ML20054H058

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Responds to NRC Re Violations Noted in IE Insp Rept 50-261/82-11.Corrective Actions:High Radiation Areas on Second Level of Containment & Around Spent Fuel Pit Heat Exchanger Properly Posted
ML20054H058
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 05/21/1982
From: Starkey R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054H051 List:
References
RSEP-82-916, NUDOCS 8206220532
Download: ML20054H058 (2)


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11. B. ROBIh STEAM ELECTRIC PLANT Post Office Box 790 Hartsville, South Carolina 29550 MM Z i 1982 Robinson File No: 13510E Serial: RSEP/82-916 Mr. James P. O'Reilly Regional Administrator USNRC Region II 101 Marietta Street, N. W.

Suite 3100 Atlanta, Georgia 30303

11. B. ROBINSON STEAM ELECTRIC PLAh'T, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO I.E. INSPECTION REPORT 82-11

Dear Mr. O'Reilly:

Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following respoase.

Severity Level V Violation - IER-82-11-02 10 CFR 20.203(c) requires that each high radiation area shall be conspicuously posted with a sign or signs designating the area a high radiation area. This requirement is implemented by Health Physics Procedure HP-1, Section 5.2.5.

Section 5.2.5 also requires that if the high radiation area is not completely bounded by physical barriers, those perimeters shall be cordoned off in a manner that clearly indicates the bounds of the area.

Contrary to the above, as of March 26, 1982, this procedure was not implemented in that a high radiation area on the second level of containment was not posted for access from the northwest personnel stairway; and, as of April 7, 1982, the high radiation area around the spent fuel pit heat exchanger was posted as a radiation area.

1. Admission or Denial of Alleged Violation CP&L acknowledges the violation as stated.

8206220532 820603 DR ADOCK 05000261 PDR

3 Letter to Mr. James P. O'Reilly Serial: RSEP/82-916 Page 2

2. Reason for the Violation The containment in its entirety is maintained as a high radiation area and access to it is controlled accordingly. High radiation areas within the containment are also identified, roped off, and posted. It was at one of the high radiation areas within the containment that two barrier ropes were used to identify the area. However, only the barrier rope at the normally used access was posted. The technician failed to recognize that the second barrier rope at the seldom used northwest stairway also required posting.

As part of the routine weekly radiation survey, the spent fuel pit heat exchanger was identified as a high radiation area and properly posted on March 29, 1982. On April 7, 1982, CP&L verified the NRC inspectors finding that contrary to the survey on March 29, 1982, the area was im-properly posted as a radiation area. CP&L has not determined how or why the posting was changed between March 29 and April'7. However, the posting may have been inadvertently changed during a decontamination of the area that occurred prior to the NRC inspector identifying the problem.

3. Corrective Steps Which Have Been Taken and Results Achieved Prompt action was taken to correctly post both areas.
4. Corrective Steps Which Will Be Taken to Avoid Further Violations These posting deficiencies will be discussed with the Radiation Control Technicians. Emphasis will be placed on the importance of posting throughout the plant on a generic basis as required by Volume 8, HP-1.1,

" Radiation Control Area Surveillance Program", and 10CFR20. These discussions will be completed by June 4, 1982.

5. Date When Full Compliance Will Be Achieved Full compliance was achieved when the specified areas were correctly posted.

If you have any questions concerning the above information, please contact me.

Very truly yours, k

R. B. Starkey, Jr.

General Manager H. B. Robinson S.E. Plant l CLW/tm cc: R. C. DeYoung (1)

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