ML20245K769
| ML20245K769 | |
| Person / Time | |
|---|---|
| Site: | Farley, 07000364, 07000135  |
| Issue date: | 06/21/1989 |
| From: | Culberson D BABCOCK & WILCOX CO. |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8907050248 | |
| Download: ML20245K769 (4) | |
Text
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1 Babcock & Wilcox Nuclear Power Division a McDermott company CERTIFIED MAIL P050 618 855 6 9 N0r h en sy7va"n 5 3
,o 9 (412) 478-3131 1
June 21, 1989 l
Ronald R.
Bellamy, Chief Facilities Radiological Safety and Safeguards Branch j
Division of Radiation Safety and 1
Safeguards U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406
Reference:
Combined Inspection Reports 70-135/89-02 and 70-364/89-01
Dear Sir:
This letter is in response to the findings noted in the reference inspection reports regarding the inspection conducted by Mr. Jerome Roth of your staff on April 10-13, 1989.
During the course of the inspection, one apparent item of non-compliance was identified and was discussed during the closecut meeting.
B&W's response to this item is presented in the attachment to this letter.
I hereby affirm that the facts set forth in this response are true to the best of my knowledge, information and belief.
If you have any questions or comments regarding this response, please contact me.
Sincerely, OMtu David G.
Culberson Manager, Technical Control DGC:NOA660(7)/mhb Attachment cc:
J. Roth (Region I)
J. J.
Kottan (Region I)
L.
C.
Rouse (Headquarters)
,/'/'Q 8907050248 890621
{DR ADOCK 07o00333 PDC
F BABCOCK & WILCOX NUCLEAR-POWER. DIVISION PENNSYLVANIA NUCLEAR SERVICE OPERATIONS SPECIFIC RESPONSES TO NRC REGION INSPECTION APRIL 10-13, 1989
(
REFERENCE:
COMBINED INSPECTION REPORTS NO. 70-135/89-02 & 70-364/89-01)
NRC NOTICE OF VIOLATION - Appendix ~A (Severity Level IV)
"R/CWP No. SPIS 020-89, dated April 10, 1989, stated that the eddy current work area.must be covered by Health Physics personnel for entry-exit of operations personnel, as needed.
Section 5.1.2 D (iv) " Monitoring Equipment and instrumen-tation" states that sufficient operable instrumentation,.to be used for radiation protection measurements, shall be available.
Contrary to the above, as of April 11,
- 1989, all the requirements of R/CWP No. SPIS 020-89, dated April 10, 1989, a written procedure, were not followed in..that the eddy current work area was not covered by Health. Physics-personnel for entry-exit of operations personnel, as needed, and no alternative means for contamination survey of those operations personnel was provided.
(70-364)"
SPECIFIC LICENSEE RESPONSE 1.
Contrary to certain comments in the inspection report, B&W believes that the requirements of the RCWP.(No. SPIS 020-89) were followed in that health physics personnel and instrumentation or monitoring equipment were available to provide coverage for entry / exit from the eddy current area on an "as-needed"
- basis, as is specifically required in the RCWP.
No individuals entered. or exited the eddy current work area without health physics coverage as required.
Our definition-of "available" in this context means that a qualified H.P.
technician is in the facility and will respond to a telephone summons from the eddy current work area to cover entry or exit of personnel.
It is not necessary from a safety standpoint, and certainly not an effective use of resources, to station a H.P.
technician at the entrance to the eddy current area full time, when his presence is required only for entry or exit.
Notification of health and safety for entry or exit is a written requirement of the RCWP and persons working in the area are required to be familiar with all aspects of the RCWP.
A telephone located in the work area is provided for such notification.
Health and Safety technicians were, in fact, available in the facility at the time the inspection occurred.
)
1
y
,.. A The notice of violation statement that "the eddy current work area was not covered by Health Physics personnel
for entrv-exit of operations personnel,. as needed..."
(emphasis added) is not consistent with actual practice, and with the situation on the day of the inspection.
The citation continues to read "and no alternative means for contamination survey of those operations personnel was provided."
The RCWP. does not provide for and therefore does not allow the employment of alternative means for contamination surveys of operations personnel
- the RCWP-reauires a HP technician for entry-exit survey as needed.
No option is allowed, nor do we believe an option should be allowed.
Monitoring equipment used for these surveys is ordinarily located at a station outside the door of the eddy current area.
The equipment is placed there for the convenience of the H.P.
personnel, not as a
substitute for required H.P.
coverage.
Equipment normally at this station was removed for repairs and subsequent calibration; the health physics technician summoned to provide entry / exit coverage as needed would bring other available instruments with him to allow proper accomplishment of his duties.
Such required instrumentation was readily available within the
- facility, and the requirements of Section 5.1.2D(iv)
" Monitoring Equipment and Instrumentation" were met in that required instrumentation was available.
In view of the foregoing clarifications, B&W believes that the violation issued resulted from a misunder-standing of the requirements and circumstances of i
entry / exit procedures for the eddy current area and should therefore be withdrawn.
2.
As clarification of a statement in Section 3 " Review of operations", Item (2) " Storage of Materials", B&W has not sampled the small containers of unlabeled chemicals stored in the designated Apollo plant storage area.
It is B&W's intention to have samples of these chemicals analyzed to determine appropriate disposal alternatives, but as yet no samples have been collected.
3.
In response to Open Item #70-364/85-03-04, identified deficiencies will be documented for ' followup using the existing formalized regulatory compliance Request for Reply (RFR) system.
This system provides an adequate and appropriate mechanism for identification, followup and closecut of identified items.
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