ML20090F027

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Responds to NRC Followup Item 50-293/91-28-01.Contests Violation That Category F Technician Not Donning Protective Clothing for Contamination Control.Instructions of Radiation Protection Coordinator Followed
ML20090F027
Person / Time
Site: Pilgrim
Issue date: 03/03/1992
From: Richard Anderson
BOSTON EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
92-024, 92-24, NUDOCS 9203100205
Download: ML20090F027 (4)


Text

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f BOSTON EDISON Pdgnm Nuclea Dower Stabon Rocky WI Road Plyrnouth. Massachusetts 02360 Roy A. Anderson 1992 March 3'r. 92-on Senior Vice Premdent - Nir,' ear BECo Lt U.S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, D.C.

20555 Docket No. 50-293 Lic1rn No. DPR_35 SLbject: REPLY TO IMSPECTOR FOLLOH ITEM 50-293/91-28-01 (REFEREMCE NRC REGION I INSPECTION REPORT NO. 50-293/91-28)

Enclosed is Boston Edison Company's reply to the Inspector Follow Itein contained in the subject inspection report.

Please do not hesitate to contact me if there are any questions regarding the enclosed reply.

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.,A. Anderson RLC/bal

Enclosure:

Reply to Inspector Follow Item 50-293/91-28-01 cc:

Mr. Thomas T. Martin Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Rd.

King of Prussia, PA 19406 Mr. James H. Joyner, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards, Region I U.S. Nuclear Regulatory Commission 475 Alleriaale Road King of Prussia, PA 19406 g31%$$ b 3

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BE o Lt. 92-J24 CC:

Mr. R. B. Eaton Civision of Reactor Projects I/II Office of NRR - USNRC One White Flint North - Hall Stop 14DI 11555 RocKville Pike Rockville, MD 20852 Sr. NRC Resident Inspector - Pilgelm Station Standard BECo Olstribution B

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BECo letter No. 92- 024 -

MCLOSURE RELY TO INSPECTOR FOLLOH ITEM 50-293/91-28-01 Boston Edison Company Docket No. 50 293 Pilgrim Nuclear Power Station License No. DPR-35 1 MSEC 10R FOLLOH-ITEM (IFI) 50-293/91-28-01 "The NRC team identified the following concern associated with OSC performance:

The health physics member of the team assigned to perform high pressure coolant injection pump repairs, on his own initiative, did not follow instructions from OSC management or prescribed by the radiation work permit regarding donning of protective clothing for contamination control.

This was found to be an isolated occurrence which, in an actual emergency of the type simulated, could have resulted in contamination of the individual but would not have precluded effective emergency plan implementation in this area (IFI 50-293/91-28-01)."

REPLY TO IFI 50-293/91-28-01 Our review and evaluation of the circumstances associated with this Follow Item determined the Health Physics Technician was following guidance issued by radiological supervision and allowed by procedure at the time the team was dispatched in the plant. Our tvaluation also determined that without access to all particip:.nt discussions held in the OSC as well as controller documentation generated in support of the in-plant team, an exercise observer / evaluator could easily perceive the events as statad in IFI 50-293/91-28-01.

This conclusion was arrived at after a thorough review of all controller / participant documentat'an as well as interviews with involved participants and controllers.

The results of our evaluation include:

The Onsite Radiological Supervisor determined that radiological conditions in the plant did not warrant separate use of the Radiological Re-Entry Briefing Sheet meaning radiological controls for job coverage in the plant would be conducted in a normal routine RWP manner.

This is procedurally allowed in EP-IP-510 "Re-Entry", under the Responsibilities of the Onsite Radiological Supervisor.

This decision was also documented on the controller checklist.~or the team in question.

Copies of these_ documents are available at Pilgrim Station.

i Discussions with both the Radiation Protection Coordinator in the OSC and the Onsite Radiological Supervisor in the TSC indicated the Health Physics fechnician was _ directed to provide normal job coverage for this in-plant i

team.

Specifically, the non-health physics team members were directed to don precautionary protective clothing while the Health Physics Technician was directed to monito_r their act',vities in a non-contaminated area.

The technician had received his instructions prior to the briefing of the maintenance workers, which could have contributed to the perception that he was ignoring the protective clothing instructions being issued to the team.

l

t BECo Ltr. No. 92- 024 EELDSURE REPLY IQ_ INSPECTION FOLLOH ITEM 50-293/91-28-01-(CONTINUEQ1 Due to an actual local area hot spot in the vicinity of the HPCI skid, the i

maintenance team was forced to simulate in an area other than that where the maintenance activities would have actually occurred.

This made it 5

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difficult to show how proper radiological controls would have been conducted in order to perform the assigned task.

This may have led to additional confusion.

Based upon the information presented above, we feel the technician did not ignore direction to don protective clothing but was instead following his instructions-as determined and directed by the Radiation Protection l

Coordinator in the OSC.

To aid in precluding such occurrences.in the future, the circumstances associated with this occurrence will be discussed in future training session for exercise participants.

The training will stress tr.e importance of thoroughly communicating player / participant actions to ensure these actions are correctly perceived by observers and evaluators.

Boston Edison Company will continue to trovide strong management support and oversight of the Emergency Preparedness area to (nsure continued improvement.

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