ML19256A742
| ML19256A742 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/02/1978 |
| From: | Switzer D CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19256A739 | List: |
| References | |
| NUDOCS 7901100018 | |
| Download: ML19256A742 (3) | |
Text
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ONNEOTICUT YANKEE ATOMIC POWER COMPANY BERLIN. C O N N ECTIC U T P. o. som 27c H ARTFORD. CONNECTIC4T O.101 February 2, 1978 Docket No. 50-213 t o >...... n U. S. Nuclear Regulatory Commission Region 1 Office of Inspection and Enforcement 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Boyce 11. Grier, Director Gentlemen:
Subject:
Docket No. 50-213 Inspection Report 50-213/77-23 This letter contains a response to the Inspection Report of G. Yuhas, conducted November 1-3, 1977 and the attached Motice of Violations.
1.
Infraction Item A "10 CFR 20.101(a) ' Exposure of individuals to radiation in restricted areas' requires that no individual receive a dose in excess of seven and one half rem to the skin of the whole body in any period of one calendar quarter."
Contrary to this requirement, on October 22, 1977, an individual received a dose to an area of skin of the whole body indicated by thermoluminescent dosimeter evaluation to be at least 22.489 rem.
Response
Based on a detailed investigation of this event by the CYAPCo and NUSCO technical staff, it is determined that no overexposure situation exists.
The presentation of the facts and their evalua-tion are provided in Enclosure #1.
The areas of concern with the NRC Inspection Report are discussed in Enclosure #2.
i In sumary it is felt that all the facts gathered should be i
considered and the most credible explanation utilized to assess tne acs_cl exposure to the individual. _The NRC Inspection was conducted at the time when the investigation was at a preliminary stage.
It is felt that for this reason many of the facts were either not available, not considered or inisapplied.
The application of the most conservative scenario to assess the individual's exposure is not realistic.
There is no reason to assign an unnecessarily high exposure to an individual when more credible explanations of the facts are present.
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tp-The evaluation presented here was done more recently and indicates that the maximum exposure to the whole body was 2.710 rem and to the skin was 0.109 rem.
The TLD reading was high because of substantial
' contamination of the holder.
The activity had decayed prior to issuance to the individual. The individual did receive his whole body exposure by work activities on 10/22/77.
The QA program of the TLD vendor is being investigated.
Following completion of this investigation, suggestions for improvements will be made in an attempt to prevent an incident of this kind from re-occurring. The investigation will be completed by 4/1/78.
2.
Infraction Item B Technical Specification 6.13 requires that any individual or group of individuals permitted to enter High Radiation Areas in which the intensity of radiation is greater than 100 mrem /hr, must be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area.
Contrary to this requirement, on October 22, 1977, an individual entered the inner annulus lower level of the containment building without a radiation monitoring device which continuously indicates the dose rate.
Licensee surveys indicate dose rates up to 700 mrem /
hr in this area.
This item is recurrent in that findings of a similar nature were identified in Inspection Report 77-05.
l
Response
I During major outages, Health Physics personnel are assigned to all working levels of the containment.
The area in question had been j
adequately surveyed, postings were current and qualified Health Physics personnel were in constant attendance.
CYAPCo feels this meets the intent of Section 6.13.
l This particular Technical Specification has been recognized by the NRC and the industry as having practical problems particularly during shutdown when extensive maintenance work is performed.
For this j
reason a generic rewording of this specification, as suggested by NRC, was submitted by Connecticut Yankee Atomic Power Company in a i
letter dated 11/30/77 to USNRC, NRR, Washington, D.C.
j I
We believe this letter clarifies the unusual series of events associated with the TLD badge reading.
The technical staff of Northeast Utilities Service Company and Connecticut Yankee Atomic Power Company will be available for further discussions if necessary.
/,,,soyce H. Grier February 2, 1978
/
We are alsa in receipt of your letter dated January 20, 1978 to Mr. D. C.
7 Switzer, returning material previously sent to you on December 6,1977.
We do not believe that it is necessary to submit a report in accordance with 10 CFR 20.405, as explained by the material submitted herein support-ing our position.
We have conveyed this intent to Mr. Peter Knapp of your office on January 30, 1978.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY h~f~xw D. C. Switzer President
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