ML20155E017
| ML20155E017 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 03/04/1988 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20155E014 | List: |
| References | |
| GDW-88-52, MN-88-24, NUDOCS 8806150482 | |
| Download: ML20155E017 (9) | |
Text
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MaineYankee
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RELIABLE ELECTRICITY FOR MAINE SINCE 1972 EDISON DRIVE. AUGUSTA, MAINE 04330.(207) 623 3521 March 4, 1988 MN-88-24 GDH-88-52 Region I United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 l
Attention: Mr. Hilliam T. Russell, Regional Administrator
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to HYAPCo dated February 1, 1988
Subject:
Response to Notice of Violation - Inspection Report 50-309/87-28 Gentlemen:
In Reference (b), Maine Yankee was notified that the posting of a radiologically controlled area was not in conformance with 10 CFR 20.203(e).
This letter provides our response to that Notice of Violation.
For completeness, we have restated the violation with our response following.
NOTICE OF VIOLATION As a result of the inspection conducted on December 1-4, 1987, and in accordance with the Enforcement Policy (10 CFR 2, Appendix C), the following violation was identified:
10 CFR 20.203(e) requires in part, that each area or room in which licensed material is used or stored and which contains any radioactive material in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part, shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION RADI0 ACTIVE HATERIALS Contrary to the above, as of December 4, 1987, the Tool Storage Area, an area located on the 36' elevation of the PAB, which contained licensed radioactive material in excess of 10 times the amount specified in Appendix C of 10 CFR 20, was not posted with a sign bearing the words "Caution Radioactive Materials."
8806150482 880607 PDR ADOCK 05000309 O
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MaineYankee United States Nuclear Regulatory Commission Page Two Attention: Mr. Hilliam T. Russell MN-88-24 MAINE YANKEE RESPONSE The tool storage area in question is along the interior of the north wall of the 2nd level of the Primary Auxiliary Building (PAB).
The PAB is inside the site radiological control area.
The tool storage area was segregated from the 2nd level floor area by a rope barricade, which was posted to show the area inside (the tool storage area) was considered contaminated, required a radiation work permit for entry, and required full protective clothing (pc's) for entry.
Entry into this area was via a single step off pad.
Inside this tool storage area contaminated tools and equipment and barrels containing contaminated clothing and equipment were stored.
He believe that the tool storage area was conspicuously posted as required by 10 CFR 20.203(e) with signs bearing the words "Caution Radioactive Materials".
Practically every item within the tool storage area had a "Radioactive Material" sign affixed to it which could be clearly seen from the barricade.
From practically any vantage point outside the barricade, several Radioactive Material warning signs were conspicuously visible within the l
area.
From the step off pad, approximately a half dozen such signs were literally within arms reach.
The types of signs used are shown in Exhibit A attached.
Exhibit B provides photos showing two views of the area in question from outside the l
rope barricade.
He believe these postings, which also serve as labels, meet
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the requirements of 10 CFR 20.203(e).
It is our understanding that the requirements in 10 CFR 20.203 are intended to ensure that the worker is provided with clear and concise l
information as to the radiation hazard in his work place.
Further NRC l
guidance on this issue was provided in IE Information Notice No. 84-82, l
Guidance for Postins Radiation Areas which discusses the application of 10 CFR l
20.203.
The Information Notice clearly indicates that the intent of this regulstion is to provide sufficient information to the worker to allow him to l
protect himself from a radiation hazard.
It further states that the circumstances of each situation must be evaluated to ensure that posting practices do not detract from this intent by desensitizing personnel through overposting.
He believe that the posting of the Tool Storage Area provided the proper amount of information to help personnel avoid the hazard. However, we have hung a sign reading "Caution Radioactive Materials" on the rope barricade in i
response to the inspector's concerns.
1 9659L-GDH l
MaineYankee United States Nuclear Regulatory Commission Page Three Attention: Mr. Hilliam T. Russell HN-88-24 This information duplicates that provided on the containers within the area and thus it would appear to constitute "overposting".
He believe that this additional posting may decrease the workers' sensitivity to radiation hazards information, and that it is not necessary to meet the requirements of 10 CFR 20.203(e).
For these reascas ve are requesting reconsideration of this apparent violation. As stated during the exit interview and subsequent phone conversations, we believe that a meeting with you would be beneficial in resolving this matter.
Very truly yours, MAINE YANKEE A$W G. D. Whittier, Manager Nuclear Engineering and Licensing GDH/bjp Attachments cc: Mr. Richard H. Hessman Mr. Pat Sears Mr. Cornelius F. Holden l
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MaineYankee EXHIBIT A Radioactive Material Postings Used Hithin The Tool Storage Area I
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CAUTION RADIOACTIVE MATERIAL DATE SICMATURE i
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MaineYankee EXHIBIT B Photographs Of The Tool Storage Area i
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