ML20126H830
| ML20126H830 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/28/1992 |
| From: | Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-92-179, NUDOCS 9301050337 | |
| Download: ML20126H830 (6) | |
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W PillLADELPlHA ELECTRIC COMPANY LIMERICK GENERATING STATION P. O. BOX 2300 SANAT(X3A, PA 19464-2300 (215) 3271200, EXT. XU)
December 28, 1992 DAVID H HELWIG VICE PatSIDENT uutnicx acuenanna swoon 99eggy y9, 59_35g License No. NPF-39 Director, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Unit 1 Response to a Notice of Violation and Payment of Civil Penalty EA 92-179 Attached is Philadelphia Electric Company's response to a Notice of Violation for Limerick Generating Station (LGS), Unit 1, which was contained in your letter dated November 25, 1992.
The cited violations involved the failure to perform adequate radiation surveys and the failure to adequately inform the work crews of the radiological conditiona in all portions of the drywell. 'The attachment to this letter provides a restatement of the violations followed by our re'sponse.
A check in the amount of $62,500 in payment for the civil penalty is enclosed.
If you have any questions or require additional infc.cmation, p'_ case contact us.
Very truly yours,
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} vr 9 Enclosures Attachment j' d g _-
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T. T. Martin, Administrator, Region I, USNRC, w/Attachmends T. J.- Ker.ny, USNRC Senior Resident Inspector, LGS, w/ Attachments 9301050337 921228 PDR ADOCK 05000JS2 O
COMMOliWEALTil OF PENNSYLVANIA COUNTRY OF CliESTER D.
H.
lielwig, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company; that he has read the response to the Notice of Violation concerning inadequate radiation surveys and inadequate radiation condition notification, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
f Vice President l
Subscribed and sworn to W
before me this day fcc>d/A 1992.
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.Page 1 of-4 InspectionL No.-- 50-352/92-26
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Reply to a Notice of Violation-Violation A Restatement of the Violation 10 CFR 20.201(b)-requires that each licensee make such surveys as may be necessary to comply with the requirements of 10 CFR Part 20 and which are reasonable under the circumstances to evaluate _the extent of radiation hazards may be present.
As defined in 10 CPR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production,-use, release, disposal, or presence of radioactive materials or other sources-of radiation under a specific set of conditions.
Contrary to the above, on_ July 8, 1992, the licensee'did'not make adequate radiation surveys to assure compliance with the-part of 10 CFR 20.101-that limits the radiation exposure _to the whole body and the skin of the whole-body.
Specifically, during the drywell entry to the 303 foot elevation individuals moved to and worked in.a restricted area on the 296 foot elevation that.
had not been surveyed.
Further,'during a subsequent drywell=
entry _on the-296 foot elevation, the licensee failed to identify and evaluate the extent of the radiation hazard associated with a-beam of radiation located in close proximity to-workers who were-repairing a main-steam line sample isolation valve __
(HV-041-1F084).
The beamLexhibited radiation levels in.the work' area readily accessible to personnel ranging from about 3 roentgens _per hour.(R/hr) to about 25 R/hr, and_ created at substantial. potential for the. workers to receive exposures in excess of 10 CFR_20.101(a) limits.
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Response
Admission of Violation Philadelphia _ Electric Company (PECo) acknowledges the violation.
Reason for the Violation L
The reasons for.the-lack'or, a survey for the work' performed on the 296 foot _ elevation on July 8,-1992,-is discussed _in the response-to Violation B.
L
' l Attachment Page 2 of 4 Inspection No. 50-352/92-26 The reasons for-not identifying and evaluating the extent of the radiation hazard associated with the beam of. radiation is discussed below.
On July 9, 1992, a control rod pattern change was performed i
while all personnel were out of the drywell.
The new pattern caused the axial power to increase and spread to a wider location in the core.
The unique geometry of the-control rods, the resulting axial power, the penetration associated in this event, and positioning of equipment in the drywell-combined to-focus'a stream of radiation into a small beam.
The detection of the radiation beam was missed during the escort survey' performed by the health physics technician because of the small area ~affected.
The lack of clear communication between Health Physics and work
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groups and lack of a specific procedure to control work in the drywell with the reactor at power were contributing factors.
Corrective Action and Results Achieved On July 9, 1992, a detailed radiation survey identified a small radiation beam following the alarming'of a digital dosimeter on a maintenance technician who was standing at a junction box on the 296 foot elevation of the drywell.
Work groups were accompanied by Health Physics personnel to prevent entry into the beam during subsequent entries into the drywell.
Corrective Actiona Taken to Avoid Future Non-Compliance A root cause analysis was performed by the Independent Safety Engineering Group (ISEG) to identify the causefof the beam and corrective actions needed to prevent a similar unplanned exposure.
A subsequent root _cause analysis identified broader corrective actions.
A procedure will be issued to provide. specific controls for work in the drywell with the. reactor at power prior-t.o any occasion for its use.
The procedure will-specify control of_ _
reactor power: level and other pertinent plant ctartup activities.
. Specific guidance on survey techniques and instruments for detecting-similar situations has been incorporated into Health L
Physics continuing training and-will be included in the procedure being developed.
All known or expected sources of streaming will be posted or shielded-as appropriate to minimize the potential for personnel exposure.
Date When Full Compliance,was Achieved Pull-compliance was achieved on July 9,'1992, when a detailed radiation survey of-the 296 foot-elevation was-completed.
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Attachment _
Page 3 Eof 4 Inspection No. 50-352/92-26 Reply to a Notice of Violation Violation B Restatement of the Violation 10 CPR 19.12 requires, in part, that all individuals working in any portion of a restricted area be informed of the radiation in.such portions of the restricted area and instructed in the-precautions and procedures to minimize exposure to radiation.
Contrary to the above, on July 8, 1992, individuals who were working in a restricted area in the Unit 1.drywLll had not been instructed in precautions and procedures to minimize their exposure to radiation.
Specifically, workers repairing a main steam line sample isolation valve (HV-041-1F084) were not adequately instructed to remain in their work area on tne 303 foot elevation and contact radiological controls personnel prior-to moving to other work locations.
As a result, the workers-entered a work location on the.296 foot elevation of the drywell-which had an unrecognized radiation beam with radiation dose rates of between 3 R/hr and 25 R/hr that'was readily accessible to the workers. - In addition, individuals who worked at the 296-foot elevation had not been informed of the radiation.in the portion of the= restricted area.
As a result the workers unknowingly' entered and worked-in general area: radiation ~ fields.
at least 6 times those which were1present at their original-. work.
location on the 303 foot elevation.
Response
Admission of Violation Philadelphia Electric Company acknowledges the violation ~.
Reason for the-Violation The Radiation Work Permit-(RWP) for the July 8, 1992 drywell entry was specifically written for the 303 foot elevation.
The-ALARA pre-job briefing 1 performed on' July 8, 1992 stated-that Health Physics' approval:was' required'prioryto moving to a new I
work location, but the workers did not recognizeEthat their movement constituted a' change-of work-location because.of the L
-short distance-to the junction box.
The lack'of' clear r
communications between heslth' physics technicians and the work L
group caused this violation.
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Attachment:
Page 4Tof14.
- i Inspection No. 50-352/92-26 This incident is indicative of less than adequate-corrective.
actions from a previous radiological-event _that~occurr'ed in the Refuel Ploor Transfer Canal.
The corrective actions'for this earlier-. event had-been applied to the-specific work _ group--
involved and did not include the station maintenance staff.
Corrective Actions and Results Achieved While reviewing the workers' exposures indicated on the self reading dosimeters immediately after. exiting the drywell_onLJuly 8,'1992, the Health Physics technician noticed _that one of the.
workers had a slightly elevated exposure-compared to the other workers. -The Health Physics technician questioned the' workers and discovered that the individual had left the' work location specified by the RWP.
The health physics technician immediately counseled-the worker at the job site.-
The worker-indicated that he would~ strictly adhere to all RWP requirementsLin the future.
Corrective Actions Taken to Avoid Future Non-Compliance Health Physics, Operations, Maintenance, and Technical staff continuing training will include a discussion of the lessons
. learned from the investigation of.this incidence, a-review of the incident, and a discussion of communication-elements 'needed for a Lgood. pre-job briefing.
In preparation for the upcoming refueling. outage on Limerick Generating Station-Unit 2, a training program'for plant workers will be conducted to enhance their awareness-:of radiological controls and work practices.
The importancelof effective communication between health physics personnel-and the worker will be discussed during this training.
_This training. program will also be incorporated into-future pre-outage training'
_ programs.
Date When Full-Compliance was" Achieved
- Full compliance _was achieved on-July _9, 1992.when_the work in the drywell was. completed, the RWP was closed, and no~further-drywell entries at power were permitted.
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