ML20199G676

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Notice of Violation from Insp on 971201-16.Violation Noted: as of 971211,licensee Health Physics Supervisors Failed to Identify & Correct Personnel Contamination Repts That Were Not Completed IAW Requirements of Procedure HPP-104
ML20199G676
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/16/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199G643 List:
References
50-302-97-20, NUDOCS 9802040324
Download: ML20199G676 (4)


Text

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NOTICE OF VIOLATION Florica Power Corporation Docket No. 50-302 Crystal River, Unit 3 License No.

OPR-72

.I During an NRC inspection conducted on December 1 to December 16, 1997,

_ violations of,NRC_ requirements were identified, In accordance with the

" General Statement of Policy and-Procedures for NRC Enforcement Actions,"

NUREG-1600,.the violations are listed below:

- A'.

Technical Specification 5.6.1 requires that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A. Regulatory Guide 1.33. Quality Assurance Program Requirements (Operation), Revision 2, February 1978. Appendix A paragraph 7.e specifies procedures for contamination control.

. Licensee Administrative Instruction (AI)-400C, New Procedures and Procedure Change Process, Revision 22, dated July, - 28, 1997 Procedure Review Checklist, step 21, required that procedures provide the instructional;information necessary for individuals to perform the activity without direct supervision.

Contrary to the above, as of December 11. 1997, the licensee had failed-to provide adequate instructional-information necessary for documenting personnel contaminations. Specifically. Procedure HPP-104, Personnel Monitoring and Decontamination, Revision 13. dated June 2,1997, included contradictory cnd confusing instructions for-documenting personnel contamination events.

.This= is a severity level IV violation (Supplement IV).

B.

Technical Specification 5.6.1 requires that written' procedures _be established. implemented, and maintained covering the activities

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recommended in Appendix A. Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation) Revision 2. February 1978.

Appendix A paragraph 7.e specifies procedures for contamination control.

Licensee Procedure HPP-104. Personnel Monitoring and Decorcamination.

Revision 13. dated June 13, 1997. required the contaminatad worker to complete and sign the Event Description portion of the Pecsonnel Clothing / Skin Contamination form.

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PDR

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2 Licensee Procedure HPP 104. Personnel Monitoring and Decontamination.

Revision 12. dated February 20, 1996 and Revision 13. dated June 13.

1997 required the Personnel Clothing / Skin Contamination form or equivalent should be completed for personnel contaminations greater than 100 counts per minute / area under the probe beta gamma contamination as i

directed by the Health Physics Supervisor.

Licensee Procedure HPP-104. Personnel Monitoring and Decontamination.

Revision 13. dated June 13. 1997, required Health Physics Supervision be responsible for rt. viewing the records of personnel contaminations for applicability with regards to personnel exposure evaluations and I

3 docunentation.

Contrary to the above, those procedures were not followed as evidenced by the following examples:

1.

As of December 11. 1997. NRC found thirteen examples wherein 4

licensee personnel were not completing all sections of personnel contamination forms in accordance with the requirements of Procedure HPP 104.

2.

During the period of January 1. 1997 and April 29, 1997, licensee personnel failed to complete personnel contamination reports in accordance with procedure requirements.

Specifically, on at least six occasions licensee personnel fail'd to use the correct forms for documenting personnel contamination events.

3.

As of December 11, 1997, licensee Health Physics supervisors failed to identify and correct personnel contamination reports that were not completed in accordance with the requirements of Procedure HPP-104.

This is a sescrity level IV violation (Supplement IV).

C.-

Technical Specification 5.5.1 requires that written procedures be established. implemented, and maintained covering the activities recommended in Appendix A. Regulatory Guide 1.33. Quality Assurance Program Requirements (Operation) Revision 2. February 1978. Appendix A paragraph 7,e specifies procedures for contamination control.

).

3 Radiation Safety Procedure 101, Basic Radioiogical Safety Information and Instructions for Radiation Workers, Revision 24 dated July, 9, 1997, required Florida Power Corporation supervision be responsible for assuring all individuals under their direction are oware of and comply

,l with applicable radiological controls and radiological safety instructions, procedures, guidelines, good practices, and policies.

Section 4.9 provided radiation workers guidance on removing protective clothing. The procedure required each item of used protective clothing be carefully deposited in the appropriate receptacle (i.e. waste items in waste receptacles and reusable items in receptacles designated as such).

Contrary to the above, on December 9, 1997, licensee radiation workers failed to deposit used protective clothing carefully in receptacles.

Specifically, NRC observed workers throwing used protective clothing at an overfilled receptacle outside of a contaminated area causing potentially contaminated protective clothing to spill on to a clean area.

This is a severity level IV vic htion (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Florida Power Corporation is hereby required to submit a written statement or aplanation to the U.S. Nuclear Regulatory Commission. ATTN:

Document Control Desk. Washington, D.C. 20555 with a copy to the Regienal Administrator, Reginn II, and a copy to the NRC Resident-Inspector at the Crystal River 3 facility, 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 iriclude for each violation; (1) the reasan 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 wili be achieved.

Your response may reference or include previous docketed correspondence if the correspondence adequately addresses the required response.

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.

If. you_ contest this enforcement action. you should also provide a copy of your response to the Director Office of Enforcement. United States Nuclear Regulatory Commission, Washington. DC 20555-0001.

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4 Because your response will be placed in the NRC Public Document Room (PDR), to i

the extent possible, it should not include any personal privacy, proprietary, i

or safeguards information so that it can be placed in the PDR without redaction.

If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information.

If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your c1 dim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for witnholding confidential commercial or f rancial information).

If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21, 4

Dated at Atlanta, Georgia j

this 16th day of Jaunaury 1998 i

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