ML19354E077
| ML19354E077 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/18/1990 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19354E075 | List: |
| References | |
| 50-334-89-21, 50-412-89-20, EA-89-204, NUDOCS 9001250327 | |
| Download: ML19354E077 (3) | |
Text
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1 NOTICE OF VIOLATION Beaver Valley Nuclear Power Station Docket Nos.
50-334 Shippingport, Pennsyirania 15077 50-412 License Nos. DPR-66 NPF-73 EA 89-204 During an NRC inspection conducted between September 25-29, 1989.. violations of NRC requirements were identified.
In accordance with the " General State-ment of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989) (Enforcement Policy), the particular violations are set forth below:
I.
VIOLATION ASSOCIATED WITH A SUBSTANTIAL POTENTIAL FOR OVEREXPOSURE 10 CFR 20.201(b) requires, in part, that each licensee make or cause to be made such surveys as may be necessary to comply with the regulations of 10 CFR Part 20.
10 CFR 20.201(a) defines a survey, in part, as 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 oftconditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation present.
10 CFR 20.101 requires that no licensee possess, use or transfer' licensed material in such a manner as to cause any individual in a restricted area to receive in a calendar quarter from radioactive raterial and other sources of radiation a total occupational dose in excess of the limit.s set forth therein.
Technical Specification 6.11 (Radiation Safety Program) requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part-20 and shall be adhered to for all operations involving personnel radiation exposure.
Radioactive Work Permit RWP 16297, "FOSAR," prepared for Foreign Object Search and Retrieval (FOSAR) maintenance activities, required continuous radiological monitoring. Radeon Procedure 8.1-(Radiological Work Permit),
Table 3.8.1.1, defines " continuous monitoring" to mean " continuous.
surveillance and awareness of the radiological conditions of the area and the exposure status of the work crew is required."
Contrary to the above, on September 28, 1989, during FOSAR maintenance activities on the B-2 steam generator (a restricted area), adequate surveys were not performed to evaluate the radiation hazards present to assure compliance with 10 CFR 20.101 and RWP 16297, as evidenced by the following examples:
1.
for a period of approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, a contractor Radiological ~
Control Technician (RCT) (employed by General Technical Services) responsible for providing continuous radiological monitoring of the OFFICIAL RECORD COPY CP PKG BEAVER VALLEY 1/17/90 - 0006.0.0 01/18/90 9001250327 90011e e
PDR ADOCK 05000334 Q
FOSAR activity did not check the work crew's self-reading dosimeters to determine their dose accumulation or to determine if the rate of dose accumulation was consistent with the radiological conditions upon which the work crew's stay time was calculated; 2.
the RCT did not positively identify and monitor the individual workers in such a manner so as to ensure that he was able to assign correct stay times for the individual workers while their arms were in the B-2 steam generator handhole; and 3.
the RCT permitted the work crew members to exceed their calculated stay times established under.the controlling Radiation Work Permit (No. 16297) without reading their pocket dosimeters to determine if they had reached their assigned dose limits.
This violation has been categorized as a Severity Level III problem (Supplement IV).
II. VIOLATION OF OTHER REGULATORY REQUIREMENTS Technical Specification 6.11 (Radiation Safety Program) requires that
< procedures for personnel radiation protection be-prepared consistent with the requirements of 10 CFR Part 20 and shall be adhered to for all operations involving personnel radiation exposure.
1.
Radeon Procedure 8.1 (Radiological Work Permit) Section 3.3.2.11 states that Special Whole-Body / Extremity Monitoring Data (RCM i
Form 8.1, Sectiun 13) shall be initiated and completed as required to provide documentation of non-routine wearing of-whole-body exposure monitoring devices. This record documents the relocation of normal personnel whole body monitoring devices and/or the
-i wearing of multiple whol~e body devices at different body locations.
Contrary to the above, on September 28, 1989, Special Whole Body / Extremity Monitoring Data (RCM Form 8'1, Section 13) was not initiated and completed to provide documentation of non-routine wearing of whole body exposure-monitoring devices.
Specifically, under RWP No. 16297 (FOSAR), whole body monitoring devices were repositioned from the chest area to the arms of the workers and RCH Form 8.1, Section 13 was not initiated and completed as required.
2.
Radeon Procedure 8.1, Section 3.3.2.14 states that.a Preliminary ALARA Review (RCM Form 8.1, Section 16) shall be initiated and completed by-the work party supervisor when the ALARA initiation values listed on RCM Form 8.1, Section 12 are exceeded.
RCM 8.1, Section 12. states that ALARA Review is required if the man-rem estimate exceeds 200 mrem per worker or 1000 mrem for the work party.
Contrary to the above, Radiation Work Permit (RWP) 16266 (R7D Modification) dated September 5, 1989 and RWP 16272 (Chemical 1
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NT%./
,V Notice of Violation 3
l l
l Decontamination of A, B, and C Steam Generators) dated September 6, 1989, contained ALARA initiation values that exceed 200 mrem per worker or 1000 mrem for the work party, and the l.
Preliminary ALARA Reviews were not initiated and co'upleted by j
L the work party supervisor as required.
- 3..
Radeon Procedure 8.1, Section 2.6 states, in part, that all RWPs l
shall be updated to reflect changes or requirements.
)
i Contrary to the above, on September 26, 1989, RWP work packages were changed and the RWP's were not updated to reflect the changes, l
as evidenced by the following examples:
l 1
a.
RWP 16266 (RTD Modification) dated September S,1989, was not i
updated to reflect that workers were no: longer wearing arm and j
~
hand monitors; and b.
RWP 16272.(Chemical Decontamination of A, B, C Steam Generators) dated September 6, 1989, was not updated to reflect-that workers-were no longer wearing full face particulate respirators.
This violation.has been. categorized as a Severity Level IV problem (SupplementIV).
Pursuant to the provisions of 10 CFR 2.201, Duquesne. Light Company. is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a copy to the Regional Administrator, Region I within 30 days of the date of this Notice.
This reply should be clearly marked as~a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted,
-(3 the corrective steps that have been taken and-the results achieved, l
-(4 the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will=be achieved.
If an adequate.
reply is not received within the time specified in this Notice, an order may be i$ sued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.
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FOR THE NUCLEAR REGULATORY COMMISSION Original Signed By:
Thomas T. Martin 4
William T. Russell Regional Administrator
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Dated at King of Prussia, Pennsylvania.
this /f day of January 1990 0FFICIAL RECORD COPY CP PKG BEAVER-VALLEY 1/17/90 - 0003.0.0 01/18/90 I
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