ML20039A433
| ML20039A433 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/01/1981 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20039A434 | List: |
| References | |
| EA-82-007, EA-82-7, NUDOCS 8112170588 | |
| Download: ML20039A433 (3) | |
Text
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, P.O4 DEC 0 1 1981 po,e int 2C
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Docket No. 50-261
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F-b Carolina Power and Light Company
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ATTN:
Mr. J. A. Jones, Senior Executive
- 2 Vice President and Chief i;$
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9
- Jf Operating Officer S
N 411 Fayetteville Street
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Raleigh, NC 27602 V.%T%)\\
Gentlemen:
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A special inspection conducted by the NRC Region II office on August 25-26, 1981, of activities at the H. B. Robinson facility Unit 2 indicated that programmatic inadequacies in external radiation exposure control, which resulted in a civil penalty (EA 81-46) in May 1981, have not been fully ccrrected.
The circumstances and immediate cause of the violation described in the Appendix to this letter, regarding the exposure during August 1981, of an individual in excess of NRC regulatory limits, were similar to an incident which occurred on May 30, 1981.
(Since the latter incident occurred before you had responded to EA 81-46, your response also covered the May 30, 1981 incident.) In both instances the exposure of workers marking steam gener-ator tubes was controlled by use of chest-worn, self-reading pocket dosimeters, despite the fact that evaluation of working conditions had revealed that the head would receive a higher exposure than the chest.
The failure to follow those plant procedures, that had been modified following the May 1981 civil penalty, appears to be a principal cause of this occurrence.
Additionally, the use of a radiation control technician who did not meet the minimum experi-ence level required by the technical specifications, appears to be among the causes of the exposure in excess of NRC limits.
The radiation control tech-nician only had eleven months experience consisting primarily of observing other workers surveying themselves with " friskers." That experience is at a level far below that required for performing survey work during steam generator maintenance.
While the magnitude of the radiation dose received by the employee only slightly exceeded the regulatory limit in this instance, we are concerned that, notwith-standing the previous civil penalty for a similar problem, you did not adequately evaluate radiological conditions, establish effective protective measures, and implement applicable plant procedures.
These concerns were expressed in an enforcement conference held on September 16, 1981, at our Region'II (Atlanta) office.
One of the issues discussed was the requirement for continuous health physics coverage of steam generator maintenance work.
During the enforcement conference, the Manager, Environmental and Radiation Control, denied the allega-tion of failure to provide continuous health physics CERTIFIED MAIL RETURN RECEIPT REQUESTED Q2ggfcUob k
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Carolina Power and Light -
Company-coverage of the steam generator tube marking operation.
We acknowledge the presence of a health physics technician. However, more than mere presence is required..It is evident that the technician present did not give continuous attention to this high exposure' task.
Had he been more vigilant and experienced, he most likely would have been aware of and controlled four entries into the steam generator made by the overexposed worker.
The NRC proposes to impose civil penalties-in the cumulative amount of Eifty Thousand Dollars for the three items in the Notice of Violation.
These items have been categorized at the Severity Levels described in accordance with the Interim Enforcement Policy published in the Federal Register,.45_FR 66754 (October 7, 1980).
Because you could have reasonably been expected _to have taken effective preventive measures as a result of the enforcement actions and inspection reports associated with the previous event, the base penalty of Forty Thousand Dollars is increased by twenty-five percent as provided in the policy.
You are required to respond to the Appendix, and in preparing your response you should follow the instructions specified in the Appendix.
In addition to your response to the specific violations, please inform us of the underlying causes of the failure of your radiation control program to prevent this type of occurrence and how you plan to correct this failure.
Your reply to this letter and Appendix will be the basis for determining whether additional enforcement actions are warranted.
In accordance with 10 CFR 2.790 of the NRC's " Rules o' Practice", Part 2, Title 10, Code of Federal Ragulations, a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
' Original Signed By R. C. DcYcung",
Richard C. DeYoung, Director' Office of Inspection and Enforcement
Enclosure:
Appendix - Notice of Violation and Proposed Imposition of Civil Penalties cc w/ encl:
H. B. Starkey, Jr., Plant Manager EI:v EI:IEbg *h D:EI:IE p
i ELD D:I WPU:JD 11/20/81 JMet er RWessman JMurray 9 Thompson RCDeon) 5520 11/g/81 11/9/81 11/[$ /81 11/
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LCarolina Power and Ligh't
.3-Company-Distribution l'
PDR-
-CP Book.
Utilities Commission
,LPDR APuglise, CON _L-316 ATTN:
Mr. Robert Koger.
L NSIC EI Reading File
_ Chairman TIC EDO Reading File Dobbs Building-ACRS-(3)
JHannon, NRR 430 N. Salisbury-St.
SEC_Y
-S. Weise,-Res Inspector, Raleigh, NC 27611
- VStello, IE Route 5 P.O. Box 266-1A DEDROG-R Hartsville, S.C. 129550 RDeYoung,.. IE-t NMoseley, IE Division of. Facility Services JSniezek, IE ATTN:
Dayne-H. Brown,-Chief HThornburg,=IE Radiation Protection Service RWessman, IE P.O. Box 12200 CA Raleigh, NC 17605 L
FIngram, PA~
JMurray,-ELD Office of_the Attorney General JLieberman, ELO (3)
ATTN:
Hon. Rufus L. Edmisten
-JCrooks, AEOD Attorney General' JCummings,_OIA.
Justice Building Enforcement Coordinators P.O. Box 629 i
RI, RII, RIII, RIV, RV-Raleigh, NC-27602 TBrockett,'IE
IE Files.
Central Files
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