ML20041G552

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Notice of Violation from Insp on 770421-24,27-29 & 0502-04
ML20041G552
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 06/29/1977
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20041G550 List:
References
50-003-77-04, 50-247-77-11, 50-286-77-12, 50-3-77-4, NUDOCS 8203220511
Download: ML20041G552 (5)


Text

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License Nos. DPR-5 DPR-26 DPR;64 APPENDIX A NOTICE OF VIOLATION Based upon the results of the NRC inspection conducted April 21-24, April 27-29, and May 2-4, 1977, it appears that certain of your activ-ities were not conducted in full compliance with NRC regulations and the conditions of your license as indicated below.

These are Infractions.

Items A, B.2, B.3, C.2, C.4.b, C.5, and C.6 relate to license DPR-5.

Items B.1, B.2, C.1, C.2, C.3, C.4.a, and C.6 relate to license DPR-26.

Items B.2, C.2, and C.6 relate to license DPR-64.

A.

10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to comply with the regulatory requirements specified in 10 CFR Part 20.

Contrary to the above requirement, surveys to permit compliance with the posting provisions of 10 CFR 20.203(c)(1) and the control requirements of 10 CFR 20.203(c)(2) were not made in the Evaporator Bottoms Drumming Station in that on April 21, 1977, previously undetected radiation levels which would permit a major portion of the body to b'e exposed to as much as 150 mrem /hr were found by the inspector in an area that was neither posted nor provided with the required controls.

This item is recurrent in that items of this nature were found during inspections conducted in December 1975, April 1976, and October-November,1976.

B.

10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary to comply with the regulatory requirements specified in 10 CFR Part 20.

1.

Contrary to the above re with 10 CFR 20.103(a)(3)quirement, surveys to assure compliance were not made on April 21, 1977, in l

the Unit 2 Refueling Cavity when a worker wearing a full face-piece mask with supplied air was decontaninating the cavity floor which was contaminated to levels as high as 8,000,000 disintegrations per minute /100 square centimeters and air samples taken to determine airborne concentrations of radio-active material were not taken in the vicinity of the worker.

8203220511 770629 PDR ADOCK 05000003 G

PDR

Appendix A 2

2.

Contrary to the above requirement, on April 27, 1977, surveys adequate to assure compliance with 10 CFR 20.103(a) were not made in the laundry room for Units 1, 2, and 3 when a worker was observed using a wooden pole to fling contaminated pro-tective clothing over his shoulder while transferring the protective clothing from one laundry container to another, The protective clothing was contaminated with radioactive material producing radiation levels as high as 2 mrem /hr.

The air sampler in the laundry room was located in such a way that it did not sample air from the worker's breathing zone.

3.

Contrary to the above requirement, on April 28, 1977, surveys adequate to assure compliance with 10 CFR 20.103(a) were not made in the Unit 1 Drumming Station where workers were pre-paring drums for shipment.

The floor surface contamination levels in the area ranged from 8,000 to 15,000 disintegrations per minute /100 square centimeters as measured by the licensee.

The air sampler in the drumming station was located in.such a way that it did not sample air in the breathing zones of the workers.

This item is ' recurrent in that items of this nature were found during inspections conducted in December 1975, April 1976, and October-November, 1976.

~

C.

Unit 2 and 3 Technical Specification 6.11 and Unit 1 Technical Specification 3.2.6 require tha,t procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

1.

A procedure entitled, " Instructions to Personnel at the VC Control Point," was developed pursuant to Unit 2 Technical s

Specification 6.11.

Section II. A of the procedure states,

" ascertain that the individual knows his RWP number and that a copy is retained at the VC Control point.

An individual shall not be allowed access until a copy is obtained."

Contrary to the above requirement, on April 21,1977, the individual manning the Unit 2 Vapor Containment, (VC), Control point permitted approximately 92 entries to the VC by individuals who reported that they were working under the authorization of an RWP which his records indicated to have expired.

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N Appendix A 3

e 2.

Health Physics Procedure No.13, " Calibration of Health Physics Monitoring Instruments," dated June 27, 1975, requires that each instrument be calibrated at least every 100 days.

Contrary to the above, two direct reading dosimeters, out of a randomly selected sample of 17, numbers 105920 and 23534, were not calibrated within the required interval of 100 days.

3.

The procedure entitled " Steam Generator Primary Channel Head Work," was developed pursuant to Unit 2 Technical Specification 6.11.

Section 4.10 of the procedure specifies that continuous air monitors are to be used for immediate evacuation purposes.

Step 1 in Appendix A of the procedure specifies that if the continuous air monitor on the job shows an approximate 15000 counts per minute rise innediate evacuation of the channel head area is required.

Contrary to the above, on April 24, 1977, a. continuous air monitor was not used to monitor a Steam Generator entry moments before, in that it was found by the inspector to be inoperable because the air flow through the air filter was almost nonexistant and not sufficient to evaluate the presence of airborne radioactive material inside the Steam Generator where workers had been working.

4.

General Administrative Directive RS-GAD-2, Revision 1, " Radio-logical Health and Safety Procedures," dated February 24, 1975, developed pursuant to Unit 2 Technical Specification 6.11 and Unit 1 Technical Specification 3.2.6 requires that areas be roped off and contamination control instituted when removable contamination exceeds 1000 disintegrations per minute /100 square centimeters.

a.

Contrary to Unit 2 Technical Specification 6.11, on April 24, 1977, rope barriers on the 96' elevation of the Unit 2 Vapor Containment, used to designate a control point for a contaminated work area in which contamination levels exceeded 1000 disintegrations per minate/100 square centimeters due to work on a reactor coolant pump, were found lying on the floor.

In addition, the step off pad at the entrance to the area was torn in such a manner that instructions printed on it were not legible nor was l

it recognizable as a contamination control device.

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Appendix A 4

b.

Contrary to Unit 1 Technical Specification 3.2.6, on April 27,1977, the step off pad at the entrance to the Unit 1 Drumming Station within which contamination levels exceeded 1000 disintegrations per minute /100 square centimeters, was torn in such a way that it was not legible nor could it be recognized as a contamination control device.

5.

Station Administrative Directive RS-GAD-2, Revision 1, dated February 24, 1975, developed pursuant to Unit 1 Technical Specification 3.2.6, requires that protective clothing be worn by all personnel entering the controlled area as protection against skin contamination.

Secticn 3.3.4.1 of the procedure

~ 1sts the protective apparel necessary to perform work in the 4

controlled area.

Section 3.3.4.1 of the procedure specifically requires gloves for work in low and medium contamination areas.

Contrary to the above, on April 28, 1977, an individual was observed working in the Unit 1 Drumming Station, a contaminated area, without the required protective clothing (gloves).

6.

A procedure entitled, " Instructions for Security Room Guard,"

developed pursuant to Unit 1 Technical Soecification 3.2.6 and Units 2 and 3 Technical Specification 6.11 specifies that the security room guard; "(1) distribute film badges as requested by plant personnel, support groups, and contractors.

Film badges shall not be given to anyone other than the individual to whom the badge is issued.

If necessary request identifica-tion, (2) assure that all personnel exiting the controlled area have signed out properly."

a.

Contrary to the above, on April 28, 1977, the security room guard, responsible for issuing film badges to all personnel entering the controlled area, issued film badges to 3 contractor individuals who, he stated, he did not recognize, without requiring any identification in order to verify that the film badges issued to the indi-viduals were their assigned badges, b.

Contrary to the hbove requirement, during the period April 29 - May 2,1977, there were 57 instances when individuals exited from the controlled area and were not required to sign out.

O I

Appendix A 5

This item is recurrent in that similar items of this nature were found during inspections conducted in December 1975, April 1976, June 1976, and October-November,1976, O

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