ML20049H196
| ML20049H196 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/30/1981 |
| From: | Utley E CAROLINA POWER & LIGHT CO. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20049H201 | List: |
| References | |
| NO-81-1872, NUDOCS 8112010130 | |
| Download: ML20049H196 (7) | |
Text
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October 30, 1981 g,4 1 31WJ5 File: NC-3513(B)
Scrial Not NO-81-1782 EA-S t-T7 Mr. Victor Stallo, Jr., Director office of Inspection and Enforcement b lI[3hl United States Nuclear Regulatory Cot:::nission W[$3G,000 cd Washington, D.C.
20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT lOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE'TO NOTICE OF VIOLATION
Dear Mr. Stello:
Carolina Power & Light Company (CP&L) has received 1E Inspection Reports 50-324/81-16 and 50-325/81-16 for the Brunswick Steam Electric Plant, Unit Nos.1 and 2.
CP&L has also received your letter of October 1, 1981 transmitting a Notice of Violation and Proposed Imposition of Civil Penalties (EA 81-77).
The above-mentioned items do not contain any information of a proprietary nature.
Pursuant to 10CFR2.205, CP&L hereby encloses its check in the amount of thirty-five thousand dollars ($35,000), payable to the Treas-urer of the United States, in payment of Violations A and B; however, CP&L requests a clarification of Violation C and, therefore, is not enclosing remittance of the proposed civil pennity for this item.
As required by 10CFR2.201, CP&L's response to the Notice of Violation issued with the Proposed Imposition of Civil Penalties is enclosed. Tbc basis for our request for clarification of Violation C in also provided in our enclosed responses.
If you need any additional information, please contact ua.
Yours very truly, E. E. Uticy WRM/1r (0693)
Executive Vice President Enclosures Power Supply and Engineering & Construction ec:
Mr. R. A. Hartfield Mr. J. P. O'Reilly Sworn to and subscribed before me this 30th day of October,1981 h/N/ mag $?[ ~
Y My commission expires: October 4, 1986 Notary Public ff g
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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 IE INSPECTION REPORTS 50-324/81-16 AND 50-325/81-16 RESPONSE TO NOTICE OF _VIOLATI_0*! _
IE Inspection Reports 50-324/81-16 and 50-325/81-16 identified thren items that appear to be in noncompliance with NRC requirements.
These itnen and Carolina Power & Light Company's response to each are addressed in the following tnxt:
Violation A:
(Severity Level III) 10CTR20,201(b) requiran licensees to make or cause to be made such nurveys an may be necessary to comply with the regulations in 10CFR20.
A nuryny as defined in 20.201(a) is an evaluation of the radiation hazards incident to the use of radioactive material under a specific set of conditions.
Contrary to thu above, su rveys, including evaluations of the radiation hazards associated with the repair of a valve on July 17. 1981, were not conducted aduquately to assure comp 11anca with the whole body done limits specified in 10CFR20.101(b) in that an individual received a quarterly whole body dose in excess of 3 remn.
(Civil Penalty - $25,000)
Carolina Po_ war & Light Connany's Respon_a_e_
Carolina Power ' Light Company acknowledges that this was a violation of NRC requiruments.
The cause for this violation was failure on the part of the individuals involved (two maintenance mechanics and one assigned radiation control technician) to recognize:
1.
The potential for exceeding administratively allowable exposure limits due'to the nudden increase in general area radiation exposure rates, associated with a valve repair in the RWCU System.
2.
The necessity to communicate this change in radiation exposure rates to their foreman and to the radiation control office for reevaluation / termination of the radiation work permit under which the work was authorized (as required by the Brunswick Plant Operating Manual Volume VIII. Radiation Control and Protection).
The radiation control and test technician assigned for providing job coverage had been assigned to the RWCU Syntem repair for several days to provide radiation monitoring in areas having components with contact radiation exposure rates in the range of 20-30 R/hr.
On being told of an increase in the exposure rato from 300 mr/hr to 30 R/hr on the valve under repair, he did not recognize the significance of this change to the radiological hazards for thn work crew.
The assigned radiation control and test technician also failed to exercise his authority to stop thu work for reevaluation as per Brunswick Plant Operating Manual, Volume I, Book 2, Administrative Instruction AI-23, Responsibility and Enforcement of the BSEP Radiation Protection Program.
All three personnel involved in the incident have been counseled by their supervisors, and appropriate disciplinary action taken.
The radiation control and tvat technician was removed from field coverage until retraining was accomplished and it was determined (through cram-ination) that he was fully qualified to resume normal field dutics.
A summary of this incident and corrective actions taken was presented at the July 1981 monthly employee information meeting for plant personnel.
This evenc was reviewed in detail with all radiation control and test technicians with emphaalu placed on recognizing plant areas where rapid radiological changes are likely to occur and the need to quickly reassess the radiological protection requirements and notify radiation control supervision once theno changea do occur.
It van stressed that certain conditions may require work to be halted while the reasscasment is being conducted.
The technician'a nuthority to stop work for reevaluation was emphasized.
Full compliance on this item has been achieved.
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Violation B - (Sever (ty Level 11([
10CFR20.101(b) requires licensees to restrict the total occupational dose to the whole body of an individual in a restricted area to 3 rama during any calendar quarter.
Contrary to the above, an individual received a total occupational whole body dose of approximately 4.2 rema during the third calendar quarter of 1981.
(Civil Penalty - $10,000)
Caro _ lina Power & Limht Company's Response Carolina Power & Light Company acknowledges that this was a violation of NRC requirements.
The'cause for this violation was a sudden increase in general area radiation exposure rates without adequate assesement of the radiation hazards produced.
The individual involved was assigned to work in areas outside the radiation control areas for the remainder of 1981.
To provant this event from occurring in the future, in addition to the normal radiation measurement devices, alarming dosimeters will be employed in future maintenanco work in KWCU where the possibility exists for significant radiation expcsures and/or potentially rapid changes in arca done raten.
Engineering evaluations are being performed on the RWCU valving components and system operation in an ef fort to improve operability and mainenance frequency.
The objective is to minimize the amount of maintenance activities conducted in this type environment.
Corrective action for this item has already been completed.
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Violation C (Severity Level IV)
Technical Specification 6 3.1 requires that cach member of the facility staff shall meet or creced the minimum qualification of ANSI N18.1-1971 for comparable positions.
Paragraph 4.5.2 of ANSI N18.1-1971 states, in part, thattechniciansinrenponsiglepositionsshallhaveaminimumof two years of working experiencu in their specialty.
t Contrary to the abod i a radia, tion control technician with less than two years crperience van derving in a responsible position, in that on July 17, 1981, this individual with fourteen months experience and training, established radiation protection requirements for work con-cerning the Unit No. 2 Reactor Water Cleanup System filtur "B" resin discharge valve without prior review of the requirementn by a qualified technician or supervisor.
(Civil Penalty - $5,000)
Carolina _ Power & Light Company's Response Caro).ina Power & Light Company (CP&L) is unable to understand the allegation as capremacd in Violation C and respectfully requests the Commission to clarify the allegation.
Until CP&L has received such clarification, the Company is unable to admit or deny alleged Violation C.
In clarifying the allegation, it is important for the Commission to understand that the radiation protection requirements for work concerning the Unit No. 2 Reactor Water Clean-up System fficer 5 resin discharge valve were established by an individual whose qualifications satisfy ANSI N18.1-1971 and in accordance with Brunswick Technical Sepcifications.
These radiation protection requirements were established in a radiation work parait which was issued in accordance with Brunswick Plant Operating Manual, Voluma VIII, Radiation Control & Test Procedure, RC&T - 0230, Issue & Une of Radiation Work Permits.
The radiation control and test technician who is apparently the person referred to in Violation C was noeisting in the implementation of the radiation protection requirements on July 17, 1981.
Am CP&L has acknow-lodged in its response to Violation A, that technician failed to recognize the signifienace of changes in circumstances which, occurred on July 17, 1981 and made an error in judgment in carrying out his assigned task.
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