ML20205J803

Notice of Violation from Insp on 961102-27.Violation Noted:Licensee Failed to Adequately Instruct Workers & Failed to Perform Adequate Radiological Surveys in Reactor Cavity & Fuel Transfer Cavity

ML20205J803
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/05/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205J796	List: IR 05000213/1996012 ML20205J793 ML20205J803
References
50-213-96-12, EA-96-496, NUDOCS 9904120203
Download: ML20205J803 (4)

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ENCLOSURE NOTICE OF VIOLATION Northeast Utilities Service Company Docket No. 50-213 l Connecticut Yankee Atomic Power Company License No. DPR-61 i Haddam Neck Plant EA.96-496 ]

During an NRC inspection conducted November 2-27,1996, violations of NRC requirements were identified. In accordance with the " General Statement of Polic d and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are set forth bek m A. 10 CFR 19.12(a) requires that all individuals who, in the course of their employment, are likely to receive in a year an occupational dose of 100 mrem, be kept informed of the storage, transfer, or use of radiation and/or radioactive materials and be informed ,

of precautions or procedures to minimize exposure. '

10 CFR 20.1501 requires licensecs to perform surveys as may be necessary to comply with 10 CFR Part 20, including the occupational exposure limits of 10 CFR 20.1201.

10 CFR 20.1C03 defines a survey as an evaluation of the radiological conditions and ,

potential hazards incident to, among other matters, the presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation or concentrations or quantities of radioactive material present.

Contrary to the above, on November 2,1996, the licensee faile'f to adequately instruct workers and failed to perform adequato radiological surveys in the reactor cavity ar d fuel transfer cavity, necessary to comply with the occupational exposure limits outlined in 10 CFR 20.1201, as evidenced by the following examples:

1. On November 2,1996, two individuals entered the reactor cavity and fuel transfer canal to perform inspections and housekeeping, and received a dose in excess of 100 mrem, and the individuals were not adequately informed of the presence of high lavels of removable radioactive contamination and radiation within the fuel transfer canal and were not adequately informed as to the precautions or procedures to minimize their occupational exposure. Specifically, the workers were not informed of the levels of removable radioactive scurface contamination (up to about 80 mrad /hr (beta) and up te about 30,000 dpin/100 cm2of removable alphs :sdioactive contamination), and the workers were not informed of an isolated hot spot on the floor of the transfer canal is'. ring up to 25 R/hr on contact (about 8 R/hr at waist level). Subsequenti srkers unknr'wingly collected, handled, and transported radioactive matena. ',debr' )

with contact radiation levels ranging from 20 R/hr to 60 R/hr. The debris was not surveyed as it was collected, handled or transported. Such surveys wore 9904120203 PDR 990405 O ADOCK 05000213 PDR

Enclosure 2 necessary and reasonable to ensure conformance with the occupational dose limits.

2. On November 2,1996, airborne radioactivity surveys were not adequate to detect high concentrations of airborne radioactivity within the fuel transfer canal as workers collected highly radioactive dry dirt-like debris therein. Such surveys were required because the areas traversed and worked in by the workers exhibited loose surface contamination levels measuring up to 80 mrad /hr (beta) centamination and up to 30,000 dpm/100 cm8.

3. On November 2,1996, airborne radioactivity surveys were not adequate to detect high concentrations of airborne radioactivity within the reactor cavity to support reactor stud hole cleaning. As a result, two individuals, likely to receive 100 millirem in a year, entered the reactor cavity at about 9:30 a.m. to clean two stud holes on the reactor and were not informed of high levels of airborne radioactivity within the reactor cavity. (01013)

B. Technical Specification 6.12.2 requires, in part, that areas accessible to personnel with radiation levels greater than 1000 mR/hr at 45 cm from the radiation source shall be provided with locked doors to prevent unauthorized entry and doors shall remain locked except during periods of access by personnel under an approved Radiation Work Permit (RWP) which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area.

Contrary to the above, on November 2,1996, personnel entered a locked High .

Radiation Area (reactor cavity and fuel transfer canal) with accessible dose rates l greater than 1000 mR/hr at 45 cm and the RWPs used for the entry did not specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. (01023)

C. Technical Specification 6.11 requires that 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.

Contrary to the above, on November 2,1996, radiation protection procedures were not adhered to, as evidenced by the following examples.

1. Radiation Protection Procedure RPM 2.5-4, requires in Stap 3.2 that radiological controls personnel shall, during the course of the job, check conditions at the job site to ensure instructions are being properly followed. However, on November 2,1996, radiological controls personnel did not provide adequate ]

health physics job coverage for personnel working in the fuel transfer canal in 1 accordance with procedure RPM 2.5-4, Step 3.2. Specifically, checks of l conditions at the job site were inadequate to ensure conformance with the

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4 Enclosure 3 understood work scope. Consequently, workers received an unplanned exposure as a result of the concentrations of airborne radioactivity that resulted from the work that they performed, and handled debris measuring between 20 R/hr and 60 R/hr on contact.

2. Radiation Protection Procedure RPM 2.1-1, requires in Step 3.1.6 that the job supervisor provide workers a description of the work to be performed.

However, on November 2,1996, the job supervisor, responsible'for inspection and housekeeping within the fuel transfer canal, did not provide health physics an adequate description of the work to be performed. Specifically, the job supervisor did not inform the health physics department that (1) excess grease found in the transfer canal would be used to grease dry bevel gears; (2) paint chips and associated metal rust would be peeled off the coffer dam walls; and (3) dry dirt-like loose debris would be vollected by hand from the canal floor and deposited into a plastic bag. (01033)

These violations are classified in the aggregate as a Severity Level U1 problem (Supplement IV)

The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violation and prevent recurrence and the date when full compliance will be achieved is already adequately addressed on the docket in NRC Inspection Report Nos. 50-213/97-01; 97-10; and 98-02, licensee letters dated March 7, 1997, and May 30,1997, in response to NRC Confirmatory Action Letter dated March 4, 1997, and Licensee Event Report (LER) 50-213/96-030, dated December 6,1996. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk. Washington, D.C. 20555 with a copy to the Regional Administrator, Region 1, within 30 de ys of the date of the letter transmitting this Notice of Violation (Notice).

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.

If you choose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent passible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

4 Enclosure 4 Under the ,.uthority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

In accordance with 10 CFR 19.11, you may be required to pcst this Notice within two working days.

Dated at King of Prussia, Pennsylvania this 5* day of April 1999 I

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