ML18152B005
| ML18152B005 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/13/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152B004 | List: |
| References | |
| 50-280-88-10, 50-281-88-10, EA-88-114, NUDOCS 8806240075 | |
| Download: ML18152B005 (4) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITI~OF CIVIL PENALTY Virginia Electric and Power Company Surry Units 1 and 2 Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 EA 88-114 During the Nuclear Regulatory Commission (NRC) inspection conducted on March 5-ll and 23-25, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 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 violations 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 11survey 11 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.
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 11A 11 drive unit incore detector and cable that led to very high radiation dose rates in their immediate vicinity.
B.
technical Specification 6.4.A requires that detailed written procedures with appropriate check-off lists and instructions be provided for preven-tive or corrective maintenance operations which would have an effect on 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 ch~nges are approved prior to implementation.
Station Proced.ure 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.
8806240075 880613 PDR ADOCK 05000280 Q
DC:D
Notice of Violation 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.
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 11A 11 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 pull 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.
- 2.
Hea 1th Physics Procedure HP-3.1. 3, Personne 1 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.
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).
Cumulative civil penalty - $100,000 (assessed equally between the violations).
Notice of Violation Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a 11 Reply to a Notice of Violation 11 and should include for each violation:
(1) admission or denial of the violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.. Should the licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed.
In addition to protesting the civil penalty, such answer may request remission or mitigation of the penalty.
In requesting mitigation.of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1988), should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 b~t may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the licensee ts directed to the other provisions of 10 CFR 2.205 regarding the procedure for imposing a civil penalty.
Upon failure to pay the penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
Notice of Violation The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II and a copy to the NRC Resident Inspector, Surry facility.
Dated at Atlanta, Georgia this I~~ day of June 1988 FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY:
J. NELSON GRACE J. Nelson Grace Regional Administrator