ML20054K266

Responds to NRC Re Violations Noted in IE Insp Rept 50-302/82-06.Corrective Actions:Health Physics Technicians Instructed to Be Observant During Surveys for Improperly Posted Radioactive Matls

ML20054K266
Person / Time
Site:	Crystal River
Issue date:	05/14/1982
From:	Lutkehaus T, Mardis D FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20054K251	List: IR 05000302/1982006 ML20054K250 ML20054K266 ML20054K271 ML20054K289
References
3F-0582-15, 3F-582-15, CS-82-128, QA259, NUDOCS 8207010352
Download: ML20054K266 (4)

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Florida Power C O A P O A A I e O to May 14,1982 CS-82-128 QA259

1. 3F-0582-15 File: 3-0-3-a-2 Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 3100 Atlanta, GA 30303

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report Number 82-06

Dear Mr. O'Reilly:

Florida Power Corporation hereby responds to the violation cited in IE Inspection Report Number 82-06 for the inspection conducted at Crystal River Unit 3 on March 16-19, 1982, as transmitted by letter dated April 14, 1982, Dance to Hancock.

NOTICE OF VIOLATION Technical Specification 6.8 requires written procedures to be established, implemented, and maintained for activities recommended in Appendix "A" of the Regulatory Guide 1.33, November,1972. Section G of Appendix "A" describes Procedures for Control of Radioactivity (for limiting materials released to the environment and limiting personnel exposure).

1. Chemistry and Radiation Protection Procedure RP-202, " Radiological Surveys", paragraph 2.1 notes that routine radiological surveys are normally performed at a given frequency. A cardex tile in the Health Physics Operations offices is used to denote specific routine survey frequencies and requires that all operating AMS-2 continuous air monitors have their filters changed weekly.

Contrary to the above, the AMS-2 located in the Radiochemistry laboratory was found to have had its filter changed on 3-15-82 and 2-22-82, an elapsed time of greater than the one week required by the procedure.

8207010352 820621 PDR ADOCK 05000302 G PDR General Office 32oi Tnirty-fourtn street soutn . P O Box 14042. St Petersburg. Florgia 33733 e 813-866-5151

Mr. 3. P. O'Reilly May 14,1982 Page 2

2. Chemistry and Radiation Protection Procedure RP-101, Radiation Protection Manual, section 6.3, Sealed sources, requires all licensee's sealed sources, such as calibration sources, to be leak tested at six month intervals.

Contrary to the above, the leak test performed in January,1982, on source #55, a .03 uCi Pu239 calibration source, was counted on an instrument accurate for beta or gamma detection only. Pu239 requires counting on alpha sensitive radiation detectors.

3. Chemistry and Radiation Protection Procedure RP-217, Radioactive Material tagging, section 1.2, states that Radioactive Material that is to be retained for storage shall be placed in a red plastic bag and that Chem-Rad be contacted immediately for tagging.

Contrary to the above, on 3-16-82, the inspector noted numerous items had been placed in a mechanic's laydown area on the auxiliary building 143' elevation and were not bagged and Chem-Rad had not been contacted. The items were subsequently found to be radioactively contaminated.

4. RP-217, Section 2.2.1, states that the Chem-Rad Section will affix a

" Radioactive Material" tag to the container or survey the container and mark as required.

Contrary to the above:

a. On 3-16-82, an unmarked and untagged box containing noncompressable radioactive waste was found by the inspector on the Auxiliary building 119' elevation near the drumming area.

b. On 3-16-82, a drum from Southern Space, marked H-9, containing a laundered bubble hoods comprising a total of .007 millicuries of radioactivity according to a shipping manifest found inside the drum had not been properly surveyed. Subsequent survey revealed the contents to be less than plant unconditional release limits.

c. On 3-16-82, the inspector observed two drums being removed from the 119' elevation containment airlock area, containing radioactively contaminated items, being handled by radiation workers in the presence of a Chem-Rad Technician bore no marking tag, nor had the required survey been performed.

This is a Security Level V Violation (Supplement IV).

Response: Florida Power Corporation concurs with the stated violation with the exception of examples 1 and 2 being contrary to Plant Procedures.

/

Mr. 3. P. O'Reilly May 14,1982 Page 3 Example 1 addresses a violation to RP-202, " Radiological Surveys," concluding that an AMS-2 sample in the radiochemicallaboratory was not changed out on a weekly basis. Section 2.1 of RP-202 addresses the frequencies of various radiological surveys. Section 2.1.1.2 lists specific air sampling frequencies and locations for samples.

There is no procedural requirement to have an AMS-2 sample analyzed or changed for the radiochemical laboratory. The cardex file is used only as a tool for scheduling procedural requirements, but also includes added administrative requirements. Since we did complete the minimum requirements listed in RP-202, we do not agree that this is an example of procedural noncompliance.

Example 2 addresses a violation of RP-101 concerning sealed source testing in that a Pu-239 source was not counted with proper instrumentation. 10 CFR 30.4(r) defines sealed source as "any byproduct material that is encased in a capsule designed to prevent leakage or escape of the byproduct material." The source in question is not byproduct material nor is the source designed as a sealed source. No leak check is required for this source by plant procedure; therefore, we do not agree that this is an example of procedural noncompliance. For the record, discussion with the technician performing this test indicated he did smear the container designed to hold the Pu-239 source to determine source integrity. Further, he stated the smear was counted with an alpha scintillation detector but that he inadvertently documented the minimum detectable level for the beta detector.

Examples 3 and 4 reflect activities contrary to RP-217, Radioactive Material-Tagging. Items identified by the inspectors to be in noncompliance with the procedure were surveyed and appropriately tagged during the inspection period.

Tagging violations occurred because of the large quantities of radioactive materials created during maintenance periods in widely spread areas within the radiation controlled areas, handled by many different groups.

Corrective steps taken included instructions to Health Physics Technicians to be particularly observant during routine surveys for improperly posted radioactive materials. Additionally, correspondence has been generated to the Maintenance Section to request their assistance with procedural adherence to our tagging procedures.

The Code of Federal Regulations, specifically 10 CFR 20.203(F), is extremely difficult to enforce at any large power reactor. For this reason, Florida Power Corporation is pursuing relief from this posting. Indicating that containers in radiation controlled storage areas may contain radioactive materials is sufficient to warn trained personnel of the hazards.

Crystal River is currently in compliance with the items identified as contrary to Technical Specification 6.8.

Mr. 3. P. O'Reilly May 14,1982 Page 4 Should there by further questions, please contact us.

Very truly yours, 0sG bniAtul

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U4uclear Plant Manager aveY David G. Mardis i Acting Manager Nuclear Licensing CGB:mm cc: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555