ML20064B581

Responds to NRC 900830 Notice of Violation & Proposed Imposition of Civil Penalty Re Violations Noted in Insp Repts 50-324/90-25 & 50-325/90-25.Corrective Actions:Event Investigations Completed,Including Event Review Meetings

ML20064B581
Person / Time
Site:	Brunswick
Issue date:	10/01/1990
From:	Eury L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
EA-90-130, NLS-90-203, NUDOCS 9010180141
Download: ML20064B581 (9)

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W he@ W SERIAL: NLS 90-203 P. O. Boa 1661 e Mateesh. N. C. 27002

'00T 011990 LYNN W. EURY senior vee Preensent operet6one support 1

Director, Office of Enforcement-U. S. Nuclear Regulatory Cormntssion Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325, 50 324/ LICENSE NOS.-DPR 71, DPR 62 REPLY TO A NOTICE OF VIOLATION (EA 90-130)-

Gentlemen:

On August 30, 1990, the Nuclear hegulatory Commission: issued'a Notice of-Violation (NOV) and Proposed Imposition of Civil Penalty (EA 90-130) for alleged unplanned radiation exposures to individuals during activities associated with a traversing incore probe (TIP) event of July 5,1990,' at CP&L's Brunswick Steam Electric Plant. Carolina. Power & Light Company (CP&L) hereby responds to the NOV. Attachment 1 to this letter is CP&L's " Reply to Notice of Violation" (10CFR2.201).

As noted in Attachment 1, CP&L acknowledges that the proposed violation constituted a violation of regulatory requirements. Enclosed is a check payable to the Treasurer of the United States in the amount of Sixty-Two Thousand Five Hundred Dollars ($62,500.00).

If you have any questions, please contact Mr. L. I. Loflin at (919) 546-6242.

Yours very truly, L

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L. W. Eur DBB/ece (829BNP)

Attachment cc: Mr. S. D. Ebneter Mr. N, B. Le Mr. R. L. Prevatte ^'

NRC Document Control Desk

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L. W. Eury; having been first duly sworn, did depose and say that the infor-  !

mation contained herein is true and correct to the best of his information,- j knowledge arid helief; and the sources of his information are officers, -

employees, contractors, and agents of Carolina Power & Light Co any.

A_ Att f. .

At n/)w . N Notary (Seal)

My commission expires: / / l 90101C)141 901001 sg PDR ADOCK 05000324 o PNV 1

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l ATTACHMENT 1 .

l 1 Carolina Power and Light Company I Brunswick Steam Electric Plant Reply to Notice of Violation Enforcement Action 90 130 Inspection Report No. 50 325 & 324/90 25 I. INTRODUCTION In accordance with 10 CFR 2.201 of theTComsnission's Rules and Practice Procedure, as' described in the-NRC. Staff's August 30, 1990 letter-transmitting .the subject Notice of Violation,' Carolina Power and Light J L Company (CP&L) hereby responds. to the cited Notice of Violation:(NOV) .

and Proposed Imposition of Civil Penalty.

II. REPLY TO INDIVIDUAL A11RCED VIOIATIONS In the NOV, the NRC Staff identified three violations which,+as'an' aggregate,.were categorized as a Severity Level III problem. These were denoted as A, B, and C, concerning allebed unplanned radiation' exposures to individuals during activities associated with.a traversing incore l probe (TIP) event of July 5,1990, at CP&L's Brunswick Steam Electric l Plant (BSEP). In this response, for each example of the' alleged violation, CP&L will (1)~ admit the' allegations,.(2): provide the, q reason (s) for the violation, (3) identify the: corrective' steps taken and the results achieved, (4) state actions to be.taken to avoid future; violations, and the date when full compliance will:be-achieved.

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The NOV states the particular violations are as follows: I A. 10CFR20.201 (b) requires each licensee.to make'or cause to I be made such surveys as:(1)lmay_be necessary for_the-l licensee to comply with the regulations'in this part-and (2) j are reasonable under the circumstances to evaluate the' l extent of radiation hazards that may.be present. 10 CFR {

20.201 (a) defines a " survey" as an. evaluation of the. j radiation hazards! incident to the production,.use, release, -

disposal .or presence of. radioactive materials or other 4 sources of radiation under a specific set of, conditions.

Contrary to the abovCon July 5,1993, -the licensee failed

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to adequately evaluate the extent of the radiation hazards.

present to. preclude a substantial potential'for an exposure in excess of 10 CFR' 20. requirements. for tuo individuals -

,1 prior to their performing a modification on'the Unit 1 "D" I Traversing-Incore Probe (TIP) Drive Mechanisms in the Unit 1 j Reactor Building, in that the workers received unplanned l radiation. exposure when they were momentarily exposed to an

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activated TIP having a radiation dose rate of approximately 4 1000 rem per hour on contact.

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'ny B. Technical = Specification _6.8.1 requires that written-procedures be established,' implemented,-and maintainedL covering the activities recommended-'in Appendix A of-Regulatory Guide-1.33, November 1972.

Regulatory Guide.1.33, November 1972, paragraph 9.e, states' general procedures for the control of maintenance, repair,i replacement, and modification work should be prepared priorD to beginning work. _These procedures should' include-information on areas such as the following:/ *

(1) Method for obtaining permission and clearanceifor' operational personnel!to work and for logging such q

. work and-('2 ) Factors to be taken'into, account,Jincluding'the necessity for minimizing-' radiation ~ exposure to.

workmen, in preparing the_ detailed _ work procedures.

Technical Specification 6.11 requires that written procedures for personnel radiation protection'shall bei  ;

. prepared consistent with the requirements of 10 CFR Part 20' j and shall be approved, maintained, and adhered.to for all' ,_ '

operations involving-personnel radiation exposure. s Contrary to the above,; on July 5,1990,: the licensee failed:

to establish adequate radiation protection procedures. <

concerning TIP replacement or. modification,' in that the licensee _'s procedure for plant modificationL87-241Ldid not include.necessary precautions to prevent accidental 4 4 withdrawal of a highly radioactive detector.into. unshielded' and occupied areas of the' licensee's facility,' creating lthe; i potential for significant' personnel radiation exposures'.~ l C. 10CFR19.12requiresthatallindividualsworking;bnaI restricted area be kept informed of'the storage,; transfer or use e' radioactive materials or of.radiationiin such ,

portions of the restricted area, and be instructed in the i health protection problems associated with exposure to such radioactive materials or radiation, and in theiprecautions. l or procedures to minimiza exposure. l i

Contrary to the above, on July 5,1990, a licensee' employee i moving a highly radioactive TIP'had not received,trainingLon; i the radiological hazards of.the TIP system and had not been instructed that continued take-up of.the detector's cable could cause the TIP to enter an unshielded.and occupied area that could result in unplanned exposures to high radiation.

levels. -l This is a Severity 1.evel III problem (Supplement IV). '

l Cumulative Civil Penalty - $62,500 (assessed equally among the. l three violations).

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A. Admission of the Violation CP&L admits that the deficiencies noted in Violations A,.B, and C l are correct in that:

1. For' Violation A, adequate ' evaluations of the extent of ' the1 radiation hazards present to precludeta substantial ~

potential for an exposure in excess of 10 CFR 20 requirements were not-performed for the July 5,1990:TIP' event.-

2. For Violation B, adequate procedures were-not established to-prevent accidental withdrawal of the highly radioactive >!

detector into an unshielded:and occupied > area.

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3. For Violation C, an individual; inadequately trained'in the potential hazards associated with'the TIP drive mechanism:

was moving a highly radioactive TIP,2which' resulted in-the TIP entering an unshielded and occupied area.

B. Reason for the Violations The event investigations associated.with this incident were <

performed under Plant Incident Report (PIR) 90 044 and Human.

Performance Evaluation (HPE) Report 90;017.

'l Violation A.

s As noted in the Admission of the1 Violation, the radiation hazards - l associated with plant modification 1(PM);87-241'were'not properly (

identified as a part of the that;nodification' package _ PM'87 241,-f 1

GAMMA TIP Replacement, involvedithe?replacementiof; existing -l neutron TIPS with a Gamma TIP:that.vould reduce TIP asymmetries, [

provide increased thermal limits margin,L and support the'use of- l GE10 fuel. The increased thermal 111mit margin would delay;the' 'l start of coastdown-operations on Unit 1 prior,to'the upcoming '

refuel / recirculation. pipe replacement project. To allow for- ..

comparison of neutron TIP and Gamma TIP performance, and provide "

operational experience with the Gamma TIPS prior to: Fuel' Cycle 8 -

where their use is essential, it'was necessary to install the- -i s

Gamma TIPS prior to the upcoming refuel outage.

Prior experience with removal of TIPS at. power has not produced, significant radiological. concerns. Emphasis of pre job briefings has always been placed on theLradiological hazards associated with ( ^

the removal and disposal of.the old irradiated-TIP. -Less emphasis-was placed on the testing of the newly installed TIPS, as this was y considered-to be a routine maintenance evolution. The hazards associated with driving and retracting TIPS-from the drive box-were not appropriately addressed in either' the pre-job briefing, R

the modification installation instructions or the maintenance procedure, l i

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- Violation B.

As stated in the Admission of the Violation -installation ,

procedures for plant modification 87 241 did not include necessary '

precautions to prevent accidental withdrawal of a highly radioactive detector by a contractor technician into the unshielded.and occupied area. - The major reason for this violation

- was a failure to follow procedure by the involved technician.1 Specifically, the procedure used specified that the'TIP be-withdrawnLto the-0001-position at the indexer; however, as.noted-in the PIR and HPE Report, there were several contributing factors to this event: '

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-1. The lead technician with primary responsibility for telling l the contract technician to stop withdrawal of the tip was focusing his attention on initiating corrective actions on a-recently discovered clutch. problem,-and failed to signal the.

contract technician to stop withdrawal of the.tip per procedure.

2. The modification procedure being used did not contain-cautions which would warn personnel working on:the TIPS of, the potential radiation hazards associated with TIP' withdrawal into the. drive box. The modification package used a plant Maintenance Procedure for this work. The.

modification implementation group assumed the maintenance-procedure;was adequate an did not recognize the deficiency of the procedure relative to the training level of personnel:

involved and the lack of caution statements.-  ;

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The high background noise and use of respirators. affected communications between workers. ] <

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The contract worker performing the _ withdrawal of the TIP was-not experienced with.this evolution or this system, and did.  ;

not understand that there were'no interlocks-to; prevent the  ;

TIP from being withdrawn all the way into the drive box.

5. The responsible modification engineer did not discuss the hazards with working on the TIPS or'the consequences of potential errors in job briefings held before starting work.~

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6. Health Physics coverage of this portion of the job had been reduced as a result of the fact that'the insertion of the new TIPS into the core was not noted as part of the adjustment process, and- that this was considered to be a routine evolution.

Violation C.

As stated in the Admission to the Violation, the individual contract worker moving the TIP during this event had not received l

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4 training or instructions that~ continued take up'of the TIP could '

cause the'TIP to' enter an-unshielded and occupied area. -

Contract! personnel receive the specific training to perform the task at hand for modifications'through the reading and -!

understanding of applicable: procedures, pre-job briefings, and >

supervision adequately instructing personnel on assigned; .

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activities and overseeing their actions.- The' training'for this.

task was insufficient in the following ways-i

1. The responsible modification engineer substituted an '

inadequately prepared technician'as a replacement'for an_  !

experienced technician that was: familiar with the. planned.

activities but had recently left the site. The replacement contract technician was not familiar with the TIP system or ,

the planned activities,iand had not participated in the' preparations.forLthe modification.

2. The lead ; technician on .theDjob did' not adequately instruct' -e the contract technician on when to stop withdrawing the tip, or on the potentia 1' risks l associated with'the. planned s action. '

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3. The responsible' modification engineer'did'not discuss the- y hazards-with' working on the-TIPS or. consequences of- .

O potential errors in=jobibriefings held before starting work.; 1 The responsible' modification = engineer also did not review-his expectatio'ns from the-lead technicians for the work.in' s the TIP tent being directed by the lead technician.'

4. The modification procedure did not contain cautions:which would warn personne1' working on the TIPS of the= potential y extreme-radiation hazard which could be present, that the y normal stops would be1 ineffective when manually retracting d the TIPS, or that continued manual' withdrawal would result c in direct exposure:to the TIP detector, p

5. No discussions were held on what action to take if the TIP detector were to be withdrawn:into the> box. TIP adjustment-was considered to'be a routine maintenance task, with. ,

unrealized potential.for exposure. -

C. Corrective Steos Which Have Be'en Taken and Resulta-Achieved-V "1 Immediate corrective. actions for the violations'involvedtin this ,

event included: 4*

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, , JT l 1. Work on PM 87-241! was immediately halted. [

!. 2. t Event investigations were completec , including event review 0 l meetings.

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3. Work was restarted on 7/6/90', with.:he following controls in- '

place: 4 i

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0 h - The Manager of Unit 1 I&C/ Electrical' Maintenance-provided direct supervision of the' activities at:the TIP drive box tent. ,

Maintenance-generated a detailed; set of instru'tions e to supplement the: steps in the: plant modificatio'ns.

- Maintenance conducted' lengthy- pre job 1 reviews / briefings with technicians and all groups

~ involved in the mod installation work.

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-- Constant HP coverage for the TIP drive box work was l

.provided. , , l Work restart was begun only after' plant management j

approval', '

i 4.- The Manager of Outage Management and Modifications evaluated on going modification-activities =to ensure that adequate 4

work control procedures lwere!in: place for modification- .j implementation.

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Appropriate personnel and their supervision have receivedl~ ,

disciplinary action. '

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' Work on the installation of'the new/ TIPS.was: completed without '

further incident. '

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Corrective Actions to Prevent Recurrence and'Date of Full 1 Comoliance ,

d This event was investigated'through:the Plant Incident Report.

process. In addition, a Human Performance Evaluation was '

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performed to ensure adequate root causes and corrective actions.

were identified. q q

Violation-A. 4

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1. Procedural changes have.been made to the Unit'2 plant ~ 'i

'q modification 87 099 and permanent Maintenance and applicable.

E&RC procedures for TIPLreplacement to reflect lessons learned from this, incident. . Included in these revisions are ,

specific Health Physics instructions, to provide strongL cautions regarding possible retraction of TIPsito the drive?

box, and to enhance; steps involved in replacing the TIPS  ;

2. An Engineering! Work Request (EWR) has been generated toL I investigate interlocks' to prevent a -TIP from being able to ' '

be retracted into the TIP box. '

3. Health Physics personnel will document pre job-briefing for any TIP Box or TIP Room entry / work, ,

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1 Restricted Area' locks :similar to those required for entry

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4 L into the TIP room'and other plant' areas.where significant radiological hazards are present, have been installed:on the-TIP drive boxes for both units.

Violation B. f

1. As noted in item 1 under Violation A, procedural. changes have'been made.to include specific = Health Physics-L instructions and cautions concerning withdrawal of TIPS inton a drive box. r

2. The." Conduct of Operations" philosophy's'tatements'in procedures'of~ appropriate organizations have been revised (to express 'that one aspect of correct preplanning of work-activities: includes research.of prior. industry events for'  :

application to the work activity.

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3. The Plant General Manager met with 1st and 2nd-line supervision.to discuss their responsibilities and ,

accountabilities and associated-consequences in the'eventi they, fail to exercise these' responsibilities. .

Violation C. a l As noted in the reason for violation, . qualification of contract personnel-involved'in modification: work is. ensured'through the reading and understanding of applicable procedures, pre-job briefings, and supervision adequately instructing personnel on assigned activities and overseeing their actions. To ensure the.

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i l .cffectiveness of this philosophy,:the.following corrective actions 1

'have been determined necessary:

1. As noted in item 1 under Violation A, procedural changes have been made to include specific. Health Physics ~ .

instructions and-cautions concerning withdrawal of TIPS into-a drive box. l

2. Real Time Training.and review of-this incident was completed. -3 by E6RC personnel, Maintenance I&C personnel,' OM&M project managers, engineers, and other supervisory personnel, NED l

-discipline personnel 'and Technical Support. Personnel'.

These reviews addressed the generic implications of verifying personnel remain sensitized to working critical ~or '

complex evolutions, including assurance that personnel remain sensitized to the importance of the use of proper procedures;.using qualified personnel to perform the tasks, and completion of task reviews and briefing prior to task .

initiation.

3. NED has developed an on going program-to train engineers and

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designers on industry events which are applicab1'e to design.-

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...,j' Ceneral As noted in the NOV and Proposed Imposition of Civil. Penalty letter,. escalation of the. proposed fine by:100 percent was deemedi i appropriate for the factor of prior notice'of'similar events in that Information Notice'(IN)_88-63, High Radiation Hazards From Irradiated Incore Detectors.and Cables, specifically warned licensees about the potential' problems associated with maintenance on TIP systems.

CP&L acknowledges that it failed'to.initi~ateLappropriate' actions to ensure incidents of the type specified in IN 88-63 would not occur at.itscBrunswick facility.. This is considered-to b'e an isolated. occurrence based on the investigations conducted. Upon reviewing the responses provided relative to IN 88-63, controls had been established to adequately address this issue for, work done by site maintenance personnel. However, personnel performing this work and utilizing Maintenance procedures included contract personnel that did not have the level of experience,-training and knowledge of the use of maintenance procedures as'that of-plant-maintenance personnel. The_ basic concern.is utilizing maintenance procedures for plant modification. installation by personnel with -

less experience than those for which thetprocedure was written.

A memorandum was issued from the-Maintenance Manager'to the.onsite NED Manager, expressing the concern _ of utilizing. maintenance procedures for plant modification' installation by personnel-with less experience than those for which the procedure was written.

NED is performing a potential-design deficiency. analysis.(90-32)',

addressing the concerns identified in this memorandum.

l This event has also been reviewed by thel plant management staff at: L CP&L's other two nuclear sites.

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CP&L feels it is in compliance with the regulations:and-requirements identified relative to this event; 1

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