ML19281B017
| ML19281B017 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/23/1979 |
| From: | Vandenburgh D Maine Yankee |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19281B016 | List: |
| References | |
| WMY-79-5, NUDOCS 7904200151 | |
| Download: ML19281B017 (9) | |
Text
'
. ;,=w====w
/
" " ~ ~ ~ ^ ~ ~
- MAME --
- UARHEE
" ' ' ~ " " ~ '
TURNPIKE ROAD (RT.9) s g'
$ [Z",1,/
ENGINEERING OFFICE WESTBORG, MASSACHUSETTS 01581 s'
617-366-9011
%, _ _; g January 23, 1979
~ _ _ "
WMY 79-5 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention:
Office of Inspection and Enforcement Mr. Boyce H. Grier, Director
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b) I&E letter to M.Y.A.P.C. dated December 28, 1978, ISE Inspection Report No. 50-309/78-18 and Meeting No. 50-309/78-21
Dear Sir:
~
Subject:
Response to Inspection No. 50-309/78-18 In reply to Reference (b), the Maine Yankee Atomic Power Company hereby submits the following information:
Item A., Apparent Item -f Noncompliance:
" Technical Specification 5.2.2, ' Facility Staff', item d. states, 'An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor. '
" Contrary to the above, on September 25, 1978, at 1800, the reactor contained fuel, was operating at power, and an individual qualified in radiation protection procedures was not on site."
Item A., Reply:
The requirement to have an individual qualified in radiation protection procedures on site when fuel is in the reactor, became part of the Maine Yankee Technical Specifications in January of 1978.
In preparation for this requirement, Maine Yankee administered a comprehensive training program to the Auxiliary Operators who would be fulfilling this reqcirement. Contrary to what is implied in the notice of violation, one of these Auxiliary Operators was on duty on the night in question.
While we do not agree that the series of questions the inspector asked the Auxiliary Operator necessarily constitutes a definitive measurement of qualification in radiation protection procedures, it is obvious that more frequent review training is required.
790420015/
U.S. Nuclear Regulatory Commission January 23, 1979 Attn:
Office of Inspection & Enforcement Page 2 The following actions have, therefore, been taken to ensure that the intent of the Technical Specification requirement for "an individual qualified in radiation protection procedures" is continued to be met:
1)
The Radiological Controls Supervisor conducted immediate review sessions with the Auxiliary Operators designated qualified in radiation protection procedures to insure they were capable of conducting their intended function.
2)
Over the next several weeks, a comprehensive refresher course in radiation protection was administered to the Auxiliary Operators designated qualified in radiation protection procedures.
3)
The formal program used to train individuals designated as qualified in radiation protection procedures has been reviewed by the Radiological Centrols Supervisor and the Radiation Protection Group in our Westborough corporate office. Revised training and retraining programs have been proposed for the review and approval of the Manager of Operations.
These revised programs are in the process of being implemented.
Item B., Apparent Item of Noncompliance:
" Technical Specification 5.12.2, 'High Radiation Area,' requires that each high radiation area in which the intensity of radiation is greater than 1000 mrem /hr be controlled in accordence with the requirements of Technical Specification 5.12.1, and that locked doors be provided to prevent unauthorized entry into such an area.
" Contrary ts the above, on September 25, 1978, the intensity of radiation near degas filter FL 33A, located on the 11' elevation of the Primary Auxiliary building, was 1500 mrem /hr and locked doors or other equivalent barriers were not provided to prevent unauthorized entry into this area.
In addition, the area was not barricaded as required in Section 5.12.1, in that, the rope barricade and 'high radiation area' sign were so located that an individual would have already entered an area where the intensity of radiation was measured to be 200 mrem /hr before passing the barricade."
Item B., Reply:
Records of health physics surveys performed within the degas filter FL 33A area indicated a rac;ation level greater than 1000 mrem /hr on contact with the filter. Tae point at which the radiation level exceeded 1000 mrem /hr was a maximum of fourteen (14) inches from the filter.
The radiation level at greater distances was significantly less than 1000 mrem /hr.
This situation does not, in our opinion, constitute a condition wherein a major portion of the body could receive a dose in one hour greater than 1000 mrem.
Because of this, the area was not designated as a lockable high radiation area pursuant to Maine Yankee Technical
t 0
U.S. Nuclear Regulatory Commission January 23, 1979 Attn:
Office of Inspection & Enforcement Page 3 Specification 5.12.2.
Since exposure of individuals to a level greater than 100 mrem /hr was possible, the access to the filter was barricaded and posted as a high radiation area, requiring complisnce with Technical Specification 5.12.1 for entry. Maine Yankee believes the high radiation control exhibited for this component and area was, in fact, proper to comply with Technical Specification 5.12.2.
The High Radiation Area barricade was initially established at the 100 mrem /hr boundary.
However, following the draining of the filter to facilitate change-out, the barricade should have been re-established.
At the time of the inspection, it was determined that the rope barrier at the edge of the 100 mrem /hr are ves approximately one foot within the actual boundary. Upon determinir g this, the Auxiliary Operator moved the barricada to a distance that assured compliance with Technical Specification 5.12.1.
To prevent a reoccurrence of this situation, a locked caged area has been established around the degas filters at a distance which will assure compliance with High Radiation Area Technical Specifications.
Additionally, a sign has been posted on the cage requiring notification of Health Physics personnel prior to draining of either of the filters.
According to information obtained from the NRC Public Document Room (l) regarding high radiation area control:
"In the absence of facts or circumstances which show otherwise it may be assumed that a major portion of the body will not be exposed when the outermost extent of the 100 mr/hr region is within 1-1/2 feet of the barrier separating an individual from the source of radiation."
When the Radiological Controls Supervisor stated to the Inspector enat ne was complying with the "18 inch criterion," the inspector informed him the criterion did not apply.
Compliance with regulations is impossible when inspection criteria change and licensees are not informed of these changes.
Item C.1 and D., Apparent Items of Noncompliance:
Item C.1:
" Technical Specification 5.8, ' Procedures,' requires that written procedures be established, implemented and ocintained covering the ctivities referenced in Appendix ' A' of Regulatory Guide 1.33, November, 1972, and that these procedares be reviewed by PORC and approved by the Plant Superintendent.
(1) Interpretations:
10CFR Part 20:
USAEC, Directorate of Regula: cry Operations.
7/31/70
U.S. Nuclear' Regulatory Commission January 23, 1979 Attn: Office of Inspection & Enforcement Page 4
" Operations Procedure 1-12-4, ' Containment Entry,' Revision 4, issued December 8,1977, developed pursuant to A.9. of Appendix ' A' of Regulatory Guide 1.33, November, 1972 requires that a radiation Work Permit be obtained for entry into the containment.
" Contrary to this requirement, on September 27, 1978, two individuals, the Plant Shift Superintendent and Shift Operating Supervisor, entered
?.he containment while the reactor was operating at power without obtaining a Radiation Work Permit (RWP), and without using respiratory protective equipment.
This entry was also contrary to the requirements of Section 3.12 of the Radiation Protection Manual; contrary to the requirements of Health Physics Procedure 9.1.10, ' Radiation Work Permits,' and since the containment was an airborne radioactivity area, entry without respiratory protective equipment was also contrary to the requirements of Section 7.4.' cf Health Physics Procedure 9.1.6."
Item D:
"10 CFR 20.201(b), ' Surveys,' requires that such surveys be conducted as may be necessary to comply with the regulations contained in each section of Part 10.
A ' survey,' as defined in Paragraph 20.201(a), means 'an evaluation of the radiation hazards incident to production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
When appropriate, such 2ation includes a physical survey of the locations of materials and eva equipment, and measurements of levels of radiation or concentrations of radioactive materials present.'
" Contrary to this requirement, on Seotember 27, 1978, two individuals entered the containment, attempting co locate a primary coolant leak, without first making the required evaluation of the airborne concentrations of radioactive materials present in order to permit compliance with the regulations of 10 CFR 20.103."
Items C.1 and D., Reply:
The incident was reviewed and discussed in detail with the Plant Shif t Superintendent by members of plant management, including the Operations Department Head, the Radiological Controls Supervisor, the Assistant Plant Manager, the Plant Manager and the Manager of Operations.
The severity of the incident and the necessity to adhere to plant procedures, Technical Specifications, and 10CFR20 were stressed.
The Operations Department Head has also discussed the incident with the other plant Shift Superintendents, again streesing the importance of complying with plant procedures.
U.S. Nuclear Regulatory Commission January 23, '?79 Attn:
Office of Inspection & Enforcement Page 5 Additionally, the Manager of Operations discussed the incident and stressed its importance to the remainder of the plant staff at a general plant meeting.
However, with regard to these items, Maine Yankee feels that the single incident cited in Item C.1 should not result in multiple citations. Any violation of procedural controls automatically constitutes a violation of the Technical Specifications and infers a violation of any regulation upon which the procedure or specification is based.
To cite each portion of the procedure violated or eacn applicable reference is redundant.
The Plant Shift Superintendent, in failing to adhere to the requirement of Procedure 1-12-4, and in failing to notify the Health Physics Staff, did in fact, violate procedures governing containment entry.
These procedures require the issuance of a radiation work permit prior to entry and the permit, in turn, requires appropriate surveys (i.e., radiation, smears, and/or airborne activity) be performed prior to its issuance.
However, multiple citations for failure to follow individual subrequirements of a procedure are not felt necessary. We request that Item D be removed from the Notice of Violation.
Item C.2, Apparent Item of Noncompliance:
" Technical Specification 5.8, ' Procedures.' requires that written procedures be establiohed implemented and maintained covering the activities referenced in Appendix 'A' of Regulatory Guide 1.33, November, 1972, and that these procedures be reviewed by PORC and approved by the Plant Superintendent.
" Appendix 'A' of Regulatory Guide 1.3?, November, 1972, requires in Section G.5 that procedures for personnel monitoring be prepared.
" Contrary to this requirement, a written procedure has not been developed or reviewed by PORC or approved by the Plant Superintendent that specifies the method for calibration of the whole body counter, which is used to monitor personnel for internal disposition of radioactivity."
Item C.2., Reply:
A procedure has been written and implemented as of December 1, 1978.
Item E., Apparent Item of Noncompliance:
Technical Specification 5.11, ' Radiation Protection Program' states:
' Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure '
The ' Radiation Protection Manual, Maine Yankee Atomic Power Company,' Revision 3, issued August 24, 1977, states in
U.S. Nuclear Regulatory Commission January 23, 1979 Attn: Office of Inspection & Enforcement Page 6 Section 4.11, ' Personnel Exposure Investigations' that, 'Whenever a situation occurs involving the suspected or known exposure of personnel to ionizing radiation in excess of permissible limits specified in Section 2 of this manual, the incident shall be promptly investigated and personnel exposure evaluated.'
Section 4.11, also requires in part, that the Plant Superintendent or his designated alternate are members of the investigating committee and that a written report of the investigation include recommendations for corrective measures to prevent similar overexposures.
Section 2 in part 2.9.3 specifies an external radiation exposure of the whole body of 2000 mrem per calendar quarter.
" Contrary to the above, during the third quarter of 1978, a suspected exposure of ionizing radiation of 2576 mrem for one individual and 2725 mrem for another individual, although investigated, was not investigated by a committee which included the Plant Superintendent or his designated alternate and a written report that contained recommendations for corrective action to prevent similar overexposure was not issued."
Item E., Reply:
The Notice of Violation in regard to this item is silent as to the facts surrounding these alleged "overexposures". Withoat the details contained in the body of the inspection report, the Notice of Violation implies that two individuals were in fact " overexposed".
Your inspector examined a memo in which members of the plant health physics organization reviewed the exposure of the two individuals in question. As noted in your inspection report, these individuals had exceeded the plant administrative limit of 2000 mrem per calendar quarter; however, their reported exposures did not exceed the NRC limits given in 10CFR20.101. The reported exposures of 2576 mrem and 2725 mrem were incorrect. As noted in your inspection report, these two individuals had made steam generator entries wearing both head and chest TLD badges.
Clerical personnel incorrectly added the head and chest TLD results together. Under the requirements of 10CFR20.101(3)(b), exposure of the head is to be considered dose to the whole body.
Therefore, only the badge with the highest exposure reading should have been recorded as whole body exposure in the individual's exposure files (i.e. the head badge cg the chest bad e)-
C Section 4.11 of the Radiation Protection Manual requires a " Personnel Exposure Investigation" in the eve at of a suspected or known exposure "in excess of the permissible limits as specified in section two" (2) of the Radiation Protection Manual.
Section two of the manual covers-both maximum permissible exposure limits (Section 2.3) and plant administrative exposure limits (Section 2.9).
Section 2.9 (Plant Administrative Control Limits) c, the manual states:
U.S. Nuclear Regulatory Commission January 23, 1979 Attn: Office of Inspection & Enforcement Page 7 "administrauive control limits are established to prevent inadvertent technical overexposures, and to serve as a ' checkpoint' for obtaining necessary approval in the event work projested in radiation areas indicates additional exposure may be necessary."
Section 2.3 (Maximum Permissible Exposure-Regulatory Limits) of the manual states the following:
"This section prescribes the maximum permissible exposure to external and internal radiation as set forth in the NRC re gulations.... "
It should be clear from this that no investigation under Section 4.11 of the manual was required as no permissible limits were exceeded, contrary to what is implied in the Notice of Violatian.
The overexposure investigation committee process has and will continue to be applied to personnel exposures in excess of NRC regulatory limits (10CFR20). This Committee will be reserved for this purpose and will not be diluted in effectiveness and importance by the interpretation given in the inspection report. Under that interpretation arithmetic errors would have to be investigated by a committee before they could be corrected!
Since no permissible exposure lhaits were exceeded, Item E should be withdrawn as an item of noncompliance.
Additional Item Noted in Letter of December 28, 1978:
"Our inspector also verified the steps you had taken to correct the Item of Noncompliance brought to your attention in a letter dated March 1, 1978. The steps you took to correct this matter have not been adequately implemented. This matter will be reviewed in a subsequent inspection."
Reply:
The above paragraph indicates that corrective action taken in response to inspection number 50-309/78-06 was inadequate. According to your letter of April 11, 1978, your inspector was to examine our corrective action during a subsequent inspection.
During the moct recent inspection, we were not informed our correct action was being reviewed and that it was found to be unacceptable or inadequate.
As a result of your letter of March 1, 1978, a chain and padlock were installed on the CRDS Temporary Storage Bunker in question.
The chain and padlock were installed shortly af ter your March 1,1978 letter was received and have remained in place since then. We s-ill maintain this bunker does not meet the definition of an area accessible to personnel and, therefore, request that the item of noncompliance be withdrawr.,
U.S. Nuclear Regulatory Commission January 23, 1979 Attn:
Office of Inspection & Enforcement Page 8 Regarding the unlocked Aerated Drain Tank Cubicle, it was determined that the automatic door closing mechanism had failed.
As noted in our March 22, 1978 letter, repairs were effected within two hours of this item being brought to our attention.
Your March 1,1978 letter also noted there was no High Radiation Area sign on the personnel hatch in the Underground Storage Bunker. The bunker had been posted but snow removal operations had removed the signs. Permanent signs were installed and, in addition, a sign has been installed inside the bunker at the top of the ladder.
Additional administrative actions were implemented as described in our March 22, 1978 letter to assure compliance with Technical Specifications. These corrective actions were not reported to have been reviewed during the September-October 1978 inspection and any inadequacies concerning our corrective actions were not identified during or following the inspection.
Summary Comments:
The management of Maine Yankee Atomic Power Company acknowledges the seriousness of Item C l.
However, we maintain the event represents an isolated incident and is not indicative of routine practice at Maine Yankee. We believe the action taken by management with respect to this incident demonstrates that management will not condone violations of procedures.
Similarly, Item A represents a serious problem in the area of Auxiliary Operator training. We have taken corrective action that is already being implemented.
However, we must note with concern that we have found it necessary to take issue with Items B, D, E and certain statements made in your December 28, 1978 letter. During our meeting on October 27, 1978, Mr.
Heider and I expressed our concern that the significance of items of noncompliance was being diluted because of the increasing number of citations for minor or insignificant occurrences.
Certain items in the present inspection report, in our opinion, are not even items of noncompliance.
We have taken issue with Item D because it is redundant with respect to Item C.l.
When procedures are written so that they are consistent with NRC regulations, logic dictates that a failure to follow procedures will result in violations of NRC regulations.
With respect to Item B, we applied the same 18 inch criterion to determine whole body exposure that was applied by inspectors in the past. We were told this criterion no longer applied.
U.S. Ndelear' Regulatory Commission January 23, 1979 Attn: Office of Inspection & Enforcement Page 9 In Item E, we are cited for " overexposing" two indi8iduals and failing to investigate. The citation is the result of an arbitrary and incorrect interpretation on the part of the inspector.
We note that as required by 10CFR:1.ll, the three pages of citations have been posted for all plant personnel to read. As the Notice of Violation fails to present all the facts, we are certain that very few plant personnel (as well as members of the general public reading the citation alone) will determine that, in fact, no "overexposures" have occurred.
In conclusion, Maine Yankee Atomic Power Company submits that it:
1.
did not expose the individuals referenced in Item E in excess of any NRC exposure limit and, therefore, no investigation was regt. ired; 2.
did not allow a high radiation area in the area of the Degas Filter to exist in violation of Technical Specification 5.12.2; 3.
did not allow to exist for over ten months, items of noncompliance involving high radiation areas brought to the Company's attention in an NRC letter on March 1, 1978 or that the corrective action, taken in response to this letter, was inadequately implemented.
Should additional information be required, please feel free to contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPAIN D. E. Vandenburgh Vice President mrt
,