ML19281B015
| ML19281B015 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/22/1979 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Groce R Maine Yankee |
| Shared Package | |
| ML19281B016 | List: |
| References | |
| NUDOCS 7904200149 | |
| Download: ML19281B015 (3) | |
See also: IR 05000309/1978018
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Docket No. 50-309
Maine Yankee Atcmic Power Company
ATTN: Mr. Robert H. Groce
Licensing Engineer
20 Turnpike Road
Westborough, Massachusetts 01581
Gentlemen:
Subject:
Inspeccion 50-309/78-18
This refers to your letter dated January 23, 1979, in response to our
letter dated December 28, 1978.
Thank you for infonning us of the corrective and preventive actions
documented in your letter. These actions will be examined during a
subsequent inspection of your licensed program.
We have reviewed che information you presented regarding Items B, D and
E and a previously identif ad item involving high radiation area control.
Our comments on these items follow:
1.
Item B: The facts presented in the inspection report and acknow-
ledged in your response clearly indicate a major portion of the
body could have been exposed to an intensity of radiation in excess
of 100 mr/hr in the unbarricaded area near degas filter FL33A.
In
addition, measurements made by our inspector and confirmed by your
representative indicate that a major portion of the body including
the gonads could have been exposed to a radiation intensity of
greater than 1000 mr/hr when in close proximity to this readily
accessible filter.
Application of the guidance referred to in your response as the "18
inen criterion" is limited to those situations where the gonads or
lens of the eyes could not receive a dose of more than 100 mr in
one hour.
There has been no change in the Office of Inspection and Enforce-
ment guidance on this matter.
79042001 %
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Maine Yankee Atomic Power Company 2
2.
Item D: We agree that had the individual adhered to Procedure 1-
12-4, adequate surveys would have been performed.
Since, the
individual did not adhere to the procedure, he assumed responsibility
imposed on licensee management to make or cause to be made surveys
as necessary for the protection of his health and safety and compli-
ance with regulatory requirements.
This responsibility is not
contingent upon the issuance of a Radiation Work Permit.
We do not
view the requirements of Technical Specifications and 10 CFR 20.201
to be redundant.
This item of noncompliance will not be withdrawn.
3.
Item E:
This apparenc item of noncompliance was issued for failure
to adhere to a procedure as required by your Technical Specifications.
Exposure received in excess of any pennissible limit established by
Section 2 of your Radiation Protection Manual is, in our opinion,
worthy of investigation in accordance with Section 4.11 of your
manual and is consistent with good radiation safety practices.
Based on the additional information provided in your response, we
understand the phrase " permissible limits" to apply only to Section
2.3, " Maximum Permissible Exposure (Regulatory Limits)."
This apparent item of noncompliance is withdrawn.
4.
Additional Item:
Paragraph 2 of Inspection Report 50-309/78-18
acknowledged that your corrective action for the three instances of
noncompliance was adequate.
The same paragraph states that the
generic administrative actions to prevent recurrence of this type
of noncompliance were not adequately implemented in that an additional
item of noncompliance (Item B) was identified during the inspection.
The point we are making is that while the corrective action for the
specific items was adequate, the action to prevent recurrence of
similar items does not appear to have been effective.
If you have further comments or questions on these matters we would be
pleased to discuss them with you.
Sincerely,
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Boyce H. Grier
Director
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Maine Yankee Atomic Power
Company
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cc:
E. Wood, Plant Superintendent
E. W. Thurlow. President