ML17338A408

Responds to 781106 NRC Ltr Re Violations Noted in Inspec Repts#50-250/78-21 & #50-251/78-21.Corrective Actions: Respiratory Protec Equip Training Classes & Health Physics Training Classes Held

ML17338A408
Person / Time
Site:	Turkey Point
Issue date:	12/01/1978
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML17338A407	List: ML17338A408
References
L-78-375, NUDOCS 7812280339
Download: ML17338A408 (8)

See also: IR 05000250/1978021

Text

~00'l,'A,'0: i g FLORIDA POWER EI LIGHT COMPANY December 1, 1978 L-78-375 Mr.James P.O'Reilly, Director, Region II Office of Inspection

and Enforcement

U.S.Nuclear Regulatory

Commission

101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 Dear Mr.O'Reilly: Re: RI I: DMC 50-250/78-21

50-251/78-21

Florida Power 8 Light Company has reviewed the subject inspection

report and a response is attached.There is no proprietary

information

in the report.Ver uly yours, Robert E.Uhrig Vice President REU/MAS/cpc

Attachment

cc: Robert Lowenstein, Esquire V812280 Rgb

0 a

ATTACHtlENT

Re: RII:DNC 50-250/78-21'55-255

12-21~Findin A Technical Specification 6.11 states, in part, that procedures

for personnel radiation protection

shall be prepared consistent

with the requirements

of 10 CFR 20 arid shall be adhered to for all operations'involving

personnel radiation exposure.Procedure HP-66,"Issuance and Control of Respiratory

Protection

Equipment," requires, in part, that prior to personnel being issued respiratory

equipment, the Health Physics Shift Supervisor, or his designee, ensure that the personnel have been properly trained and found to be medically certified to wear a respirator.'ontrary

to the above, the inspectors

observed the following instances where the requirements

of approved radiation protection

procedures

were not being adhered to: , l.On September ll, 1978, respirators

F-98 and F-138 were issued to.an.individual

who upas not medically certified to wear a respirator.

2.On August 31, 1978, respirators

F-ill, F-285, F-153, F-42, F-25, F-164,, and F-05 were issued to a corporation

name rather than a trained, medically certified individual.

Numerous examples of corporate issuance were noted by the inspector for the month of Aug'ust, 1978.Res onse A The immediate correcti ve action was to determine if the individuals

who used the cited respirators

were in fact qualified to use them.It was found that, although the respirators

may have been issued improperly, they were in all cases used by trained and medically certified individuals.

2 In order to help prevent recurrence, respiratory

protection

equipment training classes were held for appropriate

health physics personnel on October 4 and 5, 1978.The classes stressed the importance

of adhering to the policy of issuing respirators

only to individuals

who are trained and medically qualified to use them.Compliance

was achieved as of October 5, 1978.To provide further assurance of preventing

recurrence, Operating Procedure 11550.66 (Issuance and Control of Respiratory

Protection

Equipment)

will be revised to clearly prohibit issuance of respirators

to'orporation

names.Furthermore, the effectiveness

of corrective

action regarding the issuance of respirators

will be audited during the first half of 1979.

I

~Findin B 10 CFR 71.12b(ii)

requires, in part, that the persons using shipping containers, pursuant to the general license, for which a certificate

of compliance

has been issued, comply with the terms and conditions

of the certificate.

Certificate

of Compliance

No.9113 for, the Model No.7-100 shipping container authorizes

the use of the container under the general license provisions

of-10 CFR 71.12(b);and requires that (1)the contents of the secondary container meet the requirements

of low specific activity radioactive

material, defined in 10 CFR 71.4.(g).(i), (ii)8 (iii), (2)the maximum total weight of the contents and secondary container shall not exceed 7000 pounds, and (3)lid lifting lugs shall not be used for lifting the cask and shall be covered in transit.Contrary to the above, records of dewatered spent resins shipped from the site on July 21 and 28, 1978, and August 25 and 31, 1978, state that greater than 7000 pounds were shipped on August 25 and 31, 1978 in a Model No.7-100 shipping container and by calculations

from the recorded data, indicate that greater than LSA concentrations

for Group II materials (fli xed Fission Products)had been shipped for all the above shipments.

On Septerrber

12, 1978, a truck in transit was seen by the inspectors

leaving the radiation controlled

area with a Model No.7-100 shipping container on a trailer with the lid lugs uncovered.

Res onse 8 L With respect to the shipment ofgreater

than low specific activity (LSA)concentrations, the imm diate corrective

action was,to determine if the cited shipments were in fact less than LSA.The quantities

and types of radioactive

materials shipped were reevaluated

and found to have been less than LSA, however, this did not alter the fact that the information

available at the time of shipment indicated greater than LSA.In order to prevent recurrence, training classes for appropriate

health physics personnel were held on November 20 and 21, 1978 to review the subject of radioactive

material.shipment.Compliance

was achieved as of November 21, 1978.To provide further assurance of preventing

recurrence, the appropriate

health physics procedure will be revised to include checklists

to be used when shipping r dioactive materials.

The'checklists

will be based on the certificates

of compliance

for the shipping containers

that we use.Further-'ore, the effectiveness

of corrective

action regarding the shipment of radioactive

material will be audited during the first half of 1979.

I~~0

~Findin C Technical Specification 6.13;l.b states that"each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr shall be subject to the provisions

of 6.13.1(a)and, in addition, locked doors shall be provided to prevent unauthorized

entry into such areas and the keys shall be maintained

under administrative

control." Contrary to the above, on September 12, 13 and 14, 1978, radiation levels in two high radiation areas inside reactor containment

exceeded 1000 mrem/hr and no locked doors were provi.ded for these individual

areas.The areas were: 18 inches from regenerative

heat exchangers

where levels ranged from 1000 to 3000 mrem/hr, and 18 inches from reactor cavity filters where levels ranged from 1500 to 2500 mrem/hr.The reactor was shut down and the areas were accessible

to service personnel.

Res onse C As a result of the finding, we have reviewed Technical Specification 6.13.1 and Part 20.203(c)(2)

of 10 CFR 20, which is modified by the Specification.

In our opinion, the conditions

cited do not constitute

an item of noncomplian'ce.

Our opinion is based on the fact that both high radiation areas cited in the finding are located inside containment.

We have identified

the inside of containment

as a high radiation area and have provided it with a locked door as required by Technical Specification 6.13.l.b.The area is maintained

locked except during periods when access is required, at which times entry is controlled

in accordance

with 10 CFR Part 20.203(c)(2)(iii).

Our review to date indicates that a revision to Technical Specification 6.13.1 might be useful.The intent of such a revision would be to clarify the Specification

with respect to high radiation areas inside containment, to preclude differing interpretations

by reviewers, and to bring the Specifica-

tion in line with the underlying

regulation.

We plan to submit the proposed revision to the Office of Nuclear Reactor Regulation

by about December 31, 1978.We view the finding as representing

a valid concern about the control of radiation exposure to our workers, and we recognize that it is proper to improve that control whenever such improvement

is reasonably

achievable.

With respect to the two areas cited in the finding, we intend to take the following actions: (1)A locked enclosure will be installed around the Unit 3 regenerative

heat exchanger no later than 30 days after the beginning of the next Unit 3 refueling outage (scheduled

to begin about January 1, 1978).At the present time, similar action is planned for the Unit 4 refueling outage (scheduled

to.begin March 25, 1979).(2)The radiation area around the reactor cavity filters will be controlled

by one or more of the following methods: a)Changing the filters before the radiation level exceeds 1000 mrem/hr.

~~,~~d)b)Shielding the filters with lead shielding and changing the filters before the radiation level outside the shielding exceeds 1000 mrem/hr.c)Turning the cavity filtration

system off before the filter radiation level exceeds 1000 mrem/hr.If radiation levels exceed 1000 mrem/hr., additional

controls over access to the area around the filters will be instituted

until the radiation level can be reduced.Further action is planned to evaluate exposure control inside containment

during periods when the reactor is shutdown and workers have access to the containment.

Containment

radiation surveys will be made during the next refueling of each unit and, based on evaluation

of the results, additional

controls may be established

to help maintain exposure to our workers as low as reasonably

achievable.