ML20064K952

Suppls 820802 Response to NRC Re Violations Noted in IE Insp Rept 50-302/82-10.Corrective Actions:Written Test on Compliance W/Radiation & Standing Radiation Work Permits Identified Problem as Isolated Case

ML20064K952
Person / Time
Site:	Crystal River
Issue date:	10/01/1982
From:	Baynard P FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20064K934	List: ML20064K952 ML20064K992
References
3F-1082-01, 3F-1082-1, NUDOCS 8302150067
Download: ML20064K952 (2)

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1. 3F-1082-01 File: 3-0-3-a-2 Mr. 3. P. O'Reilly Regional Administrator, Region II Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 3100 Atlanta, G A 30303

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. SE10 Supplemental Response

Dear Mr. O'Reilly:

By letter dated August 2,1982, Florida Power Corporation (FPC) provided a response to Inspection Report 82-10. The following provides a rewording of our August 2,1982 response, with changes identified by change bars, and the result of our management reviews requested by your report.

A.

VIOLATION l

Technical Specification 6.11 requires procedures to meet the requirements of Title 10, l

Ccde of Federal Regulations, Part 20, be adhered to for all activities involving personnei radiation exposure.

Radiation Protection Procedure, RP-101, Section 4.8.2, requires an individual entering a contaminated area to wear proper clothing necessary for contamination control as specified by a Standing Radiation Work Permit (SRWP).

Contrary to the above, on May 5,1982, two individuals were observed on separate occasions entering a contaminated area without the proper clothing requirements specified on the SRWP.

This is a Severity Level IV Violation (Supplement I).

RESPONSE

Florida Power Corporation concurs with the stated violation. The cause of this event is l

failure to adhere to procedure.

l l

Af ter the incident occurred, the Chemistry / Radiation Protection Section (Chem / Rad) removed one individual's qualification for access into the Radiation Controlled Area (RCA) and requested retraining.

8302150067 830209 PDR ADOOK 05000302 turth Street South e P O Box 14042, St Petersburg, Flonda 33733 e 813-866-5151 1

0 PDR

Mr. J. P. O'Reilly

1. 3F-1032-01 Page The Nuclear Operations Training Department provided a special class and written test on compliance to Radiation and Standing Radiation Work Permits and general radiation protection practices.

Satisfactory results were obtained from the test, and the individual was allowed access to the RCA.

In order to avoid further violations of the Radiation Protection Program and to determine whether this is a generic problem or an isolated case, Chem / Rad management has implemented a program of increased surveillance by Health Physics Supervisors within the RCA. If generic implications are found, Management will take corrective actions to eliminate further items of non-compliance. Results of the study should be completed by September 1,1982.

Florida Power Corporation, therefore, requests extension until October 1,1982 to address any improvements to Management Control Systems.

SUPPLEMENTAL RESPONSE In order to determine whether or not this was a generic problem or an isolated case, on May 19,1982, Chem / Rad implemented a formal program of increased surveillance by Health Physics Supervisors within the RCA. The program appears to have identified that the problem was an isolated case, rather than generic. However, the visibility of supervision within the RCA seems to have had a positive effect on the workers' attitude regarding compliance with the Radiation Protection Program.

FPC management will continue to keep abreast of workers attitudes concerning the program.

Based on this and other contributing factors, such as varying activity levels, management will continue to make appropriate recommendations regarding the continuation and magnitude of the surveillance program necessary to avoid further items of non-compliance.

However, we are somewhat hesitant to establish more of a policing role for Health Physics (HP) than is absolutely necessary. We consider it essential that HP personnel be viewed more as co-workers than auditors and have so emphasized. We intend to further emphasize that it is the responsibility of supervisory personnel and not HP to assure compliance with Raoiation Work Permits and other HP/ALARA requirements. This philosophy is consistent with the recommendations of the various Regulatory Guides, NUREG's and Reports on the subject.

Should there be further questions, please contact this office.

Very truly yours, gja O

LW Dr. P. Y. Baynard l

Assistant to Vice President Nuclear Operations EF/ mig cc: Document Control Desk

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