ML20040B295
| ML20040B295 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/08/1982 |
| From: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Jay J YANKEE ATOMIC ELECTRIC CO. |
| Shared Package | |
| ML20040B296 | List: |
| References | |
| NUDOCS 8201250363 | |
| Download: ML20040B295 (5) | |
See also: IR 05000029/1981001
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0 8 JAN 1982
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Docket No. 50-29
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Yankee Atomic Electric Company
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ATTN:
Mr. James A. Kay
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Senior Engineer Licensing
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Gentlemen:
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Subject:
Health Physics Appraisal
The NRC identified a need for licensees to strengthen the health physics
program at nuclear power plants and had undertaken a significant effort to
assure that action was taken in this regard. As a first step in this effort,
the Office of Inspection and Enforcement conducted special team appraisals of
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the health physics programs, including the health physics aspects of radio-
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active waste management and onsite emergency preparedness, at all operating
power reactor sites.
The objective of these appraisals was to evaluate the
overall adequacy and effectiveness of the total health physics program at each
site and to identify areas of weakness that need to be strengthened. We will
use the findings from these appraisals as a basis not only for requesting
individual licensee action to correct deficiencies and effect improvements but
also for effecting improvements in NRC requirements and guidance. This effort
was identified to you in a letter dated January 22, 1980, from Mr. Victor
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Stello, Jr. , then Director, NRC Of fice of Inspection and Enforcement.
During the period of January 5 to 16,1981, the NRC conducted the special
appraisal of the health physics program at the Yankee Rowe Nuclear Power
Si.ation.
Areas examined during this appraisal are described in the enclosed
report 50-29/81-01. Within these areas, the appraisal team reviewed selected
procedures and representative records, observed work practices, and interviewed
personnel.
It is requested that you carefully review the findings of this
report for consideration in ef fecting improvements to your health physics
program.
The findings of the appraisal at Yankee Rowe indicate that although your
overall health physics program is adequate for present operations, several
significant weaknesses exist.
These include the following:
(1) A cloarly defined radiation protection organization was not established.
(2) Selection criteria had either not been documented or implemented for all
positions within the radiation protection organization.
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(3) An adequate respiratory protection program was not established.
(4) An adequate airborne radioiodine sampling program was not established.
These findings are discussed in more detail in Appendix A, "Significant Appraisal
Findings." We recognize that an explicit regulatory requirement pertaining to
each significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for the
health and safety of workers and the public, you are requested to submit a
written statement within sixty (60) days of your receipt of this letter,
describing your corrective action for each significant weakness identified in
Appendix A including:
(1) steps which have been taken; (2) steps which will
be taken; and (3) a schedule for completion of action.
This request is made
pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
You should be aware that the next step in the NRC effort to strengthen health
phys cs programs at nuclear power plants will be the imposition of a requirement
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that each licensee develop and implement a Radiation Protection Plan.
Each
licensee will be expected to include in the Radiation Protection Plan sufficient
measures to provide lasting corrective action for significant weaknesses
identified during the special appraisal of the current health physics program.
Guidance for the development of this plan has been developed in draft form and
was published as NUREG-0761, " Radiation Protection Plans for Nuclear Power
Reactor Licensees."
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter and the enclosures will be placed in the NRC's Public Document
Room.
If this report contains any information that you (or your contractors)
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you (a) notify this of fice by telephone within ten (10) days from the
.
date of this letter of your intention to file a request for withholding; and
(b) submit within 25 days from the date of this letter a written application
to this office to withhold such information.
Consistent with section 2.790(b)(1),
any such application must be accompanied by an affidavit executed by the owner
of the information which identifies the document or part sought to be withheld,
and which contains a full statement of the reasons on the basis which it is
claimed that the information should be withheld from public disclosure.
This
section further requires the statement to address with specificity the consider-
ations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld
shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted
above, the report will be placed in the Public Document Room. The telephone
notification of your intent to request withholding, or any request for an
extension of the 10 day period which you believe necessary, should be made to
the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.
The responses directed by this letter are not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980, PL 96-511.
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Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
Original 31Cnod Ey
Ronald C. Haynes
Regional Administrator
Enclosures:
1.
Appendix A, Significant Appraisal Findings
2.
Office of Inspection and Enforcement Report No. 50-29/81-01
cc w/encis:
H. Autio, Plant Superintendent
J. E. Tribble, President
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Massachusetts (2)
bcc w/encis:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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APPENDIX A
SIGNIFICANT APPRAISAL FINDINGS
Yankee Atomic Electric Company
Docket No. 50-29
Based on the results of the NRC Health Physics Appraisal conducted January 5 -
16, 1981, it appears that several significant weaknesses exist in your health
physics program as indicated below.
Details regarding these weaknesses are
found in the referenced sections of the appraisal report.
A.
Organization, Responsibilities, and Staffing and Management Oversight
1.
Establishment of a clearly defined station radiation protection
organization which includes each major position / function in the
Radiation Protection Department.
(Section 1.2.1)
2.
Establishment of clear assignment of duties, authorities and responsi-
bilities and specific functional position descriptions. The scope
of responsibilities and the division of duties within the ALARA,
respiratory protection, and health physics technical training programs
would benefit from a thorough reivew and formalization of assignments.
(Section 1.3.1)
B.
Personnel Selection, Qualification and Training
1.
Selection criteria should be documented for all positions within the
organization.
Selection criteria should reflect job descriptions
and should be used in the hiring of station as well as contractor
personnel. To the extent possible, selection criteria should be
applied to the promotion process.
(Section 2.2)
2.
Qualification criteria should be documented for all positions.
Qualification criteria should be considedered in the hiring process
to acquire the highest level of trained personnel.
In the cases
where the personnel hired may not meet the qualification criteria, a
training and upgrading program should be instituted to ensure that
the person is fully qualified within a specified period of time.
Documents AP 9000, AP 8001, and AP 0226 should be reviewed for
consistency of definitions of both pay title levels and functional
levels within the organization.
(Section 2.3)
3.
The training program should be reviewed, revised as necessary, and
formalized to conform to the requirements of Regulatory Guide 1.8
and ANSI N18.1-1971.
The program should include the frequency,
scope, content, objectives, performance objectives, schedules and
lesson plans, and demonstrations by the students.
Retraining should
be scheduled for all technical level personnel.
(Section 2.4)
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Appendix A
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C.
Exposure Controls
1.
The annual primary calibration methodolgy used for the whole-body
counter needs to be expanded to include a range of activities for
each nuclide as recommended by ANSI N343.
(Section 3.2.3)
2.
The lack of a formal internal dosimetry program for non gamma emitting
nuclides, e.g. , H-3, Sr-90, and alpha emitters, should be justified.
(Section 3.2.2)
3.
Procedure AP-8015 should reference the 40 MPC-hr. control measure
contained in 10 CFR 20.103(b)(2) as a point at which certain evalua-
tions and correctiva actions are required.
(Section 3.2.4)
4.
The individual assigned responsibility for the respiratory protection
program should have the qualifications outlined in Regulatory Guide 8.15 and NUREG-0041.
(Section 3.2.4.2)
5.
Alarm systems for the indication of increasing airborne radioactivity
should be employed in areas where the potential for significant
variation in the airborne radioactivity levels exist.
The training
and qualifications of respiratory equipment training personnel
should be upgraded to comply with Regulatory guide 8.15 and NUREG-0041.
Respiratory protective equipment fitting should be performed by a
qualified person.
(Section 3.2.4.2)
7.
Emergency use training for respiratory protective equipment should
be included in the overall training program.
(Section 3.2.4.2)
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8.
The maintenance program, including the inspection, testing and
repair of the respiratory protective equipment, should be reviewed
and revised as needed to comply with Regulatory Guide 8.15.
Tests
for contamination of breathing air should be conducted to assure
that it meets the requirements of American National Standards ANSI Z
86.1-1973, " Commodity Specification for Air."
(Section 3.2.4.2)
9.
The air sampling program should be upgraded to include radioiodine.
(Section 3.3.2)
10.
The frequency of surveys for alpha, beta, and neutron radiation
should be increased.
(Section 3.3.3)
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