IR 05000445/1992056

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/92-56 & 50-446/92-56

ML20128D751
Person / Time
Site:	Comanche Peak
Issue date:	02/03/1993
From:	Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9302100218
Download: ML20128D751 (5)

Text

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• (jouevg$*,, NUCLEAR REGULATORY COMMISSION

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FEB - 31993 Docket Nos. 50-445 50-446 License No. NPF-87 Construction Permit No. CPPR-127-TU Electric ATTN: W. J. Cahill, Jr., Group Vi',e President huclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 SUBJECT: NRC INSPECTION REPORT 50-445/92-56 50-446/92-56 Thank you for your letter of January 18, 1993, in response to our letter and Notice of Violation dated December 18, 1992. We have reviewed your reply-and find it responsive to the concerns raised in our Notice of Violatio We c

i will review the implementation of your corrective actions during _a future inspection to determine that full- compliance has been achieved and will be maintained, f

Sincerely,

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. L. J.//CA11an, Director Divi /ionofRadiation. Safety and Safeguards

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I ATTN: Roger D. Walker, Manager of Regulatory Affairs for Nuclear l Engineering Organization Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201

Juanita Ellis i President - CASE  !

1426 South Polk Street i Dallas, Texas 75224 l

GDS Associates, In Suite 720 1850 Parkway Place Marietta, Georgia 30067-8237 TV Electric Bethesda Licensing 3 Metro Center Suite 610 i Bethesda, Maryland 20814 Jorden, Schulte, and Burchette ATTN: William A. Burchette Es Counsel for Tex-La Electric Cooperative of Texas 1025 Thomas Jefferson St., Washington, D.C. 20007 Newman & Holtzinger, ATTN: Jack R. Newman, Es L. Street, Suite 1000 Washington, D.C. 20036 Texas Department of Licensing & Regulation

.i ATTN: G. R. Bynog, Program Manager /

Chief Inspector Boiler Division P.O. Box 12157, Capitol Station Austin, Texas 78711 Honorable Dale McPherson County Judge P.O. Box 851 Glen Rose, Texas 76043 i

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i Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756

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bec distrib. by RIV w/ copy of letter dated January 18, 1993:

J. L. Milhoan B. Murray, DRSS/FIPS L. T. Ricketson, FIPS DRP Section Chief, DRP/B Project Engineer, DRP/B '

Section Chief, DRP/TSS DRS Comanche Peak, Resident inspector (2)

MIS System DRSS/FIPS Fiie RIV File LisaShea,RM/Alf,(MSMNBB4503)

T. Bergman, NRR Project Manager (MS 13 HIS)

B.Holian,NRRProjectManager(MS13HIS)

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8 bec distrib. by RIV w/ copy of letter dated January 18, 1993:

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Section Chief, DRP/B Project Engineer DRP/B

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._SP J January 18. 1993 William J. Cahill. J a,,,, vu a r,,,,a,o V. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) - UNIT 1 DOCKET NO. 50-445-NRC INSPECTION REPORT NOS. 50-445/92-56; 50-446/92-56

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RESPONSE TO NOTICE OF VIOLATION Gentlemen:

TU Electric has reviewed the NRC's letter dated December 18, 1992, concerning the inspection conducted by the NRC. staff during the period November 9 through November 13, 1992. This inspection covered activities-authorized by NRC Operating License NPF-87 and Construction Permit CPPR-127. Attached to the December 18, 1992, letter was a Notice of Violation (NOV).

TV Electric hereby responds to the Notice of Violation (445/9256-01)'in the attachment to this letter.

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Sincerely,

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William J.-Cahill, J .)

By: ~

M Roger'f). . Wa lker Manager of._ Regulatory-

Affairs for NEO CLW/grp l Attachment

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c- Mr. J. L. Milhoan, Region IV

. Resident inspectors, CPSES (2)

Mr. T. A. Bergman, NRR

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- 400 N. Olive Street LB, B1 : Dalles Texas 75201

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Attacnment to TXX-93013 Page 1 of 4 NOTICE OF VIOLATION (445/9256-01)

10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulationsinthispartand(2)arereasonableunderthecircumstancesto evaluate the extent of radiation hazards that.may be presen Contrary to the above, on November 7, 1992, workers performing in service inspection preparation work in the Unit 1 reactor containment building removed insulation from piping and'used a wirebrush to remove corrosion from a valve without first having the radiation hazards associated with this work-evaluated through_the analysis of contamination $Urvey Thisisa-SeveritylevelIVviolation-(SupplementIV).

Bf2 0NSE-TO NOTICE OF VIOLATION (445/9256-01)

TV Electric accepts the violation and the requested information follows:

1, Reason for Violation The contractor radiation workers entered the Unit 1 containment building to locate specific valves and re -ve insulation from the valves in-preparation for inservice inspet an activitie The valves were known to be located inside loop room #1 somewhere between the 808' and 841'

elevations. The workers, assisted'by drawings and accompanied b Radiation Protection technician, entered the_ loop room area from the 841' elevatio Prior to locating the valves, the_ Radiation Protection technician decided to leave the area (continous RP coverage was not required). Subsequently, the sequence of events described below led to the failure to take:the required surveys:

(1) Prior to leaving the contractor workers 1the Radiation Protection technician provided instructions to one of the workers.regarding necessary' actions once they found the valve work area, (2) The Radiation: Protection technician stated that the Lead Radiation Protection technician would be updated concerning the work status. The Radiation Protection-technician then left the contractor: workers, updated the lead Radiation' Protection technician and exited Unit 1 containment.-

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! Attachment to TXX-93013 j Page 2 of 4 i

) (3) The contractor workers subsequently moved from the 832' ,

i elevation to the 808' elevation inside the loop room #1

. looking for the valves. The valves were located on the 808' elevation; however, Radiation Protection

{ technicians on the 808' and 832' elevtions were unaware j of the workers presence on the 808' elevation.

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(4) A turnover between Fadiation Protection technicians at .

( .the 808' elevation was conducted.: No status of the [

j work activities of the. subject contractor-personnel was

, discussed as their presence on the containment elevition 808' was unknown, i (5) The contractor workers believed they had been given t -- permission from Radiation Protection to remove a piece of

-insulation without Radiation Protection being present to perform surveys.

f b (6) . Radiation Protection _ technicians assumed that work

} activities were being covered by Radiation Protection

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personnel located on each respective containment building elevation as the work activities progresse i These assumptions proved to be unfounded.

(7) A Radiation Protection technician who found the j contractor' workers while they_were removing insulation j

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-at the loop room #1 work area (808' elbvation) assumed'

-that previous Radiation Protection coverage-had been .

i provided and that appropriate surveys had been obtained-l since the work was already in progres .

t i These are the related events which resulted in the failure to obtain radiological surveys prior to the removal of the-insulation and subsequent contamination ~of the contractor worker '

!. Corrective Action Taken and Results Achieved l

! - In response, TU Electric-took the followingLinitia11 corrective actions:

(1) Upon egress and alarming Personnel Contamination l Monitors at the Unit 11 Containment; Access Control

Point, the contractor workers were immediately taken_to-station decontamination facilities and-decontamination

[ efforts were initiated. Following decontamination. _

whole-booy counting was performed toLassessl individual

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' intakes; Results indicated'that intakes were less than

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12 MPC-hours and no regulatory limits were exceeded.-

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Attachment to TXX-93013 Page 3 of 4 (2) A central Radiation Protection control point was designated inside the Unit 1 containment building to better coordinate job coverage assignments. This eliminated the need to shuffle workers from one Radiation Protection control point to another when radiation workers had to change elevations during work activitie Responsibilities of Radiation Protection personnel working at the central control point were -

established to ensure that coordination activities between Radiation Protection and contractor personnel were handled effectivel (3) Instructions were re-emphasized to Radiation Protection personnel regarding the policy for taking contamination samples prior to initiation of work activitie (4) Similiar work activities were temporarily suspended until initial investigation could be completed. An Operation Notification and Evaluation (ONE) Form was itsued and investigations were conducted and documented in accordance with station procedure (5) Based upon the initial investigations, a specialized training course was developed and presented to over 200 contractor radiation workers to address identified radiological work practice weaknesses. Work activities were allowed to recume after this training program was complete . Corrective Steos That Will be Taken to Avoid Further Violations The major contributors to this event were associated with coordination of work activities from Radiation Protection control points established during outages and the fact that advanced radiation worker training was not provided to certain contractor personnel. To address these items the following corrective actions will also be taken:

(1) A detailed review of_ selected contractor training records for outige IRF02 will be performed. The intent of this review is to dettrmine if there is wide spread use of site specific training to the extent that outage workers may have not had an opportunity to atteno a full length RWT course over a two or three year perio This reviaw may involve a verification of the actual training classes attended by an individual over the last two or three years and verificat1cr, of course content from other utilities where the training was receive .

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Attacnment to TXX-93013 Page 4 of 4 (2) Radiation Protection and the Nuclear Training Department will formalize a practical radiation worker training course to targeted outage personnel. The material for this course exists in several radiation worker training modules provided to permanent CPSES employee The required subject matter will be included in this class and will be made available for future us (3) Radiation Protection and the Nuclear Training Department will develop a process whereby a review of contractor personnel resumes are performed and compared to the actual work anticipated to be performed by the employee during the outage. If_ extensive work will be done in radiological areas the employee may be required to attend the practical training session noted above or RWT. This training may be required even when an individual has a current training date specified on INDEX or other source (4) A lessons learned training seminar will be developed and presented by Radiation Protectica to selected permanent TU employees prior to the next scheduled outage. The purpose of this seminar will be to review lessons learned from previous outages pertaining to radiological work practices. Emphasis will be placed on reviewing examples of poor radiological work practices encountered at Comanche Pea (5) A designated containment control point will be identified as the lead control point for purposes of assigning Radiation Protection job coverage responsibilities to support outage activities, in addition, Radiation Protection will evaluate the present configuration of control points at cther plant locations, including the containment access control point (i.e., the Unit 1 access control office), to ensure efficient and effective use of these facilities. The evaluation will consider potential consolidation of these facilities.to streamline communication chain (6) The responsibilities of the various Radiation Protection control points established during outage neriods will be included in the contractor indoctrination training program for Radiation Protection technicians. This training will include aspects of Radiation Protection job assignments and importance of ensuring prope communication'between Radiation Protection control point . Date When Full Comoliance will be Achieved Full compliance has been achieve Development and issuance of the various training programs disecaed under Section 3 will be completed by April 15, 1993.

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