank Room was found closed but unlocked and uncontrolled.
i 31. 1977 Surveys performed within this area on March Indicated radiation levels in excess of 1000 mrem /hr.
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Enforcement Hist::ry .
3.
Contrary to the above, on April 1,1977, the door to the "A" Residual Heat Removal Valve Room and '
Steam Tunnel was found unlocked and uncontrolled.
Results of surveys performed within this area on
- March 31, 1977, indicated radiation levels in ex-
-
cess of 1000 mrem /hr. '
This duringitem is recurrent inspections, conducted ininthat itemsand July,1975, of May,1976.
this nature were found
<
The licensee accepted the item of noncompilance and his re-
,
Licensee Response _
'
letter dated sponse is complete. A
6/15/77 2 A.
10 CFR 20.101(a), " Exposure of individuals to radiation IE:I Inspection No. in restricted areas " requires that the whole body ex-77-21' posure of an individual in a restricted area be limited letter dated to one and one-quarter rems per calendar quarter, ex-Para-11/ 9/77 cept as provided in paragraph (b) of that section.
graph (b) allows a whole body exposure of 3 rems percalendar quart
, are met. One of these conditfor.s is that the indivi-dual's accumulated occupational dose to the whole body be determined on Form NRC-4, or on a clear and legible .
record containing all the infonnation reg. . red in that
'
form.
16.1977, an Contrary to this requirement, on September individual received 2.060 rem in the third qu. Nr.1977, c without having completed Form NRC-4 in at-ordance with '
the instructions contained on that form or 's otherwise described in 10 CFR 20.102. " Determination of accumu-lated exposure."
This item is recurrent in that a finding of a similar nature (Inspectionconducted was identified in Inspection 76-27.
September,1976)
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O. 00 956
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Enftrcement Hist:ry - .
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B. Technical Specification 6.11. "Ra'diatten Protecticn .
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!
Program," states, " Procedures for personnel radiation protection shall be prepared consistent with the re- .
,
quirements of 10 CFR Part 20 and shall be approved.
maintained and adhered to for all operations involving
' d personnel radiation exposure.
.
- Contrary to this requirement, the following radiation
- protection procedures were not adhered to on the fol-
-
,
lowing dates:
Dates on Which Procedure i Procedure Was Not Adhered To
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6.1-022, Rev. 0A, " Radiation Work August 31, and September 2,1977
-
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Permit" i
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6.1-023, Rev.1. " Extended Radiation August 9,10 and 11,1977 Work Permit Issuance and Use" 6.1-024, Rev. O, " Radiological August 31, 1977 Posting of Areas of the Station"
.
6.2-001, Rev.1 A, " PNP'S Radiation September 5, 1977 Exposure Control Program" t
6.4-067. Rev. O, " Operation of the August 10,11 and 12,1977
- Eberline Control Program"
.
6.7-104, Rev. O, " Respiratory August 10,11 and 12,1977
j .
Training" *
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This item is recurrent in that findings of a similar nature were
,
!
identified in Inspection Reports 77-09, 77-16, 76-27 and 76-12.
!
(Inspections conducted in May,1977; July,1977; .c.ntember,1976;
!
and May, 1976). ,
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C. 10 CFR 20.201(b), " Surveys", rcquir s that such tur- ,' ,,'
-
veys be conducted as may be necessary to comply with '
the regulations contained in each section of Part 20. *
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A " survey", as defined in Paragraph 20.101(a), means '
,
"an evaluation of the radiation hazards incident to , *
production, use, release, disposal, or presence of
'
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radioactive materials or other sources of radiation '
under a specific set of conditions. When appropri-ate, such evaluation includes a physical survey of the location of materials or concentrations of radio-
nettve materials present." -
i Contrary to this requirement, a survey to assure com-pliance with 10 CFR 20.101, " Exposure of individuals Ol to radiation in restricted areas", was not made rela-I - ' tive to personnel entries to the Chemical and Treated i
-
Water Tank and Pump Room under extended Radiation Work
.
Permit 77-1A in that dose rates present exceeded the l
.
measurement range of the instrument used. Entries !
,
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were made between July 4,1977 and August 10, 1977. l
!
This ites is recurrent in that a finding of a(Inspection similar
!
nature was identifled in Inspection 76-27. },
l conducted September,1976).
.
D. 10 CFR 20.103, " Exposure of individuals to concen-trations of radioactive materials in air in restricted
j areas." requires, in part that suitable measurements -
of concentrations of radioactive materials in air be !
used for detecting and evaluating airborne radioacti- ,I
!
i vity in restricted areas. * t.
Contrary to this requirement, on August 9,10 and 12, i l 1977, the method of sampling the air in the vicinity of the Waste Compactor was unsuitable in that the sam-
i
! pling arrangement did not provide for a repreuntative ,
'
l sample of air in the Waste Compactor operator's j
' breathing zone. i
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Enfcrcement Hist:ry ,
,. - .
Contrary to this requirement, on August 31. 1977. on the
-
Turbine Operating Floor, no air sampilng was performed .
,
during the decontamination effort on the Low-Pressure
.
Turbine blades even though loose surface activity as high '
as 160,000 dpm/100 cm2 was measured and the personnel involved were not wearing. respiratory protection.
This item is recurrent in that a findingInspection (of a similar nature was conducted identified in Inspection Report 76-27.
September.1976).
4 3 E. Technical Specification 6.13. "High Radiation Area." states. m,
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part. "In lieu of the ' control device' or ' alarm signal' ~
required by paragraph 20.203(c)(2) of 10 CFR 20, an ac-ceptable alternate to controlling access to a high radiation
.
,
area is as follows:
Each High Radiation Area in which the intensity of radia-tion is greater than 100 mrem /hr but less than 1000 mreWhr shall be barricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any indivi-dual or group of individuals permitted to enter such areas
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shall be provided with a radiation monitoring device which *
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continuously indicates the radiation dose in the area."
{ Contrary to this ' requirement, posting or barricading was not f provided at the following access points or areas in which the i intensity of radiation was greater than 100 mrem /hr but less than 1,000 mram/hr:
l Date Observed _ Condition Area
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August 9. 1977 Not Posted
' Control Panel for Waste Concentrator Cubicle '
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Nat Pasted; .
Turbine Building Equip-' August 15,1977 ,.' -
,g, Not Barricaded *
.
ment and Floor Drain .
l Sump Area * f August 9, 1977 , Not Posted; Top of Chemical Waste Not Barricaded
,
Filter Cubicle ,
- Not Barricaded Stairwell on the 51' August 9,1977 Elevation of the Reactor Building September 5,1977 Not Fuel Pool Cooling #and Posted Heat Exchanger Room l
This item is recurrent in that findings of this nature were identi-
.
fled in Inspection Reports 77-07 and 76-12. (Inspection conducted
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March-April,1977andMay,1976).
,
f 1 F. Technical Specification 6.11. " Radiation Protection Program,"
I states, " Procedures for personnel radiation protection shall be i
prepared consistent with the requirements of 10 CFR Part 20 and
! .
shall be approved, maintained and a'dhered to for all opera-
tions involving personnel radiation exposure."
l Contrary to this requirement, Procedure 6.1-020. " Health Physics Guidelines, Revision 1 " indicates that the requirements of 10 CFR 20.101 are " guidelines" and "are not absolute limits but '
' may be increased or decreased as determined by Health Physics Supervisory Personnel."
l 1
G. To:hnical Specification 6.8, " Procedures", states,19, part: ,
l 1. " Written procedures and administrative policies shall be i established, implemented and maintained that meet or ex-l ceed the requirements and recomendations of Sections 5.1 .
i and 5.3 of ANSI N18.7-1972 and Appendix 'A' of USNRC Regula-l '
tory Guide 1.33, except as provided in 6.8.B and 6.8.C below.
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. 12 Enforcement Histiry .
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- 2. Each procedure and administrative policy of'6.8A above.
',
and changes thereto, shall be reviewed by the Operations .
Review Committee (ORC) and approved by the Statica Mana- '
ger prior to implementation and periodically as set ,
forth in station procedures.
3. Temporary changes to procedures of 6.8A above may be made provided:
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a. The intent of the original procedure is not altered. ~
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b. The change is approved by two members of the plant O
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- management staff, at least one of whom holds a Senior Reactor Operator's license on the unit af-
' * fected.
c. The change is documented, reviewed subsequently by the .
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ORC, and approved by the Station Manager within 7 days of implementation."
Contrary to this requirement, on September 14, 1977, a change to procedure 6.1-022. Revision 0, " Radiation Work Pemit " was
, not reviewed and approved as required in that a Radiation Ex-l posure pemit program was being practiced in 11eu of some of '
,
the requirements of Section 3 and 6.f of that procedure without subjecting this change to the review by the ORC and obtaining approval of the Station Manager.
I 11 .
10 CFR 20.203(f)(1) and (2), " Caution signs, labels, signals and O-controls", requires that each container of Itcensed material bear a durable, clearly visible label showing the radiation caution
<
symbol, the words, " Caution - Radioactive Material", the identi- _
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fication of its radioactive content, and that the label provide sufficient infomation to pemit individuals handling or using
the container to take precautions to avoid or minimize exposure.
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Contrary to this requirement, on September 3,1977, a 6' x 6'
,
'
shipping cask, containing radioactive material and locate ,
contact radiation levels were as blah as 100 mres/hr, was no* .
labeled nor were the contents otherwise identified.
The licensee accepted items 8, C D
! -
Iicensee Response E, F, G, and H; thelicensee'sTheresponse licensee to item H was clarifie Letter dated 11/29/77 , documented in the Commission's reply letter. denied item A which wil spection.
O IE:1 Reply Letter dated 1/77 The.Comission documented information received per tel
. . would be re-reviewed during a subsequent inspection.
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Proposed Nonconfonnance Text
Current In- I. 10 CFR 20.101(a), " Exposure of individuals to radiation in r spection .
restricted area to one and one quarterParagraph rems per(b)calender allo,es a quarter Findings
,
except as provided by 10 CFR 20.101(b).
No. 77-31 whole body dose of three rems per calendar quarter provided certain
- specified conditions are met.
23, 1977, one individual Contrary to this requirement, on Novembei-
working in a restricted areas was reported to have received a whole
'
body dose of 3.561 iem during the fourth quarter of 1977.
l This item of noncompliance is recurrent in that an ite i
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II. 10 CFR 19.12. " Instructions to Workers" states', in art. " f
area shall be kept informed of the storage. tr. sfer. or use o '
radioactive materials or of radiation in such portions i of the i restricted area; shall be instructed in the health iprotect ls
" on -
problems associated with exposure to such radioactive mat 23, 1977, two individuals
,
Contrary to this requirement, on November h location k
f working in the restricted area were t similarnot instructed as to t eof t area) nor were they instructed to avoid the adjacen , Consequently, they entered entry to the Sludge Tank Receiver Room.These instructions were necessaryhad O the Sludge Tank Receiver Room.
to minletze exposure because, while the Clean Waste Process Room radiation levels of approximately .3 rem per hour (1 diation rem per hour
,
-
at certain contact points)(, the Sludge Tank Receiver Room had ra200 1 1evels of 15 rem per hour l This failure to properly instruct personnel contributed to the over-
'
exposure of an individual described in item I.
This item of noncompliance is recurrent in that an item of a sistlar nature was reported in an inspection conducted in May,1976. 4 ,
i III. Technical Specification 6.11. " Radiation Protection Program" states. .
" Procedures for personnel radiation protection shall be prepared i
l
.
consistent with the. requirements of 10 CFR Part 20 an Radiation Protection Procedure
-
personnel radiation exposure."
j 6.1012, " Access to High Radiation Areas." requiresh that 10 areas n'
! with radiation levels greater than 1 rem per hour, but less t an
! rem per hour, be locked as required by Technical SpecificationThe pro 6.13 "High Radiation Areas."
'
with radiation levels greater than 10 rem per hour be locked with an
.
additional padlock.
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Contrary to this requirement on November 23. '977, the Sludge were as much as 15 rem per hour, was not locked with a This failure to adhere to procedures contributed to the
'
padlock. overexposure of an individual described in item I.
,
This item of noncompliance is recurrent in that items of a si
.
.
1976; and August-Septem6er,1977. 3
!
IV.
10 CFR 20.103, " Exposure of individuals to concentrations of radio-active materials in air in restricted areas." requires in part th m
,
i air be used for detecting and evaluating airborne radioactivity in
'
restricted areas.
!.
Contrary to this requirement, on November 23, 1977, personnel p(er-
,
1 an l
fonned a valve removal operation in the Clean Waste Tank Room operation and area having contamination levels sufficient to create-l ments having been made' prior to or during the work, to detect a
'
evaluate airborne radioactivity.
,
This item is recurrent in that items of a similar nature were
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liRC CORRESPO!.*DINCE v n=i4As J. s a w oAN..re. DISTRIBUT10:1 m. . ,
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- SJL April 4,1978 ,
(r,,r M5thCA*NM NM A' /3 SLR /
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BECo. I.tr. f 78-58 y:ys / --
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Docket No. 50-29 3 DGS. / _ BICO RR d '
License No. DPR-35 sy && nm/,4;df p2
- ME --y Mr. Ernst Volgenau, Director a Office of Inspection and Enforcement U.S. Nuclear Regulatory Co ission Washington, D.C. 20555
Dear Sir:
This lett r is in asponse to your March 8,1978 letter, receivec by us on March 16, 1978, which refers to an doseincident of 3.56 of recs'exoosure at Boston of Edison an individualCompany's to a Pilgrim radiation Nuclear Power Station on Noverber 23, 1977.
Appendix A to your March 8,1978 letter identifies certain activities as apparent items Our of noncompliance response to the withof Notice NRC regulatory requirements.
Violation is submitted as Attachment A to this letter pursuant to of the terms of Practice", Part the2,Notice Title 10, and Code Section of Federal 2.201 of the NRC's " Rules Regulations.
'
As reouested in your letter, included in Attachment A are the
,
specific corrective actions either taken or planned for the '
. purpose of preventing future noncompliance. -
Appendix B to your March 8,1978 letter proposed to impose civil penalties in the cumulative amount of Sixteen Thousand Dollars ($16,000) for the apparent Our response itemsto ofthe non-com-Notice pliance identified in Appendix A.of Proposed Imposition of Civil Penalties Attachment B to this letter pursuant to the terms of the Notice and Section 2.205 of the NRC's " Rules of As Practice",
you will Part 2, Title 10,' Code of Federal Regulations.
note Boston Edison Company has elected not to contest the proposed civil penalty and thus our check in full payment is
! enclosed.
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-2- April 4, 1978 Mr. Ernst Volgenau
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> Your March 8,1978 letter also requested ' additional information concerning the techniques for determining radiation
.
Our response to this request is submitted as Attac !
this letter.
Appendix C to your March 8,1978 letter reviews the l enforcemenc history relating to radiation protection at Pilgrim Nuclear Power Station for the eighteen Although :ntenth period no speci- ;
between May of 1976 and November of 1977. i fic reply was requested to this Appendix, we have, in our r the ;
number of particular improvements We wishwhich l
to have past year and which are planned for the future. Edison assure you that the matters identified in your letter have executive attention at the highest levels full within Bost l
safety program at Pilgrim Nucle'r Power Station be in l '
cocpliance with all regulatory requirements so as lic. to ful y assure the health and safety of our workers and the pub We are confident that the actions described in Attachment A to this letter Weare willresponsive be pleased to the ccncerns to answer any
_.
C,-
raised in your letter.further questions you may have and to work with you that your concerns are met.
Very truly aprsj ,
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Enclosures: Response to Notice of Violation Attachment A: Response to Notice of Proposed Attachment B: Imposition of Civil Penalties Response to Question Regarding Attachment C: Radiation Dosimetry Technique BEco Check No. 590290 cc: Messrs. M. J. Fel h nn J. E. Howard
- G. C. Andognini D. G. Stoodley B. H. Grier, Director Region 1 ,
Boston Edison Company Reading Room
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(, , ATTACHMENT A Docket No. 50-293 License No. DPR-35
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- RESPONSE TO NOTICE OF VIOLATION Pursuant to 10 CFR 2.201 Boston Edison Company herewith
'
responds to the Notice of Violation dated March 8, 1978, received by Boston Edison Company on March 16, 1978, referencing the inspection conducted by representatives of the Region I (Philadel?hia) office on November 28-30, 1977. In the following paragraphs each identified ite.t of noncompliance will be set forth followed by Boston Edison Company's response there-to. Steps taken to preclude the recurrence ;f the identified ite=s and correctivg actions planned will *.e discussed together at the end of this response.
Ite I
- ^^ "10 CFR 20.101(a), ' Exposure of individuals to radiation in k.
s restricted areas,' limits the whole body dose to an individual in a restricted area to one and one quarter rems per calendar quarter except as provided by 10 CFR 20.101(b). Paragraph (b)
allows a whole body dose of three rems per calendar quarter pro-o vided certain specified conditions are met.
'
2 Contrary to this requirement, on November 23, 1977, one individual working in a restricted area received a whole body dose of 3.56 rems during the fourth quarter of 1977, which exceeded the applicable limit of 3 rens."
Response As was reported in Licensee Event Report 77-039/13C-0, one individual, a contractor repairman, did receive a whole body dose of 3.56 rems during the fourth quarter of 1977 and thus exceeded the 3 rem limit set forth in 10 CFR 20.101(b). The reason for this' occurrence was the individual's mistaken entry into the wrong room in the course of a repair assignment. The individual and a co-worker were assigned to repair a valve in the Clean Waste Tank Room (general area dose rates of 300 mrem /hr),
.
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(, ' Attachment A -
Page 2 1 however they instead entered the nearby Sludge Tank Rooz*/ f (general area dose rates of 30 rem /hr). The reason for this i
l mistaken entry was an apparent miscommunication between the vorkers, their supervisor and station personnel. l
.
A Radiation Work Permit (RWP) was issued for the mainte-nance work which included a cap of the area the men were to enter. Directions to the Clean Waste Tank Room, a description of the room and the location of the damaged valve were discussed with the individuals prior to commencement of the work assign-ment. Despite these instructions the two individuals mistakenly entered the Sludge Transfer Pump Room, the door to which is immediately adjacent to the door to the Clean Waste Tank Room, using the key given them for entry into the assigned area and then gained access to the Sludge Tank Room by cir amventing a second locked door. The workers realized their error when the appearance of the room they entered (Sludga Tank Roc.j did not agree with the description of the Clean Wu te Tank .;oom and they were unable to locate the valve they were to repair.
Upon exiting the room the workers' pocket dosimeters were read by the Health Physics technician and discovered to be off-scale whereupon the workers were instructed to cease working and
{:.- inmediately report to the Health, Physics Office.
Item II
"10 CFR 19.12, ' Instructions,to. workers' states, in part,
' All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted aren; shall be instructed in the health pro-tection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure. . .'
- / It should be noted that the diagram of the area in which this incident occurred, which is marked as Fipe 1 accompanying Inspection Report No. 50-293/77-31, erroneously refers to a
'
" Sludge Tank Receiver Room" (also referred to in the Inspection Report as " Sludge Receiver Tank Room"). This room is correctly identified on the station's mechanical equipment layout drawings as the Sludge Transfer Pump. Room (or the ' Clean Up Sludge Transfer Pump" Room").
The Sludge Tank Room (or the " Clean Up Sludge Tank Room ) is' the adjoining room identified on Figure 1 as containing the Sludge Receiver Tanks. It should be noted, and emphasized, that the Sludge Transfer Pump Room had general area dose rates .
(.. ' of less than 10 rem /hr on November 23, 1977-although the Sludge
- Tank Room had general area dose rates in excess of 10 rem /hr.
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. Attachment A ,
' Page 3 e 23, 1977, two contrac-
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Contrary to the above, on NovemberRad Waste floor, a restricted area, tor e,mployees working on the were not properly instructed to minimize their exposure in that '
instructions wereTank not Receiver sufficientRoom to preclude which isinadvertent entry a high radiation
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i into the.SludgeThis failure to properly instruct personnel contributed crea.
to the overexposure of an individual des,cribed in Item I."
Response i
This item appears to be based entirely upon the fact that two workers inadvertently entered the wrong room rather than upon any substantive deficiency identified in Boston Ed given to the two individuals.
It should be noted that:
(1) Both individuals had completed Boston Edi* n Company's General Employee Training (GET) course which includes the basic precautions and procedural limits which are applicable to activities conducted in radiation areas. Also, both workers had (_ previously been employed at Pilgrim Station.
(2) In accordance with Procedure 6.1-022, a Radiation (RWP) was issued for the valve repair Work Permit job. Included in the RWP was information such as the the radiation room, thedose rates at.
protective various clothing andlocations respirator within
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requirgments,
as well as a survey map of the work area. /
In addition, verbal instructions for the specific (3) . task were given to the workers only a short distance from the entrance to the Clean Waste Tank Room.
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50-293/77-31 associated with this incident,1/ nspection Report No. indicated that failure to inform the workers of othe sources of radiation in the vicinity of the Clean Waste Tank Room did not comply with the requirements of 10 CFR 19.12, Boston E
" Instruction to Workers". l the specific purpose of an RWP isThe to cause identify of this the particul l for that area may be given to the workers. l incident was that the workers inadvertently entered an areaShould each (' other than where the work was to be performed.
worker be instructed in avoiding all radiation areas within the plant, including those outside of their assiped work location, l
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it would undoubtedly confuse rather than enlighten workers.
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5ttachment A Page 4
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These instructions included directions into the Clean Waste Tank Room, a description of the clean waste tanks and the location of the valve.
(4) Although the workers thereafter entered the wrong room, the instructions given them were neverthe-
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less sufficient to enable them to realize that they were in the wrong room causing them to promptly exit and thereby limiting the severity of the. inci-dent.
Based upon our review of the instructions given the two repairmen and the circumstances of how they gained access to was met. Nevertheless, to the extent that there was a mis-communication between the workers, their supervisor and sta-tion personnel, as noted in response to Item I, which contri-buted to the occurrence of this incident, corrective actions are included in the discussion at the end of this attachment.
Item III
" Technical Specification 6.11, ' Radiation Protection Pro-
' Procedures for personnel radiation protection gra=' states,shall be prepared consistent with the recuirements of 10 CFR (- Part 20 and shall be approved, maintaine6 and adhered to for all operations involving personnel radiation exposure.'
Radiation Protection Procedure 6.1-012,' Access to High Radiation Areas', requires that areas with radiation levels greater than 1 rem per hour, but less than 10 rems per hour, be locked as required by Technical Specification 6.13, 'High Radiation Areas.' The procedure also requires that areas with radiation levels greater than 10 rems per hour be locked with an additional padlock.
Contrary to this requirement on in an area November 23, 1977, which general the radiation Sludge Tank: Receiver Room, levels were as much as 15 rems per hour, was not locked with an additional padlock. The failure to adhere to procedures contributed to the overexposure of an individual described in Item I."
Response .,
Although' literally there was not an additional ' padlock' l on the door into the Sludge Tank Room there were in fact two separate locks, actuated by two separate keys serving to pre-vent entry into the Sludge Tank Room. As noted previously
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the area with a radiation level in excess of 10 rems per hour
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was.the Sludge Tank Room, not the Sludge Transfer Pum Room in the Inspection Report and the Notice of Violation.
Although the use of a door lock rather than a padlock may have constituted a technical violation of the procedure, Boston Edison Co=pany denies that there was a violation of the intent was to provide of Radiation two separate Protection locks requiring Proc'edure two separate 6.1-012 keys which in order to enter an area with radiation levels in excess of 10 rems per hour.
Procedure 6.1-012 controls access to radiation areas byThe en the use of a key system.
whole body radiation levels in excess of 1 rem / hour Certainare station locked and can be opened with a Radiation ("R")' key.
personnel such as Health Physics technicians Access and maintenance to High-High-,j supervisors are issued master "R" keys.
radiation areas is controlled by a second lock (Procedure 6.1-012, states an " additional padlock"), which requires a The
"special" key which is maintained by the Watch Engineer. in order to enter a High-High radiation area.
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At the time of the incident on November 23,1977, two locked doors protected the entranceinofFigure the Sludge 1 to Tank the Inspec- Room.
"A" The first door tion Report) into(identified the room (Sludge as Transfer Pump Room) just outside the Sludge Tank Room required an "K" key to open it
"C" in Figure 1 to the while the second door (identified as Inspection Report) into the High-High radiation area Thus of thethe Sludge Tank Room recuired the second "special" key.even though the second l intent of the procedure was met, was an integral part of the second door rather than an addi-tional padlock.
"R" key The two repairmen had been supplied This keywith an permit would -
by the Health Physics technician.
entrance into "B" the Clean in Figure 1 to Waste TankReport)
the Inspection Roomand (through the also the Sludge Transfer Pump Room but would not allow access through the second door into the High-High radiation area of
- /"High-High" radiation areas are those with whole
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body radiation levels in excess of 10 rems /hr.
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Attachient A '
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the Sludge Tank Room. When the repairmen mistook the second door (i.e. , to the Sludge Tank Room)' for the door into the Clean Waste Tank Room, they attempted to open it utilizing the "R" key. This attempt was unsuccessful. It was at this point that the workers circumvented the lock on the second door by reaching around the barrier and thus entered the Sludge Tank Room. This act was deliberate and not an acciden-
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tal case of swandering into an unbarricaded area.
All barrierd.to High and High-High radiation areas were immediately surveyed and if necessary, modified to prevent such a recurrence.
Full compliance to the procedure includ-ing placement of padlocks where appropriate has been achieved.
Item IV !
"10 CFR 20.103, ' Exposure of individuals to concentra-i tions of radioactive materials in air in restricted areas,'
requires in part that suitable measurements of concentrations of radioactive materials in air be used for detecting andTech-evaluating airborne radioactivity in restricted areas.
nical Specification 6.11, ' Radiation Protection Program,'
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consistent with the requirements of 10 CFR Part 20. Procedure :
No.' 6'.1-022 requires that certain radiological surveys be per-formed as a minimum, including the collection and evaluation of representative air samples from work areas and also requires that survey results be entered on the Radiation Ebrk Permit
(RWP).
Further, Procedure No. 6.1-020 requires that continuous particulate and iodine air samples be taken in cacupied areas containing smearable contamination greater than 100,000 dpm
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' Contrary to the above, on November 23, 1977, while
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personnel performed a valve removal operation in the Clean Waste' Tank Room (an operation and area having smearabge con-
camination levels greater thanT100,000 dpm per 100 cm ) the
required air concentration measurements were not performed
prior to or during the work, to detect and evaluate airborne i radioactivity."
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Response w Boston Edison Company acknowledges thap the air concen-i tration measurements in the Clean Waste Tank Room were not performed prior to the maintenance that was accomplished on .
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{' Page 7 Contributing to this failure were the following circum-
stances.
Prior to scheduling the valve repair work, a Health Physics technician was asked to survey the valve Subsequent to this in order survey, to determine the contact dose rate. !
it was determined to establish an RWP for the required mainte-nance. 'The results of the original survey were utilized in the preparation of the RWP rather than requiring new surveysin a Physics technicians. The individuals establishing the RWP were aware of the type of work and time (approximately fif teen minutes) necessary to perform this task as well as being know-ledgeable in the levels of airberne contamination in comparable areas of the plant and apparently failed to perform the regt. ired air sample.*/ As noted in the Inspection Report (and required on the RWP) the individuals performing the repair Air samples were taken wearing respiratory protection equipment.
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in the room subsequent to the repair indicated activities to be less than values listed in 10 CFR Part 20.
Corrective Actions
Boston Edison Company shares the Co= mission's concern Over the past year a l 7' with the occurrence of this incident.
conscientious effort has been underway to improve the Radiation l L. Protection Program at Pilgrim Nuclear Power Station. This Major improve-
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effort will, of course, continue in the future.
ments that- have been made in the Radiation Protectior. Program during the past year are as follows:
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(1) The Station Chemical Control and Radiation Protection Technicians have been reorganized and now conduct only chemical and radiation protection functions. Previous to this reorganization they also conducted radwaste operation functions.
-(2) Two Health Physics Engineers were hired prior to July of 1977 to improve the first line supervision i
- / The highest air sample ever recorded at the station, f under more severe conditions
' 23, than 1977,those experienced had never exceeded in the Radwaste area on November level would not present any difficulty
! 50 mpc/ hrs and even that for a repair of this short duration utilizing respiratory (, equipment. d
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Attachment A Page 8
{, One
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of the Radiation Protection Technicians.
of the engineers has a degree in Radiological Health and approximately 4-1/2 years of Nealth Physics experience. The second Health Physics Engineer has 3-1/2 years of College credit plus 3 years of Boiling Water Reactor Health Physics work.
(3) Three additional Radiation Protection Technicians were hired, each having at least 8_ years of Radiation protection experience.
(4) A formal Radiation Protection Technician qualifi-cation program has been is lemented and 11 of the
tionStation Checical Technicians have Control and Radiation now completed Protec-the qualifica-
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tion program.
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(5) A one month training course for 7 of the Station Chemical Control and Radiation Protection Techni-cians was conducted during April of 1977. This improved the working knowledge of the technicians
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(~. (6) The position of Senior Health Physics Engineer has been established at the stationThis to supervise the Radiation Protection program. position has not been filled to date because of the lack of an acceptable candidate.
(7) .has Additional portable radiation detection equipment been purchased to raise the inventory of equipment to more acceptable levels and replace older equipment with more efficient equipment.
(8) Station operating procedures relative to the Radiation Protection program have been completely rewritten, reorganized and implemented. An ongoing policy of continual upgrade of all Volume 6 procedures
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will continue as the Radiation Protection program is upgraded and new equipment purchased.
(9) New laboratory instruments for the Radiation Pro-tection program have been purchased to improve the detection of radioactive material and to evaluate
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personnel internal exposure more effectively by utilizing an onsite whole body counter.
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-(10) A Respiratory Protection program has been imple-
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mented which meets with new regulatory require-ments of 10 CFR 20.103.
(11) -Ine Radiation Protection program records system has been improved by hiring two records clerks to maintain the records. Pyocedures have also been established in Volume 6 of the station operating procedures to , define the control and handling of the records.
(12) A Corporate Radiation Protection staff has been hired consisting of one Senior Radiation Protection Engineer and one Radiation Engineer.
Their function has been to assist the station Radiation Protection staff in implementing the improvements in the Radiation Protection program at the station.
In response to the particular items identified in the Notice of Violation Boston Edison Company has taken, or proposes y
to take the following actions:
[~ (1) In order to prevent the recurrence of exposure incidents and to improve the control of workers in all radiation areas, Boston Edison has initiated a complete and thorough review of all areas requir-ing barricades. The necessity for barricades, the quality of existing barricades and the locking mechanisms on barricades will be investigated in .
detail. This action is deemed responsive to Items 1 and 3 in the Notice of Violation. The estimated completion date is April 15, 1978.
(2). In order to prevent the recurrence of exposure incidents and improve the control of workers in high radiation areas several integrating digital readout dosimeters with audio signals have been-ordered. Upon delivery an evaluation program will be conducted by station personnel to deter-mine the desirability of utilizing these instru-ments as a standard procedure when entering high radiation areas. Ihis. action is deemed responsive to Items 1 and 2 in the Notice of Violation.
The estimated delivery date of these instruments i is May 31, 1978.
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(3) Permanent signs of significant size and distin-guishing color will be installed at the entrance to High and High-High radiation areas. Information centained on these signs will specify the major components contained within the enclosed area. In
- addition, barrier postings will be standardized in a new sign design that will contain four packets.
The packets will contain a recent survey map, the protective clothing required for the area, the specific room postings and the general entry Radiation Work Permit. This action is deemed responsive to Items 1, 2, 3 and 4 in the Notice of Violation. These signs are presently on order with an estimated installation date of May 15, 1978.
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(4) All survey maps will be reviewed to be certain thej indicate all gates and major components with-i.. the various working areas. This action is deemed responsive to Items 1 and 2 in the Notice of Violation. Ihe estimated completion date is
- May 15, 1978.
-(- (5) All Station Chemical Control and Radiation Protec-tion Technicians will'be scheduled for training sessions to better familiarize themselves with the location of various major components and equipment throughout the station. The eight-hour documented training session is designed to achieve a more .
complete working understanding of station layout among all the technicians. This action is deemed responsive to Items 1 and 2 in the Notice of Violation. The training is estimated to be com-pleted by April 30, 1978. Ejg
.(6) In order to improve communications between the Health Physics staff and workers, Procedure 6.1-022 has been revised to require the Health Physics
- technician issuing the RWP to conduct a briefing for all workers utilizing the RWP. The briefing will encompass a description of the survey conditions and.will be documented by sign-offs from both the technician and the worker. This action is deemed responsive to Items 1 and 2 in the Notice of Violations. This action has been completed.
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(7)
In order to assure that all required surveys are accomplished the RUP index sheet has been revised
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requested it contains check-off In blocks addition, for a allThis inde prior to the issuance of the RWP.
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survey documentation sheet has now been implemented
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which includes the surveys requested ofAdditional the techni- ;
cian, by the Health Physics Engineer.
information concerning the area in which the survey .
was conductedThese will also improvements be included whichon have thealready documen-tation sheet.
been implemented will help to prevent recurrenceof t in Item 4 in the Notice of Violation.
We believe th - the foregoing actions are_ responsive for to the Co==ission's req _est for Boston Edison Company's plans i-control of activities in high radiation areas working in those areas. We are confi- and improved commun -
cation among f-dividualdent that these actions demonstrate d theBoston Edison C tinuing co==itment to radiation safety for its workers an
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ATTACHMENT B \
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Docket No. 50-293 License No. DPR-35 RESPONSE TO NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Pursuant to 10 CFR 2.205, Boston Edison Company herewith remits the sum of $16,000 in full payment of the Notice of Proposed Imposition of Civil Penalties dated March 8, 1978, recei' d by Boston Edison Company on March 16, 1978.
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1-ATTACHMENT C
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' Docket No. 50-293
' License No. DPR-35 RESPONSE TO QUESTION REGARDING RADIATION DOSIMETRY TECHNIQUE The March 8, 1978 letter of Mr. Ernst Volgenau requested additional information concerning the techniques for deter-mining radiation doses received by employees at Pilgrim I.
The letter referred specifically to the determination of dose of an individual who was reported tr have received 2.91 rems.
Inspection Report No. 50-293/77-33 mailed to Boston Edison Company with a lette- dated Ma eh 14, 1978 presents the TLD results for this individual (Repairman A) as follows:
Card Type Chip 1 Chip 2
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G-7 3.156 rem 2. 910 rem Repairman A g
(~ NG-67 3.181 rem 3.029 rem 4 As noted by the inspector the procedure applicable to the vendor-supplied TLD system in use at Pilgrim I provides that the whole body dose to be assigned.to an individual is taken from the value exhibited by Card G-7, Chip 2. The more techni-
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g cal basis as to why Card G-7, Chip 2 is used to determine the C3 reported whole body exposure from penetrating radiation follows.
The equipment used to make dosimetry measurements was The dosimetry manufactured by the Harshaw Chemical Company.
device utilized was a standard Harshaw Twobadge typesconsisting of of chips, having four lithium fluoride (LiF) chips.
different sensitivities to neutron radiation, are used. The badge contains two holders,identifiedG-7 and NG-67, as G-7, each of which Chip 1, is has two LiF chips. One chip situated behind a 7 mg/cm 2 filter and is used only to furnish data for determining exposure to the skin of the whole body.
identified as G-7, Chip 2, is situated between A second two chipI filters and is used to determine the whole 222 mg/cm i
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The two NG-67 Chips body exposure from penetrating radiagion. filter and are used to are each situated behind a 476 mg/cm detect neutron radiation.
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Page 2, 10 CFR 20.401(a) requires that individual personnel exposure records be maintained on an NRC Form 5 or the
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equivalent. The directions for completing an NRC Form 5 i require that exposure to skin of the whole body be reported ,
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as the amount of radiation measured after being filtered by a 7 mg/cm2 or less filter. The only LiF chip that will pro-vide this data from the standard Harshaw badge is G-7, Chip 1.
Exposure to whole body penetrating exposure is to be reported as that which is measured after being filtered by a 300 mg/cm2 or less filter. The LiF chip that will provide this data from the Harshaw badge is G-7, Chip 2.
The two NG-67 Chips may be used to make estinates of the whole body penetrating radiation, if neutron radiation is not present. They are not used for determining compliance First, the with.10 CFR 20.101(a) and (b) for two reasons.
quantity of filtration in holder NG-67 Second, exceeds oni: one sidethe of guidelines the chips described on NRC Form 5.
in holder NG-67, the front side, is protected 'ay a filter.
Thus body scattered radiation is not eliminated by a backside filter, as is the case with G-7, Chip 2.
( We trust that this explanation adequately sets forth the technical basis for concluding.that the whole body radiation dose received by the second individual was 2.910 rems as deter-mined in accordance with all regulatory requirements.
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UNITED STATES gy }
g . NUCLEAR REGULATORY COMMISSloN
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/ g .(; !gj WASHINGTON, D. C. 20555 V. H. K. J)iL
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MAY 22 e7a ggg gg
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Q, l Boston Edison Company M/C Nuclear
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Docket No. 50-293 g
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ATTN: Mr. Thomas J. Galligan, Jr.
President CF-800 Boylston Street /
m Boston, Massachusetts 02199
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co Gentlemen: - .
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This refers to your letter F April 4,1978, in response to our letter dated March 8, 1978. p
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Thank you for infe ing us of .ne corrective and preventive actions documented in your letter. These actions will be examined during a subsequent inspection of your licensed program.
-: ) We acknowledge receipt of your check (No. 590290) for Sixteen Thousand (W Dollars ($16,000) remitted in full payment of the Notice of Proposed Imposition of Civil Penalties dated March 8,1978.
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We have also reviewed your submittal regarding the exposure to the other o individual (Repairman A), and conclude that the value exhibited by Card G7, Chip 2 represents the best estimate of this individual's exposure.
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'ERCCoRRESPoNDENCk
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) DISTRIBUTION Ernst Volgenhb
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Director MJF A
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831
Office of Inspection g 7 and Enforcement su V - ~
was /
J. McGuire, Pilgrim Station DGS / B C RR d Manager BY MM Der
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A. Z. Roisman, Natural Resourses Defense Council g .g
. RECEIVED -g6
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MAY 23B78 Nudear Operations .
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