ML19318A705
| ML19318A705 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/11/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19318A702 | List: |
| References | |
| EA-80-026, EA-80-26, NUDOCS 8006240051 | |
| Download: ML19318A705 (4) | |
Text
.
C/
APPENDIX A NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos.53-324 and 50-325 Brunswick License Nos. DPR-71 and DPR-62 EA-80-26 Based on the NRC inspections conducted on March 10-14, 1980, and March 29 to April 3,1980, certain of your activities were apparently not conducted in full compliance with NRC requirements as indicated below:
A.
10 CFR 50.59(a) provides that a licensee may make changes in the facility as described in the Final Safety Analysis Report (FSAR) without prior Commission approval, unless the proposed change involves an unreviewed safety question.
A proposed change shall be deemed to involve an unreviewed safety question if a possibility of an accident or malfunction of a different type than any evaluated previously in the FSAR may be created; 10 CFR 50.59(b) provides that a licensee is required to maintain records which include a written safety evaluation providing the bases for the determination that the change does not involve an unreviewed safety question.
Technical Specification 6.5.1.7.b states that the Plant Nuclear Safety Committee (PNSC) is specifically responsible for performing the 10 CFR 50.59 safety evaluation. Technical Specification 6.5.1.6 states that the PNSC is specifically respensible for reviewing all proposed changes or modifications to plant systems or equipment that affect nuclear safety and all facility operations to detect potential safety hazards.
Contrary to the above, the auxiliary boiler system was operated from April 25, 1978 to February 22, 1980, withthecondensatereyrnwaterand auxiliary boiler and tank water contaminated up to 1.3 x 10 microcuries per milliliter.
Operation of the auxiliary boiler system during this period in a contaminated mode constitutes a change in tne facility as described in the FSAR.
FSAR Section 10.18 describes the auxiliary boiler system.
That description contains no indication that tnis system is to be operated in a contaminated mode and no analysis of the consequences of potential failures in the system when operated in a contaminated condition.
Consequently, the operation of the auxiliary boiler as a radioactively contaminated system represented a change'in the facility that had not been previously described and evaluated in the FSAR.
Tne PNSC failed to perform the required 10 CFR 50.59 safety evaluation.
Tne PNSC also failed to detect and evaluate the potential safety hazard of the contaminated auxiliary boiler.
This is a violation.
(Civil Penalty - $5,000) 800624006[
u.
Appendix A B.
Technical Specification 6.8.1(e) requires that written procedures be develcped, implemented, and maintained relating to emergency plan imple-mentation.
Emergency Plan Section 2.1.1 states that releases exceeding the instantaneous radiological Technical Specifications by a factor of 10 are classified as local emergencies.
Also, Emergency Implementing Procedure (E.I.) 27.3., Abnormal Release of Radioactivity-Airborne, requires immediate action to determine the magnitude of a release when it occurs and immediate radiation and airborne surveys to further assist in assessing the radiological consequences.
Contrary to the above, immediate actions were not taken to determine the magnitude of release and surveys were not properly initiated when a boiler tube failure resulted in releasing contaminated steam from the auxiliary boiler stack on February 22, 1980.
Calculations performed later indicate that the actual release exceeded the Technical Specifica-tion instantaneous release rate limit of 0.17 microcuries per second by a factor of 22.
Failure to determine the magnitude of the release and the associated radiological consequences precluded initiating a local emergency as required by the emergency plan.
This is a violation.
(Civil Penalty - $4,000)
C.
Technical Specification, Appendix B, Section 5.4.2.b requires a written report to be made to the Director of the appropriate NRC Regional Office (copy to the Director of Nuclear Reactor Regulation), within 14 days of an environmental event, i.e., violation of an environmental Technical Specification including the unplanned release of radioactive materials of significant quantity from the site shall be reported to the NRC within 14 days.
Contrary to the above, on February 22, 1980, an atmospheric release of a significant quantity of radioactive material occurred at the site.
The release was potentially as much as 160 millicuries by calculation and was released at a rate in excess of the Technical Specification limit of 0.17 microcuries per second.
Within the required 14 day period, the NRC was not informed that an airborne release had occurred nor was the required written report submitted.
This is an infraction.
(Civil Penalty - 54,000)
D.
10 CFR 20.203(c) requires that each high radiation area be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words CAUTION (or DANGER) HlGH RADIATION AREA.
Contrary to the requirements of 20.203(c), on March 11, 1980, a high radiation area near the southern most scram discharge header in the Unit 2 reactor building was not posted.
-Appendix A This is an infraction.
(Civil Penalty - $3,000)
E.
10 CFR 20.203(f)(1) and (2) require that each container of licensed material containing quantities greater than those listed in Appendix C of 10 CFR 20 bear a durable, clearly visible label identifying the radio-
' active contents and the radiation caution symbol and the words " CAUTION, RADI0 ACTIVE MATERIAL" or " DANGER, RADI0 ACTIVE MATERIAL." The label shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof to take precau-tions to avoid or minimize exposures.
Contrary to the requirements of 20.203(f)(1) and (2), during the period March 10-14, 1980, several containers of radioactive material in the Unit 2 Reactor Building, Warehouse "C" and in the plant yard near the auxiliary boilers were not labeled with the appropriate warnings and information.
Radiation levels measured by the inspector indicated that the containers contained quantities of radioactive material in excess of those quantities specified in 10 CFR 20, Appendix C, which require labeling.
The excep-tions to labeling requirements specified by 10 CFR 20.203(f)(3) did not apply.
This is an infraction.
A similar item was brought to your attention in a Region.II letter dated February 12, 1980.
(Civil Penalty $4,000)
F.
Technical Specification 6.12.1 requires any individual or group of individuals permitted to enter a high radiation area to be provided with or accompanied by one or more of the following:
1.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
2.
A radiation nonitoring device which continuously integrates the radiation dose rate in the area and alarms when a pre-set integrated dose is received.
3.
An ir.dividual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device.
10 CFR 19.12 requires all individuals working in or frequenting any portion of a restricted area to be kept informed of radiation in such portions of the restricted area.
Contrary--to the above, on-March 13, 1980, a group of individuals was observed working in the Unit 2 drywell, a high radiation area, without the required monitoring device (s) or the presence of a~ qualified individual to monitor for them.
This group of individuals had not been informed of the presence of the high radiation levels from a source n' ear their work area and were incurring unnecessary whole body exposures as a result.
-Appendix A This is a violation.
(Civil Penalty - 54,000)
This Notice of Violation is sent to you pursuant to the provisions of Section 2.201 ~of the NRC's " Rules of Practice," Part 2, Title 10, Code )f Federal Regulations. -You are hereby required to submit to this office, within twenty-five-(25) days of-the date of this letter, a written statement or explanation in reply, including for each item of noncompliance:
(1) admission or denial of the alleged item of noncompliance; (2) the reasons for the item of noncom-
. pliance, if admitted; (3) the corrective steps which have been taken by you and the results achieved; (4) the corrective steps which will be taken to avoh.further nonccmpliance; and (5) the date when full compliance will be achieved.
-.