ML20215E542
| ML20215E542 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 10/02/1986 |
| From: | Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8610150365 | |
| Download: ML20215E542 (3) | |
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ErYorporation 88 0CT 9 A9: 9 Drams R l
Colurttia.Soum Carolvia 29250 iB031762610 October 2, 1986 U. S. Nuclear Regulatory Commission ATTN: Mr. J. Philip Stohr, Director Division of Radiation Safety and Safeguards Region II 3
101 Marietta Street, N. W., Suite 2900 Atlanta, Georgia 30323 RE: NRC Report No. 70-1151/86-12 Gentlemen:
Pursuant to the provisions delineated in Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, Westinghouse herein provides, in Appendix A, formal response to your letter of September 4,1986, regarding your inspection of our facilities conducted during the period July 28 to August 1, 1986.
i Should you have any questions or require additional information, please telephone me at (803) 776-2610.
I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION l
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E. P. Loch, Manager l
Columbia Plant lb WP0233E:3p.1
Attachment:
Appendix A 0610150365 861002 PDR ADOCK 07001151 C
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9 October 2, 1986 70-1151/86-12 APPENDIX A WESTINGHOUSE RESPONSE TO NRC NOTICE OF VIOLATION Violation: Failure to follow the requirements of approved radiation protection procedures (four examples).
The violation is correct as stated in your Notice of Violation.
Example 1: Decontamination Limits (1) The example is correct as stated in your Notice of Violation (2) When Health Physics Operating Procedure 05-014 was revised to incorporate the modified contamination control action levels of license StN-1107, a smearable limit of 3,000 dpm/100 cm2 was established in Section 7.5.5 of the procedure for Controlled Aisleways (which is well below the Controlled Area license limit of 5,000 dpm/100 cm2).
However, Appendix I of this procedure was inadvertently not changed to reflect this new limit (Appendix I continued to reference a 1000 dpm/100 cm2 limit).
When the new contamination surveillance forms were printed, they listed the action levels from Section 7.5.5 of the procedure.
3)
Health Physics Operating Procedure 05-014 was revised and approved on July 31,1986 to make Appendix I consistent with action levels in the body of the. procedure and the surveillance forms.
All procedural requirements are now being implemented.
4)
Cognizant individuals have been reinstructed to exercise more care when modifying procedures.
5)
Full compliance has been achieved.
Example 2: Personnel Monitoring (Frisking) 1)
The example is correct as stated in your Notice of Violation.
2)
Although personnel were monitoring themselves, certain individuals were not adhering exactly to the posted instructions.
Although no single cause was identified for these occurrences, several corrective actions have been taken to prevent a recurrence based upon a review of the program.
3)
Comprehensive retraining of plant personnel (including management) was conducted to a) reinforce management's commitment to personnel monitoring, b) reinstruct individuals in the proper frisking techniques, l
c) re-emphasize the importance of adhering to procedures, and o) demonstrate proficiency of surveying techniques.
Training was completed by September 19, 1986.
An audit program has been initiated to monitor the effectiveness of this training.
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4)
An evaluation is underway to determine methods of streamlining the frisking program to facilitate ccmpliance by plant personnel, i
5)
Retraining of plant personnel is complete and the audit program is implemented. _ Program evaluation and revision, as appropriate, will be completed by November 30, 1986.
i Example 3: Personnel Monitoring When Exiting " Limited Areas" i
1)
The example is correct as stated in your Notice of Violation.
i 2)
Based upon an engineering evaluation, a frisking station had been established for the Analytical Chemistry Laboratory to monitor personnel exiting the laboratory.
This control has been effective in controlling j
contamination in this area as determined by contamination surveillance.
j 3)
A procedure was written and approved on September 17, 1986 requiring laboratory personnel to survey themselves when exiting the area.
In 1
addition, the frisker was relocated to the laboratory exit and this exit l
was posted to alert non-laboratory personnel to the frisking requirement.
Contamination surveillance will continue to monitor the effectiveness of this procedure.
4)
Regulatory Affairs Procedure RA-201, " Contamination Control," was revised on September 26, 1986 to incorporate a requirement to evaluate facility zoning from-a contamination control standpoint, to assure that appropriate controls have been established, including. personnel frisking.
This applies to other " limited areas" throughout the Columbia 1
Site.
5)
Full compliance has been achieved.
Example 4: Responses of Instruments to Check Sources 1)
The example is correct as stated in your Notice of Violation.
2)
These procedures were written for use by trained Health Physics Technicians who are instructed in the operation of radiation detection l
instrumentation.
It is our opinion that this training has been effective in the application of good judgment on the part of Health Physics Technicians during the source checking of instruments.
3)
Health Physics Operating Procedures concerning instrument are being revised to describe acceptance criteria for source checking prior to use i
of the instruments.
4)
The corrective steps in Item (3) above should be effective in preventing i
recurrence.
l 5)
Full compliance will be achieved by October 31, 1986.
l WP0233E:3p.22 2
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