ML17250A635

Responds to NRC 800717 Ltr Re Violations Noted in IE Insp Rept 50-244/80-06.Corrective Actions:Procedure Established to Obtain Permission to Deviate from Radiation Work Permit

ML17250A635
Person / Time
Site:	Ginna
Issue date:	08/07/1980
From:	White L ROCHESTER GAS & ELECTRIC CORP.
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17250A634	List: ML17250A635
References
NUDOCS 8009240192
Download: ML17250A635 (6)

Text

C illi~i(Ssi~!IIII!ililizur~iiII ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649 LEON D, WHITE. JR. TKI EPIIOMK VICE PIIESIOEMT AREA COOK 7IS 546-2700 August 7, 1980 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406

Subject:

IE Inspection No. 50-244/80-06 R. E. Ginna Nuclear Power Plant, Unit No. 1 Docket No. 50-244

Dear Mr. Smith:

This letter is in response to your July 17, 1980 letter received July 21, 1980 concerning the inspection conducted at Ginna Station April 29-May 2, 1980 by Mr. Serabian of your office. Your letter stated that it appeared that one of our activities was not being conducted in full compliance with USNRC requirements, as quoted below. This letter contains information concerning this activity. Further, information is also provided concerning the deviation from industry practice discussed on page 1 of your letter.

"Technical Specification 6.11, 'Radiation Protection Program', states, in part, 'Radiation'control procedures shall be'prepared and made available to all station personnel or other persons who may be subject to radiation exposure at the station... The radiation protection program shall be organized and maintained to meet the requirements of 10 CFR Part 20,... The program shall be adhered to for all operations involving personnel radiation exposure.'.

Procedure HP-4.3, 'Work Permit Use', Revision 14, requires in Section 6.1.5 that each person working under a Radiation Work Permit (RWP) shall comply with the RWP in all respects.

Contrary to the above, on May 1, 1980, two individuals working under RWP No. 1, at Motor, Control Panel 1-C, did not comply with the RWP in all respects, in that they removed their protective work gloves, which were required by the RWP."

8000240

ROCHESTER /AS AND ELECTRIC CORP. SHEET NO. 2 DATE August 7, 1980 Mr. George H. Smith, Chief Qi RESPONSE The activity cited above was a procedural noncompliance and did not involve any'adiation exposure of any significance. The two individuals workfng at Motor Control Center 1-c in the Auxiliary Building who removed their gloves were performing delicate work on high voltage circuit breakers and were aware of low contamination levels in the circuit breaker enclosures and the conditions of the work permit. However, they decided to remove their gloves for better dexterity. Prior provisions to permit this deviation from the work permit had not been arranged, although it would have been possible to make such arrangements following a survey of contamination levels by the Health Physics Section and issuance of an appropriately worded work permit. Implementation of this procedure was discussed that afternoon following the inspection, in the "Plan-a-log" meeting, an informa-,

tion meeting normally held twice daily during a refueling maintenance outage, attended by group foremen and staff from all groups working on site. Those attending were instructed to pass along this information to those working for them. A letter discussing this activity was also issued on May 6, 1980, and was distributed to all plant groups and posted in several areas including the radiation access control point.

2. "Procedure A.1, 'Radiation Control Manual', Revision 14, requires in Section VI.A., 'Access to Controlled Areas', that smoking, chewing, or eating are strictly prohibited in con-trolled areas.

Contrary to the above, on May 1, 1980, four individuals were chewing gum while in controlled areas (i.e., the Auxiliary Building and the Reactor Containment)."

RESPONSE

The activity cited above was a procedural noncompliance and did not involve any radiation exposure of any significance. The occurrence resulted from thoughtlessness by the individuals as they entered the con-trolled'area. When this activity was noted, they were personally instructed on the rule prohibiting this. Although this rule is included in the health physics orientation, greater emphasis of the. rule is now being provided by the training personnel in the health physics orientation. In addition, a sign has been placed at the entrance to the controlled area stating that drinking, eating, smoking and gum chewing are prohibited beyond that point. This activity was discussed in the Plan-a-log meeting and in the May 6, 1980 letter mentioned in item 1 above.

~l SHEET NO.

ROCHESTER GAS AND ELECTRIC CORP. 3 DATE August 7, 1980 Mr. George H. Smith, Chief The deviation from standard industry practice which involved glove removal prior to removal of other protective clothing was a result of a change

. in control point location in the reconstruction of the locker room and control point area. The work permit sign-in area had been moved to the inside of the controlled area. Individuals were removing their gloves to'ign out on the )

work permits. To prevent recurrence all work permits will require that two sets of gloves be used, the first set to be removed prior to sign out, and the second after removing the rest of the protective clothing. This method was discussed in the Plan-a-log information meeting and May 6, 1980 letter, and is also covered in the health physics orientation sessions.

The inspe'ction report contains no information that is considered proprietary .

Very truly yours, L. D. White, Jr.