ML20042C456
| ML20042C456 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/25/1982 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20042C451 | List: |
| References | |
| 820315, FYR-82-33, NUDOCS 8203310414 | |
| Download: ML20042C456 (6) | |
Text
,
. Y NKEE ATO 10 ELECTRIC C0 PANY
" *^*"* ' ' - * '
- e 2.C.2.1 ral FYR 82-33 yf 1671 Worcester Road, Framirqham, Massachusetts 01701
,Yauxes_
x,,ch 15, 1982
~
United States Nuclear Regulatory Commission Of fice of Inspection and Enf orcement Region I l
631 Park Avenue l
King of Prussia, PA 19406 f
Attention:
Mr. Ronald C. Ilaynes, Regional Administrator Re f e re nce s :
(a)
License No. DPR-3 (Docket No. 50-29)
(b)
USNRC Letter to YAEC, dated January 8,1982 l
(c)
YAEC Letter to USNRC, dated September 8,1981, Proposed Change No. 175
Subject:
Health Physics Appraisal Audit (Inspection 50-29/81-01)
Dear Sir:
This letter responds to information required in Reference (b) pursuant to 10 CFR 50.54 (f).
We are pleased that your Inspection 50-29/81-01 resulted in no items of noncompliance being identified.
Further, we are carefully reviewing the detailed findings of your report for consideration in af fecting improvements to our health physics program.
Attachment "A" contains our responses to your Appendix A, "Significant Appraisal Findings," of Reference (b).
~
We trust our response to each of the specific findings contained in Attachment " A" is sa t isfac tory.
If you have any questions, please contact us.
Very truly yours, YANKEF ATOMIC iLECTRIC COMPANY uis H. leider Vice President Attachment COM:10NWEALTil 0F !!ASSACIIUSETTS)
)ss MIDDLESEX COUNTY
)
Then personally appeared before me, Louis H. Heider, who, being duly sworn, did state that he is a Vice President of Yankee Atomic Electric Company, c he is duly authorized to execute and file the foregoing request in the name ar.o on the behalf of Yankee Atomic Electric Company and that the statements therein are true to the best of his knowledge and belief.
i Robert H. Groce' Notary Public My Commission Expires September 14, 1984 8203310414 820325 PDR ADOCK 05000029 G
YANKEE ATOMIC ELECTRIC COMPANY ATTACIIMENT "A" RESPONSE TO SIGNIFICANT APPRAISAL FINDINGS A'.'
Organization, Responsibilities and Staffing and Management Oversight.
1.
Finding Establishment of a clearly defined station radiation
- protection organization which includes each major position / function in the Radiation Protection Department.
(Section 1.2.1)
Response
Reference (c) redefined the reporting lines of the Radiation Protection Organization.
Each major position / function of the Radiation Protection Organization is defined in our Job Description Manual.
This manual will be reviewed and revised as necessary to clearly define the Radiation Protection Organization.
Completion of this action is expected by September 30, 1982.
2.
Finding:
Establishment of clear assignment of duties, authorities, and responsibilities 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 review and formalization of assignments. (Section-1.3.1)
Response
Although the duties, authorities, responsibilities and functional descriptions are well known to the personnel in the Radiation Protection Department, a review and formalization of assignments will be performed.
Completion of action on this item is expected by September 30. 1982.
B.
Personnel Selection, Qualification and Training 1.
Finding:
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)
Page 1
Respones:
Selection criteria' has been. documented for all positions within the - Radiation Protection Organization by job descriptions and will be used in the hiring of station and when possible contractor personnel.
To the extent possible, the selection criteria will be applied to the promotion process.
2.
Finding:
Qualification criteria should be documented for all positions.
Qualification criteria should be considered 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)
Response
This finding is similar to finding number 1 above.
A training and upgradinL program will be instituted to ensure that a person will meet the qualification criteria,
]
as necessary.
Documents AP-9000, AP-8001 and AP-0226 will be reviewed for consistency of definitions.
This review will be completed by September 30, 1982.
3.
Finding:
e The training program should be reviewed, revised as necessary, and formalized to conform to the requirements -
of Regulatory Guide 1.8 and ANSI N18-1971.
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)
Response
The training program will be reviewed, revised as necessary and formalized to conform as applicable to the requirements of ~ Regulatory Guide 1.8 and ANSI N18.1-1971. Retraining will be scheduled for all technical level personnel.
The training program will.be reviewed, revised and-implemented by December 31, 1982.
.Page 2
C.
Exposure Controls:
-1.
Finding:
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)
RESPONSE
The annual primary calibration methodology has been expanded to include a. range of activities for each nuclide as recommended by ANSI N343.
Completion of this finding was accomplished on August 14, 1981.
2.
Finding:
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) 1
Response
It has been our experience that non-gamma emitting
- nuclides, e.g.,
H-3, Sr-90 and alpha emitters have not been a problem.
However, we will augment our existing bioassay program, this-is based on airborne monitoring to include excreta analysis.
After sufficient data has been gathered, and if this data upholds our belief that airborne monitoring is sufficient, than the excreta analysis program may be terminated at that time.
The bioassay program will be implemented by September 30, 1982.
3.
Finding:
Procedure AP-8015 should reference the 40 MPC-hr.
control measure contained in 10 CFR 20.103(b)(2) as a 4
point at which certain evaluations and corrective actions are required. (Section 3.2.4)
Response
Procedure AP-8015 will, be updated - to reflect the 40 MPC-hr control. measure per CFR 20.103(b)(2). - This action will be completed by September 30, 1982.
4.
FINDING:
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) i
. Page 3
4
Response
The individual assigned responsibility for the respiratory protection program has been qualified to Regulatory Guide 8.15 and NUREG-0041.
This action was completed on March 29, 1981 and again on January 15, 1982 -when personnel changes occurred.
5.
Finding:
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)
Response
A review will be conducted to determine where alarm systems could best be employed in areas where the potential for significant variation in the _ airborne radioactivity levels _ exist. As a result of this review alarm systems will be installed as necessary.
This review is expected to be completed by September.
1 The training and qualification of respiratory equipment
_ training personnel will be upgraded to comply with Regulatory Guide 8.15 and - NUREG-0041.
Respiratory protective equipment fittings. will-be performed by a qualified person.
Complete implementation is expected by September 30, 1982.
7.
Finding:
Emergency.- use training - for respiratory protective equipment should be included in the overall training program. (Section 3.2.4.2)
Response
i Emergency use training ' for self-contained breathing apparatus (SCB A) ~ is not considered necessary ' for inclusion in the ' overall plant : training. program. LFire brigade and emergency response teams get training in
~
the _ use of SCBA equipment.. The general respiratory 4
- protection training shall be ' reviewed to insure. that emergency-.use instructions. f or.-
non-SCB A -
types respiratory -protection equipment meets all requirements.
Complete implementation is expected by September 30, 4
' 1982.
-Page 4
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8 8.
Finding:
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 86.1-1973,
" Commodity Specification for Air".
(Section 3.2.4.2)-
Response
This concern is currently being implemented.
Full implementation is expected by September 30, 1982.
9.
Finding:
The air sampling program should be upgraded to include radioiodine. (Section 3.3.2)
Response
Yankee has always maintained a radiciodine sampling program for the protection of workers.
The scope and frequency of this sampling program was upgraded on February 6,1981, based on this appraisal.
10.
Finding:
The Frequency of surveys for alpha, beta and neutron radiation should be increased. (Section 3.3.3)
Response
Yankee has always maintained neutron and alpha detection capabilities.
In order to address the concerned raised by this appraisal we have~ procurred additional alpha and neutron detection units and have increased the frequency of surveys for alpha, beta and neutron radiation.
This action was completed on July 1, 1981.
c.
Page 5 e
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