ML20195F981

Notice of Violation from Insp on 880906-09 & 23.Violations Noted:Inadequate Survey Performed as Evidenced by Set of Coveralls Having Measurable Contamination Being Discovered on Coat Rack

ML20195F981
Person / Time
Site:	Framatome ANP Richland
Issue date:	11/18/1988
From:	Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195F979	List: ML20195F975 ML20195F981 ML20195F984
References
70-1257-88-08, 70-1257-88-8, NUDOCS 8811220470
Download: ML20195F981 (2)

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. APPENDIX A NOTICE OF VIOLATION Advanced Nuciear Fuels, Inc. Docket No. 70-1257 2101 Horn Rapids Road License No. SNM-1227 P. O. Box 130 Richland, Washington 99332 During an NRC inspection conducted September 6-9 and September 22, 1988, certain 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 (1988), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the violations are listed below:

A. Paragraph 20.201(b) requires licensees "to make such surveys as ... are reasonable ... to evaluate the extent of radiation hazards that may be present." Condition 9 of License No. SNM-1227 requires that licensed material be used in accordance with Part I of the application dated July 1987. Part I of that application, Section 3.1.2, states that "Radiation Work Procedures ... establish the radiological safety requirements of all work ... involving radiation and/or radioactive materials." Radiation Work Procedure ANF-P91,001, "General Facility Radiation Work Procedure,"

Section 5, states that "Protective clothing (coveralls and lab coats) shown to be clean by surveys (not shoe ccvers or gloves) arc allowed in intermediate areas (boundaries identified by yellow and green tape on floor)."

Contrary to the above, on at least one occasion, an inadequate survey was performed, as evidenced by a set of coveralls having measurable contamination being discovered on a coat rack in the intermediate area outside the gadolinium scrap recovery area. During a September 7, 1988 tour of the area, a survey of the coveralls on the coat rack outside the gaoolinium scrap recovery area disclosed contamination levels of 46,000 disintegrations per minute (dpm) surface and 9,000 dpm removable.

This is a Severity Level IV Violation (Supplement VI).

B. Condition 9 of License No. SNM-1227 authorizes the use of licensed materials in accordance with the statements, representations, and conditions of Part I of the application dated July 1987. Part I of the application. Section 3.2.6.2, Item 1.C., states that "cloth protective clothing is not reused if the contamination exceeds 1000 dpm/100 cm2 alpha."

Contrary to the above, licensee's Work Procedure ANF-P91,018 establishes a reu e limit of 5000 cpm using a HP-260 survey probe, which is equivalent to approximately 30,000 dpm alpha. A licensee employee confirmed that the licensee used this procedure to permit the reuse of clotn protective clothing with count rites of up to 5000 dpm.

This is a Severity Level IV Violation (Supplement VI).

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Pursuant to the provisions of 10 CFR 2.201, Advanced Nuclear Fuels, Inc. is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission Region V,1450 Maria Lane, Suite 210, Walnut Creek, CA 94596, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly narked as a "Reply to a Notice of Violation" and should incluta for each violation * (1) the reason for the violation if admitted, (1) 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 may be issued to 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. Consideration may be given to extending the response time for good cause shown.

FOR THE NUCLEAR REGULATORY COMMISSION a_,- 9 Dated at Walnut Creek, California G b /J k b L t hi s (5_* day o f bo.d-c i., 1988 G. P. Yuhas, Chi-f Emergency P eparedness and Rad 1ological Prote: tion Branch