3F0586-16, Responds to Violations Noted in Insp Rept 50-302/86-11. Corrective Actions:Hydrolasing of Reactor Coolant Pump B Terminated Until Evaluation of Activity & Associated Radiological Hazards Performed
| ML20195D245 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/16/1986 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3F0586-16, 3F586-16, NUDOCS 8606020230 | |
| Download: ML20195D245 (5) | |
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o e' Florida Power CORPQR AT EON May 16, 1986 3F0586-16 Dr. J. Nelson Grace Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Cormission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 86-11
Dear Sir:
Florida Power Corporation (FPC) provides the attached as our response to the subject inspection report.
FPC disagrees with the classification of violations 86-11-01 and 86-11-02 as Severity Level IV and requests they be reduced to Severity Level V.
These do not fit specifically into any of the ex3mples given in 10 CFR 2, Appendix C, Supplement IV for Severity Level IV violations.
It is FPC's position these violations exhibit only minor safety or environmental significance, which is the criterion for Severity Level V.
The protection provided to workers for performance of hydrolasing was appropriate in that no internal ingestion of radionuclides occurred and no external body contamination occurred.
As recorded in the inspection report, calculations on postulated worst case airborne releases using very conservative assumptions (50,000 cfm release rate for three hours at the highest measured concentration at the point of release) resulted in negligible environnental effects.
FPC does not consider these violations resulted in effects with more than minor safety or environmental significance.
0606020230 860516
{DR ADOCK 05000302 PDR 1
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GEN ERAL OFFICE 3201 Thirty fourth Street South.P.O. Box 14042, St. Petersburg, Florida 33733 813-866-5151
May 16, 1986 3F0586-16 Page 2 FPC policy relating to contact between the NRC and Florida Power Corporation has been for official notification of NRC positions to be made through the Nuclear Licensing Department.
During the NRC review of this inspection, the notification of change in status of an apparent violation was made to the Nuclear Plant Manager.
FPC requests your cooperation in assuring notifications are made through the desired channels to assure appropriate management control is maintained.
Sincerely, Rolf C. Widell Manager, Nuclear Operations Licensing and Fuel Management AEF/feb Attachment
FLORIDA POWER CORPORATION
RESPONSE
INSPECTION REPORT 86-11 VIOLATION 86-11-01 10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to demonstrate compliance with the regulations and which are reasonable under the circumstances to evaluate the extent of radia-tion hazards that may be present.
10 CFR 20.201(a) defines survey to mean an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials.
10 CFR 20.106 requires that a licensee shall not possess, use, or transfer licensed material so as to release to an unrestricted area radioactive material in concentrations which exceed the limits specified in Appendix B, Table II.
Contrary to the above, the requirement to perform evaluations necessary to demonstrate compliance with 10 CFR 20 and reasonable under the circumstances to evaluate the extent of radiation hazards present was not met in that on February 22, 1986:
a.
the licensee failed to perform adequate evaluations of the radiological hazards associated with hydrolasing reactor coolant pump "B" and b.
the licensee failed to perform surveys necessary to demonstrate compliance with the release limits for concentrations of radioactivity in effluents to unrestricted areas as specified in Appendix B, Table II.
This is a Severity Level IV violation (Supplement IV).
RESPONSE
1.
Florida Power Corporation's Position:
Florida Power Corporation (FPC) cnncurs with the stated violation in that adequate evaluation of the radiological hazards associated with hydrolasing reactor coolant pump (RCP)
"B" was not performed, and that a survey was not perfonned.
However, it should be noted that RCP "A" had been hydrolased earlier with no increased airborne activity in the reactor building.
2.
Apparent Cause of Violation:
The cause of this violation is personnel error in that the survey results, which indicated dose rates on RCP "B" were up to three times those noted on RCP "A", were not factored into the evaluations of the hydrolasing of RCP "B".
3.
Corrective Action:
The hydrolasing of RCP "B" was terminated until an evaluation of the activity and associated radiological hazards could be performed.
The evaluation determined that further hydrolasing and decontamination of RCP "B"
was not necessary.
In addition, the personnel hatch was closed and the equipment hatch was closed (unbolted).
4.
Corrective Action to Prevent Recurrence:
OP-417, Containment Operating Procedure, was revised on April 8,1986, to require:
- 1) the equipment hatch be normally closed (unbolted) and removal of the equipment hatch will require concurrence of the Health Physics (HP)
Supervisor; 2) the equipment hatch and at least one personnel air lock door, or a temporary door be closed whenever purge exhaust is terminated;
- 3) the equipment hatch will be closed (unbolted) during any activity which has the potential to cause significant airborne activity as determined by the HP Supervisor; and 4) the Shift Supervisor on duty will notify the HP Supervisor any time purge ventilation flow is lost when the equipment hatch is not in place.
A procedure to control hydrolasing and other decontamination activities which have the potential to cause airborne radiological hazards will be developed and implemented by July 31, 1986.
5.
Date of Full Compliance:
Full compliance was' chieved on February 22, 1986.
VIOLATION 86-11-02 Technical Specification 6.8.1 requires written procedures to be established, implemented, and maintained to cover the activities recommended in Regulatory Guide 1.33, Appendix A, 1972.
Regulatory Guide 1.33, Appendix A,1972, requires written procedures for con-trol of radioactivity to include a Radiation Work Pemit procedure for limiting materials released to the environment and limiting personnel exposure.
Contrary to the above, while a Radiation Work Permit procedure was in place, it was inadequate to limit radioactive materials released to the environment and to limit personnel exposure in that it failed to ensure that when the scope of work changed, radiation protection considerations would be reviewed, evaluated, and approved prior to implementation of a Radiation Work Permit revision.
This is a Severity Level IV violation (Supplement IV)
RESPONSE
1.
Florida Power Corporation's Position:
FPC concurs with the stated violation in that HPP-106, Radiation Work Permit Procedure, f ailed to delineate requirements to ensure that when the scope of work changes, the necessary radiation protection considerations will be reviewed and approved prior to impl ementation of the RWP revision. FPC does note that the last sentence in the third paragraph on Page 7 of the inspection report should be revised in that the procedure containing the two statements (i.e., 2.5.1 and 2.6.2) is HPP-106, not RSP-106.
2.
Apparent Cause of Violation:
The cause of the violation is an inadequate procedure.
3.
Corrective Action:
Health physics personnel were informed of the event and the need to review radiation protection considerations when work scope changes.
4.
Corrective Action to Prevent Recurrence:
HPP-106 will be revised to address requirements for revising an RWP by June 30, 1986.
5.
Date of Full Compliance:
Full compliance was achieved on February 24, 1986 when corrective action was completed.
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