ML20030D344
| ML20030D344 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/14/1981 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20030D338 | List: |
| References | |
| CS-81-150, NUDOCS 8109010207 | |
| Download: ML20030D344 (5) | |
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CS-81-150 July 14, 1981
- 3-071 -21 Mr. J.P. O'Reilly, Director Office of In-
"t. ion & Enforcement U.S. Nuclear Ke alatory Commission 101 Marietta St., Suite 3100 Atlanta, GA 30303
Subject:
Docket No. 50-302 License No. DPR-72
Reference:
RII:JMP 50-302/81-08
Dear Mr. O'Reilly:
We offer the following response to the violations listed in the referenced inspection report.
A.
10 CFR 20.103 requires the use of measurements (surveys) of concentra-tions of radioactive materials in air for timely detection and assess-
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ment of individual intakes of radioactivity by exposed individuals.
Contrary to the above, a survey or surveys were not performed on March 31, 1981, when work was performed in the hot machine shop which required respiratory protection and involved a potential airborne radioactivity j
hazard. Workers were decontaminating tools at the time.
A.
Response: Florida Power Corporation disagrees with the reported '
l violation. The Health Physics staff at Crystal River #3 routinely requires work on contaminated material in the " hot" machine shop i
to be conducted within ventilated containments. Radiation Work Permits issued for work done in the containments specifies respiratory 4
protection primarily as a means of contamination control and not necessarily as protection against a respiratory hazard.
The work described involved cleaning Once Through Steam Generator (OTSG) studs. During our investigation, we determined that a survey was performed by the Health Physics technician assigned to cover work I
1 8109010207 810320 DR ADOCK 05000302 PDR General Office 3201 inirty fourin street soutn. P O Box 14042, St Petersburg, Florda 33733 e 813-866 5151
r Notice of Violation Response Ref: RII:JMP 50-302/81-08 Page 2 in the " hot" machine shop as required by 10CFR20.102. His evaluation was that since the cleaning was done under water, an air sample was not necessary.
It would appear, considering the supporting bioassay results required by the NRC inspectors of the three " exposed" individuals, that the technician made a reasonable evaluation.
Florida Power Corporation has determined that a problem does exist in our methods of documenting Hea'th Physics coverage and followup of Radiation Work Permits in the f' eld. We have, therefore, taken action in the area of procedural modifications and instructions to Health Physics personnel to provide a more meaningful and complete set of records for jobs requiring very close Health Physics support. We expect this modified program to be fully effected by August 31, 1981.
B.
Technical Specification 6.11 states that pro h res for personnel radia-i tion protection shall be prepared consistent wi;h the requirements of 10 CFR, Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Radiological Control Procedure RP-102, Revision 12, entitled Respira-tory Equipment Manual states:
1) in Section 8.1.4, that self-contained breathing apparatus will be inspected monthly with the following points being ascertained:
Air cylinders are charged to a minimum value of 1800 psig.
a.
b.
Facepiece assemblies are totally functional and properly stored.
2) in Section 10.1.2, that every compressed gas cylinder for respiratory use shall b 're a LABEL indicating that it contains pure breathing air or pure breathing oxygen, as appropriate.
3) in Section 8.2.1.1, that cylinders will be tested routinely in ac-cordance with the manufacturer's instructions. Instructions published by the manufacturer indicate that cylinders must be hydrostatically tested every five years.
Contrary to the above:
- 1) On April 28, 1981, one Self Contained 1reathing Apparatus (SCBA) on the Turbine Building 95' elevation was available for use yet was low in air pressure (approximately 1700 psig);
- 2) On April 28, 1981, two of six SCBA spare cylinders which were avail-able for use were at less than 1800 psig;
- 3) On April 28, 1981, a SCBA unit in the Auxiliary Building was found to have an improperly stored facepiece (not in a sealed bag) yet was available for use.
r Notic'e of'V'iolation Response Ref: RII:JFT 50-302/81-08 Page 3
- 4) On April 28, 1981, SCBA cylinders were found to have no distinctive LABEL indicating contents as required.
- 5) On April 28, 1981, one SCBA cylinder was found to have been last tested hydrostatically in 1974.
B.
Response: We will address each item of the criteria fo. the apparent violation individually:
Item B.l.a Florida Power Corporation agrees that a violation of 8.1.4, Part A of RP-102 " Respiratory Protection Program" did occur in two(2) isolated cases as described. The reasons for this v_,1ation were as follows:
The inspection by IRC occured at the end of a high use period (Annual Emergency Drill) during which bottles were charged at a rapid rate so that as many spare bottles would be available as possible. This rapid charging resulted in isolated cases of bottles that appeared to be full to lE00 psig that were 0.05% less than 1800 psig after a " cooling" period and resultant contraction of the volume in the bottle. Realizing that increasing inspection frequencies cannot guarantee bottle intregrity, random spot checks were made by the Health Physics supervisors to re-inforce the confidence level that an appropriate inspection frequency is one time per month. The bottles in question were filled to greater than 1800 psig and observed for several days. No leakage was detected.
Whenever possible, i.e., non-emergency refilling, bottles will be observed for a period long enough to determine that it is not leaking (a decrease in pressure) before being placed in service.
Full compliance has been achieved.
1 Item B.l.b Florida Power Corporation does not agree that any violation occurred on April 28, 1981, concerning the proper storage of a facepiece.
The vielation specifically states "not in a sealed bag" as the violation.
Section 8.4.2 of EP-102 states that " Respiratory Protection equipment is to be placed in storage in plastic bags or storage cases after cleaning, inspection, testing, and repair". We cannot find where it states that the plastic bag must be sealed. This particular mask was in a plastic i
bag which we determine to be sufficient to ensure that the assemblies are totally functional and properly stored.
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e Notice of Violation Response REf: RII:JMP 50-302/81-08 Page 4 Item B.2 Florida Power Cor,oratio, agrees that a violation of Section 10.1.2 of RP-102 did occur. The reason for this violation was the unauthorized removal of the decal type sticker which had those words.
To correct this situation, immediate steps were taken to have a stencil cut and the words " Breathing Air Only" placed on all Scott bottles.
In the future, a part of the monthly inspection will be to ensure that all bottles are labeled (Breathing Air Only).
Full compliance has presently been achieved.
Item B.3 Florida Powcr Corporation agrees that a violation of 8.2.11 of our procedure did occur. One bottle ' as found ti.4t was out of date for hydrostatic testing. The reason for that bottle being in service was the lack of a procedural requirement to check the hydrostatic date test.
The bottle was immediately removed from service and sent off to be hydro-statically tested.
Correction steps to prevent further noncompliance entail revising our procedure to require monthly verification of hydrostatic dates.
Full compliance will be achieved by August 1, 1981.
Should there be further questions, please contact us.
Very truly yours, FLORIDA POWER CORPORATION
.Y.Bahard h
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Nuclear Plant Manager ()
Manager
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fluclear Support Services JC/rc l
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s STATE OF FLORIDA COUNTY OF PINELLAS P.
Y.
Baynard states that she is the Manager, Nuclear Support Services, of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the Nuclear Regulatory Comission the information attached hereto; and that all such statements made and matters set forth therela are true and correct to the best of his knowledge, information, and belief.
Yh. b> wand
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?f,) //P. Y/ Baynard
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Subscribed and sworn to before me, a Nctary Public in and for the State and County above named, this 14th day of July,1981.
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Notary Public Notary Public, State of Florida at Large, My Comission Expires:
May 29,1984
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