ML20134C495
| ML20134C495 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/10/1996 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Gabe Taylor SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| NUDOCS 9609270236 | |
| Download: ML20134C495 (7) | |
See also: IR 05000395/1996007
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September 10,~1996
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South Carolina Electric & Gas Company
ATTN: Mr. Gary J. Taylor
Vice President, Nuclear Operations
Virgil C. Summer Nuclear Station
P.' O. Box 88
Jenkinsville, SC 29065
SUBJECT: NRC INSPECTION REPORT NO. 50-395/96-07
Dear Mr. Taylor:
-Thank you for your response of July 31, 1996, to our Notice of Violation,
issued on July 1, 1996, concerning activities conducted at your Virgil C.
Summer Nuclear Station. We have evaluated your response and find that it
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meets the requirements of 10 CFR 2.201.
In your response, you state " South Carolina Electric & Gas Company (SCE&G) is
not in agreement with this violation."
After careful consideration of the bases for your denial, we have concluded,
for the reasons presented in the enclosure to the letter, that the violation
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occurred as stated in the Notice of Violation. Therefore, in accordance with
10 CFR 2.201 (a), please submit to this office within 30 days of the date of
this letter a written statement describing steps which have been taken to
correct the violation and the results achieved, corrective steps which will be
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taken to avoid further violations, and the date when full compliance will be
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achieved.
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We will examine the implementation of your actions to correct the violation
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during future inspections.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed.in the NRC Public Document Room.
We appreciate your cooperation in this matter.
Sincerely,
(Original signed by A. F. Gibson)
Albert F. Gibson, Director
270029
oivision of Reactor Safety
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Docket No. 50-395
License No. NPF-12
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Enclosure:
Evaluation and Conclusion
cc w/ encl:
(See page 2)
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9609270236 960910
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SCE&G
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cc w/ encl:
R. J. White
G. A. Lippard, Acting Manager
Nuclear Coordinator (Mail Code 802)
Nuclear Licensing & Operating
S.C. Public Service Authority
Experience
(Mail Code 830)
c/o Virgil C. Summer Nuclear Station
South Carolina Electric & Gas
P. O. Box 88
Company
Jenkinsville, SC 29065
Virgil C. Summer Nuclear Station
P. O. Box 88
J. B. Knotts, Jr., Esq.
Jenkinsville, SC 29065
'
Winston and Strawn
1400 L Street, NW
Distribution w/ encl:
Washington, D. C.
20005-3502
G. Belisle, RII
Chairman
L. Garner, RII
Fairfield County Council
A. Johnson, NRR
P. O. Drawer 60
R. Gibbs, RII
Winnsboro, SC 29180
P. Fillion, RII
E. Testa, RII
Virgil R. Autry, Director
W. Stansberry, RII
Radioactive Waste Management
C. Payne, RII
Bureau of Solid and Hazardous
G. Hallstrom, RII
Waste Management
PUBLIC
S. C. Department of Health
and Environmental Control
NRC Resident Inspector
2600 Bull Street
U.S. Nuclear P.egulatory Commission
Columbia, SC 29201
Route 1, Box 64
Jenkinsville, SC 29065
R. M. Fowlkes, Manager
Operations
(Mail Code 303)
South Carolina Electric & Gas
Company
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Virgil C. Summer Nuclear Station
P. O. Box 88
Jenkinsville, SC 29065
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Evaluation and Conclusion
On July 1,1996, a Notice of Violation (Notice) was issued for a violation
identified during a routine NRC inspection.
South Carolina Electric & Gas
Company (SCE&G) responded to the Notice on July 31, 1996. SCE&G was not in
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agreement with the violation.
The NRC's evaluation and conclusion regarding
the licensee's arguments are as follows:
Restatement of the Violation
Technical Specification 6.8.1 requires, in part, that written procedures be
established, implemented, and maintained covering the activities referenced in
the applicable procedures recommended in Appendix "A" of Regulatory
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Guide 1.33, Revision 2, dated February 1978.
Paragraph 7.e of Appendix A to
Regulatory Guide 1.33 states that the licensee have written radiation
protection procedures,
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Station Administrative Procedure SAP-500, Health Physics Manual, revision 8,
dated December 9,1993, Section 6.4.L, Monitoring and Control of Surface
Contamination, subsection 1 states, " Contaminated surfaces of permanent
structures within the Radiation Control Area are controlled and posted if
Beta / gamma emitting loose surface contamination levels exceed
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1,000 dpm/100 cm
Health Physics Procedure HPP-158, Contamination Control for Areas, Equipment
and Materials, revision 7, dated April 3, 1996, Section 5.1, Contamination
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Control of Areas / Equipment within the Radiological Controlled Area (RCA),
subsection 1 states, " Areas and equipment within the RCA are controlled and
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posted if the smearable contamination levels exceed 1000 dpm/100 cm
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Bota-Gamma or 100 dpm/100 cm Alpha."
Contrary to the above, on April 30, 1996, on elevation 436' in the Hot Machine
Shop, the licensee failed to follow the procedural requirements for posting
and controlling contaminated areas. The NRC identified contamination levels
15 times greater than the procedural limits for Beta-Gamma outside the posted
contamination area.
Summary of the Licensee's Response
SCE&G does not consider the condition, as described above, to be contrary to
procedural requirements. The procedural limits provide criteria for posting
contaminated areas upon completion of surveys used to measure loose surface
contamination.
The limits are not intended to imply that such conditions can
never occur nor are they intended to imply that a procedural violation exists
prior to having knowledge of the actual levels of contamination present. This
philosophy is consistent with good operating practice and ALARA principles.
Enclosure
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10 CFR 20 requires the licensee to control the receipt, possession, use,
transfer, and disposal of licensed material in a manner that limits the total
dose to an individual below the standards for protection prescribed in
Controls for loose surface contamination are in compliance with
10 CFR 20 when licensed materials are maintained within the restricted area as
defined by 10 CFR 20.1003, occupational doses are limited in accordance with
Subpart C, and surveys and monitoring are performed in accordance with
The above described condition did not result in any
significant c:cupational dose nor did it create a potential for the
unintentional release of licensed material from the restricted area at the
Virgil C. Summer Nuclear Station (VCSNS).
Radiological controls in the area and routine surveys support this conclusion
as follows:
1.
Additional smears taken in the area by the inspector did not indicate
the presence of loose surface contamination.
The smear, which formed
the basis for the violation, was from an area within a few inches of the
rope boundary.
The attached photograph and diagram of the area (re-
created) show where the inspector obtained the smear with loose surface
contamination. As shown by the attached, the loose surface
contamination was confined to a very small area located where the
potential for further spread was very limited. The surveys described
below further support the fact that the potential for spreading was very
limited.
2.
Step-off-pads for contaminated areas are surveyed every shift while the
area is in use.
Routine smears of step-off-pads are generally taken
from the center of the pad where most foot traffic occurs. Smear
surveys on the test bench step-off-pad from April 16 to May 10 did not
indicate any loose surface contamination. This demonstrates that the
loose surface contamination was confined to a small area or near the
corner of the pad.
3.
Daily sweep surveys are performed in hallways and traffic areas within
the RCA.
Sweep surveys are performed by using an oil cloth on the end
of a 24" dust mop to sweep the floor surface being surveyed.
The cloth
is then monitored by a portable survey instrument to determine if any
loose surface contamination was picked up by the oil cloth.
Sweep
surveys performed from April 16 to May 10 in the area surrounding the
posted contaminated area did not indicate the presence of any loose
surface contamination.
4.
The contaminated area shown by the photograph contained a bench for
testing relief valves.
Occupational dose was maintained ALARA by
decontaminating relief valves prior to bench testing.
Plant personnel
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typically decontaminate relief valves to around 10,000 dpm/100 cm but
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will allow up to 50,000 dpm/100 cm if further decontamination efforts
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Enclosure
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will yield limited results. This typically requires decontamination
factors between 50 and 100.
These actions maintained contamination
levels low and minimized the potential for the spread of contamination.
5.
Personnel and materials exiting the RCA are monitored for the presence
of licensed materials. Abnormal occurrences or trends are investigated
to ensure licensed materials are properly controlled.
No abnormal
trends were indicated from April 16 to May 10.
The cover memorandum accompanying the Notice of Violation stated that the
violation is of concern because the practice of placing contaminated
receptacles outside the posted contaminated area invites the spread of
contamination.
SCE&G agrees with the inspector that placing receptacles for
removing protective clothing within the contaminated area boundary is a good
practice.
This is the normal practice at VCSNS; however, there are
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applications where placing receptacles outside the contaminated area is
appropriate.
For example, the area around the test bench was maintained as
small as possible to allow the movement of materials to and from the radwaste
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areas adjacent to the test bench. The receptacles were placed outside the
contaminated area to provide adequate room for working on the test bench.
Even though placement of the receptacles deviated from normal practice, the
controls and surveys were adequate to prevent the spread of contamination.
All elements of the VCSNS radiological control program and procedures were
fully implemented at the time of the inspection.
Radiological controls for
the work and routine surveys ensured the confinement of loose surface
contamination.
The inspector surveyed several other plant areas which
confirmed the aggressive nature of the SCE&G contamination control program and
effective procedure implementation.
Your reconsideration of this violation is appreciated. As previously stated,
SCE&G does not consider the observed condition to be a procedure violation
since there was no prior knowledge of the actual level of contamination
present and full compliance was maintained with station procedures and
NRC Evaluation
The following sequence of events provides a synopsis of activities surrounding
the discovery and licensee discussions about the violation. Two inspectors
accompanied by a licensee representative were traversing the area (elevation
436 ft. in the Hot Machine Shop) on their way back from the outside radwaste
storage and handling area and came upon this posted area with the contaminated
receptacles positioned outside of the roped contaminated controlled area
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boundary. The licensee's reply made the following statement, "SCE&G agrees
with the inspector that placing receptacles for removing protective clothing
within the contaminated area boundary is a good practice." The two inspectors
were concerned about the unusual positioning of the receptacles since
contamination control measures appeared to be defeated by this arrangement.
Enclosure
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The licensee further states that "... there are applications where placing
receptacles outside the contaminated area is appropriate.
For example, the
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area around the test bench was maintained as small as possible to allow the
movement of materials to and from the radwaste areas adjacent to the test
bench. The receptacles were placed outside the contaminated area to provide
adequate room for working on the test bench.
Even though placement of the
receptacles deviated from normal practice, the controls and surveys were
adequate to prevent the spread of contamination." The smear taken in the
vicinity of this area demonstrated that this was not the case.
The inspectors
requested patches for smears and the inspectors, with the licensee observing
procured three smears; one generally as shown in the licensee's document and
the others near but not in the close vicinity.
Two of the smears (those not
in the close vicinity) were counted and were below the procedural limit. The
third smear was taken in the area shown in the licensee's photograph and
diagram because the inspectors suspected a potential contamination control
problem near the contaminated areas' boundary resulting from the placement of
the contaminated receptacles outside the posted and controlled area. This
smear was counted by the licensee and found to be approximately 15 times the
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procedural limit of 1000 dpm/100 cm .
The smear was taken in that selected
location because, in the inspectors professional judgement, that location
appeared to be the most likely location of contaminated material that might
have been dislodged from workers protective clothing as the clothing was
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deposited in the waste receptacle.
In the licensee's response, the second supporting statement was that the step-
off-pads for contaminated areas are surveyed every shift while the area is in
use and that smears are generally taken from the center of the pad where most
foot traffic occurs.
These smears and surveys for the test bench step-off-pad
from April 16 to May 10 did not indicate any loose surface contamination;
thus, demonstrating that loose surface contamination was confined to a small
area or near the corner of the pad.
The inspectors observed that foot traffic
is not always directed through the center of the pad.
Licensee routine checks
included surveys every shift, with smears generally taken from the center of
the pads.
Licensee smears were inadequate to detect contamination elsewhere.
Additional diligence to ensure contamination containment during deviation from
normal practice is warranted.
The licensee performed an area decontamination without taking additional
smears to attempt to characterize the area in the vicinity of the receptacles.
No data was presented for smears taken in the area at the time the smear in
question was obtained. The lack of additional data to support the licensee
beliefs were discussed on at least three occasions. Those discussions were
conducted as follows:
1) Daily debrief on April 30, 1996;
2) Pre-exit
debrief on May 2, 1996; and finally 3) Exit Meeting on May 3, 1996. The
inspector at each of the debriefs reemphasized that, absent additional
licensee smear data supporting their view, there was no assurance that the one
smear taken by the inspectors did not represent a greater problem in the area.
The inspectors observed during a later visit to the area that the enlargement
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of the roped area did not appear to restrict or hinder traffic in or passing
through the area.
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The work area in question (valve testing bench) provided a limited test of the
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licensee's contamination control program.
The inspector's survey demonstrated
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that the licensee's placement of contamination receptacles outside the
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contaminated area boundary, referenced shift surveys, and routine clean up
efforts were ineffective in preventing and/or identifying contamination
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outside a contaminated area boundary. The survey results demonstrated that
the area in question was not maintained, as required, within procedural
limits.
NRC Conclusion
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The NRC staff concludes that the violation occurred as stated.
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Enclosure