ML20039A438
| ML20039A438 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/01/1981 |
| From: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20039A434 | List: |
| References | |
| EA-82-007, EA-82-7, NUDOCS 8112170595 | |
| Download: ML20039A438 (4) | |
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APPENDIX NOTICE OF VIOLATION AND PROPOSED IMPOSITIOFDF CIVIL PENALTIES Carolina Power and Light Company Docket No. 50-261 H. B. Robinson, Unit 2 License No. DPR-23 EA 82-07 A special NRC inspection was conducted on August 25-26, 1981, to ascertain the circumstances
.arounding a radiation dose at the licensee's H. B. Robinson Unit 2 facility to a worker while the worker was marking steam generator tubes, an operation described by the licensee as a high exposure task.
Survey data prior to the task indicated, and exposure records of persons performing similar work confirmed, that the head would receive a higher dose than the chest.
Despite this knowledge and a procedure requiring placement of the self-reading pocket dosimeters in a position on the' body at or near the field of highest exposure rate, the licensee specified chest-worn pocket dosimeters to control exposures.
Utilizing the chest dosimeters resulted in exceeding the exposure limits for the head.
This event was similar to an overexposure which occurred at the Robinson facility on May 30, 1981 and to overexposures in 1980 for which the NRC levied civil penalties.
In order to emphasize the need for the licensee's management to implement its health physics program, including adequate evaluations and control of poten-tially hazardous operations to avoid unnecessary exposures, and because of the licensee's failure to assure that procedures adopted in response to the previous civil penalty L followed, the Nuclear Regulatory Commission proposes to impose civil penalties in the cumulative amount of Fifty Thousand Dollars for this matter.
In accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), and pursuant to section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violations and their associated penalties are set forth below:
A.
Technical Specification 6.8.1 states, in part, that written procedures shall be established, implemented and maintained that meet or exceed the requirements and recommendations of Appendix A of U.S. NRC Regulatory Guide 1.33 dated November 3, 1972.
Section G and I of Appendix A to Regulatory Guide 1.33 list procedures for repair of PWR steam generator tubes and for special radiation work permits.
Contrary to the above, on August 15, 1981, between 3:00 a.m. and 6:35 a.m.,
the licensee failed in conjunction with marking steam generator tubes to comply with required plant procedures for steam generator repairs and radiation permits.
The failure, which resulted in an overexposure (item B below) is exemplified by the four departures from the procedures described below, any or all of which constitute a violation of TS 6.8.1.:
8112170595 811201' PDR ADOCK 05000261 G
Appendix (Continued),
1.
Section 3.5.2 of HP-12, Revision 8, requires that the health physics technician ensure that high and low range dosimeters are worn by persons engaged in primary side steam generator work.
The dosimeters shall be worn on the body at or near the field of the highest dose rates.
Section 3.5.2 indicates that the highest dose rates occur in the region of the head, and self-reading dosimeters may be worn on the shoulders.
However, the health physics technician on duty specified that high and low range self reading dosimeters be worn on the chest and not on the shoulders or head of the person engaged in primary side steam generator work.
2.
Special Plant Procedure SP-319 incorporates Westinghouse procedure No. MRS 2.2.2 GEN-12 which in Section 7.2 requires that a minimum of two health physics technicians provide continuous health physics coverage.
However, during the time referenced above, only one health physics technician at a time provided coverage.
3.
Special Radiation Work Permit SRWP 815-6 and Section 7.2 of MRS 2.2.2 Gen-12 require continuous health physics coverage of steam ger.erator marking operations.
Section 5.0 of MRS 2.2.2 states that steam generator wbe marking is a "high exposure task and requires vigilance on the part of the health physics technicians to carefully monitor the marking team and to ke y track of the exposure dose rate and total dose." However, the tube marking operation was neither continuously nor vigilantly monitored by the assigr.ed health physics technician since he did not maintain continuous visual contact with workers performing tube marking 4
operations.
Additionally, he did not control and record entries into the steam generator.
4.
Section 3.2 of plant Procedures HP-12, Revision 8, requires the
" Steam Generator Entry Log" to be filled in and completed whenever a steam generator entry is performed.
However, the health physics 4
technician on duty did not record the four entries into the steam generator made by one worker.
This is a Severity III Violation (Supplement IV).
(Civil Penalty - $25,000).
B.
10 CFR 20.201(b) requires licensees to make or cause to be made such surveys as may be necessary to comply with the regulations in 10 CFR 20.
A survey as defined in 20.201(a) is an evaluation of the radiation hazards under a specific set of conditions.
10 CER 20.101(a) requires licensees to restrict the total occupational dose to the head of each individual in a restricted area to 1.25 rems during any calendar quarter except as pro-vided in paragraph (b) of 10 CFR 20.101.
t Contrary to the above, between August 11 and 16, 1981, surveys of the i
radiation hazards associated with marking steam generator tubes were not conducted adequately to assure compliance with the head dose limit specified in 10 CFR 20.101(a) in that radiation exposure to individuals
Appendix (Continued) marking steam generator tubes was controlled based on readings from self reading pocket dosimeters worn on the chest instead of the head where the exposure to radiation levels was higher.
One individual received a radiation dose to the head of 1.3 rems during the third calendar quarter of 1981, specifically, en August 15, 1981, which was in excess of the applicable limit.
This is a Severity Level III Violation (Supplement IV).
(Civil Penalty - $15,000).
C.
Technical Specification 6.3.1 requires that each member of the facility staff shall meet or exceed ANSI N18.1-1971 with regard to the minimum qualifications for comparable positions.
Paragraph 4.5.2 of ANSI N18.1-1971 states, in part, that technicians in responsible positions shall have a minimum of two years working experience in their specialty.
Contrary to the above, between approximately 4:30 a.m. and 6:35 a.m. on August 15, 1981, a radiation control technician was serving in a respon-sible position who had approximately 11 months experience, most of which consisted of observing personnel monitoring themselves for contamination as they left the controlled area.
This technician was solely responsible for monitoring and controlling doses to four individuals on the "B" steam generator platform.
Two of these individuals were marking steam generator tubes, a task that was identified by the licensee as a high exposure task requiring vigilance on the part of the health physics technician to care-fully monitor and control radiation dose rates and total worker doses.
This is a Severity Level IV Violation (Supplement IV).
(Civil Penalty - $10,000).
Pursuant to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, Carolina Power and Light Company may pay the civil penalties in the cumulative amount of Fifty Thousand Dollars or may protest impasition of the l
civil penalties in whole or in part by a written answer.
Should Carolina Power end Light Company fail to answer within the time specified, this office will issue an order imposing the civil penalties in the amount proposed above.
Should Carolina Power and Light Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in this Notice in whole or in part; (2) demonstrate
, 4 Appendix (Continued) extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
Any written answer in accordance with 10 CFR. 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Carolina Power and Light Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalties due, which have been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.
FOR THE NUCLEAR REGULATORY COMMISSION
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Richard C.,p o D ector Office of Inspection and Enforcement Dated at Bethesda, Maryland this 1 day of December 1981 l
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