ML18153C287

Responds to Violations Noted in Insp Repts 50-280/90-18 & 50-281/90-18.Corrective Actions:Permanent Drain Line Installed & Matrix Which Describes Proper Ventilation Alignment for Plant Conditions Provided for Personnel Use

ML18153C287
Person / Time
Site:	Surry
Issue date:	07/11/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-349, NUDOCS 9007170104
Download: ML18153C287 (4)

See also: IR 05000280/1990018

Text

• ~~-----VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 11, 1990 United States Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION

Serial No. NURPC Docket Nos. -License Nos.90-349 R2 50-280 50-281 DPR-32 DPR-37 NRC INSPECTION

REPORT NOS. 50-280/90-18

AND 50-281/90-18

Pursuant to the provisions

of 1 O CFR 2.201, we have reviewed your letter dated May 30, 1990, in reference

to the NRC inspection

conducted

on April 16 -20, 1990, for Surry Power Station. _ The inspection

was reported in Inspection

Report Nos. 50-280/90-18

and 50-281/90-18.

Our response to the violation

described

in the Notice of Violation

is provided in Attachment

t. We have no objection

to this inspection

report being made a matter of public disclosure.

Should you have any further. questions, please contact us. Very truly yours, \SJ:t_~ W. L. Stewart Senior Vice President

-Nuclear Attachment

cc: U. S. Nuclear Regulatory

Commission

Region II 101 Marietta Street, N. W. Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector

Surry Power Station 9007170104

900711 PDR ADOCK n~nno2so Q ----PDC

• ATTACHMENT

1 REPL V TO A NOTICE OF VIOLATION

REPORTED DURING THE NRC INSPECTIONS

ON APRIL 16 -20, 1990 . INSPECTION

REPORT NOS. 50-280/90-18

AND 50-281/90-18

NRC Comment During the Nuclear Regulatory

Commission (NRC) inspection

conducted

on April 16 -20, 1990, a violation

of NRC requirements

was identified.

In accordance

with the "General Statement

of Policy and Procedure

for NRC Enforcement

Actions," 1 O CFR Part 2, Appendix C (1990), the violation

is listed below: 1 O CFR 20.103(b)(1)

requires the licensee, as a precautionary

procedure,use

process or other engineering

controls, to the extent practical, to limit concentrations

of radioactive

materials

in air to levels below those which delimit an airborne radioactivity

area as defined in 1 O CFR 20.203(d)(1

)(ii) . 1 O CFR 20.203(d)(1

)(ii) defines an airborne radioactivity

area as any room, . enclosure, or operating

area in which airborne radioactive

materials

composed wholly or partly of licensed material exist in concentrations

which, averaged over the number of hours in any week during which individuals

are in the area, exceed 25 percent of the amounts specified

in Appendix B, Table I, Column 1 of Part 20. Contrary to the requirements

specified

above, the. licensee failed to utilize, process or other engineering

controls to the extent practical

to limit airborne radioactivity

material below 25 percent (1 O MPC-Hrs/Wk)

of the amounts specified

in Appendix B, Table I, Column 1, in that, between March 23-30, 1990, licensee personnel

were in an average airborne concentration

of 25 Hrs/Wk when the radioactivity

concentration

in the licensee's

Auxiliary

Building reached 99 times that specified

in Appendix B, Table I, Column 1, of Part 20, on March 26, 1990. This is a severity level IV violation (Supplement

IV).

• RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/90-18

AND 50-281/90-18

(1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct as stated. (2) REASONS FOR VIOLATION:

For a period of time prior to the loss of contamination

control cited in this violation, a rubber hose had been in use to provide the dewatering

flow path from the spent resin shipping containers

in the Decontamination

Building to a floor drain located in a high radiation

area of the Auxiliary

Building.

In addition, a contamination

control barrier had been erected isolating

this high radiation

area of the Auxiliary

Building.

As reported to the NRC inspector

and documented

in the Notice of Violation, on or about March 23, 1990, the floor drain backed up and drained leaving residual contamination

which was the source of the airborne contamination

detected in the Auxiliary

Building on March 26, 1990. During the time of the loss of contamination

control, several ventilation

flow perturbations

occurred in the area. Contributing

to these perturbations

were balance problems associated

with the Auxiliary

Building's

ventilation

system, the sealing of several ventilation

flow paths in adjacent areas, and the running of a Fuel Building heating supply fan without operating

the associated

area . exhaust fans. When the High Radiation

Area door was opened for personnel

access, radioactive

contamination

in the higher pressure area was transported

into the previously

clean area. (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED:

a. A permanent

drain line has been installed

and is in use for resin shipping container

dewatering

activities.

b. A matrix which describes

proper ventilation

alignment

for different

plant conditions

has been prepared and provided to operating

personnel

for their use. ' c. The Auxiliary

Building central and general ventilation

exhaust systems have been balanced.

d. Station operating

procedures

have been changed to require that a temporary

modification (TM) be performed

and documented

for the use of temporary

hookups which will be used for handling radioactive

process fluids. Such TMs are reviewed by Radiological

Engineering

and approved by SNSOC prior to initial use .

• (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Additional

walkdowns

will be conducted

to determine

if other contamination

control barriers exist which could, under certain ventilation

configurations, permit a similar event to take place. Any such installations

will be evaluated

and modified as necessary.

(5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

System walkdowns

will be completed

and corrective

actions will be implemented

by September

30, 1990 .