ML14176A651
| ML14176A651 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/26/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML14176A652 | List: |
| References | |
| NUDOCS 8109090476 | |
| Download: ML14176A651 (4) | |
See also: IR 05000261/1981007
Text
k REG
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~UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 11
101 MARIETTA ST., N.V., SUITE 3100
ATLAiNTA GEORGIA 30303
JUN 2 6 1981
In Reply Refer To:
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RII:JRW
50-261/81-07
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Carolina Power and Light Company
ATTN:
Mr. J. A. Jones, Senior Executive
Vice President and Chief
Operating Officer
SEP 0919810
411 Fayetteville Street
Raleigh, NC
27602
Gentlemen:
Subject: Health Physics Appraisal
During the period of January 26 - February 6, 1981, the NRC conducted a special
appraisal of the health physics program at the H. B. Robinson facility.
This
appraisal was performed in lieu of certain routine inspections normally conducted
in the area of health physics.
Areas examined during this appraisal are
described in the enclosed report (50-261/81-07).
Within these areas,
the
appraisal team reviewed selected procedures and representative records, observed
work practices, and interviewed personnel.
It is recommended that you carefully
review the findings of this report for consideration in improving your health
physics program.
The appraisal conducted at the H. B. Robinson facility was part of the NRC's
general program to strengthen the health physics programs at nuclear power
plants.
As a first step in this effort, the Office of Inspection and Enforcement
is conducting these special appraisals of the health physics programs at all
operating power reactor sites. These appraisals were previously identified to
you in a letter dated January 22,
1980, from Mr. Victor Stello, Jr., Director,
NRC Office of Inspection and Enforcement. One of the objectives of the health
physics appraisals is to evaluate the overall adequacy and effectiveness of the
total health physics program at each site and to identify areas of weakness that
need to be strengthened.
We also intend to use the findings from these
appraisals as a basis for improving NRC requirements and guidance.
Consequently,
our appraisal encompassed certain areas which may not be explicitly addressed by
current NRC requirements. The next step that is planned in this overall effort
will be the imposition of a requirement by the Office of Nuclear Reactor
Regulation (NRR) that all licensees develop, submit to the NRC for approval, and
implement a Radiation Protection Plan. Each licensee will be expected to include
in the Radiation Protection Plan sufficient measures to provide lasting correc
tive action for significant weaknesses identified during the special appraisals
of the current health physics programs. Guidance for the development of this
plan has incorporated pertinent findings from completed special appraisals and
was issued for public comment in April, 1981.
8109090476 810626
PDR ADOCK 05000261
n
JUN 2 6 1981
Carolina Power and Light Company
2
The findings of this appraisal at the H. B. Robinson facility indicate that,
although your overall health physics program is adequate for present operations,
significant weaknesses exist. These include the following:
a.
the external exposure control program has not been adequately implemented in
the area of personnel dosimetry during steam generator channel head entries;
b.
the personnel
contamination control
program
has not been adequately
implemented;
c.
the radiological surveillance program has not been adequately implemented;
and
d.
the safety evaluation performed to determine if
the operation of the
contaminated auxiliary boiler was acceptable did not include an assessment
of the consequences of potential release of radioactivity to the environment
nor did it
include a comparison of such releases with the radioactive
effluent limits of 10 CFR 20 and the facility's Technical Specifications.
These items were identified to your plant management during the exit interview on
February 6, 1981.
They were also discussed with you by telephone on February 10,
1981, by R. C. Lewis of the Region II office. The results of this conversation
and our understanding of your planned corrective actions were also discussed in a
letter to you from James P. O'Reilly dated February 10, 1981.
These findings are discussed in more detail in Appendix. A, "Notice of Significant
Appraisal Findings".
We recognize that regulatory requirements pertaining to the
significant weaknesses identified in Appendix A may not currently exist.
How
ever, to assist us in determining whether adequate protection will be provided
for the health and safety of workers and the public, you are requested to submit
a written statement within twenty-five (25) days of your receipt of this letter
describing your corrective action for the significant weaknesses identified in
Appendix A, including: (1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of action.
This request is made
pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
In so far as Significant Finding A resulted in a special inspection conducted on
March 2-4, 1981 and your response to the apparent violations listed in Appendix A
to our letter of May 12,
1981 addresses the inadequacies in your external
exposure control program during steam generator work, you are not required to
respond to Significant Finding A herewith.
During the inspection, it
was found that certain activities under your license
appear to violate NRC requirements.
These items and references to pertinent
requirements are listed in the Notice of Violation enclosed herewith as Appen
dix B. A written response is required.
Elements to be included in your response
are delineated in Appendix B.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this
O
letter and the enclosed report will be placed in the NRC's Public Document Room.
If the report contains any information that you believe to be exempt from
Carolina Power and Light Company
3
disclosure under 10 CFR 9.5(a)(4),
it
is necessary that you:
(a) notify this
office by telephone within ten days from the date of this letter of your
intention to file a request for withholding; and (b) submit within twenty-five
days from the date of this letter a written application to this office to
withhold such information. If your receipt of this letter has been delayed such
that less than seven days are available for your review, please notify this
office promptly so that a new due date may be established.
Consistent with
section 2.790(b)(1),
such application must be accompanied
by
an affidavit
executed by the owner of the information which identifies the document or part
thereof sought to be withheld, and a full statement of the reasons on the basis
of which it
is claimed that the information should be withheld from public
disclosure.
This section further requires the statement to address with
specificity the considerations listed in 10 CFR 2.790(b)(4).
The information
sought to be withheld shall be incorporated as far as possible into a separate
part of the affidavit.
If we do not hear from you in this regard within the
specified periods noted above, the report will, be placed in the Public Document
Room.
Should you have any questions concerning this inspection, we will be pleased to
discuss them with you.
Since ely,
James P. O'Reilly
Director
Enclosures:
1. Appendix A, Notice of Significant
Appraisal Findings
2. Appendix B, Notice of Violation
3.
Inspection Report No. 50-261/81-07
cc w/encl:
R. B. Starkey, Plant Manager
APPENDIX A
NOTICE OF SIGNIFICANT APPRAISAL FINDINGS
Carolina Power and Light Company
Docket No. 50-261
H. B. Robinson 2
License No. DPR-23
Based on the Health Physics Appraisal conducted on January 26 - February 6, 1981,
the following items appear to require corrective actions:
(Section references
are to the Details portion of the enclosed Inspection Report)
A.
The external exposure control program was deficient in the area of personnel
dosimetry during steam generator channel head entries.
Survey data indi
cated that non-uniform and complex radiation fields existed in both hot and
cold leg sections of each steam generator.
Personnel radiation monitoring
consisted of chest worn self-reading and thermoluminescent dosimeters.
Based on available information, it was evident that workers were receiving a
significantly greater whole body dose to the head or gonads than previously
recorded by dosimetry worn on their chest (Section 8.g).
B. The personnel contamination control program was deficient.
The appraisal
found:
(1) improper training of workers in the removal of protective
clothing, (2) inadequate number and location of personnel friskers in the
auxiliary building, (3) inadequate attention to and control of protective
clothing to ensure that defective anticontamination clothing is not provided
to workers, and (4) insufficient management attention and corrective actions
taken in response to excessive personnel contamination instances (Sections
5.b, 8.a-b and 11.a).
C. The radiological surveillance program was deficient. The appraisal found:
(1) the scope of radiation, contamination and airborne radioactivity surveys
was not adequate to determine the general radiological status of the plant,
(2) specific radiological surveys for radiation work permits written to
support specific work activities were not being conducted,
and (3) a
detailed radiation survey of the secondary plant had not been performed even
though. primary to secondary leaks had occurred nor had a program been
established to ensure that areas outside the radiation control area are
routinely surveyed (Sections 8.c-e).
D. The safety evaluation performed to determine if
the operation of the
contaminated auxiliary boiler was acceptable (i.e.,
does not involve an
unreviewed safety question or a change to Technical Specifications) did not
include the following elements specified by IE Bulletin 80-10:
(1) an
assessment of potential releases of radioactivity to the environment, or (2)
comparison of such releases with the radioactive effluent limits of
10 CFR 20 and the facility's Technical Specifications (Section 10.c).