ML18152A407
| ML18152A407 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/13/1988 |
| From: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-387, NUDOCS 8807200396 | |
| Download: ML18152A407 (11) | |
Text
D.S.CnuDEN VICE PRESIDEN'r-NucLEA.R VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 13, 1988 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10 Serial No.
NO/GDM:pms Docket Nos.
License Nos.88-387 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of June 13, 1988, in reference to the inspection conducted at Surry Power Station on March 5 11 and 23 25, 1988 and reported in Inspection Report Nos.
50-280/88-10 and 50-281/88-10.
Our response to the violations described in the Notice of Violation is provided in Attachment I.
Payment of the assessed civil penalty is provided in Attachment II.
Please note that several of the corrective actions identified in this response were recently discussed at a July 6, 1988 enforcement conference.
This conference was held to address radiological protection concerns identified in NRC Inspection Report Nos. 50-280/88-25 and 50-281/88-25, dated June 28, 1988.
We believe that the corrective actions discussed at the July 6 conference better address the management control and radiological protection issues common to both events.
In several cases, the corrective actions are substantially more comprehensive than the actions previously identified at the April 21, 1988 enforcement conference.
Additional action is being taken to inform the nuclear industry of this event through appropriate Network entries, discussion.at INPO radiation protection workshops, and distribution 0£ an informative videotape to other utilities
- 8807200396 :380713 PDR ADOCK 05000280 Q
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We have no objection to this inspection repo-rt being made a matter of public disclosure.
If you have any further questions, please contact us.
Very truly yours, Attachments cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W.E. Holland NRC Senior Resident Inspector
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- i RESPONSE TO NOTICE OF VIOLATION ITEMS REPORTED DURING NR.C INSPECTION CONDUCTED ON MARCH 5-11 AND 23-25~ 1988 INSPECTION REPORT NOS. 50-280/88-10 AND 50~281/88-10 During the Nuclear Regulatory Commission (NRC) inspection conducted on March 5-11 and 23-35, 1988, violations of J\\TRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violation and associated civil penalty are set forth below:
A.
10 CFR 20.201 (b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201 (a) defines a "survey" as 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.
B.
Contrary to the above, the licensee failed to adequately evaluate the extent of the radiation hazards present in that, on March 3,
- 1988, three individuals entered the Unit 2
containment and performed maintenance work on the "A" drive unit incore detector and cable that led to very high radiation dose rates in their immediate vicinity.
Technical Specification 6.4.A procedures with appropriate provided for preventative or which would have an effect on requires that detailed written checkoff lists and instructions be corrective maintenance operations the safety of the reactor.
Technical Specification 6.4.B.
requires that radiation control procedures be provided and that the station radiation protection program be organized to meet the requirements of 10 CFR 20
- Technical Specification 6.4.F requires that temporary changes to procedures described in 6.4.A and B which change the intent of the original procedures may be made, provided such changes are approved prior to implementation.
Station Procedure SUADM-ADM-21, dated January 26, 1988, requires in step 5.4.3.c that the Station Nuclear Safety and Operating Committee (SNSOC) review and approve, prior to implementation, all temporary changes or deviations from approved procedures if the intent of the procedure is changed *
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Contrary to the above, the licensee failed to properly classify a change to a
procedure as a change of the intent and to provide adequate written procedures in that on March 3,
- 1988, Maintenance Procedure IMP-C-IFM-20, Replacing Incore Flux Mapping Detector, dated August 27, 1987, and the associated change or deviation to free the stuck detector, dated March 3, 1988, did not have sufficient detailed instructions addressing such considerations as assessment of detector
- position, irradiation/activation analyses, involvement of health physics in the pre-job briefing/assessment, precautions concerning high radiation levels and limitations on the job for freeing the stuck detector to ensure that technicians working to dislodge the A incore flux detector did not pull the incore detector and the associated cable beyond a point which could cause a significant potential for overexposure.
Also, the change to the procedure was not approved by SNSOC prior to implementation even though it changed the intent of the original procedure by adding instructions to free the stuck detector.
C.
Technical Specification 6.4.D requires that procedures described in 6.4.A and 6.4.B be followed~
- 1.
- 2.
Maintenance Procedure IMP-C-IFM-20, Replacing Incore Flux Mapping Detector, dated August 27, 1987, and the associated change or deviation to free the stuck detector, dated March 3,
- 1988, required the workers to disengage the "A"
hold-down wheel, free the stuck detector and reengage the hold-down wheel to allow the cable and detector to be retracted and then driven to storage electrically.
Contrary to the above, on March 3,
- 1988, the workers continued to manually pu11 the cable into the work area after freeing the stuck detector rather than reengaging the hold-down wheel and withdrawing the detector electrically, resulting in radiation levels greater than 1000 rem per hour in their work area.
Health Physics Procedure HP-3.1.3, Personnel Dosimetry -
Dosimetry Issue and Dose Determination, dated December 8,
- 1986, requires in Step 4.13.1.3.c that no person, who has been working in an area where the non-uniformity of the radiation fields meets the criteria for the use of special dosimetry and special dosimetry was not worn, is to be allowed entry into the Restricted Controlled Area (RCA) until the form HP-14 is completed and the calculated dose is recorded.
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Contrary to the
- above, as of March 10,
- 1988, the individuals involved in the maintenance activities on the incore detector in Unit 2 containment on March 3, 1988, an area meeting the criteria for the use of special dosimetry, had not been excluded from entering the RCA.
Special dosimetry had not been worn during the incore work, nor had their radiation dose resulting from the incore work been calculated and recorded.
These violations have been evaluated in the aggregate as a Severity Level III problem (Supplement IV).
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- l ITEM A RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10 (1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
(2)
(3)
(4)
The violation is correct as stated.
REASON FOR VIOLATION:
The violation occurred due to inadequate management involvement and control of the pre-job preparations for repair of the incore detector system.
Reliance on past successful experience with similar jobs resulted in the failure to recognize or adequately consider the potential radiological hazards associated with the job.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Station management has issued directives which require additional review and evaluation of proposed tasks with similar potential for high radiation exposures.
Pre-job briefing guidelines have been developed and implemented to ensure full discussion and consideration of radiation hazards incident to these work activities.
Briefings are administered by Health Physics personnel and require specific consideration of actual or potential radiation hazards, problems which may be encountered, and contingency plans.
Certain tasks which have the potential for higher radiation exposure have also been identified which require review and approval by the Station Nuclear Safety and Operating Committee.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
An extensive review of the radiological protection program is underway
- A recognized industry consultant has been retained to provide guidance for this review.
Management emphasis has been placed on accelerating implementation of the Radiological Protection Plan,. which will provide additional administrative controls for radiation work activities.
Procetlures related to control of work activities will be implemented by September 1,
- 1988, with the remainder of the program in place by December 31, 1988
- In addition, organizational changes-in the HP organization wili provide additional radiological engineering expertise on site, as well as enhanced corporate assessment of station HP practices.
These measures will serve to improve the station's ability to anticipate potential high exposure activities, and implement appropriate levels of control.
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This
- event, as well as other recent events in the radiological protection area, will be the subject of a series of meetings to be held by the Station Manager with employees of each department involved in radiation work activities.
These meetings will focus on the recent events and their causes and corrective actions, as well as the importance of procedural compliance.
These meetings are scheduled to be complete by July 31, 1988.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
the radiological protection*program the remaining months of 1988.
The aggressive program to enhance is underway with milestone dates in
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- 1 I I I RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10 ITEM B (1)
(2)
(3)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct insofar as adequate controls were not provided to ensure that the work activities did not result in unanticipated radiation levels in the work area.
However, the maintenance procedure, IMP-C-IFM-20, was not intended to provide such* radiological controls.
This procedure was written with sufficient detail to ensure work quality and to ensure that the safety of station operations was not affected.
In this context, the procedure deviation, which added steps to free the stuck detector prior to withdrawal by the motor drive and to replace the
- detector, did not meet the criteria for prior SNSOC approval as delineated in administrative procedure SUADM-ADM-21.
The deviation was
- approved, as required, by the cognizant supervisor and Shift Supervisor prior to implementation.
The deviation, as written, was judged to not involve a change of intent since it did not impact the objective of the procedure.
REASON FOR THE VIOLATION:
Adequate radiological work controls were not implemented as a result of an inadequate review of the proposed work activities.
Historical experience with stuck incore detectors suggested that the major radiation hazard would be the detector itself.
This did not recognize the potential for activation of the cl.rive cable, nor was the position of the detector in the core adequately determined.
The pre-job briefing did not include participation by health physics personnel; therefore, adequate provisions for radiological protection, including explicit limitations on drive cable manual withdrawal, were not discussed or implemented.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Management actions have been taken to implement additional controls over radiation work activities.
These include requirements for pre-job briefings, to include Health Physics participation, which ensure full discussion and consideration of radiation hazards incident to proposed work.
Specific consideration of actual or potential radiation hazards,'
potential problems,.and contingency plans, are required.
In addition, for certain identified tasks, prior approval by the Station Nuclear Safety and Operating Committee is required.
These tasks include any work on the inaore detector system insiae containment.
As further assurance that necessary reviews have been conducted, specific approval from the Station Manager or an Assistance Station Manager is required prior to any entry of the containment under subatmospheric conditions.
The maintenance procedure for replacing incore detectors modified to include specific guidance for freeing a
stuck including appropriate radiological protection requirements.
has been
- detector,
(4)
In order to further clarify requirements for procedure deviations involving a "change of intent", further definition has been provided in SUADM-ADM-21.
In addition to the previous specific definitions, the intent of a
procedure has been broadened to. include the proper sequencing of activities and specific actions that must be accomplished to ensure the satisfactory completion of the task.
The requirement for SNSOC pre-approval of such proposed changes exceeds the requirements of the Technical Specification and serves to enhance management oversight of work activities.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Enhancements are program which will briefings, and being applied to more effectively being implemented for the radiological protection further define processes for pre-job evaluations, control implementation.
Additional resources are the radiological engineering function in order to assess potential radiation hazards.
The importance of procedural compliance, as well as review and approval of procedure deviations, will department meetings to be conducted b~ the Station 31, 1988.
the process for be included* in the Manager by July (5)
THE DATE.WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
The program to enhance the radiological protection program is underway with milestone dates in the remaining months of 1988.
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'I RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10 ITEM C.l
RESPONSE
(1)
(2)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
REASON FOR THE VIOLATION:*
Maintenance Procedure, TMP-C-IFM-20, Replacing Incore Flux Mapping Detector, was deviated to free the stuck incore flux detector (A
detector) and required the technicians to disengage the "A" hold-down wheel to allow the detector to be withdrawn electrically.
The approved deviation was improperly exceeded by the technicians when initial attempts to free the detector for electric withdrawal were unsuccessful.
The technicians continued to manually withdraw the cable into the work area, resulting in excessive radiation levels.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
(4)
(5)
A memorandum was issued by the Station Manager to station employees and contractors emphasizing the importance of procedural compliance, specifically when unexpected conditions arise during work activities.
Furthermore, IMP-C-IFM-20 has been revised to address additional precautions, limitations, and instructions for the freeing and replacement of incore detectors.
The revision to the procedure includes the collection of data to determine the dose assessment for stuck detectors, the requirement for a pre-job briefing, and the instructions for removal of stuck detectors.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The Station Manager will conduct department-specific briefings to include discussion of the importance of procedural compliance *.
Since procedural compliance can be related to the quality of the
_procedures available to station employees, a
program to enhance procedure quality has been intiated.
This effort will be designed to ensure proper procedure architecture and human factors considerations, through the implementation of a standard Writer's Guide, and consideration of departmental interfaces by a
centralized station procedure writing group.
Station procedures will be prioritized for revision under this process, with the procedure revision cycle scheduled to be complete by December 31, 1991.
THE DATE WHEN FOLL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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. i RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-10 AND 50-281/88-10 ITEM C.2
RESPONSE
(1)
(2)
(3)
(4)
(5)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
REASON FOR THE VIOLATION:
The violation occurred due to an erroneous assessment of the true source geometry immediately following the exposure event.
This assessment, performed by station Health Physics supervision, assumed that the source of the high radiation fields at the incore detector drive unit were due solely to the irradiated incore detector; a point source.
Additionally, based on the debriefing with personnel involved in this event, the detector was thought to be located at the outer face of the crane wall, thus placing the source in an uncollimated geometry.
These assumptions, when factored into known worker orientation~ lead to the conclusion that the radiation field was uniform with respect to whole body and extremity exposures.
Subsequent recovery actions disproved these initial assumptions -with regard to the source geometry and radiation field characteristics.
At this point, the individuals involved in the exposure event should have been excluded from further entry to the RCA.
However, this procedural requirement was not immediately identified.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Upon notification of the procedural noncompliance, individuals were excluded from further RCA entry and remained until final doses were determined and properly recorded.
the three excluded The requirements of Procedure HP-3.1.3 have been reviewed with appropriate Health Physics supervisory personnel.
Additionally, emphasis has been placed on the need to reevaluate procedural requirements whenever initial evaluations or assumptions are modified.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
None required
- THE DATE WHEN FOLL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.