ML20211M332

Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $50,000.Violations Noted:Individual Working in Restricted Area Received Total Occupational Whole Body Radiation Exposure of 3.29 Rems for Third Quarter 1986

ML20211M332
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/10/1986
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211M319	List: IR 05000213/1986017 ML20211M332
References
EA-86-167, NUDOCS 8612170127
Download: ML20211M332 (5)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIEC Connecticut Yankee Atomic Power Company Docket No. 50-213 Haddam Neck Nuclear Power Plant License No. DPR-61 EA 86-167 During an inspection. conducted on July 22-25, 1986, NRC inspectors reviewed the circumstances associated with a violation of NRC requirements identified by the licensee and reported to the NRC. The violation involved a whole body radia-tion exposure in excess of the regulatory limit received by an individual performing maintenance activities on a steam generator. During the inspection, additional violations of NRC requirements were identified. Further, during an NRC inspection conducted on June 16-20, 1986, violation.s cf NRC fire protection requirements were ider ;ified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to section 234 of the Atomic Energy Act of 1954, as amended, ("Act"),

42 U.S.C. 2282~, PL 96-295, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:

I. Violations Assessed Civil Penalties A. 10 CFR 20.101(b) limits the total occupational radiation exposure to the whole body of any individual in a restricted area to three rems per calendar quarter.

Contrary to the above, as of July 23, 1986, an individual conducting maintenance activities on steam generators in a restricted area, received a total occupational whole body radiation exposure of 3.29 rems for the third calendar quarter of 1986.

B. 10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the regulations of Part 20. As defined in 10 CFR 20.201(a), a " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.

Contrary to the c.bove, on July 23, 1986, a survey (evaluation) performed for work conducted by an individual on steam generator No.

4 between 3:15 a.m. and 5:30 a.m. was inadequate to assure compliance with 10 CFR 20.101(b), which limits the occupational whole body exposure during any calendar quarter to 3 rems. Specifically, the survey was inadequate in that Senior HP technicians calculated the allowable stay-time for a worker, who made four half-body entries into the steam generator channel head where radiation levels were between 20 to 30 R/hr, based on the exposure time of another worker 8612170127 861210 3 DR ADOCK 05000 0FFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0006.0.0 12/05/86

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Notice of Violation without verifying that each worker performed work under the same set of conditions. Although the second individual worked on the same steam generator, he had not made any entries into the channel head, but had been located either on the steam generator platform, or below it, where radiation levels were at most 1000 mR/hr.

C. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

1. Administrative Control Procedure (ACP) 1.0-4, " Radiation Work Permit Completion and Flow Control," established to satisfy the requirements of Technical Specification 6.11, step 5.6.1.6, requires, in part, that direct surveillance of workers by a Health Physics technician will be required in those instances where high dose rates, extreme changes in radiation levels, or other radiological hazards preclude workers from independently monitoring and minimizing their exposure.

Contrary to the above, on July 23, 1986, between 3:00 a.m. and 5:30 a.m., direct surveillance by Health Physics (HP) techni-cians of a worker performing maintenance activities on Steam Generator No. 4, a high dose rate area, was inadequate in that the HP technicians did not periodically read the worker's pocket i

ion chamber (PIC), to monitor his exposure and assure that regulatory limits would not be exceeded.

2. ACP 1.0-4, " Radiation Work Permit (RWP) Completion and Flow Control," established to satisfy the requirements of Technical Specification 6.11, step 5.5.2, requires, in part, that workers are responsible for initialling the RWP, acknowledging that they have read and understand the RWP.

Contrary to the above, on July 23, 1986, a worker performed work on Steam Generator No. 4. which was covered by RWP No. 864040, without the worker having initialled the RWP to indicate that he read and understood the RWP.

These violations have been categorized in the aggregate as a Severity Level III problem (Supplement IV).

Cumulative Civil Penalty - $50,000 - assessed equally among the violations.

II. Violations Not Assessed Civil Penalties A. 10 CFR Part 50, Appendix R, Section III.G.3.a, requires that alternative shutdown capability shall be provided where the protection of systems whose function is required for hot shutdown does not satisfy the separation and protection features set forth in Section III.G.2.

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i Notice of Violation -

F Section III.L.1(c)-(e), Alternative and Dedicated Shutdown Capability, requires that alternative or dedicated shutdown capability provided F for a specific fire area shall be able to achieve and maintain hot f standby conditions, achieve cold shutdown conditions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, I and maintain cold shutdown conditions thereafter.

I Contrary to the above, during June 1986, the alternative shutdown capability, provided for a fire that could result in the loss of the Atmospheric Dump Valves or other steam relief paths, did not assure L that the plant would be able to achieve and maintain hot standby

( conditions. The alternative shutdown capabiiity, provided through p four steam vent lines, was not assured because, in order to achieve r and maintain hot standby conditions, 180,000 gallons of water is F

necessary, whereas the demineralized water storage tank and primary h water storage tank, the sources of water specified in the licensee's

[ fire protection analysis, only contained on the average 172,000 gallons c of water in June 1986.

s j This is a Severity Level IV violation (Supplement I).

[ B. 10 CFR Part 50, Appendix R, Section III.G.I.a, requires fire protection

[ features to be provided for systems and components important to safe l- shutdown and that these features shall be capable of limiting fire

[ damage so that one train of systems necessary to achieve and maintain i hot shutdown is free of fire damage. Acceptable fire protection L features are specified in Section III.G.2 and III.G.3. By a letter dated November 14, 1984, in accordance with 10 CFR 50.48, the NRC

( Office of Nuclear Reactor Regulation approved a licensee's exemption i request which allowed the installation of a Halon System in the control room as a suitable fire protection feature.

Contrary to the above, as of June 17, 1986, the Halon System installed in the control room to provide fire protection was inadequate in that, under conditions of the control room ventilation system operating in the recirculation mode, it did not provide a 7 percent concentration

[" in the entire control room for ten minutes as specified in a letter to the NRC dated August 16, 1985, which modified a previously approved exemption request. A Halon discharge test performed on April 7, 1986 demonstrated that the Halon concentration would be approximately 4.8

. percent when the control room ventilation system was operating in 4 the recirculation mode.

f f; This is a Severity Level IV violation (Supplement I).

C. Technical Specification 6.8.1 requires that procedures be established L and implemented which comply with the requirements of ANSI 18.7-1976, Section 5.3. ANSI 18.7-1976, Section 5.3.7, requires that calibra-tion procedures be provided for assuring measurement accuracy adequate to keep safety related parameters within operational and safety limits.

L Breaker test procedure, PMP 9.5-1, Rev. 10, implements this re ;irement.

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Notice of Violation Contrary to the above, as of June 16, 1986, the breaker test proce-dure, PMP 9.5-1, Rev. 10, was inadequate to keep safety related parameters within operational and safety limits in that the procedure allowed circuit breakers to be tested and accepted without meeting specific trip settings established by design. Test acceptance was based on the capability to trip without regard to the trip setting.

This is a Severity Level V violation (Supplement I).

D. 10 CFR Part 50, Appendix R, Secticn III.J, requires that emergency lighting units with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.

Contrary to the above, as of June 19, 1986, emergency lights were not provided in the charging pump cubicles and the cable vault room areas where operators must be dispatched as required by emergency procedures to operate safe shutdown equipment and take required readings during a

' ire emergency.

This is a Severity Level V violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Connecticut Yankee Atomic Power Company is hereby required to submit to the Director, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, within 30 days of the date of this Notice, a written statement or explan-ation, including for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the correc-tive steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue an order to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of section 182 of the Act, 42 U.S.C.

2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Connecticut Yankee Atomic Power Company may pay the civil penalties by letter addressed to the Director, Office of Inspection and Enforcement, with a check, draft, or money order payable to the Treasurer of the United States in the cumulative amount of Fifty Thousand Dollars ($50,000) or may protest imposition of the civil penalties in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should Connecticut Yankee Atomic Power Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order imposing the civil penalties in the amount proposed above. Should Connecticut Yankee OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0008.1.0 12/05/86

i Notice of Violation Atomic Power Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, such answer may: (1) deny the violations listed in Section I of this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.

In requesting mitigation of the proposed penalties, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Connecticut Yankee Atomic Power Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalties.

Upon failure to pay any civil penalties due which have been subsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY:

JAMES M. Al.l#1 Thomas E. Murley Regional Administrator DatedafKingofPrussia, Pennsylvania thisjo day of December 1986 OFFICIAL RECORD COPY CP PKG HADDAM NECK REV 4 - 0008.2.0 12/05/86

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