ML20035H555

Notice of Violation from Insp on Stated Date.Violation Noted:Determined That Director for Radiological Programs Did Not Have 3 Yrs of Professional Experience in Applied Radiation Protection Work

ML20035H555
Person / Time
Site:	River Bend
Issue date:	04/30/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20035H551	List: ML20035H550 ML20035H555 ML20035H559
References
50-458-93-12, NUDOCS 9305050261
Download: ML20035H555 (3)

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APPENDIX A NOTICE OF VIOLATION j

Gulf States Utilities Docket:

50-458 l

River Bend Station License: NPF-47 During an NRC inspection conducted March 29 through April 2, 1993, violations of NRC requirements were identified.

These violations involved a failure of the Director-Radiological Programs to have the proper qualifications, a failure to post a high radiation area, and a failure to perform appropriate

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radiation surveys.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

I A.

Technical Specification 6.3.1 states, in part, that each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for comparable positions, except for the Director-Radiological Programs who shall meet or exceed the l

qualifications of Regulatory Guide 1.8, September 1975.

l Regulatory Guide 1.8, September 1975, states, in part, that the Radiation Protection Manager should be an experienced professional in

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applied radiation protection at nuclear facilities dealing with J_

radiation protection problems and programs similar to those at nuclear j

power stations. The Radiation Protection Manager should have a Bachelor l

Degree or the equivalent in a science or engineering subject, including j

some formal training in radiation protection.

The Radiation Protection Manager should have at least 5 years of professional experience in t

applied radiation protection, and at least 3 years of this professional i

l experience should be in applied radiation protection work in a nuclear l

facility dealing with radiological problems similar to those encountered in nuclear power stations, preferably in an actual power station.

j Contrary to the above, the inspectors determined that the new I

L Director-Radiological Programs did not meet or exceed the qualifications

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of Regulatory Guide 1.8, September 1975. The Director-Radiological Programs did not have 3 years of professional experience in applied radiation protection work in a nuclear facility dealing with 4

radiological problems similar to those encountered in nuclear power l

stations.

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This is a Severity Level IV violation (Supplement IV) (458/9312-01).

j The licensee responded to the matter involving a qualified Radiation Protection Manager in a memorandum dated April 15, 1993. The licensee's memorandum identified an individual that satisfies Technical l

Specification 6.3.1 to serve as the Radiation Protection Manager through l

Refuel Outage RF-6.

Therefore, no response to this violation is i

required.

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, l B.

Technical Specification 6.8.1 a. states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Section 7.e.(1) of Appendix A states, in part, that there should be i

written radiation protection procedures that cover access control to j

radiation areas.

Procedure RPP-0005, Revision 9B, " Posting of Radiologically Controlled Areas," Section 7.3.2.2.a. and b. states, in part, that to post to restrict access to a High Radiation Area the RP technician will post the l

area such that the area is completely enclosed by a physical barrier and i

place signs bearing the radiation symbol and the words " CAUTION" or "HIGH RADIATION AREA" on all sides of the barrier to form a conspicuous boundary.

Contrary to the above, on March 31, 1993, the licensee did not post a i

High Radiation Area such that the area was completely enclosed by a physical barrier.

Specifically, the inspectors discovered a scaffold in i

the 106-foot elevation of the radwaste building that could have been used to gain entry into a high radiation area that was.not posted to restrict access to the area.

l This is a Severity Level IV violation (Supplement IV) (458/9312-02).

1 C.

10 CFR 20.203(f) requires that each container of licensed material shall bear a label identifying the radioactive contents. The label shall also provide sufficient information to permit individuals handling the containers or working in the vicinity to take precautions to avoid or minimize exposures.

Contrary to the above, on March 30 and April 1,1993, the inspectors l

found two bags containing radioactive material that had not been i

labeled. One bag contained quick disconnects that had 3,000 dpm fixed i

contamination. The other contained an oil absorbent pad that had radiation levels of 25 mrad /hr of beta radiation and 26 mR/hr of gamma radiation on contact. Neither bag was labeled to provide information to permit individuals to take precautions to avoid or minimize exposures.

This is a Severity Level IV violation (Supplement IV) (458/9312-03).

I Pursuant to the provisions of 10 CFR 2.201, Gulf States Utilities is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATIN: Document Control Desk, Washington, D.C. 20555 l

with a copy to the Regional Administrator, Region IV, and a copy to the NRC

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Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation i

(Notice). This reply should be clearly marked as a " Reply to a Notice of l

Violation" and should include for each violation:

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the

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~3-l corrective steps that will be taken to avoid further violations, and (4) the

-l date when full ' compliance will be achieved.

If an adequate reply is not received within the time specified by this Notice, an order may be issued to i

i 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.

Where good cause is shown, consideration will be given to extending the response time. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall i

be submitted under oath or affirmation.

Dated at Arlington, Texas this 30th day of April 1993 I

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