ML20205M154
| ML20205M154 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/01/1986 |
| From: | Tucker H DUKE POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8604150110 | |
| Download: ML20205M154 (3) | |
Text
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b nt b DUKE POWER GOMI%NY P.O.DOx 33180 CHARLOTTE, N.C. 28242 ILE B. TUCKER TE LEPHONE wa u. 7 a8: 59 m a==
.s 9 t April 1, 1986 Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Comission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Subject:
Oconee Nuclear Station IE Inspection Report 50-269/85-42 50-270/85-42 50-287/85-42
Dear Sir:
In response to your letter dated February 19, 1986, which transmitted the subject Inspection Report, the attached response to the cited items of non-compliance is provided. Please note that by Duke letter dated March 21, 1986, the response date for the violation was delayed.
Very truly yours,
/d p
Hal B. Tucker SGG: sib Attachment cc:
Mr. J. C. Bryant NRC Resident Inspector Oconee Nuclear Station 8604150110 860401 ADOCK0500g9 PDR G
l l Efoi
l Violation:
1 10 CFR 20.203(c)(2)(iii) requires that each entrance or access point to a high radiation area shall be maintained locked except during periods when access to the area is required, with positive access control over each entry.
10 CFR 20.203(c)(4) states that in the case of a high radiation area established for a period of 30 days or less, direct surveillance to prevent J
unauthorized entry may be substituted for the controls required by paragraph (c)(2) of this section.
I Contrary to the above, each entrance or access point to a high radiation area was not maintained locked with positive access control over each entry in that on December 17, 1985:
(a) Scaffolding in the high pressure injection / low pressure injection hatch area of the Auxiliary Building (elevation 771) permitted access to a high radiation area. The licensee was not maintaining positive j
control over each entry.
l (b) The North exit from the Auxiliary Building (elevation 796) which provided access to a high radiation area created by the loading of low specific activity waste in a shielded cask was unlocked and the licensee was not maintaining positive access control over each entry.
Direct surveillance to prevent unauthorized entry was not being maintained over the entrance.
This is a Severity Level IV violation (Supplement IV).
Response to Part (a)
(1) Admission or denial of the alleged violation:
Example (a) is admitted, based on the NRC interpretation of 10 CFR 20.203(c)(2)(iii) for the circumstances cited.
(2) Reasons for the violation is admitted:
i While the scaffolding noted could conceivably provide a method to access the HPI/LPI pit area, it was felt that the m20 foot height of the scaffolding above the area floor would have precluded its use as an easy access point. Since no ladders or other climbing equipment were available for a safe descent into the area, an individual would have to climb or jump down from the scaffolding.
(3) Corrective steps which have been taken and the results achieved:
All scaffolding that could provide access to the HPI/LPI pit area been removed.
L
E
- ,g (4)
Corrective steps which will be taken to avoid further violations:
Permanent barriers will be installed over the pit openings to prevent unauthorized access.
(5) Date when full compliance will be achieved:
Based on present Nuclear Station Modification priorities and resources, the permanent barriers noted in (4) above will be installed by September 1, 1987.
Response to Part (b)
(1) Admission or denial of the alleged violation:
Example (b) of the violation is denied for the reasons noted below.
(2) Reasons for denial of the alleged violation:
At the time the inspector exited the Auxiliary Building into the cask loading area, a preliminary, conservative RCZ boundary was being erected. The projected dose at this preliminary area boundary was 2 mR/hr, based on previous dose readings of the waste containers. No radioactive packages had been transported into the cask loading area at the time the inspector first entered the area. The actual High Radiation Area was established when the waste containers were introduced into the loading zone, with 8 Health Physics personnel present in the area to provide positive access control during handling and loading of the cask.
The area boundaries were established with th ALARA concept of distance in mind. At no time during the cask loading did the exposure level at the boundaries exceed 1.5 mR/hr. Total personnel exposure for this cask loading operation was 80 mrea.
It should be noted that for jobs i
such as this, area posting and access control are not' required pursuant to 10 CFR 20.204(c) and (d), and that future cask loading jobs could be performed under these exceptions.
To summarize, Duke Power contends that the cited example is not a valid violation, since the final High Radiation Area controls had not been established and no source of high radiation was in the roped area when the inspector first entered. Adequate controls were in place during the actual waste transport and loading operation.
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1 I
a