ML18130A537

Responds to NRC 790815 Ltr Re Special Insp Conducted 790415- 19.Since Act Was Isolated & Committed by Single Employee Who Disregarded well-established Station Procedures,Act Is Not Indicative of Inadequacies in Station Procedure

ML18130A537
Person / Time
Site:	Surry
Issue date:	09/04/1979
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18130A538	List: ML18130A537 ML18130A539
References
NUDOCS 7909070441
Download: ML18130A537 (6)

Text

~--**

.. ~"<

---~'.

--,*i*

:~* ' ' *.:;':* .... ' ..

. *,\.

• -V-IRGINIA -ELECT:i:Ud,ANi;*j>cyw:E*R. C~M.PA~i

. ._... ;:,:... : . - . ., . ~- . .-. . .. ' , :** . . .-  ! .' . *. .,. ,[.

\'_, *:_':*:_../ :d, *-,:\l~~-~~_tt t:c~~I:}\~J'2.6i\:)--;{;*1.*- :\/

• ~. ,' . . ... . ',

• ~* */.. - *: . -.

.'I.

.: _. d.t_~ . -- *~ '.

• ** ' ., l

• ,' , ...  : -,. '  :~

• f'  : ** h ' .

. ~* ,; - . '-~.eptember

_4;::.1979-

~ ~

-.~*. ',:;' ~.- ;: .**~ ' *

• _..... >

. ~ . *;.'*

)

... ~- *.,.. *. .

' ' ~

• . . ~1i'~, Jri~e-/'1,~i.6 .rt~:di;~ 1 D"irectoi:/*:::*. ,.. -. *':**.*--**- - . , Sen.al.- l'io *. -676 * *- .

-_-Offic"e '*9f *Inspe_ction 'ani,i Enforcement'_*_ - -* __ - *- _,:.Cp'o/DLB: sci _--.-._<. --- -:: : , . .- -

, ,"_-/'.,- )i. .* S. _Nuclear iegul~*'-i;'ofy_*.cor:im:fss.iou**-*:*j ,.: .' :_ ': rio~ke*t* *No*.::sb-2fr{": -*

• * .';:,'*'_. :_i>.'._:::-;~~egiC>_n-;}r\--:-*:-:c:.:_::-*:***-<*..--'.**,. **.* '_-. - _*-. .:.:*_.*.'.:;*:; ,,*' ~fi~~~/:11~.\D.PR~j7,-: __

_ 101'.Hariett~.s*t:reet-,:,Suite*..310.0* **.'-- :'.  :,

• \~}a_>1t~:;_*:,:~01;g:t'a* -.-* *3o'3oj---':X .

_::::. .-:_:-\-. *'.,:: <* *

-* *:::nq~f)~\::})Jtr9:ir\.::::_. :-._:*-/f:'.* *

. i :* . .:;..fi~:is"\1.~ ~rt :ie:~p~ri~/-_to.*:;.~i'i~: le{f~-;\;f ~gust_ 15,::1979, r~gar4ing *a* spe.cia;i"*,1~:.:. *. - * -*

-.-__*:_*-~::*1~~t~~ti*:~;~{It;~f;t;~~~2tf1}[.J*l!-?1:!i~t-JJ{/~~!t!~-:;~::::~~-!?.!!!ri!~-:f!r:~ttf~:_,

.:sua~t_*:*t~f 1QCFR2.205~ -~_topy o( ~J'.i'i,c~*-_{;**c1;_ls6--*enci'~s-~d/has',b.een*}6r~r'q_e~ .to .* . , .

;:_/  :- \* :  ; -

H~/:V~~~cir:*,s~_e}~o:~*-Jr__.i *'<> .: ,-.- __ . , *_._:://:::,.. , -*,: . ,.__.:.* :_:'--->*-* . --,(f.* - -*, '

• ' *. .... ... . , ' ' ' ~

i.Yl~i:;tf;1rY: _:v~)~ts (<=> -"-

.. ;ic*e*Pli~~{/*,~:'

,.: '-*-::-- --:- ani:f}:to<l_'uct-ion .*,Oper~t_i.?ns./ .. * * .'.-:

~

• L,t~It;~f ****~<-<.:'j/~iORY*-~-ht£.*rlfl********* . . .,' .* .****,/_. *

.c.c: :M:t-.-*,,,*\:lbert'*Schwenccr.:. * *--  :>-:* -.-_,.. -*-:-

• - . . '*. ~'. - _';:::*~:.- .... _: ~ .-.*_ ..

. .:..*, -  :-: . -~, ,.. .-:,: .

~ .* C * * ', .'

'. -:.. :.-*.:* ~

.,*.: *. - ~ ... , - .- . *.'. ~ ..

• ~* _:-_ .. '

• :. . .,. *'.-* . ,/

_*-./~-. -,:_. .. ~ . *. .. - -*. ,:r*

- '- - . *~- ..

• *':°.

• .;-, -*.:._.M ,; ', ~., ' ..

~-* ...

,' ~

_: _., ~o9.:(}:zp'if~-( -_ -*, .-

RESPONSE TO IE SPECIAL INSPECTION OF APRIL 15-19 , 19 79 A. NRG COMMENT 10 CFR 20.lOl(b)(l) requires that the dose to the whole body of any indi-vidual in a restricted area shall not exceed 3 rems during any calendar quarter.

Contrary to the above, on April 14, 1979, an employee received a whole body dose of approximately 10 rems during an entry into the incore*instru-

• ment room.

This violation constituted an occurrence related to health and safety.

(Civil Penalty - $4,000)

RESPONSE

The above violation is correct as stated.

(1) Reason for Non-Compliance.

An individual violated existing radiological control procedures.

(2) Corrective steps which have been taken and the results achieved:

Proper administrative actions were taken against the individual_

involved.

(3) Corrective stens which ha~e been taken to avoid further non~compliance:

A service desk manned by a qualified Health Physics Technician has been established in an area leading to the restricted controlled area. Copies of Radiation Work Permits (RWP's), dose rate meters, survey maps and other information is readily available to all person-nel. This measure will reinforce existing procedures. A thorough review of the Health Physics Manual and existing administrative procedures required no additional changes.

(4) *The date when full compl'iancewili' be achieved:

Full compliance has been achieved.

B.

• NRC COMMENT Technical Specification 6.4.B. l(i) and 6.4.D require that stringent admini-_

strative procedures shall be implemented and followed to assure _adherence to the restriction placed on the entrance to a high radiation area and the radiation protection program. Section 1.3.F.4 of the facility Health Physics Manual states that any area posted with a radiation warning placard signifies the existence of a potential hazard and the placard instructions must not be violated. On April 14, 1979, the entrance to the Unit 2

e

• incore i"nstrument room was placarded with the following instruction:

"High Radiation Area - Prior Health Physics Notification Required for Entry.

Technical Specification 6.4.B.l(g) requires that a radiation work permit system shall be used to authorize and control work performed in high radiation .areas. Section. 1.3.F.5 of the facility Health Physics Manual requires issuance of a special Radiation Work Permit (RWP) for non-routine jobs or to cover unusual circumstances on a routine job.

Contrary to the above, on April 14, 1979, a worker entered the Unit 2 incore instrument room, a high radiation area, without prior notification of health physics personnel and without issuance of a special RWP to authorize and control this non-routine job. The worker was overexposed to approximately 10 rems during this entry.

This violation contributed to an occurrence related to health and safety.

(Civil Penalty - $4,000)

RESPONSE

The above violation is correct as stated.

(1) Reason for Non-Compliance:

An individual violated existing radiological control procedures.

(2) Corrective steps which have been taken and the results achieved:

Proper administrative actions were taken against the individual involved.

(3) Corrective SLeps which have been taken to avoid further non-compliance:

A service desk manned by a qualified Health Physics Technician has been established in an area leading to the restricted controlled area. Copies of Radiation Work Permits (RWP's), dose rate meters, survey maps and other information is readily available to all personnel. This measure will reinforce existing procedures. A thorough review of the Health Physics Manual and existing admini-strative procedures required no additional changes.

(4) The date when full compliance will be achieved:

Full compliance has been achieved.

C. NRC COMMENT 10 CFR 20.20(b), requires that each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part. 10 CFR 20.20l(a) defines a survey as "an evaluation of the radiation hazards ... under a specific set of conditions".

Contrary to the above, a survey adequate to comply with the radiation expousre limits of 10 CFR 20.101 was not made in that a worker entered the Unit 2 incore instrument room on April 14, 1979, and received an

C. NRC COMMENT (CONTINUED) exposure of approximately 10 rems.

This violation contributed to an occurrence related to health and safety.

(Civil Penalty - $4,000)

REPONSE The above violation is correct as stated.

(1) Reason for Non-Compliance:

An individual violated existing radiological control procedures.

(2) Corrective steps which have been taken and the results achieved:

Proper administrative actions were taken against the individual involved.

(3) Corrective steps which have been taken to avoid further non-compliance:

A service desk manned by a qualified Health Physics Technician has been established in an area leading to the restricted controlled area. Copies of Radiation Work Permits (RWP's), dose rate meters, survey maps and other information is readily available to all personnel. This measure will reinforce existing procedures. A thorough review of the Health Physics Manual and existing admini-strative procedures required no additional changes.

(4) The date when full compliance will be achieved:

Full compliance has been achieved.

D. NRC COMMENT Technical Specification 6.4.B.l(e) requires that any individual per-mitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the radiation dose*

rate in the area.

Contrary to the above, on April 14, 1979, a worker was permitted to enter the Unit 2 incore instrument room, a high radiation area, with-out the required radiation monitoring device.

This is an infraction.

(Civil Penalty - $3,000)

RESPONSE

The above infraction is correct as stated.

D. (CONTINUED)

(1) Reason for Non-Compliance:

An individual violated existing radiological control procedures.

(2) Corrective steps which have been taken and the results achieved:

Proper administrative actions were taken against the individual involved.

(3) Corrective steps which have been taken to avoid further non-compliance:

A service desk manned by a qualified Health Physics Technician has been established in an area leading to the restricted controlled area. Copies of Radiation Work Permits (RWP's), .dose rate meters, survey maps and other information is readily available to all personnel. This measure will reinforce existing procedures. A thorough review of the Health Physics Manual and existing admini-strative procedures required no additional changes.

(4) The date when full compliance will be achieved:

• Full compliance has been achieved.

E. NRG COMMENT .

10 CFR 20.403(b) requires that each licensee shall with.in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify by telephone and telegraph, mailgram, or facsimile, the Director of the appropriate NRG Regional Office of any incident which may have caused "exposure of the whole body of any individual to 5 rems or more radL.tion".

Contrary to the above, although telephone notification was completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, written notification of a whole body exposure of approximately 10 rems on April 14, 1979, was not transmitted to the*

Region II Director until April 17, 19 79.

This is a deficiency.

(Civil Penalty - $0)

RESPONSE

The above defiency is correct as stated.

(1) Reason for Non-Compliance:

Surry Power Station Technical Specifications require that written reports of this nature be accomplished within one working day.

10 CFR 20.403(b) requires that the Director of the appropriate NRC Regionai Office be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This apparent conflict contributed to this non-compliance *with directives.

E. (CONTINUED)

(2) Corrective steps which have been taken and the results achieved:

Employees involved in classifying and reporting this type of incident have been reinstructed in the disparity between 10 CFR 20 and Surry Power Station Technical Specifications and to insure that 10 CFR 20 be complied wj_th.

(3) Corrective steps which will be taken to avoid further non-compliance:

The action described in paragraph (2), above is adequate to insure avoidance of further non-compliance.

(4) The date when full compliance will be achieved:

Full compliance has been achieved.