ML17348A385

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-250/90-08 & 50-251/90-08.Corrective Actions:Training Dept Increased Emphasis on Radiological Postings in Radiation Worker Training

ML17348A385
Person / Time
Site:	Turkey Point
Issue date:	07/03/1990
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-90-238, NUDOCS 9007090274
Download: ML17348A385 (11)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9007090274 DOC.DATE- 90/07/03 NOTARIZED: NO ACIL:50-250 Turkey Point Plant, Unit 3, Florida Power and Light C 05000250 50-251 Turkey Point- Plant, Unit 4, Florida Power and Light C 05000251 AUTH. NAME AUTHOR AFFILIATION NOTES'OCKET GOLDBERG,J.H. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds 50-250/90-08 to NRC ltr re violations noted in Insp Repts 50-251/90-08.

DISTRIBUTION CODE: IE06D COPIES RECEIVED'LTR ENCL SIZE:

TITLE: Environ & Radiological (50 DKT)-Insp Rep /Notice of Violate.on Respons .<

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME, LTTR ENCL ID CODE/NAME LTTR ENCL PD2-2 LA 1 0 PD2-2 PD 1 1 EDISON,G 1 1 INTERNAL AEOD/ANDERSON i R 1 1 AEOD/DS P 1 1 COLLINS 1 D RGN 2 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGDB 4E4. 1 1 NRR/DLPQ/LPEB1 0 1 1 NRR/DOEA/OEAB11 1 1 NRR/DREP/PRPB11 2 2 NRR/PMAS/ILRB12 1 1 NUDOCS-ABSTRACT 1 1 OE DIR 1 1 OGC/HDS2 1 1

~REPTILE 1 1 RES 1 1 R 2 D S R 1 1 RGN2 FILE 01 1 1 RGN4 MURRAY, B 1 1 EXTERNAL EG&G S IMPSON i F 2 2 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 25

P.O. Box 14000, Juno Beach, FL 33408 0420 APL JUDY. 0 3 1990 L-90-238 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Reply to Notice of Violation NRC Ins ection Re ort 90-08 Florida Power 6 Light Company has reviewed the subject inspection report and pursuant to .10,"CFR 2..201 the response is attached.

Very truly- yours,

'A P~

President Nuclear Division JHG/GRM/sh Attachment cc: Stewart D. Ebneter, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant 90070PO274 'P(")()7Q:3 PDR ADCrCK 0 nr.roA2~50 0 PDC an FPL Group company

ATTACHMENT REPLY TO A NOTICE OF VIOLATION RE: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 NRC Inspection Report 90-08 FINDING 50-250 251 90-08-01 "Technical Specification 6.11 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR 20 and to be adhered to for all operations involving personnel radiation protection exposure.

Licensee procedure O-HPA-002, Requirement for Entry and Work in the RCA, dated July 14, 1989, requires all personnel working in areas under a Radiation Work Permit (RWP) to read and to comply with all instructions, requirements, and remarks listed RWP on 90 4015 Elevations the p

RWP. ~

Unit 3 (U3) Containment 58 foot (58 ' and 30 Replace/Repair/Maintain/Modify the Normal Containment Cooler System and Motors, dated February 1, 1990, requires that prior to entering the Radiologically Controlled Area (RCA) each individual discuss the scope of work with the Health Physics Shift Supervisor (HPSS) and notify the Work Area Health Physics (HP) technician prior to starting work.

Contrary to the above, during the period March 26-28, 1990, selected workers entered the U3 Containment and initiated work on the "C" Containment Cooler System without contacting the HPSS nor the Containment Work Area HP technicians.

ADMISSION OR DENIAL OF THE VIOLATION:

FPL concurs with the finding.

2. THE REASON FOR THE VIOLATION The cause of this event was personnel error. The RWP instructions were very clear and precise concerning the requirements for this job.

Contract personnel working in the Unit 3 containment, even though they had been trained to abide by the requirements of RWPs, failed to contact the HPSS and the Work Area HP technician as required by the RWP. The requirement to contact the HPSS and Work Area HP technician was necessary because of the potential for changes in the dose rate in the work area which could occur after movement of the reactor head.

3 ~ THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

a ~ An HP technician observed the workers in an area potentially affected by the relocated reactor head and immediately ordered them to vacate the area.

The technician informed the workers that the potential dose rate for the area had changed from 1 2 millirem per hour to 25 50 millirem per hour.

Examination of the self-reading dosimeters for all workers using the RWP during the week of March 26, 1990, determined that the maximum exposure for a single entry was 20 millirem. Thus none of the workers received an excessive dose.

b. The RWP "Entry Log," form HP-l.l, was revised to instruct the worker signing in on the RWP to notify HP prior to the start of work activities. This will provide additional emphasis to the workers concerning the importance of this requirement as well as serve as an additional reminder.

c ~ In addition, the Health Physics Department conducted an informal random survey of personnel from the various groups to determine worker knowledge and compliance with RWPs. Based on this survey, several craftsmen did not have complete knowledge of the RWP they were working under. The supervisor of this group of personnel was notified by HP of this shortcoming. A memo issued by the supervisor of the group emphasized the importance of following the RWPs and advising his personnel of possible disciplinary actions that could result from violations 'of the RWPs.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

a The Health Physics Department will establish a spare copy file of active RWPs for job supervisors

~

and foremen. This will facilitate the use of RWPs in the field.

b. The Training Department will revise applicable lesson plans to provide special emphasis on RWP compliance during Radiation Worker Training.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.

a ~ Corrective action 4.a. will be completed by October 1, 1990.

b. Corrective action 4.b. will be completed by August 31/ 1990 FINDING 50-250 251 90-08-05

'X.

"10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contained any radioactive material in an amount exceeding ten times the quantity of such material specified in Appendix C of this part to be posted with a sign or signs bearing the radiation caution symbol and the words: "Caution, Radioactive Material(s)."

Contrary to the above, on May 2, 1990, the licensee failed to maintain adequate visible posting for a radioactive waste bin storage area located adjacent to, and north of the old Compactor Waste Building.

1 ~ ADMISSION OR DENIAL OF THE VIOLATION FPL concurs with the finding.

2 ~ THE REASON FOR THE VIOLATION'his event was caused by personnel errors. Plant non-licensed personnel moving trash into the storage area failed to restore a rope barrier with postings. In addition, trash bins had been positioned in front of some postings.

3. CORRECTIVE STEPS WHZCH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED'

~ The rope barrier was restored and postings were moved such that they would not readily be blocked by moving trash bins.

b. This event and other potential problem areas were reviewed in crew meetings with applicable Health Physics and Maintenance personnel.

c ~ Routine surveillances have been established to check radiological postings. These surveillances will ensure postings are in compliance.

d. The Training Department is increasing the emphasis on radiological postings in Radiation Worker Training.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

No additional corrective actions are considered necessary.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED'he required barriers and postings were restored on May 2( 1990.