ML19345H180

Responds to NRC 810120 Ltr & 0304 Telcon Re Violations Noted in IE Insp Rept 50-201/80-06.Corrective Actions:Memo Notice Issued on 810206,reinstructing Personnel Re Importance of Complete Documentation on Special Work Permits

ML19345H180
Person / Time
Site:	West Valley Demonstration Project
Issue date:	02/11/1981
From:	Duckworth J NUCLEAR FUEL SERVICES, INC.
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19345H179	List: ML19345H180
References
1-81-017, 1-81-17, NUDOCS 8105010175
Download: ML19345H180 (3)

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V Nuclear Fuel Services, Inc. P.O. Box 124

• West Valley, New York 14171 A Subsidiary of Getty Oil Company (716) 942-3235 February 11, 1981 1-81-017 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch US fluclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Smith:

This will acknowledge and respond to your letter of January 20, 1981 (receivedJanuary 22,1981) regarding Inspection No. 50-201/80-06 conducted by Mr. P. Clemons on October 15-17, 1980, of License flo.

CSF-1 activities. Your inspection indicated one infraction and one deficiency which are discussed in the enclosure to this letter.

We believe the corrective action specified in the enclosure will prevent recurrence.

Very truly yours,

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{ L(m $ vl J. P. Duckworth General Manager JPD:RTS: Bon Enc.

cc: U.S. fluclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 8105010/7 5

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. Enclosure - J. P. Duckworth to tiuticar Regulatory Commission, Region 1, February 11, 1981 NFS RESPONSE TO USNRC REGION I LETTER TO NFS JANUARY 20, 1981 INSPECTION NO. 50-201/80-06

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NRC ITEM A. Technical Specifi. cation 7.1.4 states, " Detailed written procedures, run sheets, letters of authorization and extended work procedures shall be provided for operation of the plant. In addition, procedures for handling abnormal operating conditions and for radiation protection shall be provided." Item 3.4 of Section 3, Special Work Permit (SWP),

of the Health and Safety Manual, developed pursuant to the above states, "All entries into Zone 4 areas or high radiation areas require a Special Work Permit (SWP)...

The department requiring a SWP initiates the paper work by filling out the " Description of Work" in detail. Health and Safety will then evaluate radiation, contamination and airborne activity conditions and specify the protective clothing requirements, radiation conditions and special instructions required for the job. Before the entry is made, Health and Safety and Operations supervision or Analytical supervision must approve the SWP."

Contrary to the above, on September 2,1980, an entry was made by operating personnel into a high radiation area in the Fuel Receiving and Storage Area, and neither Operations supervision nor Analytical supervision had signed the Special Work Permit to indicate approval.

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NFS RESPONSE i

The Operations supervisor and Health and Safety personnel have been reinstructed regarding the Special Work Permits (SWP) and the importance of complete documentation on the SWP. This has been accomplished by a memo notice on this matter being given to these individuals. We believe that this action will serve to avoid recurrence of this item of noncompliance. The memo notice was issued on February 6,1981.

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Inspection No.

50-201/80-06 .

NRC 2 TEM B. 10 CFR 20.101(a), " Radiation dose standards for individuals in restricted areas," requires licensees to maintain total occupational dose to employees within specified limits.

10 CFR 20.201(b), " Surveys," requires that such surveys be conducted as may be necessary to comply with the regulations contained in 10 CFR 20.

10 CFR 20,401(b), " Records of surveys, radiation monitoring and disposal" states "Each licensee shall maintain records in the same units used in this part showing the results of surveys required by 20.201(b)..."

Contrary to the above, on or about October 8,1980, radiation surveys were performed near Cell No. 5 in the Analytical Aisle and the records of the survey results were not maintained.

NFS RESPONSE The task of window shielding fluid removal and replacement was supported by continuous Health and Safety monitoring to maintain exposures as low as reasonably achievable. After fluid replacement and return to normal ambient area conditions, the documentation on the special monitoring support was not completed.

The corrective step taken has been a Health and Safety Department review of the practice of continuous monitoring support and followup documentation.

The Health and Safety Department review was held February 3,1981 and is summarized in a memo dated February 5,198?,

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