ML19224C596
| ML19224C596 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/04/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19224C592 | List: |
| References | |
| 50-333-78-28, NUDOCS 7907030065 | |
| Download: ML19224C596 (4) | |
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APPENDIX A NOTICE OF VIOLATION Pcwer Authority of the State of New York Docket No. 50-333 Based upor. the results of an NRC inspection conducted on December 4-7, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your License No. DPR-59 as indicated below.
Items Al, A2 and E are deficiencies; Items B, C, D and F are infractions.
A.
10 CFR 19.11, " Posting of notices to workers," states in para-graph (a), "Each licensee shall post current copies of the fol-lowing documents:
(1) the regulations in this part and in Part 20 of this chapter; (2) the license, license conditions... ;
and amendments thereto; (3) the operating procedures... and (4) any notice of violation involving radiological working con-ditions issued pursuant to f cpart B of Part 2 of this chapter, and any respon:e from the licensee." Paragraph (b) states, "If posting of a document specified in (a)(1), (2) or (3) of this section is not practicable, the licensee may post, notice which describes the document and states where it may be examined." 19. ll (e) states, " Commission documents posted pursuant to. paragraph (a)(4) of this section sL11 be posted within 2 working days after receipt
... ; the licensee response, if any, shall be posted within 2 working days after dispatch by the licensee.
Such documents shall remain posted for a minimum of 5 r days..."
19.ll(d) re-quires that the above posted items si 4 pear in a sufficient number of places to pennit individuals engaged in licensed activities to obsr"ve them on the way to or from any particular licensed acti-vity tc which the document applies.
On December 6, 1978:
1.
Contrary to the requirements of 10 CFR 19.ll(a)(4) and 19.ll(e) a response dated December 1,1978 to a notice of violation in-volving radialogical working conditions, issued pursuant to 10 CFR 2(B) in canaection with Inspection No. 50-333/78-19 had not been posted within 2 working days after dispatch.
272 33B9 7907 03006 54
Appendix A 2
2.
Cortrary to the requirements of 19.11(a)(1), (2) and (3), 10 CFP 19.ll(b) and 10 CFR 19.~1(d) no copy of the documents specified in these parts was posted on the controlled bulletin board on the 286 foot elevation of the administration building which is on one of two ways to and from the licensed activities.
B.
Technical Specification Section 6.11, " Radiation Protection Program" requires that procedures for personnel radiation protection shall be prepared and adhered to for all plant operations, ed that the procedures shall include planning, preparation and traicing for operation and maintenance activities.
1.
Contrary to the above, an individual who was required to wear a half-mask respirator to perform work unnr RWP No. 9765 failed to perform the negative pressJre test of the respirator fit required to comply with the Radiation Protection Operating Procedures,Section III.B3.5.3, at 11:20 p.m. on December 4, 1978.
The individual had not been trained in the test procedure.
2.
Contrary to the above, Restricted Area signs were not posted on December 6,1978, at two temporary outdoor storage areas as was necessary to comply with the Radiation Prote. tion Pro-cedures,Section II. A1.3.1.
One area was near the railroad track into the reactor building and the other area was near the radwaste building truck bay, posted as radiation areas, with dose ratus of up to 5 mrem /hr at the boundaries.
C.
TS 6.8(A) requires written procedures and administrative policies to be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5, " Facility Administrative Policies and Procedures" of ANSI N18.7-1972 and Appendix A of Regulatory Guide 1.33, November,1972.
Procedure No. 1.4, " Control of Plant Procedures" developed pursuant to the above requirements requires that plant procedures shall be controlled, distributed and naintained in accordance with the pro-
" Tions of this procedure.
Section 7.3, " Revisions" and 7.4 "Tempor-y Changes" reautre documentation of all revisions and changes to tant procedures using a Procedure Initiation / Revision Request Form.
272 340
Appendix A 3
Contrary to the above requirements, on October 16, 1978, without adhering to any of the requirements of Procedure No.1.4, the Superintendent of Radiological and Environmental Services issued a memorandum contradicting a requirement to maintain locked gate contrcl of access to high radiation areas > 100 mrem /hr but < 1000 mrem /hr, stated in an approved procedure, " Radiation Protection Operating Procedures", and subsequently required workers adherence to instructions in one memorandum pending the revision of the approved procedure.
D.
10 CFR 20.103(c), " Exposure of individuals tc concentrations of radioactive materials in air in restricted areas" requires in part that: When respiratory protective equipment is used to limit the inhalation of airborne radioactive material pursuant to paragraph (b)(2) of this section, the licensee may make allowance for such use in estimating exposure of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15
" Acceptable Programs for Respiratory Protection." Section C.4,
" Regulatory Position" of Regulatory Guide 3.15 requires the licensee to maintain and implement a respiratory protection program that includes, as a minimum, the following items:
(partial list) c.
k.'ritten procedures to ensure the adequate individual fittir.g of respirators, as well as such procedures to ensure the testing of respiratory protective equipment for operability immediately prior to each use.
Section C,7 of Regulatory Guide 8.15 states, "Unless otherwise authorized by the Comission, the licensee is not to assign protection factors in axcess of those specified in Table I."
Footnote d(2) to Table I sta.tes that the protection factors apply only for trained individuals wearing properly fitted respirators, and footnote f. to Table I states that the half-mask respirator is tc be tested for fit with irritant smoke, prior to use. each time it is donned.
Contrary to the above requirement, the approved Radiation Protection Operating Procedures, Revision 1, hvember 17, 1978, stater that a protection factor of 10 is used with the half face mask an. fail s to specify t'at it is to be tested for fit with irritant smoke, prior to use, each time it is donned.
Workers were observed donning these masks to perform work under RWP No. 9765 at 11:20 p.m. on December 4,1978, who did not perform the required test for fit with irritant smoke.
272 340
Appendix A 4
E.
10 CFR 20.203(f) requires, in part, that eacn container of radio-active material shall bear a durable, clearly visible label identi-fying the radioactive contents and the label shall bear the radia-tion caution symbol and the words " Caution, Radioactive Material" or " Danger, Radioactive Material."
Contrary to the above requirements, tnere were unattended unlabelled containers of radioactive materials having measured surface dose rates of from 4 to 25 mrem /hr as follows:
December 4, 11:10 p.m. a 4 foot X 8 foot box of waste on the 272 foot elevation of the Reactor Building; December 5, 00:30 a.m. a 4 foot X 8 foot box of waste on the 272 foot elevation of the Turbine Building; December 5, 10:20 a.m., a 4 foot x 10 foot equipment box outdoors; December 6, 1972 eight 55 gallon drums of protective clothing on the 272 foot elevation of the Turbine Building.
F.
Environmental Technical Specifications (ETS) 2.3.B.3 states that the release rate of gaseous activity shall not exceed 8 percent of the above 2.3.B.2 averaged over any calendar quarter.
Contrary to the above, the gaseous release rate of I-131 and parti-culates with half lives greater than eight days averagedover the calendar quarter exceeded 8 percent of 2.3.B.2 for the calendar quartir that included July, August and September,1978.
(3 rd quarter,1978) 272 342