ML20106B874

Responds to NRC Re Violations Noted in Insp Rept 50-261/84-17.Corrective Actions:Adequacy of Air Sample Program Will Be Studied & Appropriate Revs Made

ML20106B874
Person / Time
Site:	Robinson
Issue date:	08/10/1984
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20106B850	List: ML20106B860 ML20106B874 ML20106B894
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM RSEP-84-515, NUDOCS 8410230551
Download: ML20106B874 (5)

Text

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e CD&L Carolina Pcwer & Light Company H.

C PLANT POST OFFICE BOX 790 HARTSVILLE,. SOUTH CAROLINA 29550 AUG 101984 Robinson File No: 13510E Serial: RSEP/84-515 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street N.W.

Atlanta, Georgia.30323 H. B. ROBINSON SEG PLANT, UNIT 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 IE INSPECTION REPORT IER-84-17

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)

ERC 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.1-3.

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 dect.de up to 1 E+7 R/hr.

RESPONSE

1.

Admission or Denial of the Alleged Violation 1

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.

Tne Technical Manual did not describe electronic calibration for the 106 and 107 R/hr ranges.

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'3.

Ccrrective Steps Which Have Been Taken Subsequent discussion with the. vendor indicates:that there is an.

L additionalicheck which could be done to verify these upper two 6 and 107 R/hr.

channels, 10 4.-

Corrective-Steps Which Will-Be Taken

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6 7 R/hr. ranges will'be imple-A procedure to include the 10 and 10 mented.-

~5.

Date When Full Compliance Will Be Achieved Full-compliance will be achieved by September 28, 1984.

B.

Severity Level IV Violation (IER-84-17-02-SL4) 10 CFR 20.103(a)(3) requires the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting an'd evaluating airborne radioactivity in restricted areas.

Contrary to the above, the requirement to use suitable measurements of concentrations of radioactive material in air was not met in that air samples performed on May 24, 1984 to evaluate airborne radioactivity

-1cvels in the "A" steam generator channel head were not taken near the

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breathing zone of the workers.

RESPONSE

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 N

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 llave Been Taken W rk in the steam generator bowls is essentially complete until o

af ter completion of the primary system hydro.

If it becomes necessary to enter a steam generator bowl in the interim, the RC L

Foremen have been instructed to brief RC Technicians covering the work on the requirements for obtaining representative air sampics.

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' Corrective' Steps Which Will Be Taken-(RC'Technidians_ covering' jobs will;be' trained on the proper'

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^ ' techniques of obtaining steamigenerator_ bowl air samples.;

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This training shall:be completed prior to beginning ' eddy:

> current' inspection l work following:the primary' system hydro of1the:

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steam generators.'

[A atudylof?the' adequacy of the' Air Sampling-Program will be L

4 conducted and: revisions to the' program will be madeias'necessary;

, 'tofprevent further-recurrence:by February 28,11985 75.

.Date when Full Compliane'Will Be' Achieved'-

Full compliance will be achieved byfFebruary '28,-1985.-

C..

Severity Level IV Violation-(IER-84-17-01-SL4)

Technical Specification 6.5;1.1.'l requires'that written procedures bei

'estat11shed, implemented and maintained covering applicable procedures:

recommended.'in" Appendix "A" of Regulatory Guide-1.33,.Rev. 2, February.

1978.~-Appendix-"A".Esgulatory Guide:1.33 states that the licensee'should-have procedures.for a radiation work permit'(RWP) system.-

Health Physics Procedure;HP-006, Radiat. ion Work Permits (RWP) requires that individuals know and understand RWP's prior to entering the radiation

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control area.- Procedure HP-006 also specifies'that a Health Physics l '

Technician, when rendering continuous coverage for 'a job, is responsible for assuring RWP requirements are met.

Contrary to the_above,IProcedure 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~

Health Physics Technician rendering continuous coverage for.this job did not: assure that the RWP requirements were met.

RESPONSE

I 1.

Admission or Denial of The Alleged-Violation

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Carolin Power and Light Company acknowledges the alleged violation.

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2..

Reason for The Violation Ls Upon identification of facial contamination on two personnel, the l

Plant staff immediately investigated the incident.

The following is L

a summary of the events:

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Reason for the Violation (continued)

The RC Technician rendering continuous coverage was unaware that the

.Ria? _ covering the. work-required respiratory protection for steam

-.: generator bow 1 ' entry. : The RC Technician questioned the workers int what the respiratory protection requirements were. and it was the consensus of 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~understandingL of the following:

' (a) - Bowl: air had beenJconsistently clean ( 0.25MPC) even during welding and grinding activities.

(b) -The job was in a high radiation arca1(300-400 mR/hr) and could be completed more efficiently without respirators.

(c) Engineering controls were in place.. These controls were in the form of a HEPA ventilation system rated at-2000 cfm flowing through a smal1~ confined area.

(d) There was no posting that required respiratory protection for entry into the bowl.

. Af ter the investigation, it was decided to notify the NRC of the incident even though it was not reportable.-

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 the work to be performed in the steam generator bowl.

In addition, the lead RC Technician in containment has been given a notebook of containment RWPs to facilitate distribution of information to workers and RC technicians.

4.

Corrective Steps Which Will Be Taken The corrective actions which were taken are considered adequate to avoid further recurrence.

5.

Date When Full Compliance Will Be Achieved

. Full compliance has been achieved.

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=Iflyou-have~any questions concerning.this-. response,-please contact my-staff-

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Very truly yours,

- R. ~ E.

rgan

General-' Manager

H. B. Robinson SEG Plant's

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