ML18139B708

Responds to NRC 811201 Ltr Re Violations Noted in IE Insp Repts 50-280/81-25 & 50-281/81-25.Disputes Violation

ML18139B708
Person / Time
Site:	Surry
Issue date:	01/15/1982
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18139B707	List: ML18139B708 ML18139B709
References
669A, NUDOCS 8202050297
Download: ML18139B708 (2)

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• R.H.LEASBURG VxoE PnEsxnENl' n2 J ~}J ,*nc.t, January 15, 1982 A1'0 o *

'1 1 '-I NUCLEAR OPERATIONS Mr. James P. O'Reilly Serial No. 669A Regional Administrator NO/RMT:acm U. S, Nuclear Regulatory Commission Docket Nos. 50-280 Region II 50-281 101 Marietta Street, Suite 3100 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37

Dear Mr. O'Reilly:

Pursuant to a request from your staff concerning our response to your letter dated December 1, 1981 which forwarded inspection report nos. 50-280/81-25 and 50-281/81-25, the attached supplemental response is being submitted.

Should you have any questions or require any further information, please contact this office .

• Ver~

R.H. Leasburg Attachment cc: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing

• 8202050297 820129 OFFIG1AL COPY J.- -

• POR ADOCK 05000280 G POR

• e Revised Attachment Page 4 NRC COMMENTS:

C. As required by 10 CFR 20.203 (c)(3), the controls established for locked high radiation areas required by Technical Specification 6.4.B.1 shall be established in such a way that no individual will be prevented from leaving a high radiation area.

Contrary to the above: on September 22, 1981, the inspector observed that the door to the Unit 1 seal water filter room was locked closed with a chain and padlock. No provision was made in the controls established by the licensee (approved key control procedures) to ensure individuals entering such an area were provided continuous opportunity for egress.

This is a Severity Level VI Violation (Supplement IV.F).

SUPPLEMENTAL RESPONSE:

1. The violation is denied.

As stated in our original response dated December 31, 1981, the Administrative controls established by the station for high radiation

,, ar~as pro~id'e fufl -complfance with~,Technicai~'specificanons 'and 10CFR.20 requirements. The compensatory measure required to maintain proper administrative control of the Unit 1 seal water filter room (i.e. the chain and padlock), resulted in no increased potential for preventing egress from the area due to several facts. First, individuals entering the area must have a key to gain access. For convenience, such keys are normally attached to the individual's person in some fashion (usually on a string hung about the neck) in order to leave the hands free. The potential for loss of a key is thus minimal. Second, the area in question measures approximately 10 feet by 12 feet and it is unreasonable to assume that individuals entering the area would padlock the gate after ~ntering.

Continous visual surveillance of the gate is possible at all times when in the room. Finally, the "buddy" system employed at the station adds a measure of safety to all entries into high radiation areas _by providing an individual to assist or call for help in the event of a problem during such entries. We, therefore, must reassert our contention that the provisions of 10 CFR 20.203 (c) (3) were not violated.

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