ML20147C267
| ML20147C267 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 01/08/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801190150 | |
| Download: ML20147C267 (4) | |
Text
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. DUKE Powan GOMPANY P.O. BOX 03889 CHAMLOT17., N.o. 98949 MALH. TUCKER retarnown (704)373 4834 vu e.
en stu aae e.ceewton
' January 8, 1988 U. S. Nuclear Regulatory Connission Attention: Document Control Desk
- Washington, D. C. 20555
Subject:
Catawba Nuclear Station Docket Nos. 50-413 and 50-414 IE Report 50-413/87-40 RII: CHB
Dear Sir:
Please find attached responses to the Violations 413,414/87-40-01 and 413,414/87-40-03 as identified in the subject Inspection Report.
Very truly yours, C
/
kO' Hal B. Tucker LTB/1222/sbn Attachment xc:
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Connission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station k
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DUKE POWER COMPANY REPLY TO A NOTICE OF VIOLATION 413, 414/87-40-01 10 CFR 19.11(a)(4) requires each licensee to post current copies of any Notice of Violation involving radiological working conditions.
Part 19.11(o) requires that such documents remain posted for minimum of five working days or until action correcting the violation has been completed whichever is later.
Contrary to the above, the Notice of Violation issued on October 19, 1987 (Inspection Report Nos. 50-413/87-31 and 50-414/87-31) concerning a violation for failure to perform adequate personnel monitoring was not posted during the week of November 16-20, 1987, on any of the bulletin boards used to post other documents required by Part 19.
Licensee corrective action was not due to be completed until January, 1988.
RESPONSE
(1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation if Admitted The Notice of Violation was not recognized as meeting the requirements for posting as specified by 10 CFR 19 when the violation was reviewed by plant personnel. Since the Violation did not appear to address actual working conditions, such as a high radiation area, but was related to proper work practices, it was not recognized as a violation involving radiological working conditions. This was a personnel error.
(3) Corrective Actions Taken and Results Achieved When notified by the inspector on November 17, 1987 that the Notice of Violation should have been posted as required by 10 CFR 19, copies of the Notice of Violation and the Duke Power Company response were immediately posted in the appropriate locations.
(4) Corrective Actions to be taken to Avoid Purther Violations Notices of Violation concerning radiation protection will be reviewed by station personnel to determine if the Violation involves radiological working conditions. This review will be performed with the consideration of the broader application of the term "radiological working conditions" to ensure that Violations involving work practices or other appropriate areas are posted as required.
(5) Date of Full Compliance i
Duke Power Company is now in full compliance.
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DUKE POWER COMPANY RESPONSE TO VIOLATION 413, 414/87-40-03 Technical Specification 6.8.1 requires that written procedures be established, implemented, and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1987.
Procedures for contamination control are recommended by paragraph 7.e.4 of Appendix A.
Technical Specification 6.11 requires that procedures for Personnel Radiation Protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Catawba Nuclear Station Directive 3.8.3, Contamination Prevention, Control of Decontamination Responsibilities, revision 21, dated July 2, 1987, requires in section 4.5.1 that items within clean areas of the radiologically controlled area be maintained with working limits for contamination less than 1,000 disintegrations per minute per 100 square centimeters (1,000 dpm/100 cm2) Beta, Gamma.
Contrary to the above, the licensee failed to establish adequate written procedures to assure that tools located in the non-contaminated area of the Hot Tool Room were stored with working levels of surface contamination less than 1,000 dpm/100 cra2 in that on November 10, 1987, three tools were found in the Hot Tool Room with contamination levels in excess of the limits.
REEDONSE (1) Admission or Denial of Violation Duke Power Company admits the violation.
(2) Reasons for Violation if Admitted Personnel error due to improper survey of tools.
(3) Corrective Actions Taken and Results Achieved (a) Ccintaminated tools were relocated to the radiation Control Zone in the Hot Tool Room.
l (b) Health Physics performed a detailed inspection of the Hot Tool Room and discovered one additional tool on the clean side contaminated. This tool was also placed in the Radiation Control Zone of the Hot Tool Room.
(4) Corrective Actions to be taken to Avoid Further Violations (a)
In order to prevent hot tools from being placed in the clean side of the Hot Tool room, the clean side area will be eliminated. We will expand our zone to include the entire Hot Tool Room as a Contaminated Storage Area. We will issue all tools from the Hot Tool Room as if l
they were hot. This change will not, however, prevent us from trying l
to keep our tools as clean as possible and below the required contamination limits.
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(b) The step off pad boundary will be extended to include all tools in the room to reflect potentially contaminated tools.
(c) The Radiation Work Permit for the Hot Tool Room will be changed to include a whole body frisk upon leaving the step off pad.
(d) All Personnel involved in this violation shall receive a training session on these changes and the importance of detailed surveys of our eq.11pment.
(5) Date of Full Compliance All corrective actions to be completed by January 31, 1988.