ML18152B319
| ML18152B319 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/1988 |
| From: | CARTWRIGHT W R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-755, NUDOCS 8812200067 | |
| Download: ML18152B319 (4) | |
See also: IR 05000280/1988035
Text
e e 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 -** . _ ..... : *-. . : 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). I , I '*~ '*
e e 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. . *~ ,, I I .. .... ~. . .. -*~, .. , ...
,-l e 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 1 1 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
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