ML20086E698
| ML20086E698 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/27/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91446, NUDOCS 9112020266 | |
| Download: ML20086E698 (3) | |
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Log # TXX-91446 E
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File # 10130 TUELECTRIC November 27, 1991 William J. Cahllt, Jr.
Gnwp Ykt President U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 S'JBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LOGKEEPING OF INDUSTRIAL VACUUM CLEANERS Ref:
- 2) TV Electric letter from W. J. Cahill Jr. to the NRC logged TXX-91265 dated July 25, 1991.
- 3) NRC Inspection Report 50-445/91-48 from Bill Beach to W. J. Cahill Jr. dated October 28, 1991.
Gentlemen:
Reference 1 and 2 provided TU Electric's response to two separate notices of violation, and described the corrective actions for the violations.
Reference 3 provided the NRC's request for additional information regarding TV Electric's assessment of the industrial vacuum cleaner log keeping discrepancies relative to the previous corrective actions stated in reference 1 and reference 2.
The first went involved a number of contractor personnel who did not perfon roving fire watches for assigned areas even though the personnel had made entries in the logs which indicated the watches had been completed.
The next event occurred when TV Electric's-fire protection technicians failed to document the results of routine inspections which was caused by a lack of attention to detail on part of those performing the inspections.
- However, TU Electric's review indicated these inspections were generall; being performed in comp' W e with the procedures.
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l TXX-91446 Page 2 of 3 4
Our review concluded that the previous events occurred due to failure to follow procedures:
1)
Roving fire watch personnel did not perform the watches as required by the procedures, but documented the activities as if the activities were performed.
2)
Fire protection technicians physically inspected the fire doors, but failed to document the results of the inspection as required by the procedure.
For the reasons stated above, TU Electric conducted thorough evaluations of the causes for procedural non-compliances and took extensive corrective and preventive actions.
With rejard to the request for additional information stated in reference 3, Radiatinn Protection Instruction (RPI)-417. "Use of Vacuum Cleaners in Radiologically Controlled Areas" was issued July 3, 1990.
The intent of RPI-417 was to control the use of vacuum cleaners used for " contaminated work activities" and established the requirements to verify dose rates upon issuance and return, storage in a secured location, and the requirement that vacuum cleaners te maintained under the contrni of Radiation Protection (RP) when not in use.
When construction activities resumed on Unit 2, there was significant increase in the use of vacuum cleaners within the Radiologically Controlled Area (RCA),
altnough not for contaminated work activities.
Since RP had control of the use of vacuum cleaners in the RCA, the responsibility to control all vacuum cleaners, regardless of their use (i.e., contaminated work or non-contaminated work) was assigned tu them.
In an effort to account far all industrial vacuum cleaners, RP loosely applied the controls established for radiological (contaminated) use vacuum cleaners and RPI-417 was revised (Rev/l May 17,1991) to clarify the requirements associated with industrial use (i.e., non-contaminated) and radiological use (i.e., contamir,ated) vacuum cleaners.
However, as a result of an oversight, no changes were made to form RPI-417-1.
The use of the form (log) was considered a convenience with respect to its application for industrial vacuum cleaners.
Upon completion the log was simply discarded.
This misapplication of RPI-417 to industrial use vacuum cleaners led to several inconsistencies in the log entries.
A ONE Form was issued to document the inconsistencies.
TXX-91446 Page 3 of 3 Even though the form was non-quality related and considere-m aid only, RP requested ISEG perform an investigation to evaluate the ap;.tront log irregularities.
It was discovered a Radiation Protection aanician did post-date log entries under the "date returned" column.
The intent was to make subsequent daily inventory checks easier to complete.
This form was used merely to make_ inventory record keeping more convenient for RP and did not serve any other purpose. -This issue was discussed with the technician involved and GP personnel were informed this was not an accepted practice, even for non-QA/non-procedural type forms.
As a result of this ONE Form, Revision 2 of RPI-417 was issued on October 2, 1991.
This revision clearly st.ates that inventory and accountabilit.v requirements only apply to radiological use vacuum cleaners.
Industrial use vacuum cleaners have been turned over to the tool rooms for control and issue and Radiation Protection is no longer involved in controlling industrial use Vacuum Cleaners.
In addition Form RP!-417-1 was revised with the words "for use with contaminated use va uum cleaners only" added under the title of the form.
TU Electric's review concluded the issue regarding the industrial vacuum cleaner log keeping discrepancies was caused by the ambiguous instructions provided by procedure RPI-417 and not by a failure to follow procedures as was the cause for the previous events.
However, these issues are related in that they all involve the completeness and accuracy of recnrdkeeping.
Nevertheless, TU Electric shares the NRC concern with recordkeeping.
Previously, TU Electric issued a memorandum regarding the accurate documentation of records. This memorandum may not have reached all employee levels.
To emphasize TU Electric's concerns and expectations and to reach the proper personnel, a followup instructional memorandum will be issued to a'I employee levels at CPSES Unit I regarding accurate record keeping.
Sincerely, William J. Ca ill, Jr.
OB/tg c-Mr. R. D. Martin, Region IV Mr. T. A. Bergman, NRR Mr. L. A. Yandell, Region IV Resident Inspectors, CPSES (2)
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