ML18009A423

Suppls Response to NRC 900216 Ltr Re Violations Noted in Insp Rept 50-400/89-23.Corrective Actions:Surveys Performed to Determined Extent & Level of Contamination & Personnel Involved Decontaminated

ML18009A423
Person / Time
Site:	Harris
Issue date:	03/29/1990
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-703 NUDOCS 9004090407
Download: ML18009A423 (12)

See also: IR 05000400/1989023

Text

ACCELERATED

DISTRIBUTION

DEMONST$&TION SYSI'.EM REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)SSION NBR:9004090407

DOC.DATE: 90/03/29 ,NOTARIZED:

NO CIL:50-400

Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION

RICHEY,R.B.

Carolina Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000400 R SUBJECT: Suppls response to NRC 900216 ltr re violations

noted in I Insp Rept: 50-400/89-23.

DISTRIBUTION

CODE: IE06D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: Environ 6 Radiological

(50 DKT)-Insp Rept/Notice

of Violation Respons NOTES:Application

for permit renewal filed;05000400 RECIPIENT ID CODE/NAME PD2-1 LA BECKER,D INTERNAL: ACRS AEOD/DSP NMSS/LLOB 5E4 NRR/DLPQ/LPEB10

NRR/DREP/PRPB11

RG~2~DRSS/RPB

RGN4 MURRAY, B EXTERNAL: EGGG SIMPSON,F NRC PDR COPIES LTTR ENCL 1 0 1 1 2 2 1 1 1 1 1 1 2 2 1 1 1 1 1.-1 1 1 2 2 1 1 RECIPIENT ID CODE/NAME PD2-1 PD AEOD/ANDERSON

i R COLLINS i D RGN 2 NMSS/SGDB 4E4 NRR/DOEA/OEAB11

NRR/PMAS/ILRB12

OGC/HDS1 RES RGN2 FILE 01 LPDR NSIC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1'1 1 1 1 1 1 1 1~1 1 1 A D D R.D NOTE TO ALL"RIDS" RECIPIENTS:

D D POSE HELP US TO REDUCE WASTEl CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISHUBUTION

AL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 26

CaroUna Power 8 Ught Company P.O.Box 165~New Hill~N.C.27562 R.B.RCHEY Maeger H~N~~P J l fgAR 2 9]99ti Letter Number.'H0-900049

(0)Document Control Desk United States Nuclear Regulatory

Commission

Washington, DC 20555 NRC"703 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO~50-400 LICENSE NO.NPF-63 SUPPLEMENTAL

RESPONSE TO A NOTICE OF VIOLATION Gentlemen:

In reference to your letter of February 16, 1990, referring to I.E.Report RII: 50-400/89"23, the attached is Carolina Power and Light Company's supplemental

response to the violation identified

in the Enclosure.

It is considered

that the corrective

actions taken are satisfactory

for resolution

of the item.Thank you for your consideration

in this matter.Very truly yours, c.sH R.B.Richey, Manager Harris Nuclear Project MGW:dgr Enclosure cc'Mr.R.A.Becker (NRC)-Mr.ST D.Ebneter (NRC-RII)Mr.J.E.Tedrow (NRC" SHNPP)004090407 90032<p PDR ADOCK 0 000400 9 PDO go<MEM/HO-9000490/1/OS1

Attachment

to CPGL Letter of Res onse to NRC I.E.Re ort RII: 50-400 89"23 Re orted Violation.'icensee

Technical Specification 6.8 requires written procedures

to be established, implemented, and maintained

to cover the activities

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Regulatory

Guide 1.33, Revision 2, February 1978, Appendix A recommends

radiation control procedures

for access control to radiation areas including a radiation work permit system, radiation surveys, and personnel monitoring.

Licensee procedure, Plant Program Procedure PLP-511, Radiation Control and Protection

Program, Revision 3, states in part, that routine radiation surveys of accessible

plant areas shall be performed on an appropriate

frequency, depending on the probability

of radiation and contamination

levels changing and the frequency of the areas visited.Furthermore, the procedure states, that surveys relating to specific operations

and maintenance

activities

in support of radiation work permits (RWPs)shall be performed to keep the exposures ALARA and to keep personnel informed of changing plant radiological

conditions.

Licensee procedure AP-503, Entry Into Radiological

Areas, Revision 5, states in part, that each individual

working in an RCA is responsible

for complying with the instructions

on the RWP and oral instructions

given by Radiation Control personnel.

Contrary to the above, the licensee failed to follow radiation control procedures

concerning

area and personnel contamination

surveys and RWP special instruction

in that: a.On August 9 and ll, 1989, the licensee failed to make radioactive

contamination

surveys at a frequency necessary to detect changing radiological

conditions, in that, the clean area on the licensee's

286 foot fuel handling floor became contaminated

causing personnel to become contaminated

with radioactive

material.b.(Example b.withdrawn from Notice of Violation per NRC Report Number 50-400/89-23

dated February 16, 1990.)c~On August 16, 1989, a licensee employee working in the RCA failed to comply with oral instructions

given by radiation control personnel on the 286 foot elevation of the Fuel Handling Building when the worker began removing a contaminated

concrete form prior to receiving authorization

to begin work from radiation control personnel.

This is a Severity Level IV Violation (Supplement

IV).MEM/H0-9000490/2/Osl

l

Denial or Admission and Reason for the Violation:

a.The violation is correct as stated.The failure of two lifting straps during the handling of a spent fuel cask was suspected to have caused damage to the cask'sealing surface.To reduce dose,to the personnel performing

an inspection

'f the cask, plans were made to remove the basket (a 3 R/hr source)from the cask.The basket was to be removed from the cask in the Cask Unloading Pool, moved across the floor on the 286'levation

of the Fuel Handling Building (FHB)and resubmerged

in the unit 2-3 transfer canal.A Special Radiation Work Permit was written for this evolution and, on August 9, 1989, radiation control personnel were stationed to monitor dose rates and airborne activity as the'asket was moved.During two unsuccessful

attempts to lift the basket, it was sprayed with water from the Cask Unloading Pool spray ring.A water mist rose about fifteen feet above the floor as this spraying was done.No spray was used during the third attempt when the basket was moved to the transfer canal.Since no airborne activity was observed during the movement, no spread of contamination

was suspected and no surveys were performed following the move.Two workers were contaminated

in clean areas of the FHB.Following the inspection

discussed above, the basket was to be placed back into the cask.Additional

precautions, which included securing FHB ventilation, using a portable HEPA unit in the area adjacent to the basket's path, trying to reduce basket contamination

by moving it back and forth in the transfer canal, and not using spray, were taken during this movement.Additional

air sampling equipment was also used and, again, no significant

airborne activity was detected, Gross masslinn surveys performed during and immediately

following movement of the basket showed no contamination

in the area.These contamination

surveys were not documented.

Since it was believed that adequate precautions

had been taken to'prevent

the spread of contamination, no surveys were performed prior to restoring general access.Two low-level (200 cpm)shoe contaminations

occurred in clean areas of the Fuel Handling Building.These contamination

incidents resulted from a failure to perform the surveys needed to detect a change in radiological

conditions.

c.The violation is correct as stated.On August 16, 1989, two workers entered the Fuel Handling Building (FHB)to perform work in areas adjacent to the Cask Unloading Pool.Prior to entering the FHB, the workers stopped at the Radiation Work Permit (RWP)Office to inquire about conditions

in the work area and radiological

controls needed for performing

the work.The RC Technicians

in the office told the workers to sign in on a general RWP and contact the radiation control technician

in the Fuel Handling Building prior to starting work.Information

MEM/HO-9000490/3/OS1

on radiological

conditions

at the work site was not available in the RWP Office since all survey information

associated

with spent fuel cask handling was being treated as safeguards

information.

The workers located the FHB RC technician, who was performing

a survey around the Cask Unloading Pool (CUP).They discussed the work, which was to remove concrete forms on the east and south sides of the CUP.To prevent any material from falling into the pool, the workers indicated that they would need to place a plastic cover over the pool.The RC Technician

informed the workers that they could enter on the north and east sides of the pool, but the south side (a High Contamination

Area)could not be entere'd until a more thorough contamination

survey had been performed.

It was the RC technician's

understanding

that the workers would only begin preparations

for the job and he took smears on the south side of the pool and exited the area to have them counted.When the radiation control technician

returned, he found that one of the workers had already removed part of the form on the east side of the pool.The form he had surveyed on the south side of the pool was contaminated

to a level of 25,000 dpm/100 cm and the technician

concluded that similar levels probably existed on the east side form.The RC technician

stopped the job and told the workers to leave the area until a Special RWP with appropriate

radiological

controls could be issued to cover the work.Miscommunication

between the workers and the RC Technician

concerning

what work could actually be done prior to completion

of the survey was the cause of this violation.

Contributing

to this failure to communicate

was the amount of work being performed by the RC Technician

in the Fuel Handling Building and the RWP Office's lack of information

concerning

the radiological

conditions

in the FHB.The HP Technician

was unable to take the necessary time to cover the work and the RWP Office could not assist in determining

the radiological

controls needed.Corrective

Ste s Taken and Results Achieved: a.For both occurrences

the following immediate corrective

actions were taken.'.Radiological

control boundaries

were established

in the Fuel Handling Building to prevent the further spread of contamination.

2.Surveys were performed to determined

the extent and level of contamination.

3.Area decontamination

was performed as necessary.

4.Personnel involved were decontaminated.

These corrective

actions were completed on August 12, 1989.C~The job was stopped and the workers exited the area.This action was completed on August 16, 1989.MEM/HO-9000490/4/OS1

Corrective

Ste s Taken to Avoid Further Violations

a~The following actions have been taken.'rocedure

HPP-152,"Receipt of Spent Fuel" has been revised, to require that decontamination

personnel be assigned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day during fuel/cask handling to maintain cleanliness

in the FHB.Normally, four personnel should be assigned to this task.Routine wipedowns of handrails and floor surfaces conducted by these personnel on the fuel handling deck have significantly

reduced the number of contamination

events in the FHB.2.Procedural

controls have been developed to incorporate

the radiological

controls necessary to prevent recurrence

of the violations

discussed above.These controls are in the form of Job Recipe 807-02 which includes the following information'.

a brief job description

reference to the job procedure a list of materials needed for job coverage recommendations

for dress/dosimetry/RWP

a description

of set-up for the work area precautions/recommendations

for job coverage postjob instructions

a history of past problems with the job Job recipes are used to assist in the writing of RWPs and to provide guidance during job briefings and job coverage.They are developed for repetitive

jobs which involve significant

doses, contamination

and/or other radiological

hazards or jobs which are complicated

and involve extensive job coverage.These actions were completed prior to,the next basket move which occurred after January 4, 1990.3.The RC Program was reviewed and, to prevent problems caused by removing postings without proper surveys in the FHB and other plant areas, it was decided to revise Procedure HPP-035,"Posting and Barricading

of Radiological

Areas".The revised procedure requires that appropriate

surveys be performed and documented

before postings or barricades

are removed.This applies to postings and barricades

established

both for actual and anticipated

radiological

conditions.

This action was completed on January 31, 1990.The RC Program review did not indicate the need to revise any other procedures.

MEM/HO-9000490/5/OS1

c~The following actions have been taken.1.HPP"152,"Receipt of Spent Fuel" was revised to require that during cask/fuel handling (day shift)a control point will be set up on Fuel Handling Building (FHB)elevation 286'outh.Establishing

a control point in the FHB will help ensure that adequate RC personnel are available to cover the work in progress.This'ontrol

point will be manned by one or more radiation control technicians

who are knowledgeable

of the radiological

conditions

in the area and who will direct the RC job coverage.As required by HPP-021,"Establishing

and Maintaining

RC Access Points" the RC Foreman will be responsible

for determining

the manning requirements

for the control point.2.HPP-152 was also revised to require that only cask receipt surveys be considered

as safeguards

information.

All other surveys performed in the FHB during fuel/cask handling evolutions

will be documented

in accordance

with normal survey procedures.

These surveys will be available to all personnel working in the FHB.3.A manager has been assigned the responsibility

for coordinating

the fuel/cask handling program to provide overall control of spent fuel receipt evolutions.

These actions were completed on December 21, 1989.Date When Full Com liance Was Achieved: Full compliance

was achieved on January 31, 1990.MEM/HO-9000490/6/OS1