ML20138C441

Notice of Violation from Insp on 860121-30 & 0212-13

ML20138C441
Person / Time
Site:	Sequoyah
Issue date:	03/27/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138C434	List: ML20138C430 ML20138C441 ML20138C470
References
50-327-86-04, 50-327-86-4, NUDOCS 8604020498
Download: ML20138C441 (3)

Text

ENCLOSURE 1 NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 License Nos. DPR-77 and DPR-79 During a . Nuclear Regulatory Commission (NRC) inspection conducted on January 21-30 and February 12-13, 1986, violations of NRC requirements were identified. The violations involved a failure to transfer radioactive material in accordance with the license . conditions of a disposal site and other deficiencies in your radiation protection program. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C.(1985), the violations are listed below:

1. 10 CFR 30.41(c) required that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.

Condition 64 of the State of South Carolina Radioactive Material License Number 097, required -that Chem-Nuclear Systems, Inc., not receive shipments of radioactive materials unless appropriate lifting devices of sufficient length have been provided and securely attached to containers and palletized shipments within a cask.

Contrary to the above, on September 27, 1985, the licensee's.

radioactive waste shipment number 0985-119 arrived at the Chem-Nuclear Systems, Inc. radioactive waste disposal site near Barnwell, SC with the cask rigging gear inaccessible for unloading in that the rigging gear was wedged in the space between the' liner and shipping cask inner wall by bracing material.

This is a Severity Level III violation (Supplement V).

2. 10 CFR 20.103(a)(3) required that for purposes of determining compliance with the requirements of ~ 10 CFR 20.103(a)(1), the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or- any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.

Contrary to -the above, the licensee failed to use-the results of the measurements listed in 10 CFR 20.103(a)(3) to determine compliance with the requirements of 10:CFR 20.103(a)(1) for a licensee employee who received an internal deposition of radioactive material on December 11, 8604020493 860327 PDR ADOCK 0 % g 7

.G

.m  %

Tennessee Valley Authority Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 2 License Nos. DPR-77 and DPR-79 1985, in that the results of the ten-whole body counts and six urine and one fecal- sample analyses performed during the period December 11-18, 1985, were not evaluated to determine the regulatory significance of the exposure.

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

3. 10 CFR 20.103(c)(2) required that the licensee maintain and implement a respiratory protection program that includes, as a minimum, written procedures regarding supervision and training of personnel and issuance

. records if the licensee makes allowance for use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air.

Contrary to the above, the licensee failed to maintain written procedures regarding respiratory protective equipment issuance records in that no such records were maintained and allowance was made for use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air.

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

4. 10 CFR 20.201(b) required that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to comply with 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. A " survey" is defined in 10 CFR 20.201(a) as 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.

10 CFR 20.101(a) required a licensee to possess, use, and transfer its licensed material in a manner which precludes whole body and lens of the eyes occupational exposure of any individual in a restricted area of more than 1.25 Rems in any period of one calendar quarter except as provided in 10 CFR 20.101(b).

10 CFR 20.301 forbids a licensee to dispose of licensed material except by certain specified means.

Contrary to the above, the requirement to perform evaluations necessary to demonstrate compliance with 10 CFR 20 and were reasonable under the circumstances to evaluate the extent of radiation hazards present was not met in that:

a. During the period January through September 1985, the licensee -

failed to perform adequate evaluations to demonstrate that individual lens of the eye exposures due to noble gas were in compliance with the lens of the eye quarterly exposure limits in 10 CFR ~20.101(a) during personnel contairment entries while the reactor was at power.

Tennessee Valley Authority -Docket Nos. 50-327 and 50-328 Sequoyah 1 and 2 .3 License Nos. DPR-77 and DPR-79

b. On January 27, 1986, surveys of material and equipment being released for unrestricted use were inadequate to demonstrate that the material and equipment contained no detectable licensed material and that the disposal requirements of 10 CFR 20.301 were not applicable,

c. The licensee did not make such evaluations of lost individual exposure' data as were necessary to ensure that individual exposures were within the quarterly whole body exposure limits in 10 CFR 20.101(a) for the two pocket dosimeter rezero sheets recorded as lost in 1986 and the nine rezero sheets lost in 1985.

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

Pursuant to the provisions of 10 CFR 2.201, the Tenne'ssee Valley Authority is hereby required to suomit 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) admission or denial of the alleged violations, (2) the reasons for the violations if admitted, (3) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is ,hown, consideration will be given to extending the response time.

Dated at Atlanta, GA this 22 day of March 1986