ML18026A539

Provides Response to Violations Noted in Insp Repts 50-387/96-04 & 50-388/96-04.Corrective Actions:All Doors to Decontamination Bldg on Refueling Floor Immediately Posted on 960201

ML18026A539
Person / Time
Site:	Susquehanna
Issue date:	06/24/1996
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PLA-4473, NUDOCS 9606280252
Download: ML18026A539 (8)

See also: IR 05000387/1996004

Text

Pennsylvania

Power 8 Light Gompany Two North Ninth Street~Allentown, PA 18101-1179

~610/774-5151

Robert G.Byram Senior Vice Preslderr r-iVuclear

610/774-7502

Fax: 610i774-5019

Jl.iw 24 1996 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Mail Stop P 1-137 Washington, D.C.20555 SUSQUEHANNA

STEAM ELECTRIC STATION REPLY TO A NOTICE OF VIOLATION (50-387/96-04-02;

50-388/96-04-02

AND 50-387/96-04-03;

50-388/96-04-03)

Docket Nos.50-387 and 50-388 This letter provides Pennsylvania

Power and Light Company's response to the Notice of Violation (50-387/96-04-02;

50-388/96-04-02

and 50-387/96-04-03;

50-388/96-04-03)

contained in NRC Integrated

Inspection

Report 50-387/96-04

and 50-388/96-04

dated May 23, 1996.I The notice required submittal of a written reply within thirty (30)day of the date of the letter.We trust that the Commjssion

will find the attached response acceptable.

If you have any additional

questions, please contact Mr.R.D.Kichline at (610)774-7705.Very truly yours, Attac nt copy: NRC Region I Ms.M.Banerjee NRC Sr.Resident Inspector Mr.C.Poslusny, Jr.NRC Sr.Project Manager

ATTACHMENT

TO PLA-4473 Page 1 of 6 (387/96-04-02;

3SS/96-04-02)

Pursuant to 10CFR20.1003, a high radiation area is an area, accessible

to individuals, in which radiation levels could result in excess of 0.100 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters

from the radiation source or from any surface that the radiation penetrates.

Contrary to the above, on January 4;1996, through February 1, 1996, a high radiation area in the decontamination

building on the refueling floor (818 ft.elevation), with dose rates up to 0.800 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters

from the radiation source (a vacuum), was not conspicuously

posted as a high radiation area.RLQHHLSc: pe~On January 4, 1996, a radiation source (under-water

vacuum housing)was placed in the decontamination

building on the refueling floor (818 ft.elevation).

The dose of the vacuum housing warranted that the decontamination

building be posted as a high radiation area.This posting was performed on February 1, 1996.The causes for the failure to post the decontamination

building between January 4, 1996, and February 1, 1996, are:~On January 4, 1996 only one door of the decontamination

building was posted indicating

that the building was a high radiation area.The need to post the~remaining doors went undetected

because of a lack of clear procedural

and work practice guidance which resulted in human error.As a result no survey of the decontamination

building was completed after the vacuum housing was placed in it, and the need to post all doors went uncorrected

until February 1, 1996, when the vacuum housing was identified

as a high radiation source.~Surveys that were conducted subsequent

to placing the vacuum housing in the decontamination

building also failed to identify the posting deficiencies.

The initial survey performed on January 4, 1996, was incomplete.

Another survey of the building was conducted on January 8, 1996, but was only performed at one corner of the building and did not identify any unusual radiation conditions.

Subsequently, a survey conducted on January 15, 1996, did identify slightly elevated dose rates at one location-outside

the building.However, the slightly elevated dose rates were considered

insignificant

because the health physics technician

performing

the survey did not recognize that the elevated dose rates were from a high radiation source, i.e., the vacuum housing.

ATTACHMENT

TO PLA-4473 Page 2 of 6 W'll doors to the decontamination

building on the refueling floor were immediately

posted on February, 1, 1996, following identification

that the vacuum housing was a high radiation source.Subsequently, a new rope barricade was erected to prevent access to the decontamination

building.Therefore compliance

with high radiation area posting requirements

was achieved.b.Although functionally

adequate, numerous procedures

have been revised to clarify station survey, posting, and work practices when working with radioactive

equipment.

These procedural

revisions will strengthen

the station's radiation controls program.C.The health physics technician

involved in this event was counseled'as to the necessity to complete survey and posting requirements

pursuant to station procedures.

d.Health Physics training was conducted which will enhance a"questioning

attitude" regarding radiological

changes noted during routine surveys.The purpose of this training was to sensitize the health physics technicians

on the need to follow-up and perform additional

investigative

surveys when elevated radiation levels are measured.e.Locking devices were placed on the decontamination

building doors so that in the future this facility can be locked when radiation levels require locked radiation controls.A"radiological

safety note" was distributed

to station personnel reiterating

the necessity of controlling

radiological

postings.Appropriate

radiological

controls work programs, and work priorities

and communication

enhancements

associated

with outage management

activities

have been developed.

These programs will increase the sensitivity

of station personnel to station radiological

control concerns, thereby reducing the occurrence

of'imilar events.h.Areas of the plant which were not already under locked high radiation controls were surveyed and upgraded as necessary to ensure the station was in compliance

with NRC posting and barricade requirements.

ATTACHMENT

TO PLA-4473 Page3 of6 An independent

walk-down, by first line supervisors, of high radiation posting changes is now required.This corrective

action, which is in response to a subsequent

posting event, adds assurances

that the 10CFR20 and plant Technical Specification

posting and barricading

requirements

are'being promptly and correctly implemented.

W'P&L management

immediately

commissioned

an intensive investigation

to establish the cause and recommend corrective

actions in response to this event.The resultant corrective

actions taken to address this event were expeditiously

dispositioned.

PP&L, therefore, considers the corrective

actions identified

above to satisfactorily

address this violation.

Based on the action taken in 2.a above, PP&L is in full compliance.

ATTACHMENT

TO PLA-4473 page4of6'g jgQ~~(387/96-04-03;

388/96-04-03)

Pursuant to 10CFR20.1003, survey means an evaluation

of the radiological

conditions

and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive

material or other sources of radiation.

Contrary to the above, as of April 4, 1996, the licensee did not make surveys to assure compliance

with 10CFR20.2001(a), which describes authorized

meaits of disposing of licensed material.Specifically, on September 21, 1995, (Note: The tanker was released offsite on September 14, 1995, as stated in Inspection

Report 50-387/96-04

and 50-388/96-04)

the licensee did not perform a survey before disposing of sludge in a tanker truck as normal, non-radioactive

waste.On prior occasions, the tanker truck contained radioactive

water above the lower limits of detection for effluent releases.4 RcBQ~H1K On February 29, 1996, PP&L was notified, by an organization

in Montreal, Quebec Canada, that a tanker truck previously

used by PP&L (PP&L identification

¹255-216)had a radioactive

materials label affixed to the tanker.Prior to releasing the tanker offsite, the tanker (which had previously

contained slightly contaminated

water)was surveyed using existing procedures, and determined

to be acceptable

for offsite release.Prior to transport to Montreal, Quebec the tanker was thoroughly

cleaned at a truck washing facility in Pennsylvania.

To determine if the tanker may have been contaminated

or if other potentially

radioactive

material may have been in the tanker following release from the site, a tanker (PP&L identification

¹255-212)that had been used in a similar manner, was surveyed.The survey identified

a small amount of slightly radioactive

sludge in the bottom of the tanker.Dose calculations

performed on this sludge concluded that any dose received would have been a small fraction of applicable

dose limits for a member of the public and, based on transportation

regulations, the sludge found would have been classified

as an"exempt quantity." Because of the process used by PP&L to determine if radioactivity

was associated

with the tanker, the tanker may have contained similar or slightly lower amounts of slightly radioactive

sludge.Therefore, it was concluded that an inadequate

survey had been performed on tanker¹255-216.~The reason for the inadequate

survey performed on the subject tanker, prior to its release offsite on September 14, 1995, was that:

ATTACHMENT

TO PLA-4473 Page 5 of 6~No procedural

guidance existed that specifically

looked for or removed unnecessary

labeling prior to release from the radiologically

controlled

area (RCA)or the site.~The procedure used to survey for contamination (HP-TP-602)

was less than adequate in that it did not specifically

require an internal survey of the tanker.~No overall procedure existed to control the process for use, surveying, sampling, or release of the tanker by the several affected functional

organizations

within PPAL.Although each functional

organization

has procedures

to address their specific activity, the lack of a comprehensive

governing procedure contributed

to a lack of training related to aspects of releasing of material offsite, weak programmatic

control of tankers for release from the RCA and site, less than adequate contamination

control of empty containers, and less than adequate work plans for completely

emptying the tanker.a.The remaining tankers at Susquehanna

that are utilized for similar purposes have been relocated within the protected area, and have been physically

secured.This will ensure positive control of these tankers prior to release offsite.b.Nuclear Department

procedures (NDAP-00-0627

and HP-TP-0602)

have been revised to require that the internal surfaces of tankers be surveyed prior to exiting the site..C.Nuclear Department

Administrative

Procedure (NDAP-00-0627)

has been revised to incorporate

steps that remove unnecessary

labels on tankers prior to release offsite.Incorporation

of a specific procedural

step to remove labels in this NDAP, which applies across functional

organizations, provides assurances

that only required labeling will be attached to tankers exiting the site.The truck wash facility was surveyed.No nuclides attributable

to nuclear power.plant operation were identified.

The internal structure of several tankers has been inspected to determine if there are any physical obstructions

that will prevent the complete draining of material from the tanker.This inspection

concluded.

that there are no major structural

internals that should prevent the complete draining of a tanker.At least two designs have been identified;

however, they present no significant

impediments

to emptying the tankers.

ATTACHMENT

TO PLA-4473 Page6of6 PP&L correspondence

was sent to the organization

in Montreal, Quebec, who received the tanker, stating that there was not a radiological

hazard associated

with the tanker, and that the label could be removed.W W'1 Surveys of the remaining tankers that were utilized for similar purposes will be performed to assure that they are not radioactively

contaminated

nor contain.radioactive

sludge above station release limits.These surveys are scheduled to be completed by July 31, 1996.b.Inspections

of the remaining tankers that, were utilized for similar purposes will be conducted to assure that inappropriate

labels have been removed.These inspections

are scheduled to be completed by July 31, 1996.C.Requirements

associated

with tanker activities

within the protected area will be enhanced to assure that adequate controls exist for the use, surveying, sampling, labeling, etc.of tankers.These requirements

are scheduled to be developed and implemented

by July 31, 1996.The overall program for controlling

and coordinating

the process for removing material from the RCA and site will be evaluated.

This evaluation

is scheduled to be completed by July 31, 1996.Training will be provided, to applicable

functional

organizations, that addresses the release of materials from the RCA that may be slightly radioactive.

This training will contain elements associated

with appropriate.

lower limits of detection (LLD's), plate out mechanisms

and the diferent requirements

for release of materials from the RCA and offsite.Initial training for key functional

organizations

is scheduled to be completed by September 30, 1996.Based on 2.a and 2.b above, PP&L is in full compliance.