ML19343B084
| ML19343B084 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 11/17/1976 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19343B085 | List: |
| References | |
| WYR-76-115, NUDOCS 8012040109 | |
| Download: ML19343B084 (3) | |
Text
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United States Nuclear Regulatory Commission
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Attention: Office of Nuclear Reactor Regulation "n
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Reference:
(a)
L! cense No. DPR-3 (Docket No. 50-29)
[Q (b)
Yankee Atomic Electric Company letter (WYR 76-83) to NRC (Proposed Change No.140), dated 8/17/76.
Dear Sir:
Pursuant to Section 50.59 of the Commission's Rules and Regulations and referring to Reference (b), Yankee Atomic Electric Company hereby proposes the following modifications to the reference license.
PROPCSED CEANGE:
Section 6.13 of the Technical Specifications pertaining to entries into high radiation areas states in part that "any individual or grcup of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates the radiation dose rate in the area".
In Reference (b), we proposed to amend the specification to also allow the use of dose integrating devices with an alarm and/cr direct observation cf ongoing work by health physics qualified personnel in lieu of the current specification.
We are directing this supplement to two items. The first is item 6.13.1.a.3 cf Reference (b).
We propose to modify this option and distinguish its application according to whethe2. dose rates are greater or less than i
1000 mrem /hr. The second item we are addressing in this supplement is the requirerent to issue Radiation Work Permits (RWP's) in connection with high radiatien area entries. We propose to exempt Chemistry and Health Physics Department personnel and Shift Auxiliary operators (AO's) from the RWP l
issuance requirement during the performance of their assigned duties.
l REASCNS FOR CHANGE: We would like to explain our reasoning and intentions l
with regard to item 6.13.1.a.3, i.e.,
the use of health physics qualified individuals to perform periodic surveillance of a job at the frequency l
specified in the RWP.
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This eption would principally be exercised only during major plant shutdowns. At these times, the large numbers of jobs going on in high radiation areas make it impractical to give every individual or group of individuals survey instru=ents or alarm devices.
The R*G system dictates that the Plant Health Physicist or his designated alternate (e.g., the Health Physics Shif t Supervisor) determines what exposure monitcring and control techniques are appropriate for all jobs, including so no4m /ot g
United States Nuclear _ _agulatory Commission
._/ ember 17, 1976 Attn: Office of Nuclear Reactor Regulation Page Two those to be performed in high radia ion areas. The decision reached is based on the dose rates in the area, the potential for a change in these dose rates and the status of each individual assigned to the job.
For one job, he might specify (on the RWP) periodic surveillance by health physics personnel only. For another, he may requires the use of a dose rate or alarm integrating device.
In both cases, personnel exposures are reviewed and evaluated by the health physics staff.
In areas or on jobs where the dose rates exceed or have the potential to exceed 1000 mrem /hr, the option of providing continuous health physics coverage might be exercised by the Plant Health Physicist. Examples of such areas or jobs are steam generatcr water box entries, containment entries at power and lif ting and movement of reactor vessel internals. For these areas or jobs, we believe that the Plant Health Physicist should have the l
option of foregoing the issuance of meters or integrating devices directly to the workers and placing the responsibilitl of exposure evaluation and control directly on his staff, who would always utilize appropriate radiation monitoring devices.
By our proposal regarding greater than 1000 mrem /hr areas (ss e item 6.13.1.b of the Enclosure), surveillance would be continuous.
Our proposal to exempt Chemistry and Health Physics Department personnel and Shift Auxiliary Operators (AO's) from the RWP issuance requirement is derived from the fundamental objectives and use of the RWP system.
The basic intent of the RWP system is to give the plant health physics l
(HP) personnel a mechanism by which specific rules regarding exposure, contamination control and worker conduct on a job can be imposed.
There is no apparent decrease in perscnnel safety resulting from HP personnel not utilizing a RWP when carrying out their own duties. Their training, experience and the resultant judgement in radiation protection is used as their means of exposure control.
The HP Departme7t personnel are qualified and entrusted to evaluate radiological conditions for specific activities and set the radiological protection requirements for the protection of other individuals who are not qualified to perform these evaluations or determine protection requirements for themselves. When required by RWP, HP personnel are assigned to continuously observe work activities and make on-the-spot judgements as to radiation protection requirements during periods of changing radiological conditions. This is precisely the purpose of the RWP system.
It seems to us to be totally incon-i sistent to hold, that HP Department personnel must be RWP controlled, i.e.,
they are not qualified to protect themselves, but at the same time, they are qualified to protect others.
As for the practical matter of issuing an RWP for entry by EP personnel into an area within which radiological conditions may be unknown or speculative - their entry being made for the express purpose of defining radiological conditions within the area - we feel this is a misuse of the
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RWP.
An RWP issued for such entries could not contain the information that it is required to contain by procedure, i.e., radiological conditions and radiological protection requirements.
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. '. United States Nuclear-ugulatory Commission h.vember 17, 1976 Attn Office of Nuclear Reactor Regulation Page Three
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The same arguments apply to Shift AO's who must enter high radiation areas during their shif t, either routinely or under special circumstances to investigate the operation of equipment. These individuals are qualified to provide their own health physics coverage.
Both HP Department personnel and shift AO's, if exempted from the RWP requirement, would still have to comply with all the other requirements of the specification and plant procedures.
Finally, we are extremely concerned that without this exemption, the RWP system will be subject to abuse and disrespect.
If an RWP must be issued simply to satisfy the words of the specification, plant personnel may come to regard the RWP as only another piece of paper and not as the device it was designed to be - an administrative control used to protect people.
SAFETY CONSIDERATIONS: As stated in Reference (b), we believe that the proposed change to Technical Specification 6.13 offers a more effective approach to high radiation area exposure control and as such, will result in better control of exposure than currently provided for by the present specification.
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Our proposed exemption of Chemistry and Health Physics personnel and Auxiliary Operators from the RWP issuance requirement of the referenced specification will not result in reduced protection for these individuals.
These proposed changes have been reviewed by the Nuclear Safety Audit and Review Committee.
SCHEDULE OF CHANGE: Implementation will commence with the Commission's acceptance of these proposed changes.
Very truly yours, i
YANKEE ATOMIC ELECTRIC COMPANY Y
L. H. Heider l
Assistant Vice President l
COMMONWEALTH OF MASSACHUSETTS)
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COUNY OF WORCESTER
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Then personally appeared before me, L.'H. Heider, who, being duly sworn, did state that he is an Assistant Vice President of Yankee Atomic Electric l,
Company, that he is duly authorired to execute and file the foregoing request in the name and on behalf of Yankee Atomic Electric Company, and that the statements therein are true to the best of his knowledge and belief.
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- Q Armand R. Soucy Notary Public My Commission Expires September 9, 1977 r
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