ML18153B620
| ML18153B620 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/27/1989 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-079, 89-79, NUDOCS 8903060026 | |
| Download: ML18153B620 (6) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. R. CARTWRIGHT VICE PRESIDENT NUCLEAR February 27, 1989 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 Seri a 1 No.
NO/GDM:pmkRl Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/88-49 AND 50/281/88-49 89-079 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of January 27, 1989 in reference to the insrection conducted at Surry Power Station from December 12-16, 1988 and reported in Inspection Report Nos.
50-280/88-49 and 50-281/88-49.
Our response to the violations described in the Notice of Violation is provided in the attachment.
The intent of the corrective actions identified in our response to violation 11 B 11 is to assure that radiation hazards are properly identified and addressed prior to work performance.
These actions include the issuance of a new multiple/special dosimetry procedure, training of HP technicians on the new procedure, reiteration to HP personnel on the importance of strict RWP enforcement, and increased involvement of HP supervision in the RWP preparation process.
In addition, HP personnel were reinstructed to develop RWP and dosimetry requirements based on the current job assessment and survey results to ensurE the radiological controls are adequate.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
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U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station
NRC Comment:
RESPONSE TO NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED ON DECEMBER 12-16, 1988 INSPECTION REPORT NOS. 50-280/88-49 and 50-281/88-49 During the Nuclear Regulatory Commission (NRC) inspection conducted on December 12-16, 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 violations are listed below:
A.
Technical Specification 6.4.D requires that radiation control procedures be followed.
Health Physics Procedure HP-5.4.50, "Temporary Shielding" dated April 28,
- 1988, contains guidance on shielding and provides, in attachments to the procedure, forms to be utilized to give detailed instructions on shielding placement and attachment.
A copy of Attachment 3 of Health Physics Procedure HP-5.4.50, contained in Temporary Shielding Request 88-55 and completed specifically for shielding the reactor cavity drain line on the
-27 foot elevation of the Unit 1 containment, requires in step 3 that temporary shielding shall be attached with ties, stainless steel, wire or red tape.
Step 3 also states that if tape is used, it will not be placed directly on the pipe.
Contrary to the above, on December 14, 1988, temporary shielding placed at various locations on the reactor cavity drain line located on the -27 foot elevation in Unit 1 containment was not fastened with ties, wire or tape.
Also, on December 15, 1988, the temporary shielding had been secured in place with tape, but the tape was placed directly on the pipe.
This is a Severity Level IV violation (Supplement IV).
B.
10 CFR 20.201(b) requires each licensee to 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 11 as an evaluation of the radiation hazards incident to the production,
- use, release, disposal or presence of radioactive materials or other sources or radiation under a specific set of conditions.
10 CFR 20.202 requires each licensee to supply approprinte personnel monitoring equipment to specific individuals and requires the use of such equipment.
Technical Specification 6.4.D requires that radiation control procedures be foll owed.
Health Physics Procedure HP-3.1.3, "Personnel Dosimetry - Dosimetry Issue and Dose Determination," dated July 27, 1988, requires in step 4.7.3.2 that the licensee evaluate the need for extremity badges when the expected exposure to the hands and forearms or feet and ankles is equal to or greater than one rem per hour and the extreMity to whole body dose (12 inches from the contact dose rate) ratio is 5:1 or greater.
Contrary to the above, the licensee failed to evaluate adequately the extent of the radiation hazards present in that, on December 14, 1988, personnel performing decontamination operations in the Unit 1 reactor cavity generated decontamination rags with radiation level readings up to 8 rem per hour while reviews of survey data and the reactor cavity conditions prior to initiating the job did not cause plant personnel to anticip~te such problems and those assigned to the job were not cognizant of the problem as it developed.
The inadequate evaluation also resulted in the licensee's failure to comply with radiation control procedures in that personnel performing decontamination operations in the Unit 1 reactor cavity were not issued extremity dosimetry.
This is a Severity Level IV violation (Supplement IV).
A.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-49 AND 50-281/88-49
- 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
- 2.
REASON FOR THE VIOLATION:
The temporary shielding in question was installed by a temporary shielding request (TSR) and proper installation was verified by a Quality Control inspector.
Subsequent to the initial installation, however, the shielding was evidently adjusted and not properly re-secured.
Since the shielding was already in place, the individual sent to re-attach the shielding did not read the TSR nor was QC notified to reverify the shieldin9 was properly attached.
- 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The improperly attached red tape was removed and the shielding was properly secured as required by TSR 88-55.
The use of red tape on stainless steel pipe has been evaluated and it has been determined that it would not be harmful to the stainless steel surface.
- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Personnel who supervise individuals assigned to shielding installation, i.e., installers, HP technicians and QC inspectors, have been instructed to inform their staffs that shielding is to be installed exactly in the manner described in the TSR.
In addition, the QC department has been requested to review the remaining temporary shield installations to assure they are installed in accordance with the applicable TSR.
- 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The shielding in question was properly secured on December 16, 1988.
The QC department will complete the review of temporary shielding installations for compliance with the applicable TSR by March 8, 1989.
B.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-49 AND 50-281/88-49
- 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
- 2.
REASON FOR THE VIOLATION:
- 3.
A radiation work permit (RWP) was issued which authorized the use of an automated system for the decontamination of the Unit 1 reactor refueling cavity.
Since the system was not able to access the cavity seal ring area, decontamination was performed by hand scrubbing and wiping.
This evolution was not authorized by the RWP and consequently had not been considered by Health Physics or ALARA when required dosimetry and surveys were prescribed.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
When the Health Physics technician noted increased readings on the teledose dosimeters assigned to the persons performing the decontamination, he stopped the job and an investigation was initiated.
Based on surveys of the cleaning rags and by recreating the decontamination operation, extremity exposures were determined, and these exposures were entered into the individuals' dosimetry records.
On December 18,
- 1988, Health Physics Procedure HP-5.1.22 11 Dosimetry Requirements for Work Under an RWP 11 was issued which defines the criteria to be used to determine the need for multiple or special dosimetry.
Training of Health Physics technicians on this procedure was completed on January 5, 1989.
By memorandum,dated January 16, 1989, Health Physics Shift Supervisors were informed of the need to* assure that RWP requirements are enforced.
Additionally, a 11 RWP Special Instruction Sheet" was issued to the Health Physics shift supervisors.
The instruction sheet is completed by each shift supervisor following receipt of the pre-RWP survey data, and the information is used by the RWP writer to complete the RWP.
- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
As noted above, the training of Health Physics Technicians on special dosimetry, the enforcement of Rv!P requirements and the use of the 11 RWP Special Instruction Sheet" are the steps that have been taken to avoid further violations.
The increased involvement of HP supervision in the RWP preparation process will provide an additional evaluation of work to be performed in radiation areas.
This review will enhance the identification of potential exposure hazards and prescribe additional compensatory actions and/or special dosimetry as necessary.
- 5.
THE DATE WHEN FULL COMPLIANCE WAS ACHIEVED:
Full compliance was achieved nn January 16, 1989.