ML20154C742
| ML20154C742 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/09/1988 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-549, NUDOCS 8809150001 | |
| Download: ML20154C742 (4) | |
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VIHOINIA ELucTmIc AND Powsu COMPANY HIcnwoxo,VamotxrA sount September 9, 1988 l
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- 0. S. Nuclear Regulatory Commission Serial No.88-549 Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos.
50-338 50 339 License Nes. NPFe4 NPF-7 Gentlemen:
VIRGIN!A ELECTRIC AND POWER COMPANY NDRfTXRRK70BER STATION UNITS 1 AND 2 i
INSPECTION REPORT NOS. 50-338/88-18 AND 50-339/88-18 PLYTOANOTICEOFVIOLATION I
We have reviewed your letter of August 10, 1988 which referred to the inspection conducted at North Anna between June 6 - 10, 1988 and reported in Inspection Report Nos.
50-338/88-18 and 50-339/88-18. The respunse to the i
Notice of Violation is provided in the attachment.
We have no objection to this correspondence being made a matter of public record.
If you have any further questions, please contact us, j
t ly 'ou,,
Very/
W. R. Cartwri t
Vice President - Nuclear I
Attachment 1
cc:
U. S. Nuclear Regulatory Comission i
101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector
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North Anna Power f.tation gW
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RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN JbME 6 - 10, 1988 INSPECTION REPORT N05. 50-338/88-18 AND 50-339/88-18 NRC CCMENT J
During the Nuclear RegelatoryCommission(NRC)inspectionconductedonJune 6-10, 1988, a violation of NRC requirements was identified.
The violation l
involved an inadequate survey to identify radioactive material as required by i
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR 2, Appendix C (1986), the violation is listed below.
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10CFR20.201(b)reguireseachlicenseetomakeor cause to be made s1)maybenecessary(2) such surveys as for the licensee to comply wii.h
.I the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
l Technical specification 6.8.1 requires written procedures to be l
established, implemented and maintained covering the activities recontnended in Appendix A of Regulatory Guide 1.33, Revision 2, t
February 1978.
Regulatory Guide 1.33, Appendix A, 1978, requires written procedures l
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for contamination control, i
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Licensee procedure HP-8.0.40, Contamination Surveys, requires that loose surface contamination levels on items being released for i
unrestricted use be less than 1,000 disintegrations per minute per 100 J
square centimeters (dpm/100 cm ) beta-ganrna activity and less than 20 dpm/100 cm alpha.
The procedure also requires that the total J
contamination (fixed and loose surface contamination) on any item be less than 5,000 dpm/100 cm and that the highest radiation level shall not exceed 100 counts per minute above background measured with a thin i
window GM detector (HP-210 or equivalent detector).
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j Contrary to the above, the licenses failed to perform adequate i
contanin e'on surveys of equipment prior to release of the equipment t
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for unre,tricted use in that:
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On September 28, 1987, equipment transferred te Power Cutting Incorporated for unrestricted use had loose surface contamination levels up to 2,317 dpm/100 cm and fixed contamination levels of
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25,000 dpm/ scan, j
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On or before March 7,
- 1988, three rotometers, with fixed d
contamination levels up to 260,000 dpm/100 cm, were released from the facility for unrestricted use and stored outside the 4
radiologically controlled area.
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This is 6 Severity Level IV violation (Supplement IV).
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- RESPONSE, 7
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ADMISSION OR DENIAL OF THE ALLEGED VIOLATION i
The vio'iation is correct as stated.
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REASON FOR THE VIOLATION
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The violation was caused by performing inadequate radiological surveys.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN ANO THE RESULTS ACHIEVED l
1 A technical report evaluating the improper release of radioactive material l
from the site and recommending corrective actions to prevent recurrence 2
l was prepared by Health Physics. This report was reviewed and approved by l
the St6 tion Nuclear Safety and Oper; ting Committee (SNSOC). The following corrective actions from the report have been completed.
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A "Yard Log" was established to document the survey of items that have i
lef t the RCA for unrestricted use and that are going to leave the j
protected area in vehicles. The "Yard Log" will document the use of a green release tag.
The green releace tag will signify that the
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material has beer, surveyed and found to be free frc<n radiation and/or contamination and can be released for unrestricted use.
l The Health thysics Technician Continuing Training Program was revised
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l to incorporate lessons learned from the improper release of radioactive i
j material.
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The report was placed into required reading for appropriate Health Physics personnel, j
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Additional corrective actions were also implemented to prevent recurrence j
of the event.
i A Health Physics Shift Instruction was issued, as a temporary measure until procedures could be revised, to reduce the maximum pennissible backgruurd radiation limit in which equipment to be released for 1
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unrestricted use can be surveyed. The new background radiation limit j
i is 200 counts per minute (cpm).
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Health Physics procedures were revised to establish the 200 cpm maximum l
permissible background radiation limit in which equipment to be l
released for unrestricted use can be surveyed.
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A Radiological Incident Report was written as a result of the inadequate survey of the three contaminated rotometers.
The identified recomended corrective actions to prevent recurrence. This report was reviewed and
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i approved by the SNSOC. The following corrective actions from the report i
have been completed.
i The report was discussed with Health Physics Shift Supervisors, who then reviewed the report with their respective shift personnel to i
emphasize the cause of the event and associated corrective actions, i
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Station Administrative Procedure ADM-12.1, Heatoring and Test Equipment
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Calibration Program, has been revised to clarify the requirements for a
dispositio;) of measuring and test equipment (M&TE)
- hat cannot be
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decontaminated.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i
4 Training will be provided to M5TP user's on the '.'6 vision to ADM-12.1.
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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I
Training of M&TE user's on the revision to ADM-12.1 will be completed by l
l October 31, 1988.
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