ML20134C495

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-395/96-07. Response Meets Requirements of 10CFR2.201.Evaluation & Conclusion Encl

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, l

issued on July 1, 1996, concerning activities conducted at your Virgil C.  !

Summer Nuclear Station. We have evaluated your response and find that it i

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."

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After careful consideration of the bases for your denial, we have concluded,

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for the reasons presented in the enclosure to the letter, that the violation

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

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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

achieved. ,

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We will examine the implementation of your actions to correct the violation

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

$ Docket No. 50-395

License No. NPF-12

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Enclosure: Evaluation and Conclusion

cc w/ encl: (See page 2) i

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9609270236 960910 r /

gDR ADOCK 0500 5

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SCE&G 2

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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

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Winston and Strawn

1400 L Street, NW Distribution w/ encl: I

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 l

Company i

Virgil C. Summer Nuclear Station l

P. O. Box 88

Jenkinsville, SC 29065

SEND TO PDR7 h NO

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SIGNATURE

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NAME KBarr ABelisle "f p N

DATE 08//9198 08 / N / S6 08 iso /96 08/ 98 08 / /96 08/ /98

COPY? (fdf) NO M NO YES NO hy NO YES NO YES NO

OFFICIAL ltELORD COPY "

DOCUMENT NAME: A:\S9601R.EDI

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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 i

Company (SCE&G) responded to the Notice on July 31, 1996. SCE&G was not in j

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 i

Guide 1.33, Revision 2, dated February 1978. Paragraph 7.e of Appendix A to l

Regulatory Guide 1.33 states that the licensee have written radiation

protection procedures, j

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

1,000 dpm/100 cm 2

Health Physics Procedure HPP-158, Contamination Control for Areas, Equipment I

and Materials, revision 7, dated April 3, 1996, Section 5.1, Contamination ,

Control of Areas / Equipment within the Radiological Controlled Area (RCA),  :

subsection 1 states, " Areas and equipment within the RCA are controlled and

posted if the smearable contamination levels exceed 1000 dpm/100 cm2  !

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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 i

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.

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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

10 CFR 20. 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

10 CFR 20.1501. 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

typically decontaminate relief valves to around 10,000 dpm/100 cm2 but i

will allow up to 50,000 dpm/100 cm 2

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 l

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 l

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

10 CFR 20.

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

. 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.

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The licensee further states that "... there are applications where placing

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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 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 l

the contaminated receptacles outside the posted and controlled area. This  !

smear was counted by the licensee and found to be approximately 15 times the '

procedural limit of 1000 dpm/100 cm2 . 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

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have been dislodged from workers protective clothing as the clothing was

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; l

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

Enclosure

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of the roped area did not appear to restrict or hinder traffic in or passing

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through the area.

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The work area in question (valve testing bench) provided a limited test of the

I licensee's contamination control program. The inspector's survey demonstrated

i that the licensee's placement of contamination receptacles outside the

i contaminated area boundary, referenced shift surveys, and routine clean up

, efforts were ineffective in preventing and/or identifying contamination

outside a contaminated area boundary. The survey results demonstrated that

the area in question was not maintained, as required, within procedural

limits.

NRC Conclusion  !

! The NRC staff concludes that the violation occurred as stated.

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Enclosure