ML18004B937
| ML18004B937 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/11/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-580 HO-870494-(O), NUDOCS 8709160189 | |
| Download: ML18004B937 (6) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
/
ACCESSION NBR: 8709160189 DOC. DATE: 87/09/11 NOTARIZED:
NO FACIL: 50-400 Shearon Harris Nuclear Poeer Plant>
Unit 1> Carolina AUTH. NAME AUTHOR AFFILIATION WATSON> R. A.
Carolina Power 5 Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Responds to NRC 870814 ltr re violations noted in Insp Rept 5Q-400/87-14. Corrective actions: resurveging all areas except those known to have high dose rates unrelated to shielding integritg proposed.
DISTRIBUTION CODE:
IEO&D COPIES RECEIVED: LTR i ENCL i SIZE:
TITLE: Environ h Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES: Application for permit renewal filed.
05000400 REC IP IENT ID CODE/NAME PD2-1 LA BUCKLEY> B INTERNAL: AEOD/DOA NMSS/SGOB NRR/DREP/EPB NRR/
ILRB G F 02 RES DEPY GI RGN2/DRSS/EPRPB EXTERNAL:
LPDR NSIC
'OPIES LTTR ENCL 1
0 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
REC IP IENT ID CODE/NAME PD2-1 PD AEOD/DSP NRR/DOEA/EAB NRR/DREP/RPB OGC/HDS1 RES RGN2 FILE 01 RGN4 MURRAY> B NRC PDR COP IES LTTR ENCL 1
1 1
1 1
2 2
1 1
1 1
1 1
1 1
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 21 ENCL 20
Carolina Power 8 Light Co'mpany HARRIS NUCLEAR PROJECT P.
O. Box 165 New Hill, North Carolina 27562 SEP 11 iS87 File Number'SHF/10-13510E Letter Number:
HO-870494 (0)
NRC-580 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 Gentlemen.'n reference to your letter of August 14,
- 1987, in which NRC disagreed with Carolina Power 6 Light Company's denial of the violation identified in I.E.
Report RII:
50-400/87-14, the attached is our revised reply to the violation identified in Enclosure 1.
CP&L accepts the violation as stated.
Corrective measures to resolve this item could require an additional 2.5 man-Rem expenditure that we feel is for the most part unjustified and non-ALARA.
Therefore, we have proposed resurveying all areas except those we know to have high dose rates unrelated to shielding integrity.
Because of this exception, NRC concurrence is requested before proceeding with the plans described in the attachment.
Implementation of the corrective measures will be 60 days following NRC approval.
Thank you for your consideration in this matter.
V truly yours, R. A. Watson Vice President Harris Nuclear Project RAW:dj Attachment cc.'essrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC) 8709160f89 8709l1 PDR ADOCK 05000400 6
PDR MEM/HO-8704940/page 1/OS1 C
Attachment to CP&L 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 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).
FSAR Section 14.2.12.2.28 states that shield surveys will be conducted at the 50X and 100X power plateaus to establish the adequacy of-shielding.
Contrary to the above, on February 23, 1987, the 50X 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 50X 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).
MEM/HO-8704940/Page 1/OS1
~Res onse:
In CP&L's May 27, 1987 response to the violation, we disagreed that the four items listed above were essential to an acceptable shield survey test.
The NRC disagreed (notwithstanding specific comments) and stated that the items were reasonable elements of a shield survey.
As requested in NRCs August 14, 1987 letter, additional corrective measures are proposed as, described below.
Depending on the areas to be
- surveyed, this effort could require an additional 2.5 man-Rem expenditure that we feel is unjustified and non-ALARA.
Therefore, NRC concurrence with these plans is requested in order to help ensure that unnecessary man-Rem will not be expended to adequately address the violation.
Final implementation for corrective measures will be 60 days following NRC approval of said corrective measures.
Issue 1:
Contact readings instead of one meter measurements from shield surfaces were made by several of the surveyors.
Res onse/Corrective Measures'.
On 4/25/87, the 100Z shield test survey (procedure 9108-S-20) was performed.
As required and documented in Step 2.3 of that procedure, personnel were refamiliarized with the radiation base points, their locations, and the method of surveying and recording data.
Particular attention was given to surveying base points at a
1 meter distance in accordance with the procedure.
Therefore, we feel no further corrective action is needed concerning this issue.
Issue 2:
Shield areas between RBPs were not continuously monitored.
Res onse/Corrective Measures'.
SHNPP will resurvey and document at 100Z power utilizing the prescribed patterned survey method described in procedure 9105-S-12 except for the following areas.'(1) the 286'levation of the Reactor Containment Building (2) the 236'levation of the-Reactor Containment Building inside the secondary shield wall.
We already know these areas have very high dose rates (several Rem/hr) due to unshielded source
- terms, and approximately 2.5 man-Rem alone would be expended to re"survey these areas more thoroughly between the base points.
We feel it would be inconsistent with ALARA
[10CFR20.1(c)]
and would provide no additional information from the standpoint of determining shielding integrity.
MEM/HO-8704940/Page 2/OS1
Issue 3:
Exposure rate measurements at 50X power were not extrapolated to rated full power.
Res onse/Corrective Measures:
As discussed in Issue 1 above, the 100X power shield test survey was conducted on 4/25/87 using the correct survey method.
With this data ""in hand",
the need to extrapolate the 50X data to 100%%d power becomes unnecessary.
- However, SHNPP will use the results of the 5X, 50%
and 100X shield test surveys to develop, correlations between dose rates and reactor power'in each area.
Issue 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 onse/Corrective Measures'.
When SHNPP performs the retest of the 100X shield
- survey, (corrective measures for Issue 42),
we will evaluate the shielding of the following selected components:
1) 2)
3) 4)
5)
Charging Pump Cubicles (3)
CVCS Letdown Heat Exchanger Cubicle Volume Control Tank Cubicle CVCS Demineralizer Shields Boron Recycle Evaporator Cubicle This will be done in accordance with the 100X power shield test survey procedure.
This will allow SHNPP to evaluate auxiliary shielding for design
- purposes, and with regards to source terms that may exist in the Auxiliary Building.
MEM/HO-8704940/Page 3/OS1
M
~