ML19305C409
| ML19305C409 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/06/1980 |
| From: | Hancock J FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19305C405 | List: |
| References | |
| CS-80-42, NUDOCS 8003280509 | |
| Download: ML19305C409 (3) | |
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- ??'Ir II en j j gg 6 February 1980 3-0-3-a-2 Power CS_80_42 Co m PO R A f sO N Mr. J. P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Commission Ref
RII:SCE 101 Marietta St., Suite 3100 50-302/79-54 Atlanta, GA 30303
Dear Mr. O'Reilly:
We offer the following responses to the apparent Items of Noncompliance in the referenced inspection report.
As required by Technical Specification 6.12.1.b, areas with radiation levels exceeding 1000 mrem /hr must be provided with doors locked to prevent unauthorized entry.
Contrary to the above:
1.
On December 17, 1979 the dcor to the Spent Resin Transfer Pump area was not closed. This provided access to the Spent Resin Catch Tank through a crawlway. Radiation levels in the crawlway 1.ere measured at 2000 mrem /hr.
2.
On December 17, 1979 doors controlling access to the Evaporator Condensate Demineralizer area and the Makeup Prefilter area were inadequate to prevent unauthorized entry.
The lock mechanisms could easily be defeated to gain access to these areas.
Surveys conducted on December 19 indicated general area radiation levels of 1500 mrem /hr.
(Makeup Prefilter area) and 2500 mrem /hr. (Demineralizer area).
Response A-1 Immediate corrective action was taken by closing the gate ac-cessing the Spent Resin Transfer Pump area. A subsequent survey in-dicated no general areas greater than 180 mrem /hr in the Spent Resin Transfer Pump Room. A heavy lead shield was in place to block the Resin Catch Tank Craw 1way.
In order to provide access to the crawl-way this shield had to be moved.
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The Health Physics Supervisor had previously identified a key control problem. A letter addressing this problem was written to the Nuclear Plant Manager, and the resulting corrective action of assigning key control responsibility to the Health Physics Supervisor will serve to avoid further noncompliance.
Response A-2 We do not agree that this item constitutes an apparent item of noncompliance.
The Code of Federal Regulations does not address the physical design of a " locked gate" except to state that rapid egress from a high radiation area must be provided.
It is our contention that a
" locked gate" is designed to keep " honest people honest".
We further contend that the originally installed locks meet the 10 CFR-20 requirements.
However, as a result of this inspection we have undertaken a project that will increase the difficulty in defeating the locking mechanism of the gates.
The inspectors performing this inspection examined this corrective action and indicated that it would satisfy "their" interpretation of the requirement. Therefore, we cannot state the locking mechanism modifications will satisfy future inspection requirements.
The modifications of the gate locking devices will be completed by 1 June 1980.
B.
As required by 10 CFR 20.203(e), areas where radioactive materials in excess of 10 times 10 CFR 20 Appendix C quantities are stored must be posted with a sign or signs Jearing the radiation caution symbol and the words: Caution, Radioactive Material (s). Also, as required by 10 CFR 20 20.203(e), containers containing radioactive materials in excess of 10 CFR 20 Appendix C quantitites must have a label identifying the radioactive contents. This label must bear the radiation caution symbol, the words:
" Danger, Radioactive Material" or " Caution, Radioactive Material" and must provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
Contrary to the above:
On December 17, 1979, approximately 50 bags of contaminated waste awaiting compaction and shipment as radioactive waste were in a holding area. These bags had no tag affixed to indicate contamination or radiation levels.
Quantities of radioactive material in excess of Appendix C quantitites were present.
Response B We do not agree that this item should be classed as an apparent item of noncompliance.
10 CFR-20.203(f) (3) (14) states that labelling is not required for containers when they are attended by an individual taking necessary precautions to prevent the exposure of any individual to radiation or radioactive material in excess of established limits. The bags cited were contained in an area that was marked " Caution - Radioactive Material" and " Radiation Area".
No compaction work is allowed within the area without a Radiation Work Permit that defines the necessary precautions to be taken.
Surveys in the waste area are currently performed a minimum of once daily, and Chem / Rad personnel are assigned to follow all waste handling operations. No attempt was made by inspection personnel to calculate whether the contents of the containers did in fact exceed 10 times " Appendix C" lavels. The "mtoinct
' asured during this inspection read two to five
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J. P. O'Reilly
- mrem /hr. An approved plant procedure " Estimation of Curie Content of Radioactive Material" is an adaptation of a method described in " Health Physics" 1976, Volume 31.
This procedure has been res wed by Region II inspection personnel. Calculations derived from this procedure utilizing five (5) mrem /hr. indicates radioactive levels considerably below ten (10) times " Appendix C" levels.
C.
As required by Technical Specification 6.8, procedures addressing areas outlined in Regulatory Guide 1.33 (1972), Quality Assurance Program Re-quirerents, Appendix A, must be followed.
Section 1.5, Appendix A requires procedures for control of modifications. Facility Compliance Procedure CP-ll4, " Procedure for Preparation and Control of Permanent Modifications, Temporary Modifications, Deviations, and MAR Functional Test Procedures" implements this requirement.
CP-ll4, Section 1.1 states, "Any change from original design requirements is a modification and must be controlled and receive design review equivalent to that imposed on the original design."
Contrary to the above, on December 18, 1979, six lead blankets, (about 30 pounds each) were found on Makeup System piping near valve MOV-305 with no analysis or control over the amount of lead installed and its effect on the seismic qualification of the system.
This piping is a seismic I safety system.
Response-C The immediate corrective action to correct this deficiency was to remove the lead blankets.
Concerne Chem / Rad personnel have been instructed that lead blankets are not authorized for use directly on seismic / safety-related piping.
Lead blankets will be used on seismic /
safety-related piping only when an engineering evaluation is provided to document that the particular section of piping will not be damaged.
Full compliance has been achieved this date.
Should there be further questions, please contact us.
Very truly yours, FL I
POWER CORPORATION OR
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. A. Hancock Nuclear Plant Manager irector, Nuclear Operations j
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