ML18152B319

Responds to NRC Re Violations Noted in Insp Repts 50-280/88-35 & 50-281/88-35.Corrective Actions:Respiratory Equipment in Question Removed from Svc,Refurbished W/Hoses & Recalibr to Ensure Required Discharge Flow

ML18152B319
Person / Time
Site:	Surry
Issue date:	12/09/1988
From:	Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-755, NUDOCS 8812200067
Download: ML18152B319 (4)

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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261

• R.CAHTWRJ:GHT VICB PRBSIDENT NUCLEAR December 9, 1988 U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D. C.

20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.

NO/GDM:pmk Docket Nos.

License Nos.

NRC INSPECTION REPORT NOS. 50-280/88-35 AND 50-281/88-35 REPLY TO A NOTICE OF VIOLATION 88-755 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of November*9, 1988 in reference to the inspection conducted at Surry Power Station from September 19-23, 1988 and reported in Inspection Report Nos.

50-280/88-35 and 50-281/88-35.* Our response to the violations described in the Notice of Violation is provided in the attachment.

We have no objection to this inspection repo~t being made a matter of public disclosure.

If you-have any further questions, please contact us.

Attachments cc:

U. S. Nuclear Regulatory Commission Region II

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101 Marietta Street, N.W.

Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland

(

NRC Senior Resident Inspector Surry Power Station I

• NRC Comment:

e RESPONSE TO NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED ON SEPTEMBER 19-23, 1988 INSPECTION REPORT NOS. 50-280/88-35 AND 50-281/88-35 During the Nuclear Regulatory Commission (NRC) inspection conducted on September 19-23, 1988, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR 2, Appendix C (1988), the violations are listed below.

A.

10 CFR 20.103(c) requires that the licensee use equipment that is certified or had certification extended by the National Institute for Occupational Safety and Health/Mine Safety and Health Administration (NIOSH/MSHA) when respiratory protective equipment is used to limit the inhalation of airborne radioactive material.

30 CFR 11, Subchapt~r B, Subpart A, Section 11.2(a) states respirators, combinations of respirators, and gas masks shall be approved for use in hazardous atmospheres where they are maintained in an approved condition and are the same in all aspects as those devices for which a certificate of approval has been issued under this part.

Contrary to the above, prior to September 20, 1988, the licensee failed to meet the NIOSH/MSHA approval requirements for the tyre C supplied air res~irators (hoods) in use, in that, the licensee used air supply hoses different from those specified in NIOSH/MSHA Certificate of Approval Number TC=19C-140 and operated the air distribution system at pressures below the range specified in the same certificate of approval.

This is a Severi_ty Level IV violation (Supplement IV).

B.

Technical Specification 6.4.D requires that radiation control procedures be followed.

Health Physics Procedure Radioactjve Material Control Program, dated August 29,

1988, requires that radioactive material be appropriately stored in such a way that control over the material is maintained and access is only to authorized individuals. This procedure also specifies the bagging and labeling requirements for contaminated material.

Contrary to the above, the licensee failed to adhere to radiation control procedures in that several contaminated items were found September 19,

1988, inside an unlocked radioactive material gang box that were not properly controlled, bagged, labeled, and secured to prevent unauthorized access.

This is a Severity Level V violation (Supplement IV).

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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-35 AND 50-281/88-35 RESPONSE TO ITEM A:

(1)

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated.

(2)

REASONS FOR VIOLATION:

The violation resulted from an oversight on the part of individuals responsible for respiratory protection equipment operation and maintenance, and inadequate procedural guidance related to review of NIOSH Certification requirements.

(3)

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The respiratory equipment in question was removed from

service, refurbished with proper supply hoses, as specified on the NIOSH certification, and recalibrated to ensure required discharge flow.

The calibration verified required minimum air flow for the recommended

. pressure readings corresponding *to maximum hose lengths.

Additionally, a

recheck of the air distribution units with the non-approved hose was performed to determine whether the required minimum 6 cfm flow had been provided at the lower pressure settings. This was confirmed and was found to be due to the non-approved hose having a larger diameter than the approved hose.

The remaining units available for service were confirmed to be maintained per NIOSH certification or refurbished.

These units were then recalibrated and relabeled to indicate use of approved hoses in proper pressure ranges.

(4)

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The procedure governing respiratory protection equipment calibration and performance verification will be revised to ensure a complete review of NIOSH certification requirements and appropriate documentation for equipment prior to its use.

(5)

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full comp.liance has been achieved with regard to the specific respiratory equipment problem identified in the Notice of Violation.

The procedure revision discussed in item (4) above will be complete by January 31, 1989.

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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50/280/88-35 AND 50-281/88-35 RESPONSE TO ITEM B:

(1)

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is cofrect as stated.

(2)

REASON FOR VIOLATION:

The violation occurred when radioactively contaminated tools and testing equipment were placed in* a labeled storage container without proper authorization by Health Physics.

The station personnel who placed the materiql into the container were not fully aware of the requirements for packaging, labeling, and surveying radioactive material for storage.

Additionally, Health Physics was not notified of these activities.

(3)* CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The improperly stored radioactive materials were immediately surveyed, packaged and labeled in accordance with station procedures. Additionally, surveys of radioactive material storage containers located within uncontaminated areas of the station were initiated to ensure. no further cases of improper storage existed.

No additional cases were identified.

As an interim measure to prevent recurrence of this problem, Health 11 Physics controlled locks.were installed on these storage containers and instructions were posted to notify individuals that Health Physics would be required to provide access to the containers.

(4)

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER.VIOLATIONS:

The interim controls established by use of Health Physics* locks will be maintained until such time as additional radioactive material controls training has been completed by appropriate station radiation workers.

This training will be provided during General Employee Training and Retraining and will review and e~phasize the procedural. requirements for proper handling and storage "of radioactive materials.

(5)

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved.

General Employee Training and Retraining will be revised.by 1/31/89.

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