ML17279A570

Responds to NRC 870902 Ltr Re Violations Noted in Insp Rept 50-397/87-24.Corrective Actions:Outside Radioactive Matl Storage Area Inspected by Health Physics Personnel on Weekly Basis

ML17279A570
Person / Time
Site:	Columbia
Issue date:	09/25/1987
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-87-253, NUDOCS 8709300425
Download: ML17279A570 (10)

Text

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RECElVED Washington Public Power Supply System NRC 3000 George Washington Way P.O. Box 968 Riohtand, Washington 99352-0968 $ Q@k-5000 I'l8l SEP P l A )l: Oq September 25, 1987 G02-87-253 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.CD 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 87-24 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter, dated September 2, 1987. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, an explanation of our position regarding the validity of the violation is provided.

Should you have any questions regarding our response, please contact Mr.

P. L. Powell, Manager, WNP-2 Licensing.

Very truly yours, C

+ G.~ C.~ rensen, Manager Regulatory Programs c

JDA/bk Attachment cc: JB Martin, NRC RY NS Reynolds, BCP8R RB Samworth, NRC DL Williams, BPA 399 NRC Site Inspector - 901A

Appendix A Page 1 of 2 APPENDIX A During an NRC inspection conducted on August 3-6, 1987, a violation of NRC requirements was identified. In accordance with the "General Statement. of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:

A). 10 CFR Part 20.203(f)(1) and (2) state: "Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents. (2) A label required pursuant to paragraph (f)(1) of this section shall bear the radiation caution symbol and the words 'CAUTION, RADIOACTIVE MATERIAL'r 'DANGER, RADIOACTIVE MATERIAL'. It shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposure."

Contrary to the above, on August 4, 1987, Shipping Container No. 88255, located on the loading dock outside the southwest end of the Radwaste Building, contained licensed radioactive material in excess of the limits specified in 10 CFR Part 20, Appendix C, was not labeled and did not contain information which would permit individuals working in the vicinity of the container to take precautions to avoid or minimize exposure.

This is a Severity Level V Violation (Supplement IV).

Validit of Violation The Supply System acknowledges the validity of the violation. The labels were blown off due to weather conditions (sun, heat, wind, etc.)

Previous actions (surveillance frequency) taken to protect outdoor radioactive material labels from extreme environmental conditions appear to be inadequat .

Corrective Ste s Taken/Results Achieved

1. Plant personnel took immediate action to re-label the containers.

2 The outside radioactive material storage area is now inspected by Health Physics personnel on at least a weekly basis.

3. Radioactive material container labeling and Health Physics tour inspection assignment have been discussed during Health Physics group meetings.

4. These actions assure that these containers are properly labeled at all times. The weekly inspection of this area will not be discontinued unless it assurance is replaced by a mechanism which provides at least the same that the containers will be properly. labeled at all degree of times.

Appendix A Page 2 of 2 Corrective Action to be Taken Pla~t personnel are in the process of evaluating other means to achieve a permanent solution to this problem including:

1. Continued experimentation with different labeling media, protective coverings and affixing methods or;

2. Maintenance of a separate log, for all containers stored outside, which would contain all pertinent information associated by container number.

Area pos'tings would include a special i'nstruction referring to the log.

44 Date of Full Com liance The evaluation will be completed by October 15, 1987.

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDB)

~ a l ACCESSION NOR: 8709300425 DOC. DATE: 87/09/25 NOTARIZED: NO . DOCKET

~

FACIL: 50-.397 NPPSS Nuclear ProJect Unit 3 Naehington Public Pone 05000397 AUTH. NAME AUTHOR AFFILIATION SQRENBENi G. C. Washington Public Poeer Supply System REC IP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 870902 ltr re violations noted in Ins'p Rept 50-397/87-24. Corrective actions: outside radioactive matl storage inspected bg health physics personnel on weekly bas i s.

DISTRIBUTION CODE: IEOiD COPIES RECEIVED: LTR ~ ENCL I SIZE: 3 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES REC IP IENT COP I EB ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD i i SAMWORTHe R 2 2 INTERNAL: ACRB 2 2 AEOD i i DEDRQ i NRR MQR I SSE*Ue D i i NRR/DOEA DIR i NRR/DREP/EPG i i NRR/DREP/RPB 2 NRR/DRIB DIR i i NRR/PMAB/ ILRB i i OE LIEBERMANe J i OGC/HDS2 i RE5 FILE $ i RES DEPY GI i i 5 ~ILE Oi i TERNAL: LPDR NRC PDR i i NB IC TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

Washington Public Power Supply System 3000 George Washington Way P.O. Box 968 Richiand, Washington 99352-0968 (509)372-5000 September 25, 1987 G02-87-253 Docket No. 50-397 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF"21 NRC INSPECTION REPORT 87-24 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated September 2, 1987. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, an explanation of our position regarding the validity of the violation is provided.

Should you have any questions regarding our response, please contact Mr.

P". L. Powell, Manager, WNP-2 Licensing.

Very truly yours,

<<,~>Wc ~

~ Regulatoryrensen, G.~ C.

~

4~

~)

Manager Progr ams JDA/bk Attachment cc: JB Martin, NRC RV NS Reynolds, BCP8R RB Samworth, NRC DL Williams, BPA - 399 NRC Site Inspector - 901A S709300425 870925 PDR ADOCK 05000397 8 PDR al

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Appendix A Page 1 of 2 APPENDIX A During an NRC inspection conducted on August 3-6, 1987, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:

A). 10 CFR Part 20.203(f)(1) and (2) state: "Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents. (2) A label required pursuant to paragr aph (f)(l) of this section shall bear the radiation caution symbol and the words 'CAUTION, RADIOACTIVE MATERIAL'r 'DANGER, RADIOACTIVE MATERIAL'. It shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposure."

Contrary to the above, on August 4, 1987, Shipping Container No. 88255, located on the loading dock outside the southwest end of the Radwaste Building, contained licensed radioactive material in excess of the limits specified in 10 CFR Part 20, Appendix C, was not labeled and did not contain information which would permit individuals working in the vicinity of the container to take precautions to avoid or minimize exposure.

This is a Severity-Level V Violation (Supplement IV).

Validit of Violation

,The Supply System acknowledges the validity of the violation. The labels were blown off due to weather conditions (sun, heat, wind, etc.)

Previous actions (surveillance frequency) taken to protect outdoor radioactive material labels from extreme environmental conditions appear to be inadequat .

Corrective Ste s Taken/Results Achieved

1. Plant personnel took immediate action to re-label the containers.

2 The outside radioactive material storage area is now inspected by Health Physics personnel on at least a weekly basis.

3. Radioactive material container labeling and Health Physics tour inspection assignment have been discussed during Health Physics group meetings.

4. These actions assure that these containers are properly labeled at all times. The weekly inspection of this area will not be discontinued unless it is replaced by a mechanism which provides at least the same degree of assurance that the containers will be properly labeled at all times.

Appendix A Page 2 of 2 Corrective Action to be Taken Plant personnel are in the process of evaluating, other means to achieve a permanent solution to this problem including:

1. Continued experimentation with different -labeling media, protective coverings and affixing methods or;

2. Maintenance of a separate log, for all containers stored outside, which would contain all pertinent information associated by container number".

Area postings would include a special instruction referring to the log.

Date of Full Com liance The evaluation will be completed by October 15, 1987.