ML20236G453
| ML20236G453 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/23/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1163, 50-346-98-07, 50-346-98-7, NUDOCS 9807060251 | |
| Download: ML20236G453 (5) | |
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Daws-Besse Nuclear Power Station.
- gn 5501 North State Route 2 Oak Harbor, Ohio 43449 9760 m
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.lohn K. Wood 419-249-2300 McePresident Nuclear Fax:419-321-8337 Docket Number 50-346 License Number NPF-3 Serial Number 1-1163 June 23, 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001
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Subject:
Response to Inspection Report Number 50-346/9700((DRS)
Ladies and Gentlemen:
Toledo Edison has received Inspection Report Number IR 50-346/98007 (Toledo Edison Log Number 1-3964) and the enclosed Notice of Violation issued on May 26,1998. The violation involves two examples of a failure to evaluate the potential radiological hazards and institute appropriate controls prior to performing work. Toledo Edison provides the attached response to the subject violation.
Should you have any questions or require additional information, please contact Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours, b
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cc: A. B. Beach, Regional Administrator, NRC Region III A. G. Hansen, DB-1 NRC/NRR Project Manager g
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S. J. Campbell, DB-1 Senior NRC Resident Inspector
- ~q Utility Radiological Safety Board o
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9007060251 990623 j
PDR ADOCK 05000346 G
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' bocket Number 50-346 License Number NPF-3 Serial Number 1-1163
-Attachment,
1 Page1 Reolv to a Notice of Violation (50-346/98007-0D Alleged Violation During an NRC inspection conducted from April 27 through April 30,1998, a violation of NRC requirements was identified. In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.
Pursuant to 10 CFR 20.1003, survey means the evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.
10 CFR 20.1201(a)(1)(i) requires, with exceptions not applicable here, that the licensee control
~the occupational dose to individual adults to an annual dose limit of 5 rems total effective dose equivalent.
Contrary to the above, on April 21 and 23,1998, the licensee did not make surveys to assure
. compliance with the regulations in 10 CFR 20.1201(a)(1)(i). Specifically:
On April 21,1998, the licensee did not perform surveys to identify the potential for a.
transient, high dose rates in the annulus area during incore detector movement, prior to allowing workers to enter the area. This area had dose rates between 10-20 rem per hour (contact) on portions of the containment wall during movement of the incore detectors (50-346/98007-01a),
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_On.pril 23,1998, the licensee failed to evaluate the ALARA controls implemented c
duung removal of steam generator mirror insulation. Specifically, the radiation protection technician covering the job, had relaxed the requirements for wearing i
faceshields and for " wetting" the contaminated surface, as discussed in the prejob briefing or as specified in the Radiation Work Permit, without performing an evaluation of the potential radiological consequences. The high contamination levels (50-500 millirad per hour (smearable)) which existed in the area required that stringent controls be maintained to prevent the spread of airborne contamination (50-346/98007-Olb).
This is a Severity Level IV violation (Supplement IV).
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bocket Numbcr 50-346
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License Number NPF-3 o
Serial Number 1-1163 Attachment,
Page 2 Response to Alleced Violation 50-346/98007-Ola Reason for Violation The annulus between the containment vessel and the wall of the shield building was not recognized as an area requiring control as a Locked High Radiation Area during movement of activated incore probes. Incore probes are pulled from the shielded incore instrumentation tunnel into the water-filled incore tank every refueling outage to be cut up for disposal purposes.
During the most recent refueling outage, there was an increase in the amount of work performed in the annulus due to replacement of radiant energy shields and repainting of the lower portion of the containment vessel in addition to the normally scheduled outage activities. During previous refueling outages, either personnel were not in the annulus area during cutting of the incore probes, or incore cutting occurred during transfer ofirradiated fuel from the reactor to the spent fuel pool. Dunng fuel transfer, the annulus is controlled as a Locked High Radiation Area because the fuel transfer tubes traverse the annulus. Due to a failure to survey the annulus area during the separate evolution ofincore cutting, the annulus was not recognized as a potential area for high radiation levels during the brief period of time the incore probe is not fully shielded.
The high dose rates in the small affected area of the annulus existed for approximately 30 seconds as the incore probe tip traversed the air gap between the shielded incore instrument tunnel and the water-filled incore tank.
Corrective Steos Taken and Results Achieved When the workers' electronic dosimeters alarmed, the workers immediately evacuated the annulus area between the containment vessel and the wall of the shield building and contacted Radiation Protection personnel. Radiation Protection personnel respcaded by performing a survey of the work location. The initial survey failed to identify the cause of the alarm, so the workers were allowed to return to the work location with continuous Radiation Protection coverage. When a second dose rate alarm occurred the workers were promptly evacuated from the work location. The t ansient high dose rate was confirmed by the Radiation Protection technician, and the entire annulus area was controlled as a Locked High Radiation Area for all incore probe cutting activities. Administrative controls were imposed to prevent use of the incore cutter without the annulus space being posted as a Locked High Radiation Area. The maximum dose recorded by any worker's electronic dosimeter was 7 millirem.
Corrective Steos Taken to Avoid Further Violations l
The forms associated with procedure DB-HP-04003, Locked High Radiation Area Boundary Verification, have been revised in accordance with procedure DB-HP-00000, Radiation Protection Program Administration, to ensure the annulus area between the containment vessel and the wall of the shield building is controlled as a Locked High Radiation Area during handling of activated incore probes. No other areas are affected during handling of activated incore probes that are not already controlled as a Locked High Radiation Area. In addition, 1
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bocket Number 50-346 License Number NPF-3 Serial Number 1-1163 I
Attachment,
Page 3 training will be provided to Radiation Protection personnel on lessons learned from this incident; including proper dosimetry alarm response, proper follow-up and investigation of unexpected i
dosimetry alarms, and new controls for incore probe handling. This training will be completed by September 11,1998.
Date When Full Compliance will be Achieved Full compliance was achieved on April 22,1998, when the annulus area between the containment vessel and the wall of the shield building was surveyed during handling of activated incore probes and posted as a Locked High Radiation Area.
Resoonse to Alleced Violation 50-346/98007-Olb Reason for Violation As a result of personnel error by the contract Radiation Protection technician covering the job, inadequate contamination control methods were used for insulation removal in an area known to be highly contaminated beneath the insulation. Controls to minimize the spread of airborne contamination were discussed during the pre-job briefing, which was attended by the technician.
However, during the actual insulation removal, the technician did not implement the controls discussed, and did not consult with Toledo Edison Radiation Protection management personnel prior to relaxing the controls. A contributing factor to this event was that the associated Radiation Work Permit covered all insulation removal in containment, and the pre-job brief for this Radiation Work Permit occurred approximately two weeks prior to this specific task. The insulation workers and thejob supervisor, who also attended the pre-job briefing, followed the direction of technician instead of following the guidance received from Radiation Protection management during the briefing.
Corrective Steps Taken and Results Achieved The contract Radiation Protection technician who erroneously relaxed the contamination control controls was counseled regarding the event and was reassigned to a different area of the plant for the remainder of the refueling outage. The workers were decontaminated, and whole body counts performed to confirm that any intake of radioactive material was significantly below regulatory limits. A discussion was conducted between Toledo Edison Radiation Protection management personnel, the insulation workers, and the job supervisor regarding the event to reaffirm the expectations regarding compliance with pre-job instructions. A detailed decontamination effort was planned and executed to correct the high contamination levels that resulted from the insulation removal from the east steam generator in order to recover the immediate work area affected. Increased supervisory oversight of further insulation jobs was provided to ensure proper contamination control methods were taken. No further contamination control incidents related to insulation removal occurred during the remainder of the outage.
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Docket Number 50-346 License Number NPF-3 Serial Number 1-1163
. Attachment,
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Corrective Steos Taken to Avoid Further Violations Additional controls will be established for removal ofinsulation from the affected area of the east steam generator A special Radiation Work Permit with a specific brief to keep personnel dose "As Lcw As Reasonably Achievable" (ALARA) for this particular area plus an additional -
control to conmet the duty Radiation Protection Manager prior to insulation removal will be
. utilized to ensure proper controls. These actions will be captured in the Radiation Protection Outage Critique for incorporation into the Radiation Protection plans for the next refueling -
outage. Additionally, training will be provided to Radiation Protection personnel involving the timeliness of pre-job briefs, management expectations regarding compliance with pre-job instructions, and the process for documenting changes to Radiation Work Permit requirements.
~ This training will be completed by September 11,1998.
Date When Full Comoliance will be Achieved Full compliance was achieved on April 25,1998, when controls were implemented to prevent further spread of radioactive contamination associated with the east steam genemtor insulation.
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