ML20217C128

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Notice of Violation from Insp on 980209-13.Violation Noted: Licensee Failed to Comply with Requirements of Section 12 of Physical Security Plan
ML20217C128
Person / Time
Site: Vallecitos Nuclear Center, Vallecitos  File:GEH Hitachi icon.png
Issue date: 03/18/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217C121 List:
References
50-073-98-201, 50-73-98-201, NUDOCS 9803260320
Download: ML20217C128 (3)


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ENCLOSURE 1 '

NOTICE OF VIOLATION

, 4 a i General Electric Company Docket No.: 50 73 L L Nuclear Test Reactor (NTR) Facility License No.: R 33 '

,.' During an NRC inspection conducted on February 913,1998,' three violations of NRC l requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

l 1. : 10 CFR 20.1902 requires that radiation areas be posted with a sign reading " Caution, L Radiation Area." ' 10 CFR 20.1003 defines a radiation area as an area, accessible to

; individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem in one hour at 30 centimeters from the radiation ig source or from any surface that the radiation penetrates.

Contrary to the above, the licenses failed to comply with the requirements of L -10 CFR 20.1902 in that an area on the east side of the South Coll, outside the cell

. wall, was found to have a radiation level of 6 8 millirem per hour (mr/hr) at a distance l ' of at least 30 centimeters from the wall. However, the area was not posted as j

. required. J 1

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This is a Severity Level IV violation (Supplement IV). 'l 2r TS 6.3 requires that the licensee have procedures for various activities including radiation protection.

a. : Standard Operating Procedure (SOP) 7.3, " Radiation and Contamination Surveys,"

Section 5.2 requires that routine surveys be conducted by radiation control personnel in accordance with Nuclear Safety Procedure 3550, " Building 105/NTR-Work Routines."

Nuclear Safety Procedure 3550, " Building 105/NTR Work Routines," Rev. 7, dated October 1995, Sections V.A, B, and D require monthly surveys in the Machine  :

Shop, NTR Setup Room. NTR Darkroom, and the Hand and Shoe Counter. 'Section j V.E requires monthly surveys in the North Room and the South Cell.  !

TS 4.6' defines monthly to be an interval not to exceed six weeks.

b. .

VNC Safety Standard No. 5.3.0, "Bioassey Program," Rev. 6, dated November

- 1996, Section 3.7 stipulates that an employee's supervisor or manager is responsible for initiating the action to begin bloessay sampling and for notifying j Regulatory Compliance of all radionuclides with'which their employees will be 4 working. . A written notification from supervision can be made using forms VNC-

- 335 and -336. Form VNC-335 has a Frequency-Of Exposure Table which states l

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that personnel who are regularly assigned to work in " Radioactive Material Aieas" on a daily basis should be counted four times per year.

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- Contrary to the above, the licenses failed to comply with the requirements of TS 6.3 in

that:

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a. In 1997, the Machine Shop, NTR Setup Room, NTR Dark Room, and the Hand and Shoe Counter were surveyed on September 10 but not again until October 28, a-

"- period of time exceeding six weeks. Also, the North Room and the South Cell were surveyed on December 10 but not surveyed again until January 27,1998, a period of time exceeding six weeks.

b. In 1996, two individuals working in radioactive material aress' associated with the Nuclear Test Reactor only received one_ bloessay (whole body count) each in 1997, all three individuals working in radioactive material areas associated with the Nuclear Test Reactor only received two whole body counts each.

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

3. Section 12 of the Physical Security Plan contains various requirements;
a. - Section 12.2 requires that the emergency generator be tested semi annually to demonstrate that, upon loss of site power, it starts automatically and the Closed Circuit Television and motion detector continue to operate.
b. Section 12.3 requires that the High Level Conference Circuit (HICON) be tested on

. the first Wednesday'of each month,

c. Section 12.4 requires that a quarterly call be made from an Off Site Emergency Agencies Call List on the first Thursday of March, June, September, and December using the site r,r automatic dial telephone.

Contrary to the above, the licensee failed to comply with the requirements of Section 12 of the Physical Security Plan in that:

a. Prior to 1998, the test of the emergency generator was only performed annually.
b. During 1997, there _was no test of the HICON completed in October, and the test

.in December was not completed on the first Wednesday of the month, in 1998, testing of the HICON was not completed on the first Wednesday of the month in either January or February.  !

c. Quarterly calls made from an Off-Site Emergency Agencies Call List in 1997 were not made on the first Thursday of March, June, September, and December as required. - _

This is a Severity Level IV violation (Supplement 111).

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3-Pursuant to the provisions of 10 CFR 2.201, General Electric Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the responsible inspector, U.S. Nuclear Regulatory Commission, Region ll,61 Forsyth St. S. W., Suite 23T85, Atlanta, GA 30303, 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 include for each violation: (1) the reason 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 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 Demand for Informat'on may be issued as to why the license should not be modified, suspended, or renked, or why such other acticn as may be proper should not be taken. Where good cause is shown, consideration wiil 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, D.C. 20555-0001.

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 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 mus1 specifically identify the portions of your response l that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure or 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 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 Rockville, Maryland this N

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