ML20056E374
| ML20056E374 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/12/1993 |
| From: | Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Boulette E BOSTON EDISON CO. |
| References | |
| NUDOCS 9308230275 | |
| Download: ML20056E374 (19) | |
See also: IR 05000293/1993010
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M i 2 1933
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Docket No.
50-293
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E. Thomas Boulette, Ph.D.
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Senior Vice President - Nuclear
Boston Edison Company
Pilgrim Nuclear Power Station
Rocky Hill R_ cad
Plymouth, Massachusetts 02360
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Dear Dr. Boulette:
Subject:
Inspection 50-293/93-10
This letter refers to your July 26,1993 correspondence, in response to our June 17,1993
letter. In addition to your correspondence, you and your staff met with us in Region I on
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August 4,1993 to discuss health physics issues presented in the subject Inspection Report.
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This letter provides our evaluation of your response to our June 17,1993 letter and presents
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the significant issues discussed during the meeting. We appreciate your willingness to meet
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with us and to discuss these important health and safety issues, The meeting attendance and
meeting handouts are provided as attachments to this letter.
Regarding Violation A,. you determined that the unauthorized high radiation area entry by _
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three workers that signed in on the wrong radiation work permit (RWP) was due to
inattention to detail by the workers. ' Disciplinary action of the workers and additional
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training of the work force are your primary corrective actions taken for this event. During
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our discussions with you and your staff, two other root causes for the event, or potential
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weaknesses identified as a result of the event, were discussed. First, the current computer
log-in program in use at the station allows any radiation worker to log-in on any active
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RWP. This practice does not ensure that the proper RWP is used, particularly_in the case of
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general RWPs. Further, since the use of general RWPs does not require an interface with
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the health physics (HP) staff, there does not appear to be a mechanism in place to prevent -
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the improper use of general RWPs in the field. Second, the current practice at the station, as
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stipulated in Section 8.1.4 of Procedure 6.1-022, is that Work Supervisors provide briefmgs
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that include the radiological area and provide other radiological controls functions for their
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workers using general RWPs. Depending on the extent of involvement of Work Supervisors -
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in the HP area, this ' practice may be in violation of your Technical Specifications that deal
with qualifications of personnel. During the meeting you stated that you would determine if
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better controls could be established regarding the computer log-in program and use of general
RWPs. You also stated that you would ensure that all radiological briefings, irrespective of
whether they are for general or specific RWPs, would be done by radiological controls
personnel. We request that you also review Section 8.1.4 of Procedure 6.1-022 to determine
if it is consistent with the personnel qualifications requirements of your Technical
Specifications.
Regarding Violation B, we are withdrawing this violation and will modify our records to
indicate this. The basis for this violation was that a worker repeatedly entered and worked in
an area which caused his dosimeter to alarm on high dose rate. While this occurred, your
position is that it was allowed under your procedure. Based on the information you provided
during the meeting, we are conceding to your interpretation of the procedure.
Notwithstanding our withdrawal, there are two concerns that were discussed at the meeting
relative to this issue that warrant your further attention.
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First, while we have acknowledged your interpretation of the procedure, we believe the
procedure that provides direction to workers regarding responding to dose rate alarms is
confusing and warrants modification. Section 5.3 of Procedure 1.3-106 states that if the
dosimeter (an Alnor model) alarms on high dose rate, the worker is to move to a lower dose
rate area if possible; otherwise the worker is to report to radiation protection. Our
interpretation of this statement is that, upon encountering a high dose rate alarm, the worker
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must go to a lower dose rate area, continue the work from the lower dose rate area, or if that
is not possible, the worker must report to radiation protection, and the worker may not re-
enter the high dose rate area for the purpose of conducting work. We believe that our
interpretation most closely follows the wording of the procedure. Nevertheless, you stated
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that your interpretation is that workers may go back into the high dose rate area to continue
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their work if they cannot do it from the low dose rate area, and that this is well understood
by plant radiation workers. We believe your interpretation does not follow the procedure
wording closely enough and that a modification to the procedure is appropriate. During the
meeting you stated that you would review the procedure to determine if a clarifying change is
needed.
Second, it is important to recognize that, allowing workers to perform tasks while their
alarming dosimeter dose rate alarm is sounding is a practice that has been a contributing
factor in an unplanned exposure. Recently (April,1993) at your station a worker continued
to work with his dosimeter sounding on total dose. The worker received an unplanned
exposure of 116 mrem above the alarm setpoint. The worker stated that he was not aware
that he was required to leave the high radiation area due to an alarm on his dosimeter. This
particular incident was not cited as a violation because it met the criteria required for a non-
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cited violation. Should future incidents of this nature occur, however, they will be
considered for appropriate enforcement action. We recognize that your policy in this area
has some benefits, particularly in the area of maintaining radiation exposures as low as
reasonably achievable (ALARA). We are also aware that you recognize that successful
implementation of the policy requires a very clear understanding on the part of the workers
of the difference between the dose rate alarm and the total dose alarm, and a clear
understanding of what actions are required in each case.
Once again, we want to thank you for meeting with us on August 4,1993. We found the
meeting very beneficial. We will review your corrective actions for the violation and your
actions for the issues during a future inspection of your licensed activities. No response to
this letter is required. Your cooperation with us is appreciated.
Sincerely,
Odgnal Signed By:
Charles W. Hehl
Charles W. Hehl, Director
Division of Radiation Safety
and Safeguards
Enclosures:
1.
August 4,1993 Meeting Attendance List
2.
Licensee Meeting Agenda
3.
Radiological Data Presented by the Licensee
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OFFICIAL RECORD COPY
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cc w/encls:
E. Kraft, Vice President, Nuclear Operations and Station Director
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L. Schmeling, Plant Department Manager
V. Oheim, Manager, Regulatory Affairs and Emergency Planning Department
D. Tarantino, Nuclear Information Manager
N. Desmond, Compliance Division Manager
R. Hallisey, Department of Public Health, Commonwealth of Massachusetts
R. Adams, Department of Labor and Industries, Commonwealth of Massachusetts
The Honorable Edward M. Kennedy
The Honorable John F. Kerry
The Honorable Edward J. Markey
The Honorable Terese Murray
The Honorable Peter V. Forman
B. Abbanat, Department of Public Utilities
Chairman, Plymouth Board of Selectmen
Chairman, Duxbury Board of Selectmen
Plymouth Civil Defense Director
Paul W. Gromer, Massachusetts Secretary of Energy Resources
Sarah Woodhouse, Legislative Assistant
A. Nogee, MASSPIRG
Regional Administrator, FEMA
Office of the Commissioner, Massachusetts Department of Environmental Quality
Engineering
Office of the Attorney General, Commonwealth of Massachusetts
T. I%one, Massachusetts Executive Office of Public Safety
Chairman, Citizens Urging Responsible Energy
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2)
NRC Resident Inspector
Commonwealth of Massachusetts, SLO Designee
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OFFICIAL RECORD COPY
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Boston Edison Company
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/ 3 1 2 1E53
bec w/ encl:
Region I Docket Room (with concurrences)
bec (VIA E-MAIL):
W. Butler, NRR
R. Eaton, NRR
V. McCree, OEDO
W. Pasciak, DRSS
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OFFICIAL RECORD COPY
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ENCLOSURE 1
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UNm2) STAH3
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NUCLEAR REGULATORY COMMISSION
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August 4,1993
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hianagement Meeting with Boston Edison Company to Discuss Health Physics Issues
hieeting No. 93-95 Attendance Roster
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Name
Title
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E. Thomas Boulette
BECo, Senior Vice Pmsident - Nuclear
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James H. Joyner
USNRC, Chief, Facilities Radiological Safety
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and Safeguards Branch
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USNRC, Radiation Specialist
USNRC, Senior Radiation Specialist
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Vemon Oheim
BECo, Regulatory Affairs and Emergency
Preparedness Department hianager
Iee Olivier
BECo, Nuclear Services Department Manager
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Walter J. Pasciak
USNRC, Chief, Facilities Radiation Protection
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Section
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Susan F. Shankman
USNRC, Deputy Director, Division of Radiation
Safety and Safeguards
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Tom Shediosky
USNRC, Project Engineer, Division of Reactor
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Projects
Laurie Wetherell
BECo, Radiation Protection hianager
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ENCLOSURE 2
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AUGUST 4,
1993
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NRC/BECo MANAGEMENT MEETING - RADIATION PROTECTION
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I.
INTRODUCTION - ETB
II.
NOV DISCUSSION - LEW
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A. RESPONSE TO INSPECTION LETTER
B. REVIEW PROGRAM PERFORMANCE INDICATORS
C. REAFFIRM COMMITMENT TO PROGRAM IMPROVEMENT
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III.
SPECIFIC RP PROGRAM IMPROVEMEFTS - LJO
A. REVIEW LIST OF IMPROVEMENTS
B. REAFFIRM COMMITMENT TO CONTINUED IMPROVEMENT
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IV.
SUMMARY - ETB/HVO
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RESPONSE TO NRC COVER LETTER ISSUES
NRC REOUEST
IN YOUR RESPONSE TO THE FIRST VIOLATION, PLEASE ALSO
ADDRESS THE WORKERS CROSSING THE HIGH RAD ROPE BOUNDARY,
WHICH WE UNDERSTAND WAS INADVERTENT. WE WOULD LIKE YOUR VIEW
AS TO NHETHER THIS WAS A RESOLT OF POOR POSTING, WHETHER THE
WORKERS DID NOT URDERSTAND THE SIGNIFICANCE OF THE POSTING,
OR NHETHER THERE WAS SOME OTHER ROOT CAUSE.
BECo RESPONSE
THE AREA WHICH THE THREE CONTRACTOR INDIVIDUALS ENTERED
WAS CORRECTLY POSTED, "HIGH RADIATION AREA, CONTAMINATED
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AREA, RADIOACTIVE MATERIALS AREA, RWP REQUIRED FOR ENTRY".
(PICTURES)
THE THREE INDIVIDUALS STATED THAT THEY OBSERVED THE
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POSTINGS ON THE WAY DOWN THE STAIRS TO THE B QUAD. THESE
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POSTINGS READ, " CONTAMINATED AREA BEYOND RAILING". WHEN THEY
ARRIVED AT THE BOTTOM OF THE STAIRS THEY ADMmw THAT THEY
DID NOT READ THE POSTING BUT ASSUMED THAT IT WAS THE SAME
POSTING AS THOSE THAT THEY HAD PASSED ALONG THE
STAIRS.DURING A DISCUSSION WITH THE RAD OPS SUPERVISOR, THE
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INDIVIDUALS STATED THAT THEY DID KNOWINGLY CROSS A BOUNDARY
BUT FAILED TO CHECK THE BOUNDARY POSTING.
BECAUSE THEY WERE DRESSED OUT IN PROTECTIVE CLOTHING /
THEY ASSUMED THEY COULD ENTER WHAT THEY THOUGHT TO BE ONLY A
CONTAMINATED AREA.
A CRITIQUE CONDUCTED ON THIS INCIDENT REVEALED THAT THE
INDIVIDUALS WERE AWARE THAT THEY COULD NOT WORK IN A HIGH
RADIATION AREA UNDER A GENERAL RWP.
THE ROOT CAUSE OF THIS PROBLEM WAS DETERMINED TO BE
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PERSONNEL ERROR DUE TO INATTENTION TO DdTAIL.
NRC REOUEST
PLEASE INDICATE YODR CORRECTIVE ACTIONS ASSOCIATED WITH
THIS ISSUE.
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BECO RESPONSE
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IMMEDIATE CORRECTIVE ACTIONS
- CONTRACTOR PERSONNEL WERE BRIEFED ON THEIR
RESPONSIBILITY
FOR UNDERSTANDING THE RADIOLOGICAL WORK REQUIREMENTS.
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BEGINNING OF THE YEAR TO ENSURE THAT THIS WAS AN ISOLATED
INCIDENT.
- RP MANAGEMENT AND CONTRACTOR FOREMEN CONDUCTED A REVIEW
OF THE PROCEDURE FOR CONDUCT OF RADIOLOGICAL OPERATIONS WITH
CONTRACTOR PERSONNEL.
- DUE TO A QUESTION ASKED DURING THE CRITIQUE ON THE
DIFFERENCE BETWEEN THE SOUND OF THE TWO ALNOR ALARMS
ALL CONTRACTOR PERSONNEL RECEIVED ADDITIONAL TRAINING.
ROOT CAUSE CORRECTIVE ACTION
- THE RADIOLOGICAL SECTION HAS COMMITTED TO PROVIDING
RADIOLOGICAL PROTECTION LIASONS TO THE FIELD ENGINEERING
AND SUPERVISION DIVISION FOR ALL FUTURE OUTAGES.
- ADVANCED RADIATION WORKER TRAINING IS BEING CONDUCTED
FOR ALL INDIVIDUALS CURRENTLY BADGED AS LEVEL II GET. ALL
SUPERVISORS ARE SCHEDULED TO RECEIVE THIS TRAINING BY THE
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END OF THE YEAR.
- ALNOR ALARM DEMONSTRATIONS ARE NOW INCLUDED IN ALL'
GENERAL EMPLOYEE TRAINING CLASSES.
- CONTRACTOR SUPERINTENDENT AND FOREMAN TRAINING WILL BE
CONDUCTED BY THE FIELD ENGINEERING AND SUPERVISION DIVISION
TO DEMONSTRATE THE PROPER METHOD OF CONDUCTING A PRE-JOB
BRIEFING WITH SPECIAL CONSIDERATION GIVEN TO THE UNDER-
STANDING OF RWP DETAILS.
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NRC REOUEST
WITH REGARD TO THE SECOND VIOLATION, AS A RESULT OF 00R
REVIEW OF THE WRITTEN STATEMENTS MADE BY THE WORKERS AFTER
THE ENTRY, WE BELIEVE THAT YOUR POLICY IS NOT CLEAR
REGARDING WHAT SHOOLD BE DONE IN THE EVENT THAT A WORKER'S
DOSIMETER BEGINS TO CONTINUOUSLY ALARM. IN ADDITION, IT IS
OUR UNDERSTANDING THAT
INSTRUCTIONS ARE GIVEN TO WORKERS IN GENERAL EMPLOYEE
TRAINING TO LEAVE THE WORK AREA WHEN THIS OCCURS.
BECo RESPONSE
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BOTH THE PNPS PROCEDURE AS WELL AS THE GENERAL EMPLOYEE
TRAINING DOCUMENT ARE CLEAR REGARDING THE APPROPRIATE
ACTIONS TO TAKE WHEN EITHER ALNOR ALARM SIGNALS.
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PNPS PROCEDURE 1. 3 -1M " CONDUCT OF RADIOLOGICAL
OPERATIONS", STATES THAT IF YOUR ALNOR ALARMS ON HIGH DOSE
RATE, MOVE TO A LOWER DOSE RATE AREA IF POSSIBLE; OTHERWISE
REPORT TO RP. THE PROCEDURE GOES ON TO SAY THAT IF YOUR
ALNOR ALARMS ON TOTAL DOSE, IMMEDIATELY LEAVE THE RADIATION
AREA.
IN ADDITION, THE GENERAL EMPLOYEE TRAINING DESCRIBES,THE
TWO TYPES OF ALNOR ALARMS, CONDITIONS THAT CAN CAUSE THE
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ALARM AND APPROPRIATE ACTION TO TAKE.
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SPECIFICALLY, WHEN THE ACCUMULATED DOSE IS GREATER THAN
THE ACCUMULATED DOSE ALARM A BEEP LASTING ONE SECOND WILL
OCCUR EVERY FOUR SECONDS. THIS ALARM WILL CONTINUE TO SIGNAL
UNTIL THE DOSIMETER IS LOGGED OUT. THE APPROPRIATE ACTION IS
TO LEAVE THE AREA AND REPORT TO RP. DO NOT LOG OUT AT A
READER.
ALSO, WHEN WORKING IN AN AREA WHERE THE DOSE RATE IS
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GREATER THAN THE DOSE RATE ALARM SET POINT THE DOSIMETER
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WILL ALARM AT THREE BEEPS PER SECOND UNTIL THE DOSIMETER IS
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BROUGHT TO AN AREA WHERE THE DOSE RATE IS LESS THAN THE DOSE
RATE ALARM SET POINT. THE REQUIRED ACTION IS TO MOVE TO A
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LOWER DOSE RATE AREA TO STOP THE ALARM. THESE ALARM SIGNALS
ARE ALSO ILLUSTRATED ON THE BACK OF EACH ALNOR DOSIMETER.
NRC REOUEST
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WE ALSO UNDERSTAND THAT UNDER SOME CONDITIONS WORKERS ARE
EXPECTED TO STAY IN THE WORK AREA WHEN THEIR DOSIMETER
EITHER -INTERMITTENTLY OR CONTINUOUSLY ALARM. IN YODR
RESPONSE TO THIS VIOLATION, PLEASE PROVIDE YOUR STATION
POLICY ON THIS HATTER.
BECo RESPONSE
AS PER THE ABOVE INFORMATION PROVIDED BY BOTH THE PNPS
PROCEDURE AND TRAINING DOCUMENT, WORKERS ARE NEVER ALLOWED
TO REMAIN IN AN AREA WITH THEIR ALNOR IN CONSTANT ALARM.
IF THE ALNOR ALARMS ON INTEGRATED DOSE, THE WORKER IS
INSTRUCTED TO LEAVE THE AREA IMMEDIATELY.
IF THE ALNOR ALARMS ON DOSE RATE, THE WORKERS ARE
INSTRUCTED TO MOVE TO A LOWER DOSE RATE AREA TO CLEAR THE
ALARM. THE DOSE RATE ALARM IS INTENDED TO ASSIST IN ALERTING
INDIVIDUALS TO MOVE OUT OF ELEVATED RADIATION AREAS IN ORDER
TO MAINTAIN THEIR EXPOSURES ALARA.
THERE ARE SEVERAL AREAS, ACCESSIBLE UNDER A GENERAL RWP,
WITHIN THE PROCESS BUILDINGS WHERE THE DOSE RATE IS EXPECTED
TO EXCEED THE ALNOR DOSE RATE ALARM SET POINT. EXAMPLES OF
THESE AREAS INCLUDE THE HALLWAY ALONG THE SKIMMER SURGE
TANKS, THE BOTTOM OF THE B QUAD JUST OUTSIDE OF THE HPCI
QUAD, AND PORTIONS OF THE FUEL POOL CORRIDOR.
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IT IS EXPECTED THAT IF AN INDIVIDUAL PASSES SLOWLY
THROUGH THIS AREA THEN THE ALNOR DOSE RATE ALARM WILL
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SIGNAL, ALERTING THE INDIVIDUAL TO MOVE QUICKLY THROUGH,THIS
AREA IN ORDER TO MINIMIZE EXPOSURE.
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On-Site Raasological Workers (Approximate) by Year
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Radiological Occurrence / Problem Reports by Year
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ROR/RPR Breakdown by Category by Year *
Improper RAM Storage
Posting Violation Y
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Other
Poor Housekeeping
RWP Violation
Procedure Violation / Inadequacy
Dosimetry Not Wom k
ALARA Concems
improper Frisking k
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Spills Cont /Contam E
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Contam/ Clean Areas
Personnel Contaminations
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20
25
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Percent of Occurrences
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- _ _
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Positive Whole Body Counts (>lNPO Levels) by Year
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Respirator Use for Radiological Protection by Year
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01993 YTD
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Personnel Contaminations by Year
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279
377
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134
,
E 1991
E 1992
E 1993 YTD
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. . _ - _ _ _ - . . .
_. - ____.. . ___ _. _ _ _ _ _ .._ _ . _. _ _ _ _ __ -
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- _ - _ _ - . - _ _ . . _ -
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Clean Floor Area Status (Sq. Ft.) by Year
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94420
117488
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Radiation Doses (Rom) by Year
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273
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- Annual Estimate 428 Rem
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BOSTON EDISON
10 CIR 2 EOI
P gnm Nacicar Power Station
Rocky Heli 6085
hvmoet n Massachusetts o2360
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July
26, 1993
BEco Ltr.93-092
E. T. Boulette. PhD
Senior Vice Prescent-Nuclear
U.S. Nuclear Regulatory Commission
Attn: Document Control Desk
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Washington, D.C. 20555
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Docket No. 50-293
License No. DPR-35
Subject:
REPLY TO NOTICE OF VIOLATIONS
Reference:
NRC Region I Inspection Report 50-293/93-10
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Dear Sir:
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Enclosed is Boston Edison Company's reply to the Notice of Violations contained in
the referenced inspection report.
As discussed per telecon between N.L. Desmond and your E.B. McCabe on July 14, 1993,
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this report is being submitted within 30 days of receipt of the report.
The report
was received by Boston Edison on June 29, 1993.
With regard to your request to better understand the actions contained in the
attached response, Boston Edison representatives will be prepared to provide
additional details at the upcoming meeting scheduled for August 4,1993 at King of
Prussia.
Please do not hesitate to contact me if there are any questions regarding this
reply.
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E. T. Boulette, PhD
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Enclosure
cc:
Mr. Thomas T. Martin
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Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
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475 Allendale Rd.
King of Prussia, PA 19406
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Mr. R. B. Eaton
Div. of Reactor Projects I/II
One White Flint North - Mail Stop 1401
11555 Rockville Pike
Rockville, MD 20852
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Sr. NRC Resident inspector - Pilgrim Station
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ENCLOSURE 1
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REPLY TO NOTICE OF VIOLATION
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Boston Edison Company
Docket No. 50-293
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Pilgrim Nuclear Power Station
License No. DPR-35
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As a result of the inspection conducted at Pilgrim Nuclear Power Station from May 10,
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1993, through May 14, 1993, and in accordance with the NRC Enforcement Policy (10 CFR 2,
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Appendix C), the following violations were identified:
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10 CFR 19.12 requires, in part, that all individuals working in a restricted area be
instructed in the precautions and procedures to minimize _ exposure to radioactive
materials, in the purpose and functions of protective devices employed, and in the
applicable provisions of the Commission's regulations and licenses.
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Specification 6.11 requires that procedures for personnel radiation protection shall be
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approved, maintained and adhered to for all operations involving personnel radiation
exposure.
Procedure, No. 6.1-022, Rev. 34, " Issue, Use, and Termination of Radiation Work
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Permits", specifies that general RWPs shall not be used to enter high radiation areas
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except for operator rounds or for radiological protection entries (Section 6.0 [4]).
Contrary to the above, on April 24, 1993, three individuals made an unauthorized
entry into a high radiation area in the "B" RHR Quad, and had not been -instructed in
the radiological conditions in their work area and had not been instructed in the
precautions and procedures to minimize exposure to radioactive materials.
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Contrary to the above, on April 24, 1993, three individuals made an entry into a
high radiation area in the
"B" RHR Quad by using the general Radiation Work Permit
No. 5011, which prohibits high radiation area entries.
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This is a Severity Level IV Violation (Supplement VI).
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RESPONSE TO VIOLATION
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The Boston Edison Company accepts this violation.
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REASON FOR VIOLATION
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The cause of the incident was inattention to detail. On April 24, 1993, contractor
(Mercury) personnel entered a posted High Radiation Area in the "B" Residual Heat Removal
(RHR) Quadrant without being briefed on the radiological conditions in their work area.
In addition, the three workers entered the High Radiation Area using a General Radiation
Work Permit (RWP) which specifically prohibits entries into. areas greater than or equal to
100 mr/hr. The Assistant Construction Superintendent.having just been assigned to the
task that evening.was unaware of the Specific RWP.93-2063 that had been written to be used
for the entire task.
He was also responsible to conduct the pre-job briefing with the
foreman and craft personnel.
Per the critique'of the event the turnover from the previous-
shift was not based upon the work documents regarding the RWP or the Maintenance Request-
(MR), but was a verbal discussion and did not cover the radiological aspects.of the job.
By their own admission, the three workers failed to read the area' postings prior to their
entry, and also failed to read General RWP No. 93-5011 (written for use on the Reactor-
Building 23' only).
In addition, the cognizant job foreman failed to ensure the work-was
conducted in accordance with the RWP and that the workers were aware of the radiological
conditions in the work. area (as outlined in PNPS Procedure 1.3.106,- Conduct of
Radiological Operations).
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CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED
Immediate corrective action was taken to suspend work on RWP 93-5011, to restrict the
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three involved individuals from entering Radiologically Controlled Areas, and to notify
appropriate management personnel.
Radiological Problem Report 93.0322 was written to
document the event.
Radiological Protection
(RP) supervision toured the work area to
verify the adequacy of area postings.
Further corrective action was taken following a critique of the incident on 4/29/93.
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three involved workers were disciplined and the job Foreman and the Assistant Construction
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Superintendent were issued formal warnings.
On 5/7/93 an extensive review of the
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incident, with day and night shift Mercury personnel, was conducted by the Field
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Engineering and Supervision Division.
The Radiological Protection Manager met with the
Projects And Construction Manager and the Mercury Project Manager to review the issue and
identify corrective actions.
Mercury personnel were briefed on their responsibility for understanding the
radiological requirements for conducting work.
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The Radiological Protection (RP) Section reviewed General RWP sign-in sheets to
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ensure that this was an isolated incident.
No additional problems were identified.
RP and Mercury management conducted a review of Procedure 1.3-106 " Conduct of
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Radiological Operations" with Mercury personnel .
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Due to a question asked during the critique on the difference between the sound of
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the two ALNOR alarms (for dose rate and integrated dose) all Mercury personnel were
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provided training on ALNOR alarms.
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Mercury management also conducted a Division meeting with all their personnel stressing
the importance of attentiveness to radiological postings and indicating that procedural
noncompliance would not be tolerated.
CORRECTIVE ACTION TAKEN TO PREVENT RECURRENCE
To assist in preventing individual inattentiveness in the future, the following will be
implemented prior to MC010 (April 1994).
Pilgrim Station has committed to provide Radiation Protection Liaisons to the Field
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Engineering and Supervision Division for all future outages.
Advanced radiation worker training will be implemented by the Technical Training
Division for Boston Edison Supervisors and selected contractor personnel required to
work in High Radiation Areas.
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Pilgrim Station has incorporated an ALNOR alarm demonstration in all General
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Employee Training, (Initial, Requalification and accelerated).
Contractor Superintendent and Foreman training will be conducted by the Field
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Engineering and Supervision Division to demonstrate the proper method of conducting
a pre-job briefing with special consideration given to the understanding of RWP
details.
DATE OF FULL COMPLIANCE
Full compliance was achieved for this event on April 29, 1993, when the workers were made
aware of their non-adherence to the RWP procedure and were disciplined.
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ENCLOSURE 2
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REPLY TO NOTICE OF VIOLATION
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Boston Edison Company
Docket No. 50-293
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Pilgrim Nuclear Power Station
License No. DPR-35
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As a result of the inspection conducted at Pilgrim Nuclear Power Station from May 10,
1993, through May 14, 1993, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:
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Technical Specification 6.11 requires that procedures for personnel radiation protection
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shall be approved, maintained and adhered to for all operations involving personnel
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radiation exposure.
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Procedure No.1.3.106, " Conduct of Radiological Operations", specified that when an -
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alarming pocket dosimeter alarms due to exceeding the high dose rate alarm setpoint, the
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worker shall move to a lower dose rate area or report to radiation protection personnel.
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Contrary to the above, on April 24, 1993, three individuals made an entry into a high
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radiation area in the "B" RHR Quad. When one of the worker's alarming pocket dosimeter
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began to continuously alarm, the worker continued to work in the area, with his' dosimeter
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alarming, until reaching a work termination' point at which time he left the area.
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This is a Severity Level IV violation (Supplement XI).
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RESPONSE TO VIOLATION
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The Boston Edison Company contests this violation.
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BASIS FOR CONTESTING VIOLATION
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PNPS Procedure 1.3.106 " Conduct of Radiological Operations" 5.3 p] reads that ."If your
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SID alarms on high dose rate, move to a lower dose rate area if possible; otherwise,
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report to RP personnel". On April 25, 1993, the Shift Outage Manager conducted a debrief
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following notification of three workers entering'into a High Radiation Area on General RWP
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5011.
Based upon the worker's statements, after entering the "B" Quad, one worker began
pulling cables through a conduit penetration while working on a ladder. He proceeded up
the ladder and his ALNOR-alarmed near the top. He proceeded to conduct as much of the
work as possible from the bottom of the ladder where the ALNOR did not alarm.
He stated
that he checked his accumulated dose periodically and found it read 3 mR on the first '
check, and slightly higher the second time.
When the crew ran into an obstruction, he
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climbed up the ladder again. While still on the ladder he checked his accumulated dose
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and found it reading 22 mR. At this point the crew exited the area and reported to RP.
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While acknowledging that the workers possessed a degree of unfamiliarity with the ALNOR
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Self-Indicating Dosimeters, Pilgrim Station contends that the worker complied with PNPS
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Procedure 1.3.106 by leaving the work area when he realized that he could not complete his
task in a low dose rate area. The ALN0R dose rate alarm caused the work crew to leave the
area and the job was aborted.
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