ML20207D152
| ML20207D152 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/18/1986 |
| From: | Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20207D120 | List: |
| References | |
| NUDOCS 8612300336 | |
| Download: ML20207D152 (6) | |
Text
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Cm WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968
- 3000 George Washington Way
- Richland Wa,shington 99352 i;
5 rs Z
Docket No. 50-397 t-2 November 18, 1986 t
Mr. J. B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
Subject:
NUCLEAR PLANT N0. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 86-28 AUGUST 11 - SEPTEMBER 19, 1986 The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated October 20, 1986. Our reply, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).
In Appendix A, an explanation of our position regarding the validity of the violation is provided.
Should you have any questions regarding our response, please do not hesitate to contact me.
Very truly yours, 8612300336 861219 d
DR ADOCK 050 7
/
G. C. Sorensen Manager, Regulatory Programs GCS:m l
Attachment cc: Mr. J.0. Bradfute - USNRC Mr. R.T. Dodds - Resident Inspector (901A)
r L
Appendix A Page 1 of 5 APPENDIX A As a result of the inspection conducted during the period of August 11 to September 19,1986 (Inspection Report 86-28), and in accordance with the NRC Enforcement Policy (10CFR2, Appendix C), the following violations were identified:
A.
Technical Specifications, Section 6.8.1 reads in part:
" Written procedures shall be established, implemented and maintained covering the activities referenced below:
(a) The applicable procedures recommended in Appendix A of Regulatory Guide (R.G.) 1.33, Revision 2,1978." RG 1.33, Appendix A, Item 8(a)(2) lists examples of equipment for which procedures s50uld be provided to insure measuring and testing devices are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy.
Item 8(a)(2)(aa) includes equipment such as area, portable and airborne radiation monitoring instruments.
Health Physics Program Description (HPD) 3.1.9, Revision 1, dated 9-11-81, paragraph 3.1.9.3, " Portable Monitoring Instrumentation," reads:
" Portable radiation monitoring instruments shall be calibrated every six months as a minimum and any time a field check indicates an out-of-date calibration condition."
Contrary to the above, 1). On August 11, 1986, Remote Area Monitor (RM) - 16, Serial Number RM-104, located on the 501' level of the Reactor Building, was in operation and not in current calibration. CalibrLtion was due on June 4,1986.
2). On August 12, 1986, Beta Air Monitor, Serial Number, C005739 in operation on the 441' level of the Turbine Building was not in current calibration. Calibration was due on February 1, 1986.
This is a Severity Level IV Violation (Supplement 1).
Validity of Violation The Supply System acknowledges the validity of this violation. However, it should be noted that the Remote Area Monitor (item A.1) was not removed from service at the calibration due date because the monitor was located in a High Radiation Area. Health Physics personnel were aware that the instrument was out of calibration; however, the instrument was not being used for personnel entry into the work area.
App:ndix A Page 2 of 5 Corrective Steps Taken/Results Achieved 1.
Instruments which were out of calibration were removed from service and replaced with currently-calibrated instruments.
2.
Health Physics personnel have been instructed to either remove from service all instruments which are out of calibration, or tag such instruments "out of service" until they can be removed.
3.
Health Physics personnel have assumed the responsibility, via the Scheduled Maintenance System (SMS) Tracking Program, to ensure that such equipment is either within current calibration or removed from service prior to the calibration due date.
Corrective Action to be Taken None Date of Full Compliance N/A B.
Technical Specifications, Section 6.12, "High Radiation Areas," requires that each area in which the intensity of radiation is greater than 100 mrem /hr shall be barricaded and conspicuously posted as a High Radiation Area.
Contrary to the above, on September 16, 1986, the NRC inspectors identified the following:
1). In the northeast stairwell of the Turbine Building whole body radiation levels up to 110 mrem /hr were measufed between the 441' and 471' level and the area was not posted as a High Radiation Area.
2). A work platform located immediately adjacent to the Main Condenser (south side, center, between pillars 10 and 11) on the 441' level of the Turbine Building, having whole body radiation levels measured at up to 140 mrem /hr, was not posted as a high radiation area.
3). A doorway (No. T-306), located on the 501' level of the Turbine Building providing access to the low pressure turbine area of the 501' level having general whole body radiation levels measured at up to 800 mrem /hr, was not posted as a high radiation area.
This is a Severity Level IV Violation (Supplement 1).
a.
Appendix A Page 3 of 5 Validity of Violation The Supply System acknowledges the validity of this violation. However, the following should be noted:
1.
There were two ladders leading to the work platform (item B.2) in the area. Although the side ladder was not posted, the main ladder was posted as a High Radiation Area.
2.
Doorway T-306 (item B.3) had been posted but the sign had fallen d own. The High Radiation Area being posted was controlled because the door was locked and the keys are controlled by Health Physics personnel.
Corrective Steps Taken/Results Achieved 1.
All areas were immediately surveyed, barricaded, and posted.
2.
More frequent plant tours and review of work areas have been initiated by Health Physics Management, Foremen and Technicians.
Corrective Action to be Taken None Date of Full Compliance N/A C.
10 CFR Part 20.203(b), " Caution Signs, Labels, Signals, and Controls,"
requires that each area in which a major portion of the body could receive in any one hour a dose in excess of 5 mrem, or in any five consecutive days a dose in excess of 100 mrem shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
" Caution - Radiation Area".
Contrary to the above, on Septemoer 16, 1986, the personnel access leading to the Main Condenser area and its adjoining stairwell on the 441' level of the Turbine Building having whole body radiation levels measured at 3 to 100 mrem /hr, was not conspicuously posted as a radiation area in that the posting was on the swing gate and could not be seen because the gate was open against a wall.
This is a Severity Level IV Violation (Supplement IV).
Validity of Violation The Supply System acknowledges the validity of this violation.
r-d.
Appendix A Page 4 of 5 Corrective Steps Taken/Results Achieved 1.
The swing gate (which was not working properly) was removed from service and the entrance was posted with ropes and stands.
2.
All other swing gates have been evaluated and those which were found to not be working properly were removed from service, and the areas were properly posted.
3.
The more frequent plant tours discussed previously will help to ensure proper posting of radiologically-controlled areas.
Corrective Action to be Taken None Date of Full Compliance N/A D.
10 CFR 20.201(b) requires that surveys be made as may be necessary to comply with all sections of 10 CFR Part 20. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to this requirement, surveys were not made as necessary to assure compliance with 10 CFR Part 20.101(a), " Radiation Dose Standards for Individuals in Restricted Areas." Specifically, as of the day of this inspection, September 16, 1986, radiation surveys were not made in the Northeast Stairwell of the Turbine Building between January 1 and September 15, 1986, as necessary to adequately control personnel exposures to radiation (see item B.1 above).
This is a Severity Level IV Violation (Supplement IV).
Validity of Violation The Supply System acknowledges the validity of this violation. However, it should be noted that Health Physics personnel perform complete surveys of specific locations where work is to be perforned prior to personnel entry into such areas. These surveys are documented on a Radiation Work Permit (kWP).
In addition, normal work practice requires that personnel contact Health Physics prior to accessing through radiological areas.
Corrective Steps Taken/Results Achieved The Northeast stairwell of the Turbine Building was surveyed and the results were documented.
I
Appendix A Page 5 of 5 Corrective Action to be Taken 1.
All areas of the ' plant are currently being reviewed to ensure they are included on the Area Survey Maps.
2.
HealthPhy'sicsProcedurePPM 11.2.24.1, " Health Physics Work Routines, will be revised appropriately at the conclusion of the review. This will help to ensure that more detailed surveys are recorded on the area survey maps.
Date of Full Compliance Corrective action will be completed by December 31, 1986.