ML20100L638

Submits Response to Violations Noted in Insp Repts 50-445/95-29 & 50-446/95-29.Corrective Actions:Instruction RPI-206, Liquid Process Filter Control, Changed to Require Start of Job Survey for Filters Removed

ML20100L638
Person / Time
Site:	Comanche Peak
Issue date:	02/29/1996
From:	Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-96064, NUDOCS 9603040362
Download: ML20100L638 (5)

Text

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t Log # TXX-96064 ,

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File # 10130  ;

. C 1R 95-29

::: Ref.-# 10CFR2.201 i

1UELECTRIC February 29. 1996 c.ta == T ury Group VVs President 1

I U. S. Nuclear Regulatory Commission Attn: Document Control Desk

. Washington, D.C. 20555 i

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NOS. 50-445/95-29: 50-446/95-29

j. RESPONSE TO NOTICE OF VIOLATION Gentlemen:

TV Electric has reviewed the NRC Inspection Report and attached Notice of

Violation dated February 8, 1996, concerning the inspection conducted by Resident Inspectors Messrs. A.T. Gody..Jr., H.F. Freeman, and Ms. V.L.

Ordaz-Purkey during the period of November 26 through January 6. 1996.

l The Notice of Violation describes a failure to follow procedures which resulted in failure to perform necessary radiological surveys to ensure adequate knowledge of radiological conditions prior to job performance and subsequ.ential radiological exposure to three workers. Our response is attached.

040101 9603040362 960229 PDR ADOCK 05000445:

G PDR P.O. Box 1002 Glen Rose. Texas 76043 J

TXX-96064 Page 2 of 2 Please do not hesitate to contact Neil Harris at (817) 897-5449 to coordinate any additional information you may need to facilitate closure of this issue.

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crfly, C. L. Ter NSH:nsh Attachment cc: Mr. L. J. Callan, Region IV l Mr. W. D. Johnson. Region IV Resident inspectors l

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! Attachment 1 to TXX-96064 Page 1 of 3 ,

. RESTATEMENT OF THE NOTICE OF VIOLATION (50 445/95 29: 50 446/95 29) i During an NRC inspection conducted on November 26 through January 6. 1996, 4

one violation of NRC requirements was identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions."

(60 FR 34381: June 30, 1995), the violation is restated below: ,

i CPSES Technical Specification 6.11.1 states that procedures for personnel adiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

Procedure RPI-602. " Radiological Surveillance and Posting." Section 6.1.2.

1 states that nonroutine surveys be performed as required to ensure adecuate

knowledge of radiological conditions prior to, during, and/or after ary evolution involving exposure or potential exposure to radiological harards.

i Radiation Work Permit 95000500. " Waste Processing" item 4. issued on June 6, 1995. states that "RP (Radiation Protection) technicians providing coverage shall perform and document necessary surveys in accordance with Procedure RPI-602."

- Contrary to the above, on December 11. 1995, the licensee found that radiation protection technicians failed to perform necessary surveys to ensure adequate knowledge of radiological conditions of Spent Resin Sluice Filter 01 prior to and during filter removal and consequently replaced the

, filter without using a shielded transfer assembly as required by the radiological conditions and procedures.

REPLY TO NOTICE OF VIOLATION (50 445/95 29: 50 446/95 29)

TU Electric accepts the violation. While the actual radiation exposures received during this incident were minimal, they were unanticipated. The radiological coverage for this evolution was not in accordance with TU Electric's expectations and the failure to survey is considered a serious event. A Plant Incident Report (PIR). including a Human Performance Evaluation (HPES) has been performed and corrective actions initiated to preclude a reoccurrence of this type of event. The information requested is provided as follows:

1. Reason for the Violation Backaround:

On December 11. a radiation protection technician surveyed the incorrect i discharge filter which ultimately led to the removal of a more radioactively contaminated discharge filter without using a shielded transfer system. In addition, another radiation protection technician did  !

not perform surveys during filter removal.

Attachment 1 to TXX-96064 Page 2 of 2 Prior to the filter change-out activity, the TU Electric did not survey the correct filter " Spent Resin Sluice Filter X-01" (Tag Number TBX-SPFLRS-01),

The on-shift Lead Radiation Protection (RP) technician instructed a field .

RP technician (Technician A) to survey the spent resin sluice filter. '

Technician RP-A thought the~ lead technician said " spent resin sluice pump filter" rather than " spent resin sluice filter." Technician A incorrectly surveyed the " steam generator blowdown spent resin sluice pump filter Ol'.

Technician A measured the dose rate on the incorrect filter and reported to >

the Lead RP technician that the dose rate on the " steam generator spent resin sluice pump filter" was less than 0.1 millirem per hour. The use of noun names to identify equipment instead of tag numbers resulted in a preliminary survey of the wrong component.

Technician A was not cualified to cover the filter change out and the Lead RP technician assignec another field RP technician (Technician B) to support the filter change out. Since the incorrect filter was initially surveyed and the assumed dose rate would be negligible. Technician B ,

assisted in the filter change out by tolding the plastic bag into which the mechanics would place the filter, rather than providing direct radiological protection coverage prior to and/or during the filter removal.

During the filter change-out, all electronic dosimeters began to alarm (set at 50 mR/hr). The RP Technician had received 8 mR. Mechanic A had received 1 mR and Mechanic B had received 4 mR. The total measured exposure to personnel associated with the unsurveyed filter change out was 21 mR with a maximum exposure to a single individual of 12 mR. The electronic dosimeters alerted the workers to the actual radiological conditions and assisted the RP technician in appropriately directing the activities which minimized the dose tn all personnel involved.

Conclusion:

Based on the above assessments, the following synopsis of causes are given.

(a) The use of filter noun names which are similar in sound and designation, contributed to the incorrect filter being surveyed and subsequent personnel exposure. (b) Technician B relied on information passed verbally and did not perform a start of job survey. (c) RPI-110-3 form, " Radiation Protecticn Job Assignment Sheet", used to facilitate ,

communication of instructions regarding work on components that require (

specific identification, was not used for either the preliminary survey or the filter removal. (d) The Radiation Protection Lead Technician was performing routine activities normally assigned to subordinates and failed to prioritize his work activities to account for tasks with potentially higher radiological consequences, i

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Attachment I to TXX-960P Page 3 of 3

2, Corrective Steos Taken and Results Achieved I

! (a) Instruction RPI-206, " Liquid Process Filter Control", has been changed to require a start of job survey for all filters removed. (b) instructions have been issued to appropriate personnel reemphasizing the use of the RPI-110-3 form, " Radiation Protection Job Assignment Sheet" Due to these corrective actions, start of job surveys are being taken and documented and surveys are performed on the correct components.

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3. Corrective Steos Taken to Avoid Further Violation i A lessons learned on this event will be provided to appropriate personnel regarding:

.; (a) the appropriate use of tag numbers and/or noun names to identi.'y

components,

(b) reemphasize management's expectation to stop and assess the i situation prior to continuing when the situation encountered is different from what was expected, (c) assure Radiation Protection personnel understand the potential results of failing to identify the radiological conditions to be i encountered prior to commencing a work activity, and (d) to reemphasize management's expectation that radiolog1 cal conditions will be assessed prior to commencing work.

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4. Date of Full Como11ance TU Electric will complete all corrective actions by May 15, 1996.

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