ML20011F558

Responds to NRC Re Violations Noted in Insp Repts 50-338/89-33 & 50-339/89-33 on 891211-15.Corrective Actions: Radiological Incident Rept Prepared to Document Release of Contaminated Equipment from Restricted Area

ML20011F558
Person / Time
Site:	North Anna
Issue date:	02/09/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-017, 90-17, NUDOCS 9003060259
Download: ML20011F558 (4)

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VIRGINIA Eu:CTRIC AND POWER COMPANY RICHiWOND, VIRGINI A 23261 r

February 9, 1990 U. S. Nuclear Regulatory Cownission Serial No.90-017 i

Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos.

50-338_

50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY D2 INSPECTION REPORT N05. 50-338/89-33 AND 50-339/89-33 REPUR E TO THE NOTICE OF VIOLATION We have reviewed your letter of January 12, 1990 which referred to the inspection conducted at North Anna from December 11 - 15, 1989 and reported in-i Inspection Report Nos.

50-338/89-33 and 50-339/89-33.

Our response to the Notice of Violation is attached.

As requested in your transmittal letter, the violation response has paid particular attention to root cause and corrective

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actions in order to prevent future violations.

We.have no objection to this correspondence being made a matter of public record.

If you have any further questions, please contact us.

Very truly yours, W. L. Stewar Senior Vice President - Nuclear Attachment cc:

U. S. Nuclear Regulatory Commisssion 101 Marietta Street, N. W.

I Suite 2900 Atlanta, Georgin 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station (0

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i RESPONSES TO THE NOTICES OF VIOLATION RE CDRDDCTED BETWEEN DECEIBER 11, 1989 AND DECE35ER 15, 1989 INT RCTIOR REPORT N05. 50-338/89-33 AND 50-339/39-33

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NRC COISIENT l

During the Nuclear Regulatory Commission (NRC) inspection conducted on December 11-15, 1989, a violation of NRC requirements was identified.

In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2,

Appendix C (1989), the violation is listed below:

10 CFR 20.201(b) requires each licensee to make or cause to be made (1) may be necessary(2) such-surveys as for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazaros that may be present.

Technical Specification 6.8.1 requires written procedures to be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, Revision 2. February 1978, requires

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written procedures for contamination control.

Health Physics Procedure HP-7.1.10

" Radioactive Material Control Program" requires that loose surface contamination on items to be cm} eased re for unrestricted use be less than or equal to 1,000 dpm/100 I

2 beta-gamma activity and less than or equal to 20 dpm/100 cm alpha activity.

The procedure also requires that the total beta-gamma activityonthesurface(fixedangloosecontamination)shall be less than or equal to 5,000 dpm/100 cm andghetotalalphasurfaceactivity be less than or equal to 100 dpm/100 cm Contrary to the above, the licensee failed to perform adequate contamination surveys of instrumentation prior to release of the equipment for unrestricted use, in that, on August 25, 1989, three Teledose transmitters and one receiver gase station with loose surface contamination up jo 2,000 dpm/100cm and fixed contamination up to 50,000 dpm/100 cm were transferred to the onsite Westinghouse Integrated Radiological Services Program (IRSP)forunrestricteduse I

and subsequently shipped to another licensee.

This is a' Severity 1.evel IV violation (Supplement IV).

.o RESPONSE.TO V10LATION

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ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.

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REASON FOR THE VIOLATION The root cause of the violation was personnel failure to follow the requirements of Health Physics (HP) Procedure HP-7.1.10.

The failure to follow procedure lead to an inadequate survey of equipment prior to the equipment.being released for unrestricted use.

The survey that was performed did not adequately identify loose surface and fixed contamination levels ~that were above the levels allowed for equipment being released for unrestricted use.

3.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A Radiological Incident Report was prepared to document the events that caused the release of contaminated equipment from the restricted area and recommended corrective actions to prevent similar occurrences.

Recommended corrective actions included:

1) The HP Technicians have been reinstructed on the importance of performing accurate release surveys along with a discussion of this-specific incident.

Additionally, this information will be introduced into the Health Physics Continuous Training Program through the Industry Event Review Process.

2) Tool monitors will be evaluated for use at Radiological Controlled Area (RCA) exit points for surveying material that is to be released for unrestricted use.

A tool monitor has been installed at the main RCA exit point for ur,e on a trial basis.

Feedback on the use of this monitor will be used to make the -decision on the purchase and location of additional monitors.

3) A material release survey form is being used to document survey I-of items being released from the RCA.

This survey form will be formalized in Health Physics procedures.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS J

A description of-this incident will be included in the Health Physics Technician Continuing Training Program (HPTCT).

HP Technicians will also be reinstructed on the proper method for performing a thorough release survey.

The use of =the material release survey form will be formally documented in Health Physics procedures. Additionally, reminder steps reinforcing the key elements of a proper survey will be. included in this form to aid the technician.

Feedback on the use of the trial tool monitor, currently installed at the main RCA exit point, will be used to decide on the purchase and location of additional monitors.

5.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED A description of this incident and the reinstruction of_HP Technicians on the proper method for performing a thorough release survey will be included in the Health Physics Technician Continuing Training Program (HPTCT) by April 1, 1990.

The material release survey form will be formalized in Health Physics procedures by April 1 1990.

Feedback on the use of the trial tool monitor will be provided by May 1, 1990.

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