ML19256E126

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Notice of Violation from Insp on 790313-15
ML19256E126
Person / Time
Site: 05000054
Issue date: 08/10/1979
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19256E120 List:
References
50-054-79-02, 50-54-79-2, NUDOCS 7910290136
Download: ML19256E126 (2)


Text

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APPENDIX A

, NOTICE OF VIOLATION

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Union Carbide Corporation Docket No. 50-54 License No. R-81 1

Based upon the results of the NRC inspection conducted on March 13-15, 1979, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your facility license (R-81) as indicated telow.

Items A and D are Deficiencies, Items B, C, E, and F are Infractions.

A.

10 CFR 20.203(f) requires that each container of licensed material bear a clearly visible label identifying the radioactive contents.

This label shall bear the words " Caution, Radioactive Material,"

and will provide sufficient information to permit individuals handling or working in the vicinity thereof to take precautions to avoid or minimize exposures.

Contrary to the above requiremants, on March 13,1979, a 55 gallon steel drum exhibiting radiation levels of 20 millirem per hour at one inch from its surface was left unattended without the required label and identifying information affixed to the drum.

B.

10 CFR 50.36(d)(1) states that a license in which technical speci-fications have not been designated shall be deemed to include the entire safety analysis report as technical specifications.

Section E.3.f of the Union Carbide Final Hazards Summary Report (safety analysis report) requires that areas found to be contaminated will be roped off until decontamination is complete and that protective clothing be provided to employees who enter a contaminated area.

Contrary to the above, on March 13, 1979, the heat exchanger hallway exhibited removable contamination levels of approximately 7,600 disintegrations per minute per 100 cm2 and was not roped off as required.

In addition, a licensee employee entered this area without required protective clothing.

C.

10 CFR 20.201 requires licensees to conduct evaluations (surveys) of the radiation hazards incident to the presence of radioactive materials to include a physical survey of the location of materials and measurements of levels of radiation or concentrations of radio-active material present.

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f)37

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Appendix A 2

Contrary to the above, work was performed in the area of the heat exchangers, (a location exhibiting contamination levels of approx-imately 7,600 disintegrations per minute per 100 cm2) to change filters in the ion exchange column without benefit of air samples to measure concentrations of radioactive material to which the worker may have been exposed.

D.

10 CFR 20.401 requires that licensee's maintain records showing the radiation exposures of individuals on Form NRC-5 or on a clear and legible record containing all information required by Form NRC-5.

Contrary to the above, as of March 15, 1979, the licensee had failed to determine the radiation dose received by an individual during the period December 26, 1977 throughJanuary8,1978and record such information on t!.a individual s Form NRC-5 or equiv-alent.

E.

Section E.3.e of the Union Carbide Final Hazards Summary Report, incorporated as license conditions by 10 CFR 50.36(d)(1) requires that " urinalysis on all personnel working in the Reactor be made on a routine basis at least once every six months."

Contrary to the above, urinalysis of personnel was performed on an annual (every 12 months) basis for the past 10 years.

F.

10 CFR 20.201 requires that licensees perform evaluations incident to the disposal of radioactive materials, to include measurements of concentrations of radioactive materials, that may be necessary to comply with the regulations of 10 CFR Part 20.

10 CFR 20.106 prohibits the release of radioactive materials to unrestricted areas in concentrations which exceed the limits specified in Appendix "B," Table II of 10 CFR 20.

10 CFR 20, Appendix "B," note 5 states that a radionuclide may be considered not present in a mixture if the ratio of the concentration of that radionuclide in the mixture to the concentration limit for that radionuclide specified in Table II of Appendix B does not exceed 1/10.

Contrary to the above, the licensee failed to evaluate 1977 and 1978 gaseous effluents for the presence and concentrations of I-133, a radionuclide calculated to have been present in amounts greater than 10% of the MPC listed in 10 CFR 20, Appendix B, Table a

II, Column I.

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