ML20002C779
| ML20002C779 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/05/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20002C772 | List: |
| References | |
| 50-302-80-25, NUDOCS 8101100848 | |
| Download: ML20002C779 (4) | |
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O SEP 81990 APPENDIY B NOTICE OF VIOLATION Florida Power Corporation License No. DPR-72 Crystal River Unit 3 Based on the hTC inspection conducted June 16-27, 1980, certain of your activities were apparently not conducted in full compliance with h7C requirements as indicated below. These items have been categorized as described in correspondence to you dated December 31, 1974.
A.
As required by Technical Specification 6.11, " Procedures for persot.nel radiation protection shall be prepared consistent with the reqairements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure."
Radiological Control Procedure RP-102, Revision 9, entitled " Respiratory Equipment Manual states:
(1) in Section 4, that "the training program shall, as a minimum, cc.fer the following:
g.
Discussion of the application of various cartridges and canisters available for air-purifying respirators...
j.
Classroom and field training to recognize and cope with emergency situations.
k.
Familiarization with plant respiratory protection devices...";
(2) in Section 4, that "The training required for use of respiratory pro-tective devices will be conducted by a member of the ChemRad Section";
(3) in Section 5.1.4, that "The ChemRad Section will maintain a record of all individuals placed on the respiratory protection program, the particular type respirator that best fits the individual, and the alternate respirator.";
(4) in Sect.f on 8.2.1.2, that " Testing will be carefully supervised and/or performed enly by responsible and thoroughly trained individuals.";
(5) in Section 8.2.2.3, that "All repairs on respiratory protective devices will be performed by personnel who are thoroughly familiar with the device and instructed in the type of repair to be performed.";
(6) in Section 8.5.2, that "In no case will a contaminated respiratory protective device be returned for reissue or use.";
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SEP 8 980 1
Florida Power Corporation Appendix B License No. DPR-72 Notice of Violation (7) in Section 8.3.1, that "Each respirator will be washed and disinfected at the conclusion of use."; and (8) in Enclosure 5, note b, that the protection factors apply "Only for shaved faces and where nothing interferes with the seal of tight-fitting face pieces against the skin.".
Contrary to the above, (1) the training program which was conducted on June 16, 1980, did not include discussions of the types of cannisters available, field training for emergencies, familiarization with plant nor devices; (2) respiratory protection training conducted on June 16, 1980, was not conducted by a member of the ChemRad Section; (3) records of the respiratory protection program did not have training, fit or medical examina-tion dates specified; (4) a tester administering a fit test on June 17, 1980, had not been trained; (5) repairs on respirators were being performed on June 24, 1980, by individuals who wer' not trained nor instructed; (6) five randomly selected ready for issuance respirators were surveyed on June 18, 1980, and found to exceed the contamination limit for the facility; (7) for the period June 16 through June 27, 1980, no disinfectant for respirators was being used; and, (8) on June 16 and 18, 1980, workers were observed with respirators worn over protective clothing and the protective clothing interfered with the facial seal.
This is an infraction.
B.
As required by 10 CFR 20.103.c, "When respiratory protective equipment is used to limit the inhalation of airborne radioactive material, the licensee may make allowances for such use in estimating exposures of individuals to such materials provided that such equipment is used as stipulated in Regula-tory Guide 8.15, " Acceptable Programs for Respiratory Protection." Regulatory Guide 8.15 section 4.f requires: " Bioassays and other surveys, as appropriate, to evaluate individual exposures and to assess protection actually provided";
and section 4.h requires: " Determination prior to assignment of any individual to tasks requiring the use of respirators that such an individual is physically able to perform the work and use the respiratory protective equipment. A physician is to determine what health and physical conditions are pertinent.
The medical status of each respirator user is to be reviewed at least annually."
Contrary to the above, on June 21,1980, (a) the issuance records for respir-ators indicated at least three individuals who had not been medically examined in the past 15 months and one individual who had not bden medically examined for respirator use in the past two years, and, (b) the respiratory program does not require termination whole body counts for anyone, nor does it require commencement whole body count for visitors.
This is an infraction.
SEF - E EE2 Florida Power Corporation Appendix B License No. DPR-72 Notice of Violation C.
As required by Technical Specification 6.12.1.a, entrance to a High ladiation Area "shall be controlled by issuance of a Radiation Work Permit and any in-dividual 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, on June 16, 1980, two workers entered a High Radiation Area in the vicinity of the Reactor vessel flange during the Icwering of the vessel head without a survey instrument, and on June 20, 1980, one worker entered a high radiation area in the " backyard" near the Chem-Nuclear trailer without a dose rate survey instrument.
This is an infraction.
D.
As required by Technical Specification 6.4.1, a retraining program for the facility staff shall be maintained and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971. Section 5.5 of ANSI N18.1 states that a training program shall be established which maintains the proficiency of the operating organization.
Contrary to the above, the licensee did not have a formal retraining program which maintained the proficiency of the health physics technicians.
This is an infraction.
E.
As required by 10 CFR 20.203.c.1, each high radiation area shall be conspic-uously posted with a sign or signs bearing the radiation caution symbol and the words: " cab 7 ION - HIGH RADIATION AREA".
Contrary to the above, on June 18, 1980, a High Radiation Area was not con-spicuously posted in the containment near the reactor vessel head storage stand. Levels of 2.2 rem per hour on contact with a vacuum cleaner. and 150 1
millirem per hour at 18 inches from the vacuum cleaner were measured. In addition, 100 millirem per was measured hour at 18 inches from a shielded motor tube housing. Workers in the area were not aware of these dose rate I
levels.
This is an infraction.
F.
As required by 10 CFR 20.201, "Each licensee shall make or cause to be made l
such surveys as may be necessary for him to comply with the regulations in this part".
10 CFR 20.103.c. states "the licensee shall use suitable sea-surements of concentrations of radioactive materials in air for detecting i
and evaluating airborne radioactivity in restricted areas...".
Contrary to the above, on June 19, 1980, no airborne radioactivity survey was taken in the breathing zone of three people working in the vicinity of the reactor vessel head bolts.
Surface contamination levels in the area provided potential for significant airborne radioactivity.
Respirators were worn.
l This is an infraction.
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Florida Power Corporation Appendix B License No. DPR-72 Notice of Violation G.
As required by 10 CFR 20.203.b, "Each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: " CAUTION - RADIATION AREA".
Contrary to the above., the following radiation areas were not conspicuously posted:
a.
On June 23, 1980, an open LSA box in the compactor room read 30 millirem per hour at 18 inches.
b.
On June 25, 1980, a general area level of 25 millirem per hour was measured outside the compactor room and the room was unmarked. The area sign was discovered under debris.
c.
On June 25, 1980, a general area Itvel of 15 millirem per hour was measured in the safeguards area pipe gallery at the 95 foot elevation.
This is an infraction.
H.
As required in part by 10 CFR 20.102.b, "Before permitting any individual in a restricted area to receive an occupational radiation dose in excess of the standards specified in 20.101(a), each licensee shall:
Calculate on Form NRC-4 in accordance with the instructions appearing herein, or on a clear and legible record containing all the information required in that form, the previously accuuulated occupational dose received by the individual and the additional dose allowed for that individual under 20.101(b).
Contrary to the above, two workers with incomplete Form NRC-4's were autho-rized by dosin ?try control printout to exceed 1.25 rem per quarter and one of the workert actually received a dose in excess of this limit (1,274 millirem based 4n pocket dosimeter readings).
This is an infraction.
I.
As required by Technical Specification 6.1? " 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."
Procedure RP-213,
" Pocket Dosimeter Functional Check", states in section 2.1.1 that "The various dosimeters will be calibration checked on a rotational basis at six month intervals or at such times as there is reasonable doubt as to the authenticity of the dosimeter's performance. The cycling for calibration purposes shall be such that an operating supply of dosimeters is readily available at all tin es."
Contrary to the above, on June 25, 1980, the calibration program as prac-ticed actually calibrated approximately annually. For example a review of records indicated pocket dosimeterc 007 and 581 were last calibrated on February 8,1979.
This is an infraction.
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