BECO-87-154, Responds to Violation Noted in Insp Rept 50-293/87-29. Corrective Actions:Involved Individual Reinstructed on Use of Extended Radiation Work Permits & Operations Personnel Briefed on Need to Follow Radiation Protection Requirements

Responds to Violation Noted in Insp Rept 50-293/87-29. Corrective Actions:Involved Individual Reinstructed on Use of Extended Radiation Work Permits & Operations Personnel Briefed on Need to Follow Radiation Protection Requirements

ML20235J075
Person / Time
Site:	Pilgrim
Issue date:	09/23/1987
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
BECO-87-154, NUDOCS 8710010297
Download: ML20235J075 (4)

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eosrweoam Executive Offices 800 Boylston Street Boston, Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuclear September 23,1987 BECo Ltr. #87- 154 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 License No. DPR-35 Docket No. 50-293

Subject:

NRC Inspection Report 50-293/87-29

Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation contained in the subject inspection report.

Please contact me directly if you have any questions on this response.

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. E rd BPL/la Attachment Regional Administrator, Region I, U.S. Nuclear Regulatory Commission -

631 Park Avenue E King of Prussia, PA 19406

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Director, Office of Inspection C8 ui and Enforcement w o

g U.S. Nuclear Regulatory Commission o

Hashington, DC 20555 y f cn Sr. Resident Inspector o 8710010297%Og93 ADOCK PDR 6h PDR

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.. 3, ATTACHMENT 1 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation Technical Specification 6.11 requires that procedures for personne1' radiation protection be prepared and adhered to for all operations involving personnel radiation exposure. Radiation Protection Procedure 6.1-022 requires in part in section VIA and VIIJ.7, that individuals follow the instructions of radiation work permits.

Contrary to the above, at about 10:10 p.m. on.. July 16 1987 a reactor operator was found inside the Reactor Water Clean-up P0mp. Heat Exchanger Cubicle, a posted, locked High Radiation Area, without the radiation survey meter l required to be used by the applicable radiation work permit .(RHP No. 87E-4)'.

The individual had signed the RHP indicating his understanding of the RHP's requirements.

Resoonse

1. Discussion:

Boston Edison Company agrees with the facts as stated'in the Notice of Violation.

On July 16, 1987 a licensed reactor operator entered the Reactor Water Clean-up Heat Exchanger (RHCU Hx) room to perform valving operations. The operator had properly signed the Radiation Work- Permit (RHP) briefing sheet which specified that a radiation survey meter was required. Upon questioning by the NRC Inspector the operator realized he did not have'the required survey meter and immediately exited the room.

The operator was logged in on the RHP from 2140 hrs to 2210 hours0.0256 days <br />0.614 hours <br />0.00365 weeks <br />8.40905e-4 months <br />. His actual time in the RHCU Hx room was approximately 10-15 minutes based on interviews with him. He received a radiation exposure of 5 millirem while in the room based on his pocket dosimetry reading. No other high radiation areas had been entered by the operator that day prior to the event.

RHP No. 87E-4 is an extended RHP issued for the duration of- one year.

l This RHP allows authorized operations personnel access to radiation areas l for inspection, surveillance and equipment operation. Operations personnel authorized to use extended RHP's are responsible for briefing themselves on the radiological conditions and requirements associated with the specific area to be entered. This self briefing is allowed based on training and certification of knowledge in plant systems, equipment locations and radiological protection requirements.

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, , 1 ATTACHMENT ll Cont.)' ')

2. Cause:

The cause for the failure to follow the RWP. requirement was.a personnel error by the involved reactor operator. The operator had been issued'a portable radiation survey instrument that can.be attached at the waist.

Follow-up' interviews with the individual. confirmed that-he stores the q meter in his locker'while not at' work.and'normally dons the survey meter l prior to: reporting to the control room to receive his. work assignment. '

.The operator stated that he simply forgotito don his survey meter on that occasion..

This instance demonstrated his' complacency in the.use of the survey instrument. .If the operator had been 1n the. habit of using the survey instrument in accordance with its . intended purpose, he either would not-have entered the room or would have realized he did not have the instrument almost immediately upon entering the, room. The operator

-described this complacency as resulting from his familiarity with the radiological conditions of the room and.his knowledge that the' RWCU, system l was not in use at that time.

I The operator acknowledged full responsibility for his error and stated-that the procedures were clear on this requirement and that.he had been specifically trained on the purpose and use of the survey meter.

3. Immediate Corrective Actions Taken:

The operator immediately exited the RNCU Hx room when questioned by the NRC Inspector and when he realized that he did not have a radiation survey meter. At 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />, the radiation protection supervisor discussed the event with the individual and reinstructed him on the use of. extended RHP's. A Radiological Occurrence Report was initiated at that time to document the event.

4. Corrective Actions Taken to Avoid Future Violations:

The Nuclear Hatch Engineer and the Operations Section Manager discussed the event with the involved individual who was given a written reprimand. ,

During discussion of the incident, the individual demonstrated that he understood the severity of the' infra: tion and the need. to-follow all station procedures.

The Operations Section Manager briefed the Operations personnel on the ,

significance of the event and the need to follow radiological protection '

requirements. This issue was also addressed in the operations night order-  ;

(ir,struction) log on 7/18/87. Additionally, this event was described in a '

memo to all operations personnel. The memo stressed that operations personnel have been provided with a survey instrument to alert.them to abnormal radiological conditions and to assist them in maintaining their ,

radiation exposures ALARA. It was also stressed that BECo will not )

tolerate complacency regarding an employee's Health Physics l responsibilities, nor any other responsibilities.

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ATTACHMENT 1 (Cont.)

To further address this issue, general guidance has been provided to the individuals who participate in the Management Monitor Watch Program to instruct observers to look for signs of complacency in activities that are  !

repetitive or where a high degree of familiarity exists. The Management Monitor Hatch Program is a process by which work activities are routinely observed to assess performance.

This event is an isolated instance of non-compliance by one individual. A I review of the event indicates that adequate procedural controls are in <

place for extended RWP's, and the requirement to carry a survey meter was clearly indicated on the RWP briefing sheet. The disciplinary action, in j combination with the instructional and directive communications, are  !

believed sufficient to preclude further instances of non-conformance by 1 the involved individual. Other operations personnel authorized to use i

, extended RWP's have been briefed on the event and the importance of '

l following radiological protection requirements. In addition, the planned 1 observations of work activities in accordance with the established ' '

monitoring program will provide early identification of complacency if it develops. l l

5. Date of Full Compliance:

Full compliance with the requirements of RWP 87E-4 was achieved on 7/16/87 at 2210 hours0.0256 days <br />0.614 hours <br />0.00365 weeks <br />8.40905e-4 months <br /> when the operator exited the RWCU Hx room.  !

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