ML17345A831

Responds to Ltr Re Violations Noted in Insp Repts 50-250/91-08 & 50-251/91-08.Corrective actions:on-site Storage Containers Surveyed Immediately & Properly Labeled & Plant Procedure O-HPS-041 Revised

ML17345A831
Person / Time
Site:	Turkey Point
Issue date:	05/20/1991
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-91-138, NUDOCS 9105290189
Download: ML17345A831 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTPATION SYSTEM r

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:9105290189 DOC.DATE: 91/05/20 NOTARIZED: NO DOCKET FACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION GOLDBERG,J.H. Florida Power &. Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to ltr re violations noted in insp rept

,-50-250/91-08 & 50-251/91-08.Corrective actions:on-site storage containers surveyed immediately & properly labeled &

plant procedure 0-HPS-041 revised.

DISTRIBUTION CODE: IE01D,. COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Re ponse NOTES' A RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 PD 1 1 AULUCK,R 1 1 D lt INTERNAL: AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAB 1 1 DEDRO 1 1 NRR MORISSEAU,D 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9D 1 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DI 1 1 OGC/HDS3 1 1 EG FEE 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: EG & G/BRYCE, J. H. 1 1 NRC PDR 1 1 NSIC 1 1 D

A D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE XVASTE! CONTACT THE DOCUMEiNT CONTROL DESK,.

ROOi~1 P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAl~IE FROM DISTRIBUTIOiN LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22

P.O. Box14000, Juno Beach, FL 33408-0420 MAY 2 0 1991 FPL L-91-138 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket No. 50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 91-08 I

Florida Power and Light Company has reviewed the subject inspection report and pursuant to 10 CFR 2.201, the required response is attached.

If there are any'questions please contact us.

Very truly yours, J. H. Goldberg ~

President Nuclear Division JHG/DPS/ds Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Nuclear Plant 5'i0=25018~r ri0520 PDR. ADOCK 0.-000 .-0 arr FPL Group company

0 p

>l 0

ATTACHMENT REPLY TO A NOTICE OP VIOLATION RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 NRC Inspection Report 91-08 FINDING "Technical Specification 6.11.1 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

10 CFR 20.203(f) requires, in part, each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents. The label- is to bear the radiation" caution symbol and the words 'Caution, Radioactive Material,'nd 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 exposures.

Health Physics Surveillance Procedure O-HPS-041, Control of Radioactive Material Inside the Radiation Controlled Area, dated January 15, 1991, requires that containers with radiation levels equal to or greater than 1.5 millirem per hour (mrem/hr) on contact be labeled. This label shall indicate the radiation level, contamination or activity. level, the type or kind of material, the name and phone number of the owner/user of the radioactive material, desired disposition of the material, date of label issue, and signature of the qualified RPM issuing the label.

Contrary to the above, on February 25-26, 1991, the licensee failed to follow procedures for labeling resin liners having contact dose rates exceeding 1.5 mrem/hr which were maintained in a storage area east of the Old Compactor Waste Building."

RESPONSE TO FINDING FPL concurs with the finding.

2. This event was caused by non-cognitive personnel error by non-licensed plant personnel. The container labeling requirements of plant procedure O-HPS-041, "Control of Radioactive Material Inside the Radiation Controlled Area,"

were not met. Resin liners were stored in two of the three concrete "On-Site Storage Containers" observed by the NRC inspector. Because of the size of the concrete "containers" (10 feet tall, 8 feet diameter, 20 ton dry weight), FP&L

0 Sl

Reply to NOV 91-08 Page 2 of 2 personnel were treating the "containers" as structures within the Radiation Control Area (RCA)'. Such structures inside the RCA are posted in accordance with station procedures, but do not require labels under 10 CFR 20.203 (f) .

One of the three containers was empty at the time of the inspection, therefore in accordance with the 10 CFR 20.203(f)(3)(iii), the 10 CFR 203 labeling requirements were not required for that "container."

3 Corrective steps which have been taken and the results achieved:

a. The on-site storage "containers" were surveyed immediately and properly labeled with a Radioactive Material Tag. This was completed by February 26, 1991.

b. Other on-site storage containers were inspected to verify that they are properly labeled as required by the above regulation and plant procedure. No problems were found. This was completed by March 1, 1991.

c Plant procedure O-HPS-041, "Control of Radioactive Material Inside the Radiation Controlled Area," was reviewed and evaluated to ensure that the radioactive material labeling requirements in 10 CFR 20.203 (f) are clear and understandable. This was completed by March 1/ 1991 that the Procedure 0-HPS-041 was revised to note on site storage containers must be labeled.

e. This event and the applicable requirements have been reviewed by applicable Health Physics Shift Supervisors and Technicians. This was completed by May 3, 1991.

4 ~ Corrective actions which will be taken to avoid further violations include:

a ~ The above corrective actions are deemed to be sufficient to preclude recurrence.

5. The date full compliance will be achieved:

Full compliance was achieved on February 26, 1991.