ML19281B022

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Notice of Violation from Insp on 780925-29 & 781010-11
ML19281B022
Person / Time
Site: Maine Yankee
Issue date: 11/15/1978
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19281B016 List:
References
50-309-78-18, NUDOCS 7904200155
Download: ML19281B022 (3)


Text

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h APPENDIX A NOTICE OF VIOLATION Maine Yankee Atomic Power Company Docket No. 50-309 Based on the results of an NRC inspection conducted on September 25-29 and October 10-11, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your license as indicated below.

Items A, B, C.1, D and E are In-fractions; Items C.2 and F are Deficiencies.

A.

Technical Specification 5.2.2, " Facility Staff," item d. states, "An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor."

Contrary to the above, on September 25, 1978, at 1800, the reactor contained fuel, was operating at power, and an individual qualified in radiation protection procedures was not on site.

8.

Technical Specification 5.12.2, "High Radiation Area," requires that each high radiaticn area in which the intensity of radiation is greater than 1000 mrem /hr be controlled in accordance with the requirements of Technical Specification 5.12.1, and that locked doors be provided to prevent unauthorized entry into such an area.

Contrary to the above, on September 25, 1978, the intensity of radiation near degas filter FL 33A, located on the 11' elevation of the Primary Auxiliary Building, was 1500 mrem /hr and locked doors or other equivalent barriers were not provided to prevent unauthor-ized entry into this area.

In addition, the area was not barricaded as required in Section 5.12.1, in that, the rope barricade and "high radiation area" sign were so located that an individual would have already entered an area where the intensity of radiation was measured to be 200 mrem /hr before passing the barricade.

C.

Technical Specification 5.8, " Procedures," requires that written procedures be established, implemented and maintained covering the activities referenced in Appendix "A" of Regulatory Guide 1.33, November,1972, and that these procedures be reviewed by PORC and approved by the Plant Superintendent.

7904200156

APPENDIX A 2

1.

Operations Procedure 1-12-4, " Containment Entry," Revision 4, issued December 8,1977, developed pursuant to A.9. of Ap-pendix "A" of Regulatory Guide 1.33, November,1972, requires that a Radiation Work Permit be obtained for entry into the containment.

Contrary to this requirement, on September 27,1978, two in-

'dividuals, the Plant Shift Superintendent and Shift Operating Supervisor, entered the containment while the reactor was opera-ting at power without obtaining a Radiation Work Permit (RWP),

and without using respiratory protective equipment.

This entry was also contrary to the requirements of Section 3.12 of the Radiation Protection Manual; contrary to the requirements of Health Physics Procedure 9.1.10, " Radiation Work Permits," and since the containment was an airborne radioactivity area, entry without respiratory protective equipment was also contrary to the requirements of Section 7.4.3 of Health Physics Procedure 9.1.6.

2.

Appendix "A" of Regulatory Guide 1.33, November,1972, requires in Section G.5 that procedures for personnel monitoring be pre-pared.

Contrary to this requirement, a written procedure has not been developed or reviewed by PORC or approved by the Plant Super-intendent that specifies the method for calibration of the whole body counter, which is used to monitor personnel.for internal disposition of radioactivity.

D.

10 CFR 20.201(b), " Surveys", requires that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 20. A " survey", as defined in Paragraph 20.201(a),

means "an evaluation of the radiation hazards incident to production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When ap-propriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive materials present."

Contrary to this requirement, on September 27, 1978, two individuals entered the containment, attempting to locate a primary coolant leak, without first making the required evaluation of the airborne concen-trations of radioactive materials present in order to permit compliance with the regulations of 10 CFR 20.103.

e 8

APPENDIX A 3

E.

Technical Specification 5.11, " Radiation Protection Program" states:

" Procedures for personnel radiation protection shall be prepared con-sistent with the requirements of 10 CFR Part 20 and shall ;e approved, maintained and adhered to for all operations involving personnel radiation exposure." The "?.adiation Protection Manual, Mtine Yankee Atomic Power Company," Revision 3, issued August 24, 1977, states in Section 4.11, " Personnel Exposure Investigations" that, "Whenever a situation occurs involving the suspected or known exposure of per-sonnel to ionizing radiation in excess of permissable limits specified in Section 2 of this manual, the incident shall be promptly investigated and personnel exposure evaluated." Section 4.11, also requires in part, that the Plant Superintendent or his designated alternate are members of the investigating committee and that a written report of the investigation include recommendations for corrective measures to prevent similar overexposures.

Section 2 in part 2.9.3 specifies an external radiation exposure of the whole body of 2000 mrem per calendar quarter.

Contrary to the above, during the third quarter of 1978, a suspected exposure of ionizing radiation of 2576 mrem for one individual and 2725 mrem for another individual, although investigated, was not investigated by a committee which included the Plant Superintendent or his designated alternate and a written report that contained re-commendations for corrective action to prevent similar overexposure was not issued.

F.

10 CFR 19.11, " Posting of Notices to Workers," requires that each licensee post current copies of those documents listed in 10 CFR 19.11 (a)(1), (2) and (3) or the licensee may, according to paragraph (b),

post a notice which describes the documents and states where it may be examined.

Paragraph (d) requires that such notices appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to and from any particular licensed activity location to which the document applies.

Contrary to the above, on September 27, 1978, a copy of the documents specified in 10 CFR 19.11(a)(1), (2) and (3) or a notice describing these documents, and where they may be examined was not posted by the licensee. A licensee representative stated that such a notice had been previously posted.