ML20215K016
| ML20215K016 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/16/1986 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RNPD-86-4795, NUDOCS 8610270311 | |
| Download: ML20215K016 (4) | |
Text
b Cp&L Carolina Power & Light Company
.. ::, u.
n ROBINSON N bOSddD TMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 1
OCT161986 Robinson File No:
13510E
. Serial: RNPD/86-4795 Dr. J. N. Grace Regional Administrator United States Nuclear Regulatory Commission Suite 2900 101 Marietta Street NW Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET No. 50-261 LICENSE NO. DPR-23 RECION II INSPECTION REPORT 86-20
Dear Dr. Grace:
Carolina Power and Light Company (CP&L) provides this response to the alleged violations discussed in the Region II Inspection Report No. 86-20.
Alleged Severity Level IV Violation Part a (RII-86-20-01-SL4)
Technical Specification 6.5.1.1.1.a requires written procedures to be established, implemented, and maintained to cover the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
Regulatory Guide 1.33, Appendix A, 1978, requires written procedures for respiratory protection programs and contamination control.
10CFR20.103(c) allows the licensee to make allowance for the use of respiratory protection equipment in estimating exposures of individuals to airborne radioactive material provided that the licensee maintains and implements a respiratory protection program that includes, as a minimum, written procedures regarding fitting of respirators.
8610270311 861016 PDR ADOCK 05000261 G
PDR 0
k
[6 t
Litter to Dr. J. N. Crsco Snrials RNPD/86-4795 Page 2 Contrary to the above, the licensee failed to establish adequate radiation protection procedures concerning respiratory protection and contamination control surveys for release of material to uncontrolled areas in that:
Licensee Procedure HPP-102, " Respiratory Fit Testing," Revision 4, a.
May 16, 1986, did net require fit testing for Self-Contained Breathing Apparatus (SCBAs) pJior to making allowance for the protection afforded by the device in estimating individual exposure to airborne radioactive material.
Response
1.
Admission or Denial of the Alleged Violation CP&L acknowledges the violation.
2.
Reason for the Alleged Violation if Admitted Health Physics Procedure HPP-102, Revision 4, " Respiratory Fit Testing," lacked a requirement for SCBA fit testing in accordance with ANSI Z88. Although training classes for wearers of SCBA satisfactorily addressed properly donning the apparatus, no fit test was required for that particular positive pressure respirator.
3.
Corrective Steps Which Have Been Taken and Results Achieved HPP-102 has been revised to include requirements for SCBA fit testing by allowing the results of fit testing with negative pressure respirators to be used to determine an individual's qualifications with i
regard to positive pressure respirators, provided the type of mask is the same (i.e., Scott Pressure Pak 4.5 and Scott-0-Vista Model 65).
4.
Corrective Steps Which Will be Taken to Avoid Further Violation No action, other than discussed under Item 3 above, is necessary to avoid further violation.
5.
Date When Full Compliance Will be Achieved Full compliance has been achieved with the issuance and implementation of HPP-102, Revision 5, on October 17, 1986.
Alleged Severity Level IV Violation Part b (RII-86-20-01-SL4)
Technical Specification 6.5.1.1.1.a requires written procedures to be established, implemented, and maintained to cover the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978.
1 l
Regulatory Guide 1.33, Appendix A, 1978, requires written procedures for respiratory protection programs and contamination control.
1
]
Lstter to Dr. J. N. Grace Saricit RNPD/86-4795 Page 3 10CFR20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in 10CFR, Part 20 and (2) are reasonable'under the circumstances to evaluate extent of radiation hazards that may be present.
Contrary to the above, the licensee failed to establish adequate radiation protection procedures concerning respiratory protection and contamination control surveys for release of material to uncontrolled areas in that:
Licensee Procedure HPP-004, " Radiological Control of Tools and a.
Equipment," did not contain adequate guidance to cause surveys to be made, as were reasonable and necessary, to evaluate the potential i
internal contamination of material being released to uncontrolled areas for unrestrictive use.
i
Response
1.
Admission or Denial of the Alleged Violatica CP&L acknowledges the violation.
2.
Reason for the Violation if Admitted Health Physics Procedure HPP-004, Revision ~7, " Radiological Control of Tools and Equipment," did not provide guidance for evaluating the potential for internal contamination in certain material prior to i
release from the Radiation Control Area.
I 3.
Corrective Steps Which Have Been Taken and Results Achieved HPP-004 has been revised accordingly, and responsible personnel have l
been trained in the procedural guidance provided for performing surveys of internal surfaces of materials prior to their release from the Radiation Control Area.
4.
Corrective Steps Which Have Been Taken to Avoid Further Violation 4
No action, other than discussed under Item 3 above, is necessary to avoid further violation.
i 5.
Date When Full Compliance Will be Achieved Full compliance has been achieved with the issuance and implementation of HPP-004, Revision 7, on October 10, 1986.
I i
.t.
Letter to Dr. J. N. Graca Smrialt RNPD/86-4795 Page 4 s
t t'
If you have any questions concerning this response, please contact Mr. J. M. Curley at (803) 383-4524, extension 2367.
1 Very.truly yours, fh Atd R. E. Morgan General Manager H. B. Robinson S. E. Plant DAS:ac cc:
H. E. P. Krug R. E. Morgan J. M. Taylor i
o l
i
'/