ML20107B482
Text
_
4=== %
j
. :/
b.i& Light ' Company
~
-' Jersey Central Pow
- 7. -
M ADISoN AVENUE AT PUNCH BOWL Ro AD 9 MoRRISToWN, N.J. 07960 e 539 6111 51 arch 28,.1973 ltr. James P. ' O'Reilly, Director.
Directorate of Regulatory Operations, Region 1 United States Atomic Energy Commission 970 Broad Street.
Newark, New Jersey 07102-
Dear Str. O'Reilly:
This letter is in reply to your letter of >! arch 7,1973 to Bir.
R.' ti. ' Sims regarding the specia1' inspection conducted by 5tr. >! eyer and >!r. Cantrell on February 13 through 16, 1973.
In response to the concerns identified in your letter and in i
Enclosure No. 2 regarding actions taken or planned to improve the effectiveness of our management control system, we wish to advise you of.the-following activities:
Radiation Flanagement Corporation is reviewing ~our exis, ting radiological program and will make recommendations which will improve and strengthen it.
In conjunction with the above, they will also be undertaking a complete review and will rewrite, as necessary, our radiation protection procedures. Their services will then continue to be utill:ed to provide routine refresher training for radiation
~
protection personnel and also to audit our effectiveness in imple-j menting our program.
Since plant startup, additions have been made at the tech-l nician level in our health physics organization to ensure adequate J
personnel to conduct our radiological program.
Due to the additional 1
supervisory load this produced in addition to the growth in health physics data compilation and reporting requirements, it has become apparent that we may nave weakened our supervisory function. To
' correct this situation, we are making the following organi:ational changes:
A' Supervisor of Radiation Protection will be added to the.
-staff to report directly to the station superintendent.
tie will have overa11' responsibility for the ~ station's radiation protection program.
'To strengthen the direct supervision of the radiation technician group,
-a second. radiation protection supervisor, also reporting to the Super-
~ visor of Radiation Protection, will be added to the plant organization.
F Finally, a engineering aide is scheduled to be added to report to the Supervisor of Radiation Protection to enable the necessary data com-pilation and reporting requirements to be satisfied without detracting from our direct supervision efforts.
d 9604160362 960213 4
,lWg
.nl n
,n-.,.i--,-
m
---.L
e Mr. James P. O'Reilly March 28, 1973 Upon effecting the above plan, we are certain the deficiencies observed during your inspection will no longer exist.
It is difficult to state exactly when all these activities will be accomplished; there-fore, we would like to offer odt assurance that this area is receiving our most immediate attention.
Radiation Mar.cgement Corporation has already started their review.
Interviews are now.being conducted with potential candidates for the expanded radiation protection organization.
It is our intention to add the individuals to the plant staff as rapidly as possible. A Technical Specification chan.4 will be submitted to reflect this organi:ational adjustment.
In connection with Item No. 1 of the enclosure to your letter, as stated in our letter of March 27, 1973, controls will be established during those times when surveys indicate the requirements of 10CFR20.105(b) may be violated such as those which could occur during radwaste drum shipments.
This will insure full compliance being achieved on this item.
In addition, to prevent a reoccurrence of this type of violation, we intend to investigate the extension of the plant perimeter fencing to a greater distance from the facility than that which presently exists.
In response to Item No. 2, the source of the radiation referred to in this item has been removed to the radwaste storage area.
The requirement for personnel monitoring for individuals working within station restricted areas nas been reviewed with all station personnel.
The individual responsible for authori:ing such individuals to be in station restricted areas is also responsible for ensuring that they possess the required dosimetry.
Full compliance will thus be main-tained with the regulations.
In connection with Item No. 3 of the enclosure to your letter, the 55-gallon drum on the 23-foot elevation of the reactor building causing the radiation level noted was removed to the radwaste facility storage area.
Those individuals responsible for surveying and postings within restricted areas have been refmniliari:ed with 10CFR20 posting requirements.
Full compliance has been achieved on this item.
In connection with Item No. 4 a. b, and c of the enclosure to four letter, all areas noted are now properly posted.
The waste drums in the reactor building have eitner been removed t > the radwaste storage area or the areas surrounding them have been properly barricaded and posted. The locked door criteria remains as an open item.
A special survey has been conducted and a determination made as to those doors which will require locking under our present operating conditions.
Those doors which presently contain the appropriate hardware to facilitate locking have been locked. Doors which cannot be locked have been posted so as to require a shift foreman or the radiation protection supervisor's permission in order to gain entry.
Full compliance will be achieved as soon as proper locking devices can be procured and installed.
e
Mr. James P. O'Reilly March 28,1973 In connection with Item No. 5 a of the enclosure to your j
letter, all the drums noted in this paragraph have either been snipped off site or have been removed to a shielded storage area.
With regard to the areas noted in Item No. 5 b of the enclosure, these areas are now posted in accordance with requirements of 10CFR20.203(b). To prevent reoccurrence of the items noted under Item No. 5, all radioactive waste drums will be stored in appropriate areas in.,1de the facility.
In addition, a survey schedule is being developed to insure gener.a1 area surveys being performed at a frequency sufficient to maintain proper postings in all areas of the station.
Full compliance has been acnieved, i
In connection with Item No. 6 a of the enclosure to your letter, the drums of concern have been removed to the radwaste storage facility and the fiberglass tanks have been appropriately labeled.
Full compliance has been achieved.
To prevent a reoccurrence of violations of this nature, the posting and labeling requirements, as identified in 10CFR20, are being reviewed with those responsible for radiation protection at the site.
l In response to Item No. 7, the doors to the radwaste building are now conspicuously posted with " Caution-Radioactive Material" signs.
Full compliance has been achieved.
As noted above, posting requirements of 10CFR20 have been reviewed with radiation protection personnel at the site.
In connection with Item No. 8 of the enclosure to your 1ctter, a schedule providing general surveys of the various plant areas is being developed to ensure adequate routine surveys are accomplished. This will ensure future compliance in this area.
In addition, we are investigating the purchase of additional portable surveying equipment with recording ability to monitor areas that may be subject to frequent changes.
Data frou such survey equipment could be used to assist in developing edequate survey frequency.
In response to item No. 9, the drums noted have been shipped off site thus full compliance has been achieved.
To prevent a possible reoccurrence, our procedures will be modified to reflect current station e
requirements pertaining to storage of urummed radioactive waste.
Such changes will require all drum storage to be inside the facility but will recogni:e the need to store a large quantity of low level waste collected during a plant outage in appropriate areas of the turbine or reactor buildings.
Such areas will be properly identified and posted in accordance with the applicabic regulations.
In response to Item No. 10, both the FDSAR Section IX, Sub-section 3.1.1 and our letter dated December 12, 1972 intended to acknowledge that potentially radioactive waste would be collected.
'In recognition of our effort to maximi:e the use of our radwaste equipment to minimi:e releases, it is not our intention to process
' Mr. James P. O'Reilly March 28, 1973 water that does not normally contain any radioactivity such as rain water which is currently collected in this outside catch basin. We would intend to permit rain water to collect in this basin area and after sampling for radioactivity released without processing. However,
since the possibility of the catch basin overflowing exists, should the present drain arrangement freeze, we propose to extend the drain with a removable section of pipe in such a way that it will normally act as a plug permitting our sampling and release as outlined above.
This extension will be of such a height that before the basin could overflow, the water collected therein will flow over the pipe and into the 1-9 radwaste sump.
This solution we believe best serves all concerns in this matter.
This plan should be accomplished within the next thirty days.
The following are responses to questions raised in Enclosure No. 2 to your letter:
la.
Station radiation protection procedures, Section 901, states,
"It shall be the responsibility of all station supervisors to see that all radiological safety rules and procedures are followed, that work involving radiation is performed in a safe and approved manner within his area of responsibility..........".
The requirements of this procedure, in addition to standard health physics rules and work practices, will be emphasized during the retraining lectures.
Supervisory responsibilities in connection with radiation protec-tion will be stressed as required to insure compliance with the procedure.
Ib.
A program has been established wherein supervisory personnel will conduct inspections on a regular basis and convey their findings to the appropriate member of the staff who wil' then initiate corrective action if required.
Ic.
A. continuous radiclogical protection training program for plant personnel is currently in the process of being established through the use of monthly safety meetings.
Radiation protection fundmnentals and procedures will be emphasi:ed at these meetings.
The radiation technicians in the performance of their duties are responsible for implementation of radiation protection instructions and procedures.
These instructions and procedures are based on 10CFR20 with regard to practices, limits, and cor. duct of operation. The require-ments, as delineated in 10CFR20, will be stressed with the present radiation technicians in a review program and have been incorporated into the qualification program for any additional radiation technicians.
Id.
A standing order has been issued to the effect that routine i
inspections will be made each shift to detect leakage, open tank hatches, and overflows.
Any discrepancies will be reported to supervision who i
will take appropriate action.
An emergency procedure to cover the
R
\\
,i Mr. James P. O'Reilly March 28,1973
]
the deficiency cited is being developed.
Such leakage does not present any radiological hazards that have not been previously evaluated in our docket.
1 The drums in question have been removed to the radwaste le
. facility and all posting; reviewed for accuracy.
Extended radiation work permits are required to be reviewed and reissued on a monthly basis as per radiation protection procedures and this requirement will continue to be enforced.
If.
Radiation instruments are available to the shift foreman for use by his shift personnel and other personnel at the station during other than normal working hours. The waste drum capper is now operational; therefore, manual capping is not necessary.
If, in the future, it becomes necessary for manual capping to be per-formed, a survey will be made at required.
2a.
All waste drums referred to in this enclosure have been removed or properly barricaded and posted.
Complete surveys have been conducted to assure that waste drums are not located in an area which might contribute unknowingly to personnel exposure.
The floor of the large pump room in the radwaste building, although contaminated, is not the major source of the observed radia-tion levels.
A radwaste modification study is in progress witn one of its main goals being a reduction in personnel exposure.
In addition, plans are underway to contract cercain decontamination activities to outside organizations.
General housekeeping has been a continuing problem at the facility and, as mentioned, plans have been initiated to contract outside services in an effort to decontaminate and clean up the plant.
2b.
The program for removal of radioactive waste drums has been accelerated. Two firms are being used to expedite shipments and, in addition, another contract is being issued for the purpose of decontam-inating the drums that are backlogged in the radwaste facility. This effort will result in ec,iplete removal of the radwaste drum inventory.
4 1
Very truly yours,
L.., 'Ju ([(
g,.)
Donald A. Ross 3
Manager, Nuclear Generating Stations pk