ML19259B579
| ML19259B579 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 03/08/1978 |
| From: | Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19259B576 | List: |
| References | |
| NUDOCS 7903060089 | |
| Download: ML19259B579 (6) | |
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a APPE': DIX A HOTICE OF VI0t.ATION Boston Edison Company Docket No. 50-293 This refers to the inspection conducted by representatives of the Region I (Philadelphia) office at the Pilgrim Nuclear Pewar Station, Unit 1 Plymouth, rassachusetts, of activitics authorized by NRC License No.
During this inspection conducted on Nove:rber 23-30, 1977, the folicwing apparent items of ncncompliance were identified.
I.
10 CFR 20.101(a), " Exposure of individuals to radiation in re-stricted areas," limits the whole body dose to an individual in a restricted area to or.c and one quarter rers per calendar cuarter exceot as orovidad by 10 CFR 20.lGl(b).
Paragraph (b) allows a whole bc-!y dose of three rens per calendar quarter provided certain.
specified cor.ditions are ret.
Contrary to this recuirermnt, on Nevenber 23, 1977, one individual working in a restricted area received a whole body dose of 3.55 re.ms during the fourth quarter of 1977, which exceeded the applicable limit of 3 rems.
This is an infracticn - (Civil Penalty M,000)
II.
10 CFR 19.12, " Instructions to workers" states, in part, "All individuals workin; in or frecuenting any pcrtion of a restricted area shall be kept infocad of the stcraa, transfer, or use of radioactiva caterials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated with exco::ure to such radioactive raterials or radiation, in precautions or procedures to minintae exposure..."
Contrary to the above, on Novceber 23, 1977, two contractor encloyees working on the Rad '.!aste floor, a restricted area, were rot properly instructed to ninini: e their excosure in that instructions were not sufficient to creclude inadvertent entry into the Sludge Tank Receiver P.com which is a hi'Jh radiation area. This failure to properly instruct perscnnel contributed to the overexpcsure of an individual described in Item I.
This is an infraction - (Civil Fenalty $4,000) 20/3 In 7 9 0 3 0 6 0 0 8N
Appendix A ina BW III. Technical Specification 6.11, " Radiation Protection Progran" states.
" Procedures for personnel radiation protection shall be preoared consistent with the requirecents of 10 CFR Part 20 and shall be approved, raintained and adhered to for all ccerations involving personnel radiation exposure." Padiation Protection Procedure 6.1-
.012, " Access to Hhh Radiation Arcas," requires that areas with radiation levels creater than 1 ram per hour, but less than 10 rens per hour, be locked as required by Technical Specification 6.13 "lligh "adiation Areas." The procedure also requires that areas with radiatica levels greater than 10 rems per hour be locked with an additional padlock.
Contrary to this requirctent on ficycrbor 23, 1977, the Sludge Tank Peceiver P. con, an area in which aeneral radiation levels mre as much as 15 rems per hour, was not locked with an additforal pad-lock. This failure to adhare to procedures centributed to the overexposure of an individual described in Item I.
This is an infraction - (Civil Penalty $4,000)
IV.
10 CFR 20.103, " Exposure of individuals to concentrations of radio-active naterials in air in restricted areas," recuires in part that suitable reasurcrents of concentrattens of radioactive ratorials in air te used for detectinq and evaluating airborne radioactivity in restricted areas. Technical Specification 6.11. "Radiatf oc Protec-tion Proqran," recuires that radiation protection procedures te prepared consistent with the requirements of 10 CFR Part 20.
Procedure Ho. 6.1-022 recaires that certain radiolecical surveys te perfor ed as a ninimum, including the collection and evaluation of representative air samples from work areas and also requires that survey results be entered on the "adiation i.'crk Pennit (PJ:P).
Further, Precedure ib. 6.1-029 requires that continuous Particulate and iodine air sr:ples le taken in occunied areas containina snear-able contamination greatnr than 100,bO3' dpa per 100 cm2 Contrary to the above, on ::ove9er 23,1977, while personnel s
perfered a valve rcnoval operation in the Clean t!aste Tank Roon (an operation and area haviaq snearable contamination levels greater I
than 100,000 dpa per 100 ci-) the raauf red air concentration measure"ents were not oerformd prior to or during the tiork, to detect and evaluate airborne radioactivity.
This is an infraction - (Civil Penalty $4,000) i g7 d
Appendix A l'M 8 #8 The " Criteria for Deternining Enforcement Action," which was provided to llRC licensees by letter dated Dececher 31, 1974, delineated the enforce-r.'ent options available to the lif:C is including adninistrative actions in the fona of written notices of violation, civil conetary penalties, and orders pertainino to the c.odification, suspension or revocation of a license.
Af ter careful evaluation of the nature and repetitiveness of these itens, this office proposes to impn=e civil penalties cursuant to Section 22^ of the itemic Encrcy Act of 1954, as amended, (42 USC 2202) and 10 CFR 20.205, in the cunulative enount of Sixtcon Thousand Collars
($16,001), as set forth in the ".'letice of Proposed Irposition of Civil Penalties," onclosed herewith as Appendix G.
This notice of violation is sent to Ecston Edison Cmpany cursuant to the provisions of Section 2.201 of the I:P.C's " ules of Practice," Part 2, Title 10, Code of Federal Pequlations.
Ecston Edisnq Ceconny is hereby recuired to subnit to this office within tuenty (?0) days of the receipt of this r,ctice, a written statenent er explanation in realy, including for each iten of ncncenalianca, (1) adnission cr denial of the alleged itens of noaccroliance: (2).the reasons for the itens cf noncon-plience if e.Mitted; (3) the corrective steps which have bcnn taton and the results achieved; (4) corrective steps which will be taken tn avoid further items of noncc. pliance; and (5) the date when full compliance m
will be achieved.
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MAR 8 1978 APPE*: DIX B
!!0TICE OF PROPOSED I" POSITION OF CIVIL pef'ALTIES Boston Edison Company Docket Jo. 50-293 This office procoses to impose civil penaltics pursuant to Section 234 of the Atonic Energy Act of l?E4, as amended, (A2 USC 2282), and to 10 CFR 2.205 in the cunulative arcunt of Sixteen Thousand Dollars ($16,000) for the specific items of nonconplianco set forth in Arpendix A to the cover letter.
In proposino to in;;ose civil penalties rursuant to this section of the T,ct and in fixing the prcposed arcunt of the penalties, the factors identified in the statments of consideration published in the Federal Reoister with the rule reking action which adopted 10 CFR 2.205 (35 FR 15394) August 26, 1971, and the " Criteria for Deternining Enforcement Action" which was sent to NRC licensees on December 31, 1974, have been taken into account.
Boston Edison Conpany cay, within tuenty (20) days of receipt of thi.,
notico pay the civil penalties in the cumulative amount of Sixteen Thousand Collars (516,000) or nay protest the icposition of the civil penalties in ubole or in nart by a written arsuer.
Should Boston Edisen Company fail to anruer within the tir:a specified, this office will issue an order innosin'T the civil penalties in the arount proposed cbove.
Should Sosten Edisen Ccapany elect to file an answer nrotestino the civil penalties, such an answer nay (a) deny the itens of nonce:cpliance listed in the Motice of Violatien in whole or in part, (:>) demonstrate extenuating circunstances, (c) shcu error in the !:atice of Violation, (d) shou other reasons why the penalties should not be imposed.
In addition to protestinq the civil penaltics in whole or in part, such an-suer cay recuast remissica or niticaticn of the nanalties.
Tny written ansuer in accordance with 10 CFR 2.205 should be set forth senarately.
from the statenent or explanation in reply pursuant to 2.231, but may.
incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Boston Edison Coraany's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to ansuor and ensuing orders; ansuer, consideration by this effice, and ensuina orders; requests for hearings, hearings and ensuing orders; cenpronise; and collection.
Upon failure to pay any civil panalty due which has been subsecuently detemined in accordance with the ar,plicable provisions of 10 CFR 2.203, the rattar ray be referred to the Attorney Gnaral, and the penalty, unless comnrenised, remitted, or mitigated, ray be collected by civil action pursuant to Section 234c of the Atoaic Energy Act of 1954, as anended, (42 USC 22S2).
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APPE!: DIX C ga
- die Boston Edison Comcany Enforcement History Relating to Radiation Protection 5 76 to 11 77 License No. DPR-35 Docket flo. 50-293 tANAGEMEifT !EETI!MS
_Date Problent Initiatinn Ection July 1976 Continuino concerns related to the manag rent and imolementation of the Health Physics Progran October 1976 Continuing concerns related to the canagement and implenentation of the Health Physics Progran November 1977 Continuing concerns related to the canagement and inplementation of the Health Physics Progran H0ilCOMPLIA?:CE ITE!iS Inspection 76-12 (Inspection Exposure of 3.127 rems during 2nd calendar conducted on ".ay quarter of 1976.
21-26, 1976)
(Repetitive)
Radiation areas and high radiation areas not posted.
Failure to control access to high radiation area.
(Repetitive)
Failure to follow Radiation Work Permit (PHP) by contractor personnel.
(Repetitive)
Failure to instruct workers.
76-27 (Inspection Inadequate air sampling progran, conducted on September 21-24 and 28-30,1976)
No individual on one shift qualified in radiation nrotecticn nrocedures.
2d73 o2 ooog ag g q
' Appendix C.
MAR 8N Insrection !!o.
Uritten apprcval not obtained on four occasions prior to exceeding 1300 e, rem / week.
(Repetitive)
Individual exceeded 10 CFR 20.101 limits without having records of his previous occupational exposure.
77-07 (Insnection Rooms with radiation levels in excess of 100 arem/ hour conducted on not controlled at several locations.
March 31,loril 4 (P.epetitive) and April G-3, 1977) 77-21 (Ir.spection Individual received 2.000 rens during third quarter conducted on of 1977 withcut having a Fonn i!RC-4.
Aunust 9-12,15, (P.apetitive) 31 and Septenber 6,14-16,1977)
Rediaticn protection procedures not adhered to in six instances.
(Repetitive)
Survey not rads to assure conpliance with 10 CFR 20.101.
(Repetitive)
Representative air samples not taken on several occasions.
(Repetitive)
Posting or barricading not provided at access points or areas where radiation levels were greater than 100 mrm/hr but less than 1000 circm/hr.
(Repetitive)
Procedures for personnel radiation protection not consistent. with requirements of Tech Specs.
Change to P.WP procedure not reviewed and approved as required.
Shipping cask with radiaticn levels as high as 100 mrea/hr not labeled nor were contents identified.
41 2073 133