ML20148E653
| ML20148E653 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/17/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20148E658 | List: |
| References | |
| EA-87-216, NUDOCS 8803250273 | |
| Download: ML20148E653 (4) | |
See also: IR 05000302/1987035
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MAR 171988
Docket No. 50-302
License No OPR-72
87-216
Florida Power Corporation
Mr. W. S. Wilgus
Vice President Nuclear Operations
ATTN:
Manager, Nuclear Licensing
Post Office Box 219
Crystal River, FL 32629
Gentlemen:
SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
(NRC INSPECTION REPORT NOS. 50-302/87-35 AND 50-302/88-03)
This refers to the Nuclear Regulatory Commission (NRC) inspections conducted by
Mr. R. E. tieddington at the Crystal River facility on October 14-16, 1987, and
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by Mr. F. N. Wright on January 5-7, 1988.
The inspection of October 14-16,
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1987, included a review of the circumstances surrounding a significant
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potential for overexposure of personnel in the vicinity of the reactor cavity
access which was identified by a member of your staff and was reported to the
NRC on October 9, 1987. The inspection of January 5-7, 1988, included a review
of the circumstances surrounding unauthorized entries into a high radiation
area without a radiation monitoring device and into a radiographer's controlled
area. The reports documenting these inspections were sent to you by letters
dated November 19, 1987, and February 8, 1988.
As a result of the October and January inspections, significant failures to
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comply with NRC regulatory requirements were identified.
NRC concerns relative
to the October inspection findings were discussed in an Enforcement Conference
held on December 11, 1987.
The letter summarizing this Conference was sent to
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you on December 18, 1987.
NRC concerns relative to the January inspection were
discussed at an Enforcement Conference held on March 9, 1988.
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The violations described in Section I of the enclosed Notice of Violation and
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Proposed Imposition of Civil Penalty (Notice) involved failures to lock, post,
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barricade, and issue a Radiation Work Permit to control access to a high
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radiation area; failure to provide adequate instruction and training to
employees working in the restricted area; and failure to establish adequate
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procedures for radiation protection and refueling operations. The events that
resulted in these violations included the removal of seseral lead bricks from a
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permanent shielding barrier blocking the reactor cavity access by an unlicensed
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Auxiliary Nuclear Operator who looked into the area beneath the reactor vessel
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to check for water leakage past the seal plate. When the lead bricks were
removed from the reactor cavity access, a nigh radiation area of 40 Rem / hour at
18 inches from the access (55 Rem / hour at the center of the opening) was
created which was uncontrolled with respect to barricading, posting, and access
by use of a Radiation Work Permit. This radiation field existed for a period
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Florida Power Corporation
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MAR.171988
of approximately 30 to 45 minutes until it was discovered'and controlled by a
health physics technician.
Ouring this time two individuals worked in the
vicinity of the opening and at least seven individuals walked through the
radiation field.
This event resulted in an urplanned exposure that violated plant administrative
limits.
It is fortuitous that only the initial Auxiliary Nuclear Operator who
removed the lead bricks received any significant exposure. Altheugh the
calculated conservative estimated exposures to the initial operator were
1.8 Rem to the whole body and 6.6 Rem to the extremities, which are less than
the NRC limits, the NRC is concerned that these violations, collectively,
caused a significant potential for personnel exposures in excess of NRC limits.
Unauthorized entries into pressurized Water Reactor (PWR) cavity areas have
been a continuing problem within the industry, which have resulted in exposures
in excess of NRC limits and the potential for life threatening exposures as
dose rates in these areas may be on the order of several thousand Rem per hour.
You were informed of this problem via three NRC Information Notices (IN)
(IN 82-51, "Overexposures in PWR Cavities;" IN 84-19, "Two Events Involving
Unauthorized Entries Into PWR Reacter Cavities;" and IN 86-107, "Entry Into PWR
Cavity with Retractable Incore Detector Thimbles Withdrawn") and by INPO
Significant Operating Experience Report (SOER) 85-3.
There were several root causes that contributed to this event which are similar
to the root causes of unauthorized entries into PWR reactor cavities at other
facilities.
They include a lack of adequate comsunication, health physics
controls, and knowledge of the hazards. Weaknesses in the associated training
program and the lack of a good method for early detection of water leakage past
the reactor cavity seal plate also contributed to this event.
In addition,
there were no written specifications for replacing the fixed shield wall after
an entry made during the previous refueling outage in 1985, and the bricks were
not placed back into the wall in as substantial a manner as they had been
originally.
The violations described in Section II of the enclosed Notice involved failure
to provide a radiation monitoring device to an individual inside a posted High
Radiation Area as required by your Technical Specification, and failure to
follow radiation control procedures.
NRC Inspection Report Nos. 50-302/86-06
and 50-302/86-26 sent to you on March 25, 1986, and September 2, 1986, respec-
tively, each of which was issued with a Notice of Violation for prior instances
(on Janui.ry 28 and February 19,1986) where individuals entered posted High
Radiation Areas without radiation monitoring devices.
Because "similar violations,"
as described in the NRC Enforcement Policy, are of significant concern to the
NRC, please give particular attention in your response to the identification of
the root cause of this problem and your corrective action to prevent recurrence.
The NRC is also concerned that upon discovery of the most recent event your
health physics personnel did not take action to remove the individual from the
High Radiation Area, but let him remain in the area without the necessary
controls for approximately thirty minutes until he had completed his work. This
failure to take prompt corrective action is also of concern to the NRC and your
response should describe those actions you have taken or planned to ensure that
immediate action is taken to correct unsafe conditions when they are observed.
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Florida Power Corporation
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hAAR 171988
To emphasize the serious nature of these events and the need for improvements
in the administration and control of your Radiation Safety Program and your
training program to ensure the safe performance of licensed activities and
adherence to NRC requirements, I have been authorized, after consultation with
the Director, Office of Enforcement, and the Deputy Executive Director for
Regional Operations, to issue the enclosed Notice of Violation and Proposed
Imposition of Civil Penalty in the amount of One Hundred Thousand Dollars
(5100,000) for the violations described in the enclosed Notice.
In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations described
in the enclosed Notice have been categorized in the aggregate as a Severity
Lesel III preblem.
The base value of a civil penalty for a Severity Level III
violation or problem is $50,000.
The escalation and mitigation factors in the
Enforcement Policy were considered, and the base civil penalty amount has been
increased by 100 percent.
In the determination of the civil penalty amount,
consideration was given to your identification of the problems, your prompt
reporting of the events, and your extensive corrective actions.
However,
because of:
(1) your prior notice of similar reactor cavity events as demon-
strated by your receipt of NRC ins 82-51, 84-19, and 86-107 and your receipt of
INPO SOER 85-3; (2) the fact that a work order to install a strongback on the
existing lead brick barricade with an appropriate locking device was generated
in 1985, was still outstanding at the time of this event, and if completed
would have prevented the occurrence of the reactor cavity access event; (3) the
fact that there were several opportunities to discover the reactor cavity
access problem in that several members of your staff, including a foreman,
passed through the vicinity, saw the operator removing the lead bricks from the
shield wall, but did not recognize or report the problem; and (4) the fact that
the violations involving unauthorized entries are similar to violations
occurring in 1986; the civil penalty was escalated 100 percent.
As indicated
in the Notice, 575,000 of the civil penalty is for the reactor cavity event
because of its greater significance.
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
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 accoraance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy uf this letter and its enclosure
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will be placed in the NRC Public Document Room.
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
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Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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MAR 17 S8P>
Florida Power Corporation
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Should you have any questions concerning this letter, please contact us.
Sincerely,
ORIGINAL SIGNED BY:
J. NELSON GRACE
J. Nelson Grace
Regional Administrator
Enclosure:
Proposed Imposition of Civil Penalty
cc w/ encl:
bf. F. McKee, Director,
Nuclear Plant Operations
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C. Simpson, Director,
Nuclear Site Support
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