ML18142A546

Responds to NRC Re Violations Noted in Insp Repts 50-280/85-13 & 50-281/85-13.Violation Denied.Contaminated Piping Insulation Found in Posted Radioactive Matls Area & Contact Radiation Level Written on Protective Wrapping

ML18142A546
Person / Time
Site:	Surry
Issue date:	06/14/1985
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
85-383, NUDOCS 8507100564
Download: ML18142A546 (3)

Text

W'lLLMM L S7Hf1ART Vice President Nuclear Operations June 14, 1985 Dr. J. Nelson Grace Regional Administrator Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Gentlemen:

Serial No.

NO/HLM:dn Docket Nos.

License Nos.

Nuclear Operations Department Post Office Box 26666 One James River Plaza Richmond, Virginia 23261 VIRGINIA POWER 85-383 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of May 16, 1985 in reference to the inspection conducted at Surry Power Station on April 15 -19, 1985, and reported in IE Inspection Report Nos. 50-280/~and 50-281/85-13. Our response to the specific violation is attached.

We have determined that no proprietary information is contained in the report.

Accordingly, Virginia Power has no objection to this inspection report being made a matter of public disclosure.

The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly yours, Attachment cc:

Cw/attachment)

Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station

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11"111 VIOLATION RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/85-13 and 50-281/85-13

, 10 CFR 20. 203 (f) requires each container of licensed material to bear a visible label identifying the radioactive contents. The label shall bear the radiation caution symbol and the words "CAUTION RADIOACTIVE MATERIAL" and shall provide sufficient information to permit individuals handling or using the containers or work-ing in the vicinity thereof, to take precautions to avoid or minimize exposures.

Contrary to the above, on April 16, 1985, a piece of p1p1ng insulation wrapped in yellow herculite measuring 30mr/hr on contact was determined to contain a quantity of radioactive material greater than that listed in 10 CFR 20, Appendix C, and the wrapping over the insulation did not display the radiation caution symbol or the words "Caution" or "Danger"-

"Radioactive Material."

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

RESPONSE

(1)

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The alleged violation is denied.

Our reason for denial is as follows:

The radioactively contaminated piping insulation referred to in the violation was located inside the reactor containment building which is a posted* radioactive materials area.

The insulation had been removed from a reactor coolant system component to facilitate inspection activities and was wrapped in yellow herculite to afford personnel protection during movement and to minimize the potential for spread of contamination.

The insulation was temporarily stored in the pressurizer cubicle behind a posted rope barrier and the contact radiation level was written on the wrapping.

The use of protective wrappings for contamination control is a radiological work practice employed in* many situations when material with loose surface or internal contamination must be handled or when work is being conducted nearby.

The wrapping reduces contamination hazards (both to the skin and through reduction in the generation of airborne radioactivity) to workers and aides in the maintenance of contamination level boundaries.

Personnel working within established radioactive material areas are provided with and required to use appropriate radiation protection equipment (e.g., protective clothing, respirators, survey instruments, etc.).

In addition, workers are trained in the various contamination control practices utilized at the station.

Wrappings, coverings and enclosures

employed in controlling contamination are not intended to serve as containers in areas where the presence of radioactive material is incident to the work environment.

(2)

REASONS FOR VIOLATION Not applicable.

(3)

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Not applicable.

(4)

CORRECTIVE STEPS WHICH WILL BE TAKEN<TO AVOID FURTHER VIOLATIONS Not applicable.

(5)

DATE WHEN FULL COMPLIANCE WAS.ACHIEVED.

Not applicable.

Under the circumstances described in Section 1 of this response, we consider that we were in full compliance with the requirments of 10CFR20.203.