ML20206S020
| ML20206S020 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/05/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-530, NUDOCS 8609220016 | |
| Download: ML20206S020 (6) | |
Text
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DMh VINOINIA ELECTHIC AND PowEn COMPANY Ricnwonn,VINGINIA 20261 US SEP 11 p!,
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September 5, 1986 Dr. J. Nelson Grace Serial No.86-530 Regional Administrator NAPS /JHL/bgp Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Ccumission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
VIRGINIA ELECTRIC AND POWER OCMPANY NORTH ANNA POWER STATION UNITS NO. 1 AND 2 RESPONSE 'IO NOTICE OF VIOLATION NRC INsm;nON REPORT NOS. 50-338/86-07 AND 50-339/86-07 We have revieuxi your letter of August 8,1986, in reference to the inspection conducted at North Anna Power Station frczn March 17, 1986 to March 21,
- 1986, and reported in Inspection Report Nos. 50-338/86-07 and 50-339/86-07. Our responses to the Notices of Violation are addressed in the attachment.
s We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact me.
Very truly yours,
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's W. L. Stewart Attachment DOCK hjg5 PDk 3
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Mr. Iester S. Rubenstein, Director PWR Project Directorate #2 Division of IMR Licensing-A Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station Mr. Ieon B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A i
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4 RESPONSE 'IO NOTICE OF VIOIATION I'IDI REPORPED DURING 'IEE NIC INSPECTICE CONDUCPED FRN 1%RCH 17 'IO MARCH 21, 1986 INSPECTION REPORP NOS. 50-338/86-07 AND 50-339/86-07 NRC COMENT A.
10 CFR 71.5 requires that licensees who transport licensed material outside the confines of their plants or other place - of use, or who deliver licensed material to a carrier for transport, shall ccmply with the applicable requirments of the regulations appropriate to the -mode
'of transport of the Department of Transportation in 49 CFR Parts 170 ~
through 189.
49 CFR 173.441(a) states that except as provided in 49 CFR 173.441(b),
each package of radioactive materials offered for transportation shall be designated and prepared for shipnent so that under conditions
-normally incident to transportation, the radiation level-does not
' exceed 200 millirem per hour at any point on the external surface of-the package.
Contrary to the above, on March 5,1986, radioactive materials shipnent No. 86-BMS-14 arrived at Chem-Nuclear's Barnwell, SC facility with dose rates in excess of 200 millirm per hour on the icwer external ' surface of the package. The exceptions provided by 49 CFR 173.441(b) did not apply.
Wis is a Severity Ievel III violation (Supp1 ment V).
RESPONSE
1.
AMISSION OR DENIAL OF 'IEE AILEGED VIOIATION h is violation is correct as stated.
2.
REASON FOR 'lHE VIOIATION As stated at the Enforement Conference, on April 9,
1986, the i
root cause of the event was survey technique and superviscry j
judgment.
I - _ _._..., _. _ _.,. _, _ _.. _ - -, _ _ _.. _. _. _., _
r 3.
CORRBCTIVE STEPS WIICH HAVE BEEN TRIGN AE 'IHE RESULTS ACffIEVED
'avo independent surveys are now' conducted for radioactive materials shipnents.
A Health Physics Depen L =it supervisor is required to review for accuracy and the cmpleteness of shipping doctanents, prior to the transport of any radioactive material fran the station and sign the shipnent " Certification".
.1he appropriate Health Physics precxdure. has been revised to reflect _ modified survey _
techniques, guidance on shipping decisions and regulatory limits, and supervisory _- l review of ~ the
~
shipping docunents.
4.
CORRECTIVE STEPS WIICH WILL BE 'DOGN 'IO AVOID FURNER VIOIATIONS A Training Inpact Report will be subnitted by Septaber 15, 1986, to change the curricula of the Health Physics Technician Developnent Program, - the Health Physics Technician Continuing Training Progr e, and the Health Physics Specialist Developnent Progra - to reflect appropriate survey techniques to be used when surveying radioactive materials.
'Ihe events surrounding this violation will be presented, using Module 1 (Modifications and Experiences) of the Health Physics Technician Continuing Training Progr e, in the next retraining cycle to begin Septaber 30, 1986, and to be cmpleted by Novmber 30, 1986.
5.
DATE MEN FULL CMPLIANCE WILL BE ACHIEVED f
Full conpliance will be achieved by Novmber 30, 1986.
RESPONSE 'IO NOTICE OF VIOIATION ITD4 REPOITED DURING 'IEE NRC INSPECTION CONDUCTED FRN MARCH 17, 'IO MARCH 21, 1986 INSPECTION REPORT NOS. 50-338/86-07 AND 50-339/86-07 NBC COP 91ENP B.
10 CFR 20.201(b) specifies that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to cmply with the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201(a) defines survey to mean an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive material or other source of radiation under a specific set of conditions.
Contrary to the above, the licensee failed to adequately evaluate the extent of the radiation hazards frm February 26, 1986, to March 24,
- 1986, in that the licensee failed to perform beta radiation measurments necessary to evaluate the beta radiation levels in steam generators "A"
and "C"
prior to allowing maintenance activities to begin in the steam generators.
Wis is a Severity Level IV violation (Supplment IV).
RESPONSE
1.
ADMISSION OR DENIAL OF 'IEE AT.TPRFn VIOIATION W is violation is correct as stated.
2.
REASON FOR THE VIOIATION This violation resulted frm a decision by Health Physics Shift Supervisors not to perform beta radiation level surveys on the "A" and "C" steam generators in order to minimize technician dose.
This decision was based on their experience with similiar work activities, the cmmonality of gama radiation measurements, and that the three steam generators were exposed to the same source term. Past experience has indicated that the beta to gama ratio is similiar in the three steam generators.
Gama radiation levels were cmfirmed to be
- .h..
. consistent among the steam generators and whole body penetrating gama radiation was controlling for the workers' stay time.
3.
CORRECTIVE STEPS WIICH HAVE BEEN TAIGN AND RESULTS JOIIEVED Health Physics Shift Supervisors have been instructed to conduct both beta and gauna radiation surveys in the primary side of the stean generators _ prior _to allowing maintenance activities to begin.
4.
CORRECTIVE S'IEPS MfICH WIIL BE TAKEN 'ID AVOID FURINER VIMATIONS
'Ihe Station Radiological Work Practice for stean generator entry will
.be revised to require both gama and beta radiation measurenents to. be-performed prior to personnel entry.
Health Physics gucedures for radiological surveys will be revised to provide additional guidance to technician. and supervisory personnel conducting surveys in support of maintenance activities.
5.
DME MEN FUIL COMPLIANCE WIII BE ACHIEVED
'Ihe Radiological Work Practice and. Health Physics procedure
'enhancenents will be fully inplenented by Novenber 1,1986.
..