ML20195G954

Notice of Violation from Insp on 880516-19 & 0601-07. Violation Noted:Failure to Meet Training Requirements Per License Condition 24 & Work Conducted in Hot Cells W/O Completing Required Restricted Access Area Permit

ML20195G954
Person / Time
Site:	07000025
Issue date:	06/23/1988
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195G950	List: ML20195G947 ML20195G954 ML20195G960
References
70-0025-88-02, 70-25-88-2, NUDOCS 8806280180
Download: ML20195G954 (2)

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APPENDIX A +

i NOTICE OF VIOLATION  !

-I Rockwell International Corporation Docket No. 70-25 Rocketdyne Division License No. SNM-21 Atomics International  !

6633 Canoga Avenue  !

Canoga Park, California 91304 [

i During an NRC inspection conducted May 16-19, June 1 and June 7, 1988, certain [

violations of NRC requirements were identified. In acccrdance with the  !

"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 i CFR Part 2, Appencix C (19d7), the violations are listed below:  !

t A. License Condition Number 24 requires the licensee to maintain and execute j the response measures of the Radiological Contingency Plan (RCP) l submitted to the Commission on August 28, 1981 as revised on March 3, i 1982. Section 7.2 of the RCP states, in part, that personnel a: signed

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responsibilities for radiological emergency service are given apsropriate basic RCP training, semiannual retraining, and annual retraining in j special subject areas of the RCP. Additionally, the RCP sti.tes that 7

Quality Assurance will audit the training prcgram annually.  :

' f Contrary to the above requirements, at tne time of the insp1ction, the j licensee failed to meet the above training requirements specific to the t Radiological Contingency Plan for personnel assigned responsibilities for l radiological emergency service. Also, the Quality Assurance Organization  !

failed to audit the above training program as required. l This item constitutes a Severity Level IV Violation (Supplement VIII). j B. License Condition Number 9 authorizes the licensee to use specified radioactive Daterials in accordance with statements, representations, and  ;

conditions contained in Part I of the licensee's application datec' August f 20, 1982, and supplements dated October 29, and December 17, 1982, March l 2, March 7, May 29, and June 12, 1984, and September 22, 1987. Part I of l the application states in Section 3.1.1, in part, that a Restricted Area l Access Permit (Form 719-L) will be used to control entry into posted  !

areas where there is likely to be external radiation or airborne  !

radioactivity in excess of acceptable levels for continuous work. The  !

form requires approval of the managers controlling areas where work is to (

be performed, approval of the personnel who are responsible for  ;

performing the work, and approval of the Radiation and Nuclear Safety l representative. Also, Part I of the application states in Section 2.6- I the licensee will provide the necessary training to all employees who are j assigned to work in areas where their ursonal safety or the safety of i operation requires that they receive special training. Additionally, the j policy requires retraining of these employees at appropriate intervals to i assure continued safe practices, i 1

(1) Contrary to the above requirements, at the time of the inspection, the licensee conducted work in two hot cells (Cell #1 on April 8, l 1988 and Cell #3 on January 19, 1988) without completing the l

i 8806280180 PDR 880623 l ADOCK 07000025 s ,

DCD

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q required Restricted Access Area Permit. The permits had been properly initiat?.. controls for radiation protection had been identified, and the operators, by signature, attested to their understanding of the controls. However, the representative of Radiation and Nuclear Safety failed to sign the Restricted Access.

Area Permits and failed to specify the expiration dates for these two permits. A review of the dosimetry records confirmed that the work had been done on the dates scheduled.

This item constitutes a Severity Level IV Violation (Su,mlement VI).

C. 10 CFR 20.401(b) requires that records of surveys conducted to show compliance with 10 CFR Part 20.201(b) be kept for a period of five years.

Contrary to the above requirement, at the time of the inspection, the licensee failed to maintain records of the surveys of the Rockwell International Hot Laboratory (RIHL) basement, the hot dock, the yard around the RIHL, or the walls in the service gallery.

This item constitutes a Severity Level V Violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, Rockwell International Corporation, Rocketdyne Division, Atomics International is hereby required to submit a written statement or explanation to the U.-S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to

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the Regional Administrator, Region V, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should incluae for each violation: (1) the reason for the violation if admitted, (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. If an adequate reply is not received within the time specified in this Notice, an i order may be issued to show cause why the license should not be modified, l suspended, or revoked or why such other action as may be proper should not be I taken. Consideration may be given to extending the response time for good cause shown.

i FOR THE NUCLEAR REGULATORY COMMISSION h

James L. Montgomery, Chief i Nuclear Materials Safety and l Safeguards Branch Dated a Walnut Creek, California this ay of June 1988