IR 05000302/1981008

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Discusses IE Insp Rept 50-302/81-08.No Noncompliance Noted. Sufficient Potential Existed for Airborne Radioactivity to Warrant Measurement of Concentration of Radioactive Matls
ML20053D879
Person / Time
Site: Crystal River 
Issue date: 04/30/1982
From: Robert Lewis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Hancock J
FLORIDA POWER CORP.
References
NUDOCS 8206070406
Download: ML20053D879 (2)


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Florida Power Corporation ATTN:

Mr. J. A. Hancock Vice President Nuclear Operations P. O. Box 14042, Mail Stop C-4 St. Petersburg, FL 33733 Gentlemen:

Subject:

Report No. 50-302/81-08 Your letter of July 14, 1981, responding to the violations concerning activities under NRC Operating License No. DPR-72 contained disagreement with parts A and B.l.b of the Notice of Violation presented as Appendix A to Inspection Report No. 50-302/81-08. Your corrective actions and plans regarding Part A appears to be adequate.

We will examine those actions and plans during subsequent inspections. No additional written response is required.

With regard to part A, we continue to believe that sufficient potential existed for airborne radioactivity to warrant measurement of the concentrations of radio-active materials in air as required by 10 CFR 20.103(a)(3).. Because of the like-lihood of airborne contamination, the Radiation Work Permit prescribed that the decontamination work to be performed on the highly contaminated studs be per-formed under water. This technique is well known for the prevention of airborne contaminant generation, The work was required to be performed in the restricted airborne contamination area of a tent presumably because both airborne and surface contamination problems were contemplated. The individual performing.the work wore respiratory protective equipment although if surface contamination was the only~ concern, a simple face shield would have been adequate and facilitated

' work by being less restrictive.

The Technician's evaluation described in your response to the Notice of Violation was inappropriate in that no provision for such an evaluation is allowed by 10 CFR 20.103(a)(3). This requirement can only be satisfied by a measurement.

The bioassay requested to be performed by the NRC inspectors was asked to be performed to verify that no worker had been exposed to levels of airborne contamination in excess of the intake limits - a-determination which could not otherwise be made due to the lack of an air sample.

Based on the above considerations, it continues to appear that a violation of 10 CFR 20.103 occurred during decontamination of the studs.

With regard to part B.lb, the NRC agrees that no violation occurred, as cited.

It is, however, recommended that such bags have a seal to indicate to the user that function and the sanitary state of the device is intact. Our records will be revised accordingly.

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Florida Power Corporation

3q q We appreciate your cooperation with us.

Sincerely, l $'l R. C. Lewis, Director Division of Project and Resident Programs cc w/ encl:

D. G. Mardis, Acting Manager Nuclear Licensing T. Lutkehaus, Nuclear Plant Manager bcc w/ encl:

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