ML20009B145
| ML20009B145 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/22/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20009B132 | List: |
| References | |
| 50-293-80-05, 50-293-80-5, NUDOCS 8107140861 | |
| Download: ML20009B145 (5) | |
Text
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' APPENDIX B NOTICE OF' VIOLATION Boston Edison Company M/C Nuclear Docket No. 50-293 Boston, Massachusetts 02199 Based upon the results of the NRC appraisal conducted on January 28-February 8, 1980, 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.
A.
Technical Specification 6.13 "High Radiation Area" states, "In lieu of the
' control device' or ' alarm signal' required by paragraph 20.203(c)(2) of 10 j
CFR 20, an av:eptable alternate to controlling access to a high radiation i
area is as follows:
A.
Each High Radiation Area in which the intensity of radiation is greater than 100 mrem /hr but less than 1000 mrem /hr shall be bar-ricaded and conspicuously posted as a High Radiation Area and entrance thereto shall be controlled by issuance of a Radiation Work Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continu-cusly indicates the radiation dose in the area.
B.
Each High Radiation Area in which the intensity of radiation is greater than 1000 mrem /hr shall be subject to the provisions of 6.13.A above, and in addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Natch Engineer on duty."
Procedure No. 6.1-012. " Access to High Radiation Areas," Revision 4, states in part, in Section VI.B. " Areas greater than 1000 mrem /hr but less than 10,000 mrem /hr shall be locked as required by Technical Specification 6.13.B..The keys for these areas will be under the administrative control of the Watch Engineer and issued as follows:
3.
Six (6) master 'R' keys will be issued to HP personnel through the HP office...
7.
Prior to the end of each work day, all individual
'R' keys that have been issued will be returned to the HP office unless other-
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wise directed by HP supervisory personnel."
I 8107140861 000814
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PDR ADOCK 05000293 0
Appendix B 2
Contrary to the above requirements, the following instances were identified when high radiation areas were not-properly posted and barricaded and key control was not maintained:
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-1.
On February 1,1980, the contents of a two feet by four feet by sixteen feet wooden box (discarded Control Rod Drives) located in the i
Reactor Building truck lock 3roduced a radiation intensity of 1.2 R/hr when measured on contact wit1 the top surface of the box (potential gonad dose) and the area was not posted or barricaded as a High Radiation Area.
2 On February 5,1980, piping located above the Chemical Waste Filter Cell produced a radiation field over an extended area of 100-200 mrem /hr when measured at about eighteen inches from the pipe and the area was not posted as a High Radiation Area.
3.
During the period, January 1 through February 6,1980, there were eight instances, as documented in the Health Physics Office Log Book, in which master "R" keys to High Radiation Areas were unaccounted for.
In addition, there were thirteen instances identified in which room specific High Radiation Areas Keys were unaccounted for - as many as ten on two occasions.
B.
Technical Specification 6.11, " Radiation Protection Program," states, " Pro-cedures 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 No. 6.4-067, " Operation of Eberline RM-14 Radiation Monii.or,"
Revision 0, Attachment 1, states in part, "Frisker Station Directions,"...
Before leaving the area, check for contamination by using the Frisker as follows:
... 5.
Pass the (Frisker) probe over the body slowly...(frisk at least shoes, nostrils and hair).
Contrary to the above, on February 5,1980, two individuals were observed leaving the controlled area of the facility via the Health Physics Control Point (located outside HP office) on the 23' elevation of the Reactor Building without checking themselves (frisking) for contamination. Addi-tional instances were observed by the appraisal team in other areas of the plant when workers performed ir. adequate frisks (excessively fast) or frisking was not performed at all.
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' App:ndix B 3
C.
10 CFR 20.103, " Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas," states in part, in Section (b)(2),
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... precautionary procedures, such as increased surveillance, limitation of working times,... shall be used to maintain intake of radioact+ /e mate-rials by any iMividual within any period of seven consecutive cays as far below that intake of radioactive material that 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 concentration specified in Appendix B, Table 1, Column 1 as is reasonably achievable. Whenever the intake of radioactive material by an individual exceeds this 40-hour control measure, the licensee shall make such evaluations and take such actions as are necessary to assure against recurrence."
Contrary to the above, after six individuals had exceeded the 40-hour control measure on January 29, 1980, the licensee did not take such actions as necessary to assure against recurrence in that six other individuals later exceeded the 40-hour control measure on February 1, 4, 5 and 6, 1980.
D.
10 CFR 20.201, under the subpart, " Precautions and Procedures", " Surveys,"
states:
"(a) As used in the regulations in this part, ' survey' mears 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.
Whe'1 appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measure-ments of levels of radiation or concentrations of radioactive material present.
(b) Each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in... part (20)."
Contrary to the abcve, from January 1 through (about) January 30, 1980, an evaluation / survey was not made to determine compliance with 10 CFR 20.103(b)(2) as it pertains to maintaining the intake of radioactive material by an individual within any period of seven consecutive days below the 40-hour control measure in that the licensee's computer print-out listing indi-vidual MPC-hours was not reviewed and evaluated.
Consequently, a computer malfunction resulting in the incorrect listing of MPC-hours was not de-tected in a timely manner thereby partially contributing to certain indi-viduals having exceeded the 40-hour control measure.
E.
10 CFR 20.103(a)(3) states in part, "For purposes of determining compliance with the requirements of this section, the licensee shall use suitable measurements of concentrations of radioactive materials in a'r, for detec-ting and evaluating airborne radioactivity in restricted area...."
Appsndix B 4
Contrary to the above, on February 5, 1980, steam cleaning was observed being perfonned by an individual wearing a full face respirator in the hot machine shop,:on contaminated equipment which exhibited surface radioactive i
contaminatim as high as 260 mrem /br gamma and 3,400 mrads/hr beta, without suitable measurements of airborne radioactivity being made or used. An airborne radioactivity sampler was oberved to be located on a table at the opposite end of the machine shop, at a distance of 30-40 feet from the worker.
F.
" Radiation Protection Program," states, " Pro-cedures 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, Procedure No. 6.1-021, "MPC Hours Determination" was not prepared consistent with the requirements of Part 20, in that precau-tionary procedures were not prescribed, such as the use of prorass or other engineering controls, increased surveillance, limitations of working times or provisions for respiratory protective equipment to limit concentrations
-of radioactive material in air and limit intake by wrkers.
G.
10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures and Drawings,"
states, " Activities affecting quality shall be prescribed by documented in-structions, procedures or drawings, of a type appropriate to the circum-stances and shall be accomplished in accordance with these instructions, procedures or drawings."
Station Procedure No. 1.4.3, Revision 8 developed pursuant to the above, dated October 10, 1979, states in part, in Section D, " Combustibles result-ing from work activity must be controlled so to keep the combustible loading within any one area within acceptable limits regarding exposures to safety-related equipment systems and structures.
Precautions are as follows:
l.
All waste, debris, scrap, rags, oil spills or other combustibles re-sulting from work activity shall be removed from the area immediately following completion of the activity.
2.
All wood staging, clean and sailed anti-contamination clothing shall be removed from the area immediately after completion of the work activity...."
Additionally, Station Procedure No. 1.4.6, " Housekeeping," Revision 5, states in Section III.A.3, "It is the responsibility of all station per-sonnel to maintain a clean and orderly facility.
General housekeeping should be accomplished as a daily routine on an assigned basis."
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l Appendix B 5
Contrary to the above requirements, combustibles resulting from previous work activities completed at least one week prior to identification; were found in excessive amounts in the following areas of the plant:
1.
On February 5,1980, a pile of waste and debris (several wood planks, plastic bags filled with waste, mop handles, etc.)
approximately four feet by three feet by eight feet in size, was observed beneath a stairway (leading to the Condensor Bay) located in the area of the Radwaste Corridor. Station Procedure No.1.4.3 specifies that the Radwaste Corridor is a " safety-related" area.
2.
During the course of the appraisal, a large pile of plastic bags containing waste, used disposable protective clothing (booties) and debris were found inside the passageway leading to the Reactor Water Cleanup Pump Rooms.
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