ML20206D409

Notice of Violation from Insp on 870309-13

ML20206D409
Person / Time
Site:	Crystal River
Issue date:	03/27/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206D397	List: IR 05000302/1987009 ML20206D394 ML20206D409 ML20206D491
References
50-302-87-09, 50-302-87-9, NUDOCS 8704130326
Download: ML20206D409 (3)

Text

_ . - _ . . . . _

. ENCLOSURE 1 4

NOTICE OF VIOLATION

, Florida Power Corporation Docket No. 50-302 Crystal River 3 License No. DPR-72 During the Nuclear Regulatory Conunission (NRC) inspection conducted on March 9-13, 1987, violations . of NRC requirements were identified. The violations regulationsinvolved for transporting (a) failure radioactiveto complymaterial, with Dep(artment b) failure toofhave Transportation adequate procedures in place to ensure- personnel were qualified to wear respiratory protective equipment necessary to perform their duties, and (c) failure to perform adequate in vivo (whole body) radiation surveys. In accordance with

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

10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. 10 CFP, 71.5(a) requires that each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport shall comply

with the applicable requirements of the regulations appropriate to the l mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.

. 49 CFR 173.475(1) requires that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests, that external radiation and contamination levels are within the allowable limits.

s 49 CFR 173.441(b)(2) requires that the radiation level may not exceed 200 millirem per hour at any point on the outer surface of exclusive use

, closed transport vehicles, including the upper and lower surfaces.

49 CFR 173.427(c) requires that a packaging which previously contained radioactive materials and has been emptied of contents as far as

practical, is excepted from the shipping paper and certification, marking and labeling requirements provided that internal contamination does not exceed 100 times the limits in 49 CFR 173.443.

49 CFR 172.202(a) requires that the shipping description of a hazardous material on a shipping paper must include the proper shipping name prescribed for the material and the identification number.

8704130326 670327 PDR ADOCK 05000302 PDR O

_- . . . _ , _ . _ _ _ _ _ _ . . . _ _ _ _ _ . . . _ _ _ _ _ _ . _ _ . . ~ _ .. _ _. _ .___ , _ ..__..._,_. . _ _ _ _ _

s f

Florida Power Corporation Docket No. 50-302 Crystal River 3 2 License No. DPR-72 Contrary to the above, the licensee failed to comply with the requirements of the Department of Transportation for offsite radioactive material shipments in that: >

1. No survey of the top outer surfaces of the exclusive use transport vehicle was performed for Radioactive Material Shipment No. 87-15 on March 5,1987.

2. Adequate contamination surveys of the packaging internals were not performed to demonstrate that Shipment Number 87-0093 on January 15,

.1987, met the empty packaging exemption criteria, j

3. The proper shipping name and identification number of Radioactive Material, Special Fom, n.o.s., UN 2974 was not listed on the shipping paper as the description of a sealed source shipped on March 17, 1986, under Shipment Number 86-16. The shipping paper described the material as Radioactive Material, n.o.s., UN 2911.

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

B. 10 CFR 20.103(c)(2) requires that the licensee maintain and implement a respiratory protection program that includes, as a minimum, written procedures regarding selection, fitting and training of personnel.

l Chemistry and Radiochemistry Protection Procedure, HPP-501, dated l September 23, 1986, Respiratory Issue and Return, Section 3.1.1 specifies i

the licensee's requirement for issuance of ' respiratory protection equipment.

Emergancy Plan Implementing Procedure, EM-208 dated April 3,1986, Duties of the Radiation Emergency Team, Section 2.3 specifies the licensee's respiratory protection qualification requirements for emergency team members.

Contrary to the above, on November 22, 1986, the licensee's respiratory protection procedures were inadequate to ensure that nuclear operators were qualified to wear respiratory protective equipment necessary for them to perform their duties.

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

C. 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) are necessary for the licensee to comply with regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

10 CFR 20.103(c)(2) requires the licensee to maintain and implement a respiratory protection program that includes surveys and bioassays as appropriate to evaluate actual exposures.

Florida Power Corporation Docket No. 50-302

. Crystal River 3 3 License No. DPR-72 Health Physics Procedure HPP-320, "Whole Body Counting System Operation,"

dated December 9,1986, which implements part of the licensee's bioassay program requires: baseline whole body counting for all personnel who could be exposed to airborne radioactive material (Section2.1.1); .

notification of the Health Physics Supervisor (HPS) if the tctal body burden is in excess of 1% maximum permissible organ burden (MP08)

(Section 2.6); input of information to the computer system as requested by the whole body counting jobstream menu (Section 3.1.2); and positioning of the individual in the whole body chair such that the detectors are centered on, and as close to, the body part being counted by the detector as possible (Section3.1.5).

. Contrary to the above, the licensee failed to perform adequate in vivo (whole body) radiation surveys during March 9-13, 1987, in that:

1. Identified positive MP0B values (greater than 1% MP0B) were not evaluated by the HPS prior to releasing personnel for entry into the plant controlled radiation area. ,

& Identical (inaccurate) whole body position coordinates were entered into the required jobstream menu for each separate whole body Nalysis, e

3. The thyroid detector was not centered on the thyroid of individuals l being counted.

4. Routine background counts for the whole body counting system were not  ;

performed to establish a baseline for the analyses. l This is a Severity Level IV violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Florida Power Corporation is hereby I

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 i

for each violation: (1) admission or denial of the violation, (2) the reason o

for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.

l Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEA REGULATORY COMMISSION

/

^ ./ a is A. Reyes rector Division of e ctor Projects Dated at Atlanta, Georgia this 27 day of March 1987

. . . . . . .