ML19339A927
| ML19339A927 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 04/25/1975 |
| From: | French J YANKEE ATOMIC ELECTRIC CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19339A924 | List: |
| References | |
| NUDOCS 8011050708 | |
| Download: ML19339A927 (3) | |
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- ;g T6I4 phon 2 617 366-90lt Tw1 780-390 0739 YAlllWE ATCGIC ELECTRIC COMPAliY urR,5-48
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20 Turnpiko Road Westborough, Massachusetts 01581 wn
, ANLtGE, April 25, 1975
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United States Nuclear Regulatory Ccmmission Region I Office of Inspection and Enforcement 1
631 Park Avenue King of Prussic, Pennsylvania 19406 Attention:
James P. O'Reilly, Director Referenec:
(a) License "o. DPR-3 (Cocket No. 50-29)
(b) DRO Inspection Report No. 50-29/75-02 (c) Proposed Change 112, January 3, 1974
Dear Sir:
This letter is written in response to your letter dated April 1, 1975, in which you stated.that certain of our activities appear to bo in violation of AEC requircrents. These items were reported as the result of a routihe unannounced inspection of the IIealth Physics operations at Yankee Atomic Electric Corpany at Rowe, Massachusetts.
Inforuatien is submitted as follows in ansver to the alleged violations contain?d in the enclosure to your letter:
A.
Contrary to Technical Specification D.1:
1.
Proceduro OP8106 and OP8415 were not followed in the following instances:
(a)
RWP 1G52 and 1659- (1974) authorized workers to receive 600 mr/ week without specific, written authorization of the plant health physics repre-sentative to excoed the administrative lir.it of 300 mr/ week.
I (b)
RWP 448 (1974) required the use of a breathing zone air sampler but none was used.
(c)
RWP's 448, 498, 493 and 585 (1974) had'the required II.P. signature rendcred by a teeporary contractor health physics technician who was not a member of the health physigs, department nor was ho formally designated by procedure or written i
authorization to sign RWP's.
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- United St'atas Nuclear R;gulatory Commission April 25, 1975 Attn ' James P._O'Reilly, Director Pags Two (d)
FWP's 585, 620 and 634 (1974) did not require continuous health physics coverage, continuous air Lamples, or breathing zone air samplers as required by procedure for sork on ecolant loop No. 1.
Furthermore, RWP 585 (1974) had been altered as to working conditions and work location by soneone other than the health physics representative.
(e)
RWP's 459, 466 and 501 (1974, for work in ti.e waste storage building did not require a continuous air sample or a breathing zone air sampler as required by procedure, i
2.
Procedure OP8302 for relcase of radioactive material from the controlled area was not follcwed when environmental renitoring devices scre remcved frcm.the plant for some peried in October,1974. One device was contaminated with sufficient radicactive material to give a film badge reading of 1900 mrc= in 3 wecks.
B.
Contrary to 10 CFR 20.201(b) :
1.
The licensee failed to make such surveys as were necessary to assure coepliance with 10 'CFR 20.101 (a) in that he did not conduct a survey 'f the fan room sufficient to detect o
the presence of radioactive materials found in various locatiens during the inspection, with readings up to 40 mren/hr at 18 inches, and to permit posting and labeling required by 10 CFR 20.203.
This matter.was identified and brought to the attention of the appropriate persons by the inspector on three consecutivo dates.
2.
The licensee failed to make such surveys as were necessary to assure compliance with 10 CFR 20.103 when workers were permited to work under RWP's 18, 20, 23, 32, 45 and 47 (1975) inside of primary ' systems components without any evaluation as to concentrations of airborne radioactive material.
Although they differ considerably in detail, Yankee believes that cach of the foregoing infractions occurred as a result of a lack of training of the individuals involved. The training required to correct these problems must cover two major areas:
- 1) contents of procedures, and-2) their practical implementation. To this end, AP 9000, " Training of Chemistry and.Fealth Physics Department Personnel", is :urrently in the review process. When issued, this procedure will specifically ont-line the training required for overy individual who must operate within the guidelines of the plant procedures.
In addition, tighter supervisory controls over Radiation Work Fermits and radiation surveys have been-instituted by 1) allowing only J. Flanagan,_ Plant H.P., I. Seybold, Health Physics Engineering
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' United States Nuclear Regulatory Commission April-25, 1975 i,
l Attn James P. O'Reilly, Director Page Three
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Assistant, and B. Ecuker, Chemist to sign an RWP, 2) requiring the Plant Health Physicist and B. Bouker to review all radiation surveys daily, and 3) requiring the Plant H.P. to review all Radiation Work i
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Permits weekly.
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C.
Contrary to Technical Specification D.2.g(3) the effluent j
monitor for the incinerator stack has been removed and placed in another location.
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The e# fluent monitor referenced in Technical Specification D.2.g(3) is required to be in continuous service in order to provide an alarm and a record in the event of the release of radicactive gas from the waste j
disposal blanket gas system through the loop seal. Greator sensitivity i
of this menitor.was achieved by moving it to its present location immedi-I ately downstream of the loop seal, where it sr.ac the full concentration of waste gas rather than a diluted saeple in the incinerator stack.
1 Monitoring of incinorator stack effluents is presently achieved 1
through implementation of CP 2283, " Burning of Solid Combustible l
Wastes", which requires that incincrator stack effluents he campled l
continuously and analyzed hourly when burning. Further, upon complction of Engineering Design Change Request 74-3, expected corpletion date:
November 1975, the incinerator stack will to made to discharge through l
j the Plant Vent Stack, where a sophisticated stack monitoring system will continuously monitor all effluents. EDCR 74-3 implementation will bring the incineration evolutien into compliance with the. provisions of the Yankee Rowe Technical Specifications as specified in Proposed Change 112, dated January 3, 1974.
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We Acknowledge the concern expresced in your cover letter to the Inspection Ropert relative to the management control system for radiation
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protcction at Yankee Rowe. We fcol that the corrective action as described previously in this letter will augment the existing control system.
In additien, we are currently in the process of evaluating the most effective manner by which the management control system can bc strengtheacd. This process involver a management analycis of the current j
staffing and relationships between the plant and the 3calth Physics Group at Westboro. Upen conclusion of this analysis, necessary corrective action will be implemented.~
I We trust that ycu will find this response satisf;: tory; however, I
if you desire additional information, feel free to contact us.
t Very truly yours, YANKEE ATCMIC ELECT 14C COMPANY i
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h Mvwco J. L. French
Manager of Opera'tiens I
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