ML18153B503
| ML18153B503 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/25/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18153B504 | List: |
| References | |
| EA-88-158, NUDOCS 8809080354 | |
| Download: ML18153B503 (3) | |
Text
t Docket Nos.
50-280 and 50-281 License Nos.
DPR-32 and DPR-37 EA 88-158 AUG 2 5 1988 Virginia Electric and Power Company t}'(T"TN:
Mr. D. S. Cruden, Vice President, Nuclear Operations Post Office Box 26666 Richmond, Virginia 23261 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-280/88-16, 50-281/88-16, 50-280/88-25 AND 50-281/88-25)
This refers to the Nuclear Regulatory Commission (NRC) inspections conducted at the Surry Power Station on May 2-6, 1988 and May 31 - June 3, 1988, respective-ly.
The inspections included a review of health physics activities during the Unit 1 refueling outage and a review of the circumstances surrounding an individual receiving an exposure on May 27, 1988, such that his total quarterly dose exceeded the NRC occupational radiation dose limit. The reports documenting these inspections were sent to you by letters dated June 28, 1988.
As a result of these inspections, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on July 6, 1988.
The letter summarizing this conference was sent to you on August 1, 1988.
Violations A, B, C, and D described in Section I of the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) are associated with exceeding the NRC occupational radiation dose limits and involved: failure to control an individual's occupational radiation exposure to less than 3 rems per calendar quarter; failure to adequately evaluate the radiation hazards present during work on the reactor vessel flange in Unit 1 containment; failure to adequately instruct individuals working in or frequenting a restricted area; and failure to have an adequate procedure for purposes of administering a Radiation Work Permit program.
The events or circumstances that resulted in the overexposure included entrance into Unit 1 containment on May 27, 1988, by three contractor workers to inspect and clean the reactor vessel flange in preparation for reseating the reactor head.
Prior to arrival of the contract workers at the job site, the health physics technician assigned to cover the work entered containment and performed a radiation survey at the work location.
The workers were informed that the radiation levels in the work area were 2-3 Roentgen per hour (R/hr); however, no mention was made of the 7-15 R/hr radiation levels measured inside of the reactor vessel flange, nor were the contractors given specific stay times or precautions for minimizing their radiation dose.
The work on the flange took significantly longer than initial-ly anticipated.
In addition, at least one of the workers performed part of the work in the higher radiation field. After completing the work and exiting the
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Viginia Electric & Power Co. AUG 2 5 1988 reactor cavity, a contractor asked another health physics technician to read their self-reading pocket dosimeters.
The technician found that all three contractors' low and high range dosimeters were off-scale. The health physics technician stopped all operations in the Unit 1 containment and all personnel, except for essential personnel, were escorted out of containment.
Upon evalua-tion of the thermoluminiscent dosimeters for the contractors and the health physics technicians, it was determined that one of the contractors received a radiation dose of 2.527 rem.
When this dose was added to his previous dose for the quarter of 0.752 rem, the total quarterly dose was 3.279 rem.
Violations E, F, and G described in Section I of the enclosed Notice are associated with the outage inspection and involved:
failure to provide radiation monitoring devices to personnel entering into high radiation areas; failure to post areas where respirators were required by health physics; and failure to perform adequate surveys to evaluate the extent of airborne radio-active material present.
The NRC is concerned that these violations collectively indicate significant weaknesses in the overall radiation protection program at the Surry Power Station.
During the Enforcement Conference, you indicated that the root causes of these violations were (1) -inadequate management control and support of the radio-logical control program, (2) inadequate technical expertise within the radiation protection staff, (3) inadequate work controls, and (4) inadequate procedur~s.
At the Enforcement Conference, you described a comprehensive and aggressive program addressing the root causes for the violations and for improving the performance and management oversight of the radiation protection program at Surry.
You also provided a written outlin~ of your performance improvement plan to the NRC (See Enforcement Conference Summary Letter dated August 1, 1988).
The contents of the written outline will be considered as formal commitments to the NRC.
Progress in meeting the commitments will be evaluated by the NRC during future inspections of your facility and periodic management meetings.
To emphasize the serious nature of the overexposure event and the need for improvements in the administration and control of your radiation protection program implemented to ensure the safe performance of licensed activities and adherence to NRC requirements, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Exec~tive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of One Hundred Thousand Dollars
($100,000) for the violations described in Section I of the enclosed Notice.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988) (Enforcement Policy),
the violations described in Section I of the enclosed Notice have been catego-rized in the aggregate as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III violation is $50,000.
The escalation and mitigation factors were considered, and the base civil penalty amount has been increased by 100 percent based on your prior poor performance in this area.
On June 13, 1988, the NRC issued a Notice of Violation and Proposed
Virginia Electric & Power Co. AUG 2 5 1988 Imposition of Civil Penalty (EA 88-114) as a result of failure to adhere to NRC requirements which led to a significant potential for overexposure of personnel during the incore detector maintenance that occurred in Unit 2 containment on March 3, 1988.
It appears that the corrective actions you took to improve your management controls over work in high radiation areas following the March 3, 1988 event were not effective in preventing the actual overexposure on May 27, 1988.
We are encouraged by your aggressive and extensive corrective actions that are now in progress, as presented during the Enforcement Conference.
However, your prior performance in this area and the fact that the corrective actions were not begun as promptly as we would have expected offset any potential for mitigation.
The violation described in Section II of the enclosed Notice involved the failure to adequately label four boxes containing radioactive material and two items of radioactive material located in radioactive material storage areas, in that the labels did not indicate radiation levels of the material.
You are required to respond to this letter and the enclosed Notice and should follow the instructions specified therein when preparing your response.
In your response, you should document the specific actions taken and any addition-al actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, -the NRC will determine whether NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice" Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Enclosure:
Notice Qf Violation and Proposed Imposition of Civil Penalty cc w/encl:
'vEf. L. Benson, Station Manager
~
E. Hardwick, Manager - Nuclear Programs and Licensing bee w/encl:
(See page 4)
Sincerely, Original signed by J. Nelson Grace J. Nelson Grace Regional Administrator