ML20136F894
| ML20136F894 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/07/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-1119, NUDOCS 9703170107 | |
| Download: ML20136F894 (3) | |
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t CENTEREOR ENERGY 5501 N State Route 2 419 249-2300 JoM K. Wood Oak Harbor.OH 43449 FAX: 419 321-8337 Vce Pres &nt. Nucleter Davis Besse Docket Number 50-346 License Number NPF-3 Serial Number 1-1119 March 7, 1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001
Subject:
Response to Notice of Violation (NRC Inspection Report Number 50-346/96013
[DRS])
Ladies and Gentlemen:
Toledo Edison provides the attached Rest,onse to the subject Notice of Violation, issued on February 6,1997 (Log Number 1-3787). Toledo Edison accepts the alleged violation.
The violation involves an event where an entrance to the truck bay area adjacent to the cask wash down pit, which was a radiation area with general radiation dose rates as high as 10 millirem in one hour, was not posted in accordance with 10CFR20.1902.
Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Ver uly ycurs, DlIUdic cc:
A. B. Beach, Regional Administrator, NRC Region ill A. G. Hansen, NRC Project Manager S. Stasek, DB-1 NRC Senior Resident inspector Utility Radiological Safety Board j
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' Docket Number 50-346 License Number NPF-3 Serial Number 1-1119 Attachment Page1 Violation "10 CFR 20.1902(a) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words 4
' CAUTION, RADIATION AREA.'
Contrary to the above, as of December 6,1996, an entrance to the truck bay area, which was a radiation area with general radiation dose rates as high as 10 3
millirem in one hour, was not posted with a sign bearing the radiation symbol and the words, ' CAUTION, RADIATION AREA.' (VIO.50-346/96013-03[DRS])"
Reason for Violation i
The reason for the violation is a failure to post the ladder accessing the Auxiliary Building Train Bay as a Radiation Area following the decontamination and deposting of the adjacent cask wash pit area as a Contamination and Radiation Area. On November 8,1996, the new fuel storage area and cask wash pit area were surveyed and released as a Contamination Area. This area had been recently used to perform preventive maintenance on underwater filters. During the deposting of the contaminated area, the access to a Radiation Area in the Auxiliary Building Train Bay via a vertical ladder was not recognized by the Radiation Protection Tester nor by Supervision. This ladder is not a normal access pathway to the train bay and therefore was not recognized initially as requiring a posting. The oversight in posting was also not recognized by
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other Radiation Protection management during oversight and walkdown activities. The area remained unposted as an access to a Radiation Area until December 17,1996, when the condition was brought to the attention of Radiation Protection supervision by the NRC.
Corrective Actions Taken and Results Achieved l
Upon notification by the NRC, Potential Condition Adverse to Ouality Report (PCAOR 96-
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1568) was initiated to document and investigate the posting deficiency and the access ladder was posted as a Radiation Area on December 17,1996.
A walkdown of all other radiological postings was conducted to verify their accuracy and additional PCAORs generated as required to identify and correct deficiencies. This walkdown was completed on December 17,1996.
Corrective Actions to Prevent Recurrence The Radiation Protection Section has established a periodic routine activity to verify radiological postings. This activity involves a weekly verification of required postings. This activity was initiated on January 13,1997.
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- . A I" ~ Docket Number 50-346 i
License Number NPF-3 1
Serial Number 1-1119 Attachment
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Page 2 4
Discussions have been held between Radiation Protection Section management and all Radiation
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Protection personnel to emphasize the need to apply attention-to-detail principles to all activities, including the accuracy of radiological postings. These discussions were initiated on December 18,1996.
j Formal training to PCAQR 96-1568 and this violation will be conducted during the current
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continuing training cycle for all Radiation Protection Section persennel. The training will include discussion on identifying all access pathways to posted areas, including those rarely used. This training will be completed by April 14,1997.
Date When Full Comnliance Will be Achieved Full compliance was achieved on December 17,1996, when the Auxiliary Builcing Train Bay access ladder was posted as a Radiation Area.
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