ML20247K904

Notice of Violation from Insp on 890117-20 & 26.Violations Noted:Failure to Submit Accurate Personnel Monitoring Info to NRC & Failure to Follow Radiation Protection Procedures

ML20247K904
Person / Time
Site:	Fort Calhoun
Issue date:	05/23/1989
From:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247K871	List: IR 05000285/1989004 ML20247K904
References
50-285-89-04, 50-285-89-4, EA-88-030, EA-88-30, NUDOCS 8906020047
Download: ML20247K904 (3)

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%/; -APPENDIX NOTICE OF VIOLATION Lgx

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• 0maha Public' Power District Docket No.: 50-285.

Fort Calhoun Station. (FCS)~ -License No.: DDR-40.

j. EA No.: 88-30 During.an!NRC' inspection conducted January.17-20 and 26, 1989, vio1'ations of NRC; requirements were identified. In accordance with the " General Statement of Polii:y and Procedure. for NRC Enforcement Actions," 10'CFR Part 2, Appendix C

.-(1988), the violations are~ listed below:

Failureito Follow Procedures

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'1. ' Technical Specification.(TS) 5.11 requires that the licensee's procedures for' personnel radiation protection be consistent with the'

requirements,of-10LCFR Part 20 and approved,. maintained, and adhered' to for. all . operations involving personnel- radiation exposure.

Paragraph 3.222.1, Section 3.0, Volume VII, of the FCS Operating Manual requires, in part,- that any individual permitted to enter a posted'high radiationLarea (any area.where.a major portion of the body could-receive: greater than 100 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, but less than-1000 millirem in.1'ho'ur is considered a high radiation area and posted as such).shall be provided with or accompanied by one or more of'the following:

a. Continuous health physics technician coverage,

b. Individuals trained in radiation protection procedures and precautions may enter and perform required tasks after an 1 initial survey has been performed and they are made.

knowledgeable of the dose rates in the area. These individuals must wear a radiation monitoring device which continuously integrates the dose rate in the area and alarms at a preset integrated dose,

c. The. appropriate access control and monitor.ing will be specified on the radiation work permit required for entry into high radiation areas.

d. Health. physics must be aware that you are to enter the area and the reason for the entry.

e. Entrance must be controlled by issuance of a radiation work permit.

Furthermore, paragraph 3.2.2.2.2 requires, ". . . that individuals entering a very high radiation area (dose rates greater than 1000 millirem per hour), even though they may be a qualified health i

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@, 2 Ephysics -technician and equipped with proper dosimetry and radiation-monitoring instruments,7a second person.shall always' accompany the person entering."

a; . Contrary to.the above, the NRC determined that on January,8, 1989, thatla contract health. physics technician had been left

.alone.in'a very.high radiation area.

b. ;Contr'ry to the'above, the NRC determined that on~ January'26, 1989, a contract electrical-maintenance craftsman was found inside ofla= posted high radiation area'.without an integrating dosimeter and without-the knowledge'_of-the radiation prot'ection staff.

N Individually, these are classified as Severity Level. IV violations.

-(Supplement IV) (285/8904-01)

F 2.. Station Operating Manual Volume VII, paragraph IV.3, of Procedure HP-1, '" Fast' Scan Whole Body Counting," requires, in part, that a termination body count shall be performed when an. employee has

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terminated his/her work at FCS.

Contrary to the above, the NRC determined'on January 17, 1989, during a review of 25 personnel _ exposure records that approximately 12 out

'of--25 individuals involved had not received termination whole body

" -counts upon completion of work at FCS.

'This. violation is a Severity Level IV violation. (Supplement IV) ie (285/8904-04)

B. Failure to Submit Accurate Personnel Monitoring Information to the NRC 10 CFR Part 50.9 requires, in part, that information provided to the Commission (NRC) by a licensee shall be complete and accurate in all material aspects.

10 CFR Part 20.408 requires, in part, that licensees shall transmit to an employee upon termination of employment with the licensee or upon 4

, termination of work at'the licensee's facility information as to the r,esults of monitoring of an employee for exposure to radiation and radioactive materials.

. I'0 CFR- Part 20.409 requires, in part, that the licensee shall also

' transmit to the NRC the same information as transmitted to the employee in accordance with 10 CFR Part 20.408.

NRC Generic Letter 85-08 (May 23,1985) requested that the licensee voluntarily use the standard NRC Form 439 for submitting exposure data for termination reports. Instructions for completing NRC Form 439 specifically state that "The time to be covered by this report is that i.. ..

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p 3 period of employment or work assignment in your facility (ies) which ended

'with the most recent termination and was not interrupted by any previous termination during which personnel-monitoring was required . . . ."

!* Part.III of NRC-Form 439 specifically requires that Item 12 be checked, in the box provided, if the licensee had not performed monitoring for exposure to radioactive material. Any monitoring results are entered in E Item 13.

f Contrary to the above, the NRC determined on January 17, 1989, that the licensee had routinely indicated on radiation exposure termination reports (licensee Fcrm FC-285 equivalent to NRC Form 439) sent to individuals and the:NRC that personnel were monitored for internal radioactivity and i

the results were "No detectable activity." However, a random review of about 50 personnel monitoring. records revealed that 12 individuals had not  !

been whole body counted upon termination at FCS in order.to establish the presence of any detectable activity.

This is: a Severity Level V violation. (Supplement IV) (285/8904-02)

Pursuant to the provisions of.10 CFR 2.201, Omaha Public Power District is hereby required to submit to this office, within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason fer the violation.if admitted, (2) the corrective steps which havo been taken and the results achieved, (3) the corrective steps which.will be taken to avoid further violations, and

' (4)'the'date when full compliance will be achieved. Under the authority of Section 182 of th'e Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION l

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. Martin I egional Administrator i Dated.at Arlington, Texas this. 23rd day of May 1989

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