ML20106B860
| ML20106B860 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/31/1984 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20106B850 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM RSEP-84-534, NUDOCS 8410230538 | |
| Download: ML20106B860 (5) | |
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.a u Carolina Power & Light Company H. B.
PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 AUG S 11934 Robinson File No: 13510E Serial:
RSEP/84-534 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 H. B. ROBINS 0H SEC PL*EI, UNIT 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 IE INSPECTION REPORT IER-84-17, REV. 1
Dear Mr. O'Reilly:
Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.
A Severity Level IV Violation (IER-84-17-03-SL4)
NRC Order dated March 14, 1983 requires, in part, that the licensee implement and maintain the post accident monitoring capability set forth in NUREG 0737, Item II.F.1.
NUREG 0737, Item II.F.1, Attachment 3, specifies that the licensee provide two containment high range radiation monitors which meet the requirements of Table II.F.3-3.
Table II.F.1-3 specifies that an onsite calibration by electronic signal substitution is to be performed for all range decades above 10R/hr.
Contrary to the above, as of May 12, 1982, the two High-Range Primary Containment Radiation Monitors, RM-32 "A" and "B" had not been calibrated by electronic signal substitution through each decade up to 1 E+7 R/hr.
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RESPONSE
1.
Admission or Denial of the Alleged Violation Carolina Power and Light acknowledges the alleged violation.
2.
Reason for the Violation The calibration check procedure for RMS-32 "A" and "B" was written in accordance with the vendor Technical Manual.
The Technical Manual did not describe electronic calibration for the 106 and 107 R/hr ranges.
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- Letter:to Mr.-James P. O'Reilly-
. Serial: 1RSEP/84-534-
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1 l3.
Corrective Steps Which Have-Been Taken 1
-Subsequent discussion withLthe vendor. indicates that there--is an
. additional ~ check whi h could be done to verify these upper tan)
' channels,109and109 R/hr.
4.
Corrective Steps Which'W111 be Taken 6 and 107 R/hr ranges will be imple-A. procedure to. include the 10 l~
mented.'
c5.
Date When Full Compliance Will be Achieved Full compliance will be achieved by September 28, 1984 l
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B.-
Severity Level IV Violation (IER-84-17-02-SL4) 10CFR20.103(a)(3) requires the licensee to use suitable measurements of l
concentrations of radioactive materials in the air for detecting and evalu-ating airborne radioactivity in restricted areas.
i Contrary to the above, the requirement to use suitable measurements of p
concentrations of radioactive material in the air was not met in that air j
samples performed on May 24, 1984 to evaluate airborne radioactivity i
levels in the "A" steam generator channel head were not taken near the' L
breathing zone of the workers.
RESPONSE
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1.
Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the violation as stated.
2.
Reason for the Violation The RC Technician rendering continuous coverage did pull an air sample. The nature of the work was to pass material from inside the bowl out through the manway to the pump bay.
The technician pulled an air sample while work was ongoing at the manway believing this to be a representative sample.
3.
Corrective Steps Which Have Been Taken l
Work in the steam generator bowls is essentially complete until after completion of the primary system hydro.
If it becomes necessary to enter a steam generator bowl in the interim, the RC i
Foremen have been instructed to brief RC Technicians covering the work on the' requirements for obtaining representative air samples.
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. Lettier-to Mr. ' James P.: O'Reilly Serial: -RSEP/84-534
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- 4. :. Corrective Steps Which Will be Taken RC Technicians covering jobs will be trained on the proper techniques of obtaining steam generator bowl' air samples.
This training shall be completed prior to beginning Eddy Current _ inspection work following the primary system hydro of the steam generators.
A study 'of _ the adequacy oflthe Air Sampling Prograin will be
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conducted, and revisions to the program will'be made as necessary-to prevent further recurrence by February 28, 1985.
5.
Date When Full' Compliance Will be Achieved'
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CP&L is currently in compliance with the regulation. The study _of the Air Sampling Program should help-to refine the existing program.
. C.
Severity Level IV Violation (IER-84-17-01-SL4)
Technical Specification 6.5.1.f.1 requires that written procedures be established, implemented,-and maintained covering applicable procedures recomended in Appendix "A" of Regulatory Guide 1.33, Rev. 2, February 1978.- Appendix "A" Regulatory Guide 1.33 states that the licensee should have procedures for a Radiation Work Permit (RWP) system.
Health Physics Procedure HP-006, Radiation Work Permits'(RWP) requires that individuals know and understand RWPs prior to entering the radiation control area. Procedure HP-006 also' specifies that a Health Physics-Technician, when rendering continuous coverage for a job, is responsible' for assuring RWP requirements are met.
Contrary to the above, Procedure HP-006 was'not followed:in that:
a) on May 24, 1984, individuals entered "A" Steam Generator Channel Head with-out respiratory protection equipment required by RWP #2051, and b) the Henith Physics -Technician rendering continuous coverage for this job did not assure that the RWP requirements were met.
RESPONSE
1.
Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
2 Reason for the' Violation Upon identification of facial contamination on two personnel, the Plant staff imediately investigated the incident.
The following is a surunary of the events:
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- I$tt r ttMENJames P. i 'Reilly.
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Reason for the' Violation :(continued)..
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'The RC Technician rendering' continuous coverage.was unaware that the RWP covering the work required respiratory, protection for steam-l generator bowlientry._ The RC Technician questioned the workers on-
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Lwhat the respiratory protection requirements were, and it was..the consensuseof: opinion ~that the RWP, respiratory protection require-ments were "as posted." : The~ RC Technician made an on-the-job deci-
- sion to not require respiratory protection based on his understanding.
--ofathe following:
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(a) ' Bowl Sir had been ' consistently clean -(40.25MPC) even during t
welding and grinding activities.'
(b) - The job was in a high radiation area (300-400 mR/hr) and could
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be completed more. efficiently without respirators.-
(c) Engineering controls were in place. These controls were in the
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form of-a HEPA ventilation system rated at 2000 cfm flowing-through a small confined area.
L (d).There was no posting that required respiratory protection for entry into the. bowl..
After the investigation, it was decided to notify the NRC of the incident even though it was not. reportable.
l 3.
Corrective Steps Which Have Been Taken The RC' Technician was counseled and trained immediately following the incident. He acknowledged his errors in judgment in that he should have known the requirements for-that job before allowing j
the work to be performed in the steam generator bowl.
In addition, l
the lead RC Technician in containment has'been given a notebook of F
contsinment RWPs to facilitate distribution of information to workers and RC Technicians.
4 4.
Corrective Steps Which Will be Taken The corrective actions which were taken are considered adequate to avoid further recurrence.
b 5.
_Date When Full Compliance Will be Achieved Full compliance has been achieved.
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-Letter;to Mr. James P. O'Reilly;
' Serial: RSEP/84-534~
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If you hAve any questions concerning this' response,.please ' contact my ataff or'me..
'Very truly yours, R.'E. Morgan General Manager H. B. Robinson SEG Plant.
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