ML18004B816
| ML18004B816 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/27/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-560 NUDOCS 8706010093 | |
| Download: ML18004B816 (6) | |
Text
REQUL TORY INFORNATIO'A DISTRIBUTI N SYBTEI'I (R IDS)-
"iCCESSION NBR: 8706010093 DOC. DATE: 87/05/27 NOTARIZED:
NO
'IL:50-400 Shearon Harris Nuclear Pouer Planti Unit 1> Carolina TH. Nhi~/E AUTHOR AFFILIATION BON> R. A.
Carolina Poiiier Zc Light Co.
REC IP. NANE RECIPIENT AFFILIATION Document Control Branch (Document Control Desk )
SUBJECT:
Responds to NRC 870427 ltr re violations noted in Insp Rept 50-400/87-14. Corrective actions:reviewed FSAR Zc regulatory commitments relative to performance oF shielo surveys ai 50/ power level.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: Qeneral (50 DI;t)-Insp Rept/Notice oF Vio ation Response DOCKET 05000400 NOTES: App licati on for permit reneua1 Fi led.
05000400 INTERNAL:
RECIP IENT ID CODE/NANE PD2-1 LA BUCI(LEY B ACRB DEDRO NRR ROE, II. L NRR/DREP/EPB NRR/DRIS DIR OGC/HDSi RES DEPY QI COPIES LTTR ENCL 1
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1, REC IP I ENT ID CODE/MARIE PD2-1 PD 4EOD ENF LIEBERNAN NRR/DOEA DIR NRR/DREP/RPB NRR/P
/ ILRB REC FIL QN2 FILE Oi
, COPIES LTTR ExCL 1
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LPDR NSIC 1
IiRC PDR 1
TOTAL NUI'IBER OF COPIES REQUIRED:
LTlR 23 ENCL 22
I Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, NC 27562 eV3 ~
~987 File Number:
SHF/10-13510E Letter Number'HO-870438 (0)
NRC-560 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen.'n reference to your letter of April 27, 1987, referring to I.E.
Report RII:
50-400/87-14, the attached is Carolina Power
& Light Company's reply to the violation identified in Enclosure 1.
It is considered that the attached response is satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Very truly yours, R. A. Watson Vice President Harris Nuclear Project RAW:bjb Attachment cc:
Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 8706010093 870527 PDR ADQCK 05000400 6
PDR MEM/HO-8704380/PAGE 110Sl
Attachment to CPSL Letter of Response to NRC I.E. Report RII:
50-400/87-14 Re orted Violation.'0 CFR 20.201(b) requires surveys to be made as may be necessary to comply with 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Technical Specification 6.11 requires that procedures for personnel radiation protection shall be adhered to for all operations involving personnel radiation exposure.
Startup Test Procedure SU"9105-S-12, Shield Test Survey at 50X Power Test Plateau, dated February ll, 1987, requires that the survey be performed about one meter from the wall (Section 6.6) and that the area between Radiation Base Points (RBPs) be continuously monitored (Section 6.11).
FSAR Section 14.2.12.2.28 states that shield surveys will be conducted at the 50X and lOOX power plateaus to establish the adequacy of shielding.
Contrary to the above, on February 23,
- 1987, the 50K shield survey was 'not adequately performed in that:
1.
Contact readings instead of one meter measurements from shield surfaces were made by several of the surveyors.
2.
Shield areas between RBPs were not continuously monitored.
3.
Exposure rate measurements at 50/ power were not extrapolated to rated full power.
4.
Surveys of auxiliary shielding associated with sources external to the containment building (e.g.,
chemical and volume control system),
including vertical and horizontal shield surfaces and labyrinths were not performed.
This is a Severity Level IV violation (Supplement IV).
Denial or Admission and Reason for The Violation'.
The violation as stated above is denied.
It is the position of CP&L that SHNPP was consistent with both the FSAR commitment to perform a shield test survey and 10 CFR 20.201(b) requirement to perform adequate radiation surveys for protection of personnel.
The survey procedure (9105-S-12) was developed using ANSI 6.3.1-1980 even though the use of this standard is not a requirement of the FSAR or the NRC SER. Additionally, shield test survey procedures from other utilities were used.
ALARA considerations played a key role in the development of the procedure, The procedure was conducted in a satisfactory and MEM/HO-8704380/PAGE 2/OS1
Denial or Admission and Reason for the Violation.'(continued)
ALARA manner such that overall shielding integrity could be evaluated.
Other routine and special
- surveys, performed as specified in plant procedures, serve to characterize the effectiveness of shielding in other auxiliary plant locations not specifically included in the Shield Test Survey.
Those surveys better evaluate dose rates which are not a function of power level but instead are due to the extent of local equipment operation.
CP&Ls response to the four areas of apparent violation concerning inadequate performance of the 50X Shield Test Survey procedure, 9105-S-12, are discussed separately below'.
Item 1:
Contact readings instead of one meter measurements from shield surfaces were made by several of the surveyors.
~Res onse:
BBNPP concurs that readings at some RBPs were contact-type measurements, but disagrees that this was contrary to the intent of the procedure.
The Shield Survey procedure instructs that dose measurements be made at "about one meter" (9105-S-12, Step 6.6),
whereas ANSI 6.3.1 states "as close to the shield section as is practical".
The approximate one meter distance specified for vertical shields was based
,on the fact that in many locations contact surveys cannot be performed because of interference with components, cable trays, piping, etc.
In those cases where contact measurements were recorded, it was because closer accessibility was possible and dose was higher than the one meter reading.
This is a more conservative approach and is, in our opinion, fully consistent with the Shield Survey procedure for taking surveys of vertical shielding.
Item 2:
Shield areas between RBPs were not continuously monitored.
~Res onse:
SHNPP disagrees that areas between RBPs were not continuously monitored.
The specific requi'rements in the Shield Survey procedure 9105-S-12, Step 6.11 are as follows:
"Continuously monitor the radiation levels while proceeding from one RBP location to the next in addition to recording radiation levels at RBPs."
The technicians performing the survey were instructed to survey the RBP then move to the next RBP and repeat the pattern.
Consistent with their instructions and with good health physics techniques, they monitored the instrument response continually while moving between RBPs.
As a result, they would be aware of significant changes in radiation levels It is our position that this method is consistent with the Shield Survey procedure for continuously monitoring radiation levels between RBP locations.
MEM/HO-8704380/PAGE 3/OS1
Denial or Admission and Reason for the Violation'(continued)
A total of 269 RBP locations were selected for survey.
They were spaced at suitably close distances from each other based on their distance from the reactor and taking ALARA into consideration.
SHNPP believes that a
sufficiently large pool of data exists from which to determine shielding adequacy and identify problem areas.
In addition, subsequent routine and special surveys would supplement this data.
Item 3:
Exposure rate measurements at 50X power were not extrapolated to rated full power.
~Res ense:
This statement is correct.
- However, SHNPP commitments in FSAR Section 14.2.12.2.28 do not require extrapolation of the 50X power measurement to rated full power.
Consideration was given during the development of the procedure to the use of a power correction factor but it was concluded that applying an assumed correction factor to the 50X dose rates or extrapolating 50X dose rates to 100X power would not produce dose estimates that could be technically justified or that had reasonable confidence. as to their accuracy.
Therefore, the procedure was written from the standpoint of comparing the 50X results "at face value" with the FSAR zone maps and determining if any significant problems exist at that level relative to 10 CFR 20 requirements for personnel protection from radiation exposures.
The identical process would be repeated at 100X power.
Shield Test Survey procedure 9105-S-12, Section 7.2 provided the acceptance criteria for evaluating the data.
Those radiation base points that exceeded the FSAR zone designations at the 50X power level were evaluated as Test Exceptions and where appropriate the need for corrective action is being investigated.
In addition, the base points on the operating level (286') of Containment that significantly exceeded their FSAR.zone dose rate were thoroughly studied prior to plant management authorizing higher power levels.
That evaluation, the results of which were discussed with the inspectors, included an approximation as to what the 100X power level dose rates might be.
The primary purpose of this evaluation was to address a concern about equipment qualification and whether or not any major design changes had been made during the construction phase that had not been reflected in revised FSAR dose rate zone maps.
These matters were thoroughly reviewed by the Plant Nuclear Safety Committee.
MEM/HO-8704380/PAGE 4/OS1
Denial or Admission and Reason for the Violation'(continued)
Item 4:
Surveys of auxiliary shielding associated with sources external to the Containment Building (e.g.,
chemical and volume control system),
including vertical and horizontal shield surfaces and labyrinths, were not performed.
~Res ense:
This statement is correct.
- However, SHNPP commitments in FSAR Section 14.2.12.2.28 do not require surveys of auxiliary shielding at the 50X power test plateau.
The FSAR specifically states that at the 100X power test
- plateau, "gamma radiation levels will be determined in various other plant locations".
Other plant locations were in fact selected for the 50X power survey.
These included all plant elevations in both the Auxiliary and Waste Processing Buildings at the Containment wall including Containment penetrations.
.It was intentionally decided not to survey other auxiliary shielding locations (e.g.
equipment cubicles and labyrinths) because dose rates observed would not necessarily be a function of power level but of the duration of local equipment operation (i.e.,
amount of contamination buildup in a system).
This decision was
.consistent with ANSI 6.3.1-1980 Section 2 where it states that testing of systems which do not contain sufficient radioactivity during the startup phase should be deferred until "radiation sources develop or are introduced in sufficient strength to allow meaningful measurements to be made."
The routine radiological survey program (daily, weekly, special RWP surveys, etc.) would characterize the effectiveness of the shielding during the post-startup phase.
Performing additional auxiliary area surveys was not deemed ALARA (10 CFR 20.1 (c)) nor was it deemed "reasonable under the circumstances" as stated in 10 CFR 20.201 (b).
In conclusion, CP&L has reviewed the FSAR and regulatory commitments relative to performance of shield surveys at the 50X power level and has concluded that the survey methology used and evaluations performed adequately satisfy those commitments.
MEM/HO-8704380/PAGE 5/OS1