IR 05000387/2013013
| ML13269A254 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/25/2013 |
| From: | Darrell Roberts Division Reactor Projects I |
| To: | Rausch T Susquehanna |
| BOWER, FRED | |
| References | |
| EA-12-180, EA-13-037, EA-13-140, OI 1-2011-030, OI 1-2012-012, OI 1-2012-043 IR-13-013 | |
| Download: ML13269A254 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 25, 2013
SUBJECT:
NRC INVESTIGATION REPORT NOS. 1-2012-012, 1-2012-043, 1-2011-030, AND NRC INSPECTION REPORT NO. 05000387;388/2013013; AND NOTICE OF VIOLATION
Dear Mr. Rausch:
This letter refers to three investigations completed within the past year by the U. S. Nuclear Regulatory Commission (NRC) Office of Investigations (OI) conducted at the PPL Susquehanna, LLC (PPL) Susquehanna Steam Electric Station (SSES). These investigations each reviewed the circumstances associated with apparent violations of PPL procedural requirements pertaining to the SSES radiation protection program.
The first OI investigation (1-2012-012), which was completed on August 23, 2012, examined whether a contract roofer at SSES deliberately failed to follow an SSES procedure pertaining to personnel contamination monitoring. Based on the evidence gathered during the OI investigation, the NRC concluded that on October 11, 2011, the contract roofer willfully, with careless disregard, failed to contact the SSES Health Physics (HP) department after receiving two radiation portal monitor (PM) alarms when exiting the SSES protected area (PA).
Specifically, on the specified occasion, after the contract roofer received a second alarm on a PM at the SSES PA exit, one of the NRC resident inspector staff, while exiting the SSES PA, observed the contractor and reminded him of the requirement to contact HP. Because the contract roofer could not locate a telephone in the area, his coworker (who had successfully passed the PM and exited the PA) approached a SSES security officer stationed at the security control point, purportedly to request assistance with contacting the HP department. As a result of a likely miscommunication, the HP department was not contacted and the contract roofer used a different PM and exited the PA after not receiving an alarm, even though, in accordance with his testimony to OI, the contract roofer knew he was supposed to contact the HP department and wait for assistance. Although the contract roofers coworker testified to OI that a security officer at the security control point had told him to have the contract roofer try another PM, OI, through its investigation, was unable to corroborate that any security officer provided such direction. The contract roofers actions caused PPL to violate the SSES operating license.
The violation is described in the enclosed Notice of Violation (Notice). Because this violation was caused by the willful action of the contract roofer, it was evaluated under the NRCs traditional enforcement process using the factors set forth in Section 2.3.2 of the NRC Enforcement Policy. After careful consideration of these factors, the NRC concluded that this violation should be classified at Severity Level IV. In reaching this decision, the NRC considered that the significance of the underlying violation was minor because the individual did clear a subsequent monitor and the issue did not involve the spread of radioactive contamination into an uncontrolled area. However, the NRC decided to increase the significance of this violation since it was willful and the NRC regulatory program is based, in part, on licensees and their contractors acting with integrity. Because the violation was identified by the NRC, it is being cited in the enclosed Notice in accordance with Section 2.3.2 of the NRC Enforcement Policy.
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in this letter.
Regarding the corrective actions, PPL: (1) conducted an internal investigation to determine the cause and appropriate corrective actions; (2) took disciplinary action against the contractor; and, (3) recommended installing: (i) a means of communication (i.e., telephone) at the PA exit location to facilitate contacting HP; and, (ii) cameras in the vicinity of the PMs to facilitate monitoring for compliance. Therefore, you are not required to respond to this violation unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
The second OI investigation (1-2012-043), which was completed on February 12, 2013, examined whether: (1) a contract carpenter at SSES deliberately failed to follow an SSES procedure when he moved a high radiation area (HRA) posting; and, (2) the contractor company attempted to cover up its employees actions. Based on the evidence gathered during the OI investigation, the NRC concluded that on March 30, 2012, the contract carpenter deliberately moved an HRA posting; however, insufficient evidence was found to support that the contract carpenters company attempted to cover-up the employees actions. Specifically, on the specified date, the contract carpenter was assigned, along with some other carpenters, to erect a scaffold in the isolation phase bus area of the SSES Turbine Building. An area near the job location was roped off and a posting on a stanchion indicated that a HRA existed in the overhead. After an RP technician who had accompanied the workers to conduct a radiation survey left, the contract carpenter moved the stanchion and roping out of the way to make room for the scaffold. When there was still not enough room to build the scaffold, the materials were dismantled and eventually removed from the area. The following day, the contract carpenters foreman documented the issue in a condition report (CR) and PPL initiated an investigation, during which the contract carpenter admitted to moving the posting in spite of knowing that he was not allowed to do so.
The third OI investigation (1-2011-030), which was completed on May 1, 2013, examined whether licensee and contract employees at SSES deliberately violated SSES procedural requirements pertaining to Radiologically Controlled Area (RCA) egress. Based on the evidence gathered during the OI investigation, the NRC has concluded that one contract employee deliberately and one contract employee willfully (with careless disregard) violated SSES RCA egress requirements. Specifically, on April 6, 2011, a contract insulator, after receiving an initial contamination alarm from his hardhat when using a personal contamination monitor (PCM) prior to exiting the RCA, appropriately made a second monitoring attempt, but deliberately leaned his head out of the PCM to avoid receiving a second alarm. The insulator then exited the RCA although he hadnt been appropriately monitored for radioactive contamination. Additionally, on April 7, 2011, a contract electrician willfully used an inoperable PM while exiting the RCA. Specifically, after receiving no alarms from a PCM, the electrician appropriately entered a PM, but noticed that the volume seemed lower than normal and that no lights were on when he exited. The electrician testified to OI that he believed the monitor had worked properly and, therefore exited the RCA. However, as identified by PPL, the PM was, in fact, inoperable, although it was not labeled as being out of service. The NRC determined that the electrician should have assessed why the volume was low and the lights were out before exiting the RCA, and that he should not have assumed the monitor was working.
The contractors actions caused PPL to violate the SSES operating license. Specifically, SSES License Condition 2.C(2) requires that PPL will operate SSES in accordance with the TS.
SSES TS 5.4.1, in part, requires that written procedures shall be implemented covering the procedures recommended in RG 1.33, Rev 2, App A, February 1978. RG 1.33, Rev 2, App A, recommends the establishment of radiation protection procedures for access control to radiation areas and for contamination control. Pertaining to the second OI Investigation (1-2012-043),
PPL implementing procedure NDAP-QA-0626, Radiologically Controlled Area Access and Radiation Work Permit System states that individuals are not allowed to move radiological postings, barricades, and barriers and to contact HP if there is a need to have any of these items moved or modified. Contrary to the above, on March 30, 2012, a contract carpenter did not contact the SSES HP department and, instead, moved an HRA posting on his own.
Pertaining to the third OI Investigation (1-2011-030), PPL implementing procedure NDAP-QA-0623, Radiation Protection Standards and Responsibilities requires individuals to not leave the RCA until they can successfully pass through a PCM and a PM. Contrary to the above, on April 6 and April 7, 2011, contract employees left the SSES RCA without successfully passing through both a PCM and a PM.
Because the violations associated with the second and third OI investigations were caused by the willful actions of contract employees, they were evaluated under the NRCs traditional enforcement process using the factors set forth in Section 2.3.2 of the NRC Enforcement Policy.
After careful consideration of these factors, the NRC concluded that these violations should be classified at Severity Level IV. In reaching this decision, the NRC considered that the significance of the underlying violations was minor because: (1) pertaining to OI investigation 1-2012-043, the HRA was conservatively posted and physical access into the actual HRA overhead did not occur; and, (2) pertaining to OI investigation 1-2011-030, both individuals successfully cleared other contamination monitors and the issue did not involve the spread of radioactive contamination into an uncontrolled area. However, the NRC decided to increase the significance of the violations since they were willful and the NRC regulatory program is based, in part, on licensees and their contractors acting with integrity.
In accordance with Section 2.3.2 of the Enforcement Policy, and with the approval of the Director, Office of Enforcement, each issue has been characterized as a non-cited violation (NCV 05000387;05000388/2013013-01 , Unauthorized Movement of a High Radiation Area Boundary and NCV 05000387;05000388/2013013-02, Failure to Follow RCA Egress Requirements), because: (1) PPL placed the issues in its CAP (CR Nos. 1550619 & 1390434);
(2) PPL restored compliance by verifying the posting was properly replaced and that no contamination had spread to uncontrolled areas; (3) the violations were not repetitive as a result of inadequate corrective action; and, (4) although the violations were willful, (a) PPL identified the violations, and took significant corrective and remedial actions (including disciplinary actions against the involved individuals, developing HP staffing requirements for RCA access and egress locations, and instituting performance monthly performance monitoring of radiation worker practices); (b) the violations involved the acts of individuals who were not considered licensee officials with oversight of regulated activities as defined in the Enforcement Policy; and, (c) the violations did not involve a lack of management oversight and were the result of the isolated actions of the contract employees.
The NRC has concluded that information regarding the reasons for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the dates when full compliance was achieved is already adequately addressed on the docket in this letter. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. If you contest any of the violations described in this letter, or their significance, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at Susquehanna.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions regarding this letter, please contact Fred Bower at 610-337-5200.
Sincerely,
/RA/
Darrell J. Roberts, Director Division of Reactor Projects Region I Docket No. 50-387; 50-388 License No. NPF-14; NPF-22 Enclosure: Notice of Violation cc: Distribution via ListServ egress locations, and instituting performance monthly performance monitoring of radiation worker practices); (b) the violations involved the acts of individuals who were not considered licensee officials with oversight of regulated activities as defined in the Enforcement Policy; and, (c) the violations did not involve a lack of management oversight and were the result of the isolated actions of the contract employees.
The NRC has concluded that information regarding the reasons for these violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the dates when full compliance was achieved is already adequately addressed on the docket in this letter. Therefore, you are not required to respond to this letter unless the description herein does not accurately reflect your corrective actions or your position. If you contest any of the violations described in this letter, or their significance, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Senior Resident Inspector at Susquehanna.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response, if you choose to provide one, will be available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Should you have any questions regarding this letter, please contact Fred Bower at 610-337-5200.
Sincerely,
/RA/
Darrell J. Roberts, Director Division of Reactor Projects Region I Docket No. 50-387; 50-388 License No. NPF-14; NPF-22 Enclosure: Notice of Violation cc: Distribution via ListServ DOC NAME: S:\Enf-allg\Enforcement\Proposed-Actions\Region1\Susquehanna HP Proc NOV-IV EA-12-180.docx ADAMS Accession No.: ML13269A254 X Non-Sensitive X Publicly Available X SUNSI Review/ MMM*
Sensitive Non-Publicly Available OFFICE RI/ORA RI/DRP RI/DRS RI/DRS RI/OI RI/ORA J Noggle/ T NAME M McLaughlin/ MMM* M Gray/ MKG* R Lorson/ RKL* J Teator/ JAT* T Stokes/ TLS*
Moslak for DATE 08/07/13 08/20/13 08/21/13 08/28/13 08/22/13 008/28/13 OFFICE RI/ORA RI/DRP NAME D Holody/ DJH* D Roberts/ DJR DATE 09/03/13 09/ 25 /13
- Concurrence on previous sheet Distribution:
W. Dean, RI, RA D. Lew, DRA D. Roberts, DRP M. Scott, DRP R. Lorson, DRS J. Trapp, DRS J. Noggle, DRS M. Gray, DRP F. Bower, DRP D. Screnci / N. Sheehan, OPA T. Stokes, OGC D. Holody, RI R. Urban, RI M. McLaughlin, RI S. Barber, RI N. McNamara/ D. Tifft, RI P. Finney, SRI J. Greives, RI S. Farrell, AA C. ODaniell, RI R. Carpenter, OE J. Bowen, NRR M. Holmes, OI J. Teator, OI M. Lemoncelli, OGC M. Simon, OGC M. Clark, OGC R1DRPMail Resource ROPreports Resource RidsNrrPMSusquehanna Resource R1 OE Files (with concurrences)
NOTICE OF VIOLATION PPL Susquehanna, LLC Docket Nos. 50-387 & 50-388 Susquehanna Steam Electric Station License Nos. NPF-14 & NPF-22 EA-2012-180 During a U.S. Nuclear Regulatory Commission (NRC) investigation by the NRC Office of Investigations completed on August 23, 2012, a violation of NRC requirements was identified.
In accordance with the NRC Enforcement Policy, the violation is listed below:
Condition 2.C(2) of the Susquehanna Steam Electric Stations Renewed Facility Operating Licenses subjects PPL Susquehanna, LLC to the additional conditions specified or incorporated in the Technical Specifications.
Susquehanna Steam Electric Station Technical Specification 5.4.1.a requires that written procedures be established, implemented, and maintained covering the activities recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978, Item 7.e recommends the establishment of written Radiation Protection procedures for personnel monitoring activities.
PPL Susquehanna, LLC implementing procedure, NDAP-QA-0627, Radiation Protection Program requires personnel who receive a second alarm on any monitor to stay in the area and contact Health Physics.
Contrary to the above, when attempting to exit the Susquehanna Steam Electric Station Protected Area (PA) on October 11, 2011, a contract employee who received a second alarm on a radiation portal monitor did not stay in the area and contact Health Physics.
Instead, the individual (through a co-worker) contacted Security, used a different portal monitor, and then exited the PA after the second monitor did not alarm.
This is a Severity Level IV violation (Section 6.7)
The NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance was achieved is already adequately addressed on the docket in the letter transmitting this Notice of Violation (Notice). Therefore, you are not required to respond to this Notice unless the description herein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation; EA-12-180," and send your response to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region I, 2100 Renaissance Boulevard, Suite 100, King of Prussia, PA 19406, and a copy to the NRC Resident Inspector at Susquehanna Steam Electric Station, within 30 days of the date of the letter transmitting this Notice.
Notice of Violation 2 If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room and from the NRCs Agency-wide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days of receipt.
Dated this 25th day of September, 2013