ML20127N501

Notice of Violation from Insp on 850325-29

ML20127N501
Person / Time
Site:	Crystal River
Issue date:	05/24/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127N499	List: ML20127N496 ML20127N501 ML20127N509
References
50-302-85-12, NUDOCS 8507010635
Download: ML20127N501 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Florida Power Corporation Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 The following violations were identified during an inspection conducted on March 25-29, 1985. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1. Technical Specification 6.8.1 stated that written procedures shall be established, implemented and maintained for certain activities including applicable procedures in Appendix h A" of Regulatory Guide 1.33, 1972.

Appendix "A" of Regulatory Guide 1.33, November 1972, required procedures for surveys and monitoring.

Chemistry and Radiation Protection Procedure RSP-101, Basic Radiological Safety Information and Instructions for " Radiation Workers," step 3.1.4 required that, "When exiting the Auxiliary Building "RCA," a whole body frisk must be performed in accordance with Section 3.3." Section 3.3.

delineated the " Guidelines for conducting a "Whole Body Frisk" using a RM-14 with HP-210 probe." This guidance indicated that hands be frisked for five (5) seconds each prior to picking up the probe. Personnel are instructed in notes to Section 3.3.2 that, "if any increase in count rate is noted, THEN return the probe to the suspected area of contamination for a minimum of five (5) seconds. If the ALARM sounds or a significant increase (i.e.,

greater than 50 cpm above background) is visual or audible response is noted, THEN notify Health Physics personnel immediately." The guidance recommended frisking the hands, head or hat, face, neck, front of body trunk, bottom of each foot, each dosimetry device or other small personal item for approximately 5 seconds each. The guidance recommended the remainder of the body including the arms, legs, knees, buttocks, and back to be frisked slowly for approximately 30 seconds. If this guidance is followed, a whole body frisk should take approximately 70 seconds.

Chemistry and Radiation Protection Procedure RP-101, Radiation Protection Manual, step 4.8.4.e recommended that, " prior to donning personal clothing, all individuals should conduct a Whole Body Frisk at the nearest frisking station" and 4.8.5.a required that "all personnel shall conduct a Whole Body Frisk prior to each exit from the 95 foot elevation control complex RCA."

Detailed frisking recommendations similar to those described in procedure RSP-101 are also contained in this procedure.

Contrary to the above, procedures RSP-101 and RP-101 were inadequate in that they failed to assure the implementation of the respective procedural requirement that whole body frisking "shall" or "must" be performed in accordance with the stated guidelines and on March 26-29, 1985, personnel were not performing adequate whole body frisks to permit detection of contamination at licensee action levels, in that of approximately 30 Ogg70{0g $$$8 2 0

Enclosure 1 2 personnel observed at the reactor building exit and the auxiliary building 95 foot elevation Radiation Control Area (RCA) exit (two of these individ-uals were observed frisking at both exits), the following practices were observed:

a. Generally, picking up the frisker probe without first frisking their hands;

-b. Frisking for significantly less than 30 seconds,

c. Failing to frisk areas of the body, other than the hands, face and feet, and;

d. Moving the frisker probe so fast that contamination significantly in excess of licensee action levels would have to be present on the individual in order for the instrument audible response to indicate that an area needed additional frisking.

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

2. 10 CFR 19.11 required that certain documents, notices or forms be con-spicuously posted to permit their being observed by individuals on their way to or from licensed activities.

Contrary to the above, on March 26, 1985, the required documents, notices or forms were not conspicuously posted to permit observation by individuals engaged in licensed activities in that:

a. The required documents, notices or forms on the bulletin board located on the auxiliary building 95 foot elevation near the Health physics office were obscured from view by other materials posted on top of the required posting,

b. The bulletin boards in the Rusty Building and the turbine building entrance did not have all the required materials p'osted.

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

3. 10 CFR 20.203(f) requires each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents. The label shall bear the radiation caution symbol and the words " CAUTION -

RADI0 ACTIVE MATERIAL" and shall provide sufficient information to permit individuals handling or using the containers or working in the vicinity thereof, to take precautions to avoid or minimize exposures.

Contrary to the above, a yellow bag which contained a contaminated hose measuring approximately 8 mrem /hr on contact was determined to contain a quantity of radioactive material greater than that Itsted in 10 CFR 20, Appendix C, and the bag label did not include the radiation caution symbol.

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

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Enclosure 1 3 Pursuant to 10 CFR 2.201, you are required to ;ubmit to this office within 30 days of the -date of this Notice, a written statement or explanation in reply, including: . (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

Date:

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