ML20215H285
| ML20215H285 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/13/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-059, 87-59, NUDOCS 8704200241 | |
| Download: ML20215H285 (5) | |
Text
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g Executive Offices 800 Boylston street Boston, Massachusetts 02199 Ralph G. Bird senior Vice President - Nuclear April 13, 1987 BECo Ltr. #87-059 U.S. Nuclear Regulatory Commission Attn: NRC Document Control Desk Washint; on, D.C. 20555 License No. DPR-35 Docket No. 50-293
Subject:
NRC Inspection Report 50-293/87-011
Dear Sir:
Attached is Boston Edison Company's response to the Notice of Violation issued with the subject inspection report.
1 Please do not hesitate to contact me directly if you have any questions.
R.G. Bird EM/la Attachment cc: Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue - Region I King of Prussia, PA 19406 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commtssion Washington, D.C. 20555 Senior Resident Inspector 8704200241 870413 8
PDR ADOCK 05000293 G
PDR I l
ATTACHMENT 1 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Restatement of Violation:
Technical Specification 6.8 requires, in part, that the procedures recommended in Appendix A of Regulatory Guide 1.33 be established and implemented.
1.
Procedure 6.1-012, Revision 18, " Access to High Radiation Areas" requires that keys controlled by radiation protection personnel be audited at each shift turnover.
Key audits are to be documented on a form specified in the procedure.
Contrary to_the above, on February 3, 1987, the 7:00 p.m. shift turnover key audit was not performed.
In addition, the February 8, 1987 7:00 a.m.
shift turnover key audit was not performed.
2.
Procedure 6.1-024, Revision 13. " Radiological Posting of Areas of the Station," requires in Section VII E that areas where airborne radioactive concentrations are greater than.21 MPC be posted as " Caution Airborne Radioactivity Area."
Contrary to the above, at about 10:00 a.m. February 12, 1987, the sand blasting tent on the Turbine Deck exhibited airborne radioactivity concentrations of 0.29 MPC and the area was not posted as specified above.
3.
Procedure 6.1-024, Revision 13, " Radiological Posting of Areas of the Station," requires in part in Section VII E, that areas where loose surface contamination exceeds 1000 dpm/100cm* shall be posted with the words " Caution Contaminated Area" and be barricaded so as to show the extent of the affected area.
Contrary to the above, at about 7:00 p.m. on February 10, 1986 an area on the Refuel Floor around the stored Reactor Vessel Head exhibited loose 2
surface contamination levels of up to 2000 dpm/100cm and the area was not barricaded so as to show the extent of the affected area.
In addition, the posting was inadequate in that personnel could enter the area without realizing that it was contaminated.
4.
Procedure 6.1-022, Revision 21, " Issue, Use, and Termination of Radiation Work Permits (RWPs)," requires in part in Section E.7 that individuals exiting an RHP area note his/her time out and pocket dosimeter reading when they exit the area.
Contrary to the above, at or about 7:00 p.m. on February 11, 1987 three individuals did not implement the procedure in that two individuals did not note their time out while the third individual did not note either his time out or pocket dosimeter reading. The individuals had left the area.
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ATTACHMENT 1 (Cont.)
5.
Procedure 1.3.10, Revision 15 " Key Control," requires in part in section IIA.7 what the Hatch Engineer signify his approval of issuance of High-High Radiation Area Access Keys to an individual by initialing the key log for that issuance.
Contrary to the above, on several occasions including December 15, 1986, January 16, 1987, January 20, 1987, High-High Radiation Area Access keys were issued to individuals and the Hatch Engineer did not initial the key log to signify his approval for issuance of the key.
The above examples constitute a Severity Level IV Violation. (Supplement IV)
Boston Edison Response:
As stated in the Notice of Violation and associated inspection report, this condition was the result of a number of incidents of non-compliance with the station procedures. He do not believe that these conditions represent a breakdown in the radiological control program, however we do believe some of these conditions indicate a lack of aggressiveness by Radiation Protection technicians in the execution of their duties. Our response is arranged to first identify the comprehensive corrective actions being taken to resolve the violation and second to identify the specific corrective action for each of the five items which were the basis for the violation.
I.
Comprehensive Response Corrective Actions Taken and Results Achieved The identified non-compliances with station procedures have been aAtressed through three separate actions.
The first was to provide formal wr!tten direction to the Radiation Protection (RP) technicians of their responsibility to implement and comply with all aspects cf the station procedures.
Second, the operations department was informea via a night order of the need to similarly fully implement the reluirements of the station procedures, specifically the controls a;4cciated wt th issuance of High-High Radiation Area keys.
Finally, statien personnel are being re-informed by memorandum of the need to full) cc.mly with the controls associated with all etition procedures.
Corrective Steps Taken to havent Future Violations No specific programmatic deficiencies were identified.
The corrective steps taken to prevent future vietaticas censist of enforcing the requirements of station proceautes, including the initiation of disciplinary actions where arrrecriate.
RP Technicians have been formally reinfortred of their resr0nsibility to aggressively enforce procedure requirements.
This was als0 Outlined in the memorandum to station personnel regarding the 00n-eemplivice with procedures. Additionally, the training department is Ning requested to expand the existing emphasis of this issue in future General Employee training.
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ATTACHMENT 1 (Cont.)
o To addrets the discrepancy in the way the High-High Radiation Area keys are controlled, a revision to the radiologicai key control process is under development.
This change will reassign the responsibility for control of the keys from the control room to the Radiation Protection department.
This is consistent with the use of the keys, and the post-THI guidance related to minimizing the non-vital duties and responsibilities of the operating staff.
Date When Full Compilance Was Achieved The actions required to assure full compliance were completed on April 10, 1987.
II.
Specific Corrective Action For Each Of The Five Items Item 1 As described above, the RP technicians have been informed of the specifics which led to this violation, and re-instructed in their responsibility to comply with procedure requirements. As described above, an examination of ten days key audit records from March of 1987 did not identify any further discrepancies indicating corrective action has been effective.
Item 2 As described above, the RP technicians have been re-instructed in their specific responsibility to implement and comply with station procedures.
Investigation into the specific incident determined that the individual involved was aware of the need to post the area as an Airborne Radiation Area. He stated that approximately ten minutes after the initiation of work in the area, and following successful initiation of air sampling, he posted the area with no prompting from others.
The need to promptly post any area in a fashion consistent with existing conditions has been re-emphasized with this individual, as well as the other RP Technicians.
Item 3 I
The area which was the subject of this item was properly posted in accordance with plant procedures initially, nowever a section of the barricade rope preventing access to the area had fallen loose, opening a section approximately three feet wide.
This yellow and magenta rope had been taped to a handrail at one end when installed, and had loosened and fell sometime prior to the inspector's tour of the area.
During this period, access to the area without proper warning to individuals of the potential for contamination was possible.
This isolated condition did not represent a programmatic breakdown in the implementation of the radiological protection program. The RP technicians have been cautioned regarding the conditions which led to this violation, and the need to assure that barriers are durable cnd can be expected to remain intact for the length of time the condition is expected to exist. Also, the RP technicians were reminded of their responsibility to identify and correct any deficiencies they identify in the field during area tours.
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ATTACHMENT 1 (Cont.)
EI Item 4 This item was the result of individuals who were performing work _
controlled by an RWP and not complytr,9 with administrativre ccntrols. On a typical day as many as 500 entries and exits are recorde6 on RHPs. As a result of this large number of transactions some procedural non-compliances have occurred in the past.
The RP department contacts any individuals who fall to comply with the procedure reauirements, and obtains the required information. This practice allows gathering the maximum amount of information and counseling of individuals who failed to follow procedures. The memorandum distributed to station personnel reiterates the need to comply with procedures an/, reminds them that disciplinary action may be taken for failure to do so.
Item 5 The specific corrective steps taken to audress this non-compliance with station procedures include an initial cautioning of operators via a night order. This order reminded them of their responsibility to fully implement station procedures. Changes to the radiological program are planned which will remove the operations watch engineer from involvement in the control of keys for radiologically controlled areas.
These changes are expected to be impiemented prior to May 1, 1987.
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