ML20207T646

Discusses Insp of on 861120-21 & 1216 & Forwards Notice of Violation.Severity Level III Assigned Since Dose May Be Significantly Lower than Reading Due to Limited Area of Exposure.Penalty Not Proposed Due to Prior Good Performance

ML20207T646
Person / Time
Site:	Summer
Issue date:	03/10/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Nauman D SOUTH CAROLINA ELECTRIC & GAS CO.
Shared Package
ML20207T647	List: ML20207T646 ML20207T685
References
EA-87-007, EA-87-7, NUDOCS 8703240210
Download: ML20207T646 (3)

Text

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o MAR 101987 Docket No. 50-395 License No. NPF-12 EA 87-07 South Qarolina Electric and Gas Company ATTN:/ Mr. D. A. Nauman, Vice President Nuclear Operations P. 0. Box 764 (167)

Columbia, SC 29218 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT N0. 50-395/86-22)

This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by )

T. R. Collins at the V. C. Summer facility on November 20-21, and December 16, i 1986. The inspection included a review of the circumstances surrounding the 1 identification by the licensee of an apparent exposure to the hand of a licensee employee in excess of regulatory limits. As a result of this inspection, violations of NRC regulatory requirements were identified. The NRC's concerns were discussed by M. L. Ernst, Deputy Regional Administrator, NRC, Region II, with you and your staff during an enforcement conference held on December 16, 1986.

The violations described in the enclosed Notice of Violation involved the localized contamination on the hand of a licensee employee which resulted in a calculated absorbed dose of 420 rad to a small area of the skin of the hand.

Compliance with 10 CFg Part 20 requires that skin dose be averaged over an area no larger than 1.0 cm . Further, the current regulations require that the exposure be recorded in rem and state explicitly that a dose of 1 rad of x-ray, gamma or beta radiation is equal to 1 rem for purposes of the regulations.

Therefore, the magnitude of the exposure must be recorded as 420 rem. This value exceeded the allowable limit of 18.75 rem per quarter to the hands and could be censidered a Severity Level I violation (personnel exposures to the hands greater than 375 rem). However, because the calculated dose is the most conservative value that could be assigned to the exposure and the safety implications of the dose may be significantly reduced because of the extremely limited area of exposure, the violation is more appropriately categorized at a Severity Level III.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations described in the enclosed Notice have been classified as a Severity Level III problem.

Normally, a civil penalty is considered for a Severity Level III violation or problem. However, after consultation with the Director, Office of Inspection and Enforcement, I have decided that a civil penalty will not be proposed in

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South Carolina Electric and Gas Company this case because of your prior good performance in the area of radiological protection, including a well managed and otherwise effective contamination control program and your unusually prompt and extensive corrective actions taken relative to the apparent overexposure to preclude any future event.

You are required to respond to this letter and should 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, 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 enclosures will be placed in the NRC Public Document Room.

The responses directed by this letter and its enclosures 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.

Should you have any questions concerning this letter, please contact us.

Sincerely, Original signed by J. Nelson Grace J. Nelson Grace Regional Administrator

Enclosures:

1. Notice of Violation

2. Inspection Report cp w/encls:

4. S. Bradham, Director, Nuclear Plant

/ Operations VJ. L. Skolds, Deputy Director Operations and Maintenance I B. Knotts, Jr.

j Debevoise and Liberman

%I. A. Williams, Jr., Special Assistant, Nuclear Operations -

, Santee Cooper tA. M. Paglia, Jr. , Manager Nuclear Licensing

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