ML20072E182

Responds to NRC Re Violations Noted in IE Insp Rept 50-261/82-31.Corrective Actions:Routine Radiation Work Permit for Decontamination Work Revised to Allow General Decontamination in All But Three Areas

ML20072E182
Person / Time
Site:	Robinson
Issue date:	02/24/1983
From:	Starkey R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20072E152	List: ML20072E182
References
RSEP-83-219, NUDOCS 8303210602
Download: ML20072E182 (2)

Text

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_ qc-g ag,4s H. B. ROBINSON STEAM ELEt I

LANT POST OFFICE BOX 790 HA'ITSVILLE, SOUTH CAROLINA 29550 FEB ?. 41983 Robinson File No:

13510E Serial:

RSEP/83-219 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W., Suite 3100 Atlanta, Ceorgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 REVISED RESPONSE TO IE INSPECTION REPORT 82-31

Dear Mr. O'Reilly:

Carolina Power and Light Company (CP&L) submitted a response to the subject inspect'.on report on October 22, 1982.

In a follow-up Quality Assurance audi'. of that response, CP&L has identified a misunderstanding in the Violat'.on B, Item 1, " Corrective Steps Which Have Been Taken and Results Achieved," response.

Please conside r the following revised response to Violation B, Item 1.

_ Violation "B" - Severity Level V (IER-82-31-05-SLS)

Technical Specification 6.11 requires that procedures shall be prepared consistent with the requirements of 10CFR20 and shall he approved, maintained, and adhered to for all operations involving personnel radiation exposure.

(1) Health Physics Procedure HP-7, " Radiation Work Permit,"

Section 5.13.1, requires for "non-routine" RWPs and prior to perf orming work under the RWP, that personnel shall read and understand the provisions of the RWP.

Contrary to the above, Health Physics Procedure HP-7 was not adhered to in that personnel were observed drumming evrporator bottoms while being signed in on a " routine" RWP used for general decontamination.

These personnel were not aware that an RWP for this operation existed; and, therefore, had not read the requirement of the proper RWP.

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~ Re sponse -

1(1) Admission or Denial of Alleged Violation Carolina Power and Light Company acknowledges the violation.

(2) ' Reason for Violation Section~ 5.13.1 of HP-7 (Revision 11) requires that " prior to ~

performing any work under a 'non-routine' RWP," all-personnel shall read and understand all. the provisions of_ that RWP.

' At the, time of. this violation, RWP #2 allowed decontamination personnel to enter all areas of the Plant and " dress as-

. posted for the ares." RWP.#13 is a non-routine RWP specifically for entering the drumming room. ' Although the decontamination personnel were only aware of 'and only read RWP #2, all

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- provisions of RWP #13 were followed while the work was performed.

(3) ' _The Corrective Steps Which' Have Been Taken and Results Achieved The routine RWP for decontamination work will be' revised to allow for general decontamination in all areas except for

- Locked High Radiation, High Radiation, and High Contamination Areas.

In these three areas, a non-routine RWP will be required for general decontamination work.

The routine RWP, however, allows for ' trash and laundry pick-up at the entrances to Locked High Radiation, High Radiation, and High Contamination Areas.

(4) The Corrective Steps Which Will Be Taken To Avoid Further Violation The corrective actions stated above in Section 3 should be sufficient to avoid further violation.

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(5) - Date When Full Compliance Will Be Achieved a

Pull compliance will be achieved on February 28, 1983.

If ycm have any questions concerning this revised response, please contact my staff or me.

Very truly yours, R. B. Starkey, Jr.

i; General Manager H. B. Robinson SEG Plant CLW:JMC/b ss cc:

R. C. DeYoung

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