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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217D3951999-10-13013 October 1999 Forwards Request for Addl Info Re Util 990806 Submittal on USI A-46, Implementation Methodology Used at Pilgrim Nuclear Power Station, Per GL 87-02 ML20217E1581999-10-0808 October 1999 Forwards Insp Rept 50-293/99-05 on 990726-0905.Three Violations Noted & Being Treated as Ncvs.Violations Include Failure to Assure That Design Bases Correctly Translated Into Specifications ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20212J8301999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Pilgrim Nuclear Power Station.Staff Conducts Reviews for All Operating NPPs to Integrate Performance Info & to Plan Insp Activities at Facility Over Next Six Months ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212F7871999-09-24024 September 1999 Advises That Util 990121 Application for Amend Being Treated as Withdrawn.Proposed Changes Would Have Modified Facility UFSAR Pertaining to Values for post-accident Containment Pressure Credited in Pilgrim Net Positive Head Analyses ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212C2861999-09-16016 September 1999 Forwards SER Accepting Licensee 981123 Request for Relief RR-E1,RR-E5,RR-E6 Pursuant to 10CFR50.55a(a)(3)(i) & Request for Relief RR-E2,RR-E3 & RR-E4 Pursuant to 10CFR50.55a(a)(3)(ii) ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211H5701999-08-27027 August 1999 Forwards Insp Rept 50-293/99-04 on 990610-0725.Two Violations Identified Being Treated as non-cited Violations ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20210U7521999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opossing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U6691999-08-18018 August 1999 Forwards from Massachusetts State Senator T Murray Opposing Merger Between Bec Energy & Commonwealth Energy Systems ML20210U5761999-08-18018 August 1999 Responds to Opposing Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts. Informs That for Sale,Nrc Responsible for Only Ensuring That Entergy Technically & Financially Qualified to Operate NPP ML20210U5151999-08-17017 August 1999 Forwards Notice of Withdrawal of Application for Approval of Indirect Transfer of FOL for Pilgrim in Response to .Approval No Longer Needed Since Beco Sold Interest in Pilgrim to EOI on 990713 ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216E2321999-07-26026 July 1999 Discusses GL 92-01,rev 1,suppl 1, Rv Structural Integrity. NRC Revised Info in Rvid & Releasing as Rvid Version 2 ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210E2231999-07-20020 July 1999 Discusses Arrangements Made by Dennis & M Santiago During 990615 Telephone Conversation for NRC to Inspect Licensed Operator Requalification Program at Pilgrim During Wk of 991004 ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210A9441999-07-14014 July 1999 Responds to Re Changes to Pilgrim Nuclear Power Station Physical Security Plan Identified as Issue 2,rev 14, Addendum 1,respectively.No NRC Approval Is Required IAW 10CFR54(p) ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209G2251999-07-0909 July 1999 Forwards Insp Rept 50-293/99-03 on 990419-0609.Five Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations,Consistent with App C. Several Individual Tagging Errors Occurred ML20209C4661999-07-0707 July 1999 Forwards SE Accepting Addendum on Proposed Change in Corporate Ownership Structure Involving Entergy Nuclear Generation Co ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20196J7251999-07-0101 July 1999 Informs of Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, for Pilgrim Nuclear Power Station ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20196H2381999-06-29029 June 1999 Forwards SER Denying Licensee 980820 Request for Alternative Under PRR-13,rev 2 for Use of Code Case N-522 During Pressure Testing of Containment Penetration Piping ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8761999-06-28028 June 1999 Forwards SER Authorizing Licensee 990317 Relief Request to Use ASME Code Case N-573 as Alternative to ASME Code Section XI Article IWA-4000 for Remainder of 10-year Interval Pursuant to 10CFR50.55a(a)(3)(i) ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217N8911999-10-15015 October 1999 Forwards Rept of Changes,Tests & Experiments at Pilgrim Nuclear Power Station for Period of 970422-990621,IAW 10CFR50.59(b).List of Changes Effecting Fsar,Encl ML20217C3151999-10-0606 October 1999 Forwards Scenario Package for Pilgrim Nuclear Power Station Nrc/Fema Evaluated Exercise Scheduled for 991207.Without Encl ML20217C8051999-10-0505 October 1999 Forwards Proprietary Results of Audiologic Evaluations for Jp Giar,License SOP-10061-3.Attachment Clearly Shows Requirements for Operator Hearing Ability Are Met. Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML20217D5591999-10-0505 October 1999 Documents Pilgrim Nuclear Power Station Five Yr Survey of Main Breakwater.Survey Has Determined That Pilgrim Main Breakwater Is Intact & Remains Adequately Constructed to Perform Designed Safety Function ML20216J9961999-09-29029 September 1999 Forwards Resume of Person Identified as Acting RPM in Licensee to NRC Re Notification That Person Named in License Condition 11 of 20-07626-02,is No Longer Employed at Pilgrim Station.Resume Withheld,Per 10CFR2.790 ML20212H1441999-09-23023 September 1999 Withdraws 990121 Request for License Change Re Emergency Core Cooling Sys Net Positive Suction Head,Due to Incorrect Datum Preparation ML20212H1381999-09-23023 September 1999 Submits Info in Support of Request Filed on 990730 to Grant one-time Exemption from 10CFR50,App E,Authorizing Biennial Full Participation Emergency Preparedness Exercise to Be Conducted in 2002 Instead of 2001 ML20216F3451999-09-16016 September 1999 Forwards Summary Rept Providing Results of ISI Conducted at PNPS on-line & Refueling Outage (RFO 12) ML20216E7111999-09-0909 September 1999 Forwards License Renewal Application Including Form NRC-398 & Form NRC-396 for Jp Giar,License SOP-10061-3.Without Encls ML20216E5891999-09-0707 September 1999 Forwards Copy of Pilgrim Station Organization Structure. Encl Refelcts Changes in Upper Mgt Level Structure.Changes Were Effective 990901 ML20211M4501999-09-0303 September 1999 Informs That Pilgrim Nuclear Power Station Plans to Conduct Full Participation Emergency Preparedness Exercise with Commonwealth of Ma on 991207,IAW 10CFR50,App E,Section IV.F.2 ML20211M9161999-08-31031 August 1999 Submits Review & Correction of Info in Reactor Vessel Integrity Database (Rvid),Version 2,re Pilgrim Station ML20211J8391999-08-30030 August 1999 Forwards Rev 1 to Provisional Decommissioning Trust Agreement for Plant,Changing Portions of Agreement to Permit Up to Two Distributions & Clarify Formula for Distribution ML20211C3381999-08-19019 August 1999 Provides semi-annual LTP Update,Including Schedule, Commitment Descriptions,Progress Since Last Update & Summary of Changes.Rev Bars Indicate Changes in Status Since Last Submittal ML20211B3841999-08-16016 August 1999 Forwards Response to NRC Second RAI Re Pressure Locking & Thermal Binding of SR power-operated Gate Valves ML20210U4831999-08-13013 August 1999 Forwards fitness-for-duty Program Performance Data Sheets for Period of 990101-0630,per 10CFR26.71(d) ML20210S0891999-08-0909 August 1999 Forwards Amend 11 to Indemnity Agreement B-48 Signed by Boston Edison Co & Entergy Nuclear Generation Co ML20210R6251999-08-0606 August 1999 Provides Supplementary Info on USI A-46 Implementation Methodology at Pilgrim Station,To Enable NRC to Perform Evaluation & Issuance of Plant Specific SER for Plant ML20210M9411999-08-0202 August 1999 Requests That NRC Treat Pending Actions Requested by Beco Prior to 990713,as Requests Made by Entergy.Ltr Requests That Minor Administrative Changes to License Amend 182 & Associated Ser, ,reflect 990713 Transfer ML20210H8761999-07-30030 July 1999 Requests That NRC Grant Exemption from Requirements of 10CFR50,App E,Section IV F,Which Would Authorize Rescheduling of 2001 Biennial Full Participation Emergency Preparedness Exercise for Pilgrim Station to 2002 ML20210H8661999-07-29029 July 1999 Provides Revised Response to GL 96-06 & Addresses NRC Insp Concern for Containment Penetration X-12.Info Submitted to Facilitate NRC Review & Closeout of Subject GL for Plant ML20216D4131999-07-22022 July 1999 Informs That J Conlon,License OP-11040-1,terminated Employment with Beco on 990703,per 10CFR50.74.Individual Will Not Participate in Util Licensed Operator Requalification Training Program ML20210C4151999-07-19019 July 1999 Informs That Util Intends to Submit Approx Eight Licensing Actions in FY00 & Eight in FY01,in Response to Administrative Ltr 99-02.Actions Are Not Expected to Generate Complex Reviews ML20210F3711999-07-14014 July 1999 Informs NRC That Effective 990713,listed Pilgrim Station Security Plans Have Been Transferred from Boston Edison to Entergy & Are Still in Effect ML20209C7761999-07-0606 July 1999 Submits Annual Summary Rept of Changes Made to QAP Description as Described in QA Manual,Vol Ii.Rept Covers Period of Jul 1998 Through June 1999.No Changes Made During Period ML20209C3851999-07-0606 July 1999 Forwards Redacted Draft of Decommissioning Trust Agreement Re Transfer of PNPS & NRC Operating License & Matls License from Boston Edison Co to Entergy Nuclear Generating Co ML20209B9431999-06-30030 June 1999 Provides Formal Notification That Closing Date for Sale & Transfer of Pilgrim Station Scheduled to Occur on 990713. a Wang Will Be Verbally Notified of Time of Sale Closing ML20209B9411999-06-30030 June 1999 Discusses Deferral of IGSCC Welds to RFO 13.Deferral of Welds to Refueling Outage 13 Does Not Impact Acceptable Level of Quality & Safety Per 10CFR50.55(a)(3)(i) Since Plant in Compliance W/Exam Percentage Requirements ML20209B9791999-06-29029 June 1999 Forwards Rev 13A to Pilgrims COLR for Cycle 13,IAW TS 5.6.5 Requirements.Rev 13A Provides cycle-specific Limits for Operating Pilgrim During Remainder of Cycle 13 ML20209A8701999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure for Plant,Reporting Status of Facility Y2K Readiness Encl ML20210U5901999-06-25025 June 1999 Opposes Merger of Bec Energy & Commonwealth Energy Sys in Commonwealth of Massachusetts.Expresses Skepticism Re Claim by Companies That Consumers Will Benefit from Proposed Consolidation & four-year Freeze in Base Rates ML20209C3431999-06-22022 June 1999 Forwards Addendum 1,Rev 14 to Pilgrim Station Security Plan,Iaw 10CFR50.54(p)(2).Changes Proposed Have Been Implemented & Constitute Increase in Plant Defense Plan Commitments.Encl Withheld,Per 10CFR73.21 ML20195G3721999-06-0707 June 1999 Informs That Proposed Indicators Failed QA Assessments for Digital Verification,Validation & Control of Software. Proposed Mod Can Be Completed on-line ML20195B5021999-05-27027 May 1999 Provides Suppl Info to 990203 Request of Beco That NRC Consent to Indirect Transfer of Control of Util Interest in License DPR-35.Request Described Proposed Merger of Bec Energy with Commonwealth Energy Sys ML20207D4681999-05-24024 May 1999 Provides Addl Info to That Included in Beco Ltr 98-123 Dtd 981001,addressing NRC Concerns Described in GL 96-06, Concerning Waterhammer in Reactor Bldg Closed Cooling Water Sys ML20195B9051999-05-20020 May 1999 Forwards Completed Renewal Applications for Listed Operators.Without Encls ML20206J4901999-05-0606 May 1999 Forwards Completed License Renewal Application,Including Forms NRC-398 & 396 for Sc Power,License OP-6328-3 ML20206P0711999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, for K Walz,License SOP-10886-1.Encl Withheld IAW 10CFR2.790(a)(6) ML20206D3621999-04-27027 April 1999 Informs NRC That Final Five Sys self-assessments Required to Fulfill Commitment Made in 980828 Response to Insp Rept 50-293/98-04 Were Completed on 990422.Completion Was Delayed by High Priority Refueling Outage 12 Preparatory Work ML20205R9871999-04-21021 April 1999 Forwards Affidavit of JW Yelverton of Entergy Nuclear Generation Co Supporting Request for Withholding Info from Rept on Audit of Financial Statements for Year Ended 971231. Pages 16 & 18 of Subj Rept Also Encl ML20207B0891999-04-20020 April 1999 Forwards e-mail Message from Constituent,J Riell Re Y2K Compliance of Nuclear Power Plant in Plymouth,Massachusetts. Copy of Article Entitled Nuke Plants May Not Be Y2K Ready Also Encl ML20206A2741999-04-16016 April 1999 Dockets Encl Ltr Which Was Sent to AL Vietti-Cook Re Condition of Approval of Transfer of License & License Condition for DPR-35.Encl Resolves Issues Between Attorney General of Commonwealth of Massachusetts & Applicants ML20205P9131999-04-16016 April 1999 Submits Applicant Consent to Listed Condition of Approval of Transfer of License & License Condition for License DPR-35 & Affirmatively Request That NRC Adopt Listed Language in Order ML20205P9271999-04-16016 April 1999 Withdraws Motion for Leave to Intervene & Petition for Summary Or,In Alternative,For Hearing.Requests That NRC Adopt Condition of Approval of Transfer of License & License Condition Agreed to Beco & Entergy Nuclear Generation Co ML20205Q9231999-04-15015 April 1999 Forwards Proprietary & non-proprietary Addl Info in Support of Request to Transfer of Plant FOL & Matls License to Entergy Nuclear Generation Co.Proprietary Info Withheld,Per 10CFR2.790 ML20205P9631999-04-15015 April 1999 Provides Attachments a & B in Support of Request for Transfer of Plant Operating License & NRC Matl License from Beco to Entergy Nuclear Generation Co as Submitted in Ref 1. Info Provided in Response to Request at 990413 Meeting ML20205H9281999-04-0707 April 1999 Requests Withdrawal of Uwua Locals 369 & 387 Unions Joint Intervention in Listed Matter ML20205F3731999-04-0202 April 1999 Submits Addl Info Provided in Support of Request for Transfer of Pilgrim Nuclear Power Station Operating License & Matls License.State of Ma Order Authorizing Divestiture & Copy of Financial Arrangement Encl ML20204H3771999-03-26026 March 1999 Informs That Local 387,Utility Workers Union of America,AFL- Cio Voted to Approve New Contract with Entergy Nuclear Generation Co & Voted to Accept Boston Edison Divestiture Agreement ML20205D4231999-03-24024 March 1999 Forwards Decommissioning Funding Rept for Pilgrim Nuclear Power Station,In Accordance with 10CFR50.75(f)(1) 1999-09-09
[Table view] Category:UTILITY TO NRC
MONTHYEARBECO-90-108, Forwards Anticipated Operator Licensing Exam Schedule Requested by Generic Ltr 90-07, Operator Licensing Natl Exam Schedule,1990-09-12012 September 1990 Forwards Anticipated Operator Licensing Exam Schedule Requested by Generic Ltr 90-07, Operator Licensing Natl Exam Schedule, ML20059D6641990-08-30030 August 1990 Forwards Revised Emergency Plan Implementing Procedures,Per 10CFR50,App E,Section V.W/O Encl ML20059D6791990-08-30030 August 1990 Notifies That Two Remaining Actions for Implementation of SPDS at Plant Complete,Per .Spds Procedures Modified,Identifying Sampling Panel C-19 Return Valves to Operator BECO-90-100, Advises That Valve MO-1001-50 Cannot Be Shown to Meet 30-day Mission for PASS in post-accident Environ Due to Elevated Radiation Dose Rates.Util Currently Developing Solution to Allow PASS to Meet 30-day Availability Requirement1990-08-27027 August 1990 Advises That Valve MO-1001-50 Cannot Be Shown to Meet 30-day Mission for PASS in post-accident Environ Due to Elevated Radiation Dose Rates.Util Currently Developing Solution to Allow PASS to Meet 30-day Availability Requirement BECO-90-102, Forwards Fitness for Duty Program Performance Data for Jan- June 19901990-08-23023 August 1990 Forwards Fitness for Duty Program Performance Data for Jan- June 1990 BECO-90-095, Informs That Kn Taylor Permanently Reassigned to Nuclear Training Dept as of 900717.Taylor Will Remain in Position Which Does Not Require License Certification1990-08-0808 August 1990 Informs That Kn Taylor Permanently Reassigned to Nuclear Training Dept as of 900717.Taylor Will Remain in Position Which Does Not Require License Certification BECO-90-092, Forwards, Decommissioning Funding Rept, Per 10CFR50.33(k) & 50.75(b)1990-07-26026 July 1990 Forwards, Decommissioning Funding Rept, Per 10CFR50.33(k) & 50.75(b) ML20044B3111990-07-11011 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Corrective Actions Include Replacement of Transmitters Identified in Suspect Lots & Implementation of Surveillance Program ML20044A7891990-06-19019 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. Table Listing Status of Each Issue Encl ML20043D7181990-05-31031 May 1990 Advises That Response to NRC 900426 Safety Evaluation Re Util 880804 & 890619 Responses to Generic Ltr 88-01 Will Be Sent on 901115 ML20043A8211990-05-15015 May 1990 Notifies of Change of Senior Operator Status for Cj Martin, Per 10CFR50.74.CJ Martin Will No Longer Participate in Licensed Operator Requalification Training Program ML20042F2211990-05-0101 May 1990 Advises That Scheduled Completion of SPDS Human Factors Validation Activities Scheduled for 900630 & Sys Availability Test by 900731 ML20043B3881990-05-0101 May 1990 Responds to Violations Noted in Insp Rept 50-293/90-05. Corrective actions:82 Excess Flow Check Valves Installed & Operability of Valves Verified by Performing Surveillance Testing ML20012F5601990-04-0202 April 1990 Responds to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Util Instituted Biofouling Control Program in 1982 & Program Has Been Effectively Implemented at Plant & Complies W/Generic Ltr ML20012F3631990-03-30030 March 1990 Requests Temporary Waiver of Compliance from Requirements of Tech Spec Table 3.2.C-1, APRM Upscale Rod Block in Startup & Refuel Modes to Avoid Unnecessary Delay in Critical Path Surveillance Testing ML20012C6501990-03-15015 March 1990 Responds to Generic Ltr 90-01 Re Request for Voluntary Participation in NRC Regulatory Impact Survey.Completed Questionnaire for Applicable Areas Delineated in Survey Encl ML20012D1931990-03-15015 March 1990 Forwards Proposed Scope & Objectives of Annual Exercise 90-04-B Scheduled for 900618 Per Lazarus 890609 Ltr, Emergency Exercise Objective & Scenerio Guidelines. Exercise Will Test & Evaluate Util EPIPs ML20012C7191990-03-14014 March 1990 Forwards Explanation of Errors in 890707 Application Re Corrective Action Plan & Advises That Errors Do Not Affect Technical Basis on Which Exemption Granted.Util Corrective Action Plan Remains Unchanged ML20011F5381990-02-26026 February 1990 Responds to Violations Noted in Insp Rept 50-293/89-12 on 891002-1119.Corrective Actions:On 891109,operations Personnel Directed,Via Night Orders,To Be More Diligent W/ Tagout Documentation & Boundary Tagging Clarified ML20011F2301990-02-23023 February 1990 Notifies of Change in Status of Senior Licensed Operator. DW Gerlits Terminated Senior Reactor Operator License on 900201 But Will Retain Position as Senior Sys & Safety Analysis Engineer ML20006G1411990-02-23023 February 1990 Advises That Tj Mcdonough Reassigned Effective 900126. Individual Will No Longer Participate in Licensed Operator Requalification Training Program ML20011F6521990-02-21021 February 1990 Forwards Inservice Insp Plan for 1990 mid-cycle Spring Outage for Facility.Augmented Insp Will Be Performed for Three IGSCC Category a Welds Using Guidance in Generic Ltr 88-01 & Criteria in NRC Bulletin 88-08,Suppl 3 ML20011F4481990-02-20020 February 1990 Forwards Revised Operability Evaluation of Salt Svc Water Pumps for Plant.Evaluation Concludes That Salt Svc Water Pumps Operable & Requirements of Tech Spec 3.5.B.1 for Pumps Met ML20006G0051990-02-20020 February 1990 Forwards Update to long-term Plan,In Accordance W/Section V.A of Plan for Long-Term Program. Util Implementing Plant Betterment Mods & Activities ML20011E7551990-02-0909 February 1990 Requests Temporary Relief from Tech Spec 4.7.A.2.b.1.d, Limiting Condition for Operation. ML19354E7661990-01-23023 January 1990 Responds to NRC Bulletin 89-002, Stress Corrosion Cracking of High Hardness Type 410 Stainless Steel Bolting in Anchor Darling.... Review Determined That No Subj Anchor Darling Swing Check Valves or Similar Valves Installed at Facility ML20011F4441990-01-19019 January 1990 Forwards Operability Evaluation Re Salt Svc Water Pumps P208 B,C,D & E,Per 900117 Telcon.Evaluation Concluded That Salt Svc Water Pumps P208 B,C,D & E Operable & Tech Spec 3.5.B.1 Requirements Met ML20006A0761990-01-15015 January 1990 Forwards Executed Amend 10 to Indemnity Agreement B-48 ML20006A2591990-01-15015 January 1990 Responds to Generic Ltr 89-10, Safety-Related Motor- Operated Valve Testing & Surveillance. Util Will Develop Program to Enhance Maint,Analysis & Testing Already Conducted on motor-operated Valves ML20005G7701990-01-11011 January 1990 Discusses Revised Schedule for Operability & Availability of Spds,Per 891221 Notification to Nrc.Rev Necessitated by Software Problems Affecting 891231 Schedule Projected in Util 890710 Ltr ML20005G7451990-01-11011 January 1990 Provides Bases for Environ Qualification of Instrumentation Monitoring Effluent Radioactivity & Status of Standby Power Per Reg Guide 1.97,Rev 3 & Generic Ltr 82-33 ML20005G8061990-01-11011 January 1990 Advises That Commitment to Complete Enhancements of Control Panels as Part of Dcrdr,Per NUREG-0737,Item I.D.1 by Oct 1989 Not Met.All Three Panels at Simulator Enhanced & Installation of Revised Meter Scales in Progress ML20005F0761990-01-0404 January 1990 Forwards Revised Inservice Test Program in Response to Generic Ltr 89-04.List of Inservice Test Program Relief Requests Previously Submitted & Acceptable,Per Generic Ltr 89-04,encl ML20005E5601989-12-29029 December 1989 Certifies That Util Has Established Fitness for Duty Program That Meets Requirements of 10CFR26.Drug & Alcohol Level Screening Match Rule Imposition & Implementation Will Be Effective on 900103 ML20042D4821989-12-26026 December 1989 Responds to Violations Noted in Insp Rept 50-293/89-10. Corrective Action:Radiological Section Standing Order 89-09 Issued Allowing Only Radiological Supervisors to Exercise Locked High Radiation Area Door & Key Control ML20011D6851989-12-14014 December 1989 Forwards Response to Generic Ltr 89-21, Request for Info Re Status of Implementation of USI Requirements. ML20011D1631989-12-14014 December 1989 Forwards Pilgrim Nuclear Plant Station Final Assessment Rept, Summarizing Results of self-assessments & Evaluations Conducted Throughout Implementation of Plant Restart Plan & Power Ascension Program ML19325F2751989-11-10010 November 1989 Responds to NRC Bulletin 88-010,Suppl 1, Nonconforming Molded-Case Circuit Breakers. Util Installed H2/02 Analyzers Procured in 1980 & Therefore Exempt from Bulletin Requirements ML19327C0911989-11-0606 November 1989 Forwards Response to Suppl 3 to NRC Bulletin 88-008, Thermal Stresses in Piping Connected to Rcs. Since cyclic- Thermal Heatup/Cooldown Not Present in Piping,Failure Due to Cyclic Thermal Fatigue Will Not Occur ML19325E8581989-11-0101 November 1989 Discusses Litigation Before FERC Re Plant.Util Will Undertake Review of Matls Developed by Opposing Parties in Proceedings.Required Repts Will Be Submitted to NRC After Reportability Has Been Determined ML19325E5251989-10-27027 October 1989 Responds to Generic Ltr 88-20,Suppl 1,describing Plan for Completing Individual Plant Exam for Severe Accident Vulnerabilities.Performance of Level 1 PRA Based on Current Plant Design & Operation Intended ML19325E5661989-10-27027 October 1989 Response to Generic Ltr 89-04, Guidance on Developing Acceptable Inservice Testing Programs. Revised Inservice Testing Program Which Will Include Statement of Conformance to Technical Positions Will Be Submitted by 891215 ML19324B8191989-10-25025 October 1989 Informs That C Leonard & J Stokes Reassigned to Positions Which Do Not Require License Certification Effective 891003 & 891020,respectively ML19327B2291989-10-20020 October 1989 Responds to Generic Ltr 89-07 Re Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs.Changes Made to Contingency Plan,Per 10CFR50.54.Plan Withheld (Ref 10CFR73.21) ML19325E0981989-10-20020 October 1989 Responds to NRC Re Violations Noted in Insp Rept 50-293/89-07.Corrective Actions:Terminal Block Replaced, post-work Functional Test of Ref Temp Switches Performed & Procedure Tp 88-78 Revised to Correct Relay Numbers BECO-89-142, Responds to NRC Re Violations & Proposed Imposition of Civil Penalty from Insp Rept 50-293/89-95. Corrective Action:Two Responsible Util Operators Suspended Because Breakers Incorrectly Positioned for Test1989-09-22022 September 1989 Responds to NRC Re Violations & Proposed Imposition of Civil Penalty from Insp Rept 50-293/89-95. Corrective Action:Two Responsible Util Operators Suspended Because Breakers Incorrectly Positioned for Test BECO-89-144, Requests Interim Approval for Relief from Testing of RHR Sys Valves 63 & 64 Until Refueling Outage 8 Scheduled for 9103151989-09-22022 September 1989 Requests Interim Approval for Relief from Testing of RHR Sys Valves 63 & 64 Until Refueling Outage 8 Scheduled for 910315 BECO-89-135, Forwards Util Anticipated OL Exam Schedule,Per 890706 Generic Ltr 89-12 Request1989-09-11011 September 1989 Forwards Util Anticipated OL Exam Schedule,Per 890706 Generic Ltr 89-12 Request BECO-89-131, Forwards Tech Spec Figures 6.2-2 & 6.2-1,replacing Title of Director of Nuclear Engineering W/Title of Station Director & Adding New Title of Vice President of Nuclear Engineering1989-09-0505 September 1989 Forwards Tech Spec Figures 6.2-2 & 6.2-1,replacing Title of Director of Nuclear Engineering W/Title of Station Director & Adding New Title of Vice President of Nuclear Engineering BECO-89-129, Submits Addl Info Re 890707 Request for Exemption from Certain Containment Leakage Testing Requirements of 10CFR50. Plant mid-cycle Maint Outage,Previously Scheduled for Oct 1989,has Been Rescheduled for Spring 19901989-09-0101 September 1989 Submits Addl Info Re 890707 Request for Exemption from Certain Containment Leakage Testing Requirements of 10CFR50. Plant mid-cycle Maint Outage,Previously Scheduled for Oct 1989,has Been Rescheduled for Spring 1990 1990-09-12
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BOSTON E'DIEDN COMPANY B00 BovLsTON STREET WasTON, MASSACHUSETTS 02199 WILLIAM D. HARRINGTON ocusen viss meessoast em m.
February 15, 1984 BECo Ltr. # 84-028 Mr. Richard h. Starostecki, Director Division of Project and Resident Programs U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, Pennsylvania 19406 Docket No. 50-293 CAL No. 84-03 Response to Confirmatory Action Letter 84-03
Dear Sir:
This refers to the completed and planned actions taken by this company in re-gards to the incident of January 18, 1984, in which a Health Physics Techni-cian was thought to have exceeded the regulatory limits for quarterly extremity radiation dose. The information herein submitted satisfies the commitments as mutually agreed upon and defined in Confirmatory Action Letter 84-03.
This submittal contains three elements which are:
(1) An item-by-item response to each activity discussed in Confirmatory Action Letter #84-03.
(2) A summary statement regarding the subject issues.
(3) A seven part Expr,sure Evaluation conducted and prepared by our Health Physics Organization.
CAL #84-03 Item No. 1 Prevent access of the individual who may have exceeded the regulatory limits for quarterly extremity radiation dose to radiation areas at Pilgrim until assignment of his personal exposure. Limit subsequent exposure accordingly.
Response
The individual was restricted from radiation areas commencing the afternoon of January 18, 1984. He was inadvertently allowed entry to radiation areas on the morning.of January 20, 1984, due to the misassumption that the ex-
.posure evaluation was completed. The misassumption occurred because the ex-tremity dose estimate figure at that time was one to two rem and, as this was not significant extremity exposure, radiation protection supervision de-termined that the individual could return to work. When this was discovered 8402270271 840215 PDR ADOCK 05000293 G PDR g(,
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sosTON EDISON COMPANY Mr. Richard W. Starostecki Prge on January 20, 1984, the individual was again restricted from radiation areas until the formal exposure evaluation was completed on February 7, 1984. Based on the results of the exposure evaluation and exposure as-signment, subsequent restriction from radiation areas was determined not to be necessary.
CAL Item No. 2 Establish and maintain positive health physics coverage for the work per-formed in the Control Rod Drive (CRD) Repair Room pending completion of the evaluation described in Item 4.
Response
On Thursday, January 19, 1984, the Chief Radiological Engineer ordered the immediate implementation of constant health physics coverage for all entries into the CRD Repair Room. (This did not apply to entries to the "A" RHR Valve Room or the Steam Tunnel which requires an individual traverse, a small section of the CRD Repair Room.) The Sr. Radiological Engineer then instructed the personnel directly responsible for providing health physics coverage on the CRD replacement job of the constant H. P. coverage require-ment. In addition, an entry was made in the CRD Repair Room H. P. Log Book concerning the requirement. Subsequently, all applicable Radiation Work Per-mits were revised to reflect the requirement.
CAL Item No. 3 Evaluate, by January 31, 1984, the actions of all workers who may have en-tered the CRD Repair Room on the 23 ft. elevation of the Reactor Building between January 14 and 10, 1984. Assign resulting personnel exposure by February 15, 1984, and implement personnel exposure restrictions, as neces-sary, to comply with 10 CFR 20. 101.
Response
In order to evaluate the actions of all workers who may have entered the CRD Repair Room between January 14 and January 18, 1984, (inclusive), all RWP
- Sign-in Sheets associated with the CRD Repair ' ,cnn were reviewed and all per-sonnel that may have had access to the subject room were identified.
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Sixty eight persons were identified who may have had access. All but two of these persons were interviewed, and their actions associated with the CRD Repair Room were determined and documented by two senior members of the Radi-ological Group's management staff. The two other persons were not interviewed because they had been laid off. Their actions were reviewed with fellow work-ers that accompanied them during the time identified on the RWP Sign-in Sheet.
From this information it was determined that one of the individuals had not actually been in the CRD Repair Roor. between January 14 and January 18, 1984.
The other individual was entering the "A" RHR Valve Room and at no time entered the area of the CRD Repair Room that is in question.
v
. BOSTON EOlsON COMPANY
-Mr. Richard W.' Starostecki Pzge' 'The. individual known to ' have handled the chip was interviewed immediately after Radiological Group management personnel were notified of the inci-dent. He was also interviewed by Radiological Group management personnel several times throughout the course of the investigation. Four people who were determined.to be those most likely to have handled the chips or know-ledgeable about anybody possibly handling the chips were initially inter-viewed by January 20, 1984. Three of these individuals were interviewed by.'a Senior Health Physics Technician assigned to the CRD replacement pro-ject. He reported the results of this interview to the Sr. ALARA Engineer.
The fourth individual was interviewed by the Sr. ALARA Engineer. Of the sixty-six people, in total who were interviewed, the majority of the inter-
. views occurred on January 25 and 26, 1984. It should be noted that at no time during the entire interview process was there any indication that an individual. handled the chips other than the individual known to.have handl3d the chips on January- 18, 1984.
Of the sixty-six people interviewed, only five people indicated coming in
. physical contact with the bucket with the chips in it. (This does not in-clude the individuals who " created" the bucket during a control drive dis-assembly on January 14, 1984. All of these individuals used long-handled
-tools and wore extremity dosimetry). .Both the extremity and whole body ex-
.posures were evaluated for these individuals. The results of the evalua-tions indicated that one of the five individuals potentially received a
. maximum of 30 mrem.to the hands. The whole body exposure (as indicated by each individual pocket dosimeter and TLD) was determined to be representa-
.tive of the actual exposure received after evaluation of the geometry be-tween the bucket, the various parts of the whole body and the location of the dosimetry on the body, while the bucket was being handled each time.
As a result.of this evaluation, it has been determined that exposure al-ready assigned by the routine TLD and pocket dosimeter monitoring program was accurate.
L The eveluation of the actions of'all workers was completed by January 27, 1984.
~ CAL Item No. 4.
p Evaluate the health physics controls used for the work in the CRD Repair
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Room between January 14 and 18, 1984. Include in this evaluation, as a mini-mum: (a) the adequacy of the information provided to workers relative to the hazards associated'with the radioactive material in the CRD Repair Room; and (b) the adequacy of. the radiation surveys performed, the radiction work per-mit used, sourcc controls, and the personnel dosimetry supplied to the work-ers involved.
Response to Item No. 4 An evaluation of the health physics controls. used for the work in the CRD Repair Room between January 14 and 18, 1984, was performed. There were three primary components to this evaluation. The first component was an in-
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8DSTON EpisDN COMPANY Mr. Richard W. Starostecki Pcge intensive review by the Radiological Group management staff of the controls that were in place. The second component was interviews with the Health Physics personnel directly responsible to implement the health physics cov-erage for work in the CRD Repair Room during this period. The third compon-ent was interviews with the personnel working in the CRD Repair Room during this period. (The interviews referred to are the same interviews referred to in Response No. 3 above. The questionnaire used for the interviews was structured to elicit information concerning the health physics coverage as well as information concerning the chips and the bucket.) Based on the re-sults of the evaluation, it was determined that the health physics coverage was adequate and that one improvement was desirable. This improvement was the requirement for constant health physics coverage for all work in the CRD Repair Room. This improvement was identified very early in the evaluation and was immediately implemented as described in the Response to Item No. 2 above.
Referring specifically to each of the items listed in CAL Item No. 4, the following is submitted:
a) " adequacy of the information provided to workers relative to the hazards associated with the radioactive material in the CRD Re-pair Room" Based on the interviews with workers, those who worked in the vicinity of the bucket were either aware of the high dose rates from the bucket specifically, or of the dose rates in the room and that they were not to be in that area un-less they had to. (Some workers indicated they were not aware of the bucket or the high dose rates in the vicinity of the bucket. These workers, though, were those whose assignment in the room did not require them to go in that part of the room.) When asked if the H. P. Technician signing them in on the RWP knew of the task they were to perform and the areas of the room to be entered, they replied in the affirmative. Therefore, it has been determined that the infor-mation provided to the workers was adequate except for one instance which we identified. This instance involved the entry to the CRD Repair Room on the morn-ing of January 18, 1984. The individuals were not told about the bucket and its associated dose rates. These individuals did move the bucket and remcve some CRD components from it and were not aware of the associated dose rates.
Several problems were identified that contributed to these individuals not know-ing the dose rates associated with the bucket. First, a survey of the CRD Re-pair Room had been performed on the previous shift which indicated the location of the bucket and the dose rates. All copies of the survey (the survey forms are multi-part) erroneously were placed in the " Supervisor's Review" box in the Health Physics office. One copy should have been placed in the RWP folder. In addition, the Health Physics Technician briefing t'_a three workers prior to their entry had not been informed during shift turnover about the bucket. He did re-view the RWP folder, but the survey from the previous shif t was not present.
The Health Physics Technician did not know about the bucket; therefore, could not inform the three workers of its presence. A lack of adequate communications, both written and verbal, was the cause of this inadequacy in the health physics coverage.
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BOSTON. EDISON COMPANY Mr.' Richard W. Starostecki
'Page A memo has been issued by the Chief Radiological Engineer to all Health Phy-sico personnel stressing the requirement fce complete shift turnovers and preper communications between Health Physics personnel.
.b) "the_ adequacy of radiation surveys performed" An evaluation of 'all of the surveys performed in the CRD Repair Room from
' January _14 to January 18, 1984, was performed. All surveys reviewed indi-cate at least the higher does rates in the vicinity of the bucket and most
' surveys specifically indicated the presence of the bucket and its associated
-dose rates. Based on the results of this evaluation, the radiation surveys performed in the room during this period were determined to be adequate.
c) "the radiation werk permit used" An evaluation of the Radiation Work Permit (RWP) used as uell as all RWP's covering work in the CRD Repair Room was performed. Based on this evalua-tion it was determined that the RWP's and the requirements they imposed were adequate and that one improvement should be implemented. This improve-ment is the requirement for constant health physics coverage as described in the Response to Item No. 2 above.
.d) " source control"
- An evaluation of the source controls being implemented in the CRD Repair Room
- was performed. Based on the results of this evaluation, it was determined that the source control was adequate and that improved source control would also be achieved by the required constant health physics coverage as described in the Response to Item No. 2 above. This evaluation did identify one instance
.of inadequate source control during the entry to the CRD Repair Room by three individuals on the' morning of January 18, 1984. The cause for this instance is provided in the response to Section "b" above as it is directly related to the
-inadequate briefing to the workers. The memo referred to in Section "b" and the required constant health physics coverage will prevent the recurrence of this event, e) "the personnel dosimety supplied to the workers involved" An evaluation of the personnel dosimety supplied to the workers involved was performed. This evaluation also included personnel dosimetry supplied to all workers at PNPS.
This evaluation involved the review, in particular, of the use of both ex-tremity dosimetry and the use of whole body dosimetry. Specific extremity monitoring 'at PNPS is normally accomplished by securing a regular TLD to
.the extremity to be monitored. (A self-reading dosimetry is also normally secured to the same area). In particular, when the extremity to be moni-tored is the hand, the TLD is secured to the wrist. If the surface dose rates are such.that a portion of the hand is likely to receive a signifi-cantly higher does than the wrist, long-handled tools are employed so that
'the does rates to all parts of the hand are essentially the same. Similar techniques are utilized when necessary for each of the extremities. Whole
-body monitoring at PNPS is normally accomplished by wearing a TLD badge and
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BOSTON EDISON COMPANY
- Mr. Richard W. Starostecki Page self-reading dosimeter on the front of the trunk of the body, usually the waist or chest area. However, when a specific situation involves a poten-tial for a portion of the whole body to receive a significantly higher dose than that to the area where the badge is normally worn, either the TLD badge and self-reading dosimeter are worn at the area of expected highest dose or TLD badges and dosimeters are worn at more than one area of the whole body and the individual's dose is assigned after analysis of all of the TLD badge results.
Based on the results of this evaluation, it was determined that personnel
. dosimetry supplied to workers in the specific incident being discussed and to all radiation workers at PNPS is adequate and reflects the state of the art of personnel dosimetry.
Summary The results of the investigation performed subsequent to this incident in-dicated that (1) there was an error in judgement in which a trained and qualified individual improperly handled highly radioactive material (2) there were several breakdowns in communication including a sole reliance on log books to transmit data which more appropriately should have also been reflected in the appropriate RWP's and (3) there is the need to reemphasize, to all Health Physics personnel, the unique radiological hazards associated with physically small, high dose rate sources due to the inaccuracies as-sociated with " contact" dose rates as measured by conventional survey in-struments.
One potential problem resulted from inadequate communications between health physics personnel; however, adequate communications would not have prevented
.this incident. The communications problem has since been corrected. The in-dividual in an interview following the occurrence, was questioned as to what he would have prescribed if someone had wanted to remove an unknown source from a bucket and he properly stated the requirements which he would impose.
This incident is analogous to an experienced electrician touching an energized wire because he neglected to check it properly first, or an experienced car-penter cutting c2f a thumb or finger while operating a saw, or an experienced mechanic losing a finger or hand because he put them into operating equipment.
'In.these cases, the people are adequately trained and experienced personnel but still, for' inexplicably intangible reasons, they neglect or forget their training and exper. fence and make a serious judgemental error which may-lead to actual bodily injury. In all examples, which have occurred many times, in-dividuals failed.to take a known precautionary step they have taken many times previously. Finding a solution to totally prevent these types of situations
.ougr not be possible.
We trust this submittal will meet with your approval and we are prepared to meet and further discuss this incident, our subsequent restorative actions or any'other aspect involved to facilitate your review.
Respectfully submitted, W. D. Harrington Attachment (s)
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- EXPOSURE EVALUATION OF INCIDENT OF JANUARY 18, 1984 i
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, I. Overview of Incident i.
II. Quantification of Sources -
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III. Geometry of Event IV. Time of Exposure
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I V. Relevant-Information from Personnel Interview
-t VI. Estimate of Exposure - Gamma .
VII. Estimate of Exposure - Beta S
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I I. OVERVIEW OF INCIDENT i
. On January 18, 1984 a Health Physics Technician identified a white i plastic bucket in the CRD Repair Room with a notably high dose rate on a contact with the outside of the bucket. The rerorted measured contact I
g dose rate on the surface of the bucket was 10E/hr.
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{ In an attempt to reduce exposures to personnel working in the room C T
i the HP Tech decided to identify, segregate and transfer the source (s) of i these radiation levels to a lead pig.
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t The technician removed the suspected sources of radiation, several small metal chips, from the bucket by hand, surveyed each, and placed e
them in the lead pig. During this transfer dose rates well in excess of i the original measurement of 10R/hr were observed when individual metal t
j chips were held essentially in contact with the survey instrument.
f Due to the fact that dose rates appeared to increase greatly as the
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i distance from the source to survey instrument decreased it appeared that ,
true contact dose rates to the individual's fingers might be greatly in excess of the survey instrument reading. Therefcre an investigation was
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.; instituted to determine the true contact dose rates, exposure times and J
resulting extremity exposure.
The results of this investigation indicate with certainty the individual in question received no more than 4.56 Rem gamma dose and negligible beta exposure resulting from contact with the sources identified as having been handled. Indeed, all the sources presen" in the lead pig if handled simul-taneously, could not have resulted in a gamma exposure greater than 10.41 Rem.
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The appropriate extremity exposure to assign for this incident is
! 4.56 Rem gamma with negligible beta contribution due to the thickness of the gloves worn during the incident.
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[ II. QUANTIFICATION OF SOURCES I In an effort to accurately determine the contact dose rates several 7 tests were performed. First the radioactive chips were retrieved from the. lead pig and individually placed in true contact with a TLD chip, i
The time of exposure was carefully measured and the location of the mutual r.
chip relative to the TLD chip was carefully maintained. The source chip and receptor chip were truly in contact except that two intervening layers of plastic and one layer of cotton were used to simulate the technician's gloves.
Each source chip was exposed to three different TLD chips for known time
. periods (except for chip #7 which was exposed only twice). Exposure times were all greater than 5 minutes _thereby minimizing errors in time measurement.
Each.TLD was read out in a conventional manner.
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The raw results of these measurements are contained on attachment A and the corrected (background subtracted) and averaged results are contained on
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attachment B.
In addition, to assess any beta dose contribution and to verify the energy of the gamma radiation a Ge-Li an'alysis of a fraction of one of the source chips was also performed. The results are presented on attachment C. These results confirm the assumption that Co-60 comprises essentially all of the
l e activity contributing to tha cxposurs. Tha rssults cleo c;rva to identify the maximum beta energy present as 0.314 Mev. which has a smaller range than required to penetrate the 95 mg/cm2 thickness of the gloves and dead skin layer (see attachment D).
Although the HP Technician remembered handling only 3 to 5 separate chips during three different transfer movements, 8 chips were found in the shielded container. 'Ib ensure a thorough evaluation, dose rate measurements were made ,
on all 8 chips (the two smallest chips were taken together as one).
I III. GEOMETRY OF EXPOSURE t
This exposure event was unusual in that the sources of radiation were of unusually small dimensions as shown in attachment E. These dimensions are small when compared with the size of the probe or sensitive volume of conven-tional survey instruments.
As a result, dose rates considered to be " contact" as measured by a survey instrument, underestimated the true contact dose rate by a factor of from 20 to 55 with 55 being the case for the smallest source chip (see attachment F).
To obtain accurate contact dose rate measurements a detection device with dimensions comparable to the source and with no intervening casing or housing I
was placed in true contact with the source chip. This device was a personnel dosimeter chip, 1/8" x 1/8" X .035". This arrangement closely approximated the true source-receptor geometry during the exposure period. Two layers of rubber and one of cotton representing the protective clothing worn by the individual were the only material intervening between the source and receptor. Continuous pressure was applied during the measurement to ensure source-receptor contact.
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IV. TIME OF EXPOSURE r Due to the unusually high dose rates an accurate estimate of the exposure I time was vital in assessing dose. The individual who actually handled the radioactive chins participated in a time-motion study performed under accu-
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rately simulated and controlled conditions. The individual wore a respirator and 3 pairs of gloves during this study and recreated the physical arrange-f.
. ment of pertinent objects (source bucket, extender survey instrument and lead c pig) as accurately as possible. The individual repeated his physical motions l
during the period in question ten times during this simulation. Each series
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of motions involved the movement of three simulated source chips from the source bucket, to the survey instrument and into the lead pig. The results of this time-motion study are presented in attachment G. The average total time of contact exposure to the source chips was 8.02 seconds.
k' V. RELEVANT INFORMATION FROM PERSONNEL INTERVIEW The Health Physics technician involved in the exposure was interviewed on several occasions. He was able to identify from pictures with considerable confidence, those chips he had handled on the day of the incident. He iden-
-tified the chip moved on the first motion as either chip #3 or #7 (both chips have similar shapes), on the second motion as either chip #2 or #4 (also similar in shape) and on the third motion,as chip #5 (actually two small chips).
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He was also quite sure of the physical locations of the source bucket, survey instrument and lead pig since he had pre-planned the activity to limit exposure.
He was also confident about the path and duration of his motions.
Although he had originally reported dose rates as high as 300r/hr on a chip (s) as measured by his survey instrument, he admitted that he had not allowed the meter to stabilize at any specific reading but that he had ob-
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/ served the meter needlo "hesding tcwird 300R", at which time ha threw the source chip (s) into the lead pig.
The technician stated that he had no reason to believe that the lead pig was empty when he started putting chips into it. Therefore some chips must have been present in the pig from some prior activities.
. VI . -ESTIMATE OF EXPOSURE - GAMMA q The final exposure estimate considers the highest credible contact dose rates, the time of contact exposure and number of chips moved. Since the technician was able to identify the chip moved on the first motion as pos-sibly being either of two chips, the chip with the highest dose rate was considered. The same situation occurred for the second motion. The chips i moved on the third motion were positively identified as the two smallest
- of the group.
i Gamma contact dose rates on each chip moved (the last two small chips are considered as one) were multiplied by the time of contact (less than 3 seconds on each move) and added, to obtain the total contact exposure as follows:
0.505R/sec X 3 sec. = 1.52 R 0.783R/sec X 3 sec. = 2.35 R 0.230R/sec X 3 sec. = 0.69 R (
TOTAL = 4.56 R Indeed, even if the individual involved had handled all of the pieces found .a the lead pig (which is unlikely if not incredible) he would have received no more than 10.41 Rem to the extremity from Ganma radiation.
VII. ESTIMATE OF EXPOSURE - BETA
- The thickness of the rubber and cotton gloves together (.88 mg/cm 2) along with the thickness of the dead skin layer (7 mg/cm2 ) limited beta exposure to insignificant values.
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ATTACHMENT A RAW EXPOSURE DATA MREM Hot Chip # Time-On Time-Off TLD # Net Time i
171880 1 10:50 10:56 218651 5'-01" I 146730 1 10:57 11:02 218503 5'-01" 135510 1 11:03 11:08 217248 5'-01" 240350 2 11:09 11:14 218690 5'-01" 237040 2 11:14 11:20 102689 5'-02" 230770 2 11:21 11:25 218866 5'-01" <
151330 3 11:26 11:31 027799 5'-13" 157900 3 11:32 11:37 028015 5'-01" 152760 3 11:37 11:42 099349 5'-00" 204800 4 11:42 11:47 218581 5'-01" 205290 4 11:47 11:52 114145 5'-01" 200350 4 11:53- 11:58 099398 5'-01" 5 11:59 12:04 218260 5'-02" Nota (1) 76060 64573 5 12:04 12:09 217144 5'-01" 67350 5 12:10 12:15 114428 5'-00" 121690 6 12:15 12:20 103317 5'-01" 122080 6 12:20 12:25 102979 5'-01" 120950 6 12:26 12:31 026693 5'-01" 118020 7 12:32 12:37 113670 5'-01" 103190 7 12:38 12:43 217744 5'-01" (1) Two slivers considered as 1 chip.
(2) . Control TLD #114262 read 30 mrem. ,
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, ATTACHMENT B
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. CORRECTED EXPOSURE DATA 4
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Chip # TLD # l'et Dose ' Net Time Dnse Rate
, (Rem) (Sec) (Rem /Sec) i
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l 1 218651 171.850 301 0,571
. 1 218503 146.700 301 0.487 1 217248 135.480 301 0.450
'I Average 0.503 Rem /sec c (1911 Rem /hr) f-l 1
2 218690 240.320 301 0.798 1 2 102689 237.010 302 0.785 l t 230.740 301 0,767 2 218866 Average .783 Rem /sec (2819 Rem /hr)
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3 027799 151.300 313 0.483 9 3 028015 157.870 301 0.524 9 3' 099349 152.730 300 0.509 Average 0.483 Rem /sec (1818 Rem /hr)
't i
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-4 218581 204.770 301 0.680 4~ 114145 205.260 301 0.682
- i. 4 099398 200.320 301 0.666 i
i Average 0.676 Rem /sec (2434 Rem /hr) (
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5 5 218260 76.030 302 0.252 5 217144 64.543 301 0.214
.s 5 114428 67.320 300 0.224 l~
Average 0.230 Rem /sec (828 Rem /hr)
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- ATTACIDENT 2
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. CORRECTED EXPOSURE DATA - Page 2
--Chip #' TLD # Net Dose Nat Time Dose Rate
- _ (Rem) (Sec) (Rem /Sec) 4 6 103317 121.660 301 0.4 04
'6 102979 122.050 301 0.405
.' 0.402
> 6 026693 120.920 301 Average 0.404 Rem /sec l C h (1454 Rem /hr) i i
.i- 7 113670 118.000 301 0.392
- 7- 217744 103.160 301 0.343 I t i
4 Average 0.368 Rem /sec (1325 Rem /hr)
TCffAL OF AVERAGE VALUES OF REM /SEC = 3.4,69 Rem /sec i
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3"
. , - ; DECAY TIME (MIN): 1 ATTACHMENT C CALIB CURVE 4.. 8 3
,q' l DILUTION FACTOR.! 1 5
Go-Li Analysis of a Chip ~)
DEAD TIME (%)...!
(p (+-KEV =1.5, 4SIG=1.5, 4SM00THS=1) r)
~:
SAMPLE DESCRIPTION..: CRD SLIVER !
() CCSRP,.0PERATOR......! MITCHELL () i DATE 1 HOUR SAMPLED.:
DATE 1 HOUR ANALYZED: 1-26-84,1418 j COUNT (YES/NG) ?Y SET I/O DEVICE TO REMOTE, PRESET TIME TO O O
() COLLECT TIME (SEC) ? 1000 c)
. NOW COUNTING e c COUNT DONE 6 7 GAMMA SPECTR0 GRAPHIC ANALYSIS q,
' (g -
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ENERGY (KEV) ISOTOPES g[ CHANNEL NET AREA (CDUNTS) g) i (g 1055,17 321. 488.19 e) 1445.53 399. 667.21 I-132 1662.66 368. 766.76 NB-95
() . 1714.51 375. 790.52 NB-98,KR-88,MN-54
()
1809.65 3767. 834.14 !
1876.19 411. 864.64 CO-58 ;
gg 2165.33 412. 997.14 ()
2548.06 72521. 1172.48 CO-60 2895.64 62839. 1331.67 CD-60 3498.83 57. 1607.80 g) '
(3 3821.87 65. 1755.62 LA-142 C2 C) i RADIONUCLIDE ANALYSIS COLLECT TIME (SEC)..! 1000 ()
(3 ISOTOPE ACTIVITY +- - 2 SIG
-MP- 5 1.52737C ^2 'JC/SAMPL +- 1.17702E-03 ( 77 04 %) 3 MN-54 3, "7 1.69374E-02 UC/SAMPL 1- 1.48626E-03 ( 8.77 %)
gg CO-60 yg, 4.44102E-01 UC/SAMPL +- ~ 3.49146E-03 ( 0.79 %)
()
3....
DIFFERENCE g) ISOTOPF THEORETICAL MEASURED ()
NB-95 765.79 766.76 0.97 gj MN-54 834.83 834.14 -0.69 (j CO-60 1332.49 1331.67 -0.82 i STANDARD DEVIATION = 0.83
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. ATTACHMENT D ANALYSIS OF THICKNESS OF PROTECTIVE GLOVES t-4 Rubber Swatch (16 in2 . 103.23 cm2 ).
4003.60 mg = 38.78 mg/cm2 2
it 103.23 cm
'l C
I Cotton Swatch (13.75 in2 - 88.71 cm2 )
1: 888.60 mg = 10.02 mg/cm2
, j' 88.71 cm2 Y
t 7 mg/c.m 2
~
Thickness of Dead Skin Layer =
V
-I Net' thickness of protective layer = 38.78 X 2 + 10.02 + 7 = 94.58 mg/cm 2
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ATTACHMENT E i
- APPROXIMATE AREAS AND VOLUMES OF CHIPS L6 .
' Chip # Iangth Width Thickness Area volume i
3 1 1 3/8 3/8 1/16" 1.125 in2 .0322 in
. 2 3/4 1/2 1/16 0.875 .0234 C
3' 1 7/8 1/4 1/16 1.000 .0293 4 1 3/8 1/16 0.844 .0234 5* 3/8 3/8 1/1ti 0.375 .0088
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- 6 1 3/8 1/4 1/16 0.750 .0215 7 1 3/8 1/4 1/16 0.750 .0215
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ATTACHMENT F
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- MEASURED GAMMA DOSE RATES 4
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- 1 _2 3 4 e
Contact Dose Contact Dose i
. Rate with Rate with TLD Ratio Extender - R/hr R/hr Chip # 3/2 l t <
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l -1 90 1811 20.1 t
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, 2 110 2819 25.6
-F. l 3 ~75 1818 24.2 i
,I 4 100 2434 24.3 I 5* 15 828 55.2 Smallest Chip l
, 6 70 1454 20.8 7 50 1325 26.5 r
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- Actually the two smallest chips taken together.
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' ATTACHMENT G
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RESULTS OF TIME-MOTION STUDY 2 pairs of Rubber Gloves January 25, 1984: 3:15 - 3:45 approx.
1 1 pair of Cotton Gloves Face Mask Net Sec. for
-Run # 3 Kaves
[
, 1 7.77 2 7.37 3 8.33 4 8.05
. ,i 5 7.69 l- 6 8.08 7 8.46 Jk- 8 7.97 9
'l. 9 8.33 ,
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! 10 8.17
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t-x = 8.022'sec. S = .355 sec.
t i Min = 7.37 Max = 8.46 ol,.
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