ML20237L463

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Order Modifying License DPR-35.Licensee Shall Complete Independent Contractor Assessment of Radiological Controls Program by 841230 & Provide Region I Administrator W/ Contractor Repts by 850130
ML20237L463
Person / Time
Site: Pilgrim, 05000000
Issue date: 11/29/1984
From: Taylor J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20237L241 List:
References
FOIA-87-450 EA-84-112, NUDOCS 8708280114
Download: ML20237L463 (7)
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Docket No. 50-293 License No. DPR-35 i BOSTON EDISON COMPANY EA 84-112 l (Pilgrim Nuclear Power Station)

I ORDER MODIFYING LICENSE I

The Boston Edison Company (the licensee) is the holder of Facility Operating [

License No. OPR-35 which authorizes the operation of the Pilgrim Nuclear Power Station (the facility) at steady-state power levels not in excess of 1998 c megawatts themal. The facility is a boiling water reactor (BWR) located at the licensee's site in Plymouth County, Massachusetts.

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i In August 1984, the NRC conducted inspections to review the circumstances )

i associated with the unplanned occupational radiation exposure of 1.1 rem to the hand of a contractor employee. The results of the inspections are in

  • NRC Inspection Reports Nos. 50-293/84-25 and 50 293/84-29. The exposure, which was identified by the licensee, occurred on August 18, 1984 while the '

individual was performing work in the Control Rod Drive (CRD) Repair Room.  !

Althou9h the unplanned exposure was not in excess of regulatory limits, a substantial potential for exposure in excess of regulatory limits did exist.  !

The individual received the unplanned exposure while disassembling control rod drives in the CRD Repair Room. The exposure occurred when the individual picked up with his right hand a highly radioactive chip exhibiting radiation 8708280114 870828 q PDR hLD 50

, dose rates on contact of approximately 1100 rem / hour. Adequate radiological controls were not implemented during the performance of the work in the CR0 Repair Room. Specifically, adequate surveys of the room were not performed prior to or during work in the room, adequate instructions were not provided to the worker by the health physics technician regarding precautions to be taken to minimize exposure, and the procedures used during the CRD disassembles by contractor personnel had not been reviewed and approved by the licensee. '

Furthemore, notwithstanding the use of the unapproved procedure by contractor personnel, the procedure for CR0 disassembly, which had been reviewed and approved, i

did not include sufficient precautionary statements and radiation survey hold

( points necessary for implementation of appropriate radiological controls and timely detection of highly radioactive chips. Consequently, it is not apparent l that the use of the approved procedure would have precluded this event.

The violations of HRC requirements associated with these events are set forth in the attached Notice of Violation. These recent violations at the facility represent a continuing problem in the effective implementation of radiological controls during the performance of work in the CR0 Repair Room at the Pilgrim Station. On April 17, 1984, a Notice of Violation and Proposed Imposition of Civil Penalty (EA 84-29) was issued to the licensee in the amount of $40.000 for similar violations associated with a similar unplanned exposure which occurred in the CRD Repair Room in January 1984, involving improper handling of highly radioactive chips. The licensee paid the civil penalty on May 21, 1984.

f l l Further, similar violations were identified by the NRC in May 1984 involving failure to perfom surveys and properly instruct individuals during work per-fomed in the Residual Heat Removal (RHR) quadrant and in the drywell. See NRC Inspection Report No. 50-293/84-14 III  !

Collectively, these occurrences at the facility represent inadequate planning, supervision and control of activities involving the potential for personnel exposure to radiation in excess of regulatory limits. These occurrences are indicative of programmatic deficiencies in the radiological controls program and

( they demonstrate the need for effective corrective measures to prevent similar occurrences in the future. At a management meeting on September 5, 1984 and an enforcement conference on October 16, 1984 with NRC Region I, the licensee acknowledged the need for such corrective action and made certain commitments for improvement, including the retention of a contractor to perform a complete assessment of the Radiological Controls Progra:n. On October 26, 1984 Reoion I issued a Confirmatory Action Letter documenting these commitments. In view of the importance of establishing, maintaining, and implementing an effective Radiological Controls Program, I have detennined that the commitments documented in the Confirmatory Action Letter are required in the interest of public health

, and safety and, therefore, should be confirmed by Order.

f 4-l IV In view of the foregoing, pursuant to Sections 103,1611,161o, and 182 of the Atomic Energy Act of 1954, as amended, and the Comission's regulations in 10 CFR 2.204 and Part 50. IT IS HEREBY ORDERED THAT:

A.

By December 30, 1984, the licensee shall complete an independent contractor assessment of the radiological controls program at the Pilgrim Station.

The assessment shall include, but not be limited to, the following areas:

(1) radiological control program organization, including position k responsibilities and authorities; (2) personnel selection, qualification and training program; (3) external exposure control program; (4) internal

  • exposure control program; (5) surveillance program; (6) ALARA program; (7) corrective action system; and (B) management oversight.

B.

By January 30, 1985, the licensee shall provide to the Regional Administrator, Region I, a copy of any or all contractor reports regarding the assessment required by Section IV.A. of the Order.

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C. i By February 28, 1985, the licensee shall submit to the Regional Administrator, I Region I, for review and approval, a Radiological Improvement Plan (RIP) for upgrading the radiological controls program. Upon the Rapional Administrator's review and approval of the RIP, the RIP shall be implemented. The RIP shall l

address as a minimum the programmatic improvements necessary to correct the deficiencies identified during the assessment required by Section IV.A of the Order, and shall describe:

(1) action items to be performed; (2) the integration of these action items into existing programs as complimentary facets of the overall radiological controls program;

{ (3) the schedule for completion of the specific action items; and (4) the system for monitoring and tracking the status and completion of the action items.

All action items shall be completed by December 30, 1985, unless otherwise justified in writing to the Regional Administrator,'Ragion I, and approved by him. Until such time as all action items are completad, quarterly reports regarding the status of the RIP's improvements shall be provided to the Senior Vice President Nuclear with a copy to the Re;gional Administrator, Region I.

D.

By February 28, 1985, the licensee shall submit to the Regional Administrator, Region I, an Interim Plan (IP) for achieving adequate management oversight and maintaining sufficient radiological controls of work in progress until the action items described in the RIP are completed. At a minimum, these l

( interim actions shall include radiological audits of work in progress, transmittal of bi-weekly reports of the audits to the Senior Vice President for review, enhancement of technician training and qualifications for maintaining control of radiologically hazardous activities, and means to assure that personnel are aware of radiological incidents and corrective measures to prevent their recurrence.

E.

The Regional Administrator, Region I, may relax or terminate, in writing, any of the preceding conditions for good cause.

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The licensee or any other person whose interest is adversely affected by this Order may request a hearing on this Order.

Any request for hearing shall be submitted to the Deputy Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, within 30 days of the date of this Order. A copy of the request shall also be sent to the Executive Legal Director at t!.e same address and to the Regional Administrator, Region I, 631 Park Avenue, King of Prussia, Pennsylvania 19406.

ff a hearing is to be held concerning this Order, the Commission will issue an Order designating the time and place of hearing. If a hearing is held, the issue to be considered at such hearing shall be whether this Order shall be sustained.

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This Order shall become effective upon expiration of the time during which a hearing may be demanded or, in the event that a hearing is demanded, on the date specified in an order issued following further proceedings on this Order.

FOR THE NUCLEAR REGULATORY COMMISSION 2 l

.W &, Deputy Director ames M. Tay1 Office of Ins action and Enforcement Dated al Bethesda, Maryland, thisJfilayofNovember1984 f

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