ML20210R670

Notice of Violation from Insp on 970714-18 & 27-28. Violations Noted:Licensee Did Not Make Surveys to Assure Compliance with 10CFR20.1201(a) Which Limits Radiation Exposure to Skin

ML20210R670
Person / Time
Site:	Clinton
Issue date:	08/25/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210R607	List: IR 05000461/1997017 ML20210R601 ML20210R670
References
50-461-97-17, NUDOCS 9709030211
Download: ML20210R670 (3)

Text

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NOTICE OF VIOLATION ,

Illinois Power Company Docket No. 50-461

~ Clinton Station License No. NPF 6 During an NRC inspection completed on July 28,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,' NUREG 1600, the violations are listed below:

1. 10 CFR 29.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive mater!al or other sources of radiation.

Contrary to the above, on June 18,1997, the licensee did not make surveys to assure compliance with 10 CFR 20.1201(a), which limits radiation exposure to the skin. Spec'ifically, the licensee did not adequately identify or quantify licensed radioactive material on the arm of an individual who alarmed a personnel contamination monitor and was released from the restricted area.

This is a Severity Level IV violation (Supplement IV).

2. Technical Specification 5.4.1 requires, in part, that written procedures be established, implemented, and maintained covering the applicable procedres recommended in Regulatory Guide (RG) 1.33, Appendix A, Revision 2 (February 1978).

RG 1.33, Appendix A recommends that radiation protection procedures be implemented which address personnel monitoring and that chemistry procedures be developed which address sample collection and analysis, and instrument pen ormance,

a. Step 2.1.1 of procedure no. CPS 8801.60 (revision (rev. 23) " Gamma 10, Portal Calibration Test," which provides the instructions for the calibration of personnel contamination monitors, states that the monitors be calibrated at least once every 12 months,

b. Step 2.1.1 of procedure no. CPS 8801.62 (rev. 37), "Personnal Contamination Monitor (PCM18) Functional Calibration Test," which provides the instructions for the calibration of personnel contamination monitors, states that the monitors be calibrated at least once every 12 months.

9709030211 970875 PDR 0 ADOCK 05000461 l PDit j

Notice of Violation 2

c. Step 8.4.3 of procedure no. CPS 1024.35, " Control of Radioactive Effluents" and step 8.13 of procedure no CPS 7410.75, " Operation of AR/PR Monitors" states that at least annually, data from vab samples shall be checked against dat6 obtained from continuous radiation monitors to verify accuracy of the monitor end need for special calibration.

Contrary to the abmve, the NRC inspection identified that:

a. On July 16,1997, a gamma 10 portal monitor (serial number 85496E) had not been calibrated since February 26,1996.

b. On July 16,1997, a personnel contamination monitor 1B (serial number 1203) had not been calibrated since January 3,1996,

c. Since 1988, the licensee had not at least annually been checking data from grab samples against data obtained from continuous radiation monitors to verify the accuracv of the monitor and the need for special calibration.

This is a Severity Level IV violation (Supplement IV).

Pursuant to ths provisions of 10 CFR 2.201, Illinois Power Company is hereby required to submit a written statement of explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident inspector at the faci"ty that is the subject of this Notice of Violation (Notice), within 30 days of the date of the letter

, transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation cr, 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 a further violation, and (4) the date when full compliance will 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 a 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.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary informatior 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 t your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarrarited invasion uf

Notice of Violation 3 personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois, this 25th day of August 1997