ML20031E829
| ML20031E829 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/18/1981 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20031E822 | List: |
| References | |
| 527, NUDOCS 8110160466 | |
| Download: ML20031E829 (4) | |
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t VIRGINIA l$LECTHIC AND POWER COMPANY Ricnwonn, V1HOINIA 20261
! " f ' 2d li O. 5 3 R. H. LE AMB UMG September 18, 19b1 Vaca Peasanmur Nuca. man Oramarrous Mr. James P. O'Reilly, Director Serial No. 527 Office of Inspection and Enforcement N0/RMT:acm U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of August 20, 1981 in reference to the inspection conducted at North Anna Power Station between Juna 8-12, 1981 and reported in IE Inspection Report Nos. 50-338/81-16 and 50-339/81-13. Our responses to the specific infractions are attached.
We have determined that no proprietary information is cor.tained in the reports.
Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours,
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N R. H. Leasburg Attachment City of Richmond Commonwealth of Virginia d
Acknowledged before me this /
day of I, 19 8/
% G.7W W Notary Public My Commission expires: -R. 4 4
, 19 83 SEAL cc: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 8110160466 811009 DR ADOCK 05
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e Attacharnt Page 1 RESPONSE TO NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED FROM JUNE 08-12. 1981 338/81-16-01 AND 339/81-13-01 NRC COMMENT A.
Technical Specification 6.3 requires that each member of the facility staff shall meet or exceed the minimum qualification of ANSI N18.1-1979 for comparable positions. Paragraph 4.5.2 of ANSI N18.1-1971 states, in part, that technicians in responsible positions shall have a sinimum of two years of working experience in their specialty.
Contrary to the above, health physics technicians with less than two years experience were serving in responsible positions, in that on June 11, 1981 a health physics technician with one and a half years training anu ex-perience entered Unit I containment while the plant was operating and per-formed independent surveys and established radiation protection require-ments for work concerning the pressurizer without review of the survey results or the radiation protection requirements by a qualified technician or supervisor prior to their use.
This is a Severity Level V Violation (Supplement IV.E.2).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The notice of violation is not correct as stated.
Health Physics provides four shift, twenty-four hour coverage. Each shift is assigned a lead health physics respresentative meeting the requirements established by ANSI N18.1-1971 prior to such assignment. This individual functions in a responsible position in that he evaluates radiological hazards, prescribes protective controls, approves radiation work permits, ensures approved procedures are properly executed, and directs the activi-ties of other technicians / technician trainees. Since the lead health physics respresentative meets or exceeds the qualifications of ANSI N18.1-1971, compliance with the minimum requirements of Technical Specifi-cation 6.3 is being achieved.
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Paga 2 RESPONSE TO NOTICE OF VIOLATION 331/81-16-02 AND 339/81-13-02 NRC COMMENT B.
Technical Specification 6.8 requires that written procedures be establish-ed, implemented and maintained covering the applicable procedures recom-mended in Appendix "A" of Regulatory Guide 1.33, Revision 2 (February 1978) and that these procedures be reviewed by the Station Nuclear Safety Operating Committee (SNSOC) and approved by the Station Manager. Regula-tory Guide 1.33, Appendix "A" states that radiation protection procedures should be provided for personnel radiation monitoring and the respiratory protection program. Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and that be approved, maintained and addered to for all operations involving personnel radiation exposure.
Contrary to the above, written radiation protection procedures were in use which had not been reviewed and approved in that:
1.
Procedure HP-ADM-4, Determination of Prior Dose, had not been reviewed by SNSOC and approved by the Station Manager prior to implementation.
2.
Procedure HP-ADM-5, Issue of Respiratory Protection Equipment, had not been reviewed by the SNSOC and approved by the Station Manager prior to implementation.
This is a Severity Level VI Violation (Supplement IV.F).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The notice of violation is correct as stated.
2.
REASONS FOR THE VIOLATION This infraction was the result of a personnel error. The procedures were not recognized as requiring review by the SNSOC and approval by the Station Manager prior to implementation.
d Attachmint Paga 3 3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Administrative procedures HP-ADM-4 and HP-ADM-5 were submitted to the SNSOC for review and approved by the Station Manager.
In addition, the remaining Health Physics Administrative procedures currently in use have been reviewed for applicabiilty to Technical Specification 6.8 by the Supervisor Health Physics.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS To prevent recurrence, all future Health Physics Administrative procedures will be reviewed for applicability to Technical Specification 6.8 by the Supervisor Health Physics prior to implementation.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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