ML19309F797
| ML19309F797 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/31/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19309F788 | List: |
| References | |
| 50-219-79-07, 50-219-79-7, NUDOCS 8005010231 | |
| Download: ML19309F797 (4) | |
Text
_ _ _ _ -
O APPENDIX A 4
NOTICE OF VIOLATION Jersey Central Power and Light Company Docket No. 50-219 Forked River, New Jersey 07960 License No. DPR-16 Based on the results of an NRC inspection conducted on April 18-20, 1979 and July 19-20, 1979, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your license as indicated below.
These items are infractions.
1.
10 CFR 20.201, " Surveys", states in Paragraph (b), "Each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part. A survey as defined in Paragraph 20.201(a) means, "an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
When appro-i priate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or con-centrations of radioactive material present."
a.
Contrary to the above, on March 16, 1979, radiation surveys necessary to assure compliance with 10 CFR 20.101, " Exposure of individuals to radiation in restricted areas" were not performed in support of work activities conducted in accordance with Radioactive Work Permit (RWP)
No. 062279.
RWP No. 062279 was issued based on survey data compiled on March 1,1979 and indicated that the radiation levels in the work area were 1.0 mrem per hour. Actual radiation levels in the work area measured as high as 200 mrem /hr on March 16, 1979.
b.
Contrary to the above, between March 16 and April 26, 1979, no evalua-tions were made to determine the radiation exposure received as a result of the radiation dose to the skin of three individuals who became extensively contaminated with radioactive water (Primary Coolant) while performing activities in accordance with Radioactive l
Work Pennit No. 062279.
Initial radiation levels as high as 224 mrads l
per hour were measured on the skin surfaces of the individuals on March 16, 1979.
l l
hhh
4 4
Appendix A 2
2.
10 CFR 20.201, " Surveys", states in Paragraph (b), "Each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part." A survey as defined in Paragraph 20.201(a) means, "an evaluation of the radiation hazards, incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appro-priate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concen-trations of radioactive material present."
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas" states in Paragraph (a)(3), for purposes of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radio-active materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for i
timely detection and assessment of individual intakes of radioactivity by exposed individuals.
i a.
Contrary to the above, on March 16, 1979, surveys of concentrations of radioactive materials in air were not made to support work which had the potential for subjecting personnel to exposure from airborne radioactive materials in air.
Such work was performed by inuividuals in accordance with the following Radioactive Work Permits (RWPs):
RWP No.
Title 061979 Run Temp Pipe Line, DWEDT Line-Hub Drain in CSHX Area 062279 Cut DWEDT Discharge Line and Cap-SW Corner of Rx Building in Pipe Tun b.
Contrary to the above, for the period between March 16 and April 20, 1979, no evaluations such as measurements of radioactivity in the body, measurements of radioactivity excreted from the body or any combination of such measurements, was made on three individuals l
performing work in accordance with Radioactive Work Permit 062279, in l
l which the personnel were subject to extensive contamination resulting in a dose rate as high as 224 mrads per hour on the upper portions of i
{
the persons head and face.
t
Appendix A 3
3.
10 CFR 19.12, " Instructions to Workers", states, "All individuals working in or frequenting any portion of a restricted area shall be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area; shall be instructed in the health protection problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed".
The extent of those instructions shall be coninensurate with potential radiological health protection problems in the restricted area.
In addition, Health Physics Procedure 902.1, Revision 13, Radioactive Work Permits states in Section 4.1, " Working personnel should be briefed on the work to be performed and the radiological safety procedures applicable to the job".
Contrary to the above, on March 16, 1979, two individuals were directed to perform work in accordance with Radioactive Work Permit No. 062279, " Cut DWEDT Discharge Line and Cap-SW Corner of Rx Building In Pipe Tun" without being informed of the specific radiological hazards associated with this activity, i.e., the personnel were not informed that the pipe they were to cut into contained highly radioactive water and was under at least 22 psi pressure; the quantity of the liquid expected to be released after the pipe was cut, the radiation levels in the area they were working and the procedural specification required by the Job Instruction Procedure 79-7, " Repair of DWEDT Discharge Line".
As a result the personnel were not aware of the potential radiological health protection problems associated with the work and were not advised of precautions and procedures to minimize their exposure.
4.
Technical Specification 6.11, " Radiation Protection Programs", states,
" Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure".
Contrary to the above, on March 16, 1979, the followi.ng procedures, written pursuant to this specification were not adhered to in regard to activities conducted as permitted by RWP No. 062279, " Cut DWEDT Discha.rge Line and Cap":
Procedure Specifications Not Followed 902.1, Revision 14 - Radioactive 3.1, 4.1, 4.2, 5.3.1 Work Permits 905.10, Revision 4 - Personnel 3.2, 5.2.2, 5.2.3, 5.4.1, 5.4.2 Contamination - No Injury I
j Appendix A 4
Procedure
' Specifications Not Followed 905.2, Revision 4, Class II 3.1.1, 3.1.4, 5.1, 5.2 Emergency 903.9, Revision 0, Daily Exposure 5.12 and Access Control Card 901.6, Revision 1, Considerations 5.4 in Air Sampling for Respiratory Protection 903.5, Revision 14, Bioassay 5.1 Samples and Whole Body Counting 5.
Technical Specification 6.8.1, "Proceduras" states, " Written procedures shall be established, implemented (adhered to), and maintained that meet or exceed the requirements of Section 5.1 and 5.3 of American National Standard N18.7-1972 and Appendix ' A' of the Nuclear Regulatory Commission's Regulatory Guide 1.33-1972..."
Procedure 79-7, Revision 0, Repair of DWEDT Discharge Line, written in accordance with this specification, states the following:
"3.0 Prerequisites..
3.5.
Ensure the discharge line is appropriately isolated, drained and tagged prior to cutting into it.
5.0 Instructions..
5.1.4.
Ensure the section of the discharge line to be cut is isolated, drained and tagged.
Contact the Group' Shift Supervisor for notification".
l Contrary to the above, on March 16, 1979, Procedure 79-7, Revision 0, was not adhered to in that the discharge line was not isolated and drained prior to cutting the pipe.
Consequently, several persons received exten-sive radioactive contamination when they were sprayed with the liquid contents (Primary Reactor Coolant) of the pipe which was under an estimated 22 psi of pressure when the pipe cut was made.
Radiation levels as high as 224 mrad /hr were measured over the entire skin surfaces of one of the individuals and in various locations of the body of the two other individuals who were exposed.
1