ML20148F420
| ML20148F420 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/10/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Mcdonald R ALABAMA POWER CO. |
| Shared Package | |
| ML20148F425 | List: |
| References | |
| EA-88-033, EA-88-33, NUDOCS 8803280159 | |
| Download: ML20148F420 (4) | |
See also: IR 05000348/1988002
Text
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MAR 101988
Docket Nos.
50-348 and 50-364
EA 88-33
Alabama Power Company
LAftN: Mr. R. P. Mcdonald
Senior Vice President
Post Office Box 2641
Birmingham, Alabama 35291-0400
Gentlemen:
SUBJECT:
(NRC INSPECTION REPORT NOS. 50-348/88-02 AND 50-364/88-02)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by
T. R. Collins at the Farley Nuclear Plant on January 4-6, 1988.
The inspection
included a review of the circumstances surrounding the unauthorized entry into
a radiation exclusion area which was identified by your staff and reported to
the NRC on January 30, 1987.
The report documenting this inspection was sent
to you by letter dated February 8, 1988. As a result of this inspection,
significant failures to comply with.NRC regulatory requirements were identi-
fied, and accordingly, NRC concerns relative to the inspection findings were
discussed in an Enforcement Conference held on February 17, 1988. The letter
summarizing this Conference was sent to you on March 2, 1988.
The violations described in the enclosed Notice of Violation involved failures
to adequately control access to a high radiation area, failures to comply with
prc:edures for access control to radiation areas including a radiation work
permit system, and failure to adequately instruct individuals on the limita-
tions and precautions for working in or frequenting a restricted area. The
events that resulted in these violations included a contractor providing
decontamination support on December 28, 1987, following the fifth refueling
outage. One of the rooms requiring decontamination was Room 450 which was
located in the Unit 1 Auxiliary Building.
This room contained high radiation
areas and provided the only access to Room 449, where the spent fuel pool
demineralizer was located.
The "boundary" between these two rooms was neither
obvious nor clearly established. Room 449 and a portion of Room 450 were
considered to be an exclusion area, defined as an area having radiation fields
greater than 1 rem per hour.
The entrance to the exclusion area was not locked,
although it was barricaded by three yellow and magenta ropes and high radiation
area / exclusion area warning signs.
A flashing red light was also located at the
exclusion area boundary.
Radiation fields in the exclusion area ranged from
5 to 240 rem per hour at contact with the spent fuel pool demineralizer and
approximately 150 rem per hour at 18 inches from the surface of the tank.
Moments after a contract decontamination foreman unlocked the door to Room 450,
a health physics technician entered the room.
Subsequently, as a result of
miscommunications, two contract decontamination workers entered the room to
perform decontamination activities.
One worker crossed the exclusion area
boundary and worked in an area approximately five feet from the spent fuel
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AAAR 101988
Alabama Power Company
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pool demineralizer. After approximately five minutes, this worker. observed
that his low range dosimeter was offscale and immediately exited the room and
reported to a health physics technician.
Tnis event resulted in an unplanned exposure that violated Farley's administra-
tive dose control of 375 millirem per week. Although the exposure to the
worker during the incident was assessed at 455 millirem to the whole body,
which is less than the NRC limits, the NRC is concerned that these violations
created a significant potential for personnel exposures in excess of NRC limits.
The serious nature of this event indicates the need for improvements in the
administration and control of your Radiation Safety Program, in maintaining
adequate communications, and of your training program to ensure the safe
performance of licensed activities and adherence to NRC requirements.
During the Enforcement Conference, you indicated that the use of the rope
barrier, high radiation area warning signs, and a flashing light as a warning
device were adequate to control access to the areas of Room 450/449 that were
in excess of 1,000 millirem per hour and that these controls were permitted by
your Technical Specifications.
Technical Specification 6.12.2 does permit
access to individual areas with dose rates in excess of 1,000 millirem per hour
which are located within larger areas, such as PWR containments, to be con-
trolled by roping off this area, conspicuously posting this area, and activating
a flashing light as a warning device only if no enclosure exists for purposes
of locking and no enclosure can be reasonably constructed around the individual
area.
It is our position that a lockable barrier could have been constructed
at the access to the exclusion area.
Therefore, the use of the rope barrier
and the flashing light were inappropriate to control access to the exclusion
area in Room 450/449.
In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," 10 CFR Part 2, Appendix C (1987) (Enforcement Policy),
the violations described in the enclosed Notice have been categorized as
a Severity Level III problem. Normally, a civil penalty is proposed for a
Severity Level III violation or problem.
However, after consultation with the
Director, Office of Enforcement, and the Deputy Executive Director for Regional
Operations, I have decided that a civil penalty will not be proposed in this
case because of your prior good performance in the area of concern.
You
received a rating of category 1 for the past five Systematic Assessment of
Licensee Performance periods, and no escalated enforcement actions were taken
for problems in this area during these periods.
In addition, during the past
two years, only one Severity Level IV violation has been cited involving
failure to wear the protective clothing required by the radiation work permit.
You are required to respond to this letter and the enclosed Notice and should
follow the instructions specified therein when preparing your response.
In
your response, you should document the specific actions taken and any addi-
tional 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 Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
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Alabama Power Company
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h4AR 10 %)88
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The responses directed by this letter and its enclosure 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,
DRIG@lAL SENED BYi
), NEdON GRACE
J. Nelson Grace
Regional Administrator
Enclosure:
cc w/ encl:
O#f 0. Whitt, Executive Vice President
(Jf'O. Woodard, General Manager -
Nuclear Plant
yd-G.Hairston,III,VicePresident-
, Nuclear Support
ch W. McGowan, Manager-Safety Audit
p d Engineering Review
W. Fulmer, Supervisor-Safety
Audit and Engineering Review
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MAR 101988
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