ML19291C407
| ML19291C407 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/04/1979 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Brunner E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19291C400 | List: |
| References | |
| NUDOCS 8001240364 | |
| Download: ML19291C407 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF stac'inic an'o e ion December 4, 1979 Re: D ocket Nos. 50-277 50-278 Inspection Nos. 50-277/79-23 50-278/79-25 Mr. Eldon J.
Brunner, Chief Reactor Operations and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Brunner:
Your letter of November 14, 1979, forwarded combined Inspection Report 30-277/79-23 and 50-278/79-25.
Appendix A to your letter r.ddresses one item which did not appear to be in full compliance with Nuclear Regulatory Commission requirements.
The item is.ategorized as an infraction and is restated below with our response.
Technical Specification 6.1.1,
" Radiation Protection Program", requires that procedures f or p ers onnel radiation protection shall be prepared consistent with requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving pers onnel exp osure.
1.
Health Physics Procedure HP0/CO-4, " Radiation Work Permits", Revision 13, dated March 20, 1979, "The responsibility Section III states in part for following the requirements of the RWP will be accepted by each individual when he signs in on the RWP".
RWP 2-94-0555 dated S ep tember 14, 1979, issued f or decontamination of equipment and system components in the Unit 2 116' foot elevation chemical decontamination area states that taped 1795 28 !
s oou 4o3c.g
M, r. Eldon Brunner, Chief Page 2 openings are required under anti-contamination requirements.
Contrary to the above requirements, on September 17, 1979, two individuals who had signed in on RWP 2-94-0555 were observed working in the chemical decontamination area, a contaminated area, with untaped open coveralls and untaped gloves.
Response
The workers in the chemical decontamination area were contractors from the company which owns the electro-polishing equipment.
They were in the process of filling the equipment with fresh solution in p reparation for decontamination to be performed during the outage.
The individuals were interrupted and instructed to adhere to RWP requirements in all instances, not just during the preparation for decontamination.
2.
Health Physics Procedure HPO/CO-4, " Radiation Work Permits", Revision 13, dated March 20, 1979, requires in Section VI that each person shall provide the following data on the Radiation Work Permit (RWP) upon leaving:
a)
Time out b)
Dosimeter reading c)
Differential dosimeter reading Contrary to the above requirement, between September 18 and 20, 1979, seven individuals who had signed in on RWP 3-94-0423, dated August 2, 1979 f or Unit 3 refueling floor general work area =,
f ailed to p rovide the required informatica upon leaving.
On September 19 and 20, 1979, four individuals signed in on RWP 3-01-0492, dated September 15, 1979 for Unit 3 MSIV room valve repair, general maintenance, and inspection, without providing the required inf ormation upon leaving.
Response
These individuals f ailed to p rovide time out, d o s ir.e t e r reading, and dif f erential dosimeter reading up on leaving the area.
Doses to the individuals were obtained by their daily Harshaw TLD readings, but f or purp os es.of documenting MPC-hr airborne exp os u re, the length.of time on the floor was required.
The information was obtained through discussions with the individuals and their supervisors.
The individuals were also ins t rt a
this time to use correct RWP procedures.
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N e
Mr. Eldon Brunner, Chief Page 3 3.
Health Physics Procedure HP0/Co-4, " Radiation Work Permits", Revision 13, dated March 20, 1979, requires in part in Section VI, that all pers onnel who desire to enter the area covered by the RWP shall read and be familiar with the data and instructions on the RWP, sign their own name, and provide name, date, time in, dosimeter reading Contrary to the above requirement, on September 24-25, two individuals were working under RWP 2 0563 in a Unit 2 reactor building hot tool repair cage who had not signed in or p rovided approp riate data on the RWP.
Response
The RWP f or the hot tool repair cage was issued to require Health Physics coverage for certain work on potentially contaminated equipment.
Dose rates and contamination were less than requirements for an RWP at the time of this incident.
When questioned, the contractor personnel involved stated that they had read and understood the RWP and then had dressed for entry, but had f orgotten to sign in on entry to the area.
They were instructed at the time of the incident to use cor-rect RWP procedures.
The three items in this inf raction involve individuals who are not part of the Peach B ot tom s taf f, i.e.,
contractors and PE maintenance pers onnel not normally assigned to the station.
Training Division has been made aware of these findings and is upgrading their training to place more emphasis on the importance of RWP procedural compliance.
In each case the failure to f ollow s tandard p rocedures was pointed out to the individuals involved and they were instructed to use correct RWP procedures.
Routine audits and surveillances are performed by the Quality Assurance Division in the area of RWP compliance and they feel there has been significant improvement in this area over the past two years.
They will continue to s ch edule random checks in this area to assure compliance with RWP procedures.
Very truly y ou rs,
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