ML20027E580

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Responds to NRC 820922 Ltr Re Violations Noted in IE Insp Rept 50-261/82-31.Corrective Actions:Area in Drumming Blocked Off W/Water Filled Drums Stacked 6-ft High,Leaving Just Enough Room for Drumming Hoist to Move Freely
ML20027E580
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 10/22/1982
From: Starkey R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20027E576 List:
References
RSEP-82-1733, NUDOCS 8211150509
Download: ML20027E580 (4)


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Carolina Power & Light Company w~ ,--,n _ gm IR0CI2k. O ed&w- ON STEAM ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 OCT2 21982 Robinson File No: 13510E Serial: RSEP/82-1733 Mr. James P. O'Reilly Regional Administrator USNRC Region II 101 Marietta Street, N. W.

Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO IE INSPECTION REPORT 82-31

Dear Mr. O'Reilly:

Carolina Power and Light (CP&L) has received and reviewed the subject report and provides the following response:

Violation "A" - Severity Level IV (IER-82-31-04-SL4)

Technical Specification 6.13.1.b requires that each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr shall be provided with locked doors to prevent unauthorized entry into such areas.

Contrary to the above, an area in the drumming room with a radiation level above 1000 mrem /hr was not locked as required. This area was identified on August 25, 1982, by the Licensee as not being able to be secured and no action was taken to prevent unauthorized entry into the area. .

l Response )

(1) Admission or Denial of Alleged Violation Carolina Power and Light Company acknowledges the violation.

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Latter to Mr. Jtica P. O'Reilly

-Serisl: RStP/82-1733 Page 2 (2) Reason for the Violation On August 25, 1982, a Radiological Control (RC) Technician on the 0000-0800 shif t found that the cage fence door lock could not be secured and reported this situation in the- RC Technician shif t turnover log book. At this time no one else was notified. The on-duty RC Foreman was made aware of the situation later in the day and corrective action was taken.

(3) Corrective Steps Which Have Been Taken and Results Achieved The area in question was completely blocked off with water filled drums stacked to a height of six (6) feet leaving just enough room for the drumming room hoist to move freely. This action has resulted in the area being completely blocked off which is comparable to having a solid wall.

(4) The Corrective Steps Which Will Be Taken to Avoid Further Violation Corrective measures have already been taken as stated in Step 3 of this response.

(5) The Date When Full Compliance Will Be Achieved Full compliance has been achieved as stated above.

Violation "B" - Severity Level V (IER-82-31-05-SL5)

Technical Specification 6.11 requires that procedures shall be prepared consistent with the requirements of 10CFR20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposures.

(1) Health Physics Procedure HP-7, " Radiation Work Permit",Section I

5.13.1, requires for "non-routine" RWPs and prior to performing work under the RWP, that personnel shall read and understand the provisions of the RWP.

Contrary to the above, Health Physics Procedure HP-7 was not adhered to in

, that personnel were observed drumming evaporator bottoms while being signed

! in on a " routine" RWP used for general decontamination. These personnel were l not aware that an RWP for this operation existed; and, therefore, had not read the requirement of the proper RWP.

l (2) Health Physics Procedure HP-28, " Control of Personnel Contamination and Decontamination Techniques", Section 3.2.1.2, requires that a personnel contamination record, Form HP-28-1, shall be completed if it is confirmed that an individual is contaminated.

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Letter to Mr. Jc=so P. O'Reilly Sa' riel:

  • RSEP/82-1733 Pzge 3 Contrary to the above, Health Physics Procedure HP-28 was not adhered to in that a personnel contamination report was not completed when a frisker alarmed indicating contamination on the inspector's hand.

Respo nse (1) Admission or Denial of Alleged Violation Carolina Power and Light Company acknowledges the violation.

(2) Reason for the Violation (a) Violation B, Part (1) ,

Section 5.13.1 of HP-7 (Revision 11) requires that " prior to performing any work under a 'non-routine

  • RWP" all personnel shall read and understand all the provisions of that RWP.

At the time of this violation, RWP #2 allowed decontamination personnel to enter all areas of the plant and " dress as posted for the area". RWP #13 is a non-routine RWP specifically for entering the drumming room. Although the decontamination personnel were only aware of and only read RWP #2, all provisions of RWP #13 were followed while the work was performed.

() Viola tion B, Part (2)

Section 3.2.1.2 of HP-28 (Revison 2) states that upon confir-mation that an individual is contaminated, a Form HP-28-1 shall be completed. The control point technician was aware of this procedure. The inspector's report states that a second frisking was performed resulting in a second alarm.

The inspector subsequently stated that he made a successful decontamination attcmpt. The inspector then reported that he asked the technician if a personnel contamination report needed to be completed. The technician replied that a form did not need to be completed. This response is not in accordance with procedure HP-28, and it is a violation of that procedure.

(3) The Corrective Steps Which Rave Been Taken and Results Achieved (a) Violation B, Part (1)

RWP #2 has been altered so that decontamination personnel are only allowed to pick up trash and clean up in a Radiation Area. They may not enter a High Radiation Area or Locked High Radiation Area without obtaining and fulfulling all the provisions of a non-routine RWP.

r Latter to Mr. Jc;se P. O'Reilly Saric1: *RSEP/82-1733 Page 4 )

6 (b) Violation B, Part (2)

After the incident, all technicians were cautioned on the correct course sof action that shall he taken in order to comply with procedure HP-28.

(4) The Corrective Stepa Which Will Be Taken to Avoid Further Violation (a) Violation B, Part (1)

The corrective actions stated above in Section 3 should be sufficient to avoid further violation.

(b) Violation B, Pa rt (2)

A training course was given to all frisker technicians, specifically on HP-28 and the personnel contamination report.

(5) D_ ate When Full Compliance Will Be Achiew d Fbil compliance was achieved on October 8,1982. .

If you have any questions concerning this response, please contact me.

Ve ry tru,1y yours, =

7 f $!

R.. B. Starkey, Jr.s General Manager H. B. Robinson SEG Plant CLW/b ss cc: R. C. DeYoung