ML19263B545

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Responds to NRC Ltr of 781030 Re Violations Noted in IE Insp Rept 50-333/78-21.Corrective Actions:Operators Who Were Trash Compacting Instructed Re Requirements & Dosimeters; High Radiation Area Gate Locked
ML19263B545
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 11/20/1978
From: Leonard J
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19263B540 List:
References
NUDOCS 7901180372
Download: ML19263B545 (3)


Text

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POWER AUTHORITY OF THE STATE OF NEW YORK JAMES A. Fir 2 PATRICK NUCLEAR POWER PLANT S

JOHN o. LEONARD, JR.

P.o. Box 41 Resident Mrnager Lycoming, New York 13093 315 342 3840 Novcinber 20, 1978 JAFP-78-621 Mr. Boyce H. Grier, Director United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Reference:

Docket #50-333 IE Inspection #78-21

Dear Mr. Grier:

With reference to the inspection conducted by Mr. K. Plumlee of your office cn September 25-28, 1978, at the James A. Fit: Patrick Nuclear Power Plant, and in accordance with the provisions of Section 2.20; of Part II of Title 10 of the Code of Federal Regulations we are submitting our reply to Items A 6 B of Appendix A of the Notice of Violation trans-mitted by your letter dated October 30, 1978 as received by the under-signed on November 2, 1978.

APPENDIX A Notice of Violation Based on the results of an NRC inspection conducted on September 25-23, 1978, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC License No. DPR-59 as indicated below.

Items A and B are infractions.

A.

A requirement of Technical Specifications Section 6.11, " Radiation Protection Program," is that procedures for radiation protection shall be cdhered to for all plant operations.

1.

Contrary to the above on September 27, 1978, radioactive waste measured at up to 10 mr/hr on contact was compacted without adhering to the special instructions of the radiation work permit RWP controlling this operation, that radiation protection be contacted to provide airborne monitoring as required during operation of the compactor.

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Page 2 Nosember 20, 1978 JAFP-78-621 2.

Contrary to the above at 10:35 a.m. on September 27, 1978, an individual was working in a restricted area of the plant without adhering to the requirement of the Radiation Pro-tection Procedures,Section II.C, to wear his assigned personnel dosimeters in restricted areas.

Response to Item A 1.

The Operations Superintendent was promptly notified of the non-conformance with regard to the RWP in effect at the job site for trash compacting. The operators who were compacting trash were reminded of the requirements and were instructed to comply with them.

To ensure that other operators were cogni: ant of the RWP requirements for trash compacting a notice was placed in the plant " night orders" for each shift to read.

Subsequent sampling during trash compacting indicated airborne concentrations of approximately seven (7) percent of the maximum permissible concentration (MTC).

2.

We believe that this is an isolated incident and that our training program adenuatelv trains personnel at the niant of their resconsibilites for wearing dosimetry device.

As noted in the inspection report the individual involved had been instructed at the time to always wear his dosimetry devices when in the restricted areas of the plant, but took his shirt off in the work area and inadvertently left the dosimetry devices attached to his shirt.

Plant personnel have been instructed through existing training programs that should they see a person without dosimetry that they tell the person to leave the restricted area and report to the Radiation Protection Office.

We believe we are now in full compliance concerning these two items.

B.

A requirement of Technical Specifications Section 6.11(A)2 is that locked doors shall be provided to prevent unauthorized entry into areas in which the intensity of radiation is greater than 1,000 mrem /hr.

Contrary to the above on September 25, 1978, about 11:20 p.m.,

an unattended high radiation area gate at an entrance to the drywell, an area in which the intensity of radiation is greater than 1,000 mren/hr, was not maintained locked.

Page 3 November 20, 1978 JAFP-78-621 Response to Item B Although the gate indeed was not locked because it had jammed in the shut position and only appeared to be locked, we believe that this item is not a violation of Technical Specifications (TS)

Section 6.11(A)2 because of the following:

TS Section 6.11(A)2 applies to high radiation areas where the radiation dose rate is greater than 1,000 mrem hr. We have made a thorough search of our records and can find no evidence that there were areas in the drywell where a person could have received a whole body radiation exposure of greater than 1,000 mren in one hour during the time of the inspection under the shutdown condition then existing.

Although there were local " hot spots" where contact readings on a survey meter may indicate greater than 1,000 mrem /hr in each case the dose rate to "a major portion of the body" (per 10CFR20.202) was less than 1,000 mrem /hr.

This has been verified by interviews with radiation protection technicians assigned to perform surveys in the drywell at the time of the inspection.

We respectively request that the status of this item be reviewed by your staff in view of the above.

Very truly yours,

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G. T. Berry P. W. Lyons R. Rajaram G. Wilverding E. Kelly J. Davis J. Leonard R. Pasternak H. Fish R. Burns S. Wells DCC File

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