ML18004B905
| ML18004B905 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/14/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8708270218 | |
| Download: ML18004B905 (8) | |
See also: IR 05000400/1987014
Text
ACCESSION
NHR
FACIL: 50-400
AUTH. NAME
GRACEI J. N.
RECIP. NAME
UTLEYiE. E.
ULATORY INFORMATION DISTR HUTION SYSTEM (RIDS)
8708270218
DOC. DATE: 87/08/14
NOTARIZED:
NO
Bhearon Harris Nuclear
Power Planti Unit ii Carolina
AUTHOR AFFILIATION
Region
2
Office of Director
REC IP IENT AFFILIATION
Carolina
Power
5 Light Co..
DOCKET
05000400
BUHJECT:
Ack receipt of 870527 ltr informing
NRC of steps
taken to
correct violations noted
in Insp Rept 50-400/87-14.
NRC
/ determined
that violation occurred.
W/NRC assessment
of
licensee
response.
DISTRIBUTION CODE:
IEOID
COPIES
RECEIVED: LTR i ENCL g
SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES: Application for permit renewal filed.
05000400
RECIPIENT
ID CODE/NAME
PD2-1
P D
INTERNAL: AEOD
NRR MORIBBEAUID
NRR/DREP/EPH
NRR/DRIS DIR
OE-L-ZEH.ERMANiJ
FG FIL
RGN2
FILE
01
EXTERNAL:
LPDR
NBIC
COPIES
LTTR ENCL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
RECIPIENT
ID CODE/NAME
HUCKLEYiH
DEDRO
NRR/DOEA DIR
NRR/DREP/RPH
NRR/PMAS/ ILRH
OGC/HDS1
DEPY GI
NRC
COPIES
LTTR ENCL
2
2
1
1
1
2
2
1
1
1
1
1
1
1
1
0
TOTAL NUMHER OF
COP IEB REQUIRED:
LTTR
20
ENCL
20
ij
Carolina+ower
and Light Company
ATTN: '18r.
E.
E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P.
0.
Box 1551
Raleigh,
NC
27602
Gentlemen:
SUBJECT:
NRC
INSPECTION
REPORT
NO. 50-400/87-14
Thank you for your response
of May 27, 1987, to our Notice of Violation, issued
on April 27,
1987,
concerning activities
conducted
at your Shearon
Harris
facility.
We
have
evaluated
your
response
and
found that it meets
the
requirements of'0 CFR 2.201.
After careful consideration
of the
bases for your denial of the Violation, we
have determined, for the reasons
presented
in the enclosure
to the letter, that
the violation occurred
as
stated
in the Notice of Violation.
Therefore,
in
accordance
with 10 CFR 2.201(a),
please
submit to this office within 30 days of
the date of this letter,
a written statement
describing
steps
which have
been
taken to correct the violation and the results
achieved,
corrective steps
which
will be utilized to avoid further violations,
and the date
when full compliance
will be achieved.
The responses
directed
by this letter and its enclosure
are not subject to the
clearance
procedures
of the Office of Management
and Budget
as required
by the
Paperwork
Reduction Act of 1980,
PL 96-511.
We appreciate
your cooperation
in this matter.
Sincerely,
IF~61;<;,:
S}GHEE 0't:.
'. NELSON.GAVEL
J.
Nelson
Grace
Regi onal
Administrator
Enclosure:
Staff Assessment
of Licensee
Response
cc w/encl:
(See
page
2)
87082702i8
870814
ADOCK 05000400
6
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g[f
Carolina
Power and Light Company
cc w/encl:
K. A. Watson,
Vice President
Harris Nuclear Project
~D. L. Tibbitts, Director of Regulatory
Compliance
'J.
L. Willis, Plant General
Manager
bcc w/encl:
G~Sarth,
NRC Resident
Inspector
A;Upchurch, Chairman, Triangle J
Council of Governments
document Control
Desk
State of North Carolina
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ENCLOSURE
Staff Assessment
of Licensee
Response
Restatement
of Violation
required surveys to be
made
as
may be necessary
to comply with
and
are
reasonable
under
the
circumstances
to evaluate
the
extent of radiation hazards
that may be present.
Technical Specification 6.11 required 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'urvey
at
50%
Power
Test'lateau,
dated
February
11,
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).
Final
Safety
Analysis
Report
(FSAR) Section 14.2. 12.2.28
stated
that shield
surveys will be conducted
at the 505 and
1005 power plateaus
to establish
the
adequacy of shielding.
Contrary to the
above,
on February
23,
1987,
the
50% 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.
Shiel'd 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.
Licensee
Comment
0
The
licensee
denied
the violation as
stated.
The'icensee
stated
that the
shield survey conducted
was consistent with both the
FSAR commitment to perform
a shield test
survey
and the
requirement
to perform adequate
radiation
surveys for protection of personnel.
Survey procedure
(9105-S-12)
was
developed
using
even
though the use of this standard
was
not
a requirement of the
FSAR or the
NRC Safety Evaluation Report
(SER).
The
survey
procedure
was
conducted
in a satisfactory
and
ALARA manner,
such that
overall shielding integrity could
be evaluated.
Other routine
and special
surveys,
performed
as specified in plant procedures,
served to characterize
the
effectiveness
of shielding in other auxiliary plant locations not specifically
Enclosure
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.
NRC Res
onse
The violation
as
stated
concerns
the
inadequacy
of radiation
shield test
surveys
as conducted.
Verification of shield design criteria is essential
to
properly evaluate
radiological
hazards,
regarding
both personnel
exposure
and
equipment qualification criteria, for normal operations
and also for accident
conditions.
The
NRC considers
that
the elements
detailed in the
NOV were
necessary 'to adequately
perform comprehensive
shield verification surveys.
The
first two elements
in the Notice of Violation (NOV) were required
by plant
procedures.
We
acknowledge
that
the
licensee
was
not
committed to
Program for Testing Radiation Shields in Light Water Reactors
(LWR).
However,
during the inspection
and in the subsequent
response
to the
NOV, the
licensee
stated
that
ANSI Standard
6.3.1
was utilized for the
development
of the shield verification survey procedure.
It should
be noted
therefore
that,
in apparent
contradiction
to this statement,
this Standard
includes
the elements
detailed in the
NOV as
necessary
for an adequate
shield
verification survey.
Furthermore, it is our position that the general
area
radiation
surveys
did not
meet
the
requirements
for verification of shield
integrity.
The licensee
response
and the
subsequent
NRC evaluation to each
specific issue
regarding
inadequate
shielding verification detailed in the
are discussed
below.
Licensee
Comment - Issue
1
The licensee
agreed
that contact
readings
instead of one meter
measurements
from shield
surfaces
were
made
by several
surveyors.
The one meter distance
specified for vertical shield measurements
was
based
on the fact that in many
locations
contact
surveys
could not
be performed
because
of interference
with
components.
Where
contact
readings
were
made, it was
because
closer
accessibility
was possible
and
dose
rates
were higher than for the
one meter
reading.
This was
a more conservative
approach.
NRC Res
onse
The purpose of the shield survey
was to evaluate
the integrity of the various
shield
surface
and shield
areas.
A systematic
and consistent
survey of both vertical
and horizontal shield areas
was necessary
to complete
an
adequate
shield verification survey.
As noted
in the report details,
surveyors
who
conducted
contact
survey
measurements
at the shield surface
violated
Step 6.6
of
Procedure
9105.S-12,
which
required
surveys
to
be
conducted
at about
one meter.
The response
to the
NOV indicated that due to
interferences
with some
components
selected
dose rate measurements
were made at
one meter distance
from the shield surface.
It is our understanding that based
on interviews with the
persons
who
had
performed
the survey,
discrepancies
concerning
the methods for making measurements
was
due to lack of knowledge
by
those
persons
concerning
the
requirements
of the
procedure
rather
than
a
physical inability to survey
in the required
location.
In any
case,
the
Enclosure
discrepancies
were
not
documented
and
could
have
resulted
in erroneous
interpretation of the shield survey results.
Licensee
Res
onse - Issue
2
The licensee
disagreed
that areas
between
RBPs were not continuously monitored.
Shield Survey
Procedure
9105-S-12,
Step 6.11 requires
continuous monitoring of
radiation levels while proceeding
from one
RBP location to the next in addition
to recording radiation levels at
RBPs.
Technicians
performing the measurements
surveyed
the
RBP and moved to the next
RBP to repeat
the pattern.
While moving
between
RBPs
the
surveyors
continuously
monitored their instruments
while
moving between
RBPs.
NRC Comment
From discussion
with selected
technicians
who
had
performed
the
50% shield
surveys,
the
inspector
noted
that,
in
moving
between
RBPs
the
survey
instruments
were
moved in a straight path.
During the traverse
between
RBPs e
patterned
survey, similar to that performed at
each
RBP,
was not conduc'ted.
The failure to conduct
a patterned
survey between
the
RBPs could have resulted
in an inadequate
evaluation of the shield integrity above
and below the path of
the
survey
instrument
when
moving
between
RBPs.
Furthermore,
selected
technicians
indicated that if dose
rate results
obtained
during
a traverse
between
RBPs
were higher than at the
RBPs
themselves,
the readings
were not
recorded
on the
data
sheets.
We regard
the failure to properly
document
elevated
dose rate readings
between
RBPs
as
an example of an inadequate
shield
verification survey.
Licensee
Comment - Issue
3
SHNPP
commitments;
do
not
require
extrapolation
of the
50%
power
measurements
to rated full power.
Extrapolation of 50Ã dose rate to
100% power
dose
rates
could not
be technically justified
and
would not
be reasonably
accurate.
Results for the
50'4 power level were evaluated
with the
FSAR zone
maps
to determine if any significant problems
existed.
RBPs which exceeded
zone
designations
were
evaluated
and
corrective
action
is
being
investigated.
Also,
RBPs
on .the
Containment 286'perating
level
which
exceeded
the
FSAR zone
dose
rate limits were thoroughly evaluated
prior to
authorizing higher power levels.
The evaluation
included
an approximation
as
to what the
100%
power level
dose
rates
might be.
The evaluation
addressed
equipment
qualification
and
were thoroughly
reviewed
by the
Plant
Nuclear
Safety Committee.
NRC Res
onse
We
do not agree that the extrapolation of dose
rates
measured
at
50K power
level
to
dose
rates
expected
at
the
100%
power
was
not justified.
The
extrapolation of the
low power level
dose
rates
to indicate the general
dose
rates
expected at
100Ã power is reasonable
and considered
necessary
in planning
for shield
surveys
to be conducted
at higher
power levels.
Furthermore,
the
licensee's
response
to the
NOV indicated that extrapolation of dose
rates at
Encl osure
50K power to 100Ã power levels were utilized to estimate
dose rates at selected
RBPs
on the 286'evel
of containment.
This position is supported
in ANSI
Standard 6.3. 1.
Extrapolation of dose
rates
and comparison to
FSAR rated full
power radiation
zone
maps
would provide
an early indication of shield design
problems
and
allow for timely corrective
actions.
We believe that
such
extrapolations
are rather straight forward to perform and not at all uncertain
as
maintained
by the
licensee.
Also, at rated full power level,
areas
of
containment
may
be
inaccessible
due
to elevated
dose
rates,
and
thus
extrapolation of 50Ã values
would be utilized to indicate the expected full
power dose
rates for these
areas.
We consider
the failure to extrapolate
from
the
50%
power level
to the
rated full power level for all shield
survey
measurements'o
be
inadequate
for the completion of a comprehensive
shield
survey.
Licensee
Comment - Issue
4
FSAR 14.2. 12.2.28
does
not require
surveys
of auxiliary shielding at the
50% power test
plateau.
Only at the
100% power test plateau
gamma radiation
levels will be determined.
Other plant locations were in fact selected
for the
50K power survey.
These
included all plant elevations
in both the Auxiliary
and
Waste
Processing
Building at
the
Containment
wall
and
Containment
Other auxiliary shielding locations
were not surveyed
because
dose
rates
would not necessarily:be
a function of power level
but of,the
duration of local equipment operation.
The routine radiological
survey program
would characterize
the effectiveness
of the shielding during the post start-up
phase.
Additional auxiliary area
surveys
were not
deemed
ALARA nor was it
deemed
reasonable
under the circumstances
as stated
in 10 CFR 20.201(b).
NRC Res
onse
Inspection results
and your response
to the
NOV indicated the
SHNPP did conduct
auxiliary building radiation shield surveys at
50K power.
It is our position
that those
surveys
should
have
been
performed in accordance
with your shield
survey procedure.
Shield surveys of the auxiliary radiation source
areas
would
allow proper identification, evaluation,
and corrective action of any shielding
deficiencies, if noted.
We agree
that for some auxiliary shield areas
dose
rates
would not be
a function of power level
due to duration of local equipment
operation..
We
do not agree
that the
general
area
surveys
conducted
in the
auxiliary building areas
would adequately
evaluate shielding design.
Licensee
procedures
should also provide for surveys at
a later date in auxiliary areas
when
source
terms
develop in those
areas
that
have
no detectable
radiation
levels during startup.
NRC Conclusion
For
the above
reasons,
the
NRC staff concludes
that the violation occurred
as
stated.
I
)