ML18152B218
| ML18152B218 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/26/1988 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-591, NUDOCS 8810030116 | |
| Download: ML18152B218 (7) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA. 23261 September 26, 1988 U. S. *Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D. C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.
NO/GDM:pmk Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/88-16, 88-25.AND 50-281/88-16, 88-25 88:..591 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of August 25, 1988, in reference to the inspection conducted at Surry Power Station on May 2-6 and May 31 June 3, 1988 and reported in Inspection Report Nos. 50-280/88-16, 88-25 and 50-281/88-16, 88-25.
Our response to the violations described in the Notice of Violation is provided in Attachment I.
Payment of the assessed civil penalty is provided in Attachment II.
Please reference our letter dated July 13, 1988 (Serial No.88-387) which provides our response to the Notice of Violation issued in NRC Inspection Report Nos. 50-280/88-10 and 50-281/88-10.
The July 13 response provides our corrective actions as discussed at the July 6, 1988 enforcement conference regarding the violations identified in IEIR 50-280/88~25 and 50-281/88-25.
These actions are presently being implemented as discussed in the referenced letter.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact. us.
W.R. Cartwright Vice President - Nuclear Attachments cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA _30323 Mr. W. E. Holland NRC Senior Resid_ent Inspectpr Surry Power Station
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RESPONSE TO THE NOTICE OF VIOLATION ITEMS REPORTED DURING THE NRC INSPECTIONS ON MAY 2-6 AND MAY 31 - JUNE 3, 1988 INSPECTION REPORT NOS. 50-280/88-16, 88-25 AND 50-281/88-16, 88-25 NRC Comment:
During the Nuclear Regulatory Commission (NRC) inspections conducted on May 2-6 and May 31 - June 3, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
- 1.
Violations Assessed A Civil Penalty A.
10 CFR 20.lOl(b)(l) requires that during any calendar quarter the total occupational dose to the whole body not exceed 3 rems.
Contrary to the above, on May 27, 1988, an individual received 2.527 rems to the whole body while performing work in Unit 1 reactor cavity.
As a result, the individual's total dose for the second calendar quarter of 1988 was 3.279 rems.
B.
10 CFR 20.201(b) requires that each licensee shall make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201 (a) defines a "survey" as an evaluati.on 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.
C.
Contrary to the above, on May 27,
- 1988, prior to permitting three individuals to enter the Unit 1 reactor cavity to perform the cleaning and inspection of the reactor vessel flange area, an adequate evaluation was not performed.in that proper controls for personnel to mfnimize their individual exposures were not established.
10 CFR 19.12 requires that all individuals working in a restricted area be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area and be instructed in the health protection problems associated with exposure to such radioactive materials or radiation, and in precautions or procedures to minimize exposure.
Contrary to the above, on May 27,
- 1988, the three individuals who entered the Unit 1 reactor cavity to inspect and clean the reactor vessel flange were not made aware of the extent of radiation in the
.area and informed of precautions to minimize radiation exposures during the work.
D.
Technical Specification 6.4.B requires that radiation control procedures be provided and that the station radiation protection program be organized to meet the requirements of 10 CFR 20.
Health Physics Radiation Manual, Section 2, Part 1, Radiation Work Permits, dated January 21, 1988, requires in Step C.w.a that a Special Radiation Work Permit be used for the performance of a specific work activity in a specific location or area.
Contrary to the above, adequate procedures.for the preparation of a special radiation work permit were not provided to-ensure that Special Radiation Work Permit (RWP)
No.
88-1472 described the actual radiological conditions in the area of the reactor vessel flange cleaning and inspection work and that the RWP prescribed adequate controls and precautions to minimize the worker 1s exposure.
E.
Technical Specification 6.4.B.1.e requires that any individual or group of individuals permitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the dose rate in the area.
Health Physics Procedure H.P.-212, Locked High Radiation Area Access Control, dated April 19, 1984, requires in Section 2.1 that a dose rate meter is required for all entries into high radiation areas (greater than 100 mr/hr) and is required to be turned on continuously while in such areas.
. Contrary to the above, on Ma.y 3-4, 1988, three.different.groups.of individuals entered the posted high radiation area on the -27 foot elevation, Unit 1 containment, without being provided* with a radiation monitoring device.
F.
Technical Specification 6.4.B requires that radiatitin control procedures be provided and that the radiation.p.rotection prag.rc1.m be organized to meet the requirements of 10 CFR Part* 20.
Health Physics Procedure H.P. -3.7.1, Radiological Area Posting and Control, dated November 5, 1985, requires 4.2.8.3.C that areas be posted 11Respiratory Protection Entry 11 when. respirators are.. required by hea 1th phys.ics Radiation Work Permit.
Designation, in Section Requir~d for and/or the Contrary* to the above, on May 3~ 1988, areas inside Unit 1 containment on the
-27 foot elevation areas were not posted to indicate 11Respiratory Protection Required for Entry 11 where respirators were required by health physics.
G.
10 CFR 20.201(b) requires that each licensee shall make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Technical Specification 6.4.B*
requires that radiation control procedures be provided and that the station radiation protection
- program be organized to meet the requirements of 10 CFR Part 20 *
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Health Physics Procedure H.P.-3.3.2, Health Physics Survey -
Airborne
~Radioactivity, dated November 20, 1984, requires in Section 3.1.4 that all air:samples taken to assess airborne hazards to personnel shall be collected as near to the anticipated breathing zone as possible.
Health Physics Procedure H.P.-3.7.2, Health Physics Survey -
- Station, dated November 5, 1985, requires in Section 3.4.2 that general area grab samples shall be representative of the workers breathing zone.
Contrary to be above, on May 3, 1988, on three separate occasions, air samples taken in support of work in Unit 1 containment were not' taken in the worker's breathing zone.
Collectively, these violations have been evaluated in the aggregate as a Severity Level III problem (Supplement IV).
Civil Penalty - $100,00.0 (Assessed equally among the viol at ions.)
II. Violation Not Assessed A Civil Penalty Technical Specification 6.4.B requires that radiation control procedures be provided and that the station radiation protection program be organized to meet the requirements of 10 CFR Part 20.
Health Physics Procedure H.P.-2.3, Contaminated Equipment and Component Control, dated February 2,
- 1987, requires in Section 8.3 that all unattended radioactive material within the Restricted Controlled Area shall have as a minimum, the words "CAUTION, RADIOACTIVE MATERIAL" accompanied by a radiation symbol and the highest dose rate mR/hr affixed in a readily visible location.
Contrary to the above, on May 3, 1988, the licensee failed to adequately label four boxes containing radioactive material and two items of radioactive material located in radioactive material storage areas in that no radiation levels were indicated.
This is a Severity Level V violation (Supplement IV).
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-16, 88-25 AND 50-281/88-16, 88-25 II.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The *violation is correct as stated.
(2)
REASON FOR VIOLATION:
The violation resulted from a failure on the part of Health Physics technicians to ensure radioactive material labeling requirements were properly implemented and maintained.
In several instances, previously applied radioactive material labels had been obscured by additional layers of protective wrappings used for weather protection.
In these cases, the technician failed to ensure that new labels were affixed on the outer wrapping.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Technicians responsible for proper handling and storage of radioactive material have been instructed in procedures implemented to properly control this material.
Additionally, specific review of procedures governing proper radiological postings, surveys and work area controls was performed with all new contract technicians.arriving prior to the Unit 2 refueling outage.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further actions are deemed necessary regarding the specific violations described above.
However, additional programmatic corrective actions are still in progress as described in our July 13, 1988 response to Inspection Report 50-280, 281/88-10.
(5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full ~ompliance has been achieved.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-16, 88-25 AND 50-281/88-16, 88-25 I. A. B. C. D.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATIONS:
The violations are correct as stated.
(2)
REASON FOR VIOLATIONS:
The violations resulted from a failure to adequately plan for and implement the exposure controls to be utilized during the inspection and cleaning of the Unit 1 reactor vessel flange.
Pre-job briefings conducted prior to the work did not adequately address the use of stay times, the expected dose rates and the anticipated duration of the job.
Health Physics personnel assigned to provide exposure monitoring and controls during the job were not adequately prepared to minimize worker exposures.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
)
As discussed in our response to the Notice of Violation issued in Inspection Report 50-280,281/88-10, management actions have been taken to implement additional controls over radiation work activities.
Organizational and programmatic changes are being implemented at both the corporate and station levels related to the radiation protection program.
Furthermore, detailed pre-job briefing guidelines have been implemented to ensure proper review of radiological conditions and exposure controls.
For tasks to be conducted in areas where dose rates exceed 1,000,mrem/hr, these briefings require documented discussions to ensure clear understanding of radiological controls.
The briefings also establish actions to be taken if unexpected conditions are encountered.
New procedures have also been developed and implemented to more adequately
.defin~ and control the Radiation Work Permit program.
Requirements for radiologi-cal surveys, radiological controls and supervisory review are described in detail.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further actions are deemed necessary regarding the specific violations described above.
However, additional programmatic corrective actions are still in progress as described in our July 13, 1988 response to Inspection Report 50-280, 281/88-10.
(5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
1 I i;.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88~16, 88-25 AND 50-281/88-16, 88-25 I. E. F. G.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATIONS:
The violations are correct as stated.
(2)
REASONS FOR VIOLATION:
As we stated at the July 6, 1988 enforcement conference, the violations represent further examples of the failure of personnel to follow procedures.
In addition, contract Health Physics technicians were not adequately instructed in the specific procedural requirements related to these concerns.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Health Physics technicians providing job coverage duties or instruction to workers entering high radiation areas were reinstructed in the procedural requirements for these duties.
Specific review of procedural requirements, including radiological postings, surveys, and.work area controls, was performed with new contract Health Physics technicians arriving prior to the current Unit 2 refueling outage; In addition, the Station Manager has conducted meetings with station supervision, as well as the various station departments, to emphasize the importance of procedural compliance and the attendant accountability of acceptable performance in this area.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further actions are deemed necessary regarding the specific violations described above.
However, additional programmatic corrective actions are still in progress as described on our July 13, 1988 response to Inspection Report 50-280,.. 281/88-10....
. (5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.