ML20248C044

Notice of Violation from Insp on 980403-27 & 0506.Violations Noted:Radiologically Posted Area Established for sodium-24 Used in Moisture Carryover Test Was Not Posted W/Sign Bearing Radiation Symbol & Listed Words

ML20248C044
Person / Time
Site:	Byron
Issue date:	05/28/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248C016	List: IR 05000454/1998010 ML20248C011 ML20248C044
References
50-454-98-01, 50-454-98-1, 50-455-98-10, NUDOCS 9806020049
Download: ML20248C044 (3)

Text

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50-454; 50-455 Byron Station, Units 1 and 2 License Nos. NPF-37; NPF-66 During an NRC inspection completed on May 6,1998, violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

1. 10 CFR 20.1902(a) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION,  ;

RADIATION AREA."

Contrary to the above, en April 3,1998, the radiologically posted area established for I the sodium-24 used in the moisture carryover test, a radiation area with a radiation dose j rate of approximately 10 millirem in one hour at 30 centimeters from the shipping /

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

" CAUTION, RADIATION AREA." (50-454/455-98010-01)

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

2. Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiction exposure.

Byron Administrative Procedure BAP 720-3, Revision 18, dated October 27,1997,

" Control of Materials For Conditional or Unconditional Release from Radiologically Posted Areas," step C. 4 states, that all items having the potential to be contaminated shall be unconditionally released or meet the conditional release requirements. The referenced procedure defines unconditional release as an article / material that has no detectable licensed radioactive material above background and defines conditional  !

release as an article / material that is contaminated, or suspected to be contaminated, l and is logged and controlled to prevent unauthorized use or removal and is retumed to a permanent RPA (radiologically posted area) within 1 shift unless appropriate controls are established. j Contrary to the above, (a) On February 19,1998, the licensee unconditionally released a radioactive l material bag containing protective clothing having radioactive contamination at a level of 128,000 disintegrations per minute (50-454/455-98010-02a); and (b) On February 25,1998, the licensee unconditionally released a 480 volt panel that had 4,500 disintegrations per minute of removable contamination.

(50-454/455-98010-02b)

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

9006020049 900528 PDR ADOCK 05000454 G PDR

Notice of Violation 2 j 3. Technical Specification 6.11 requires that procedures for personnel radiation protection i be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.

Radiation Protection Procedure BRP 5000-7, Revision 7, dated June 28,1996,

" Unescorted Access To And Conduct in Radiologically Posted Areas," requires that l each person entering a RPA (radiologically posted area) is responsible to adhere to the rules. Step 3.z requires, in part, that workers avoid bad rad practices; they do not adjust glasses with outer rubber gloves, they do not touch their face while in protective clothing, and they do not wear protective clothing partially unzipped.

j Contrary to the above, (a) On April 27,1998, a worker inside of containment unzipped his protective clothing and reached inside to read his pager without removing his outer rubber glove which was potentially contaminated (50-454/455-98010-05a);

(b) On April 27,1998, two workers removing insulation inside of containment reached up and adjusted their glasses without removing their outer rubber gloves (50-454/455-98010-05b); and (c) On April 30,1998, a worker inside of containment rubbed his nose without removing his outer rubber glove. (50-454/455-98010-05c)

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

Pursuant to the provis!ons of 10 CFR 2.201, Commonwealth Edison 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 ill, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, 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 or severity level, (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 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.

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.

Notice of Violation 3 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 mual specifically identify the portions of 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 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 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 Lisle, Illinois this 28th day of May 1998 I

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