ML20205M395
| ML20205M395 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/27/1988 |
| From: | Counsil W, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TXX-88753, NUDOCS 8811030074 | |
| Download: ML20205M395 (5) | |
Text
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NP9 Log # TXX-88753 File # 10130
=
r IR 88-54 itlELECTRIC 9,g,, &cfgjag gi3=,rg, October 27, 1988 U. 5. Nuclear Regclatory Commission Attn: Document Control Desk Washington, D. C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC INSPECTION REPORT NOS.
50-445/88-54 AND 50-446/88-50 Gentlemen:
TV Electric has reviewed your letter dated September 27, 1988, concerning the inspection conducted by Messrs. S. P. Burris and S. D. Bitter during the period August 3 through September 8, 1988.
This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for CPSES Units 1 and 2.
Attached to your letter was a Notice of Violation.
We hereby respond to the Notice of Violation in the attachment to this letter.
Very truly yours, h b-W. G. Counsil By:
D. R. Woo 31an Docket Licensing Manager ROD /gj c - Mr. R. D. Martin. Region IV Resident inspectors, CPSES (3) gDRe11osoo74 ggggg7 g
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x Attachment to TXX-88753 October 27, 1988 Page 1 of 4 NOTICE OF VIOLATION
[44578B54-V-01)
Special Nuclear Material License 1912 dated February 14, 1983, governs the i
storage and possession of nuclear fuel.
Part VII of the license, entitled "Radiation Safety," states that the radiation protection engineer is responsible for implementation of the health physics program and that CPSES is comitted to establishing a program to maintain occupational and general public exposure to radiation As low As is Reasonably Achievable (ALARA).
The i
administrative controls used are covered by health physics procedures.
These l
procedures include the issuance and use of radiation pennits, l
CPSES Station Administration Manual, Procedure STA-656, "Radiation Work j
Control," states that all routine entries into a radiation controlled area j
require a general access permit or a radiation work permit.
Contrary to the above, on August 14 and 15,1988, a contract employee working i
in the fuel building crossed a barrier into a radiation controlled area without meeting the required administrative controls (445/8854-V-01).
I RESPONSE TO NOTICE Of VIOLATION T(445fa854V;0Q TV Electric agrees with the alleged violation and the requested information follows:
4 1.
Reason for Violation The violation resulteo because the personnel involved in this incident confused the requirements for access to green and blue striped badge security areas with the requirements for access to the radiation controlled area associated with the spent fuel pool.
CPSES Fuel Building fire protection, cleanliness control, and security requirements are implemented in accordance with procedure STA-803, "Fuel Building Access and Activity Control." This procedure establishes badging systems for fuel Building access control.
As stated in STA-803, Rev. 3:
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"The blue striped badge is required for access to all areas where nuclear fuel is being stored or handled."
"The green striped badges allow access to areas above blue striped areas by personnel who do not have blue striped badges."
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Attachment to TXX-88753 October 27, 1988 Page 2 of 4 l
The New Fuel Storage Vault and Spent Fuel Pool #1 below the 860 ft.
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elevation are posted as blue striped badge areas. Green striped badge areas are defined as being above the 860 ft. elevation (see attached sketch).
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The Radiation Controlled Areas (RCA) which s,e established per procedure RPI-600, "Radiological Surveillance and Posting," are posted on the New l
fuel Storage Vault Covers and on the Spent Fuel Pool #1 guard rails. As shown in the attached sketch the radiation controlled area extends into the green striped badge area to approximately four feet above the bridge crane lower platform. At the time of the occurrence there was an RCA barrier rope across the entrances to the lowe* platform.
l On August 9, 1988, a TV Electric Work Permit (TWP) was issued for I
scaffolding work above the 860 foot elevation in the fuel Building.
The foreman involved in the scaffolding work believed the TWP authorized entry to the crane lower platform. On two occasions (August 13. and 15.
j 1988) the foreman obtained a green striped badge from security sersonnel and during the course of his work entered the RCA by crossing t1e RCA barrier rope and walking out on the lower platform. On both occasions the security personnel who issued the foreman a green striped badge believed that the RCA was bounded by the blue striped badge area and that l
the green striped badge area did not include any radiatir,n areas. On the i
August 15 occasion, the foreman was observed entering the lower platform i
by a Radiation Protection Technician.
The Radiation Protection i
Technician reported the occurrence in accordance with established i
procedures.
2.
Corrective Steps Taken and Results Achieved i
i The Radiation Protection technician instructed the foreman to exit the I
)latform and explained the difference between the green and blue striped sadge security areas and radiation controlled areas.
Radiological Incident / Problem Report 88-0002 and Deficiencs Report PS8-04086 were l
issued to document the occurrences.
Based on area surveys and re-creation of the foreman's actions. the forenan's total radiation dose was i
calculated to be no greater than 0.4 mrem.
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As a result of the radiological incident / problem report evaluaticn, all
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green striped badging was temporarily fuspended, in audition Security personnel were reinstructed on the differences between security badge areas and requirements for radiation control'.d area access.
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Attachment to TXX-88753 October 27, 1988 Page 3 of 4 3.
Corrective Steps Which Will be Taten to Avoid Further Violations b
STA-803 has been changed to require Radiation protection approval of work activities in both the green and blue striped oadge areas. Radiation Protection personnel will brief the personnel requiring access on the applicable radiological conditions and restrictions.
The Security Post Order for the fuel Building has been changed to clearly indicate that blue and green striped badges are for security purposes only, and that the RCA encompasses both areas.
Security personnel have been instructed to ensure that Radiation Protection personnel are made aware of planned entries into the blue and green striped badge areas.
As an added precaution RCA boundary postings, including those on the fuel Building 860 foot level and the lower platform, have been enhanced by the addition of signs stating, "Contact Radiation Protection Prior to Entry."
Other RCAs onsite have been inspected to assure that no inadvertent intrusion is possible. Access to the other RCAs is controlled by locked barriers.
The postings were found to be in accordance with RPI.600.
The actions described above will be modified as necessary to accomodate future changes in radiological conditions and operational status.
4.
Date When Full Compliance Will be Achieved full compliance has been achieved.
Attachment to TXX-88753 October 27. 194Pe i
Page 4 of 4 AREA LAYOUT CVERwEco_vrgy i
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spent il ruel 3
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Crane lll I
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1 Ladder F I
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SIDE VIEW 1
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Green Badge Above i
Lowee
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Platform O
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