ML20153H056
| ML20153H056 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/05/1988 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8805120107 | |
| Download: ML20153H056 (5) | |
Text
-
i o
DUKE Powna GoxPm 1
l'.o. Isox 33189 CllAHLOTTE, N.O. 28949 IIA 1.15. TUCKER Tut.menoxe vnou earnument (704) 373-4534 ususse roomervios r
May 5, 1988 i
U.S. Nuclear Regulatory Comission
' Document Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369, -370 NRC/0IE Inspection Report Nos. 50-369,370/88-06 Reply to a Notice of Violation Violation 50-369,370/88-06-01 Gentlemen:
i Pursuant to 10CFR 2.201, please find attached (Attachment 1) Duke Power Company's response to the violation identified in the subject inspection report.
During the course of reviewing the subject inspection report, Duke identified several statements which we would like to clarify.
Accordingly, please find l which provides our coments on certain items within the subject NRC i
Inspecticn Report.
l Very truly yours, l
"gn j
Hal B. Tucker SEL/270/ bhp 1
Attachment L
xc Dr. J. Nelson Grace I
Regional Administrator, Region II U.S. Nuclear Regulatory Comission i
101 Marietta St., NW, Suite 2900 Atlanta, CA 30323 Mr. Darl Hood
~
U.S. Nuclear Regulatory Comission Office of Nuclear Reactor Regulation i
Washington, D.C.
20555 a
j Mr. W.T. Orders NRC Resident Inspector McGuire Nuclear Station M
{
8805120107 880505 PDR ADOCK 05000369 Q
DCD r
l
ATTACEKENT 1 DUKE POWER COMPANY McGUIRE NUCLEAR STATION REPLY TO A NOTICE OF VIOLATION VIOLATION 50-369,370/88-06-01 4
During the NRC inspection conducted by T. R. Collins on March 7-11, 1988, the i
following violation was identified:
Technical Specification 6.12 requires that each high radiation area, as i
defined in 10 CFR Part 20, in which the intenaity of radiation is equal to or l
less than 1,000 arem/ hour at 45 CM (18 inches) from the radiation source or i
from any surface which the radiation penetrates be barricaded and conspicuously posted as a high radiation area.
It further requires that any individual permitted to enter such areas be provided with a radiation monitoring device 4
which continuously indicates the radiation monitoring device which continuously indicates the radiation dose rate in the area or radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated does is received.
Contrary to the above, on March 8,1988, the licensee failed to barricade and post a high radiation area at the Unit 2 pipe chase entrance in Room 647 on l
the 716' elevation. Dose rates in the pipe chase were up to 800 mrea/ hour at 18 inches. A health physics technician, correcting the as found condition, entered the high radiation area without a radiation monitoring device which continuously indicated the radiation dose rate or integrated the dose rate and would have alarmed when a preset dose was received.
l This is a Severity Level 1Y violation (Supplement IV).
Reply To Violation,:
i 1.
Admission or denial of violation:
Duke Power Company admits the violation occurred.
I 2.
Reason for the violation if admitted:
i l
The violation occurred because two Health Physics (HP) Technicians independently failed to properly apply basic knowledges and skills.
Technician "A" failed to close an access door and Technician "B" failed 3
i to properly access the area to close the door.
j 3.
Corrective steps which have been taken and results achieved:
i HP Technician A and B had previously signed a statement verifying that they had read and understood Technical Specification (T.S.) 6.12 on i
October 16, 1986 and on June 18, 1987, re spe ctively.
Each technician had subsequently received training regarding the requirements of T.S. 6.12 a
1 and how to properly post and barricade an area as described in the j
violation.
Immediately after the violation occurred, HP Supervision verified that the technicians understood the T.S. requirements.
All HP personnel received a written description of the incident and were reminded of the T.S. requirements during HP crew meetings.
-~. - - - -.. -,
.-,--,-,,--,-,,,,,.,,,c-,,,--,,,n.,
,,c.,,-,,,--,,a_
,, n.~
n-,,,,,-.-,-nw,_
-.n,
~.
Page 2 i
4.
Corrective steps planned to avoid further violations:
All HP Technicians, Supervision, and Staff will attend formal case studies to further analyze T.S. requirements and to evaluate the incident. The case study is designed.to point out what happened, when it happened, potential causes, short term preventative actions taken, most-
~
probable root cause, and to provide an opportunity for group analysia.
Each attendee will be able to provide input on how f'arther violations can be avoided. Management will evaluate these recommendations and implement i
appropriate changes.
5.
The date when full compliance vill be achieved:
Duke is in full compliance now.
The case study will be completed by June 1, 1988.
1 I
)
i I
l I
s I
i l
i i
l i
1 l
i l
ATTACHMENT 2 DUKE POWER COMPANY McGUIRE NUCLEAR STATION INSPECTION REPORT NUMBER 50-369, 370/88-06 CORRECTION AND CLARIFICATION The following information is of fered to clarify and/or correct information contained in the referenced report.
1.
Page 2, Section 4 of the report stated that, "It was also stated that i
corporate ALARA staff support should increase in the future due to the recent change in corporate supervisory personnel responsible for that group."
Clarification The Duke Power Company corporate ALARA staff will be providing increased support to McGuire as requested by station management due to concerns over high station doses; however, the corporate ALARA supervisor has not changed.
2.
Page 3, Section 6 of the report stated that, "Plant procedures require an investigation of all pocket ion chamber (PIC)/TLD correlations that are dif ferent by + 10%.
Correction Duke does not use fixed percentages for comparing monthly TLD and pocket dosemeter (PD) totals.
Sliding percentages are used with a positive bias to accommodate rounding off errors.
Example:
For TLDs equaling 100 i
mrem, PD totals between 55 and 170 mrem are permitted. For itDs equaling 300 mrem, PD totals from 240 to 375 mrem are allowed.
For TLDe greater than 500 mrem, the permitted range is 0.9 X TLD to 1.25 X TLD.
No TLD/PD comparisons are made for TLDs less than 60 mrem and PD totals less than 85 mrem.
3.
Page 5, Section 7 stated that, "The NaI chair counter currently in use will remain in service af ter the purchase for backup and positive count verification."
Correction i
Duke has determined that the NaI chair counter will remain in service depending upon space available following installation of the standup whole-body quick counter.
If space is not available, Duke will remove the NaI chair counter from service.
i i
Page 4 4.
Page 6, Section 9 of the report stated that, "An individual from the corporate ALARA group will be added for the May 1988 outage.
Correction In response to station requests, two individuals have been provided from l
the Duke corporate Health Physics staff to assist with ALARA planning for l
the May 1988 outage.
These individuals will work with station maintenance during job planning and execution to resolve exposure I
problems, perform dose tracking functions, and provide interface with l
station Health Physics as necessary.
5.
Page 7, Section 9 of the report stated that the inspector discussed "the l
negative effect that the setting of apparently unattainable goals may l
have on workers drive and desire to achieve those goals".
Clarification Collective dose goals for Duke Power Company are based on national averages for pressurized water reactors.
The collective dose goals for each Duke nuclear station is adjusted based on the anticipated workload using the best available industry data. The dose goals for McGuire of 1,043 person-rem is an aggressive goal that will be challenging for the station to achieve. However, tremendous progress has been made in job planning, available resources, and worker awareness of exposure. As a result, there is increasing optimism both on the corporate and station management level that the station dose goal can be achieved.
I 1
1 1
4 l