ML20247K323

Notice of Violations from Insp on 980413-0504.Violations Noted:On 980404,licensee Did Not Make Sure Surveys to Assure Compliance w/10CFR20.1902(b),which Describes Posting of High Radiation Areas

ML20247K323
Person / Time
Site:	Duane Arnold
Issue date:	05/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247K320	List: IR 05000331/1998007 ML20247K315 ML20247K323
References
50-331-98-07, 50-331-98-7, NUDOCS 9805220065
Download: ML20247K323 (4)

Text

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NOTICE OF VIOLATION lES Utilities Inc. Docket No. 50-331 Duane Arnold Energy Center License No. DPR-49 During an NRC inspection conducted from April 13 through May 4,1998, six 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 20.1501(a) 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 mean a evaluation of the radiological conditions and potential hazards incident to the prodi a use, transfer, release, disposal, or presence of radioactive material or other sa ms of radiation.

Contrary to the above, on April 4,1998, the licensee did not make surveys to assure compliance with 10 CFR 20.1902(b), which describes the posting of high radiation areas. Specifically, the licensee failed to adequately evaluate the radiological hazards incident to the April 4,1998, low pressure core injection system full flow testing. The testing resulted in radiation levels in the reactor building exceeding 100 millirem per hour in areas that were not posted as high radiation areas. (50-331/98007-01)

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

2. Technical Specification 6.9.1 requires, in part, that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and be adhered to for all operations involving personnel radiation exposure.

A. Procedure ACP 1411.22 (Revision 6), " Control of Access to Radiological Areas,"

requires, in part, that personnel entering radiation areas and high radiation areas obtain a radiation work permit, review the radiation work permit, and follow the instructions and requirements set forth.

Radiation Work Permit 50380 Job Step 6 (Revisions 6 and 7) requires that if the ability to monitor dose rates is lost, the work be stopped until monitoring can be reestablished.

Contrary to the above, on April 7-10,1998, the licensee performed diving evolutions in the torus, a high radiation area, under Radiation Work Permit 50380 Job Step 6, lost the ability to monitor dose rates, and did not stop the work until monitoring was reestablished. (50-331/98007-03)

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

9805220065 980512 PDR ADOCK 05000331 0 PM

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Notice of Violation 2 l

B. Procedure ACP 1411.22 (Revision 6)," Control'of Access to Radiolo#.at Areas,"

l requires, in part, that personnel entering high radiation areas obtain a radizion work permit, review the radiation work permit, follow the instructions and requirements set forth, and obtain a briefing by health physics personnel prior to entering the area.

Radiation Work Permit No. 52 Job Step 1 (Revision 6), " Routine Work &

Inspections in ras," requires, in part, that the user not enter high radiation areas.

Contrary to the above:

(1) On April 1,1998, two workers performed an evolution under Radiation .

, Work Permit No. 52 Job Step 1 and entered a high radiation area on the 780' elevation of the turbine building. (50-331/98007-05a)

(2) On April 1,1998, two workers entered a high radiation area on the 780' elevation of the turbine building and did not receive a briefing by health physics personnel prior to entering the area. (50-331/98007-05b)

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

l C. Procedure ACP 1411.22 (Revision 6)," Control of Access to Radiological Areas," i i

requires, in part, that personnel entering radiation areas and high radiation areas )

obtain a radiation work permit and follow the instructions and requirements set forth.

l Radiation Work Permits Nos. 40010 Job Step 6 (Revision 3),33 Job Step 1 l

(Revision 4),53 Job Step 1 (Revision 6),10230 Job Step 1 (Revision 6), and .

10051 Job Step 1 (Revision 3) require, in part, that the user wear an electronic

! dosimeter.

l Contrary to the above:

(1) On April 4,1998, a member of the operations staff entered the drywell, a posted high radiation area, under Radiation Work Permit No. 40010 Job Step 6 (Revision 3) and did not wear an active electronic dosimeter. (50-331/98007-06a)

(2)' On April 5,6, and 8,1998, three Individuals entered radiation areas under Radiation Work Permits Nos. 33 Job Step 1 (Revision 4),53 Job Step 1 l (Revision 6), and 10230 Job Step 1 (Revision 6) and did not wear an active electronic dosimeter. (50-331/98007-06b) l

Notice of Violation 3 (3) On April 8,1998, an individual traversed the reactor building, a radiation area, under Radiation Work Permit No.10051 Job Step 1 (Revision 3) and did not wear an active electronic dosimeter. (50-331/98007-06c)

(4) On April 14,1998, two individuals entered areas of the turbine and reactor buildings, posted radiation areas, but the individuals had not obtained a radiation work permit. (50-331/98007-06d)

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

! 3. 10 CFR 20.1902(b) requires that the licensee post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " Caution, High Radiation Area" or " Danger, High Radiation Area."

Contrary to the above, on April 8 -10,1998, the torus, a high radiation area with a dose rate of approximately 600 to 800 millirem in one hour at 30 centimeters from filtration

units, was not posted with a sign bearing the radiation symbol and the words

" CAUTION, HIGH RADIATION AREA" OR " DANGER, HIGH RADIATION AREA."

(50-331/98007-04)

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

4. Technical Specification 6.4.1 requires that a training program be established to maintain the overall proficiency of the operating organization, which consists of both retraining and replacement training elements, and meet or exceed the minimum provisions outlined in ANSl/ANS 3.1-1978.

Section 5.1 of ANSl/ANS 3.1-1978 requires, in part, that a continuing training program be used for requalification training necessary to ensure that personnel remain proficient.

i Procedure PCP 1.2 (Revision 9), *DAEC Chemistry Quality Control Program," requires, ,

in part, that each chemistry technician perform post accident sampling system j surveillance test procedures at least once every 2 years to remain qualified on the post  !

accident sampling system.

Contrary to the above, as of April 14,1998, three chemistry technicians, who were designated to operate the post accident sampling system, had not performed the post accident sampling system surveillance tests since June 12,1995, November 17,1995, and November 21,1995, respectively. (50-331/98007-07) j This is a Severity Level IV violation (Supplement IV).

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Notice of Violation 4

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Pursuant to the provisions of 10 CFR 2.201, IES Utilities 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 Regional Administrator, Region lil, and a copy to.the NRC Resident inspector at the facility that is the subject of this Notice, within j 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should 1 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 or severity level, (2) the corrective steps thc. 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 a Demand for Information may be

- issued as to why the license should not be modified, suspended, or revoked, or why such other l action as may be proper should not be taken. Where good cause is shown, consideration v,ill 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.

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 must i specifically identify the portions of your response that you seek to have withheld and provide in I detail the bases for your claim 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 l CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lida, Illinois this 12th day of May 1998 l

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