ML20128A807
| ML20128A807 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/21/1993 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Watson R CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20128A810 | List: |
| References | |
| EA-92-217, NUDOCS 9302020320 | |
| Download: ML20128A807 (7) | |
See also: IR 05000324/1992032
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JAtl 21 1993
Docket Nos.
50-325 and 50-324
License Nos. OPR-71 and DPR-62
EA 92-217
Carolina Power and Light Company
ATTN: Mr. R. A. Watson
1
Senior Vice President
Nuclear Generation-
Post Office Box 1551
Raleigh, North Carolina 27602
Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL
PENALTY - $50,000 (NRC INSPECTION REPORT NOS. 50-325/92-32
AND 50-324/92-32)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by
Mr. E. Testa on September 23-28, October 26-30, and November 12, 1992, at the
Brunswick Steam Electric Plant. The inspection included a review of the facts-
and circumstances related to the cutting of a startup source holder that
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contained, unknown to the personnel invclved, an americium / beryllium neutron
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source. The cutting of the source holder resulted in the inadvertent contami-
nation of the Unit 2 refueling floor on September 22, 1992.
The report docu-
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menting this inspection was sent to you by letter dated November 24, 1992.
As
a result of this inspection, potent'al violations of NRC requirements were
identified. An enforcement conference was held on December 7, 1992, in the-
NRC Region II office to discuss the potential violations, their causes, and
your corrective actions to preclude recurrence.
A summary of this enforcement
conference was sent-to you by letter dated December 11, 1992.
On September 22, 1992, with Units 1 and 2 in cold shutdown as a result of a
forced outage which began on April 21, 1992, preparations were underway for
the final stage of the cleanup of the Unit 2 Spent Fuel Pool (SfP).
Several
days earlier, while sorting the remaining miscellaneous non-irradiated
components in the SFP for disposal, contract workers, who were conducting the
cleanup, discovered a startup source holder tube on the bottom of the SFP
under a support beam.
They raised the tube from the floor and placed it on an
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underwater table where a . visual examination revealed what appeared to be an
unused source holder.
Subsequently, the source holder was lifted from the
table by the bottom end and shaken in order to determine if there was a source -
in the holder.
Underwater gamma dose measurements were taken.
As a result of
the measured dose rates, the unused appearance of the source tube, and-the
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fact that a source did not fall out of the source holder when it was shaken,
the decision was made to remove the source holder from the SFP.
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Once it was out of the SFP, additional surveys were performed and a hot spot
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was found in the approximate center of the source holder.
The decision was
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then made to cut one foot on_each side of the hot spot so that the two foot
section with the hot spot could be disposed of with high dose rate waste
material and the remaining sections, with low dose rate waste.
Following
preparation of the immediate work area the cuts were made and technicians
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began a survey of the work area.
The surveys indicated unusually high
contamination levels in the work area and decontamination efforts were
initiated. These efforts continued until early evening and following general
decontamination and cleanup, licensee personnel frisked themselves with an
RM-14/HP-210 survey instrument and found no contamination.
The following day, September 23, 1992, Health Physics personnel were
discussing the previous day's events, specifically the unexpectedly high
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contamination levels. One Health Physics technician recalled that some
startup sources contained americium-241 whereupon it was decided to re-survey
the area and have the smear; counted for alpha contamination.
That survey
resulted in the discovery of high alpha contamination levels, and the
subsequent discovery that one individual involved in the cutting work had
sustained potential internal contamination.
Efforts to contain and isolate
the contamination began immediately.
<
Violation A in the enclosed Notice of Violation and Proposed Imposition of
Civil Penalty (Notice) involved the failure to either label the americium-241
or provide a readily available written record identifying the americium-241
source and its storage location in the SFP. This particular source arrived at
the Brunswick facility in December 1978 and may have been used in maintaining
the Source Range Monitor minimum count rate at the beginning of Unit 2 fuel
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reloading in 1979.
The source would likely have been removed once an adequate
response on the Source Range Monitor was obtained and.would not have been used
long enough that either it or its- holder would have been significantly
irradiated by the reactor core or the holder's appearance significantly
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altered. Accountability for the source-was not maintained, and therefore, no
record was available to document its storage location for a period of
14 years.
If accountability had been maintained or if the source had
been properly labelled, this event may not have occurred.
Violation B in the enclosed Notice involves the failure to perform an adequate
survey to evaluate the extent of potential radioactive hazards that were -
present prior to the cutting of the source holder.
Specifically, the
personnel concluded that the holder had not been used by incorrectly relying
on the holder's appearance.
The holder's appearance is a poor indicator of-
whether the holder has been used in the reactor or if -the holder contains a
source.
In addition, given that the holder was bent. the fact that nothing
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came out when it was examined is an inconclusive test for the presence of a
source. Also, the individuals involved in this event should have understood
the type of source that could have been in the holder.
Knowing that,-they
should have recognized that gamma surveys, especially those conducted in the
presence of a gamma hot spot, would likely be insufficient to detect the
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presence of a neutron source that emits only a low energy gamma.
Finally, no
effort was made to determine whe:her all on-site sources were accounted for
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prior to cutting the holder. While such an ef fort would not have helped
prevent the incident that occurred, the lack of this effort is indicative of a
predisposition on the part of the involved personnel to the conclusion that
the holder was empty, rather than the conclusion that the holder contained a
source.
Plant management failed in not maintaining effective oversight of this work in
that (1) an adequate technical evaluation of the start-up source halder was
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not performed prior to r.ny cutting by the personnel involved in the SFP
cleanup, (2) adequate oversight of the contract workers who conducted the
cleanup and made many of the decisions about disposal of the source holder was
not performed, and (3) a complete source inventory was not maintained.
This
overall lack of effective management controls directly contributed to the
event.
The staff recognizes that significant improvements have been made in the area
of spent fuel pool management, including the handling and assessment of
miscellaneous material. Additionally, the staff acknowledges the long-term
corrective actions that have been undertaken to improve source inventory and
other procedures.
The two violations and the significant contributing factors have been
evaluated in the aggregate because they have the same underlying cause
(i.e., management deficiencies related to project planning and source
inventory control) and it is likely that, if proper accountability of the
source had been maintained, a more thorough evaluation of the source holder
would have been conducted prior to the cutting evolution.
These issues
represent a tignificant failure to control licensed material and provided the
potential for radiological exposures in excess of regulatory limits.
Therefore, these violations have been classified in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
(Enforcement Policy), 10 CFR Part 2, Appendix C (57 FR 5791, February 18,
1992), as a Severity Level Ill problem.
To emphasize the importance of maintaining control over radioactive material,
I have been authorized, after consultation with the Director, Office of
Enforcement, and the Deputy Executivm Director for Nuclear Reactor Regulation,
Regional Operations and Research, to issue the enclosed Notice of Violation
and Proposed Imposition of Civil Penalty (Notice) in the amount of $50,000 for
the Severity Level III problem.
The NRC staff credits the Health Physics technicians involved in this event
for their concern relative to the high levels of contamination, the initiative
shown in their evaluation of that problem, and the subsequent actions taken,
including additional surveys. Their inquisitive attitudes reduced the
potential for additional radiation exposures associated with this event.
Normally, such actions, which led to the identification of the violations,
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Carolina Power and Light
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Company
along with the corrective actions your staff took in response to the
violations, would warrant some amount of mitigation of the base civil penalty.
However, af ter considering all the circumstances in this case, mitigation of
the base civil penalty was found inappropriate.
Specifically, this event
resulted from a failure in an area fundamental to any health physics program,
the proper control of radioactive material. Additionally, the loss of control
of radioactive material in this case resulted in a significant contamination
event.
The contamination event could have been prevented if your staff had
performed an adequate evaluation of the situation, and notwithstanding the
f ailure to prevent the event, it could have been identified earlier if your
staf f had recognized either of the several resulting indicators of the
problem.
Therefore, in accordance with Section Vll.A.1 of the Enforcement
Policy, discretion is being exercised, and a civil penalty equal to the base
amount for a Severity Level 111 problem is being issued to emphasize the
concerns discussed above.
You are required to respond to this letter and thould follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence.
After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the NRC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely,
Odgir21SD*bne%e
d
Stenart D. E
i
Stewart D. Ebneter
Regional Administrator
Enclosure:
Notice of Violation and Proposed
Imposition of Civil Penalty
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cc w/ encl.
(see next page)
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Carolina Power and Light
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cc w/ encl:
Roy Anderson, Vice President
Brunswick Nuclear Project
P. O. Box 10429
Southport, NC 28461
H. Ray Starling
Vice President - Legal Department
Carolina Power and Light Co.
P. O. Box 1551
Raleigh, NC 27602
Kelly Holden
Board of Commissioners
P. O. Box 249
Bolivia, NC 28442
Chrys Baggett
State Clearinghouse
Budget and Management
116 West Jones Street
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Raleigh, NC 27603
Dayne H. Brown, Director
Division of Radiation Protection
N.- C. Department of Environment.
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Health & Natural Resources
P. O. Box 27687
Raleigh, NC 27611-7687
H. A. Cole, Spec. DA General
State of North Carolina
P. O. Box 629
Raleigh, NC 27602
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Robert P. Gruber
Executive Director
Public Staff - NCUC
P. O. Box 29520
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Raleigh, NC 27626-0520
Ms. Gayle B. Nichols
Staff Counsel
SC Public Service Commission-
P. O. Box 11649
Columbia, SC 29211
State of North Carolina
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DISTRIBUTION:
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JSniezek, DEDR
JLieberman, OE
SEbneter, Rll
JGoldberg, OGC
TMurley, NRR
JPartlow, NRR
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Enforcement Coordinators
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FIngram, GPA/PA
BHayes, 01
DWilliams, OlG
EJordan, AEOD
JLuehman, OE
Day File
EA File
Document Control Desk
H. Christensen, Ril
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NRC Resident inspector
U.S. Nuclear Regulatory Commission
Star Route 1, Bax 208
Southport, NC 28461
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FIngram, GPA/PA
BHayca, 01
DWilliaan, OIG
EJordan, AEOD
JLuehman, OE
Day File
EA File
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Document Control Desk
H. Christensen, RII
R. Lo, NRR
NRC Resident Inspector
U.S. Nuclear Regulatory commission
Star Route 1,
BOX 208-
Southport, NC
28461
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