ML20005B245
| ML20005B245 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/06/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005B242 | List: |
| References | |
| 50-320-80-18, NUDOCS 8107070008 | |
| Download: ML20005B245 (2) | |
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APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-32'0 Based on the results of an NRC inspection conducted on October 7,1980, and November 18-24, 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC facility license No. DPR-73 as indicated below. These items are categorized as Infractions.
A.
10 CFR 19.12 " Instructions to Workers" states in part:
"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...."
Contrary to the above, on October 6,1980, personnel entering the Three Mile Island Unit 2 fuel handling building north make-up valve room were not informed of high beta radiation fields associated with leaking valves of the make-up system. Also, personnel were not instructed on which areas in the make-up valve room should be avoided due to existing high beta and gamma radiation fields.
B.
10 CFR 20.201(b) states:
"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."
Contrary to the above, on October 6, 1980, beta radiation surveys, adequate to assure compliance with the regulatory limits of 10 CFR 20.101, were nc?, performed by personnel entering the Three Mile Island Unit 2 fuel handling building north make-up valve room.
C.
The Order of Modification of License, dated July 20, 1979, as amended by the Order, dated February 11, 1980, states in part:
...Pending further amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with the requirements set forth in Attachment 1...."
(Proposed Technical Specification, Appendix A to License No. DPR-73).
The proposed Technical Specification 6.8.1.f requires in part:
" Written procedures shall be... implemented... covering...the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978." Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978 includes in Section 7 " Access Control to Radiation Areas Including a Radiation Work Permit System". Unit 2 Health Physics Procedure (HPP) 1613, Revision 11, August 15, 1980, Radiation Work Permits (RWP), paragraph 5.0 states:
"An RWP is required for any work which would encounter radiation or radioactive materials in excess of the following guidelines:.. 5 mR/hr....An RWP will be terminated if conditions in the area degrade significantly from the conditions on the original RWP or if the time designated on the RWP 8107070000 81050 PDR ADOCK 05000 G
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2 expires. The RWP may be modified based upon surveys made after the RWP was prepared.
Changes to RWP's must be approved and reflected on all copies of the RWP by Radiological Controls Field Operations Supervisor / Foreman or the Shift Supervisor or their designees."
Cor.trary to the above requirement, on October 6, 1980, personnel entered the north make-up valve room under RWP 8C2-5194 and entered areas with significantly higher radiation levels than stated on the RWP.
One of the individuals entered the south valve room which was not authorized by the RWP.
Changes to the RWP were not made and approved as required, prior to personnel entry into the south make-up valve room, or prior to personnel entry into higher radiation levels than those specified on the RWP for entry into the north make-up valve room.
D.
10 CFR 50, Appendix B. Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion V, " Instructions, procedures, and drawings" states, in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings." The accepted Quality Assurance Program (QAP),
Section 17.2.10 (Table 17.2-2) lists health physics procedures as procedures used to implement the QAP.
Contrary to the above, as of October 6, 1980, certain of the Radiological Controls Department's requirements for entry to a certain group of high radiation areas were not prescribed by documented instructions or procedures. These requirements included ottaining the radiological controls manager's approval for entry and performing as As Low As Reasonably Achievable (ALARA) review priar to entry. The areas to which the entry requirements applied were also not prescribed in documented instructions or procedures.
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