ML20236F985

Notice of Violation from Insp on 870825-27.Violations Noted: Individual Received Occupational Dose of 23.6 Rems to Skin of Whole Body Exceeding 1 Calendar Quarter Requirement,Per 10CFR20.101(a) & Whole Body Survey Not Performed

ML20236F985
Person / Time
Site:	North Anna
Issue date:	10/26/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236F954	List: ML20236F951 ML20236F985
References
50-338-87-30, 50-339-87-30, EA-87-183, NUDOCS 8711020362
Download: ML20236F985 (4)

Text

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NOTICE OF VIOLATION

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Virginia Electric and Power Company Docket Nos. 50-338 and 50-339

North Anna, Units 1-and 2 License Nos. NPF-4 and NPF-7 EA 87-183 During the Nuclear. Regulatory Commission (NRC)1 inspection conducted on August 25-27, 1987, violations of NRC requirements were identified. In accord-

-ance with the " General Statement of Policy and Procedure.for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are listed below:

A. 10 CFR 20.101(a) requires,'in part, that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in 4 a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation, a total. occupational dose in excess of 7.5 rem to the skin of the whole body.

Contrary to the above, on August 19, 1987, licensed material was used in such a manner as to cause an' individual in the Unit 1 Containment Building,

a. restricted area, to receive an occupational dose of 23.6 rem to one square centimeter of the skin of the whole body, resulting in a total occupational dose'for the individual for the calendar quarter of 23.828 rem to the' skin of the whole body.

This is a Severity Level IV violation (Supplement IV). This violation applies-to Unit 1 only.

B.. 10 CFR 20.201(b) states that each licensee shall make'or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate-the extent of radiation hazards that may be present.

10 CFR 20.201(a) defines survey to mean an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions, and, when appropriate, includes a physical survey of the location of materials .and equipment, and measurements of levels of radia-tion or concentrations of radioactive material present.

Technical Specification 6.11 states that procedures for personnel radia-tion protection shall be prepared consistent with the-requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

Radiation Protection Manual, Section 1, Part 3, Subsection G, Existing '

Restricted Areas, Step 6, states that Health Physics (HP) will locate portal monitors or friskers as necessary and personnel shall use such equipment unless otherwise instructed by HP.

Job Performance Measures No. 1 of General Employee Training, Step 1.2,  :

defines proper use or proper frisk as a whole body frisk and a dosimetry l frisk. l l

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Notice of Violation l Contrary to the above, surveys to evaluate the extent of radiation hazards that may be present were inadequate in that:

1. On August 19, 1987, an individual exited the Unit 1 containment, a contaminated area, and a whole body survey was not performed as required resulting in 30 minutes to one hour of additional exposure I

to a microscopic particle containing 1.6 microcuries of cobalt-60.

2. On August 26, 1987, seven out of ten individuals exiting either Unit 1 or Unit 2 containment, contaminated areas, failed to perform necessary whole body surveys in that only hands, feet, and head were monitored.

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

C. Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

. Regulatory Guide 1.33, Appendix A, Paragraph 7.e, requires radiation protection procedures covering access control to radiation areas including a Radiation Work Permit (RWP) system.

Procedure HP-5.3.10, RWP Program, August 21, 1986, Paragraph 4.3.1, states that RWPs shall provide the radiological controls required in support of specific conditions relating to the specific work activity and area or purpose of entry.

RWP No. 87-2312, Perform Eddy Current Testing in A, B, and C Steam Gen-erators, August 14-27, 1987, requires that in addition to other protective clothing requirements, a plastic suit and a fresh air hood will be worn.

Contrary to the above, RWP requirements for protective clothing were not met in that on August 19, 1987, an individual who had signed into Unit 1 containment on RWP No. 87-2312 made entry to "A" steam generator platform to perform a survey and failed to wear a plastic suit or a fresh air hood.

This is a Severity level IV violation (supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company 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, Region II, and a copy to the NRC Resident Inspector, North Anna, within 30 days of the date of this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) admission or denial of the violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

Notice of Violation Where good cause is shown, consideration will-be given to extending the response time. 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.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY:

J. NELSON GRACE J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia this 26 day of October 1987

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