ML18142A546

Responds to NRC 850516 Ltr 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)

See also: IR 05000280/1985013

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 --------,____ ----~, ,.,----8507i00564

85060014280

~DR ADOCK 050 PDR

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 "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 .