ML19269C010
| ML19269C010 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/12/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19269C001 | List: |
| References | |
| 50-219-78-27, NUDOCS 7901190199 | |
| Download: ML19269C010 (10) | |
Text
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APPENDIX A NOTICE OF VIOLATION Jersey Central Power and Light Company Docket No. 50-219 This refers to the inspections conducted by representatives of the Region I. (Philadelphia) Office at the Oyster Creek Nuclear Generating Station, Forked River, New Jersey, of activities authorized by NRC License No. DPR-16.
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During these inspections conducted en September 6-8, 18-19, and 26-29, 1978 (Inspection No. 50-219/78-23) and on October 17-19, 1978 (Inspection No. 50-210/78-27), the folicwing apparent items of nonccmpliance were identified.
A.
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas," requires in paragraph (a)(3) that for purposes of determining compliance with the requirements of section 20.103 the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
Contrary to th.e above:
1.
Surveys of airborne radioactive material to assure compliance with 10 CFR 20.103(a) were not made on September 28, 1978, in the Centrifuge Room of the Rad Waste Building, a restricted area, when two individuals, wearing half masks with air purifying cartridges, entered the room on an inspection tour.
The centrifuge was not operating.
Floor smears taken by the licensee from the area entered yielded removable contamination levels of approximately 986,000 dpm/100 cm2 2.
Surveys of airborne radioactive material to assure compliance with 10 CFR 20.103(a) were not 'made on September 28,1978, in the Operating Aisle of the Rad Waste Building, a restricted area, when two individuals, wearing half masks with air purifying cartridges, used the service air system to blow out air supply hoses.
The rapid flow of Tir was directed against the contaminated floor.
Floor smears taken by the licensee on September 28, 1978 indicated removable contamination levels ranging from approximately 10,000 to 163,000 dpm/100 cm2 No air survey was made to determine the airborne concentrations to which the individuals were exposed during this operation.
An air survey made approximately 15. minutes after the work was
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completed showed that the airborne concentration of radio-active material had increased substantially when compared -to a survey made in the same location three hours earlier.
7901190/c7 ef
5 Appendix A -
3.
Surveys of airborne radioactive material to assure compliance with 10 CFR 20.103(a) were not made on September 27, 1978 when an individual wearing a full face supplied air respirator, entered the Centrifuge Room of the Rad Waste Building, a restricted area, while the centrifuge was processing radio-active waste.
The nearest air sample taken during the centri-fuge operation was obtained in the Operating Aisle of the Rad
. Waste Building.
This sampling point was outside and at least 100 feet from the closed, unventilated Centrifuge Room, and was not representative of the' air.coricentrations to which the individual was exposed.
Smears taken in the Centrifuge Room by the licensee on September 26, 1978, revealed that removable radioactive contamination levels ranged from approximately 300,000 to 1,350,000 dpm/100 cm2, This is an infraction (Civil Penalty $3,000).
B.
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas," requires in paragraph (b)(1) that the licensee shall, as a precautionary pro-cedure, use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radicactivity area as defined in 520.203(d)(1)(ii).
Contrary to the above, on September 29, 1978, neither process nor other engineering controls were used to limic concentrations _of radioactive materials in air during work at the open discharge chute of a hopper in the Drum Filling Aisle of the Rad Waste Building which was a restricted area.
The hopper was blocked with dry caked radioactive powder and no measures to limit the disper-sion of the dislodged material into the breathing zone of the two individuals were utilized.
Two individuals wearing full face supplied air respirators stood beneath and to the side of the chute and poked with a stick to dislodge the radioactive material above.
Floor smears taken by the licensee measured loose contamination of approximately 150 mrem /hr at contact.
This is an infraction (Civ'il Penalty $3,000).
C.
10 CFR 20.103, " Exposure of individuals to concentrations of radio-active materials in air in restricted areas," requires in paragraph (c) 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 exposures of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15,
" Acceptable Program for Respiratory Protection".
Appendix A Regulatory Guide 8.15, 'able 1, " Protection Factors for Respirators",
states in footnote (b) that the protection factors for respirators are, "Only for shaven faces and where nothing interferes with the seal of tight-fitting facepiecec against the skin".
Oyster Creek Procedure No. 904.2, Revision 8, dated May 22, 1978,
" Fitting and Removal of a Full Face Respirator," states in section 4.5', "There shall be no interference between a headgear and the normal method of wearing a respirator".
Contrary to the above, on September 29, 1978, allowance was made for the use of respiratory protective equipment, full face supplied air respirators, when two individuals wcrked to dislodge dry radio-active powder blocking the open di.scharge chute of a hopper in the Drum Filling Aisle of the Rad Waste Building, which was a restricted area.
The individuals' disposable hoods interfered with the seal's of the tight-fitting facepieces against their skin.
This is an infraction (Civil Penalty $3,500).
D.
Technical Specification 6.13, "High Radiation Area," requires that each High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be barri-caded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit.
It further requires that any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.
Contrary to the above:
1.
On September 7,1978, a survey taken by the inspector of a sealed wooden box approximately 4 feet by 8 feet by 3 feet high, located on the 119' elevation of the Reactor Building, identified a radiation field over an extended area of aporoxi-mately 150 mrem /hr at 2 inches from the top of the box (apparent potential gonad dose) and the area was not barricaded and conspicuously posted as a High Radiation Area.
The single High Radiation Area sign on the top surface of the box was covered by a nylon rigging sling and did not provide a conspic-uous warning to personnel.
2.
On September 26, 1978, a survey taken by the inspector of piping near the wooden platform at the entrance to the Torus area identified a radiation field over an extended area of approximately 200 mrem /hr when measured at about eighteen inches from the pipes and the area was not barricaded and posted as a High Radiation Area.
Appendix A 3.
On October 17, 1978, a survey, performed by the inspector and confirmed by the licensee, of the Reactor Cavity Drain Line, located on the 75' elevation of the Reactnr Building, identified a radiation field over an extended area of approximately 120 mrem /hr when measured at about twelve inches from the pipe (apparent potential dose to lens of eyes) and the area was not barricaded.
This is an infraction (Civil Penalty S4,000).
E.
Technical Specification 6.11, " Radiation Protection Program" in addition to requiring that procedures for perscnnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20, also requires that they be approved, maintained and adhered to for all operations involving personnel radiation exposures.
1.
Oyster Creek Procedure No. 902.4, Revision 2, " Access and Egress Control" dated May 21, 1976, states,1) that if a personnel monitor is provided at the Radioactive Work Permit (RWP) area exit, it shall be used to check for gross personnel contamination, and 2) passage from the Radicactive Materials Area will be permitted only after an individual has removed any protective clothing and monitored himself to determine that the allowable limits of personnel contamination are not exceeded.
Contrary to the above:
(a) On September 6, 1978, one individual was observed leaving the Radioactive Materials Area at the main monitoring and change room, where monitoring equipment was provided, without performing the required monitoring.
(b)
On September 18, 1978, one individual was cbserved leaving the control point at the Turbine Operating Floor, an RWP area where a monitor was provided, without monitoring himsel f.
(c)
On September 28, 1978, two individuals were observed leaving the control point in the Rad Waste Building, an RWP area where a monitor was provided, without monitoring themsel ves.
2.
Oyster Creek Procedure No. 914.4, Revision 9, dated March 18, 1976, "Use of Protective Clothing and Equipment" states in section 3.1 that only clothing with radiation levels less than 1 mR/hr above background is to be made available for use.
9.
Appendix A Contrary to the above, on September 7, 1978, a survey taken by the inspector and confirmed by the licensee of three pairs of coveralls from the issue bins located in the lionitor and Change Room, where they were available for use, revealed one pair of coveralls which exceeded 1 mR/hr above background.
3.
Oyster Creek Procedure No. 902.1, Revision 14, dated
" September 13,1978, " Radioactive Work Permits" states in section 4.2 that all applicable radiological limits and precautions shall be held in strict compliance by all personnel.
Contrary to the above, on October 18, 1978, an individual was observed working in a posted and barricaded high radiation and contamination area without the protective equipment (high range self-reading dosimeter, surgeons cap, plastic gloves and rubber shoe covers) required by the Radioactive Work Permit (No. 2731).
4.
Oyste Creek Procedure !!o. 906.3, " Pre-operational Checkout of TLD Reaier", Revision 1, dated May 22, 1978, requires that ;
pre-operational checkout of the TLD reader be performed prior to reading any TLD dosimeters.
Specific pre-operational checkout requirements are:
(a)
In Section 5.7 which states, " Record average reading
[ Light Source Value] on log sheet".
(b)
In Section 5.8 which states, "Under the remarks column on the log sheet, record the name of the person performing the checkout".
Contrary to the above, a review of records showed that:
(a)
On July 26 and August 7,1978, the average light source value was not recorded on the log sheet.
1 (b)
During the period July 11 thru August 16, 1978, the name of the person peforming the TLD checkout was not entered on any of the log sheets.
5.
Oyster Creek Procedure No. 903.2, " Personnel Monitoring" Revision 11, dated July 5,1978, states in Section 3.2 that as a prerequisite to assigning personnel dosimetry "all dosimetry has been checked and found to be acceptable for use".
Appendix A.
Oyster Creek Procedure No. 906.17, " Spike Tecting and Leak Testing Self-Reading Dosimeters", Revision 1, dated May 22, 1978, requires:
(a)
In Section 5.1 " Spike Testing", step 5.1.17 that if the dosimeter net value is not within +10% of the Condenser R-meter reading, the dosimeter shat 1 be removed from immediate service.
(b)
In Section 5.2 " Leak Tes' ting", step 5.2.9 that if the dosimeter net value is not within 2% of the full scale reading, for each 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, the dosimeter shall be removed from immediate. service.
Contrary to the above, a review of test results for 10 self-reading dosimeters selected on October 18, 1978, from the in-service dosimetry racks, located in the Main Guard House, showed that:
(a)
Dosimeter No. 704221 had failed both the spike and leak testing and had not tten removed from immediate service.
(b)
Dosimeter No, 602310 had not been tested (spike or leak) and found acceptable for service as required.
This is an infraction (Civil Penalty $4,000).
F.
10 CFR 20.203, " Caution si requires in paragraph (f) gns, labels, signals and controls,"
that each container of licensed material shall bear a durable, clearly visible label identifying the radio-active contents.
The label must bear the radiation caution symbol and the words " Caution - Radioactive Material" or " Danger - Radi.o-active Material".
It must also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precaution to avoid or minimize exposures.
Oyster Creek Procedure No. 909.2, Rev. O, dated August 20, 1976,
" Radioactive Material Container Labeling", specifies in sections 5.1 and 5.2, the same basic requirement for labeling radioactive material containers as 10 CFR 20.203(f).
Contrary to the above, on September 6,1978, two 55 gallon drums containing radioactive waste, located on the 119' elevation of the Reactor Building did not bear the " Caution-Radicactive Material" label nor were the drums labeled with information to permit individuals handling or working in the vicinity thereof to take precautions to avoid or minimize exposure.
Appendix A This is a deficiency (Civil Penalty $1,500).
G.
10 CFR 20.203, " Caution signs, labels, signals and controls,"
requires in paragraph (e)(1),that each area or room in which licensed material is used or stored and which contains any radio-active material in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part, shall be con-spicuously posted with a sign or signs bearing the radiation caution symbol and the words:
" CAUTION, RADIOACTIVE MATERIAL."
Contrary to the above, on September 6,1978, the major portion of the east and south fence surrounding the Radioactive Waste Building and adjoining storage areas, which contained greater than 10 times Appendix C quantities of radioactive material, were not conspicuously posted as rcquired, in that the majority of the " Caution Radio-active Material" signs had faded to the point where the radiation symbol was recognizable only upon close examination.
This is a deficiency (Civil Penalty - None)
H.
10 CFR 73.55(d)(2) states:
"At the point of personnel and vehicle access into a protected area, all hand-carried packages shall be searched for devices such as firearms, explosives and incendiary devices, or other items which could be used for industrial sabotage."
Contrary to the above, on September 19, 1978, it was observed that while processing two individuals for access into a protected area, the guards on duty did not search two hand-carried packages which were being brought into a protected area.
This is an infraction (Civil Penalty $3,500).
I.
10 CFR 73.40, " Physical protection:
General requirements at fixed sites," requires the licensee to have and follow a Security Plan which provides for physical protection against industrial sabotage and against theft of special nuclear material.
The Oyster Creek Industrial Security Plan, dated January 7,1974, Section 3.4.2, states in part:
"As an added security measure, all outside doors leading to a building, regardless of its contents, will be locked." Contrary to the above:
1.
On September 7,1978, door #18 was open, unlocked and unattended.
Appendix A 8-2.
On September 7, 8 and 18,1978, door #17 was unlocked and unattended.
This is an infraction (Civil Penalty $3,500).
This Notice of Violation is sent to Jersey Central Power and Light Company pursuant to the provisions of Section 2.20! of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Jersey Central Power and Light Company is hereby required to submit to this office within twenty (20) days of the receipt of this Notice, a written statement or explanation in reply, including for each item of noncom-pliance, (1) admission or denial of the alleged items of noncompliance; (2) the reasons for the items of noncompliance if admitted; (3) the corrective step which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncom-pliance; and (5) the date when full compliance will be achieved.
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APPENDIX B NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Jersey Central Power and Light Company Docket No. 50-219 This office has considered the enforcement options available to the NRC including administrative actions in the form of written Notices of Violation, civil monetary penalties, and Orders pertaining to the modi-fication, suspension or revocation of a license.
Based on these con-siderations we propose to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended, (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of Twenty-Six Thousand Dollars (526,000), for the specific items of noncompliance set forth in Appendix A to the cover letter.
In proposing to impose civil penalties pursuant to this section of the Act and in fixing the proposed amount of the penalties, the factors identified in the Statements of Consideration published in the Federal Register with the rule making action-which adopted 10 CFR 2.205 (36 FR 16894) August 26, 1971, and the " Criteria for Determining Enforcement Action," which was sent to NRC licensees on December 31, 1974, have been taken into account.
Jersey Central Power and Light Company may, within twenty (20) days of receipt of this Notice pay the civil penalties in the cumulative amount of Twenty-Six Thousand Dollars ($26,000), or may protest the imposition of the civil penalties in whole or in part by a written answer.
Should Jersey Central Power and Light Company fail to answer within the time specified, this office will issue an Order imposing the civil penalties in the amount proposed above.
Should Jersey Central Power and Light Company elect to file an answer protesting the civil penalties, such an answer may (a) deny the items of noncompliance listed in the Notice of Violation in whole or in part, (b)' demonstrate extenuating circumstances, (c) show error in the Notice of Violation, (d) 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.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explan-ation in reply pursuant to 2.201, but may incorporate by specific reference (e.g., giving page and paragraph numbers) to avoid repetition.
Jersey Central Power and Light Company's attention is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and ensuing orders; answer, consideration by this office, and ensuing orders; requests for hearing, hearings and ensuing orders; compromise; and collection.
ppendix 3 -
Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, the matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended, (42 USC 2282).
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