ML18022A583
| ML18022A583 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/22/1987 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-586 HO-870516-(O), NUDOCS 8710270251 | |
| Download: ML18022A583 (4) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 87i0270251
~
DOC. DATE: 87/.10/22 NOTARIZED:
NO DOCKET FACIL: 50-400 Shearon Harris Nuclear Poeer Planti Unit ii Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION WATSON'. A.
Carolina Poeer 5 Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds.to NRC 870922 ltr re violations noted in Insp Rept 50-400/87-22. Corrective actions: shift order or radiation control personnel implemented to require tracking of MPC-h exposures.
DISTRIBUTION CODE:
IE01D COP IES RECEIVED: LTR J ENCL g SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response 1
NOTES: Application for permit renewal filed.
05000400 REC IP IENT ID CODE/NAME PD2-1 PD RGN2 EXTERNAL:
LPDR NSIC INTERNAL:
AEOD NRR MORISSEAUi D NRR/DREP /EP B NRR/DR IS DIR FILE 01 COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
RECIPIENT ID CODE/NAME BUCKLEY) B DEDRO NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ILRB OGC/HDSi RES DEPY GI NRC PDR COPIES
'TTR ENCL 2
2 1
1 1,
1 2
2 1
1-1 1
1 1
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 20
Carolina Power & Light Company HARRIS NUCLEAR PROJECT P.
O.
Box 165 New Hill, North Carolina 27562 OCT 22 198/
File Number'SHF/10-13510E Letter Number.'O-870516 (0)
C
'p 4
Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 NRC-586 Gentlemen'.
In reference to your letter of September 22, 1987, in which NRC disagreed with Carolina Power
& Light Company's denial. of the violation identified in I.E.
Report RII:
50-400/87-22, the attached is our revised reply to the violation identified in Enclosure l.
Carolina Power
& Light Company accepts the violation, and as requested, submits 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.
It
.is considered that the corrective actions taken are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
'ery truly yours, 87i02 5000400 87/022 PDR ADOCH 0 PDR 8
. A. Watson Vice President Harris Nuclear Project RAW:dj Attachment cc'.
Messrs.
B. C. Buckley (NRC)
G. Maxwell (NRC-SHNPP)
Dr. J. Nelson Grace (NRC)
MEM/HO-8705160/Page 1/OSl goi
((
Attachment to CP&L Letter of Response to NRC I.E. Report RII:
50-400/87-22 Re orted Violation:
10CFR20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in
- 10CFR20, and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
A survey is defined in 10CFR20.201(a) as an evaluation of the radiation hazards incident to the production,
- use, release,
- disposal, or presence of radioactive materials or
other sources of radiation under a specific set of conditions.
10CFR20.101(a) specifies the quarterly occupational radiation dose limits to the lens of the eyes and the skin of the whole body.
Contrary to the
- above, the licensee failed to perform adequate evaluations of individual exposures to noble gas in that
.algorithms used to covert thermolumine'scent dosimeter (TLD) readings to skin and lenses of the eye dose for personnel who made containment entries on June 17,
- 1987, and'efore were inappropriate for the noble gases present in containment.
The licensee used no other dose assessment technique to assess doses due to noble gases.
Corrective Ste s Taken and Results Achieved:
As stated in our letter of response dated August 21,
- 1987, a
review was performed of the radiation emitted and the relative concentrations of the noble gases found at SHNPP.
Xe-133 was determined to be the only nuclide for which underestimation of the skin dose from beta radiation by the TLD algorithm was a
concern.
Likewise, Ar-41, Kr-87, Kr-88 and Xe-138 were determined to be the nuclides of concern for calculating potential unassigned dose to the lens of the eye.
This evaluation showed that the maximum unassigned dose to any individual during the first two quarters of 1987 was less than 7 mrem to the skin and 1 mrem to the lens of the eye.
Such low
- doses, even on a per quarter
- basis, are below the ability of our dosimetry methods to measure with any reasonable degree of accuracy for any type of radiation.
They therefore, are considered insignificant and were not assigned to individual exposure records.
Corrective Ste s Taken to Avoid Further Noncom liance:
As an interim measure until all evaluations were completed and procedures
- changed, if
- needed, a
Shift Order for Radiation Control Personnel was implemented to require tracking of MPC-hour exposures for total noble gas concentrations in excess of 1.0 x 10-5 pCi/cc.
This action is complete.
MEM/HO-8705160/Page 1/OS1
Corrective Ste s
Taken to Avoid Further Noncom liance:
(continued) 2 ~
A revision to the TLD algorithm was made to ensure adequate assessment of lens of eye dose from noble gases.
This action is complete.
3.
Dosimetry procedures have been revised explaining the limitations of the TLD algorithm (i.e.,
the underestimation of beta skin dose from Xe-133).
This action is complete.
4.
Procedures will be developed and, implemented for calculating and assigning beta skin dose from Xe-133 when exposure conditions could result in a significant dose.
The procedure will include an action level at which tracking MPC-hours will begin.
This action will be completed by December 31, 1987.
Date When Full Com liance Will Be Achieved Full compliance will be achieved upon development and implementation of procedures as stated in No.
4 above.
It is currently projected that this action will be completed by December 31, 1987.
MEM/HO-8705160/Page 2/OS1