ML19320D373
| ML19320D373 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/08/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19320D366 | List: |
| References | |
| EA-80-039, EA-80-39, NUDOCS 8007210294 | |
| Download: ML19320D373 (3) | |
Text
e APPENDIX A
~h
'(V NOTICE OF VIOLATION Oyster Creek Nuclear Generating Station Docket No. 50-219 EA-80-39 This refers to the special radiation protection inspection conducted by a representative of the Region I (Philadelphia) Office at the Oyster Creek Nuclear Generating Station, Jersey Central Power and Light Company, Forked River, New Jersey, of activities authorized by NRC License No. DPR-16.
During this inspection conducted on March 18-19, 1980, the following apparent it ems of noncompliance were identified.
~
A.
Technical Specification 6.8, Procedures requires in Section 6.8.1, that written procedures be established, implemented, and maintained that meet or exceed the requirements of Sections 5.1 and 5.3 of American National Standard N18.7-1972 ar.d Appendix "A" of the Nuclear Regulatory Commis~sion's Regulatory Guide 1.33-1972.
Appendix "A" of Regulatory Guide 1.33 lists, in Section G.S.e, Radioactive Work Permit Procedure as a procedure to be prepared. American National Standard (ANSI) N18.7 presents in Section 5.3.2 the content to be included in a procedure.
Included in Section 5.3.2 are precautions and limitations, and actions.
Contrary to the above, for the period July 2, 1979 through March 18, 1980, no Radioactive Work Permit Procedure was established, implemented i
or maintained meeting the above requirements in that the procedure established by the licensee as a Radioactive Work Permit Procedure did not contain precautions and limitations, nor actions.
Specifically, the RWP did not contain:
(1) Precautions, limitations or actions to be taken by personnel, includir.3 radiation protection technician actions, such as termination of the RWP due to changing radiation conditions or actions to be taken as a result of a worker's failure to adhere to the requirements of the j
RWP; (2) Criteria to define the conditions for use of extended versus routine RWP; (3) Limitations regarding the use of one RWP to cover multiple work activities; (4) Required action (based on radiological hazards present) such as holding a preplanning meeting prior to commencement of the work.
The preplannin'g meetings would serve to instruct workers in the precautions and procedures to minimize exposure; and (5) Londuct of an as low as reasonably achievable (ALARA) review prior to commencement of work.
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Appendix A This. lack of precautions and limitations, and actions resulted in two individuals sustaining significant intakes of radioactive material and external radioactive contamination.
This is a violation (Civil Penalty $5,000).
B.
10 CFR 20.103(a)(3) requires that the licensee use suitable measurements of concentrations of radioactive materials in air, for detecting and evaluating airborne radioactivity in restricted areas."
Contrary to the above, on March 2,1980, at 10:00 AM and 8:00 PM two control rod blade handling tools were removed from the facility's Spent Fuel Storage Pool, a restricted area.
The tools were handled, and examined, and at least one tool was repaired by personnel without suitable measure-ments of airborne radioactivity being made The tools had removable radioactive contamination up to 340,000 dpm beta gamma and 390 dpm alpha per 100 square centimeters.
This is an infraction (Civi; Penalty $4,000).
C.
10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas" requires in Paragraph (b), that to the extent practicable, the licensee as a precautionary procedure, use process or other engineering controls to limit concentrations of radio-active materials in air to levels below those which delimit an airborne radioactivity area as defined in 20.203(d)(1)(ii).
When it is impractic-able to apply process or other engineering controls, other precautionary procedures, such as increased surveillance, limitation of working times or the provision of respiratory protective equipment, shall,be used to maintain intake of radioactive material by any individual within any period of seven consecutive days as far below that intake which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform
, concentrations specified in Appendix B, Table 1, Column 1.
Contrary to the above, no process or engineering controls, or other precautionary procedures were used by the licensee during cleaning and examination of control rod blade handling tools on March 2,1980 to limit concentrations of radioactive materials in air and intake of radioactive material by two individuals performing the above work.
The individuals involved sustained extensive radioactive skin contamination and intakes of radioactive material in excess of the 7 day intake limit.
This is an infraction (Civil Penalty $4,000).
D.
Technical Specifica~ tion 6.11, " Radiation Protection Program," requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to
.for all operations involving personnel radiation exposure.
~ Radiation Protection Procedure No. 915.7, Revision 0, '! Personnel Monitoring,". developed pursuant to the above, requires in Paragraph 5.6
Appendix A that extremity dos.imetry be issued when the estimated extremity dose is expected to exceed four (4) times the estimated whole body dose.
Additionally, 10 CFR 20.202(a) requires appropriate personnel monitoring equipment to be supplied by the licensee and used by each individual who is likely to receive 25 percent of the applicable value specified in 10 CFR 20.101(a).
Contrary to the above, on March 2,1980, personnel performed work on a control rod blade handling tool without being provided extremity dosimetry.
The tool was contaminated with radioactive material, which produced contact dose rates (one roentgen per hour gamma and 49 rads per hour beta plus gamma), which could result in extremity doses greater than foue (4) times the whole body dose. In addition _, personnel were likely to receive 25 percent of the extremity dose limit specified in 20.101(a).
This is an infraction (Civil Penalty $4,000).
E.
10 CFR 19.12 " Instructions to Workers," requires that individuals working in or frequenting any portion of a restricted area be kept informed of the storage, transfer or use of radioactive materials or of radiation in such portions of the restricted area; be instructed in the health protection problems associated with exposure to such radioactive materials or rad?ation, in precautions or procedures to minimize exposure and in the purposes and functions of protective devices employed.
The extent of these instructions shall be commensurate with potential radio-logical health protection problems in the restricted area.
Contrary to the above, on March 2,1580, two workers, performing handling, cleaning, examination and repair of highly contaminated control rod blade handling tools were not given instructions commensurate with the potential radiological health protection problems associated with handling the tools including, but not limited to, planning meetings to discuss
, radiological precautions and procedures for handling the contaminated tools.
Consequently, the two workers received personnel skin contamina-tion up to 20,000 dpm over portions of their bodies and intakes of radio-active material of 1,600 nanocuries and 500 nanocuries of cobalt-60.
The 1,600 nanocurie intake is 29% of the allowable quarterly quantity limit as specified in 10 CFR 20 for cobalt-60.
.This is an infraction (Civil Penalty $4,000).
This Notice of Violation is sent to you pursuant to. e provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
You are hereby required to submit to this office, within twenty-five (25) days of the date of this notice, a written statement or explanation in reply, including for each item of noncompliar;e:
(1) admission or denial of the alleged' item of noncompliance; (2) the reasons for the item of noncompliance, if admitted; (3) the corrective steps which have been taken by you and the results achieved; (4) the corrective steps which will be taken to avoid further noncompliance; and, (5) the date when full compliance will be achieved.
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