IR 05000280/1988010
| ML18152B003 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/13/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18152B004 | List: |
| References | |
| NUDOCS 8806240058 | |
| Download: ML18152B003 (4) | |
Text
Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 EA 88-114 JUN 13 1988 Virginia Electric and Power Company
- ATTN
Mr. D.S. Cruden, Vice President, v
Nuclear Operations P. 0. Box 26666 Richmond, VA 23261 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by C. H. Bassett at the Surry facility on March 5-11 and 23-25, 198 The inspection included a review of the circumstances surrounding a significant potential for overexposure of personnel during the incore detector maintenance that occurred in Unit 2 containment on March 3, 198 The report documenting this inspection was sent to you by letter dated April 18, 198 As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the*
inspection findings were discussed in an Enforcement Conference held on April 21, 198 The letter summarizing this Conference was sent to you on May 3, 198 The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty involved a failure to adequately evaluate the radiation hazards present during work on an incore detector; inadequate procedures for freeing the incore detector and for briefing those involved in the work and failure to conduct operations in accordance with approved procedure The events or circumstances that resulted in these violations included entrance into Unit 2 containment on March 3, 1988, by three
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individuals to perform maintenance work on the 11A 11 drive unit incore detector and associated cable. During work to free the incore detector, which had become stuck in the core on February 8, 1988, and could not be retracted from the thimble tube, one of the workers pulled over 100 feet of cable through the polar crane wall penetration and into their work are As a result of these actions, the detector was pulled to a point just inside of the crane wall or biological shield adjacent to the workers* location while approximately three feet of activated cable were pulled into the work area itself. The radiation levels measured in the vicinity of the workers just prior to evacuation of the work area were in excess of 1,000 rem per hour.* Although the resultant maximum doses assigned to the workers was only 1.03 rem to the whole body and 1.27 rem to the extremities, which are less than the NRC limits, it was fortuitous that no one involved received excessive exposur The NRC is concerned that these 8806240058 880613 PDR ADOCK 05000280 Q
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Virginia Electric and Power Company - 2 -
JUN 1 3 1988 violations collectively created a significant potential for personnel exposures in excess of NRC limit During the Enforcement Conference, you indicated that the root cause of the incident was that none of the personnel involved in planning, reviewing, authorizing, or performing the work were aware that the detector drive cable could be activated and therefore could produce high radiation levels. While the plant staff's lack of awareness of the cable activation and the associated radiation hazards may have contributed to the event, it is the NRC's position that the event resulted from a breakdown in the administrative and management systems which are in place to prevent such an occurrence. This breakdown is evidenced by:
(1) inadequate communication in that Station Operations failed to inform Instrumentation and Control (I&C) personnel of the plant status following flux mapping in February 1988 (i.e., the detector was stuck*in the core) and I&C personnel failed to ask the pertinent questions which would have led to an awareness of the problem~ (2) I&C, Health Physics (HP) and the Shift Supervisor considered this unusual maintenance performed inside a sub-atmospheric containment as routine, (3) exclusion of the Station Nuclear Safety and Operating Committee (SNSOC) from the review process, due to an erroneous determination that the procedural change under which the work was performed did not change the intent of the procedure, (4) the use of a standing radiation work permit (RWP) that was intended for minor maintenance and inspections rather than using a more specific Special RWP, (5) failure to perform a critical assessment of the potential hazards involved in the work evolution, (6) the technicians performing the maintenance went beyond the original scope and intent of the procedural change for freeing the stuck detector, and (7) lack of involvement of Station management in the pre-work evaluation. With regard to item (3) above, we note that on February 2, 1988, your administrative policies concerning changes to procedures were modified to specify that any change to the purpose, initial conditions, or precautions. and limitations sections are defined as a change of intent. This was a corrective action in response to a violation contained in Inspection Report 50-280, 281/88-01. This corrective action was either inadequate or inadequately implemented to prevent this violation from occurrin To emphasize the serious nature of this event and the need for improvements in the administration and control by station management of the systems and programs implemented to ensure the safe performance of licensed activities and adherence to NRC requirements, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional *operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of One Hundred Thousand Dollars ($100,000) for the violations described in the enclosed Notic In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C (1988) (Enforcement Policy),
the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III proble The base value of a civil penalty for a Severity Level III violation is $50,00 The escalation and mitigation factors were considered, and the base civil penalty amount has been increased by 100 percent based on the following considerations:
(a) with respect to assessment of the problem and management involvement following the event, insufficient consideration initially was given to the significance of what had
Virginia Electric and Power Company - 3 -
JUN131988 occurred, which resulted in your lack of proper response and investigation until motivated by the NR The investigation that was finally conducted was incomplete in that the true root cause had not been properly assessed at the time of the Enforcement Conferenc Without a determination of the root cause, effective and lasting corrective actions cannot be complete (b) There has been a pattern of poor performance at Surry with regard to procedural complianc NRC Inspection Reports Nos. 50-280/86-20 and 50-281/86-20; 86-42; 87-03; 87-05; 87-21; 87-24; 87-35 and 88-01 each document one or more examples of failure to follow operation/maintenance or health physics procedure Because of your lack of prompt response and investigation of the event, your inadequate corrective actions to prevent recurrence based on an apparent incomplete investigation, and your performance with respect to procedural compliance in the recent past, the civil penalty was escalated 100 percen You are required to respond to this letter and the enclosed Notice and should follow the instructions specified therein when preparing your respons In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC 1s 11Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty j
c w/encl:
- L. Benson, Sta ti on Manager
.. E. Hardwick, Manager - Nuclear v Programs and Licensing
Sincerely, ORIGINAL SIGNED BY:
J. NELSON GRACE J. Nelson Grace Regional Administrator
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Virginia Electric and Power Company
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