ML20050C093
| ML20050C093 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/21/1976 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20050C088 | List: |
| References | |
| 50-003-76-05, 50-247-76-08, 50-247-76-8, 50-3-76-5, NUDOCS 8204080128 | |
| Download: ML20050C093 (5) | |
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APPENDIX A s
NOTICE OF VIOLATION License Nos. DPR-5 DPR-26 Docket Nos.50-003 50-247 Based on the results of an NRC inspection conducted on April 6-9, 1976, it appears that certain of your activities were not conducted in full compliance with NRC regulations and conditions of your License as indicated below:
1.
10 CFR 20.101(b) permits, in certain prescribed and restrictive circumstances, a whole body radiation exposure of en individual in a restricted area to no more than 3 rems per calendar quarter.
Contrary to the above, on April 5,1976, an individual in the 3eactor Vessel Sump Room, a restricted area, received a whole body radiation exposure of 10.06 rems.
This violation constituted an occurrence related to health and safety.
(Civil Penalty = $4,000) 2.
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. Also, Technical Specification 6.8.1 requires that written procedures and administrative policies shall be established, i=ple=ented and maintained that meet or exceed the require-ments and recommendations of Section 5.1 and 5.3 of ANSI N18.7 - 1972.
Contrary to the above, surveys adequate to assure compliance with the posting and control requirements of 10 CFR 20.203(c)(1) and to CFR 20.203(c)(2) and to assure compliance with the radiation exposure limits of 10 CFR 20.101 were not made in that on April 5, l
1976, unidentified radiation levels as high as 666 R/hr existed l
in areas accessible to personnel in the Reactor Vessel Sump Room.
Further, Section 5.3.2.5 of ANS1 N18.7 - 1972 requires that operating and maintenant2 procedures contain precautions to alert the individual performing the task to those situations in which important neasures should be taken early to protect personnel, including cautionary notes applicable to specific l
APPE!iDIX I KO l
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steps to be included in the main body of a procedure. Such pre-cautionary notes were not included in Maintenance Procedure No. 2/3 CM-RV1/2.4 entitled " Removal of Reactor Vessel Upper Internals and Closure Head." Had such notes been included to alert maintenance personnel that hazardous radiation levels would exist in withdrawing the incore thimbles, the excessiveIn exposure described in Item 1 above might have been avoided.
addition, although step 14 of Maintenance Procedure 2/3 CM-RV1/2.4 required a radiation survey, it was not timely in that such a survey should have been made at the beginning of and during withdrawal of the incore thimbles rather than after withdrawing the thimbles.
This viointion contributed to an occiterance related to health and safety.
(Civil Penalty = $5,000)
Technical Specification 6.11 requires that procedures for personnel 3.
radiation protection shall be prepared consistent with the require-ments of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. Pursuant Station Administrative Order (SAO) No. 105, to this requirement, Revision 3, " Work Permits," dated March 1, 1975, requires that work Permits (WPs) and Radiation Wdrk Permits (RWPs) be issued and speci-fies the procedural steps to be followed.
g Contrary to the above, SAO 105 was not adhered to on April 3, l
'1976, in that, (1) the Maintenance Foreman and the Health 076-2-204 for Physics Technician did not jointly present RWP the Reactor Vessel Sump Room to the Watch Foreman, which would have provided the opportunity for any required discussion of the work to be performed to assure that the job was properly planned.
(2) the Health Physics Technician did not enter RWP
, No. 076-2-204 on WP 24560 and initial the Wi signifying that (3) the job was prepared from a radiation saf aty standpoint, work Permit 24560 was issued by the Watch Foreman before he had received the required, completed RWP, (4) a complete job description, required to be attached to the RWP form and used as the basis for determining radiation safety requirements, was (5) the " Isolation and Protection Provided" section not supplied, of WP 24560 was not stamped with the words " Radiation Work Permit Required" and associated wording and spaces for signatures and APPENDIX I i
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dates, and (6) Work Pemit 24560 remained in effect beyond the work shift of the person to whom it was issued and work was continued the following shift; however, neither the person to whom it was issued nor his relief signed and dated the reverse side of the WP under a heading " Transfer of Work Pemit" to indicate that they had discussed the work together and with the Watch Forman or Genera.1 Watch Foreman, as required. Further it was also noted that SAO 105 was not adhered to on March 31, 1976, in that RWP No. 076-2-149 was issued by an Outage Coordi-nator, a person not authorized to issue RWPs.
This violation contributed to an occurrence related to health and safety.
(Civil Penalty = $5,000) 4.
Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the require-ments of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
This item is an infraction.
4 a.
Pursuant to the above requirement, Station Administrative Order No.105, Revision 3, " Work Pemit," dated March 1,1975, requires that Work Pemits (WPs) and Radiation Work Permits (RWPs) be. issued and followed.
Contrary to the above, SAO 105 was not adhered to on April 9, 1976, in that individuals worked in the Reactor Cavity without the protective equipment (respirators) required by RWP 076-2-45, and individuals worked on the 95' elevation of the Vapor Contain-ment without the prctective equipment (gloves) required by RWP l
076-2-87.
(Civil Penalty $1,000) b.
Pursuant to the above requirement, revised Controlled Area Sign-In Procedure, effective November 11, 1975, requires certain types l
of information to be entered on the sign-in sheet by individuals entering or leaving the Controlled Area.
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Appendix A MId 2 k S6 Contrary to the above, during the period of April 2-5, 1976, there were more than 60 instances wherein individuals failed to log the number of the RWP under which they were entering the Controlled Area.
(Civil Penalty - $1,000) c.
Pursuant to the above requirements, General Administrative Directive RS-GAD-2, Revision 1, " Radiological Health and Safety Procedures,"
dated February 24, 1975, requires that areas be roped off and contamination control instituted when removable radioactive contamina-tion exceeds,1,000 dpm per 100 square centimeters.
Contrary to the above, the waste evaporation room of the unit 2 PAB, an area containing removable radioactive contamination in excess of the above specified limit, was not roped off and contamination controls were not instituted.
(Civil Penalty - $1,000) 5.
10 CFR 20.203(c)(2) requires that high radiation areas established for more than 30 days be equipped with control devices to reduce the level of radiation upon entry into the area, or be equipped.
with control devices to energize conspicuous visible or audiole g
alarm signals upon entry into the area, or be maintained locked except during periods when access is required, with positive control over each individual entry.
Contrary to the above, en April 9,1976, six high radiation areas in the Unit 2 PAB and one high radiation area in the Unit 1 PAB estab-lished for more than 30 days were not equipped with the specified i
l control device and were unlocked and unattended with no positive
. control maintained over each individual entry. Further, positive control was not maintained over other locked high radiation areas in the Unit 2 PAB in that at least one employee, not authorized to enter such areas, had a master key in his possession and could unlock and enter the high radiation areas without the authorization of plant management.
This is an infraction l
(Civil Penalty - $3,000) l 6.
10 CFR 20.203(c)(1) requires that each high radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words, " Caution - High Radiation Area."
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4 Appendix A - 'jW 2 PM Contrary to the above, high radiation areas accessible to personnel inside the containment were not properly posted in that (1) on March 31, 1976, the Readter Vessel Sump Room had radiation levels up tk 150 mR/hr and was not posted as a high radiation area, (2) on April 9,1976, the RHR Heat Exchanger Room had radiation levels up to 200 mR/hr and was improperly posted as a radiation area with a> notation that the radia-tion field was 100-150 mR/hr, and (3) an April' 9,1976, the area around the letdown valves had radiation lev:1s up to 150 mR/hr and was impro-perly posed as a radiation area with a notation that the radiation field was 150 mR/hr.
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This is an infraction.
(Civil Penalty = $3,000) 7.
10 CFR 20.203(b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words, " Caution - Radiation Area."'
Contrary to the above on April 9,1976, a corridor accessible to I
personnel at t>.e 15 foot level in the Unit 2 PAB connecting the sump pump and, tack rooms with the No. 21 and 22 RHR pump rooms had field radiation levels wherein an individual could receive a radiation dose of-up to 20 mrem in any one hour and was not posted as a radiatien area.
This is a deficiency.
(Civil Penalty - None)
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