ML20002C777
| ML20002C777 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/08/1980 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hancock J FLORIDA POWER CORP. |
| Shared Package | |
| ML20002C772 | List: |
| References | |
| NUDOCS 8101100846 | |
| Download: ML20002C777 (4) | |
See also: IR 05000302/1980025
Text
go ut
+
'o
UNITED STATES
8
1,
NUCLEAR REGULATORY COMMISSION
,
3
,E
REGION 11
&[
o
101 MARIETTA sT,. N.W.. SUITE 3100
ATLANTA, GEORGIA 3o3o3
In Reply Refer To:
S 1930
RII:RWZ
50-302/80-25
Florida Power Corporation
ATTN:
J. A. Hancock, Director
Nuclear Operations
P. O. Box 14042, Mail Stop C-4
St. Petersburg, FL 33733
Gentlemen:
Subject: Health Physics Appraisal
During the period of June 16-27, 1980, the NRC conducted a special appraisal of
the health physics program at the Crystal River Unit 3 Nuclear Power Station.
This appraisal was performed in lieu of certain routine inspections normally
conducted in the area of health physics. Areas examined during this appraisal
are described in the enclosed report (50-302/80-25). Within these areas, the
appraisal team reviewed selected procedures and representative records, observed
work practices and interviewed personnel. It is recommended that you carefully
review the findings of this report for consideration in improving your health
,
physics program.
The appraisal conducted at the Crystal River facility was part of the NRC's
general program to strengthen the health physics programs at nuclear power
plants. As a first step in this effort, the Office of Inspection and Enforcement
is conducting these special appraisals of the health physics programs at all
operating power reactor sites. (These appraisals were previously identified to
you in a letter dated January 22, 1980, from Mr. V. Stello, Jr., Director, NRC
Office of Inspection and Enforcement.)
One of the objectives of the health
!
physics appraisals is to evaluate the overall adequacy and effectiveness of the
total health physics program at each site and to identify areas of weakness that
need to be strengthened. We also intend to use the findings from these appraisals
as a basis for improvements in NRC requirements and guidance. Consequently, our
i
appraisals encompass certain areas which may not be explicitly addressed by
current NRC requirements. The next step that is planned in this overall effort
j
will be the imposition of a requirement by the Office of Nuclear Reactor Regula-
I
tion (NRR) that all licensees develop, submit to the NRC for approval, and
implement a Radiation Protection Plan. Each licensee will be expected to include
in the Radiation Protection Plan sufficient measures to provide lasting corrective
action for any significant weaknesses identified during the special appraisals
of the current health physics program.
Guidance for the development of this
plan will incorporate pertinent findings f rom the special appraisals and will be
l
!
issued by NRR in the fall of this year.
l
The findings of this appraisal at the Crystal River facility indicate that,
i
although your overall health physics program is adequate for present operations,
l
several significant weaknesses exist. These include the following:
a.
an adequate respiratory protection program, from training to use, did not
exist;
E10s
0 GMA
i
8 980
1
Florida Power Corporation
-2-
b.
an adequate training / retraining program which would maintain the proficiency
of the health physics technicians had not b*en developed nor implemented;
c.
an adequate records management system for health physics records did not
exist;
d.
an adequate health physics surveillance system to preclude many of the
problems discussed in this report was not being implemented.
These weaknesses were identified to your plant management at the exit interview
held on June 27, 1980, and also identified to you in a letter from James P.
O'Reilly, Director, NRC, Office of Inspection and Enforcement, Region II, dated
J ne 30,1980.
These findings are discussed in more detail in Appendix A, " Notice of Significant
Appraisal Findings". We recognize that regulatory requirements pertaining to
the significant weaknesses identified in Ar pendix A may not currently exist.
However, to assist us in determining whether adequate protection will be provided
for the health and safety of workers and the public, you are requested to submit
a written statement within twenty (20) days of your receipt of this letter
describing your corrective action for the significant weaknesses identified in
Appendix A, including: (1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of action. This request is made pursuant
to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
Your
response to the findings listed in Appendix A, should not repeat the commitments
made in your July 9, 1980 letter to James P. O'Reilly, Director, NRC, Office of
Inspection and Enforcement, Region II, but should update those commitments with
any additional findings you have obtained since that time.
The findings of this appraisal also indicate certain activities which apparently
were not conducted in full compliance with NRC requirements as set forth in the
Notice of Violation enclosed herewith as Appendix B.
The items of noncompliance
in Appendix B have been categorized into the levels of severity as described in
our Criteria for Enforcement Action dated December 1, 1974. Section 2.201 of
Part 2, Title 10, Code of Federal Regulations, requires you to submit to this
office, within twenty (20) days of your receipt of this notice, a written state-
ment or explanation in reply including:
(1) corrective steps which have been
taken by you and the results achieved; (2) corrective steps which will be taken
to avoid further items of noncompliance; and, (3) the date when full compliance
will be achieved.
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 the enclosures will
be placed in the NRC's Public Document Room.
If this material contains any
information that you believe to be proprietary, it is necessary that you make a
written application within 20 days to this office to withhold such information
from public disclosure. Any such application must be accompanied by an affidavit
executed by the owner of the information, which identifies the document or part
sought to be withheld, and which contains a statement of reasons which addresses
with specificity the items which will be considered by the Commission as listed
_
a 1980
Florida Power Corporation
-3-
i
in Subparagraph (b)(4) of Section 2.790. The information sought to be withheld
i
shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified period, this
,
letter and the enclosures will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to
discuss them with you.
Sincerely,
% L.
O
'
mes P. O'Reilly
D rector
1
Enclosures:
1.
Appendix A, Notice of Si
"fican
Appraisal Findings
2.
Appendix B, Notice of Violation
3.
Office of Inspection and Enforcement
Inspection Report No. 50-302/80-25
cc w/ encl:
D. C. Poole, Nuclear Plant Manager
1
, , , - , + - ,
- , - .
- - - - - - < , . ,
.-
g
,-,
---
, , , ~
81990
1
I
APPENDIX A
NOTICE OF SIGNIFICANT APPRAISAL FINDINGS
Florida Power Corporation
License No. DPR-72
Crystal River
Based on the Health Physics Appraisal conducted June 16-27, 1980, the following
items appear to require corrective actions (Section references are to the Details
portion of the enclosed Inspection Report.)
A.
An adequate respiratory protection program, from training to use, did not
l
exist. The importance of this significant appraisal finding is underscored
by the number of noncompliance items listed in Appendix B (Items A, B, and
,
F) which relate to the respiratory protection program (Sections 7 and 9).
B.
An adequate training / retraining program which would maintain the proficiency
of the health physics technicians had not been developed nor implemented.
This lack of training / retraining contributed to several of the noncompliance
items identified in Appendix B (Section 5).
C.
Management of health physics records was inadequate. The appraisal found:
(1) NRC Form-4's incomplete; (2) dosimeter /TLD investigations not documented;
(3) dosimeter calibration records incomplete; (4) respirator issuance
records incomplete; (5) exposure records changed without a documented
basis; and, (6) survey records not readily retrievable.
In addition,
records were not stored in fireproof containers (Section 8).
D.
An adequate health physics surveillance program to preclude many of the
problems discussed in this report was not being implemented.
Numerous
examples of inadequate surveillance are detailed in the details of the
report (Section 9),
i