ML20236U789
| ML20236U789 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/25/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-682, NUDOCS 8712030376 | |
| Download: ML20236U789 (10) | |
Text
_ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
10.CFR 2.201 VIRGINIA ELecrHIc Ann Pownn COMPANY RIcnxonis, VIRGINIA 20261 W L.STBWANT v,c. r= m-November 25, 1987-Nect. man oPERATIOfru I
United States Nuclear Regulatory Commission Serial No.87-682 Attention: Document Control Desk NAPS /GGH Washington, D.C. 20555 Docket Nos.
50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-338/87-30 AND 50-339/87-30 REPLY TO NOTICE OF VIOLATION We have reviewed your letters of September 9, 1987 and October 26, 1987 concerning the inspection conducted at North Anna between August 25 and August 27, 1987, and reported in Inspection Report Nos. 50-338/87-30 and 50-339/87-30. Our responses to the Notice of Violations are contained in the attachment.
In addition to the corrective actions identified in the attached responses, Virginia Electric and Power Company plans to continue its on-going efforts to reduce hot particle sources.
We have no objection to this correspondence being made a matter of public record.
If you have any further questions, please contact us.
Very truly yours, Wi C
W. L.
tewart Attachment pg2gggg guygp l
a
$p'
, i
cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, CA 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station
a.
I l
ATTACHMENT RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN AUGUST 25, 1987 AND AUGUST 27,1987 INSPECTION REPORT NOS 50-338/87-30 AND 50-339/87-30 l
NRC COMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on August 25-27, 1987, violations of.NRC requirements were identified.
In accordance with the "Ceneral Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violations are' listed below:
1 A.
10 CFR 20.101(a) requires, in part, that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation,. a total occupational dose in excess of 7.5 rem to the skin of the whole body.
Contrary to the above, on August 19,
- 1987, licensed material was used in such a manner as to cause an individual in the Unit 1 Containment
- Building, a
restricted
- area, to receive an occupational dose of 23.6 rem to one square centimeter of the skin of the whole body, resulting in a total occupational dose for the individual for the calendar quarter of 23.828 rem to the skin of the whole body.
This is a Severity Level IV violation (Supplement IV).
This violation applies to Unit 1 only.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
2.
REASON FOR THE VIOLATION:
This violation was the result of contamination by a single 20 :o 30 micron diameter, 1.6 microcurie cobalt-60 particle which was found below the left shoulder blade on the back of a health physics technician.
Our investigation concluded that the most probable cause of the contamination was transfer of the particle from the protective clothing to the skin.
Our survey of a randomly selected sample of the existing inventory of protective clothing indicated that the most likely source of the contamination was the protective clothing, and could be traced to laundry practices.
It was conservatively assumed that the particle was
l l
l transferred onto the individual's back immediately after donning the protective clothing, which resulted in a maximum exposure' time.of 3.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />. The total accumulated skin dose for the quarter, which was calculated in accordance with established procedures and guidance provided in NRC Information Notice 86-23, was 23.828 rem, of which 23.6 rem was calculated'to have been received from the particle. We conducted i
an independent measurement to assess the particle emission dose rates l
using excelectron dosimeters provided by Bate 11e Northwest Laboratory, and the calculated results.were confirmed.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
At the time of the violation, laundered protective clothing was hand' feisked inside and outside.and reissued if the count rate indicated less j
than'10,000 counts per minute. Used protective clothing in excess of SmR/hr is segregated prior to laundering and disposed of as radioactive l
waste. The monitoring of laundered protective clothing was subsequently relocated to an area of low background radiation, and an automated laundry contamination monitor has been installed. Also, the level for reissue -of protective _ clothing was reduced from 10,000 to 5,000 counts per minute. Our practice is to inspect both the inside and outside of laundered protective clothing and any with a count in excess of 5000 per l
minute are now discarded as radioactive waste.
The above -criteria is-also applied.whenever-a vendor facility is used for laundry services.
In addition, a 100 percent check of the above criteria is made at North Anna of protective clothing returned from a vendor prior to reusing.
Work-practices' were enhanced for predesignated areas where particle contaminations were likely to. occur.
Specifically, workers accessing these.
predesignated areas were required to wear outer disposable protective clothing which is to be removed just prior to leaving the predesignated area.
Upon leaving the predesignated areas, workers are required to proceed immediately to the Radiological Control Area (RCA) exit to perform whole body monitoring in order to minimize potential hot particle exposure time. Protective clothing worn in these predesignated areas is not reused but discarded as radioactive waste. Also, workers exiting any contaminated area were required to proceed to the RCA exit and perform whole body monitoring. The necessity for strict adherence to Radiation Work Permit requirements was reemphasized to workers.
Personnel monitoring methods are being strictly enforced.
Hot particle awareness and practical factors training has been performed I
for laundry workers and most decontamination technicians.
Hot particle awareness instruction has been conducted for station radiation workers, and hot particle information has been incorporated into the annual J
General Employee Training program. Comprehensive hot particle training
)
was provided to station and health physics contractor personnel.
{
A Radiological Work Practice which addresses hot particle concerns has been developed and implemented.
It addresses access and egress controls,
)
protective clothing requirements and provides guidance on personnel j
I
monitoring, disposal of contaminated protective clothing, and monitoring of workers in hot particle areas.
Finally, additional whole body automatic personnel contamination monitors have been installed to enhance timely detection of hot particles.
The need for additional automatic monitors is being evaluated.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
It is planned to develop specific procedures from the Radiological Work Practice on hot particle concerns.
Also, hot particle assessment and control techniques will be incorporated into the health physics technician development program.
A program for oversite of vendor laundry services will be inititated.
j This will enable us to better monitor vendor laundry practices.
1 A valve maintenance housekeeping procedure will be implemented. This procedure includes cleaning requirements for systems opened for maintenance activities. The flushing requirements in this procedure will help control the introduction of material into the reactor coolant system by ensuring a higher level of system cleanliness.
Therefore, the generation of hot particles resulting from activation of materials introduced during maintenance should be reduced.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
s The installation of the automatic personnel contamination monitors at the RCA exit points, where practical, will be complete by December 31,1987.
The radiological work practice addressing hot particles will be proceduralized and the health physics development program revised to address the controls and procedures by April 30, 1988.
The program for oversite of laundry services will be implemented in 1988.
The new valve maintenance housekeeping procedure will be issued by January 31, 1988.
l l
l l
l l
B.
10 CFR 20.201(b) states that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 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 materials or other sources of radiation under a
specific set of conditions,
- and, when appropriate, includes a
physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive material present.
Technical Specification 6.11 states that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Radiation Protection Manual, Section 1,
Part 3,
Subsection G,
Exiting Restricted Areas Step 6, states that Health Physics (HP) will locate portal monitors or friskers as necessary and personnel shall use such equipment unless otherwise instructed by HP.
1 of General Employee Training, Step 1.2, defines proper use or proper frisk as a whole body frisk and a dosimetry frisk.
Contrary to the above, surveys to evaluate the extent of radiation hazards that may be present were inadequate in that:
1.
On August 19, 1987 an individual exited the Unit I containment, a contaminated area, and a whole body survey was not performed as required resulting in 30 minutes to one hour of additional exposure to a microscopic particle containing 1.6 microcuries of cobalt-60.
2.
On August 26, 1987, seven out of ten individuals exiting either Unit 1 or Unit 2 containment, contaminated areas, failed to perform necessary whole body surveys in that only hands,
- feet, and head were monitored.
This is a Severity Level IV violation (Supplement IV).
1
RESPONSE
l l
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
l
1 F
2.
REASON FOR VIOLATION:
\\
The only approved method for whole body monitoring at the time of the violation was a manual whole body and dosimetry frisk (General Employee Training, Job Performance Measures No. 1, Step 1.2).
Because of the considerable amount of time necessary to perform thorough whole body monitoring by hand, some personnel were only. performing partial-whole body-frisks (e.g.
hands, feet, and head) when exiting containment and substituting the final monitoring by the automatic personnel' contamination monitors (PCM-1 A/B) at the Radiological Control Areas (RCA) exit for the required whole body manual frisk.
On August 19, 1987 the Health Physics Technician did not perform timely whole body monitoring. A partial whole body frisk was performed but the hot particle contamination was not detected. The dose received from the j
hot'. particle' was increased because of the time spent-returning instruments and counting smears before entering the automatic personnel contamination monitor at the RCA exit and discovering the contamination.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
A Health Physics technician was assigned to ensure that proper manual whole body frisking was performed by all personnel leaving the Unit 1 and Unit 2 reactor containment buildings.
A new personnel monitoring policy was subsequently adopted for exiting contaminated -areas.
Now, upon leaving a contaminated
- area, the individual performs a manual hands and feet frisk after removal of protective clothing at the step-off-pad, and then proceeds immediately and directly to the RCA exit area to complete whole body monitoring using an automated personnel contamination monitor..If an automated whole body monitor is not available at the RCA exit, then the individual must perform a whole body manual frisk at the RCA exit area.
The new personnel monitoring requirements were posted at step-off-pads and were incorporated into the annual Gene sl Employee Training program.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
If other areas are identified that require the installation of additional personnel contamination monitors they will be installed.
)
r 5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
l l
l
~
i i
i C.
Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering applicable procedures recommended in appendix "A"
of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,
Paragraph 7.e.
requires
}
radiation protection procedures covering access control to j
radiation areas including a Radiation Work Permit (RWP) system.
1 Procedure HP-5.3.10, RWP
- Program, August 21,
- 1986, Paragraph
~
4.3.1, states that RWPs shall provide the radiological controls required in support of specific conditions relating to the specific work activity and area or purpose of entry.
j i
RWP No. 87-2312, Perform Eddy Current Testing in A,
B, and C Steam Generators, August 14-27,
- 1987, requires that in addition to other protective clothing requirements, a plastic suit and a fresh air hood will be worn.
Contrary to the above, RWP requirements for protective clothing were not met in that on August 19, 1987, an individual who had signed into Unit I containment on RWP No.
87-2312 made entry to "A"
steam generator platform to perform a survey failed to wear a plastic suit or a fresh air hood.
This is a Severity Level IV violation (supplement IV).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
2.
REASON FOR THE VIOLATION:
Radiation Work Permit (RWP) No. 87-2312, " Perform Eddy Current Testing in A, B, and C Steam Generators, August 14-27, 1987" contained protective clothing (PC) requirements (e.g. plastic suit, fresh air hood) applicable to personnel actually making steam generator (S/G) entries.
The Health Physics technicians assigned under this RWP did not always comply exactly with the RWP, using instead established health physics guidelines provided for the selection of respirator protection equipment, dosimetry and protective clothing.
The violation resulted from failure of supervisors and technicians to require strict compliance with procedural requirements or properly deviate the RWP in accordance with established procedures.
l
{
L 1
____,_____m_
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Health Physics supervisors and technicians have been reinstructed in the importance of complying with procedural requirements.
Strict control and 1
adherence to RWP requirements have been imposed by the Health Physics department and station managenent.
Where appropriate, specific requirements for Health Physics personnel are identified on the RWP or a i
separate RWP is initiated.
l 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further corrective action is considered necessary.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
f
_ _ _