ML20006E220
| ML20006E220 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/09/1990 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 4410-90-L-0007, 4410-90-L-7, NUDOCS 9002220331 | |
| Download: ML20006E220 (6) | |
Text
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GPU Nuclear Corporation I
g gf Post Office Box 480 l
Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 i
F TELEX 84 2386 l
Writer's Direct Dial Number:
(717) 948-8400 I
February 9, 1990 l
4410-90-L-0007/Oll6P i
j US Nuclear Regulatory Commission
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Office of Enforcerrent Washington,.OC.
20555 l
p Attention: James Liebeman Thme Mile Islard Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 l
Docket No. 50-320
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Response to Notice of Violation and
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Proposed Imposition of Civil Penalty
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Dear Mr. Liebeman:
l This m sponds to NRC letter, dated January 11, 1990, William T. Russell, Regional Administrator, USNRC Region I, to GPU Nuclear Corporation which forwarded a Notice of Violation and Proposed Imposition of Civil Penalty. The NRC action is based on tha finding 3 ^f an inspection by NRC Region I which r
' concluded that on Septemer 25,198Y, a contractor employee received an i
. occupational exposum to an extumity in excess of the limits of 10 TR
.20.101(a) and that necessary and rea,onable radiation surveys were not made in accordance with 10 TR 20.201(b). GPU Nuclear initially informed the NRC Senior Resident Inspector of this incident on September 27, 1989.
GPU Nuclear agmes that the violation did occur and will forward payment of the proposed fine of $50,000 under separate cover.
' A second Notice 'of-Violation was issued involving the failum to report within 24-hours of discovery an event that may have caused an exposure to the hanos
. of an individual in excess of 75 rems. A civil penalty was not assessed for this violatiun.
- The attachment to this letter provides the GPU Nuclear response to both Notices of-Violation.
9002220331 900209
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GPU Nuclear Corporation is a subsidiary of the General Public Utlia.n Corporation
- 4. Lieberman February 9, 1990 4410-904.-0007 Page 8 GPU Nuclear is disappointed that the NRC Staff found no basis to mitigate the proposed fine based on ten years of outstanding radiological performance at i
I TMI-2 as recognized by the Commission and the independent TMI-2 Safety Advisory Board. This citation docunents the second incident resulting in exposures in excess of 10 TR 20 limits during the ten years and over 2 million person-hours of difficult and unprecedented radiological work.
The previous incident in which such an exposure was received occurred in 1979.
We believe there is a misperception that our corrective actions focused exclusively on the Decontamination Facility.
While the immediate corrective actions appropriately focused on the Decontamination Facility, the long-term corrective actions addressed the entire TMI-2 facility. These corrective actions included the appointment of a radiological work practices task force l
to review this event and recommend plant-wide corrective actions, as appropriate. Radiation workers were counseled again about the reouirenents for handling fuel debris. Finally, shift turnover for the Radiological Controls Department was enhanced through improved communications. All existing Radiation Work Permits have been reviewed and updated, as necessary, to ensure that' they provide the appropriate level of specificity.
In summary, we believe GPU Nuclear has maintained an excellent exposure record over the past 10 years. The event was the first overexposure in ten years, no adverse programmatic trends have been identified, ano strong and extensive measures were taken to prevent recurrence.
Sincerely, l
Mh d M. 8. Roche Director, TMI-2 EDS/ emf cc: Document Control Desk W. T. Russell - Regional Administrator, Region I J. F. Stolz - Director, Plant Directorate I-A L. H. Thonus - Project Manager, THI Site F. I. Young - Senior Resident Inspector, TMI d-
i ATTACHENT 4410-90-L-0007 1.
NRC NOTICC CF VIQ. ATION A.
10 CFR 20.101(a) reouires, in pa'rt, that no licensee possess, use or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar OJarter a to!31 occupational oose to the hands in excess of 18.75 rem.
Contrary to the above, on September 25, 1989, a contractor employee working in the Decontamination / Burn / Flush Facility (Facility) located in the Unit 2 Reactor Building (a restricted area) received occupational radiation exposures to the skin of the left hana of approximately 55 rems and 8 rems to the skin of the right hand while perfoming clean-up and oecontamination activities.
D.
10 CFR 20.201(b) reouires, in part that each licensee make or cause to be made surveys as (1) may be necessary to comply with the regulations of 10 CFR Part 20, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20,201(a) defines a survey, in part, as an evaluation of the radiation hazards incident to the production, use, release, disposal of presence of radioactive materials or other sourtes of radiation under a specific set of conditions. When appropriate, such an evaluation includes a physical survey of the location of material and eoulpnent and measurements of levels of radiation present.
Contrary to the above, on September 25, 1989, necessary and reasonable surveys were not made, as evidenced by the following examples:
1.
a post-work radiation survey perfomed by a Radiological Controls Technician (RCT) in the Facility on September 22, 1989, identified and documented high beta contamination levels on the Facility grating; however, prior to the resumption of work in the 7
Facility en September 25, 1989, the Group Radiological Controls Supervisor failed to perform an adeouate evaluation, as he was unaware of, and, thus, did not consider this information when evaluating the radiation hazards present when providing the pre-job brief to the contractor individuals who would be working in the Facility; and 2.
the responsible staff did not anticipate the problems that would be caused by leaving items in the decontamination room from the previous activities on September 22, 1989, that could contain or shield fuel fragments. Furthemore, the responsible staff did not evaluate the applicable procedures, radiation survey technioues, and training for possible modification to take these probloms into account during the pre-job survey and use of the Facility.
These violations have been classified in the aggregate as a Severity Level III problem (Supplement IV). 0116P
ATTACHENT 4410-904.-0007 I.
GPU NUC1_ EAR RESPONSE GPU Nuclear acknowledges that the event cited above did occur. GPU Nuclear letters 4410-89-L-Olli dated October 25,1989, and 4410-89-L-0122 dated December 6,1989, submitted Licensee Event Report (LER) 89-06 and the LER supplenental report, respectively, for this event. These letters i
described the causes of the violation and the corrective actions taken to avoid similar occurrences. All long-tem corrective actions identified in the LER supplenental report have been conpleted. In addition, tre reconnendations resulting from the radiological work practices task force review, noted in the LER supplenental report, have been completed except for the post-defueling radiological program change (Item 1.) which will be implenented upon entry into TMI-2 Facility Mode 2.
The other L'
reconnendations, which address necessary facility-wide'improvenents in radiological work practices, have been implenented as follows:
i A.
"2.
Upgrade the physical condition of work areas where appropriate."
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All material was removed from the Decon Flush Facility ana the entire facility was decontaminated. A f ormal inventory control program has 8
been establishea for the facility with storage of materials no longer permitted.
In addition, design changes have been accomplished to ameliorate the steam environnent extant at the time of the event.
Finally, the physical condition of other areas of the Reactor Building was improved.
B.
"3.
Review all existing and future RWPs to assure they provice an appropriate level of specificity."
All existing Radiation Work Permits (RWPs) have been reviewed ano updated, as necessary, to ensure that they provide the appropriate level of specificity. Due to the nature of RWP construction (i.e.,
using existing RWPs formats as models for future RWPs), this action ensures that future RWPs will be appropriately specific.
In addition, a new Radiation Review was implemented and the RWP duration for the Decon Flush Facility was shortened to accommodate changing conditions.
C.
"4.
Assure that official logs record significant operational, radiological, and industrial safety events / conditions and reouire 1
review of these logs."
l TMI-2 administrative procedures reouire the recording of significant operational, radiological, and industrial safety events / conditions; on-coming shif t personnel are reouired to review these logs.
L Further corrective cetions initiated as a result of this event included improvements in shif t turnover communication in the Radiological Controls Departnent.
l 0116P
ATTACHMENT c,
4410-90-L-0007 In addition to tre above corrective actions, nunerous nenoranda have been written to radiation workers reinforcing:
o the potential for changing work conditions; o
tre reed to know the RWP reouinnents; heightered awamress of the potential dangers inteIent in their work; o
o tte reed for forthright reporting of issues and events; and o
that cleanup is part of the job and must be completed to finish work.
It is noteworthy that the Corrective actions / task force recontrerdations, L
as implenented, affect the entire TMI-2 facility and not just the Decontamination Facility. Full compliance will be achieved af ter entry into Facility Mode 2 wten the final recomnercation of the task force is implemented.
II. NRC NOTICE OF VIQ.ATION 10 CFR 20.403(b) and (d) reouire, in part, that a licensee within 24-hours of discovery of the event, report to the NRC Operations Control Center any event involving licensed material possessed by the licensee that may have caused or threatens to cause exposure of the feet, ankles, hand, or forearms of any individual to 75 rems or more of radiation.
Contrary to the above, on September 28, 1989, the licensee detemined that an event involving licensed material (described in violation A of Section I of this Notice) may have caused or threatered to cause an exposure to tre hands of one individual in an amount in excess of 75 rems; however, the NRC Operations Control Center was not notified of the event until October 6, 1989.
This is a Severity Level IV Violation (Supplenent IV).
GPU NUQ EAR RESPONSE GPU Nuclear acknowledges that the report reouired when exposures may exceed 75 rem was not formally communicated to the NRC Operations Control Center until October 6,1989. As reported to the NRC at the November 22, 1989, Enforcement Conference, the final calculated dose to the worker was 55 rads. GPU Nuclear had been open and conrnunicative with the NRC since the discovery of the event.
Continuing discussions were held with NRC Site personnel and NRC Region I representatives beginning on September 27, 1989. An NRC Region I technical expert was apprised of the extensive, complex assessment being conducted as part of this incident investigation and was actually present at the site on September 28, 1989 and October 12-13, 1989.
It was GPU Nuclear's intent to provice an early, tinely notification to NRC of the possibility of an exposure in excess of the 10 CFR 20 limits, a continuing update as the complex dose assessment proceeded, and tinely, formal notification when and if the dose assessnent indicated that there may have been an exposure in excess of 75 rem. Formal notification to the NRC, in accordance with 10 TR Part 20.403(b), was made on October 6,1989, within three hours of concluding that the extremity dose may have exceeded 75 rem.
I Oll6P
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ATTACHMENT l
cu 4410-90-L-0007 This was 12 days af ter the incident because:
- 1) the doses calculated for the incident varied significantly from day-to-day early in the investigation (i.e., doses of up to 300 rad Beta to much less than 75 rad Beta) as new information was determined through formal investigation and incorporated into the complex dose assessnent algorithm. These changes were occassioned in large part by differences in the description of the event as reported by the participants. Our past experience has been that initial dose assessnents tend to produce very high estimates of dose (i.e., bounding all scenarios) and routinely are reduced significantly in reporting the results of the final dose assessnents as was the case in this event (i.e., the final dose of 55 rads would not have been reportable under this reouirenent); 2) GPU Nuclear sought to clarify the details of the event through a formal investigation by the TMI Security Departnent; 3) a re-enactment of the event was reouired to determine by c
tine and motion studies the duration of the incident exposures as well as the exact details of the occurrence; and 4) it was considered to be in the best interest of the workers to ensure the data reported was as 1
accurate as the recreation of the conplex incident would permit so as to avoid undue stress on the workers.
Retrospectively, it is apparent that GPU Nuclear did not apply a sufficiently broad interpretation to the relevant regulation (10 CFR Part 20.403(b)) at the tine of our initial determination of reportability of the event. Based on NRC's interpretation of the rule, as presented in NRC Inspection Report 89-09 and the January 11, 1990, Notice of Violation, it is apparent that the rule could be considered applicable at several milestones in the post-incident investigation. Had THI-2 been note experienced.in the interpretation and application of this rule, we probably would have determined the applicability of the reporting reouirement and effected a formal report much earlier. Based on this experience, GPU Nuclear is more keenly aware of the intent of the reportirg reouirements of this rule and, in the unlikely event of a recurrerce, would most assuredly make an earlier report notwithstanding the level of uncertainty associated with initial dose assesteents. To facilitate the broadest possible awareness of the relevant Wi'orting reouirements and to ensure that the lessons learned from tN.1 t; vent receive the widest possible dissemination within GPU Nuclest, copies of this response, the associated Notice of Violation, Inspection Report 89-09, and LER 89-06 are being provided to the Unit Director, Licensing Manager, and Radiological Controls Director of each GPU Nuclear Facility (i.e., Oyster Creek, TMI-1, and THI-2) and to the Director, Radiological and Environmental Controls and the Licensing and Regulatory Affairs Director.
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