ML20140D510

Responds to NRC Re Violations Noted in Insp Rept 50-247/84-24.Corrective Actions:Health Physics Personnel W/O Previous Steam Generator Work Experience Will Be Trained

ML20140D510
Person / Time
Site:	Indian Point
Issue date:	11/25/1984
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20140D493	List: IR 05000247/1984024 ML20140D510
References
NUDOCS 8412180555
Download: ML20140D510 (3)

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November 25, 1984 Re: Indian Point Unit No. 2 Docket No.50-247 Mr. Thomas T. Martin, Director '

Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Pegion I 631 Park Avenue King of Prussia, Pa. 19406

Dear.Mr. Martin:

This refers to I.E. Inspection 50-247/84-24 conducted by Mr. P. Clemons of your office on August 27-31, 1984 of activities authorized by NRC Licensing No. DPR-26 at Indian Point Unit No. 2. Your October 26, 1984 letter stated that it appeared that certain of our activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A. Our response to the items of non-compliance is presented in Attachment A to this letter.

Should you or your staff have any questions, please contact us.

Very'!trulyyours,/

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</n cca Senior Pesident Inspector l U. S. Nuclear Pegulatory Commission P. O. Box 38 Buchanan, New York 10511 l

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ATTACHMENT A 1

RESPONSE TO NOTICE OF VIOLATION APPENDIX A VIOLATION Technical Specification 6.11, " Radiation Protection Program" requires l that, ~ " Procedures for personnel radiation protection shall be prepared I consistent with the requirements of 10 CFF Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."

(a) Procedure No. FHS 3.403, " Steam Generator Channel Head Entry", developed pursuant to the above, requires in Section 5 3 that "An SAO-134 will be prepared for the entry of personnel in the Steam Generators". An SAO-134 was prepared for the entry in Steam Generator No. 23 on August 22, 1984, and it required that exposures be recorded for each jumper as the jumper left the Channel Head.

Contrary to the above, on August 22, 1984, a worker, working on Steam Generator No. 23, made four partial and/or full jumps into the generator, and the health physics technician covering the job did not record the workers exposure information after each jump. The technician did not read the worker's special external whole body dosimeters until after the fourth jump, and this result in the worker exceeding his quarterly administrative exposure limit of 1250 millirem. The actual , dose received during the jumps was 1350 millirem.

(b) Procedure No. EHS 2 006, " Dissemination of Infomation Relative to Environmental Health and Safety Procedures",

requires that procedures and procedure changes be reviewed with the Radiation Protection Section personnel. Section 2.1.5 of Procedure No. EH&S 2.006 states, "A required Reading Acknowledgement Form (Addendum 1) denoting the procedure / revision number and title, the Radiation Protection Section individual's name required to read the procedure, his/her initials indicating awareness and understanding of the procedure contents, and verification by a Radiation Protection Supervisor shall be completed for all new procedures or revisions to procedures".

Contrary to the above, as of August 31, 1984, the license did not have a copy of the Peading Acknowledgement Form (EHS 2.006-1, Addendum 1) indicating that the health physics technician covering the Steam Generator job on August 22, 1984, had read and understood the procedure contents of Procedure No. EF&S 3.403, " Steam Generator Channel Heed Entry."

This is a Severity Level IV violation (Supplement IV).

e RFSPONSE con Fdison agrees with the description of the events, as stated in the Notice of Violation. In order to preclude recurrence of such events, the following actions have been taken:

1. Establishment [ of a requirement' that HP personnel without previous steam generator work coverage experience receive mockup training in steam generator work coverage, prior to their assignment to this activity. This requirement will be incorporated in EH&S procedure 3.403 by 1/1/85.

2. Retraining of the HP Technician responsible for this violation, including mockup training, and his completion of a Peading Acknowledgement Form for EH&S Procedure 3 403.

3. A review of contractor and company health physics technicians compliance with EHS 2.006 was initiated to establish that a Reading Acknowledgement Form was completed by those individuals for EH&S 3.043. Contractor and health physics technicians who have not completed this form will not be allowed to perform the tasks governed by EH&S 3 403.

4. Appropriate disciplinary action was implemented.

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