ML18009A297

Responds to NRC 891108 Ltr Re Violations Noted in Insp Rept 50-400/89-23.Corrective Action:Min of Four Decontamination Personnel Will Be Assigned 24 H Per Day During Fuel/Cask Handling to Maintain Cleanliness in Fuel Handling Bldg

ML18009A297
Person / Time
Site:	Harris
Issue date:	12/08/1989
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-690 HO-890137-(O), NUDOCS 8912130425
Download: ML18009A297 (12)

Text

ACCELERATED DISTRIBUTION DEMONS'GMTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

A CESSION NBR:8912130425 DOC.DATE: 89/12/08 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION RICHEY,R.B. Carolina Power & Light Co.

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

SUBJECT:

Responds to NRC 891108 50-400/89-23.

ltr re violations noted in Insp Rept DISTRIBUTION CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Environ & Radiological (50 DKT)-Insp Rept/Notice of Violate.on Res P ons NOTES:Application for permit renewal filed. 05000400

/ i RECIPIENT COPIES RECIPIENT COPIES A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 PD2-1 PD 1 1 D BECKER, D 1 1 D

INTERNAL: ACRS 2 2 AEOD/ANDERSON,R 1 1 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGDB NRR/DOEA/OEAB11 NRR/~RE/ PB11 4E4 1 1

2 1

1 2

NRR/DLPQ/LPEB10 NRR/DREP/PEPB9 D NRR/PMAS/ILRB12 1,

1 1

1 1

1 DOQ~AB RA T 1 1 ~

OGC/HDS 1 1 1 REG FILE 02 1 1 RES 1 1 GN2 DRSS/RPB 1 1 RGN2 FILE Ol 1 1 RGN4 MURRAY,B- 1 1 EXTERNAL: EG&G SIMPSON,F 2 2 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 R

D D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAS'ONTACI'HE.DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDt TAL NUMBER OF COPIES REQUIRED: LTTR 27 'ENCL 26

Carolina Power 8 Ught Company P. O. Box t65 ~ New Hitl, N. C. 27562 DEC 8 1989 R. B. RICHEY Manager Harris Nuclear Project File Number'. SHF/10-13510E Letter Number.'HO-890137 (0)

Document Control Desk NRC-690 United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS. NUCLEAR POWER PLANT DOCKET NO. 50-400 LICENSE NO. NPF-63 REPLY TO A NOTICE OF VIOLATION Gentlemen.'

In reference to your letter of November 8, 1989, referring to I.E.

Report RII: 50-400/89-23, the attached . is Carolina Power and Light Company's reply to the violation identified in Enclosure l.

It is considered that the corrective actions taken are satisfactory for resolution of the item.

Thank you for your consideration in this matter.

Very truly yours, R. B. Richey, Manager Harris Nuclear Project MGW:djs Enclosure cc: Mr. R. A. Becker (NRC)

Mr. S; D. Ebneter (NRC RII)

Mr. J. E. Tedrow (NRC SHNPP) 8912180425 891208 PDR ADOCj" 0 000400 I) PDC MEM/HO-8901370/1/OS1

Attachment to CPGL Letter of Res onse to NRC I.E.

Re ort RII: 50-400 89-23 Re orted Violation.'icensee Technical Specification 6.8 requires written procedures to be established, implemented, and maintained to cover the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Guide 1.33, Revision 2, February '1978, Appendix A

'egulatory radiation control procedures for access control to 'ecommends radiation areas including a radiation work permit system, radiation surveys, and personnel monitoring.

Licensee procedure, Plant Program Procedure PLP-511, Radiation Control and Protection Program, Revision 3, states in part, that routine radiation surveys of accessible plant areas shall be performed on an appropriate frequency, depending on the probability of radiation and contamination levels changing and the frequency of the areas visited. Furthermore, the procedure states, that surveys relating to specific operations and maintenance activities in support of radiation work permits (RWPs) shall be performed to keep the exposures ALARA and personnel informed of changing plant radiological conditions.

Licensee procedure AP-503, Entry Into Radiological Areas, Revision 5, requires personnel exiting the main radiation control area (RCA) to monitor themselves for contamination with a whole body monitor and if the monitor alarms, the workers are required to perform a frisk survey of the area indicated, and notify the Radiation Control Group if contamination is found during the frisk, or upon second alarm by the whole body contamination monitor.

Licensee procedure AP-503, Entry Into Radiological Areas, Revision 5, states in part, that each individual working in an RCA is responsible for complying with the instructions on the RWP and oral instructions given by Radiation Control personnel.

Contrary to the above, the licensee failed to follow radiation control procedures concerning area and personnel contamination surveys and RWP special instructions in that:

a ~ On August 9 and 11, 1989, the licensee failed to make radioactive contamination surveys at a frequency necessary to detect changing radiological conditions, in that, the clean area on the licensee's 286 foot fuel handling floor became contaminated causing personnel to become contaminated with radioactive material.

MEM/HO-8901370/2/OS1

b. On August 16, 1989, a licensee worker failed to perform an adequate personnel contamination survey .to detect low level

. radioactive contamination having an activity greater than the minimum detectable activity of the detector and notify the. radiation control group when the worker alarmed the whole body contamination monitor a second time.

C ~ On August 16, 1989, a licensee employee working in the RCA failed to comply with oral instructions given by radiation control personnel on the 286 foot elevation of the fuel handling building when .the worker began removing a contaminated concrete form prior to receiving authorization to begin work from radiation control personnel.

This is a Severity Level IV violation (Supplement IV).

Denial or Admission and Reason for the Violation'.

a. The violation is correct as stated.

The failure of two lifting straps during the handling of a spent fuel cask was suspected to have caused damage to the cask sealing surface. To reduce dose to the personnel performing an inspection of the cask, plans were made to remove the basket (a 3 R/hr source) from the cask. The basket was to be removed from the cask in the Cask Unloading Pool, moved across the floor on the of the Fuel Handling Building (FHB) and resubmerged in 286'levation the unit 2-3 transfer canals A Special Radiation Work Permit was, written for this evolution and, on August 9, 1989, radiation control personnel were stationed to monitor dose rates and airborne activity as the basket was moved. During two unsuccessfuL attempts to lift the basket, it was sprayed with water from the Cask Unloading Pool spray ring. A water mist rose about fifteen feet above the floor as this spraying was done. No spray was used during the third attempt when the basket was moved to the transfer canal. Since no airborne activity was observed during -the movement, no spread of contamination was suspected and no surveys were performed following the move. Two workers were contaminated in clean areas of the FHB.

Following the inspection discussed above,'he basket was to be placed back into the cask. Additional precautions, which included securing FHB ventilation, using a portable HEPA unit in the area adjacent to the basket's path, trying to reduce basket contamination by moving it back and forth in the transfer canal, and not using spray, were taken during this movement. Additional air sampling equipment was also used and, again, no significant airborne activity was detected. Gross masslinn surveys performed during and immediately following movement of the basket showed no contamination in the area. These contamination surveys were not documented. Since it was believed that adequate precautions had been taken to prevent the spread of contamination, no surveys were performed prior to restoring general access. Two low-level (200 cpm) shoe contaminations occurred in clean areas of the Fuel Handling Building.

MEM/HO-8901370/3/Osl

These contamination incidents resulted from a failure to perform the surveys needed to detect a change in radiological conditions.

b. The violation is not correct as stated. The violation is incorrect as stated in that the revision of the procedure in effect on August 16, 1989, did not require that the individual notify Radiation Control (RC) after the second whole body frisker alarm.

On August 16, 1989, a worker exited the Radiological Control Area (RCA) after twice alarming the whole body frisker at the exit point. The worker released himself from the RCA after failing to locate any contamination in excess of 100 cpm above background during a hand frisk using a HP-210 probe. This action was allowed by Revision 5 (Advance Change 5/1) of AP-503, "Entry into Radiological Areas" which was the governing procedure. The procedure in effect on August 16, 1989, did not require that the individual notify RC after the second body frisker alarm therefore, the violation was not caused by a failure to follow procedure.

When this individual alarmed the whole body frisker following a subsequent RCA entry, he was hand frisked by an RC Technician using an HP-210 and no contamination was located. After a second whole body frisker alarm a frisk was performed using a CM-7 (a large area, gas flow proportional detector) and contamination was detected on the right palm. An HP-210 reading of 100 net cpm was barely detectable at this location. After washing the area, a third whole body frisker alarm indicated contamination on the face and shoulder. This contamination also was barely detectable at 100 net cpm. The CM-7 was used to localize the contamination and, after the area was washed, the individual was able to pass a fourth frisk by the whole body frisker.

A subsequent investigation of the worker's two RCA entries concluded that he had probably become contaminated during the first ent'ry and had, therefore been outside the RCA with contamination levels just at the site limit. This violation resulted from the inability of the worker to detect the extremely low level of contamination present and a procedure which allowed individuals to release themselves following a whole body frisker alarm if contamination could not be detected during a hand frisk using an HP-210.

MEM/HO-8901370/4/OS1

C ~ The violation is correct as stated.

On August 16, 1989, two workers entered the Fuel Handling Building (FHB) to perform work in areas adjacent to the Cask Unloading Pool; Prior to entering the FHB, the'orkers stopped at the Radiation Work Permit (RWP) Office to inquire about conditions in the work area and radiological controls needed for performing the work. The RC Technicians in the office told the workers to sign

'in on a general RWP and contact the radiation control technician in the Fuel Handling Building prior to starting work. Information on radiological conditions at the work site was not available in the RWP Office since all survey information associated with spent fuel cask handling was being treated as safeguards information.

The workers located the FHB RC technician, who was performing a survey around the Cask Unloading Pool (CUP). They discussed the work, which was to remove concrete forms on the east and south

'ides of the CUP. To prevent any material from falling into the pooL, the workers indicated that they would need to place a plastic cover over the pool. The RC technician informed the workers that they could enter on the north and east sides of the pool, but the south side (a High Contamination Area) could not be entered until a more thorough contamination survey had been performed. It was the RC technician's understanding that the workers would only begin preparations for the job and he took smears on the south side of the pool and exited the area to have them counted. When the radiation control technician returned, he found that one of the workers had already removed part of the form on the east side of the pool. The form he had surveyed on the south side of the pool was contaminated to a level of 25,000 dpm/100 cm and the technician concluded that similar levels probably existed on the east side form. The RC technician stopped the job and told the workers to leave the area until a Special RWP with appropriate radiological controls could be issued to cover the work. Miscommunication between the workers and the RC technician concerning what work could actually be done prior to completion of the survey was the cause of this violation.

Contributing to this failure to communicate was the amount of work being performed by the RC technician in the Fuel Handling .Building and the RWP Office's lack of information concerning the radiological condi'tions in the FHB. The HP technician was. unable to take the necessary time to cover the work and the RWP Office could not assist in determining the radiological controls needed.

MEM/H0-8901370/5/OSL

Corrective Ste s Taken and Results Achieved:

a~ For both occurrences ,the following immediate corrective actions were taken'.

1. Radiological control boundaries were established in the Fuel Handling Building to prevent the further spread of contamination.

2. Surveys were performed to .determine the extent and level of contamination.

3 ~ Area decontamination was performed as, necessary.

4~ Personnel involved were decontaminated.

These corre'ctive actions were completed on August 12, 1989.

b. The individual was decontaminated and successfully passed the whole body frisker. -

This action was completed on August 16, 1989.

C ~ The job was stopped and the workers exited the area. This action was completed on August 16, 1989.

Corrective Ste s Taken to Avoid Further Violations'.

a~ The following actions have been taken:

A minimum of four decontamination personnel will be assigned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day during fuel/cask handling to maintain cleanliness in the FHB. Routine wipedowns of handrails and floor surfaces conducted by these personnel on the fuel handling deck have significantly reduced the number of contamination events in the FHB.

2. Prior to the next spent fuel receipt/cask handling evolution or January 31, 1990, whichever comes first. Procedure HPP-152, "Receipt of Spent Fuel" will be revised to incorporate the corrective actions to prevent further violations discussed in Section a.l.

3. Prior to the next basket 'movement evolution, or January 31, 1990, whichever comes first.

Procedural controls will be developed which will incorporate the radiological controls necessary to prevent recurrence of the violations discussed above.

MEM/HO-8901370/6/OS1

4. By January 31, 1990, Procedure HPP-035, "Posting and Barricading of Radiological Areas" will be revised to specify the actions required prior to restoring general access to plant areas in cases where access was restricted due to actual or potential radiological conditions.

These actions will be completed by January 31, 1990.

b. Because of observations of poor frisking technique by NRC and INPO, Advance Change 5/2 to AP-503, "Entry Into Radiological Areas" was issued on September 8, 1989. This procedure change requires that personnel who alarm a whole body frisker perform a hand frisk using an HP-210 and contact radiation control personnel if an alarm is received. If no contamination is detected with the HP-210, a second frisk with the whole body frisker is performed.

If the whole body frisker alarms a. second time, the individual is required to contact radiation control personnel. A frisk is then performed by an RC technician prior to release of the individual.

This action was completed on September 8, 1989.

C ~ The following actions have been taken'.

During cask/fuel handling (day shift) a control point will be set up on - Fuel Handling Building elevation 286'outh. The control point will be manned by a radiation control technician who is knowledgable of the radiological conditions in the area and will 'direct RC coverage of work in progress.

2 ~ Only cask receipt surveys will be considered as safeguards information. All other surveys performed in the FHB during fuel/cask handling evolutions will be documented in accordance with normal survey procedures. These surveys will be available to all personnel working in the FHB.

3 ~ Technical Support has assigned a job coordinator to the fuel/cask handling program to provide overall control of spent fuel receipt evolutions.

4~ Prior to the next spent fuel receipt/cask handling evolution or January 31, 1990, whichever comes first. Procedure HPP-152, "Receipt of Spent Fuel" will be revised to incorporate the corrective actions to prevent further violations discussed in Sections c.l, and c.2 above.

These actions will be completed by January 31, 1990.

MEM/HO-8901370/7/OS1

Date When Full Com liance will be Achieved:

Full compliance will be achieved by January 31, 1990.

MEM/HO-8901370/8/OS1