ML19093A408

Response to a Letter of 11/11/1977 in Reference to the Inspection Conducted on 10/04-10/07/1977 and Reported in IE Inspection Reports 05000280/1977029 & 05000281/1977029

ML19093A408
Person / Time
Site:	Surry
Issue date:	12/06/1977
From:	Stallings C Virginia Electric & Power Co (VEPCO)
To:	O'Reilly J NRC/RGN-II
References
IR 1977029
Download: ML19093A408 (5)

Text

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Attacbn1ent 519/111177 Page 1 of 4 J

RESPONSE TO NON-CO:t-IPLIANCE ITEX REPORTED IN IE INSPECTION REPORT NO. 50-280/77-29 AND 50-281/77-29

- NRC COHHENT A. Technical Specification 6.4.D requires, in part, that radiation con-trol procedures be followed, Health Physics Procedure No. HP 3 .4-2 limits fixed contamination of respirators ready for reissue to less than 0.2 mrem/hr.

Contrary to the above; on October 5, a survey of seven respirators ready for reissue revealed three with fixed contamination levels ranging from 0.3 to 0.4 mrem/hr above background.

RESPONSE

A. CORRECT AS STATED CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

All respirators were checked to insure that their fixed con,-

tamination levels were less than .2 mrem/hr. An investigation of the cause of this violation has revealed that the respirators in question were probably placed in plastic bags by the contract labor force working in the laundry area without being properly surveyed. As a result of this probable cause, respirators are now taken to a separate, low

- background area to be surveyed and prepared for issue by Vepco Health.

Physics personnel only. During maintenance periods, where contract laborers are hired to assist in the laundry area, they are not allowed to participate in respirator surveys or packaging. As an *additional administrative check of the respirator program, a plant Health Physicist has been assigned to do a daily random check of respirators ready for issue for contamina'tion levels and to document his results. The Results Achieved are to provide greater assurance the respirators *ready for issue are within the established contamination limits.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER NON-COMPLIANCE:

A separate room is being constructed to be used solely for respirator cleaning and storage. This room will be manned by Health Physics personnel and will provide much more stringent controls over respirator cleaning, surveying, and reissue. ~aterial is on site and the room will be in us~ by early 1978.

DATE WHEN FULL COMPLIANCE-WILL BE ACHIEVED:

Full compliance has been achieved.

J'

519/111177 Page 2 of 4 NRG COMMENT

- B. Technical Specification 6.4.D requires, in part, that radiation control procedures be followed. Health Physics Radiation Protec-tion Manual Section 2.4.C includes procedures which require that a physician be immediately contacted if contamination is found in the eyes, mouth, or an open wound.

Contrary to the above, contamination was found in an employee's mouth on September 26 and no physician was contacted.

B. Response CORRECT AS STATED CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

During the incident in question, in which an employee had been internally contaminated, the Health Physics Supervisor, after evaluation of the incident, had recommended to the Station Manager that medical attention was not necessary. It is felt that his evaluation was correct and the actual violation is that the Health Physics Supervisor did not receive approval from the Station Nuclear Safety and Operating Committee to deviate from an approved procedure (Health Physics Radiation Protec-tion Manual). As a result of this incident, the applicable section of the Health Physics Radiation Protection 1-lanual will be changed to state thc1t a physicfan w111 he contacted if deemed necessa:l[y by the Health Physics Supervisor or Health Physicist. This change will be completed by December 30, 1977 CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER NON-COMPLIANCE:

None DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

C, NRC COMMENT Technical Specification 6.4.D requires, in part, that radiation control procedures be followed. Health Physics Radiation Protection Manual, Section 2.10.A.2 requires areas with smearable beta-gamma activity in excess of 220 disintegrations per minute (dpm) per 100 square centi-meters to be roped off ana.posted.

Contrary to the above, surveys taken October 6 revealed two non-roped or posted areas with smearable activity of 450 and 900 dpm per 100 square centimeters.

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519/111177 Page 3 of 4

c. Respons_e

e. C. CORRECT AS STATED CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The areas in question were decontaminated to a level less than 200 dpm per 100 square centimeters. The areas were adjacent to marked contaminated areas as discussed in the details section of the report.

Daily contamination surveys are done to check the adequacy of barriers for contaminated areas. The daily contamination surveys of October 5 and October 6 had found these two areas and they were decontaminated.

The intent of section 2.10.A.2 of the Health Physics Radiation Protection Manual is to rope off and post those areas which are greater than 220 dpm per 100 square centimeters and are not able to be decontaminated immediately.

As a corrective action, the frequency of contamination surveys were in-creased during plant shutdown periods. :i.Zesults achieved have been to further decrease the possibility of contaminated areas not being identified.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER NON-COMPLIANCE Section 2.10.A.2 of the Health Physics Radiation Protection l1anual will be changed to clarify its intent.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

December 30, 1977 D. NRC COMMENT Technical Specification 6.4.B.1 requires, in part, that "the entrance to each radiation area in which the intensity of radiation is equal to or greater than 1000 mrem/hr shall be provided with locked barricades to prevent unauthorized entry into these areas".

Contrary to the above, the entrance to the Boron Evaporator Filter area (Gate No. 7) was found unlocked on October 6, 1977. The most recent survey performed (October 5) indicated radiation levels in this cubicle as high as 5000 mrem/hr.

D. Response D. CORRECT AS.STATED CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The Operations Department has created a daily check list that is filled out by an_operator on his plant tour. This check lists all the greater than lR gates as to their as found, as left, and changed condi-tion. Any discrepancies can be immediately corrected. The Health Physics Department has modified all of their applicable survey forms to include an initial block, stating that all greater than lR gates are locked. In addition, the Station Manager has discussed this violation with all the station supervisors who have, in turn, met with their respective departments and emphasized to station personnel the seriousness of this violation. Results Achieved have been to significantly decrease the possibility of a greater than lR gate being left open.

519/111177 P<;1.~e 4 of 4

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER NON-COMPLIANCE:

e None DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

E. NRG COMMENT Tehcnical Specification 3.7.E requires automatic functions operated from radiation monitor alarms to be as stated in Technical Specification Table

3. 7--5. This Table requires the liquid waste effluent monitor to automati-cally shut discharge valves at alarm conditions with the alarm setpoint less than or equal to on effluent concentration of 1.5 x 10- 3 uCi/cc.

Contrary to the above, on August 13, 1977, July 18, 1977 and October 27, 1976 the liquid waste monitor did not operate as specified, as demonstrated by isotopic analyses showing effluent concentrations in excess of the stated set point with no alarm trip occur~ing during the releases.

E. Response CORRECT AS STATED CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED An investigation of this violation indicates a !. onflict between Technical Specification 3.11.A and the liquid waste monitor setpoint given in Technical Specification Table 3.7-5. Corrective action has been a written directive to the Health Physics Technicians who perform the liquid waste isotopic analysis to not approve release of liquid waste if any one isotope has a value greater than 1.5 x 10- 3 uCi/ml (excluding tritium). Results Achieved have been to eliminate the possibility of having a situation where the concentration of a single isotope could be greater than the liquid waste monitor trip setpoint.

CORRECTIVE STEPS TAKEN WHICH WILL BE TAKEN TO AVOID FURTHER NON-Cm-IPLIANCE:

A 'rethnical Specification change will be submitted to correct the value given in Technical Specification Table 3.7-5 for the liquid waste monitor alarm setpoint. This change request is being formulated at t11is time.

i)_A_TE_ WHEN FULL COMPLIANCE WILL BE ACHIEVED :

Full compliance has been achieved.