ML20245H832
| ML20245H832 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/21/1989 |
| From: | Whittier G Maine Yankee |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20245H824 | List: |
| References | |
| 1037L-RCC, GDW-88-54, MN-88-19, NUDOCS 8905030546 | |
| Download: ML20245H832 (3) | |
Text
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RELIABLE ELECTRICITY FOR MAINE SINCE 1972 EDISON DRIVE. AUGUSTA, MAINE 04330. (207) 622-4868 February 21,1989 MN-88-19 GDH-88-54 Region I United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Attention: Mr. Hilliam T. Russell, Regional Administrator 1
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo dated January 20, 1989 - Inspection Report No. 50-309/88-80
Subject:
Response to Notice of Violation - Inspection Report 50-309/88-80 Gentlemen:
This letter responds to the Notice of Violation contained in Reference (b).
For completeness, we have restated the violation with our response following.
Notice of Violation Technical Specification 5.11 requires that procedures for personnel radiation protection be prepared and adhered to for all operations involving personnel radiation exposure.
a.
Maine Yankee Radiation Protection Manual, dated May 13, 1988 requires in section 4.1 that all individuals who enter the Plant Radiation Control Area (RCA) are to have personnel monitoring devices in their possession.
Contrary to the above, at about 2:22 P.M. on November 11, 1988, an individual entered and worked in the Fuel Storage Building, part of the RCA, without the required dosimetry.
The individual worked in radiation fields up to 5 mr/hr.
b.
Radiation Protection Procedure No. 9.1~1, revision 15, requires in section 6.2.7 that at least one smear from each survey which has greater than 5,000 dpm beta-gamma be counted for alpha.
Contrary to the above, on November 6, 1988 and for an undetermined period of time prior to that date, numerous smear surveys indicating j
greater than 5,000 dpm beta-gamma were identified and smears from the l
surveys were not counted for alpha.
8905030546 890426 PDR ADOCK 05000309 Q
PDC 1037L-RCC
".'".?
i MaineYankee a
United States Nuclear Regulatory Commission Page Two Attention: Mr. Hilliam T. Russell MN-89-19 c.
Radiation Protection Procedure No. 9.1.10,. revision 22, requires in section 5.7-1 that workers understand and comply with their Radiation Work Permit (RHP) exactly as written.
1.
RHP No. 505 requires in part that workers tape the cuffs of their protective clothing.
Contrary to the above, at about 3:00 P.M. on November 5, 1988 four individuals, working under RHP N-505 in the Pressurizer Cubicle, did not have the cuffs of their protective clothing taped.
2.
RHP No. 927 requires workers to wear two pairs of coveralls and a disposable tyvek suit when working on the No. 1 Steam Generator platform.
Contrary to the above, at about 5:00 P.M. November 2, 1988 a worker entered and worked on the platform without the second pair of coveralls.
Maine Yankee Resoonse a.
A contracted Rad Controls technician forgot to pick up the required dos';netry. The individual was disciplined for this error.
There wers no further observed incidents of personnel entering the RCA withat dosimetry.
b.
Procedtre 9.1.1 was revised prior to the outage to require counting smears, with more than 5,000 dpm, for alpha.
This was done in response to the need for early detection of alpha contamination.
This requirement was easy to fulfill during normal plant operation when there are relatively few surveys performed.
During the outage it became apparent that the procedure was overly restrictive.
A review of survey data revealed that there was no problem with alpha contamination.
The overly restrictive procedure (9.1.1) was revised 12/14/88 to reflect current practices for counting smears for alpha activity.
Rad Controls personnel were reminded of the need to follow proceduras as written or to initiate a procedure change to change them to agree with current methods. There were no further known instances of radiation protection practices being in conflict with this procedure.
c.
Failure to wear the proper clothing as required by the RHP was caused by workers not complying with RHP requirements and by technicians failing to ensure compliance with all RHP requirements at the start of work.
1037L-RCC
L,,N MaineYankee United States Nuclear Regulatory Commission Page Three Attention:
Mr. Hilliam T. Russell MN-89-19' The workers who were identified to not be in compliance with RHP clothing requirements immediately complied when directed to do so.
RWP noncompliance was discussed at Rad Controls shift turnover meetings. A reminder was issued to all Rad Controls personnel stressing the need to perform thorough pre-job briefings and to strictly enforce all RHP requirements at the job site.
In addition, Rad Controls supervisors were required to tour the RCA to observe work in progress and to check for RHP compliance.
In order to improve worker performance (including procedure and RHP compliance), Maine Yankee has implemented a Job Observation Program. This program requires close observation of work by a Rad Controls supervisor and a technician.
Immediate feedback is given to workers on performance relative to radiation protection policies and procedures. Written feedback on the observation goes to the appropriate department manager. A quarterly review of Job Observation findings is compiled and forwarded to department managers along with recommendations to improve overall performance. Over 130 such observations were conducted during the refueling outage. He plan to continue this program to enhance worker performance in the area of radiation protection.
Maine Yankee will also review lesson plans for outage training and revise them as necessary in order to stress radiation protection procedure and RHP compliance. These revisions will be completed prior to the next refueling outage.
Full Compliance:
Full compliance was achieved when revised procedure 9.1.1 was issued, December 14, 1988.
Should you have any questions on this matter, please contact me.
Very truly yours, MAINE YANKEE Off9'llVf i
G. D. Whittier, Manager i
Nuclear Engineering and Licensing GDH:BJP c: Mr. Richard H. Hessman Mr. Patrick M.
Ser s Mr. Cornelius F. Hoiden 1037L-RCC