ML18005A704
| ML18005A704 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/17/1988 |
| From: | Watson R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| CON-NRC-650 HO-880232-(O), NUDOCS 8811220441 | |
| Download: ML18005A704 (13) | |
Text
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:8811220441 DOC.DATE: 88/11/17 NOTARIZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION WATSON,R.A.
Carolina Power
& Light Co.
RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 881018 ltr re violations noted in Insp Rept 50-400/88-28.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR Q ENCL SIZE-TITLE: General (50 Dkt)-Insp Rept/Notice of Violation esponse DOCKET 05000400 NOTES:Application for permit renewal filed.
05000400 RECIPIENT ID CODE/NAME PD2-1 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEB 11 NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRRgPMAS/ILRB12 OE~XEBE, J LE 02 TERNAL: LPDR, NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME BUCKLEY,B AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RGN2 FILE 01 NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1
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NOIE 'IO ALL "RIDS" RECZPZERIS'IZASE HELP US TO REDUCE WASTE! ~CI'IHE DOCUMENI'GNI'.RDL DESK KXM Pl-37 (EXT. 20079)
TO XXiQQMXR 'DKR MHE PKH DZSTRZKlTION LISTS FOR DOCUMEMIS YOU DON'T NEED'.
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 24
CIIRL Carolina Power 8 Light Company NO'lJ' 7 1988 HARRIS NUCLEAR PROJECT P. 0.
Box 165 New Hill, North Carolina 27562 File Number.'SHF/10-13510E Letter Number'.
HO-880232 (0)
NRC-650 Document Control Desk United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO ~ 50-400 LICENSE NO. NPF"63 REPLY TO A NOTICE OF VIOLATION Gentlemen'.
In reference to your letter of October 18, 1988, referring to I.E.
Report RII:
50-400/88-28, the attached is Carolina Power 6 Light Company's reply to the violations identified in Enclosure 1.
Although the violations are
- admitted, Carolina Power and Light Company disagrees with the severity level assigned to violation C.
We do not believe that this identified violation meets the criteria of a severity level IV as described in 10CFR2 Appendix C,
Supplement IV D, and that assignment of a severity level V is more appropriate.
This is based on our determination that the violation has only minor safety or environmental significance.
Thank you for you consideration in this matter.
Very truly yours, R. A. Watson Vice President Harris Nuclear Project MGW:tbb Attachment cc.'Messrs.
W. H. Bradford (NRC-SHNPP)
B. C. Buckley (NRC)
M. L. Ernst (NRC)
MEM/HO-8802320/1/OS1 Sgff220441 88iff7 PDR ADOCK 05000400 9
Attachment to CPSL Letter of Res onse to NRC I.E.
Re ort RII:
50-400 88-28 Violations Re orted Violation'.
A.
10CFR20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Health Physics Procedure HPP-030, Control and Release of Equipment/Material from the RCA/Restricted Area, Revision 3, dated August 27,
- 1987, requires 'n Section 10.1.1 that material/equipment being transferred within the RCA be surveyed for radiation and contamination per HPP-060, Performance of Radiation and Contamination Surveys.
- Also, Section 10.1.2 states that if radiation/contamination levels are less than 100 net cpm per probe area as measurable with a thin window pancake-type detector by direct frisk (fixed and remove le) and less than MDA (defined as
<100 net cpm per lDD cm ) for the counting instrument used by smear survey (removable),
the material/equipment can be released for transfer.
Health Physics Procedure HPP-060, Performance of Radiation and Contamination
- Surveys, Revision 2,
dated September 29,
- 1987, requires in Section 7.12
- that, when counting smears for beta-gamma contamination using a frisker, a
minimum count time of about 20 seconds is recommended to allow for a 90 percent deflection of full scale in the slow response mode.
- Also, 10.8.2 requires a
frisk of the acces'sible surfaces of the material being surveyed by moving the probe. slowly over the surfaces within one-half inch of the surface.
Contrary to the above, the licensee failed to meet the survey requirements in that, during the week of August 15-18,
- 1988, on numerous occasions various items including electrical
- cords, hoses,
- cables, and other pieces of equipment were not ad'equately surveyed (frisked or smeared) to determine the extent of radiation hazards that may have been present.
This is a Severity Level IV violation (Supplement IV).
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
MEM/HO-8802320/2/Osl
With less than two years of power operations SHNPP entered its first refueling outage as a relatively "clean plant."
For this
- reason, Radiation Control (RC) personnel were used to finding very few contaminated items at the exit from the reactor containment building (RCB).
This experience plus time pressure created by the large number of items which needed to be frisked out at the RCB control point led to the less than adequate performance of contamination surveys.
Corrective Ste s Taken and Results Achieved:
Personnel responsible for performing contamination surveys on tools and equipment were cautioned, by August 19,
- 1988, as to the proper procedure for performing such surveys.
As a
- result, proper contamination surveys were performed for the balance of the outage.
Corrective Ste s Taken to Avoid Further Noncom liance'.
The proper performance of contamination surveys will continue to be emphasized during RC technician training.
The qualification cards for CP&L RC technicians were reviewed and verified that the survey qualification requires a person to satisfactorily Eerfocm the task.
Procedure EEC-104, Contract E&RC Technician Qualification and Training, will be revised to require the same qual card requirements for surveys by contractor RC technicians.
Date When Full Com liance Will Be Achieved:
Full compliance will be achieved when the change to ERC-104 is made as stated above.
This is projected to be complete by January 1,
1989.
Re orted Violation.'.
Technical Specification 6.12 requires that any individual permitted to enter a
high radiation area in which the intensity of radiation is equal to or less than 1000 millirem per hour at 18 inches shall be provided with or accompanied by..'.
1.
A radiation monitoring device that continuously indicates the radiation dose rate in the area',
or 2.
A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a present integrated dose is received; or 3.
an individual qualified in radiation protection procedures, with a
radiation dose rate monitoring device.
MEM/HO-8802320/3/OS1
Contrary to the above, the requirements for entry into a high radiation area were not met in that, on August 18,
- 1988, an individual was observed in a high radiation area without a
radiation monitoring device or accompanied by an individual qualified in radiation protection procedures with a radiation dose rate monitoring device.
This is a Severity Level IV violation (Supplement IV).
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
The cause of the violation is attributed to the lack of awareness and experience on the individual worker's part on remembering not to leave the vicinity of other persons inside the high radiation area (HRA) who had the survey instrument assigned for the group.
SHNPP acknowledges that, the event happened based on the inspector's observation, although we have no information as to specifically who the individual was.
Me are aware that several individuals qualified as snubber inspectors were relatively inexperienced as radiation workers.
In spite of proper training for entries to
- HRAs, this individual most Likely simply forgot about needing to stay with a person having the survey instrument.
Corrective Ste s Taken and Results Achieved:
The RC technicians assigned at the RCB access point were directed to question persons entering the RCB as to whether or not they would be going inside the secondary shield wall.
In this way, the technicians ensured that individuals not being escorted by Health Physics (HP) personnel and needing Dositecs were issued one.
This action was implemented on August 19, 1988.
Corrective Ste s Taken to Avoid Further Noncom liances During future
- outages, when unescorted access into HRAs inside the RCB are
- required, a
similar positive control
- method, as stated above, will be used for issuance of dose rate meters or alarming dosimeters to those who require one.
The use of proper dosimetry when entering an HRA will be reinforced to plant personnel by December 1,
1988.
Prior to the beginning of he next refueling outage, plant personnel will again be reminded of HRA dosimetry requirements.
MEM/HO-8802320/0/OS1
Date When Full Com liance Will Be Achieved:
Initial reinforcement of requirements to plant personnel as stated above will be completed by December 1,
1988.
Remaining actions are pending the next refueling outage which is currently scheduled to begin approximately November 11, 1989.
Re orted Violation.
C.
Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the Process Control Program implementation.
Technical Specification 6.8.2 requires that each procedure of Technical Specification 6.8.1, and changes
- thereto, be reviewed and approved in accordance, with Technical Specification 6.5.1 prior to implementation and reviewed periodically.
Contrary to the
- above, these requirements were not met in
- that, procedures covering the Process Control Program were not reviewed and approved prior to implementation and reviewed periodically.
This is a Severity Level IV violation (Supplement IV).
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
Written procedures for the plant installed solidification system are provided and were reviewed and approved in accordance with Technical Specification 6.5,1 prior to implementing as required by Technical Specification 6.8.1 and 6.8.2.
These plant procedures are listed in the Process Control Program PLP-300 Table 6.1.
Due to delays in startup testing of the plant's solidification system a
contract for a
vendor mobile solidification system was obtained as required by Technical Specification 4.11.3 in March 1987.
The vendor contract required processing to be performed in accordance with an NRC approved Process Control Program.
This requirement is covered in the SHNPP Process Control Program Section 4.2 which states'.
MEM/HO"8802320/5/Osl
"Solidification vendor services may be used to solidify or dewater any radioactive waste stream provided the solidification or dewatering is done in accordance with an approved or qualified Process Control Program.
If
'the solidification vendor's Process Control Program is used the requirements of this Process Control Program are not applicable."
The vendor's Process Control Program and operating procedures were submitted to the NRC as part of the Topical Report 4313-01354-01P-A "CNSI Mobile Cement Solidification" and Topical Report DM-11118-Ol-NP-A "CNSI Dewatering Control Process Containers."
These reports were approved by the NRC in January 1983 and June 1985 respectively.
Since the work was being performed by the vendor using vendor procedures which had been previously reviewed by the NRC as part of the Topical Report and the NRC approved plant Process Control Program made reference to the vendor's program being in
- control, the plant determined these vendor procedures were not direct Process Control Program implementing procedures.
Plant management determined it was not necessary to make these procedures part of the Plant Operating
- Manual, therefore, the reviews required by Technical Specification 6.5.1, were not performed.
The procedures were informally reviewed by Radwaste Engineering and found in Compliance with the approved Topical Report at which time the vendor was authorized to perform solidification and dewatering.
The reason for the reported violation was a difference in the interpretation of the Technical Specification as to the applicability to a vendor mobile solidification system versus the plant installed solidification system.
Plant procedures implementing the Process Control Program had been reviewed and approved per Technical Specification 6.5.1 and the vendor procedures had been informally reviewed.
The vendor program had also been reviewed and approved by the NRC.
Corrective Ste s Taken and Results Achieved:
1.
Solidification and dewatering was immediately suspended until procedures were reviewed and approved by the plant.
2.
A contract amendment was initiated to require the vendor to use only procedures which have been reviewed and approved by the plant.
MEM/HO-8802320/6/OS1
3.
An Operations Management procedure OMM-008 "Process Control Program Implementation Procedure Review and Approval" was written to provide a
program for review and approval of vendor procedures which implement the Process Control Program.
This procedure also requires periodic reviews of the vendor procedures at least once every two years.
Procedure revision will be considered a review.
4.
Technical and Safety reviews are being 'completed on all vendor procedures which implement the Process Control Program.
Five of seven vendor procedures have been reviewed and approved for use by the plant.
No Technical or Safety problems were found which would cause waste solidified or dewatered by these procedures to be in noncompliance with any Federal, State or Burial site requirements.
Corrective Ste s Taken to Avoid Further Noncom liance:
The program as stated
- above, has been established to provide review and approval of vendor procedures which implement the Process Control Program.
Date When Full Com liance Will Be Achieved:
The plant was in compliance on September 2,
- 1988, when solidification was suspended until procedures were approved.
Full compliance will be achieved upon review and approval of the remaining vendor procedures as stated above.
Completion is currently projected for January 2,
1989 Re orted Violation.'.
Technical Specification 6.11.1 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10CFR20 and shall be
- approved, maintained, and adhered to for all operations involving personnel radiation exposure.
Health Physics Procedure HPP-460, Operation of the Dositec
- 502A, Revision 1,
dated June 25,
- 1987, requires in Section 6.1.c, that the instrument (Dositec) be response checked prior to issue.
Contrary to the
- above, the licensee failed to adhere to procedures in that, during the period of August 15"17,
- 1988, Dositecs were not response checked prior to being issued.
This is a Severity Level IV violation (Supplement IV).
MEM/HO-8802320/7/OS1
Denial or Admission and Reason for the Violation'.
The violation is correct as stated.
The violation occurred because RC personnel misinterpreted the procedural requirement for a
response check "prior to use" within the context of how the alarming dosimeters (Dositecs) were being "used."
To support the first refueling outage during which large numbers of personnel require unescorted access into HRAs inside containment, Dositecs were selected to satisfy the survey instrument requirement (Technical Specification 6.12) for HRA entries.
- Thus, a quantity of Dositecs were response checked in the calibration lab prior to putting them "in use" by assigning them to the containment access point. Performing this response check in the cal lab is necessary because it requires a relatively high activity check source.
Using low activity button sources available outside the cal lab requires about 7-8 minutes to response check a
Dositec.
Therefore, it is not practicable to response check each Dositec prior to issuing it to an individual.
Normally that is the time that a survey instrument is considered to be put "in use."
- Thus, by that interpretation, the response check requirement was not met for the Dositecs.
Corrective Ste s Taken and Results Achieved:
RC personnel began performi'ng daily response checks of Dositecs available for use on or before August 19, 1988.
This ensured that Dositecs were response checked prior to being put into use by whoever needed one during the course of that day.
Corrective Ste s Taken to Avoid Further Noncom liance'.
A change to HPP-460 was approved on September 21,
- 1988, which documented the requirement for daily response checking the Dositecs available for use.
Date When Full Com liance was Achieved:
Full compliance was achieved on September 21,
- 1988, upon approval of the change to HPP-460 which documented the daily response checks of Dositecs available for use.
MEM/HO-8802320/8/OS1