ML20203J069
| ML20203J069 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/15/1997 |
| From: | Tulon T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-17, 50-457-97-17, NUDOCS 9712190115 | |
| Download: ML20203J069 (6) | |
Text
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December 15,1997 Document Control Desk US Nuclear Regulatory Commission -
Washington, D.C.~ 20555
Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/97017 Braidwood Nuclear Power Staion Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
J. A. Grobe letter to T. J. Tulon dated November 17,1997, transmitting Notice of Violation from Inspection Report 50-456(457)/97017 During the radiation protection inspection which ended on October 22,1997, two Severity Level IV violations were identified. These violations are documented in the reference specified above. Comed's response to the violations is included in the attachment to this letter. Braidwood Station concurs with the cited violations.
Braidwood has worked hard to ensure good radiation worker practices and contractor performance. To address the radiation protection weaknesses, a stand dmvn was held with Radiation Protection personnel to emphasize the importance of being attentive to detail and self-checking. Additionally, augmented contractor training was held. These
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actions were taken to emphasize station management's expecta: ions for radiation worker
,/ l performance, good communication and conservative decision making.
The following commitments were made in the attachment to this letter:
p The Radiation Protection Training Advisory Committee (TAC) will determine the e
level of training necessary for incoming Contract Radiation Protection Supervisors and Contract Radiation Protection Technicians. Training to be considered would involve conservative decision making, STAR (Stop Think, Act, Review) training simulator, and three way communications.
The Technical Lead Health Physics (HP) peer group, consisting of HP personnel from each Comed nuclear station, will determine Comed's position regarding the acceptability of using extendible dose rate meters rather than ion chambers fbr establishing dose rates.
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- Document Control Desk 1-December 15,1997.
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If your_ staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at '(815) 458-2801; extension 2980.
M I
T othy J. Tulon te Vice President
. Braidwood Nuclear Generating Station Attachment
.cc:
- A.B. Beach, NRC Regional Administrator, Region III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F..Niziolek, Division of Engineering, Oirice of Nuclear Safety, IDNS ca..rwW7134mt. doc d
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' ATTACllMENT 1 REPLY TO NOTICE OF VIOLATION
. (50-456:457/07017-01) 1.
Technical Specification 6.11 requires, in part, that procedures for radiation protection be adhered to for all operat ons involving personnel radiation exposure.
i Procedure BwRP 5010-1, " Radiological Posting and Labeling Requirements,"
revision 7, requires, in part, that personnel entering any radiologically posted area are to read and to comply with all associated postings.
Contrary to the above, on October 10,1997, an individual, who was performing work on the 2CV8149 valve within the radiologically posted area, failed to follow the instmetions contained on a posting (i.e., the posted step-off pad). Specifically, the individual stepped over the high contamination area boundary rope and left the area without removing his outer boots and gloves, as required by the posting (step-off-pad).
t REASON FOR Tile VIOLATION The worker performing the measurements entered the high contamination area (HCA) by stepping over the radiation rope as instmeted during the pre-job brief. This was done at the direction of the Radiation Protection Technician (RPT) monitoring the job. The worker exited the same way, which was contrary to the instructions discussed in the pre-job brief. The pre-job briefing instructed exiting via the step off pad. The worker immediately stepped back into the area and spoke with the RPT monitoring the valve work and was instructed on the proper method for exiting the area.
The root cause for the violation is the lack of self-checking principles in the work environment. The pre-job briefing discussion clearly defined the proper way to enter and exit thejob site. These discussions were thorough and adequate, however the worker did not recall the discussion regarding the proper manner to enter and exit the area.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACilIEVED The worker was locked out of the Radiological Protected Area (RPA) pending further investigation. In addition, the worker was counseled on the severity of the inappropriate action.
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' ATTACliMENT 1 REPLY TO NOTICE OF VIOLATION.
(50-456:457/97017-01)
ACTIONS TAKEN TO PREVENT RECURRENCE The werb was sent through a refresher session of Nuclear General Employee Training (NGET), which included a special test emphasizing this offense to validate the effectiveness of the counseling. The following information was presented during the training session: an initial NGET Radiation Worker Training (RWT) video, a Braidwood "RP Tips for a Successful Outage" handout, the Comed Rad Worker Handbook. and
. discussions on protective clothing donning and removal:
Subsequent to this event, the Radiation Protection Department initiated a tailgate discussion with site personnel, including RP staff, Contract Radiation Protection Technician personnel, and craft contractors, to address RP events that occurred during the refueling outage.
i DATE Wi1EN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved when the individual was counseled for his actions and successfully completed the training course.
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- ATTACliMENT 1 REPLY.TO NOTICE OF VIOLATION
, (50-456:457/97017-02) 2.
Technical Specification 6.12.2 requires for indisidual high radiation areas accessible to personnel with radiation levels of greater than 1000 milliroentgen /hr that are located within large rooms, such as PWR containment, where no enclosure exists for the purposes oflocking, and where no enclosure can be reasonably constructed around the individual area, that individual area shall be barricaded (by a more cubstantial obstacle than rope), conspicuously posted, and a flashing light shall be activated as a warning device.
Contrary to the above, on September 29,1997, two radiation protection technicians measured radiation levels of 1200 to 1500 milliroentgens/hr in an area within the Unit 2 Containment Building, a posted high radiation area where no enclosure existed for the purposes oflocking and where no enclosure could be reasonably constructed, but failed to barricade and conspicuously post the area and to activate a flashing light.
REASON FOR THE VIOLATION The primary cause of this violation is procedural noncompliance. A contract radiation protection technician (CRPT) did not post the area as a locked high radiation area (LHRA as required by BwRP 5310-2," Control of Access to High Radiation Areas and Very High Radiation Areas," and BwRP 5010-1, " Radiological Posting and Labeling Requirements," due to an assumption made on the dose rate reading. The afTected line was surveyed at ~ 8 inches instead of-12 inches and the survey was performed using an extendible dose rate meter as compared to an ion chamber, The CRPT assumed that both of these factors made the result conservative and that if the reading had been taken at 12 inches with an ion chamber, the line would not meet the criteria for a High Radiation Area (greater than 1 rem / hour at i foot). The CRPT did not verify and validt te the dose rates with an ion chamber. As a result of this reasoning, the CRPT left the radiolo3 cally posted i
area (RPA) and failed to control and post the area as a LHRA. The CRPT also failed to verify and validate the assumption with a supenisor. A second CRPT on thejob also did not recognize the area should have been contrclied and posted as a LHRA until the supenisor mentioned this to him when he was out of the RPA.
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The Lead CRPT was immediately dispatched to verify the dose rates in the area, and to properly control and post the area as a locked high radiation area until shielding was installed. In addition, appropriate personnel were disciplined in accordance with contractor policy and were terminated from Braidwood Station.
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. ' ATTACIINfENT 1 RE. PLY.TO NOTICE OF VIOLATION (50 456:457/97017-02)
ACTIONS TAKEN TO PREVENT RECURRENCE Braidwood Radiation Protection Management required all CRPT and Contract e
Radiation Protection Supervisors (CRPS) to attend training on conservative decision making, the STAR (Stop, Think, Act, Review) training simulator, and three way communications. This corrective action was initiated in response to subsequent RP events which demonstrated some inconsistencies in these areas.
The Radiation Protection Training Advisory Committee (TAC) will determine the level of training necessary for incoming Contract Radiation Protection Supenisors and Contract Radiation Protection Technicians. Training to be considered would involve conservative decision making, the STAR (Stop, Think, Act, Review) training simulator, and three way communications.
The Technical Lead llealth Physics (IIP) peer group, consisting ofIIP personnel from each Comed nuclear station, will determine Comed's position regarding the acceptability of using extendible dose rate meters rather than ion chambers for establishing dose rates.
DATE WHEN FULL CONfPLIANCE WAS ACillEVED Full compliance was achieved when the area was posted in accordance with station procedures.
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