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Category:NOTICE OF VIOLATION OF A REGULATION
MONTHYEARML20154J8991998-10-0707 October 1998 Notice of Violation from Insp on 980726-0906.Violation Noted:Licensee Did Not Establish Measures to Assure Regulatory Requirements & Design Basis of Control Room High Efficiency Air Filtration Sys ML20239A1231998-08-28028 August 1998 Notice of Violation from Insp on 980609-0725.Violation Noted:From 1980 to 980609,licensee Failed to Maintain Provisions to Ensure That One Train of Cables Were Free from Fire Damage ML20237A3031998-08-0606 August 1998 Notice of Violation from Insp on 980427-0515.Violation Noted:From 960710-970427,licensee Elected Not to Monitor Performance or Condition of Control Rod Drive Sys Against Established Goals ML20247N8441998-05-19019 May 1998 Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000 (Ref 10CFR2.790(b) for Violations Noted During Insp on 980302-05 & 11-12 ML20247P0221998-05-19019 May 1998 Notice of Violation from Insp on 980225-0418.Violations Noted:Work Plan to Replace External Cooling Water Flexible Hoses to a Core Spray Pump Motor Not Commensurate with Complexity of Task.As Result,Physical Damage Occurred ML20217N5971998-04-27027 April 1998 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $165,000.Violations Noted:Between Jan 1995 & 970120 Licensee Failed to Take Prompt & Effective Corrective Action for Significant Condition Adverse to Quality ML20217F0101998-03-24024 March 1998 Notice of Violation from Insp on 980107-0224.Violation Noted:Nrc Identified That Condition Outside Design Basis of Plant Involving EDG Fuel Oil Storage Sys Was Not Reported to NRC within 1 Hour ML20202D2441998-02-0606 February 1998 Notice of Violation from Insp on 971111-980106.Violations Noted:Util Did Not Properly Evaluate Cause & Implement Corrective Actions to Preclude Repetition of Temporary Temp Detectors Deficiencies from Reactor Vessel Flange ML20197K1101997-12-17017 December 1997 Notice of Violation from Insp on 971006-10 & 1119.Violation Noted:Nine Penetrations Were Not Qualified in That Qualification Methodology Used by Boston Edison Had Not Been Validated by Test Results to Be Equivalent to Type Testing ML20197H2411997-12-11011 December 1997 Notice of Violation from Insp on 970914-1110.Violation Noted:On 971001,licensee Identified That,Tagout T97-61-162 Was Incorrectly Prepared & Applied;Breaker 1021 Was Placed in Closed Vice Open Position as Required by Tagout ML20211A2741997-09-17017 September 1997 Notice of Violation from Insp on 970721-0801.Violation Noted:For Problem Rept PR97.9220,trip of B Residual Heat Removal Pump,Individual Performing Root Cause Analysis Was Not Formally Trained in HPI Methodology ML20149K0401997-07-22022 July 1997 Notice of Violation from Insp on 970429-0624.Violation Noted:On 970602,station Services Dept Worker Tied Open Boiler Room Door Which Forms Part of Radiologically Controlled Area & Action Not Directed by RP Personnel ML20149K1291997-07-18018 July 1997 Notice of Violation from Exam on 970505-09.Violation Noted: Two SRO Applications Dtd 970418,documented Five Manipulations Based on Credit Taken for Multiple Manipulations Due to Power Change & One Should Be Credited ML20141K7841997-05-22022 May 1997 Notice of Violation from Insp on 970303-0428.Violation Noted:Function of 180/120 Voltage Regulating Transformers Not Correctly Translated Into Specification ML20137E5591997-03-18018 March 1997 Notice of Violation from Insp on 970112-0302.Violation Noted:Plastic Valve Restraint on Valve 1301-36 Melted & Broken ML20132G2591996-12-18018 December 1996 Notice of Violation from Insp on 960924-1122.Violation Noted:Monthly Composites for Tritium & Gross Alpha Radioactivity & Quarterly Composites for Sr-89,Sr-90 & Fe-55 Not Always Analyzed According to Table 4.81 of TS ML20129H5021996-10-30030 October 1996 Notice of Violation from Insp on 960729-0923.Violation Noted:Corrective Actions for Problems Identified Since Apr 1995,were Not Effective in Identifying & Correcting Overall Adherence & Adequacy Problems at Plant ML20129F8701996-10-21021 October 1996 Notice of Violation from Insp on 960708-12,22-26.Violation Noted:Primary Containment Integrity Was Not Maintained in That Two Electrical Containment Penetrations Not Properly Protected ML20129A0381996-10-11011 October 1996 Notice of Violation from Insp on 960916-20.Violation Noted: Noted:Failure to Audit Access Authorization Program within 12 Months of Implementation.Failure to Conduct Audits of Nine Accepted Contractor & Vendor Access Authorization ML20058D4411993-11-19019 November 1993 Notice of Violation from Insp on 930830-1015.Violation Noted:Inadequate Evaluation of Radiation Hazards Associated W/Main Steam Line Plugs Resulted in Workers Sustaining Unplanned Internal Radiation Exposures ML20128D9911993-02-0303 February 1993 Notive of Violation from Insp on 921130-1218.Violation Noted:Licensed Procedures Inadequate Concerning Exhaust Damper on Emergency Diesel Generator B ML20128C4301993-01-28028 January 1993 Notice of Violation from Insp on 921124-1231.Violation Noted:Licensee Failed to Properly Implement Procedures 3.M.2-7.6 in That Technicians Established Incorrect RPS Protective Setpoints ML20058G9821990-11-0707 November 1990 Notice of Violation from Insp on 900816-1008.Violation Noted:Licensee Issued Two Minor Field Rev Notices Which Affected Safety Evaluation Bases of Plant Design Change for Temporary Leak Seal Repair of Shutdown Cooling Sys Valve ML20247K6721989-09-0707 September 1989 Notice of Violation from Insp on 890525-0710.Violation Noted:One Trip Sys Had Only One Instrument Channel Operable for Stated Function from 890525-0609 ML20246L8131989-08-23023 August 1989 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000.Violation Noted:Breakers for Three Valves Left Closed & Energized,Contrary to Desired Position on Tagout Sheet & Test Accepted W/O Noting Discrepancy ML20245H9711989-04-26026 April 1989 Notice of Violation from Insp on 890206-0310.Violation Noted:Licensee Made 17 Shipments of Contaminated Laundry Between Jan 1988 & Feb 1989 Which Failed to Identify Presence of Fe-55 ML20205P7171988-10-26026 October 1988 Notice of Violation from Insp on 880623-0803.Violation Noted:Licensee Failed to Issue Termination Exposure History Repts to Over 400 Individuals,Per 10CFR19 & 20 ML20204D6961988-10-14014 October 1988 Notice of Violation from Insp on 880912-16.Violations Noted:Undersized Motor Contactor Installed in Motor Control Ctr Cubicle B1735 Not in Conformance to Technical Requirements Specified by Drawing E10,Rev 12 ML20151U7701988-08-10010 August 1988 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $1,250,000.Violations Noted:Control Room Operators Observed Sleeping While on Duty,Reading Matls Not Directly Job Related & Failure to Rept Items to NRC ML20197F2651988-05-31031 May 1988 Notice of Violation from Insp on 880306-0417.Violation Noted:Failed to Properly Review & Release Design Re Installation of New Reactor Water Level Gauges ML20154B0221988-05-0606 May 1988 Notice of Violation from Insp on 880120-0305.Violation Noted:Implementation & Testing of Certain Mods Not Properly Preplanned & Performed in Manner to Assure Quality ML20151W4161988-04-27027 April 1988 Notice of Violation from Insp on 880201-05.Violations Noted: Appropriate Qualitative & Quantitative Criteria for Removing Corrosion Byproducts Not Applied to Battery Terminals & No Procedures Written for Breakers ML20153A8501988-03-11011 March 1988 Notice of Violation from Insp on 871207-880119.Violation Noted:Doors to Areas Being Controlled as Locked High Radiation Areas Found Unlocked & Unattended ML20237A5701987-12-10010 December 1987 Notice of Violation from Insp on 871005-09.Violations Noted:Inaccurate Shipping Manifest & Certification Accompanying Shipment 86-44 & Inaccurate Description of Radionuclides on Shipping Papers Sent to Burial Site ML20236T5421987-11-20020 November 1987 Notice of Violation from Insp on 870803-07,10-14 & 20. Violation Noted:As of 870820,severe Design Basis Time Temp Not Established for Solenoid Valve SV-220-44 & Cable Splice Assemblies Q102A,Q102B,Q103A & Q103B ML20236H5151987-10-28028 October 1987 Notice of Violation from Insp on 870914-18.Violation Noted:Licensee Failed to Post Notice of Violation ML20235T2501987-09-24024 September 1987 Notice of Violation from Insp on 870901-03.Violations Noted: None of Three Firemen from Nuclear Test Reactor Bldg Emergency Team Provided w/self-contained Breathing Apparatus Training & Failure to Maintain Records on Training ML20235L3531987-09-24024 September 1987 Notice of Violation from Insp on 870817-21.Violation Noted: post-maint Test Results That Failed to Meet Acceptance Criteria Not Adequately Evaluated ML20234D2481987-09-15015 September 1987 Notice of Violation from Insp on 870810-17.Violation Noted: Licensee Failed to Apply QA Program to Provide Control Over Activities Affecting Quality of Sys Consistent W/Importance to Safety ML20238A7181987-08-24024 August 1987 Notice of Violation from Insp on 870713-17.Violation Noted: Reactor Operator Found Inside Reactor Water Cleanup Pump HX Cubicle,W/O Radiation Survey Meter Required for Use by Applicable Radiation Work Permit,On 870716 ML20238A7651987-08-21021 August 1987 Notice of Violation from Insp on 870803-07.Violation Noted:Plant Design Change 86-70,standby Gas Treatment Sys Mod,Released & Implemented But Did Not Completely Specify Design Verification Testing Requirements ML20214S4171987-05-22022 May 1987 Notice of Violation from Insp on 870221-0406 ML20214Q3151987-05-21021 May 1987 Notice of Violation from Insp on 870427-0501 ML20215L1101987-05-0505 May 1987 Notice of Violation from Insp on 870302-13 ML20205E2691987-03-23023 March 1987 Notice of Violation from Insp on 870101-0220 ML20205C7901987-03-17017 March 1987 Notice of Violation from Insp on 870105-09 ML20207S5431987-03-13013 March 1987 Notice of Violation from Insp on 870210-13 ML20207S7711987-03-10010 March 1987 Notice of Violation from Insp on 870112-16 ML20210A9421987-01-30030 January 1987 Notice of Violation from Insp on 861217-19 ML20207K1531986-12-31031 December 1986 Notice of Violation from Insp on 861021-1124 1998-08-06
[Table view] Category:TEXT-INSPECTION & AUDIT & I&E CIRCULARS
MONTHYEARIR 05000293/19990051999-10-0808 October 1999 Insp Rept 50-293/99-05 on 990726-0905.Violations Noted.Major Areas Inspected:Operations,Engineering,Maint & Plant Support IR 05000293/19990041999-08-27027 August 1999 Insp Rept 50-293/99-04 on 990610-0725.Non-cited Violations Noted.Major Areas Inspected:Aspects of Licensee Operations, Engineering,Maint & Plant Support ML20209G2331999-07-0909 July 1999 Insp Rept 50-293/99-03 on 990419-0609.Violations Noted & Being Treated as non-cited Violations.Major Areas Inspected: Operations,Maint,Engineering & Plant Support.Response to Main Transformer Fire by Fire Brigade Members Was Good PNO-I-99-026A, on 990518,main Transformer Was Damaged During Testing of Replacement Bushing While Unit Was in Refueling Outage.Current Refueling Outage Was Originally Scheduled to Be Completed on 990607,with Return to Full Power Operation1999-06-0101 June 1999 PNO-I-99-026A:on 990518,main Transformer Was Damaged During Testing of Replacement Bushing While Unit Was in Refueling Outage.Current Refueling Outage Was Originally Scheduled to Be Completed on 990607,with Return to Full Power Operation PNO-I-99-026, on 990518,fire Occurred at Pilgrim Station in Main Electrical Transformer.Licensee Requested off-site Firefighting Assistance.Resident Inspector Responded to Site Upon Notification of Event.Licensee Issued Press Release1999-05-19019 May 1999 PNO-I-99-026:on 990518,fire Occurred at Pilgrim Station in Main Electrical Transformer.Licensee Requested off-site Firefighting Assistance.Resident Inspector Responded to Site Upon Notification of Event.Licensee Issued Press Release IR 05000293/19990021999-05-17017 May 1999 Insp Rept 50-293/99-02 on 990308-0418.Two Level 4 Violations Occurred & Being Treated as Ncv.Major Areas Inspected: Operations,Maint,Engineering & Plant Support IR 05000293/19990011999-04-20020 April 1999 Insp Rept 50-293/99-01 on 990125-0307.Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support.Also Included Routine Core Insp of Security Program During Period of 990301-05 IR 05000293/19980101998-12-22022 December 1998 Insp Rept 50-293/98-10 on 981020-1208.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support,Including Implementation of Fire Protection Program IR 05000293/19980081998-12-0101 December 1998 Insp Rept 50-293/98-08 on 980907-1019.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support IR 05000293/19983011998-11-24024 November 1998 NRC Operator Licensing Exam Rept 50-293/98-301OL (Including Completed & Graded Tests) for Tests Administered on 981016- 23.Exam Results:All Applicants Passed All Portions of Exam IR 05000293/19982031998-11-24024 November 1998 Insp Rept 50-293/98-203 on 980928-1023.No Violations Noted. Major Areas Inspected:Capability of Selected Sys to Perform Safety Functions Required by Design Bases,Adherence of Sys to Design & Licensing Bases & Consistency of Configuration ML20154J8991998-10-0707 October 1998 Notice of Violation from Insp on 980726-0906.Violation Noted:Licensee Did Not Establish Measures to Assure Regulatory Requirements & Design Basis of Control Room High Efficiency Air Filtration Sys IR 05000293/19980071998-10-0707 October 1998 Insp Rept 50-293/98-07 on 980726-0906.Violations Noted.Major Areas Inspected:Operations,Maint,Engineering & Plant Support ML20239A1231998-08-28028 August 1998 Notice of Violation from Insp on 980609-0725.Violation Noted:From 1980 to 980609,licensee Failed to Maintain Provisions to Ensure That One Train of Cables Were Free from Fire Damage IR 05000293/19980061998-08-28028 August 1998 Insp Rept 50-293/98-06 on 980609-0725.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support IR 05000293/19980091998-08-20020 August 1998 Insp Rept 50-293/98-09 on 980713-24.No Violations Noted. Major Areas Inspected:Engineering Activities in Areas Including Evaluations to Address Operability Concerns,C/A Process & Actions Associated W/Findings from Previous Insps ML20237A3031998-08-0606 August 1998 Notice of Violation from Insp on 980427-0515.Violation Noted:From 960710-970427,licensee Elected Not to Monitor Performance or Condition of Control Rod Drive Sys Against Established Goals IR 05000293/19980051998-07-0909 July 1998 Insp Rept 50-293/98-05 on 980421-0608.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support.Concerns W/Fire Proctection Area Were Identified ML20247P0221998-05-19019 May 1998 Notice of Violation from Insp on 980225-0418.Violations Noted:Work Plan to Replace External Cooling Water Flexible Hoses to a Core Spray Pump Motor Not Commensurate with Complexity of Task.As Result,Physical Damage Occurred ML20247N8441998-05-19019 May 1998 Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000 (Ref 10CFR2.790(b) for Violations Noted During Insp on 980302-05 & 11-12 ML20248J3981998-05-14014 May 1998 EN-98-038:on 980519,notice of Proposed Imposition of Civil Penalty in Amount of $55,000 Issued to Licensee.Action Based on One Violation Involving Apparent Failures Associated W/Assessment Aids at Facility ML20217N5971998-04-27027 April 1998 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $165,000.Violations Noted:Between Jan 1995 & 970120 Licensee Failed to Take Prompt & Effective Corrective Action for Significant Condition Adverse to Quality ML20247M3891998-04-22022 April 1998 EN-98-032:on 980427,notice of Proposed Imposition of Civil Penalty in Amount of $165,000 Issued to Licensee.Action Based on Two Severity Level III Violations & One Severity Level III Problem Re Failure to Identify & Take C/As ML20217P7801998-04-0303 April 1998 Insp Rept 50-293/98-03 on 980302-05 & 11-12.Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Licensee Security Force Capability IR 05000293/19980011998-03-24024 March 1998 Insp Rept 50-293/98-01 on 980107-0224.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support ML20217F0101998-03-24024 March 1998 Notice of Violation from Insp on 980107-0224.Violation Noted:Nrc Identified That Condition Outside Design Basis of Plant Involving EDG Fuel Oil Storage Sys Was Not Reported to NRC within 1 Hour ML20202D2441998-02-0606 February 1998 Notice of Violation from Insp on 971111-980106.Violations Noted:Util Did Not Properly Evaluate Cause & Implement Corrective Actions to Preclude Repetition of Temporary Temp Detectors Deficiencies from Reactor Vessel Flange IR 05000293/19970131998-02-0606 February 1998 Insp Rept 50-293/97-13 on 971111-980106.Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support ML20197K1101997-12-17017 December 1997 Notice of Violation from Insp on 971006-10 & 1119.Violation Noted:Nine Penetrations Were Not Qualified in That Qualification Methodology Used by Boston Edison Had Not Been Validated by Test Results to Be Equivalent to Type Testing IR 05000293/19970121997-12-17017 December 1997 Insp Rept 50-293/97-12 on 971006-10 & 1119.Violations Noted. Major Areas Inspected:Eq Documents for EQ Equipment That Required Requalification Due to Containment Environ Changes Resulting from CS Flow Rate Reduction in 1988 ML20197H2411997-12-11011 December 1997 Notice of Violation from Insp on 970914-1110.Violation Noted:On 971001,licensee Identified That,Tagout T97-61-162 Was Incorrectly Prepared & Applied;Breaker 1021 Was Placed in Closed Vice Open Position as Required by Tagout IR 05000293/19970111997-12-11011 December 1997 Insp Rept 50-293/97-11 on 970914-1110.Violations Noted:Major Areas Inspected:Operations,Maint,Engineering & Plant Support IR 05000293/19970101997-11-26026 November 1997 Insp Rept 50-293/97-10 on 971104-07.No Violations Noted. Major Areas Inspected:Emergency Response Organization, Simulated Events,Mitigation Actions Emergency Declarations & off-site Agencies IR 05000293/19970991997-11-26026 November 1997 Correction to SALP Rept 50-293/97-99.Page 2 of Subj Rept Corrected PNO-I-97-072, on 971123,operators Initiated Plant Shutdown When Main Steam Isolation Valves AO-203-1C & AO-203-2B Were Declared Inoperable During Surveillance Test1997-11-24024 November 1997 PNO-I-97-072:on 971123,operators Initiated Plant Shutdown When Main Steam Isolation Valves AO-203-1C & AO-203-2B Were Declared Inoperable During Surveillance Test ML20198P8241997-11-0404 November 1997 SALP Rept 50-293/97-99 for Period 960407-970913 IR 05000293/19970081997-10-24024 October 1997 Insp Rept 50-293/97-08 on 970805-0913.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maint & Plant Support ML20198L9231997-10-21021 October 1997 Insp Rept 50-293/97-05 on 970514-0828.Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Engineering PNO-I-97-061, on 970922,util Informed Region I of Receipt of Internal Nuclear Safety Concern Potentially Involving Instance of Falsification of Control Room Log in 1989.Formal Investigation Initiated & Press Release Issued1997-09-23023 September 1997 PNO-I-97-061:on 970922,util Informed Region I of Receipt of Internal Nuclear Safety Concern Potentially Involving Instance of Falsification of Control Room Log in 1989.Formal Investigation Initiated & Press Release Issued ML20211A2741997-09-17017 September 1997 Notice of Violation from Insp on 970721-0801.Violation Noted:For Problem Rept PR97.9220,trip of B Residual Heat Removal Pump,Individual Performing Root Cause Analysis Was Not Formally Trained in HPI Methodology IR 05000293/19970071997-09-15015 September 1997 Insp Rept 50-293/97-07 on 970625-0816.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support IR 05000293/19970801997-09-12012 September 1997 Insp Rept 50-293/97-80 on 970721-0801.Violations Noted.Major Areas Inspected:Effectiveness of Processes for Identifying Resolving & Preventing Issues That Degrade Quality of Plant Operations & Safety ML20216G8181997-09-0404 September 1997 Insp Rept 50-293/97-09 on 970827-28.No Violations Noted. Major Areas Inspected:Licensee Access Authorization Program PNO-I-97-053, on 970826,special Security Insp Will Be Performed,That Will Examine Security Activities at Vermont Yankee,Pilgrim & Indian Point 3.Team Will Include Security Specialists from Region I & NRR1997-08-22022 August 1997 PNO-I-97-053:on 970826,special Security Insp Will Be Performed,That Will Examine Security Activities at Vermont Yankee,Pilgrim & Indian Point 3.Team Will Include Security Specialists from Region I & NRR IR 05000293/19970041997-08-0707 August 1997 Insp Rept 50-293/97-04 on 970505-23.No Violations Noted. Major Areas Inspected:Effectiveness of Licensees Efforts in Maintaining Design Basis of safety-related Sys ML20149K0401997-07-22022 July 1997 Notice of Violation from Insp on 970429-0624.Violation Noted:On 970602,station Services Dept Worker Tied Open Boiler Room Door Which Forms Part of Radiologically Controlled Area & Action Not Directed by RP Personnel ML20149K0431997-07-22022 July 1997 Insp Rept 50-293/97-03 on 970429-0624.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support ML20149K1291997-07-18018 July 1997 Notice of Violation from Exam on 970505-09.Violation Noted: Two SRO Applications Dtd 970418,documented Five Manipulations Based on Credit Taken for Multiple Manipulations Due to Power Change & One Should Be Credited ML20149K1311997-07-18018 July 1997 NRC Operator Licensing Exam Rept 50-293/97-06 (Including Completed & Graded Tests) for Tests Administered on 970505-09 ML20141K7841997-05-22022 May 1997 Notice of Violation from Insp on 970303-0428.Violation Noted:Function of 180/120 Voltage Regulating Transformers Not Correctly Translated Into Specification 1999-08-27
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I I NOTICE OF VIOLATION Boston Edison Company Pilgrim Nuclear Power Station Docket No. 50-293 License No. OPR-35 EA 84-112 On August 24, 1984, an NRC special safety inspection was conducted to review the circumstances associated with an unplanned occupational radiation exposure l l
of about 1.1 rem to the hand of a contractor worker during the disassembly of a '
control rod drive (CRD) in the CRD Repair Room. The radiation exposure was l identified by the licensee on August 18, 1984. Although the unplanned occupational radiation exposure was not in excess of the regulatory limit, a substantial potential for such an exposure did exist. ,
The radiation exposure occurred when the worker handled a highly radioactive 1 chip of material deposited in the spud end of the CRD Flush Tank tool tray.
Prior to the incident health physics technicians had performed surveys in the area of the tool tray and found the area to be exhibiting abnormally high j radiation dose rates (500 mrem / hour to 1000 mrem / hour). This information was transmitted to the on-coming health physics technician. Also, the health physics technician should have been aware that highly radioactive chips had previously been found lodged inside other CR0s. However, disassembly of the spud and of a CRD was allowed to be performed without on-going radiation surveys.
{ ' When the highly radioactive chip was identified after the disassembly of the spud end, the health physics technician did not adequately comunicate ,
j the radiological hazards of the chip to a worker. As a result, the worker picked up the chip with his hand, held it for several seconds, and then threw i it down. The chip was later detennined to have a contact radiation dose rate of about 1100 rem / hour.
During subsequent review of the CRD room the licensee found that (a) 12 other i previously unidentified, highly radioactive chips were present in the CRD I Repair Room, demonstrating inadequacies in control of general area radiation i levels and in radiation surveys, and (b) the procedure used by the workers for '
disassembly of the CRDs had not been reviewed and approved and had been in use for approximately two months, demonstrating inadequate licensee supervision of j on-going contractor activities.
I Further, it is not apparent that use of the approved procedure would have prevented this occurrence.
The approved procedure did not provide adequate precautionary statements regarding (1) the survey of components prior to handling, (2) the periodic checking of self-reading personnel dosimetry for inadvertent exposure (3) criteria for disposal and/or ultrasonic cleaning of CRD outer filters, (4) hold points for removal, disassembly, cleaning, inspection, storage and tools.and isolation of CR0 parts, and (5) dose rate criteria for CRD parts Such precautions should have been included in the approved procedure to satisfy procedure development guidance specified in the technical specifications and appropriate ANSI Standards.
8708290126 070825 PDR FDIA GUILD 87-450 PDR
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Notice of Violation In addition, the documented ALARA reviews for the Radiation Work Pemit (RWP) associated with the CR0 disassembly, and the RWP itself, did not provide guidance relative to allowable general area radiation dose rates in the room, did not provide guidance for allowable radiation dose rates on tools and equipment in the room, and did not provide guidance relative to allowable radioactive contamination of the room. As a result, the general area dose rates in the CR0 Repair Room were as high as 400 mrem / hour, although 20 mrem / hour was used for ALARA pre-planning. Further, contamination levels were as high as 650 mrad /
hour (removable) and radiation dose rates on tools used by workers for CR0 disassembly routinely exhibited contact radiation dose rates as high as 1000 mrom/ hour. Although these radiation and contamination levels made identifi-cation of chips difficult, work was routinely allowed to be perfomed in the CRD Repair Room under these conditions.
As a result of these deficiencies, a substantial potential existed for an occupational exposure in excess of the limits specified in 10 CFR Part 20.
In accordance with 10 CFR 2.201 and the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 49 FR 8583 (March 8,1984),
the violations are set forth below:
i A. 10 CFR 20.201(b) requires that each licensee make or cause to be i
- made such surveys as (1) may be necessary for the licensee to l comply with the regulations in this part, and (2) are reasonable under that maythebe circumstances present. to evaluate the extent of radiation hazards 10 CFR 20.201(a) defines a radiation survey 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.
Contrary to the above, -
- 1. On August 18, 1984, radiation surveys, necessary and reasonable to ensure compliance with the dosimetry supply provisions of 10 CFR 20.202 and the occupational exposure radiation limits of 10 CFR 20.101, were not made during disassembly of the spud end of a Control Rod Drive (CRD). Specifically, although the area of the tool tray at the spud end was exhibiting abnormally high radiation dose rates between 500 mrem / hour to 1000 mrem / hour and previous experience indicated that highly radioactive chips could become lodged in a CRD, radiation surveys were not performed during initial disassembly of the spud end.
- 2. Radiation surveys, necessary and reasonable under the circumstances i
to ensure compliance with the occupational exposure limits of 10 CFR 20.101 and the dosimetry supply provisions of 10 CFR 20.202 were not made in the CRD Repair Room in that on August 18, 1984, and for an undetermined smount of time prior to this date.12 highly radioactive chips present in the room were not identified, and I
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l Notice of Violation '
their associated radiological hazards were not evaluated. The 12 chips, located in various areas of the room, exhibited contact radiation dose rates of between about 600 rem / hour to 1200 rem / hour.
- 8. 10 CFR 19.12 requires in part that individuals working in or frequenting any portion of a restricted area be kept informed of the storage and )
use of radioactive materials or of radiation and be instructed in precautions or procedures to minimize exposure.
Contrary to the above, on August 18, 1984, a worker disassembling the spud end of a control rod drive was not adequately instructed by the health physics technician in precautions or procedures to minimize-his exposure in that the health physics technician located a highly radioactive chip in a room where work was being performed but did not warn the workers of its presence. As a result, the worker picked up a radioactive chip, measuring about 1100 rem / hour on contact, held it in his hand for several seconds. and then threw it down and thereby received an unplanned extremity exposure of about 1.1 rem. l C. Technical Specification 6.8.1, requires that written procedures be es-tablished, implemented and maintained that meat or exceed the re-
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i quirements and reconnendations of Appadix "A" of USNRC Regulatory Guide 1.33 and be reviewed by the Operations Review Committee (ORC)-
and approved by the ORC Chainnan prior to implementation. Appendix "A" of Regulatory Guide 1.33 (1972) reconnends that procedures for replacement and repair of Control Rod Drives be established.
Contrary to the above, from about June 24, 1984 through August 18, 1 1984, control Rod Drives were disassembled in the CR0 Repair Room and the procedures used during the disassembly had not been reviewed by the ORC and had not been approved by the ORC Chairman. ,
Collectively, these violations have been categorize.d in the aggregate as a Severity Level III problem (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Boston Edison Company is hereby required to submit to this office, with a copy to the Regional Administrator, Region I, within 30 days of the date of this Notice, a written statement or explanation, including for each alleged violation: (1) admission or denial of the alleged violation; (2) the reasons for the violation, if admitted; (3) the
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Notice of Violation i corrective steps which have been taken and the results achieved; (4) the cor-rective steps which will be taken to avoid further violations; (5) the date when full compliance will be achieved. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
FOR THE NUCLEAR REGULATORY COMMISSION
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ector
, Affice of Inspection and Enforcement Dated a1 Bethesda, Maryland this J W ay of November 1984 k