IR 05000388/1989025
| ML17156B440 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/01/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| Shared Package | |
| ML17156B441 | List: |
| References | |
| EA-89-182, NUDOCS 8911080473 | |
| Download: ML17156B440 (4) | |
Text
November 1, 1989 Docket No.
50-388 License No.
NPF-22 EA 89-182 Pennsylvania Power 5 Light Company ATTN:
Mr. Harold W. Keiser Senior Vice President - Nuclear 2 North Ninth Street Al1entown, Pennsylvania 18101.
Gentlemen:
Subject:
NOTICE OF VIOLATION (NRC Inspection Report Number 50-388/89-25)
This letter refers to the special NRC inspection conducted on September 1-2, 1989 at the Susquehanna Steam Electric Station, Unit 2.
The inspection was conducted to review the circumstances associated with a radiological incident which occurred at the facility on August 31, 1989.
The incident involved a
contractor employee rece'iving an unplanned radiation exposure of approximately 470 millirem to the whole body and an unplanned exposure of approximately 3.4 rem to the skin of the whole body ( localized to the chest area) while performing reactor coolant sampling activities.
The unplanned exposure was identified by your staff and reported to the NRC.
During the inspection, the report of which was sent to you on September 14, 1989, violations of NRC requirements were identified.
On October 3, 1989, an enforcement conference was held with Mr. R.
G.
Byram, Plant Superintendent, and other members of your staff to discuss the violations, their causes and your corrective actions.
The incident occurred while the individual was obtaining a filter that had been collecting a sample of radioactive material from the reactor coolant for a fuel pin integrity project.
In order to obtain this sample, the individual was required to use sampling techniques not routinely used at Susquehanna.
Specifically, the contractor retrieved the filter from a sampling rig that was installed at the chemistry sampling station to collect the sample, and placed the filter in a plastic planchette.
The individual then placed the planchette in his shir t pocket without performing a survey of the filter even though the filter had been collecting a reactor coolant sample for approximately
hr s.
The same individual then proceeded to the chemistry laboratory and was exposed to the radioactive filter in his shirt pocket for approximately seven minutes.
Although the unplanned radiation exposure received by the individual was not in excess of regulatory limits, the violations, which are described in the enclosed Notice, are of concern to the NRC because adequate radiological con-trols over the performance of the work activity were not implemented, thereby creating a substantial potential for a radiation exposure in excess of regu-latory limits.
The violations that contributed to this unplanned exposure 8911080473 891101 PDR ADOCK 05000388
PNU OFFICIAL RECORD COPY SUSQUEHANNA - 0001.0.0 11/01/89 gee/
Pennsylvania Power 5 Light Company
included:
( 1) failure to perform radiation surveys of the sampling rig prior to disassembly of the rig and recovery of the sample; (2) failure to properly instruct the individuals (who were working in a restricted area)
in precautions or procedures to minimize radiation exposure; (3) failure to follow certain radiation protection procedures as required by the technical specifications; and (4) failure to establish a reactor coolant sampling procedure as required by the technical specifications.
Furthermore, the NRC is also concerned that the personnel did not perform frisking for contamination until returning to the chemistry laboratory, and the Radiation Work Permit used for this activity did not require any surveys to be made prior to handling or working with the samples.
In accordance with the "General Statement of Policy and Procedure for NRC, Enforcement Actions,"
CFR Part 2, Appendix C ( 1989) (Enforcement Policy),
these violations have been classified in the aggregate at Severity Level III because they created a substantial potential for radiation exposure in excess of regulatory limits, and because they demonstrate a lack of management oversight and attention to your radiation protection program, particularly to those activities involving the supervisory oversight of contractors.
Although a civil penalty is normally issued for a Severity Level III violation or problem, I have decided, after consultation with the Director, Office of Enforcement and the Deputy Executive Director for Nuclear Materials Safety, Safeguards and Operations Support, not to issue a civil penalty in this case because:
( 1) your staff identified, investigated and promptly reported the unplanned exposure to the NRC and, therefore, 50/o mitigation of the base civil penalty is warranted; and (2) your corrective actions, as presented at the enforcement conference (which included a detailed root cause analysis of the event by a multi-disciplined team, a review of the oversight of all on-site contractor groups, as well as extensive efforts in making the dose assignment to the individual), were considered prompt and comprehensive, and therefore, 50% mitigation of the base civil penalty is warranted.
The other mitigation and escalation factors (including your past performance in the radiation protection area)
were considered and no further adjustment was considered appropriate.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice of Violation (Notice) when preparing your response.
In your response, you should document the speci iic actions taken and any additional actions you plan to prevent recurrence.
In addition, your response should address NRC's concerns that personnel failed to perform frisking for contamination in a timely manner and that the Radiation Work Permit issued for the activity in question did not require surveys to be made prior to handling or working with radioactive samples.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether future NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
Furthermore, we emphasize that any recurrence of these violations may result in more significant enforcement action.
OFFICIAL RECORD COPY SUSQUEHANNA 0002.0.0 11/01/89
Pennsylvania Power
& Light Company
In accordance with Section 2.790 of the NRC's "Rules 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 Room.
The responses directed by this letter and the enclosed Notice 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.96-511.
Sincerely, Qy]r 0n 1 8i~~g gy William T. Russell Regional Administrator Enclosure:
Notice of Violation cc w/encl:
A.
R. Sabol, Manager, Nuclear Quality Assurance E. A. Heckman, Licensing Group Supervisor R.
G. Bryam, Superintendent of Plant-SSES S.
B. Ungerer, Manager, Joint Generation Projects Department J.
D. Decker, Nuclear Services Manager, General Electric Co.
B. A. Snapp, Esquire, Assistant Corporate Counsel H.
D. Woodeshick, Special Office of the President J.
C. Tilton, III, Allegheny Electric Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Pennsylvania OFFICIAL RECORD COPY SUSQUEHANNA " 0003.0.0 11/01/89
Pennsylvania Power
& Light Company
DISTRIBUTION:
PDR LPDR SECY CA H.
Thompson, DEDS J. Taylor, DEDR J.
Lieberman, OE W. Russell, RI D. Holody, RI J.
Goldberg, OGC T. Murley, NRR J. Partlow, NRR S. McNeil, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV Resident Inspector F.
Ingram, GPA/PA M. Malsch, OIG B. Hayes, OI E. Jordan, AEOD J.
DelMedico, OE OE:Chron OE:EA DCS Region I Docket Room (with Management Assistant, DRMA P.
Swetland, DRP M. Thadani, NRR J.
Dyer, EDO concurrences)
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