ML20217Q271
| ML20217Q271 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/21/1997 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-293-97-03, 50-293-97-3, LTR-2.97.085, NUDOCS 9709020184 | |
| Download: ML20217Q271 (5) | |
Text
, _ -..
10CFR 2.201 Boston Edison Pilgran Nuclear Power Staten
. Rocky Hdi Road Plyrnouth, Massachusetts 02360 L J. Olivier-
- Vice President Nuclear Operations.
August 21, 1997 ano station ok ctor BECo Ltr. #2.97.085 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20655 Docket No. 50 293 License No. DPR-35 i
SUBJECT:
Realv to Notice of Violation (Reference NRC Inspection Report 97-03)
Enclosed is Boston Edison Company's reply to the Notice of Violation contained in the subject inspection report.
The following commitments are made in this letter.
The traming program ~ for waste control technicians will be reviewed and upgraded by o
December 31i1997. Training on the upgraded program will be completed by June 30,1998.
o-Provide penode refresher training to station serv 6ces personnel, o Procedure 1.4.39 will be revised by December 1997 to improve matructions to painters.
Please do not headate to contact me if there are any questions regardmg the enclosed reply.
/'Y
. J.
' vier RLC/WGtJRAH/dmcN970302 Enciosure: Reply to Notice of Violation cc:
Mr. Alan B. Wang, Project Manager Project Directorate 1-3 Office of Nuclear Reactor Regulation Mail Stop: OWF1482 Ih l i U.- S. Nucisar Regulatory Commission
/
1 Whee Flist North 11555 Rockville Pike Rockville, MD 20852 '
, n (, C,,J '
9709020184 970821 -
-PDR-ADOCK 05000293 0
pDe_
-4 Boston Edison Company !
- U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406
- Senior Resident inspector Pilgrim Nuclear Power Station -
I l.
l 4
s i
f
. Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR-35 ENC l.OSURE Reply to Notice of Violation 97-03-02 Violation "As a result of an inspection conducted April 29 - June 24,1997, the following violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy (60 FR 34381; June 30,1995), the violation is described below:
PNPS technical specification 0.11 requires that radiation protection procedures shall be adhered to for all operations involving personnel exposure. PNPS procedure 1.3.114, Conduct of Radiological Operations, Step 5.1.1.6 specifies not to move or remove any radiological:
postings or boundaries unless directed by radiological protection (RP) persoriae: to do so.
Contrary to the above, on June 2,1997, a station services department worker tied opf n the boiler room door which forms part of the radiological controlled area and this action was not directed by RP personnel.
This is a Severity Level IV violation (Supplement IV)."
REASON FOR THE VIOLATION The' reason-for the violation was determined to be human performance cau=ed by non-compliance with procedure 1.3.114. The waste' control technician (WCT) who had been working in the boiler room area tied open the door to allow the floor to dry after cleaning without considering radiation protection ramifications. The existing radiological controlled area :
(RCA) sign remained on the reverse sMe of tL Joor but could not be read when the door was tied open. The procedure required the WCi to inform the radiaticn protection personnel before keeping the door tied open; however, the WCT was unaware of the requirement to seek
' permission from the RP personnel and the impact of keeping the door open.
In addition, the NRC identified other events in the inspection report that we reviewed for
. possible common cause contributors. During RFO#11 (April 1997), a salt service water pump became inoperable when the electrical breaker that powers the pump motor was inadvertently bumped open during a cleaning activity in the auxiliary bay where the breaker is located. On
-July 19,1995, a plant transient from 100% to 70% (rapid downpower) occurred when the lube oil sightglass on the "B" seawater pump motor became inverted during a cleaning and painting activity. The oil drained from the sightglass and resulted in scoring of the motor bearing. The transient was caused by contract painters. In 1995, action was taken to require workers, specifically painters, to hold a daily briefing with the Nuclear V,ttch Engineer to discuss the areas to be worked and the precautions necessary to prevent future damage or impact en
- plant equipment.. Although this action was taken, the requirement was not proceduralized.
Their have been no further known occurrences involving painters.
1
Our assessment of the above events indicated a weakness in the waste control technician training program and painting instructions for contractor painters. More specifically, the current training activities do not result in a satisfactory awareness of the impact that casual errors can have on plant operation during station services activities.
CORRECTIVE STEPS TAKEiN AND RESULTS ACHIEVED The following corrective steps were taken to resolve the boiler room doc event:
L The door was immediately restored to its proper closed configura an, and the event was discussed with the individual involved.
Areas in the plant having the potential to repeat this type event were evaluated, and a second set of postings (inside the door) were added in the following areas:
- Boiler Room door to outside
- Makeup demineralizer door to outside
- Augmented Off Gas building door to outside
- Outside Retube building door to outside.
I The above postings were completed on June 6,1997.
Notices about radiological postings and boundaries were displayed on the station video news system (TargetVision) for employee awareness throughout the nuclear organization.
An employee information notice ("FYl") was published on June 13,1997. The focus of this FYi was to remind the employees of the importance of not b'acking or moving any postings and barriers located in and around the plant that are pinced for radiological, security, and safety requirements.
A discussion of the event was included in the monthly nuclear organization safety meeting information packages used for the June 18,1997, meeting.
The event was discussed with all WCTs. Also, industry and plant events were reviewed with WCT personnel, and their input for improvement was obtained. These actions were completed by June 27,1997, 2
CORRECTlW STEPS THAT WILL BE TAKEt' TO AVOID FURTHER VIOLATIONS The WCT training program is irnended to include plant impact %inirs to highbght the vanous ways that plant equipment could adversely be impacted during station services activities (e.g.,
having the potenbal for a plant transient). The WCT training program will be improved as follows:
The intermediate training objective is to review and upgrade the training program to include problem report trends, day-to-day job activities, potential plant impact, and WCT personnel input. The upgrade to the training program will be completed by December 31, 1997.
Updated training for WCT personnel addressing the pctential for adverse plant impact during routme and nonroutine stathe services activities will be conducted by June 30, 1998.
The long term training objective is to incorporate penodic refresher training un an annual j.
basis (or more frequeritly if indicated by future assessment) to maintain proficiency on procedural requirements and potential plant impact for routine and nonroutine activities that pertain to station services activities. The program is subject to updates on a continuing basis, if warranted, based on worker or management level assessments.
To improve upon the instructions for painters, procedure 1.4.39, " Control of Painting in the Reactor Buildmg," will be revised to include indoctnnation on potential plant impact for routine and nonroutine activities that portam to station services activities. The revised procedure 1.4.39 will be implemented by December 1997.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full comphance was achieved on June 2,1997, when the boiler room door was closed to allow proper viewing of the RCA posting.
3 a