ML20035E971
| ML20035E971 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/09/1993 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20035E972 | List: |
| References | |
| EA-93-037, EA-93-37, NUDOCS 9304200130 | |
| Download: ML20035E971 (6) | |
See also: IR 05000352/1993004
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IPR 0 91993
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Docket Nos. 50-352
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50-353
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Mr. D. M. Smith
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Senior Vice President - Nuclear
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Philadelphia Electric Company
Nuclear Group Headquarters
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Correspondence Control Desk
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P. O. Box 195
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Wayne, PA 19087-0195
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Dear Mr. Smith:
SUBIECT:
(Enforcement Conference Report (NRC Combined Inspection Nos.
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50-352/93-04; 50-353/93-04) and NRC Combined Supplemental Inspection
Report Nos. 50-352/93-04 and 50-353/93-04)
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This letter refers to the NRC inspection conducted by Mr. R. Nimitz on January 19-22 and
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February 1-3 and 8-12,1993, the subsequent enforcement conference, and to the follow-up
inspection conducted on March 17,1993 at the Limerick Generating Station. The inspection
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in January and February included reviews of planning and preparation for the Unit 2
refueling outage and the circumstances, evaluations and corrective actions associated with
two events that occurred on May 31,1992, and January 27,1993. The two events both
involved workers who became radiologically contaminated while handling traversing incore
probe (TIP) tubing under the Unit I and Unit 2 reactor vessels. The combined inspection
report for this inspection was transmitted to you by letter dated February 26,1993. Five
apparent violations were identified in the inspection report.
As a result of findings of that inspection, an enforcement conference was conducted with you
and members of your staff on March 16,1993, at the NRC Region I office, King of Prussia,
Pennsyhania, to discuss the safety significance of your overall performance in the area of
radiological controls over the past year, the apparent violations presented in the combined
inspection report, your corrective actions subsequent to the identification of the violations,
and your perception of the appropriateness of the apparent violations relative to criteria
outlined in the NRC's Enforcement Policy (10 CFR Part 2, Appendix C). The conference
was attended by you and other representatives of Philadelphia Electric Company and
members of NRC management and staff. The conference was open to the public and
members of the public were in attendance. This letter transmits the summary of the
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enforcement conference. The inspection on March 17,1993, was to follow-up on
information that you provided during the enforcement conference. The combined
supplemental inspection report for the March 17 inspection also is enclosed.
The violations described in the enclosed Notice of Violation (Appendix A) involved work
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that was related to the May 31,1992 and January 27,1993 events where workers handled
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the TIP tubing under, respectively, the Unit I and Unit 2 reactor vessels. fhe May 31 event
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involved workers using a dummy TIP and entering under the vessel without the knowledge of
the health physics department, and the January 27 event involved workers uncoupling very
contaminated TIP tubing under the vessel. Regarding the May 31,1992 event, no response
to the violation (Violation C) is required, as corrective actions to preclude recurrence have
been put in place and appear to be effective. This violation has been classified at Severity
Level IV. The principal root cause for the violation involved inadequate communications
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between the workers and the health physics staff. Your corrective actions addressing this
type of communication weakness appear to have been effective, because we have not
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identified any subsequent events with this root cause since the corrective actions have been
implemented. Nevertheless, we are concerned that the experience your health physics staff
gained, or should have gained, as a result of that event, namely that the TIP tubes presented
a substantial contamination hazard, did not result in actions to preclude the January 27,1993,
event.
Regarding the January 27 TIP tubing event, two violations, Violations A and B, are
described in the enclosed Notice of Violation. You are required to respond to this letter and
should follow the instructions specified in the enclosed Notice of Violation when preparing
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your response. Details of these violations are presented in the above referenced NRC
Combined Inspection Reports. As described during the enforcement conference, adequate
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radiological surveys were not performed by the health physics technician overseeing the
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work, and workers were not provided adequate instructions to enable them to minimize their
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exposure to high levels of radioactive contamination. The failure to provide adequate
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instructions actually occurred twice. First, at the pre-job briefing, knowledge of the potential
hazard that was available from the May 31 event was not utilized or disseminated; and
second, after surveys during the early stages of the jeb indicated high contamination levels,
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appropriate consideration was not given to the increased hazard indicated by this new
information, nor was it provided to the woriers. The amount of radioactivity that was
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uncontrolled in the workers' immediate air space was at least eleven times an amount that, if
inhaled, would have resulted in an internal exposure in excess of regulatory requirements.
Based on the loss of control of this hazard and the amount of activity released into the
workers' immediate airspace, we have concluded that there was a potential for an exposure
in excess of regulatory requirements. However, in reviewing other factors associated with
the job, we have also concluded that a substantial potential for such an exposure did not
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exist, and as a result, have classified these violations at Severity Level IV. Our reasons for
concluding that a substantial potential did not exist are, (1) the nature of the contamination
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was that it was dense, not readily dispersible, and passed through the workers' airspace
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quickly, (2) the workers were wearing face shields, which provided protection against
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inhalation of the falling material, and (3) your whole-body count results indicated that the
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workers sustained no uptake of radioactive material.
Because these violations were licensee-identified and at Severity Level IV, they were
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evaluated against the criteria of 10 CFR 2, Appendix C, Section VII.B.2 to determine the
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appropriateness of citing these violations. As a result of the evaluation it was concluded that
citing tne violations was appropriate because previous licensee findings associated with the
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May 31,1992 event did not prevent these violations and reasonably could have been
expected to prevent them.
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In the NRC inspection report transmitted to you by letter dated February 26,1993, we
recognize that you performed a thorough investigation of the January 27 event. However,
after further review during the inspection on March 17 of your evaluation methodology of
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the potential for overexposure of workers, we have determined that your evaluation failed to
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identify the magnitude of the radiological problem. This was because your calculation only
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took into account a small amount of the total radioactive material on the subpile room floor
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or a small amount of the total radioactive material on the grating and on the walls. While it
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is our conclusion that your overall event investigation was strong, it is also our conclusion
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that your evaluation of the potential for a substantial exposure in excess of regulatory
requirements was weak.
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As identified by your event investigation, the central root cau'se for the January 27 event was
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poor communications between the health physics job control point supervisor and the health
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physics technician overseeing the job. In addition, it is our view that the engineering review
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performed by the health physics department prior to the start of the TIP tube job did not
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result in adequate instructions being provided to the job control point supervisor and to the
health physics technician regarding specific precautionary actions necessary to ensure
reasonable control of the hazard. It is our understanding that your staff also now recognizes
the importance of this factor in the causes of the event. During your presentation at the
enforcement conference, you described general program upgrades that you are planning to
implement; however, it is unclear how these will specifically address the root causes of the
violations for the January 27 event. As indicated in the instructions in Appendix A of this
letter, you are required to present your root causes for each violation and your corrective
actions. In your response, please also address the weakness in engineering review described
above.
In addition to the above three violations, two other apparent violations were identified in our
report transmitted to you on February 26. They involved inadequate surveys during lifting of
objects from the spent fuel pool, and inadequate airborne radioactivity sampling during work
in the TIP drive box. Based on new information that we received during our inspection on
March 17, as described below, we have decided not to cite these apparent violations.
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Nevertheless, we believe that your performance of the activities involved represented
questionable health physics practices.
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Regarding the issue of objects being removed partially from the water in the pool, frequent
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surveying of workers' gloves is imponant to protect the worker who is handling the object
from getting a radioactive particle on his gloves (or other protective clothing, or skin) and
subsequently receiving an unplanned exposure. The new information that we obtained during
the March 17 inspection was that special gloves were used by the workers handling the
objects, that these gloves were frequently changed, and the gloves were frequently surveyed
by the roving health physics technician. This information suggests that potential hazards
were being controlled. However, this practice, including the frequency at which gloves are
changed or at which hands are surveyed, should be proceduralized and should be based on an
engineering safety review. The range of sizes and intensities of the hot particles observed in
the reactor cavity after draindown appeared to be such that, if they had become lodged on a
worker's glove, they would not have caused a significant hazard due to the practices you
were employing, albeit non-proceduralized. However, in light of the fuel leak problem
recently experienced at the Limerick station, this was fortuitous, in that the hot particles
could have been larger in size and intensity than was actually found. Given the potential for
highly radioactive particles in the pool water, you should review your health physics
practices in this area and in your response to this letter describe what new actions, if any,
are appropriate and will be implemented. In reviewing this area, we would like to bring to
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your attention NRC Information Notices 90-33 and 90-47. The Information Notices discuss,
among other issues, hot particles in spent fuel pools. They discuss methods for identifying
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and controlling hazards around pools and also present a history of problems that have
occuued in this area. Enforcement action resulted from a number of the problems described
in the Information Notices. The problems described in the Notices may be of panicular
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interest to your staff, as they were of the belief that enforcement in this area was
unprecedented.
Regarding the issue of sampling for airbome radioactivity, during the inspection on March
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17 we learned that the contamination inside the TIP drive box was sticky and oily, contrary
to the survey record that describes it as a black, dust-like material, and thus presented little
or no airbome hazard. Regarding the positioning of the air sampler, there likely would be a
difference of opinion among radiation protection professionals as to whether it was
reasonable or not. There was no question, however, that it was not optimal. Had the
engineering controls associated with the job been less (e.g., less air flow through the box), or
had the contamination levels been greater and the contamination more readily dispersible, the
apparent violation likely would have been cited.
As a last point, you stated during the enforcement conference that in at least one instance, a
technician misrepresented a situation to the inspector because the technician felt intimidated
by the NRC. Title 10, CFR 50.9, requires that information provided to the Commission by
a licensee be complete and accurate in all material respects. Misrepresentations as the one
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noted are not taken lightly by the NRC and have the potential for enforcement action. We
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request that you take measures to ensure that your employees understand the importance of
providing NRC with complete and accurate information. In your response to this letter,
please outline the actions Philadelphia Electric Company will take in this regard.
I would also note that the NRC has been, and continues to be, sensitive to the potential for
intimidation of licensee representatives through the inspection process. Our inspectors are
trained to be sensitive to this issue when interacting with licensee representatives during
inspections. Periodic reemphasis of our expectations assures there is a continuing sensitivity
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to this issue. Nonetheless, we appreciate your candid view on the issue and we will strive to
improve our efforts in this area.
Your cwperation with us is appreciated.
Sincerely,
Crigi a1 Signed Ey:
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Rich r d W. Cooper
Richard W. Cooper, II, Director
Division of Radiation Safety
and Safeguards
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Enclosures:
1.
Appendix A, Notice of Violation
2.
NRC Enforcement Conference Report Nos. 50-352/93-04; 50-353/93-04
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3.
NRC Combined Supplemental Inspection Report No. 50-352/93-04; 50-353/93-04
cc w/encis:
J. Doering, Chairman, Nuclear Review Board
D. R. Helwig, Vice President - Limerick Generating Station
G. A. Hunger, Jr., Manager - Licensing Section
G. Madsen, Regulatory Engineer - Limerick Generating Station
Secretary, Nuclear Committee of the Board
Public Document Room (PDR)
Imcal Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, (2)
NRC Resident Inspector
Commonwealth of Pennsylvania
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