ML20116A594
| ML20116A594 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/19/1996 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-96419, NUDOCS 9607260187 | |
| Download: ML20116A594 (5) | |
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.S Log # TXX-96419 File # 10130
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2 IR 96-06
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2 Ref. # 10CFR2.201 filELECTRIC July 19. 1996
- c. % Twy Groep Vice President U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington. D.C.
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SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NOS. 50-445/96-06: 50-446/96-06 RESPONSE TO NOTICE OF VIOLATION l
5 Gentlemen:
TU Electric has reviewed the NRC Inspection Report and attached Notice of Violation dated June 20, 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 March 31 through May 11, 1996.
The Notice of Violation describes a failure to follow radiation work permit requirements used to ensure adequate radiological safety of personnel performing work activities.
There were three examples noted within the Notice of Violation.
TV Electric's response is attached.
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TXX-96419 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.
Sincerely.
W2 fun:~g C. L. Terry i
NSH:nsh Attachment i
cc:
Mr. L. J. Callan. Region IV Resident Inspectors t
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Attachinent 1 to TXX-96419 5
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RESTATEMENT OF THE NOTICE OF VIOLATION (50 445/96 05: 50 446/96 06)
During an NRC inspection conducted on March 31 through May 11, 1996, one violation of NRC requirements was identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
(NUREG-1600), the violation is restated below:
CPSES Technical Specification 6.11.1 states that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all l
operations involving personnel radiation exposure.
Procedure STA-656, " Radiological Work Control". Revision 7, dated October i
18, 1995 Section 5.4, states in part that radiation workers were responsible for following the appropriate radiation work permit.
l The removal, repair and replacement of Reactor Coolant Pump Motor 2-01 was an operation that involved personnel radiation exposure-and Radiation Work l
Permit (RWP) 96002401 was the appropriate permit for the operation.
l RWP 96002401, Special Instruction 12 and 13 states : "12) CONTACT RP FOR i
TRANSPORT REQUIREMENTS PRIOR TO REMOVAL OF EQUIPMENT / MATERIAL FROM A CONTAMINATED AREA.
- 13) PROTECTIVE CLOTHING LISTED IS THE MINIMUM REQUIRED TO ENTER A POSTED CONTAMI%ATED AREA, UNLESS OTHERWISE APPROVED BY THE LEAD TRP] TECHNICIAN." Further. the radiation work permit listed rubber gloves 1
dnd 8. Cloth hood in the minimum protective clothing required section.
Contrary to the above, the following three examples of failure to follow the noted RWP were identified during the removal and replacement of Reactor Coolant Pump Motor 2-01.
1.
On April 24, 1996, crane operators did not contact radiological protection prior to removing equipment from a posted contaminated area, as required by Special Instruction 12 of the RWP.
2.
On April 29, 1996, a maintenance worker was in a contaminated area without the minimum required protective clothing in that rubber gloves were not being worn, without lead technician [RP] approval as required by Special Instruction 13 of the RWP.
3 On April 29, 1996, maintenance workers were in a contaminated area without the minimum required protective clothing in that cloth hoods were not being worn properly, without lead technician [RP] approval as required by Special Instruction 13 of the RWP.
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Attach'ent 1 to TXX-96419 m
Page 2 of 3
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' REPLY TO NOTICE OF VIOLAT10H (50-445/96 06; 50 446/96 06)
L TV Electric accepts the violation. The cited actions did not result in any l
uncontrolled or undetected spread of contamination nor did the actions result in personnel contamination.
However, the violation is correct in i
that on the 3 occasions, personnel did not comply with the approved i
radiation work permit.
The adherence to radiological protective c
requirements for these evolutions were not in accordance with TU Electric's expectations and the failure to follow procedures is considered a unacceptable practice.
The information requested is provided as follows:
'1.
Reason for the Violation During.the CPSYS Unit 2 second refueling outage (2RF02), work was being performed on a failed reactor coolant pump motor.
Throughout the outage, the majority of the containment building was not a posted contamination area.
In fact, portions of some posted contamination l
areas were less than the levels normally required for posting.
The areas where the cited actions were being performea were posted as contamination areas. The contamination levels in and around the motor and electrical connections were less than 1000 dpm/100 cm2 (minimum level for posting as a contaminated area).
Knowing the contamination levels were less than 1000 dpm/100 cm, the workers r
deviated from the requirements of the radiation work permit. These deviations were not previously approved by Radiation Protection and I
were contrary to the. radiation work permit requirements.
2.
Corrective Steps Taken and Results Achieved An Operations, Notification and Evaluation (ONE) Form was generated i
to identify and address specific radiation work permit non-compliance.
Additionally, all work on the reactor coolant pump motor was temporarily stopped.
The respective department managers met with the workers involved to emphasize management expectatient of radiation work permit compliance prior to resuming work on the reactor coolant pump motor.
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i At achment 1 to TXX-96419 Page 3 of 3 3.
Corrective Steps Taken to Avoid Further Violation a.
A Lessons Learned memorandum from the CPSES Radiation Protection Manager will be distributed site wide to radiation workers.
The memorandum will address the following:
a.
Details of the Notice of Violation, i
b.
Radiation Work Permit requirements and compliance.
c.
Management's expectations regarding radiation work permits, and d.
Adherence to radiological postings.
b.
Radiation Protection techniciar.1 will receive additional l
training regarding this specific Notice of Violation and the l
significance of assuring that workers have a full understanding l
of posting and radiation work permit requirements.
The training will also address management's expectation for strict
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compliance with radiation work permit requirements unless proper authorization is given to deviate from the requirements.
TU Electric will complete the above actions by September 30, 1996 to j
j prevent recurrence.
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Date of Full Compliance TV Electric is in full compliance at this time.
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