ML19330B818
| ML19330B818 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/01/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19330B817 | List: |
| References | |
| EA-80-041, EA-80-41, NUDOCS 8008070027 | |
| Download: ML19330B818 (4) | |
Text
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APPENDIX A
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NOTICE-OF. VIOLATION Carolina' Power and Light Company Docket Nos: 50-324 Brunswick 50-325 EA-80-41 Based on the NRC inspection conducted on April 26 to May 16, 1980, certain of your activities apparently were not conducted in full compliance with NRC requirements as indicated below.
A.
10 CFR 20.301 prohibits a licensee.from disposing of licensed material except as authorized by 10 CFR Parts 20, 30, 40, and 70.
In addition, 10 CFR 20.201 requires that surveys be made as may be necessary to comply with 10 CFR Part 20.
Contrary to the above, on at least 16 separate occasions durir.g the period from mid-1978 through April 1980, licensed material (in the form of contaminated equipment) was disposed of without authorization.
In addition, surveys conducted for the purpose of detecting and identifying items radioactively contaminated with licensed material were inadequate, thereby contributing to the unauthorized disposal of licensed material.
These 16 occasions consisted of the following disposals: at least 13 times during mid-1978 through April 1980, to the Brunswick County sanitary landfill; once during April 1980, to the North Carolina Salvage Company in Goldsboro; once during May 1979, to the Horton Iron and Metal Company; and, once prior to May 1980, to the Merrit Holland Company in Wilmington, North Cardlina.
Each of these 16 occasions (inadequate surveys and resulting unauthorized disposals) constitutes a separate infraction and a civil penalty o,f $4,000 is proposed for each.
(Cumulative civil penalty - $64,000).
B., BSEP Technical Specification (T.S.) 6.8.1.a requires that written procedures be established, implemented, and maintained covering the activities and procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972.
This Regulatory Guide requires radiation protection procedures for control of radioactive materials to prevent release to the environment and minimize personnel exposure.
1.
Licensee procedure BSEP Vol. VIII, RPM, paragraph 6.2.2, requires
.thatequipmenttobeunconditionallyreleasedfromthe"Radiat{on Control Area" to the " clean area" have less than 200 dpm/100cm loose surface contamination and less than 0.25 mR/hr fixed contamina-tion measured at one inch from the surface of the item.
The " clean area" is defined as any area within the " Controlled Access Area" in which contamination levels are less than those specified above.
The
" Radiation Control Area" is defined as any area to which access is controlled for the purpose of limiting radiation exposure or preven-ting the spread of contamination.
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Appendix A.-
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- Contrary to the above, on April 29, 1980, this procedure was not implementeil in that cr,iteria.used by contract wprkers would have' j
permitted the release of items to the clean area Vith levels of loose surface contamination in' excess of the above limits.
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2.
BSEP Vol. VIII, RPM, p.tragraph 6.6.6, requires personnel leaving the Radiation Control Area to monitor themselves for contamination.
Contrary to the above, on April 27, 1980, two workers exiting the reactor building 50' elevation near the torus access (a Radiation Control Area) failed to monitor themselves for contamination at the monitor station provided.
3.
BSEP Vol. VIII, RPM, paragraph 10.1.1, requires personnel to be assisted by the Radiation Control and Test Group (RC&T) in cases of skin contamination.
Contrary to the above, on April 29, 1980, three non-RC&T individuals at the personnel decontamination station were engaged in decontamina-tion of their skin.
The workers failed to notify RC&T to gain assistance although a call button was provideq for workers' use.
4.
RC&T Procedure 0110, paragraph 8.5, requires personnel to use portal monitors.
Contrary to the above, on April 29, 1980, an individual bypassed the portal monitor at the construction exit from the restricted area.
5.
RC&T Procedure 0211, paragraph 3, requiret protective clothing to be removed in such a way as to minimize the spread of contamination.
Paragraph 8 of the same procedure requires that gloves and coveralls be removed in such a way that only the inside surfaces are toyched with the hands.
Contrary to the above, on April 27, 1980, workers'were observed touching potentially contaminated outside su'rfaces of coveralls and gloves with their hands as they undressed at the Unit 2 torus check-point.
6.
RC&T Procedure 0110, paragraph 8.3.3, requires the instrument probe to be moved slowly when performing a whole body frisk.
Contrary to the above, on April 27, 1980, at the frisker station on the 50' elevation exit from the reactor building, workers surveying themselves at this station moved the instrument probe over their I
bodies so quickly that low levels of contamination would not be
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detected.
l 7.
RC&T Procedure 0302, paragraph 2.1.1 requires the portal monitor alarm setpoint to be approximately 0.1 mR/hr.
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Appendix A -
Contrary to the aboveg/on April 26,1980, a portal monitor located atthemain'controlpointfailedtoalarmat0.7mR/hr.
8.
BSEP Vol. VIII, paragraph 6.5.4 requires protective clothing radiation levels be less than 0.5 mR/hr above background at one inch before issue to personnel for use.
Contrary to the above, on May 1, 1980, does rates of 1.0 and 2.4 mR/hr (above background) at one inch were measured on coveralls ready for issue.
Each of these 8 items constitutes a separate infraction and a civil penalty of $4,000 is proposed for each.
(Cumulative civil penalty -
$32,000)
C.
10 CFR 20.203(b) requires areas with whole body exposure rates in excess of 5.0 mR/hr to be posted as a " Radiation Area."
Contrary to the above, on April 30, 1980, the laundry shipping preparation area in which the dose rate to a worker was measured to be 25.0 mR/hr, was not posted as a " Radiation Area."
This is an infraction (Civil Penalty - $4,000.00).
D.
10 CFR 20.103(a)(3) requires that airborne radioactive material surveys be taken in restricted areas to evaluate workers' exposure to radioactive materials in air.
(1) Contrary to the above, on April 24, 1980, airborne surveys were not conducted at the cleanup area on the reactor water cleanup system building roof (a restricted area) when work was underway whiqh could cause high levels of airborne contamination.
(2) Contrary to the above, on April 30, 1980, airborne surveys were not conducted in the Health Physics Systems I.aundry trai'ler facility (a restricted area) when the potential for high levels of airborne contamination existed due to the work in progress.
Each of these 2 items constitutes a separate infraction and a civil penalty of
- $4,000'is proposed for each.
(Cumulative civil penalty - $8,000)
Although the total civil penalties amount to $108,000, pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (42 USC 2282), the total civil penalties for any thirty-day period cannot exceed $25,000.
Consequently, civil penalties in the amount of $89,000 are proposed for the above.
This Notice of Violation is sent to Carolina Power and Light Company pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
You are hereby required to submit to
,this office, within twenty-five days of the date of this letter, a written
g Appendix A -
statementorexplanationinrepipi..inc.l.uding.foreachitemofnoncompliance:
(1) admission or denial of the alleged item of noncompliance; (2) the reasons for the iten of noncompliance, if' admitted; (3) the corrective steps which have been taken by you'and the results achieved; (4) the corrective fteps which will be taken to avoid further noncompliance; and (5) the date when compliance sill be achieved.
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