ML20237H620
| ML20237H620 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 08/13/1987 |
| From: | Whittier G Maine Yankee |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 9032L-SDE, GDW-87-192, MN-87-91, NUDOCS 8708170293 | |
| Download: ML20237H620 (5) | |
Text
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MAIRE HARHEE ATOMIOPOWER00MPARUe avaus,,J,Te o"al2l h
(207) 623-3521 e
August 13, 1987 MN-87-91 GDH-87-192
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i United States Nuclear Regulatory Commission Attention: Document Control Desk Hashington, D. C.
20555 I
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo dated July 14, 1987 Notice of Violation (NRC Inspection Report 87-08)
(c) USNRC Letter to MYAPCo dated June 2, 1987 - Inspection Report No. 87-08
Subject:
Reply to a Notice of Violation l
Gentlemen:
This letter replies to the Notice of Violation transmitted via Reference j
(b).
These violations were based on inspections of our radiological controls i
program and documented in Reference (c).
/
Our responses follow each of the cited violations, which have been restated for completeness.
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The inspectors identified other areas of concern regarding our radiological controls program and housekeeping at the close of the 1987 refueling. He are pursuing corrective actions to address these concerns and
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would be pleased to discuss this with you at your convenience.
Very truly yours, MAINE YANKEE ATOMIC P0HER COMPANY kh AV i
G. D. Whittier, Manager Nuclear Engineering and Licensing GDH/bjp Enclosure cc: Mr. Victor Nerses Mr. Hilliam T. Russell Mr. Pat Sears Mr. Cornelius F. Holden h
j 8708170293 870013
/
8 PDR ADOCK 05000309 9032L-SDE G
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MAINE YANKEE ATOMIC POWER COMPANY l
ATTACHMENT A-MAINE YANKEE RESPONSE TO NOTICE OF VIOLATION VIOLATION A Technical Specification 5.11 requires that procedures for personnel lf radiation protection be prepared and adhered to for all operations involving personnel radiation exposure.
Radiation Protection Procedure 9.1.10, Radiation' Hork Permits, requires, in part, in Section 7.4, that the method of high radiation area control utilized and the surveillance frequency of checking work in such high radiation area be indicated on the rad Stion work permit.
Contrary to the above, Radiation Hork Permit Nos. 87-4-231, 87-4-232, and 87-4-281, used for entries.into high radiation areas on April 30, 1987,
.did not indicate the method of high radiation area control or the surveillance frequency of. checking the work performed in those creas.
MAINE YANKEE RESPONSE TO VIOLATION A a.
Reason for the Violation:
This violation resulted from insufficient procedural guidance on the development of RHPs.
In trying to write general radiation work permits (RHPs) to allow access to the Containment Building for l
inspection activities - sometimes involving more than one job, non-specific High Radiation Area controls (such as " consistent with job being inspected") were specified.
Since the RHP procedure did not explicitly prohibit writing such RHPs, the Radiological Controls personnel assumed it was an acceptable practice.
'b.
Corrective Steos Taken and Results Achieved:
All RHPs written for such inspection activities were reviewed and immediately corrected, by specifying on the RHP ' survey meter required' or 'techr.ician job coverage', when this issue was identified by the inspector.
Radiological Controls personnel were instructed not to write RHPs with non-specific High Radiation Area (HRA) controls.
I c.
Corrective Steos that will be Taken to Avoid Further Violations:
1.
The RHP procedure will be revised to explicitly require the identification of specific methods of High Radiation Area controls on the RHPs.
The circumstances surrounding this violation and the associated corrective actions will be reviewed by all Radiological Controls personnel.
These actions will be completed by September 1, 1987.
d.
Date when Full Comoliance will be Achieved:
Full compliance was achieved on April 30, 1987.
9032L-SDE
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MAINE YANKEE ATOMIC POWER COMPANY i i
VIOLATION B l
Technical Specification 5.12.1 requires, in part, that each high radiation area in which the intensity of radiation is at such levels that a major
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portion of the body could receive in any one hour a dose in excess of 100 mrem be barricaded and conspicuously posted as a high radiation area.
Contrary to the above, at approximately 12:00 p.m. on April 27, 1987, a high radiation. area existed on the -2' elevation of the containment near the Reactor Head ' Stand, and the barricade and postings for this high radiation area were inside the 100 mR/hr boundary and thus were not serving as a warning to any one approaching the area. As a result, an individual in the area could have received a dose to the major portion of the body of 120 mrem in an hour.
MAINE YANKEE RESPONSE TO VIOLATION B a.
Reason for the Violation:
This violation appears to have been caused by the relocation of hoses which, when moved, pushed the barricade toward the radiation source.
Surveys taken prior to the inspector's measurements showed that the High Radiation Area was properly barricaded (and posted), complying I
with the requirements of 10CFR20 and Technical Specification 5.12.1.
i b.
Corrective Steos Taken and Results Achieved:
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The barricade was-immediately adjusted to establish a boundary of less than 100 mrem / hour. Other High Radiation Area barricades were also promptly surveyed and all were in compliance with the requirements of Technical Specification 5.12.1.
c.
Corrective Steos that will be Taken to Avoid Further Violations:
2.
New barricades, which have spring-mounted uprights that spring back to the original position if contacted by workers or equipment, are being fabricated and placed into service.
The barricade stanchions have heavy base plates. The location of the base plate will be marked to denote any movement.
Procedure j
9.1.6 " Establishing and Posting Controlled Areas" will be revised to require that survey maps of HRAs indicate barricades and the dose rates at the barricades. These actions will be fully implemented by September 1, 1987.
d.
Date when Full Comoliance will be Achieved:
Full compliance was achievd on April 27, 1987.
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1 MAINE YANKEE AYOMIC POWER COMPANY l
3-VIOLATION C
'10 CFR 20.203(c)(iii) requires that each entrance or access point to a high radiation area be maintained locked with positive access control over each individual entry.
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Contrary to the above, on May 10, 1987, access to the Haste Storage Area l
adjacent to the Radiation Control Area (RCA). Storage Building was not j
maintained under positive access control.
Specifically, scaffolding and a l
ladder were located adjacent to a wall of this area which would allow an individual to reach the top of the wall and gain access to the inside where radiation dose rates were as high as 2000 mrem /hr.
MAINE YANKEE RESPONSE TO VIOLATION C a.
Reason for the Violation:
A scaffolding, which had been used during the inspection of the reactor coolant pump rotating assembly, was inadvertently placed near the 15 foot high radwaste storage area wall.
Since a ladder at another location is the normal method of access to the area, the scaffolding was not recognized as a meant of access when it was placed against the wall.
b.
Corrective Steos Taken and Results Achieved:
The scaffolding was immediately moved away from the wall to prevent unauthorized access-to the high radiation area as soon as this matter was brought to our attention by the inspector.
c.
Corrective Steos that will be Taken to Avoid Further Violations:
The wall has been posted to prohibit objects, which could be used for access, being placed against the wall. Heekly supervisory inspection tours of the area have shown no further instances of unauthorized means of access being placed against the wall.
i d.
Date when Full _Comoliance will be Achieved.
i Full compliance was achieved by July 31, 1987.
9032L-SDE
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MQlNE YANKEE ATOMIC POWER COMPANY. VIOLATION D 10 CFR 19.12 requires, in part, that all individuals working in or-frequenting any portion of a restricted area be kept informed of the storage of radioactive material and precautions to minimize exposure.
Contrary to the above, at approximately 11:00 p.m. on May 8, 1987, certain workers were standing in a restricted area next to a 55-gallon drum which had contact dose rates of 1200 mrem /hr, and these workers were not informed that radioactive material was stored in the 55 gallon drum, nor were they provided precautions to minimize their exposure to the radiation emanating from the material in this drum.
MAINE YANKEE RESPONSE TO VIOLATION D a.
Reason for the Violation:
The workers were not informed of the radiation source because the
' technician failed to check the work area as required by the RHP.
b.
Corrective Steos Taken and Results Achieved:
The drum was moved away from the workers and barricaded and posted as a High Radiation Area when the inspector brought the matter to our attention. As soon as the crane was available, the drum was removed from the refueling cavity. No other high radiation drums were introduced into the work area during the reactor head installation.
c.
Corrective Steos that will be Taken to Avoid Further Violations:
i Specific, written instructions for providing RWP job coverage were provided to all technicians in the Containment Building.
The instructions included requirements for checking workers' dosimeters, verifying area dose rates, and keeping radioactive material containers properly labeled.
Supervisor inspections conducted during the outage verified that the technicians were complying with these instructions.
4.
In addition, procedure 9.1.6 will be revised by September 1, 1987 to require proper labeling of all radioactive material containers.
5.
In order to address a concern raised during the Enforcement Conference, the removal of reactor head stud hole plugs will be reviewed by the ALARA Committee.
This will be completed prior to the next refueling outage.
d.
Date when Full Como11ance will_hg_ Achieved 1 Full compliance was achieved by May 9, 1987.
9032L-SDE