ML20212H723
| ML20212H723 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/19/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NUDOCS 8701270548 | |
| Download: ML20212H723 (6) | |
Text
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10 CFR 2.201 VinoxxxA ELECTRIC AND POWEN COMi%NY HIcnwoNn,VIHOINIA 2352 61 W.L.Stewaar v.c. v.s.io==,
January 19, 1987 Ncca. man orsmATsons U. S. Nuclear Regulatory Commission Serial No.86-848 Attn: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos.
50-338 50-339 License Nos. NPF-4 NPF-7 Centlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/86-27 AND 50-339/86-27 We have reviewed your letter of December 19, 1986, in reference to the inspection conducted at the North Anna Power Station from November 17, 1986 to November 21, 1986, and reported in Inspection Report Nos. 50-338/86-27 and 50-339/86-27. Our response to the Notice of Violation is addressed in the attachment.
We would also like to clarify some issues that were raised in section 10 of the inspection report. Section 10a of the inspection report indicated that the licensee did not have routine audits scheduled for health physics activities other than periodic audits of the PCP program, which included various aspects of auditing the transportation program. As discussed with a member of your staff on January 12, 1987, routine audits are scheduled and performed in accordance with Technical Specification 6.5.3 in the following areas: Radiological Environmental Monitoring, Offsite Dose Calculation Manual and implementing procedures, Process Control Program, training and performance and qualification of personnel in these areas.
In addition, audits are i
performed to ensure conformance of operations to the provisions of other Technical Specifications and license conditions.
In addition, Section 10b of the inspection report stated that the licensee had not established a schedule for surveillances. The surveillance program was developed to enhance the audit program by analyzing and evaluating information obtained from sources such as deviation reports, inspection reports, inspection and enforcement reports and notices, and previous surveillances and audits.
The frequency of the surveillance will be based on the evaluation of this data. The surveillances are intentionally not scheduled so that when the surveillance is performed the data obtained will be more representative of actual plant conditions.
ER2*EBM ETgge IE o /
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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, kk W. L. Stewart Attachment
cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station l
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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING THE NRC INSPECTION CONDUCTED FROM NOVEMBER 77, IU NOVEMBER 21, 1986 INSPECTION REPORT NOS. 50-338/86-27 AND 50-339/86-27 NRC COMMENT Technical Specification 6.8.1 states that written procedures shall be established, implemented, and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2, February 1978.
Appendix A, Regulatory Guide 1.33, Paragraph 8.a recommends that the licensee maintain procedures to ensure that tools, gauges, instruments, controls and other measuring and testing devices are properly controlled, calibrated and adjusted at specific periods to maintain accuracy.
Contrary to the above, the licencee failed to ensure that tools, gauges, instruments, controls and other measuring and testing devices were properly controlled, calibrated and adjusted at specific periods to maintain accuracy in that on November 20, 1986, it was determined that a calibration procedure had not been established for alpha scintillation counter, Serial No. 737, with AC-3 probe, and that this instrument had been used to quantitate removable alpha contamination from the 244 foot elevation of the Auxiliary Building on November 3, 1986.
This is a Severity Level V violation (Supplement IV).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is correct as stated.
2.
REASON FOR THE VIOLATION This violation is the result of an inadequate procedure.
The instrument calibration procedure did not provide detailed instructions in the calibration of the RM-20, when using an alpha scintillation detector (AC-3).
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The alpha scintillation counter (Eberline RM-20, Serial No.
737, and AC-3 probe) was removed from service on November 21, 1986. Alternative equipment, gas-flow proportional countern, were available for measuring alpha contamination.
Similar instrument calibration procedures have been reviewed for adequacy, and appropriate procedures have been revised and/or developed.
Supervisory personnel responsible for the preparation, review, and approval of the Health Physics procedures have been reinstructed in the proper methods of procedure development and validation.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are necessary.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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VERIFICATI0lt OF ACCURACY The following procedures were created and approved by SNSOC on 1/12/87 as a result of this violation; HP-3.4.1.10 HP-3.4.1.11 HP-3.4.2.8 The following procedures were revised and approved by SNSOC on 1/13/87 as a result of this violation; HP-3.3.3.2 HP-3.3.3.19 Supervisory personnel were instructed by the Superintendent Health Physics on the proper methods of procedure development and validation. This inotruction took place on 1/12/87.
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