ML20079L101

Responds to NRC Re Violations Noted in Insp Repts 50-277/91-28 & 50-278/91-28 on 910909,20,23 & 24.Corrective Actions:Health Physics Procedure HP-210 Re Radiation Survey Techniques Revised to Provide Guidance for Beta Surveys

ML20079L101
Person / Time
Site:	Peach Bottom
Issue date:	10/31/1991
From:	Miller D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9111060071
Download: ML20079L101 (5)

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N I"3"'I Oct ober 31, 1991 Docket Nos. 50-?77 50-778 U. S. Nuclear Regulatory Commission A11N: Document Contiol Desk Washington, DC 20$55 SUDJECT: Peach Bottom Atomic Power Station - Units 2 & 3 Response to Notice of Violation 91-28-01 (Unit 3)

(Combined inspection Report Numbers 50-277/91-23; S0-270/91-28)

Dear Sir:

In response to your letter dated October ?, 1991, which transmitted the Hotice of Violation in the referenced inspection report, we submit the attached response. The subject inspection report concerns a routine radiological safety inspection conducted during September 19, 20, 23 ana 24, 1991.

If you have any questions or require additional information, please do not -

hesitate to contact us.

Sincerely, f;7m y, }/Ma* ,; ,

jy , p j / = Ii- T cc: R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania J. J. Lyash, USNRC Senior Resident inspector T. T. Martin, Administrator, Region 1. USNRC H. C. Schwemm. Atlantic Electric R. 1. McLean, State of Maryland J. Urban Delmarva Power 91i1060671 911031 nooce cmo:f>DR 77 dal non

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e Document Control Desk Page ?

bcct J. W. Austin A4-4N, Peach Bottom J. A. Basilin 5?A-5, Chesterbrook G. J. Beck 5?A-5, Chesterbrook J. A. Bernstein $1A-13. Chesterbrook R. N. Charles SIA-1, Chesterbrook Commitment Coordinator 5?A-5 Chesterbrock Correspondence Control Program 618-3, Chesterbrook J. B. Cotton 53A-1, Chesterbrook G. V. Cranston 638-5, Chesterbrook E. J. Cullen 523-1. Main Office A. D. Dycus A3-IS, Pcach Bottom A. A. Fulvio A4-13. Peach Bottom D. R. Helwig SIA-ll, Chesterbrook R. J. Lees, NRB $3A-1 Chesterbrook C. J. McDermott 513-1, Main Office D. B. Miller, Jr. SMO-1, Peach Bottom PB Nuclear Records A4-2S, Peach Bottom K. P. Powers A4-lS, Peach Bcttom J._M. Pratt B-2-S, Peach Bottom J. T. Robb $1A 13. Chesterbrook D. M. Smith 52C-7 Chesterbrook n

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Document Control Desk l Ppge 3 ,

RESPONSC 10 N0llCL Of V10tA110N 91-28-01 (Unit 3)

Restate ent of Violation 10 CFR 20.201(b) requires, in part, that each licensee shall make or cause  :

to be made such surveys as may be necessary and reasonable to comply with the requirements of 10 CFR Part 20. 10 CfR 20.201(a) defines a survey, in part, as an evaluation of the radiation hatards incident to the presence of ,

radioactive materials under a specific set of conditions. When appropriate.

such an evaluation includes a physical survey of material and equipment measurements of levels of radiation present.

Contrary to the above, at approximately 7 p.m. and 11 p.m. on September 18,  !

1991, entries were made to the Reactor Water Cleanup Pump 3D area to perform work on the pump internals, and inadequate surveys were made to assure compliance with that part of 20.101 which limits radiation dose to individuals in restricted areas. Specifically, prior to removing the Reactor Water Cleanup Pump 3B impeller, no beta measurements were made on '

the impeller. After the impeller was removed it was determined that the ,

contact beta dose rate was approximately 1100 Rad /hr.  !

This is a Severity Level IV violation (Supplement IV).

Background

On September 18,1991, at 4 p.m. a maintenance crew was escorted by a llealth Physics (HP) technician into the Unit 3 'B' RWCU pump room to breach the ,

pump and remove the internal assembly. As the pump assembly was removed. .

the HP technician obtained the gamma dose rate on the impeller assembly and '

wear ring of the pump housing. The HP technician was unable to obtain a beta dose rate on the impeller assembly and wear ring as a result of components being lowered face down.onto the floor. Due to heat stress.

considerations, work was halted and the crew exited the area.

A second entry was made into the room at approximately / 30 p.m. that evening, lhe purpose of this entry was to remove the impeller from the snaft. The HP technician for this crew received turnover from the first HP

' and was tol_d the impeller w n reading 26 R/Hr. The HP technician entering the room questioned the_ beta dose reading und was told, "l_didn't get a beta dose reading by the first HP. 1his statement was interpreted by the llP entering the room as e.non-detectable beta dose rate. -The c.rew entered the '

room and the HP verified the ganna dose rate. Attempts to remove the impeller from the shaft were unsuccessful and the crew exited the room due to heat stress considerations. 1here were no attempts to obtain beta dose ,

rates during this evolution.

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Document Control Dest Page 4 Another entry was made into fhe room at approximately 11:45 p.m. th;t night by a third HP and work crew to remove the impeller from the shdit. The third HP technician recei/ed a turnover from the second HP on the conditions in the room, lhe third HP re-verified the gamma dose rate and the crew was allowed to initiate work, lhe impeller was rePoved from the shaft and was immediately moved ta the 'orner of t_e room, the HP technician turned the impeller over to obtain dose rates on the unsurveyed side, 11 was at.sthis time the beta reading was discovered to be offscale high. The impeller was then covered with three lead blankets and the work crew was escorted out of I the area.

Reasons for the Violations Procedural guidance to require beta surveys during system or component breaches was less than adequate. Although the ootential for nigh beta dose rates existed, appropriate crocedural controls were not in place to reauire a suf ficient evaluation of t he radiological hdlards.

Additionaliy, although gamma dose rates were obtained and veriried by the s different HP technicians throughout the event, the beta dose rates were not.

The HP technicians failed to adequately verify radiological survey infor. nation during turnover. -

Communication between HP technicians during the incident was also

- inadequate. The statement "I didn't get a beta dos 1 reading" was misinterpreted by the HP technician to medh that no beta dose was present, rather than no d rate measurement was obtained.

The ALARA pre-jo, .iew did not appropriately address the rodiological Although the review addressed hazards associat- with the work activity.

thd potential f( tigh gamma dose rates, the polcntial for significant beta dose rates was nut identified even though previous experience had shown that h',gh beta dose rates could be encountered during worn on primary system components.

< , Corrective Steps Taken and Results Achieved Work activities in the Unit 3 'B' RWCU pump room were terminated after the potential dose hazard was identified. The Senior Health Ph.ysivist

• accompanied by a HP technician conducted an indepth beta survey of the tomponents utilizing high beta dose rate inFtrumentation. The casing wear ring was identified as having a dose rate of 1100 Rad /Hr and the pump impeller a dose rate of 880 Rad /Hr. Extremity dosimetry of the workers involved was sent out for innediate processing to ascertain the dose to the workers' hands. The results of this processing determined that Philadelphia Electric administrative extremity dose limits were not excceded.

Philadelphia Electric administrative dose limits are 26% more stringent than the federal limits imposed by 10 CFR 20. Interviews were conducted with the workers, HP technicians, HP supervisors and Radiological Engineers involved in the incident to examine the causal factors. Results of these interviews g contributed to determining the correction actions to prevent future violations. The importance of proper communication techniques, including repeat backs for clarification was emphasized to the entire HP technician staff in discussions with HP Supervision. In addition, the importance of c

verifying information received during tornover was also stressed, f

Or ument Control Desk Page 5 Corrective Action to Prevent Recurrence tiealth Physics Pre,edure, lif-?l0, "Radiat ion Survey Techniques" will be revised to provide additional guidance for beta survey requirements during system breaches. This revision will be completed by November 30, 1991.

llealth Physics Procedure llP-311. "ALARA Job Reviews" wi;. be reviewed to evaluate the criteria for conducting pre-job reviews and the content required for these reviews, lhis review and any revisions will be comn'eted by December 31, 1991.

HP procedure revisions will be included in required reading packages for the lip technician and technical staf f. These revisions will also be forwarded to the Training Department to be incorporated into continuing trainino, Additional instrumentation capable of measuring high beta dose rates has also been requisitioned to enhance the survey capabilities of the technicians.

Date When full Compliance was Achieved full compliance was tchieved September 19, 1991, when the Unit 3 'B' RWCU pump impeller and casing ring were surveyed to determine the beta radiation present.

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