ML20044D796
| ML20044D796 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/14/1993 |
| From: | Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9305200303 | |
| Download: ML20044D796 (7) | |
Text
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10 CFR 2.201 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION P. O. BOX 2300 SANATOGA. PA 19464-2300 (215) 327-1200. EXT. 3 COO DAVID R HELWIG May 14, 1993 VICE PRESCENT vuracx ocura4nus sr4nou Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 Reply to a Notice of Violation NRC Combined Inspection Report Nos. 50-352/93-04 and 50-353/93-04 and NRC Combined Supplemental Inspection Report Nos. 50-352/93-04 and 50-353/93-04 Attached is Philadelphia Electric Company's (PECo's) reply to a Notice of Violation for Limerick Generating Station (LGS), Units 1 and 2, which was contained in your letter dated April 9, 1993.
The cited violations involved the failure to perform adequate radiation surveys and the failure to adequately inform workers of the radiological conditions during the removal of traversing incore probe (TIP) tubing under the Unit 2 reactor vessel. to this letter provides a restatement of the violations followed by our reply.
Your letter transmitting the Notice of Violation contained a number of additional issues. provides our response to these issues.
An extension of the due date for this reply to May 17, 1993 was agreed to during discussions among Messrs.
D. B. Neff (PECo) and N.
S. Perry, J. H. Joyner, and J. T. Wiggins (USNRC, Region I) on May 10, 1993.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, 6
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9305200303 930514 At tachments PDR ADOCK 05000352 G
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ret 1y, LSNRC Senior Resident inspector, LGS
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Page 1 of 5 Inspection Report Nos. 50-352/93-04 J
50-353/93-04 1
i Reply to a Notice of Violation i
Violation A Restatement of the Violation 10CFR20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of 10CFR Part 20 and which are reasonable under the circumstances to evaluate j
the radiation hazards that may be present.
As defined in 10 CFR 20.201(a) a " survey" means an evaluation of the radiation nazards incident to the production, use, release, disposal or presence of radicactive materials or other sources of radiation under a specific set of conditions.
When appropriate, su;h evaluation includes a physical survey of the location of material and equipment, and measurements of levels of radiation or concentrations of radioactive material present.
Centrary to the above, the licensee did not make surveys to r
determine that individuals were not exposed to airborne i
concentrations exceeding the limits specified in 10 CFR 20.103.
Specifically, at about 2:00 a.m. on January 21, 1993, during removal of traversing incore probe (TIP) tubes, the licensee failed to detect the introduction of high levels of radioactive contamination (subsequently measured to be as high as 320 l
millirad /hr per 100 square cm removable) into the work area as the Unit 2 TIP tubes were removed.
As a result, there was a j
potential for workers, performing the task without benefit of i
respiratory protective equipment, to sustain a significant intake of radioactive material.
i This is a Severity Level IV Violation (Supplement IV).
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Response
Admission of Violation Philadelphia Electric Company acknowledges the violation.
i Reason for the Violation j
The root causes for failing to perform an adequate survey during the completion of TIP tube removal are:
o The engineering review performed by the Health Physics department prior to the start of the TIP tube job was
Page 2 of 5 Inspection Report Nos. 50-352/93-04 50-353/93-04 performed with insufficient consideration of industry experience and cur own experience, j
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Lack of performance standards whien address specific expectations for job coverage.
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Corrective Actions and Results Achieved l
Immediate corrective actions taken were:
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o The drywell area was isolated and posted as an airborne area.
o Air and surrace surveys were performed inside and outside the drywell.
As a result or the immediate corrective action; taken, Health l
Physics personnel effectively controlled the area and identified the extent of the radiological hazard.
i Interim corrective actions taken were:
o The area was decontaminated, surveyed, and released for work.
o Management connunicated the event to the Radiation Engineering group.
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Constant Health Physics coverage was provided on subsequent TIP work, t
Enhanced engineering controls and monitoring were employed on o
subseg-cnt TIP work.
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Access was limited in the area of subsequent TIP work.
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o All remaining radiologically significant outage work scopes r
were reviewed to ensure appropriate planning, monitoring, and i
control.
As a result of the interim corrective actions taken, all I
subsequent TIP work and other remaining radio)ogically
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i significant tasks were successfully completed without any further radiological events.
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Page 3 of 5 Inspection Report Nos. 50-352/93-04 50-353/93-04 Corrective Actions Taken to Avoid Future Non-compliance The following corrective actions are expected to be completed by September 1,
1993:
o Guidelines will be developed for radiologically signiricant work unich will require an evaluation of t he magnitude of the potential nazard to ensure the appropriateness of the radiological controls.
The assumptions used in these evaluations will be clearly stated in order that technicians performing job coverage can evaluate the actual radiological conditions against the expected radiological conditions.
o The pre-job review procedure will be revised to incorporate further guidance as to when the Radiological Engineering group reviews radiation work permits.
o Job performance standards will be developed for job coverage to ensure consistent support by Health Physics technicians.
Expectations for coverage of breaches and definitions of different types of coverage will be claritied.
o Personnel will be sensitized to the need to examine PBAPS and other industry experience for similar jobs and to anticipate j
conditions.
o Improvements will be made to the Health Physics Job History Files to incorporate lessons learned from the industry.
Date When Full Compliance was Achieved i
Full compliance was achieved on January 27, 1993 when the i
drywell was isolated and posted as an airborne area and air and j
surface surveys were performed inside the drywell.
The subpile room was decontaminated, surveyed, and released for work.
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Page 4 of 5 Inspection Report Nos. 50-352/93-04 50-353/93-04 Reply to a Notice of Violation t
Violation B Restatement of the Violation 10CPR19.12 requires that the licensee inform workers of the storage, transfer, or use of radioactive material and in precautions or procedures to minimize exposure.
Contrary to the above, on January 27, 1993, the licensee did not adequately inform workers as to the presence of high levels of radioactive contamination or of means to minimize their exposure to such contamination.
Specifically, at about 2:00 a.m.
on January 27, workers were not informed either during the pre-job briefing or after surveys during the early stages of the job of the presence of high levels of radioactive contamination contained within traversing incore probe tubes.
The is a Severity Level IV Violation (Supplement IV).
Response
Admission of Violation Philadelphia Electric Company acknowledges the violation.
Reason for the Violation The pre-job briefing aspects of this violation are addressed in the response to Violation A.
The root cause for the other l
aspect of this violation was a less than adequate understanding by the Health Physics Technicians that the actual contamination levels were significantly different than those anticipated.
Corrective Actions and Results Achieved In addition to the corrective actions discussed in the response to Violation A:
o The work teams on subsequent TIP work were thoroughly briefed j
on the details of the event and the potential radiological l
situation.
Page 5 of 5 Inspection Report Nos. 50-352/93-04 50-353/93-04 j
o The need for close communications between HP technicians and their supervision / control point leader was stress to HP technicians.
o The involved Health Physics personnel were counseled on their job performance.
As a result of the corrective dctions taken, all remaining outage work tasks were completed successfully without incident.
Corrective Actions Taken to Avoid Future Non-Compliance In addition to the corrective actions discussed in response to Violation A:
o Appropriate Maintenance Training Lessons plans will be revised to indicate the reactor vendor information (i.e.
General Electric Service Information Letter No. 164) and the lessons learned from this event.
o Maintenance procedure M-059-001, "TIP Tube and Support Stee; Removal and Installation," will be revised to include the lessons learned from this event and a strong cautionary statement of the potential of airborne and surface contamination.
Date When Full Compliance was Achieved Pull compliance was achieved on January 27, 1993 when the drywell was isolated and posted as an airborne area.
The subpile room was decontaminated, surveyed and released for work.
All workers were informed of the contamination levels during pre-job briefings.
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Inspection Report Nos. 50-352/93-04 l
50-353/93-04 l
Tne purpose of this attachment is to address additional issues raised in your April 9, 1993 letter which transmitted the Notice of Violation.
Differences in Calculational Approaches Your inspection report states "While it is our conclusion that your overall event investigation was strong, it is also our conclusion that your evaluation of the potential for a substantial exposure in excess of regulatory requirements was weak."
In order to better understand this issue and strengthen our performance, we will arrange for an independent expert review of the various analyses of this event.
The results of this review will be made available to the NRC staff.
We Will also survey j
other utilities to accertain what practices and guidance they use for the evaluation of such matters and will adopt best practice i
approaches into our program.
These actions are expected to be completed by July, 1993.
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Correlation of Improvement Program Initiatives to Root Cause Corrective Actions In your inspection report you indicated that it was unclear how the improvement program initiatives described during the enforcement conference specifically addressed the root causes of the violations for the January 27 event.
In attachment 1 the correlation of the improvement program elements with the identified root causes is clarified.
In addition, the engineering review aspects of the event is also specifically discussed.
I Removal of Items From the Fuel Pool l
Your inspection report stated with regard to the issue of objects being partially removed from the water that the hazard was beirg appropriately controlled but was not proceduralized and did not appear to be based on s.. engineering safety review.
In light of our fuel leak problem, it was suggested that we review our practices.
We have completed a preliminary review of our practices for identifying and controlling hot particles in the spent fuel pool and have concluded that current practices are generally satisfactory; however, we intend to review the practices and
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Page 2 of 2 Inspection Report Nos. 50-352/93-04 50-353/93-04 guidance used by others in the industry and will adopt the best practices for our program.
These actions are expected to be completed by September, 1993.
TIP Box Air Sampler Placement Your inspection report indicated that there could legitimately be a difference of opinion as to the appropriateness of the air sampler location but indicated, "that it was not optional."
j In order to strengthen our program, we intend to survey the practices aa3 guidance of other utilities and will adopt best l
practice approaches into our program.
These actions are expected l
to be completed by September, 1993.
l Complete and Accurate Information i
Your inspection report requested that we outline the actions we intend to take with regard to ensuring that our employees understand the importance of providing complete and accurate information to the NRC.
i This topic has been discussed by Health Physics supervision with all Health Physics technicians during continuing training.
Additional communications to the Health Physics staff has been conducted by means of a Health Physics Priority Information Notice and by routine meetings.
The importance of immediately raising communication difficulties with NRC inspectors to Health Physics supervision wac stressed.
Additionally, in order to ensure that all employees understand the importance of providing NRC with complete and accurate information, a For Your Information (FYI) Notice was issued to reinforce the requirements of 10CFR50.9.
An FYI is a means for management to convey expectations to the workforce through work group meetings conducted by first line supervision.
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