ML20236R577

Ack Receipt of 870923 Response to Violations Noted in Insp Rept 50-293/87-29 & NRC .Corrective Actions Will Be Examined During Future Insp

ML20236R577
Person / Time
Site:	Pilgrim
Issue date:	11/17/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8711230366
Download: ML20236R577 (2)

See also: IR 05000293/1987029

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NOV 17 1987

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Docket No. 50-293

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Boston Edison Company'M/C Nuclear

ATTN:

Ralph G. Bird

Senior Vice President - Nuclear

800 Boylston Street

Boston, Massachusetts 02199

Gentlemen:

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Subject: Inspection 50-293/87-29

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This refers to your letter dated September 23, 1987, in response to our letter

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dated Augur.t 24, 1987.

Thank you for informing us of the corrective and preventive actions documented

in your letter. These actions will be examined during a future inspection of

your licensed program.

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Your cooperation with us is appreciated.

Sincerely,

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Odginal Signed By:

Ronald R. Bellamy

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871123036687g7

Thomas T. Martin, Director

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PDR

ADOCK O

PDR

Division of Radiation Safety

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.and Safeguards

cc:

K. P. Roberts, Station Manger

Paul Levy, Chairman, Department of Public Utilities

Chairman, Board of Selectmen

J. D. Keyes, Boston Edison Regulatory Affairs

E. D. Robinson, Nuclear Information Manager

R. N. Swanson, Nuclear Engineering Department Manager

The Honorable E. J. Markey

Plymouth Civil Defense Director

Senator Edward P. Kirby

The Honorable Peter V. Forman

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Sharon Pollard, Secretary of Energy Resources

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Rachel Shimshak, MASSPIRG

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Public'DocumentRoom(PDR)

Local Public Document Room (LPDR)

Nuclear Safety. Information Center (NSIC)

NRC Resident Inspector

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Commonwealth of Massachusetts (2)

0FFICIAL RECORD COPY

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Boston Edison Company

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NOV 17 1967

M/C Nuclear

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bcc:

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Region I Docket Room (with concurrences)

Management Assistant, DRMA

Section Chief, DRP

R. Wessman, PM, NRR

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Robert J. Bores, DRSS

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BOSTON EDISON

Executiw Offices

800 Boyis'en Street

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Boston, Massachusetts 02199

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Ralph G. Bird

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Senior Vice President - Nuclear

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September 23,1987

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BECo Ltr. #87- 154

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U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Hashington, DC 20555

License No. DPR-35

Docket No. 50-293

Subject: NRC Inspection Report 50-293/87-29

Dear Sir:

Attaciled is Boston Edison Company's response to the Notice of Violation

contained in the subject insoection report.

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

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Attachment

Regional Administrator, Region I

O.S. Nuclear Regulatory Commission

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631 Park Avenue

King of Prussia, PA 19406

Director, Office of Inspection

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and Enforcement

U.S. Nuclear Regulatory Commission

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Hashington, DC 20555

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'Sr. Resident. Inspector

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ATTACHMENT 1

Boston Edison Company

Docket No. 50-293

Pilgrim Nuclear Power Station

License No. OPR-35

Notice of Violation

Technical Specification 6.11 requires that procedures for personnel radiation

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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

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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 Pump Heat Exchanger Cubicle, a

posted, locked High Radiation Area, without the radiation survey meter

required to be used by the applicable radiation work permit (RHP No. 87E-4).

The individual had signed the RWP indicating his understanding of the RWP's

requirements.

Resoonse

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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

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operator had properly signed the Radiation Hork Permit (RHP) briefing

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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.

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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

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actual time in the RHCU Hx room was approximately 10-15 minutes based on

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interviews with him. He received a radiation exposure of 5 millirem while

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in the room based on his pocket dosimetry reading.

No other high

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radiation areas had been entered by the operator that day prior to the

event.

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

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This RWP allows authorized operations personnel access to radiation areas

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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ATTACHMENT:1-(Cont.)

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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

meter in his locker while not at work and normally dons the survey meter

prior to reporting to the. control room to receive his work assignment.

.The operator stated that he simply' forgot to don his survey. meter on that.

occasion.

This instance demonstrated his complacency in the use of the survey

instrument.

If the operator had been in the habit of using the survey

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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

was not in use at that time.

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The operator acknowledged full responsibility for his error and stated

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that the procedures were clear on this requirement and that he had been

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specifically trained on the purpose and use of the survey meter.

3.

Immediate Corrective Actions Taken:

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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

RWP's. A Radiological Occurrence Report was initiated at that time to-

document the event.

4.

Corrective Actions Taken to Avoid Future Violations:

The Nuclear Watch Engineer and the Operations Section Manager discussed

the event with the involved i.ndividual who was given a written reprimand.

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During discussion of the incident, the individual demonstrated that he

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understood the severity of the infraction and the need to follow all

station procedures.

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The Operations Section Manager briefed the Operations personnel on the

significance of the event and the need to follow radiological protection

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requiremn'ts.

This issue was also addressed in the operations night order

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

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memo to all operations personnel.

The memo stressed that operations

personnel have been provided with a survey instrument to alert them to

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abnormal radiological conditions and to assist them in maintaining their

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radiation exposures _ALARA. . It was also stressed that BECo will not

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tolerate complacency regarding an employee's Health Physics

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responsibilities, nor any other responsibilities,

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ATTACHMENT 1 (Cont.)

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To further address this issue, general guidance has been provided to the

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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

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Monitor Watch Program is a process by which work activities are routinely

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observed to assess performance.

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This event is an isolated instance of non-compliance by one individual, A

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review of the event indicates that adequate procedural controls are in

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place for extended RWP's, and the requirement to carry a survey meter was

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clearly indicated on the RWP briefing sheet.

The disciplinary action, in

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combination with the instructional and directive communications, are

believed sufficient to preclude further instances of non-conformance by

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the involved individual. Other operations personnel authorized to use

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

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following radiological protection requirements.

In addition, the planned

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observations of work activities in accordance with the established

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monitoring program will provide early identification of complacency if it

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develops.

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5.

Date of Full Compliance-

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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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