ML20036A814
| ML20036A814 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 04/29/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20036A808 | List: |
| References | |
| 70-1151-93-02, 70-1151-93-2, NUDOCS 9305170040 | |
| Download: ML20036A814 (3) | |
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4 ENCLOSURE 1 NOTICE OF VIOLATION Westinghouse Electric Corporation Docket No.
70-1151 Commercial Nuclear Fuel Division License No..SNM-1107 During an NRC inspection conducted on March 1-5, 1993, and subsequent telecon discussions with members of your staff on March 31 and April 1,1993, violations of NRC requirements were identified.
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:
A.
License Condition Number 9 of Special Nuclear Material License No.1107 (SNM-1107) requires that licensed material be used in accordance with t
statements, representations, and conditions contained in Chapters 2, 3, and 4 of the Application dated March 26, 1984, and supplements and letters thereto.
Section 3.2.1.1 of the Application for License No. SNM-1107 requires.
that written procedures for radiation protection functions activities be prepared and followed.
1.
Section 3.2.2.2, of the Application for License No. SNM-1107 requires that access points to the Controlled Area be established through change rooms and step-off pads.
Each access point is to l
include a " hot" side and a " cold" side, with a step-off area provided between the hot and cold side.
t 2.
Section 3.2.2.3, requires that clean protective clothing be provided for personnel entering the Controlled Area in the form of coveralls, underwear, socks, labcoats, shoecovers, safety shoes, etc., consistent with the individual's work assignment.
Personnel clothing, for those dressing out in protective clothing, is stored on the cold side. Used protective clothing is stored on the hot side and collected there for laundering.
3.
Procedure RA-207, Radiation Work Permit, states that a Radiation Work Permit is required for all jobs where radiation protection -
requirements are not cclared by operating procedures when the-following condition is met:
release of contamination outside of 1
Contamination Controlled Areas is likely to exceed 220 dpm/100 cm.
2 Procedure RA-402, Radioactive Material Transfer From Manufacturing Building, states that postings are required on all outside buildings and trailers containing radio.' *ive materials and/or contaminated equipment. Trailers shall itsa be locked wisen not in use, with the key controlled by cognizarc personnel.
9305170040 930429 PDR-ADOCK 07001151 C
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i Westinghouse Electric Corporation 2
Docket No. 70-1151 Commercial Nuclear Fuel Division License No. SNM-1107 i
4.
Procedure RA-203, General Health Physics Rules and Recommenda-tions, states that personnel shall not drink (other than from water fountains) eat or smoke in chemical areas and laboratories.
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t Procedure RA-205, Respiratory Protection, states that users should always use clean respirators, and respirators are to be deposited in designated receptacles. Also, chemical canister filters which protect against fumes such as ammonia and acids must only be used once for protection against fumes.
l S.
Procedure R0-02-008, Survey of Incoming Shipments of Radioactive Materials, requirct a survey of incoming materials.
Precedure R0-05-014, Performing Contamination Survey of the Westinghouse Facility, requires that food preparation, eating and drinking areas be surveyed.
Procedure RA-207, Radiation Work Permit, establishes a procedure to identify the responsibilities of the parties concerned in the regulating, issuing and using a Radiation Work Permit.
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Contrary to the above, radiation protection activities were not followed in controlling radioactive contamination.
1.
On March 1, 1993, at or about 1:00 p.m., three entrances to the i
UNH Tank Area (a controlled area) were found without. step-off I
pads.
i 2.
On March 1, 1993, at or about 1:30 p.m., contaminated protective i
clothing was found stored on contaminated shelves adjacent to the entrance on the cold side of the UNH Tank Area (a. controlled area).
3.
On March 1,1993, at or about 3:30 p.m.,
a low level radwaste 6
storage trailer parked inside the truck bay on Loading. Dock #3 was found unlocked and open when not in use.
In addition, no RWP had h
been prepared and the activity was not covered by an operating procedure and the key was not controlled. The posting on the-trailer was hidden by the open door folded back against the side.
Contamination of approximately 3,000 cpm was found on the loading dock adjacent to the trailer.
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4.
On March 1, 1993, at or about 3:00 p.m., a used contaminated respirator was found on the third shelf of a storage cabinet in 1
the advanced waste water-treatment building with a carbonated beverage can and gum wrappers next to or in close proximity. This is a contaminated area.
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5.
During the week of. August 17-28, 1992, several examples of failure to. perform surveys of incoming shipments of radioactive material, inadequate surveys of food preparation, eating and drinking areas, i
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r Westinghouse Electric Corrm ation 3
Docket No.
70-1151 Commercial Nuclear Fuel Division License No.
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i and inadequate HP coverage for some work performed under radiation work permits (0SA item 92-04-30) were identified by record review.
This is a Severity Level IV violation (Supplement VI).
l B.
License Condition Number 9 of SNM-1107 requires that licensed material be used in accordance with statements, representations, and conditions i
contained in Chapters 2, 3, and 4 of the Application dated March 26,
' l 1984, and supplements and letters thereto.
i Section 3.2.1.1 of the Application for License No. SNM-1107 requires e
that written procedures for radiation protection functions activities be i
prepared and followed.
Procedure RA-102, Plant Inspection Program for Regulatory Compliance, l
reauires formalized radiation protection inspections be conducted in l
accordance with a written inspection plan.
Contrary to the above, the Radiation Protection Inspection Plan was not performed as required by the procedure nor were corrective actions adequately implemented. Radiation protection inspections in accordance with a written inspection plan had not been conducted during-the 1992 calendar year.
l This is a Severity Level IV violation (Supplement VI).
i Purscant to the provisions of 10 CFR 2.201, Westinghouse Electric Corporation is hereby required to. submit a written statement or explanation to the U.S.
i Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
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20555 with a copy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This.
reply should be clearly marked as a " Reply to a Notice of 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 corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may'be issued as to 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.
j Dated at Atlanta, Georgia this day of-1993 i
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