ML17278A246
| ML17278A246 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/13/1985 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17278A245 | List: |
| References | |
| 50-397-85-20, NUDOCS 8507010221 | |
| Download: ML17278A246 (6) | |
Text
APPENDIX A NOTICE OF VIOLATION Washington Public Power Supply System P. 0. Box 968 Richland, Washington 99352 Docket Number 50-397 License Number NPF 21 During an NRC inspection conducted on May 29-31, 1985 violations of NRC requirements were identfied.
The violations involved adherence to Technical Specification required procedures during a maintenance outage involving posting of radiation areas, labeling of radioactive material containers work activities within the drywell and contxol of overtime for chemistry and health physics technicians.
In accordance with the "General Statement of Policy and Procedures for NRC,Enforcement. Actions," 10 CFR Part 2, Appendix C
(1985) the violations are listed below:
id A.
Technical Specifiction 6.2.2.f.2 states in part, " An,,individual should not be permitted to work....more'han
'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in.any 7 day period...
Any deviation... shall be authorized by the plant manager... in accordance with written procedures and with documentation of the basis for granting the deviation."
Procedure 1.3.27 step, 5..F states in part that any deviation shall be approved and documented prior to approving the overtime.
Contrary to the above requirements, two 'individuals each worked 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in seven consecutive days prior to May '10,'1985 when the approval was documented.
In addition, the memorandum approved by the plant manager dated May 10, 1985 containing documentation of the approval did not provide the basis for granting the deviation.
These two individuals worked 15 and 20 consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days.
This is a Severity Level V Violation (Supplement I).
B.
Technical Specification 6.11.1 states in part," procedures... shall be prepared consistent with the requirements of 10 CFR 20 and shall be...
adhered to... ".
Plant Procedures Manual (PPM) 11.2.7.1,
'Area Posting'tates in part that all areas accessible to personnel with exposure rates greater than or equal to 2.5 mrem/hr shall be posted at'ach accessible perimeter with the words 'AUTION RADIATION AREA
'nd PPM 11.2.14.3,
'Storage of Radioactive Material'tates in part that The storage area shall be posted at any accessible side with a "CAUTION RADIOACTIVE MATERIAL" sign and that each container shall also be labeled with the " CAUTION RADIOACTIVE MATERIAL" sign, the type of material and radiation levels at contact and three feet.
Contrary to the above requirements on May 30, 1985 the outdoor solidification work area was being used to store radioactive material and:
1.
Three steel boxes containing compressed radioactive trash were not labeled at all regarding radioactive material content; 85070i022i 850613 PDR ADOCK 05000397 PDR
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The storage area was not labeled at one accessible side in that the two barrier ropes on one side of the area were both down, the sign with the radioactive material posting was face down in sand and other postings were not readily apparant; 3.
The area was not posted on any side as a radiation area and the measured radiation exposure rate at 18 inches from one container was 3.0 to 4.0 mr per hour.
The above conditions existed for about two hours prior to discovery by the NRC inspector.
The exceptions of 20.203 (f)(3) and 20.204 did not apply.
I This is a Severity Level IV Violation (Supplement IV).
C.
Technical Specification 6.8.1 states in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below: a. Regulatory Guide 1.33... g. Pire Protection Program Implementation."
RG 1.33 Appendix A, Item 9.C lists examples of safety related equipment for which procedures should be prepared prior to beginning work.
I 1l PPM 1.3.18,
'Tool and Equipment,'Control Around Open Plant Systems's identified by the licensee as a safety related procedure.
'This procedure, step 1.3.18.4.C states that use of this procedure is mandatory for components of the primary system when components are opened for rework.
Step 1.3.18.7, Procedure
, states that 'tools shall be inventoried and logged in and out 'of 'the work area and that all tools and equipment shall be equipped with a lanyard.'
I PPM 1.3.19, a licensee
'designated safety related procedure prohibits the use of clay mineral sorbants in the power block( reactor building, turbine building).
Contrary to'he above.
1.
On May 29, 1985, between 3PM and 5PM, work in progress on an open safety related portion of the primary system (inboard main feedwater check valve) was conducted without following procedure 1.3.18 in that tools were not logged, lanyarded or otherwise controlled.
2.
On May 29 and May 30, 1985, the the use of prohibited material (clay mineral absorbant) was observed on the 572 foot elevation of the reactor building.
This is a severity Level IV Violation (Supplement I).
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Pursuant to the provisions of 10 CPR 2.201, Washington Public Power Supply System is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation:
(1) the reason for the violations if
- admitted, (2) the corrective steps which have been taken and the results
- achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
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Dated
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R.A. Scarano, Director, Division of Radiation Safety Safeguards
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