IR 05000219/1978023
| ML19262C319 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/21/1978 |
| From: | Crocker H, Nimitz R, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19262C313 | List: |
| References | |
| 50-219-78-23, NUDOCS 8002110242 | |
| Download: ML19262C319 (27) | |
Text
{{#Wiki_filter:' Enclosure 2 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-219/78-23 Docket No. 50-219 License No. DPR-16 Friority Category C -- Licensee: Jersey Central Power and Licht Comoany Madison Avenue at Punch Bowl Road Morristown, New Jersev 07960-acility Name: Oyster Creek Nuclear Generating Station Inspection at: Forked River, New Jersey Inspectier. conoucted: September 6-8, 18-19 and 26-29, 1978 Inspectors: [[ -%Ay ///.2. / 7.9 ?"_g#Rpst ion Specialist date signed D.
N'Eb .0 / .Whi e, Rd iation Specialist / ca',e signed , % -l I)l2 l78 R. L. Nimitz,4adiati n Specialist (Intern) cate signed Approved by: ///E//p[ H. W. Crocker, ActTiig Chief, Radiation '/ cate 4ignec Support Section Inspection Summary: Inspection on September 6-8.18-19, and 26-29,1978 (Recort No. 50-219/78-?3) Areas Inspected: Routine, unannounced inspection by regional based inspectors of tne radiation protection program during the refueling outage, including radiation protection procedures, advanced planning and preparation, exposure control, respiratory protection program, posting and control, radioactive and contaminated material control, instruments and equipment, surveys, and plant tours.
Upon arrival on September 6, 1978, at 7:00 p.m., and at other times during the inspection, areas where work was being conducted were examined to review radiological protection procedures and practices.
The inspection involved 141 inspector-hours on site by three regional based inspectors.
Results: Of the eight areas inspected, no items of noncompliance or deviations were found in one area; two apparent items of noncompliance were found in one area (infraction - failure to lock doors as required; infraction - failure to conduct searches as required - Paragrapr 10).
Three apparent items of noncompliance Region I Form 12 80 02110 ). y2 4 945 275 (Rev. April 77)
. . Inspection Summary
were found in another area (infraction - failure to post and barricade high radiation areas; deficiency - failure to post a radioactive materials area; deficiency - failure to label containers of radioactive material - Paragraph 6): Two apparent items of noncompliance were found in another area (infraction - failure to use respiratory protection equipment properly; infraction - failure to utilize engineering controls - Paragraph 5); One apparent item of noncompliance was found in each of the following areas (infraction - failure to perform air surveys of airburne radioactive material - Paragraph 7; infraction - failure to adhere to radiation protection procedures - Paragraph 4; One deviation was found in one area (ALARA concepts not implemented according to FSAR commitments - P;ragraph 8).
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. . DETAIL 1.
Persons Contacted D. Ross, Manager, Nuclear Generating Station J. Carroll, Jr., Station Superintendent J. Sullivan, Jr., Chief Engineer E. Scalsky, Radiation Protection Supervisor R. Dube, Supervisor Quality Assurance L. Smailek, Health Physicist J. Riggar, Site Security Supervisor J. Cook, Group Radiation Protection Supervisor D. Arbach, Group Radiation Protection Supervisor T. Rayment, Workers' Representative (10 CFR 19.14) R. Cardinali, Shop Steward N. Cole, Shift Supervisor, Operations B. Cooper, Shift Supervisor, Operations The inspector also interviewed other licensee employees including members of the health physics staff (station and contractor), reactor and auxiliary operators, maintenance personnel and security officers (station and contractor).
2.
Exit Interviews During the course of the inspection and at the conclusion of the inspection, exit interviews were conducted with licensee representa-tives.
The dates of the exit interviews and licensee reprer.enta-tives present are listed below.
September 8, 1978 -- J. Carroll, Jr.
J. Sullivan, Jr.
L. Smailek September 19, 1978 -- J. Sullivan, Jr.
E. Scalsky J. Riggar R. Dube L. Smailek 1945 277
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September 29, 1978 -- D. Ross J. Carroll, Jr.
J. Sullivan, Jr.
E. Scalsky L. Smailek 3.
Advance Planning and Preparations The licensee retained the services of at least 77 contractor health physics individuals (supervisors, technicians, control point monitors, record clerks, and various others) to supplement their permanent staff during the refueling outage.
Most of these individuals were brought in approximately one week in advance of the refueling outage.
The licensee trained these individuals in pertinent plant proce,tures and specific health physics procedures connected with their 1ssigned duties. The licensee interviewed those individuals who would be assigned responsible health physics positions against the qualifications listed in American National Standard Institute (ANSI) Standard N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel", Sections 4.5.2, Technicians and Section 4.3.2, Supervisors not Reoviring AEC Licenses.
The inspector reviewea the resumes' of several h91th physics technicians and supervisors brought in for the refueling outage against the same standard.
A licensee representative stated that procedures had been developed for the outage which covered the responsibilities and duties of the contractor health physics technicians assigned to specific areas of the plant.
A procedure was developed for each of the following areas: Drywell (23' elevation of Reactor Building) -- Refueling Floor (119' elevation of Reactor Building) -- Control Rod Drive Rebuild Area (75' elevation Reactor Building) -- Condenser Bay (Turbine Building) -- Turbine Building Operating Floor (Turbine Building) -- 1945 278
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A licensee representative stated that in those situations where work was performed by an individual who did not meet the qualifi-cation requirements specified in ANSI N18.1-1971, the supervisor assigned to that area would review the individual's work (radiation, contamination, and airborne surveys) and initial the documents to indicate that the work was reviewed.
The inspector reviewed the procedures and no items of noncompliance were identified.
4.
Radiation Protection Procedures The inspector reviewed the licensee's radiation protection proce-dures for consistency with the following: Technical Specification 6.8, " Procedures" -- Technical Specification 6.11, " Radiation Protection Program" -- -- 10 CFR 20, " Standards for Protection Against Radiation" -- ANSI N18.7-1972, " Administrative Controls for Nuclear Power Plants" -- Regulatory Guide 1.33-1972, Appendix A, " Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors" Technical Specification 6.11, " Radiation Protection Program", states that procedures for personnel radiatior. protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
a.
Procedure No. 902.4, Revision 2, " Access and Egress Control" dated May 21, 1976, developed pursuant to Technical Specifi-cation 6.11 states,1) that if a personnel monitor is provided at the Radiation Work Permit (RWP) area exit, it shall be used to check for gross personnel contamination; and 2) passage from the Radioactive fiaterials Area will be permitted only after an individual has removed any protective clothing and monitored himself to determine that the allowable limits of personnel contamination are not exceeded.
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(1) On the evening of September 6,1978, while waiting for their Radiation Work Permit to be processed, one of the inspectors observed an individual leaving the Radioactive Materials Area at the Monitoring and Change Room, without performing the required personnel monitoring.
The inspector noted that there were two portable geiger counters (friskers) and two Eberline portal monitors provided at the exit point from the main monitoring and change room.
The individual was observed not to have used any of the equipment provided prior to leaving the Radioactive Materials Area.
(2) On September 18, 1978, the inspectors, escorted by the facility Radiation Protection Manager (RPM), made an inspection of the Turbine Building Operating Floor (TB0F) to verify that exposure and contamination controls necessary as a result of turbine maintenance were adequately imple-mented.
The inspectors interviewed the contractor health physics supervisor who was assigned health physics responsi-bilities associated with the maintenance activities on the TB0F.
The inspectors discussed with the health physics supervisor the specific requirements that were to be followed when individuals exited the step-off-pad located at the contaminated boundary.
The inspector noted that a Radiation Work Permit (RWP) was required for work within this boundary. A review of the licensee's survey records indicated that removable contamination in excess of 2200 dpm/100 cm2 was present on equipment and floor surfaces in the area beyond the step-off-pad.
The inspectors observed that a manned control point had been established at a distance of approximately 12' away from the step-off-pad and that personnel were required to check in and out at this control point prior to entering and leaving the controlled area of the TB0F.
The health physics supervisor stated that all personnel exiting the RWP area were required to monitor themselves for personnel contamination with the portable geiger counter (frisker) located at the TB0F control point.
The inspectors observed that the frisker was located within twenty feet of the step-off-pad, in the vicinity of the control point change area.
Shortly after the discussion 1945 280
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with the health physics supervisor, one of the inspectors observed a Jersey Central Power and Light Company employee leave the RWP area at the step-off-pad, proceed to the control point to within five feet of the frisker, obtained his RWP and left the cont-ol point.
At a considerable distance from the control point the inspector informed the individual that he did not monitor himself for contami-nation.
The individual stated that he was aware of the requirement but had forgotten to frisk.
The individual returned to the control po' int and performed the necessary monitoring.
The RPM stated that the individual was probably accustomed to monitoring himself in the Monitoring and Change Room.
The RPM immediately instructed the health physics supervisor to require strict adherence to the frisking requirement upon leaving an RWP area.
(3) On September 28, 1978, while inspecting controlled areas of the Rad Waste Building, the inspector observed two Jersey Central Power and Light Company employees leaving the control point, located inside the Rad Waste Building, without monitoring themselves fcr cor.tamination.
The inspector observed that one individual had been, wearing a lab coat over his personal clothing during his entry into the contaminated areas of the Rad Waste Building and the other individual was wearing coveralls during his entry into the contaminated areas of the Rad Waste Building.
The inspector noted that a hand held frisker was located at the step-off-pad and the two individuals did not use the frisker after leaving the contaminated area (RWP area).
b.
Procedure No. 914.4, Revision 9, dated March 18, 1976, "Use of Protective Clothing and Equipment", states in Section 3.1 that only clothing with radiation levels less than 1 mR/hr above background be made available for use.
On September 7,1978, the inspector, in the presence of a licensee representative, removed and surveyed three psirs of coveralls from the issue bins in the Monitor and Change Rcom.
The survey showed that one pair of coveralls had radiatior, levels greater than 1 mr/hr above background.
The radiation level measured was 2 mr/hr above background.
The inspector 1945 281
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and the licensee representative took the pair of coveralls to the laundry room for resurvey with the laundry monitor.
The pair of coveralls when passed slowly under the laundry monitor caused the device to alarm.
The inspector noted that the licensee's corrective action to a previous item of noncompliance (Inspection Report 78-09) of tb. aame nature was to develop a procedure detailing the proper method of passing the laundry through the laundry monitor so as to maintain levels less than 1 mr/hr on the coveralls which are made available for use.
The licensee's corrective action to develop a procedure for the laundry monitor was to be achieved by September 1, 1978.
These findings represent noncompliance with Technical Speci-fication 6.11 (50-219/78-23-01).
This item is recurrent in that the same instances of noncompli-ance were found during inspection Nos. 77-13 and 78-09.
5.
Respiratory Protection The inspectors reviewed the licensee's respiratory protection program against the requirements of 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas".
10 CFR 20.103 requires in paragraph (c) that when respiratory pro-tective equipment is used to limit the inhalation of airborne radioactive material pursuant to paragraph (b)(2) of this section, the licensee may make allowance for such use in estimating exposures of individuals to such materials provided that such equipment is used as stipulated in Regulatory Guide 8.15, " Acceptable Program for Respiratory Protection."
Regulatory Guide 8.15, Table 1, " Protection Factors for Respirators" states in footnote (b) that the protection factors for respirators are, "Only for shaven faces and where nothing interferes with the seal of tight-fitting facepieces against the skin".
During a tour of the Rad Waste Building cn September 29, 1978, the inspectors observed that two maintenance mechanics and one health physics technician, were wearing their full face supplied air respirators in such a manner that their disposable hoods interfered 1945 282
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. with the seals of the tight-fitting facepieces against their skin.
The inspectors verified that the individuals had been working in the Drum Filling Aisle of the Rad Waste Building, attempting to dislodge dry caked radioactive powder which had blocked the open discharge chute of the centrifuge hopper.
The health physics technician stated to the inspector that three individuals from the maintenance department (one supervisor and two mechanics) were involved in this maintenance function.
He stated that two of the individuals were inside the Drum Filling Aisle trying to dislodge the blockage while the other stood outside the area to provide support for the operation.
He stated that the individuals were using a long round wooden stick (possibly a broom handle) approxi-mately six feet in length, to dislodge the dry powder up in the chute.
In order to insert the wooden stick into the chute the individuals had to locate themselves to the side but within arms distance of the open end of the chute.
The health physics technician stated that a 55 gallon drum was positioned under the open end of the chute.
The drum was one quarter full of dry powder which had fallen from the chute. Measurements, made by the licensee, on contact with this drum revealed a dose rate of 2000 mrem / hour.
The inspectors learned from interviewing a contractor health physics technician who was assigned to the Rad Waste Building that smears taken by the licensee in the Drum Filling Aisle nearby revealed loose contamination levels as high as 150 mrem / hour per 100 square centimeters.
The inspectors noted that the front edge of the disposable hoods worn by the three individuals came down to just above their eyebrows and that the sealing surfaces of the tight-fitting facepieces were placed against the disposable hoods.
The inspectors observed that this created interference with the seal of the tight-fitting facepiece against the skin.
The health physics technician stated that each of the individuals had received a leak check of their full face supplied air respirators at the Rad Waste Br:ilding change area.
For this check Isoamyl Acetate (banana oil) was used.
In addition, prior to entering the Drum Filling Aisle, the individuals performed a negative pressure leak check on their respiratory protection equipment.
He stated that results were satisfactory in all cases.
The inspectors noted that in addition to the requirements of 10 CFR 20.103(c) which endorses Regulatory Guide 8.15, Table I, health physics procedure 904.2, " Fitting and Removal of a Full Face Respirator," " Revision 8, dated May 22, 1978, states in paragraph 4.5, "There shall be no interferences between a headgear and the normal method of wearing a respirator."
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The inspector noted that the licensee routinely makes allowance for respiratory protection.
The operation on September 29, 1978, was an instance when such allowance was being taken according to licensee representatives.
The inspector identified the failure to wear the respiratory pro-tection equipment in accordance with 10 CFR 20.103(c), as an item of noncompliance (50-219/78-23-02).
The inspector noted that during an inspection conducted in May, 1978 (Inspection Report 78-09) a citation was made against 10 CFR 20.103(c) because the licensee made allowance for the use of respira-tory protection equipment and the equipment was not used as stipu-lated in Regulatory Guide 8.15, sections c.5 and c.8.b (use of a supplied-air suit not aporoved under 30 CFR Part 11 and not approved by the Commission).
The inspectors stated to licensee management that during a tour of the controlled areas on September 18 and 19, a similar situation was observed involving personnel not wearing their respiratory protection equipment in accordance with 10 CFR 20.103(c), Regulatory Guide 8.15, Table 1 and health physics prctedure 904.2.
They noted that two individuals, at the Drywell control point were preparing to enter the Drywell but had their disposable hoods located on their heads in such a way that the disposable hecds interfered with the seals of the tight-fitting facepieces against the skin.
It was observed that the contractor supplied health physics technicians assigned to the Drywell assisted these individuals in putting on their respiratory equipment.
Prior to entry, this matter was brought to the attention of a licensee representative who instructed the health physics technicians to properly fit the respiratory equipment on the individuals.
The inspectors learned from interviews that the individuals involved were going to enter the Drywell and remove " shoot out steel" from below the vessel where loose contami-nation levels as high as 314,000 disintegrations per minute per 100 square centimeters were present.
10 CFR 20.103 requires in paragraph (b)(1) that the licensee shall, as a precautionary procedure, use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radioactivity area as defined in 10 CFR 20.203(d)(1)(ii).
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. NUREG-0041 " Manual of Respiratory Protection Against Airborne Radioactive Materials," referenced in Regulatory Guide 8.15, states in section 2.1, "The primary objective of respirator programs considered in this manual is to limit the inhalation of airborne radioactive materials.
This objective is normally accomplished by the application of engineering controls, including process, contain-ment, and ventilation equipment.
When such controls are not feasible or cannot-be applied, the use of respiratory protective devices may be appropriate."
During the course of the inspection, the inspectors interviewed the health physics technician assigned to monitor radiological condi-tions in the Drum Filling Aisle of the Rad Waste Building on September 29, 1978, while maintenance personnel attempted to dislodge radio-active material blocking the open discharge chute of the centrifuge (details discussed above).
The inspectors asked the health physics technican whether or not an air sample had been taken during this maintenance operation and where was the air sampler located relative to the workers.
Tne health physics technician stated that an air sample was taken at a distance approximately ten to twelve feet away from the workers during the time they were trying to dislodge the dry powder in the open discharge of the chute.
The technician stated that he had placed the air sampler in that particular location due to the fact that he observed that the radioactive material from the discharge chute was flowing in that general direction.
The inspectors asked if he thought the air concentrations in the breathing zone of the workers would be greater as a result of this type of operation.
The individual stated that it was highly probable that the air sampled in the breathing zone of the workers would show a greater concentration of airborne radioactive material than that of an air sample taken twelve feet away.
The inspectors noted that the air sample taken in the Drum Filling Aisle during the dis-lodging operation was not representative of the airborne concentra-tions to which the workers were exposed.
A licensee representative later stated that the amount of particulate matter produced from the dislodging of the dry powder inside the discharge chute would be so great that if the air sampler was located in the breathing zone of the worker, the air filter would become plugged.
Based upon interviews with the individuals involved and an inspec-tion of the Drum Filling Aisle, (a short time after the individuals had left the Drum Filling Aisle), the inspectors determined that the licensee did not utilize any type of practical process or M45 285
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engineering controls (e.g., portable vent.lation systems and con-struction of local confinements or temporary enclosures) to limit the concentrations of radioactive materials in air produced as a result of this type of maintenance operations.
The above finding represents noncompliance with 10 CFR 20.103(b)(1) in that engineering controls were not utilized as required.
(50-219/78-23-03) 6.
Posting, Labelina and Area Control The inspectors toured the facility upon arrival on site September 6, 1978 and at other times during the inspection.
Posting, labeling and radiation area control were reviewed against the following requirements: Technical Specification 6.13, "High Radiation Area" -- -- 10 CFR 20.203, " Caution Signs, Labels, Signals and Controls" -- Procedure 909.1, " Radioactive Hazard Tagging", Revision 0 -- Procedure 909.2, " Radioactive Material Container Labeling," Revision 0 -- Procedure 902.2, " Identification and Posting Controlled Areas," Revision 2 a.
Posting and Control of High Radiation Areas Technical Specification 6.13, "High Radiation Area," requires that each High Radiation Area in which the intensity of radia-tion is greater than 100 mrem /hr but less than 1000 mrem /hr shall be tnrricaded and conspicuously posted as a High Radia-tion Area and entrance thereto shall be controlled by issuance of a Radiation Wor k Permit and any individual or group of individuals permitted to enter such areas shall be provided with a radiation monitoring device which continuously indicates
- "e radiation dose rate in the area.
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On the morning of September 7,1978, the inspectors made a tour of the 119' elevation and found a 4' by 8' by 3' high serled wooden box located near the spent fuel storage pool.
T. e i spectors noted that this box had been placed there n subst.auent to the inspection of the same area on the evening of September 6,1978.
Radiation levels measured by the in-spectors revealed that the contents of the wooden box produced a radiation field over an extended area of the top surface of 150 mrem /hc ar and the area was not barricaded or conspicuously posted as a high radiation area.
The inspectors observed that a nylon rigging sling approxi-mately 4 inches wide and 8 feet long had been placed in a pile on the top surface of the box.
Underneath the sling the inspectors found a sign which read "High Radiation Area".
The inspectors noted that an individual could unknowingly be exposed to a dose rate at the gonads of 150 mrem /hr if he were to sit on tne wooden box.
On September 26, 1978, during a tour of the 23' elevation of the Reactor Building the inspector noted that the entrance to the Torus area is made through an open hatch, down a metal ladder which leads to an 8' by 8' service olatform.
The inspector noted that the Radiation Work Peinit (RWP) No. 2637- - 78, provided for the tour of the controlled areas, stated in the special precautions and instructions section, " Observe posted latest surveys at control points".
The inspectors noted that the entrance to the Torus area on the 23' elevation is routinely used as the control point.
One of the inspectors and a licensee representative climbed down the ladder at the entracce to the Torus to inspect the area.
Due to equipment located on the 8' by 8' platform, a walkway had been estab-lished which required personnel entering the area to pass in close proximity to a 4 inch pipe positioned perpendicular to the platform.
Measurements made by the inspector revealed the radioactive material inside the pipe produced radiation levels up to 700 mrem / hour at contact with the pipe and 200 mrem / hour at 18 inches away from the pipe over an extended area.
The inspector noted that the radiation levels measured at 18" would produce a dose to a major portion of the whole body in excess of 100 mrem in one hour.
The area was not posted as a high radiation area as required. After a close inspection of the area, the inspector observed that a rope was lying on the platform beneath a stack of scaffolding which had been deposited in the area.
The licensee representative stated that the area 1945 287
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had been posted and barricaded previously and that personnel moving scaffolding into the area could have removed the posting and barricading.
The inspector observed at least two individuals working inside the Torus, pumping out residual water.
The inspector noted that failure to post and barricade areas in which the intensity of radiation was greater than 100 mrem / hour represented noncompliance with Technical Specifica-tion 6.13.la (50-219/78-23-04).
During the tour of the 119' elevation (refueling floor) of the Reactor Building on the evening of September 6, 1978, the inspectors observed a 4' by 7' by 8' wooden box located in the vicinity of the equipment storage pool.
Upon surveying the wooden box, the inspectors noted that the contents of the box produced a radiation field over an extended area of 150 mrem / hour when measured at six inches and the area was not barricaded.
The inspectors noted that one side of the box was posted with two signs stating, "High Radiation Area".
During the inspector's observation of this item identified above, it was noted that RWP No. 2111-78 which permitted the inspector's entry into high radiation areas, specified the use of a continuously indicating dose rate instrument.
The accom-panying licensee representative provided such instrumentation, a PIC-6A survey meter (Serial No. 216).
The licensee representative made measurements of the wooden box with the PIC-6A and noted that the instrument only indicated 60 mrem /hr.
The inspectors' measurements of the item (made with two Digimasters, Serial Nos. 3501 and 3502) indicated sl50 mrem /hr.
The inspectors further noted that the licensee's instrument, when used for measurements in other areas, con-sistently indicated lower than the inspector's instruments by a factor of approximately two.
Upon completion of the tour on September 6, 1978, the inspectors' an6 the licensee's instruments were tested for accuracy by use of the licensee's sealed source containing 2.39 Curies of Cs-137.
The exposure dose rate produced by the source was checked with a Condenser-R-meter having a National Bureau of Standards traceable calibration.
The following data was produced: 1945 288
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Condensor-R Doserat: (mR/hr) Response Source (10 minute exposure) Instruments (Dose Rate) Cs-137 830 2.39 Ci (5/20/78) Licensee's PIC-6A, Serial No. 216.s330 mR/hr Licensee's Teletector s1000 mR/hr NRC's Digimaster Serial No. 3501 1850 mR/hr NRC's Digimaster Serial No. 3502 1850 mR/hr It was noted that the licensee's PIC-6A (Serial No. 216) responded low by a factor of 2.5, whereas the instruments used by the inspectors indicated a value within 5% of the actual dose rate as measured by the Condenser-R-meter.
The inspector noted that the licensee's use of the PIC-6A (Serial No. 216) in high radiation areas would not have full-filled the technical specifications requiring the provision of a radiation monitoring device which continuously indicated the dose rate in the area, since the instrument did not indicate the true dose rate in the area.
After a careful review of this matter the inspectors deter-mined that it was marginal whether or not the wooden box was actually required to be barricaded, therefore, no item of noncompliance was identified.
The inspectors expressed concern to licensee management with regards to the fact that the radiation monitoring instrument provided for the tour did not accurately indicate the true dose rate in the area.
Concerns with the licensee's radiation monitoring instruments are further discussed in detail 9.
b.
Labeling of Containers 10 CFR 20.203, " Caution si requires in paragraph (f) gns, labels, signals and controls," that each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents.
The label must bear the radiation caution symbol and the words " Caution - F.adioactive Material" or " Danger - Radioactive Material".
It must also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
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Contrary to the above, on the evening of September 6, 1978, while inspecting the 119' elevation (refueling floor) of the Reactor Building, the inspectors observed two 55 gallon drums and one 4' by 7' by 8' wooden box containing radioactive waste located near the equipment storage pool that were not labeled " Caution - Radioactive Material" nor did they bear the necessary information to prevent individuals handling or using the containers or working in the vicinity thereof to take precautions to avoid or minimize exposures.
The inspector measured radiation levels at contact on one drum of 30 mrem / hour and 80 mrem / hour at contact with the other drum.
The wooden box measured 150 mrem / hour at a distance of six inches.
An inspection of the same area on September 7, 1978 revealed the presence of a 4' by 8' by 3' wooden box located near the spent fuel storage pool which the contents of the box produced radiation levels over an extended area of 150 mrem / hour at two inches and the box did not bear the required labels nor was the box labeled with the necessary information.
The inspector noted that this is also contrary to Oyster Creek Procedure 909.2, Rev. O, Section 5.1, which specifies required labeling for licensed material.
Failure to label the drums as required represents an item of noncompliance with 10 CFR 20.203(f).
(50-219/78-23-04) This item is recurrent in that a similar item of noncompliance was found during inspection No. 77-13.
Regarding the requirement to label containers, the inspector determined that the High Radiation Area sign posted on the wooden box observed on September 6,1978 would have provided information to individuals handling or working in the vicinty of the box to take necessary precautions to minimize or avoid exposures.
In addition, this would have applied to the wooden box observed on September 7,1978, had it been conspicuously posted as a High Radiation Area.
The inspector discussed the September 6,1978 inspection findings with the Plant Superintendent on the morning of September 7, 1978, prior to making the September 7, 1978 inspection of the 119' elevation of the Reactor Building.
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The inspectors findings included the following: high radiation area not barricaded as required -- two 55 gallon drums and one wooden box not labeled as -- required -- miscellaneous tools and equipment protruding from the designated contaminated areas into noncontaminated areas the frisker (used for personnel contamination monitoring) -- located at the exit point of the 119' elevation had a background level of 30,000 counts per minute -- the continuously indicating dose rate instrument provided for the tour was found to be reading low by a factor of 2.5 (details, paragraph 6) The Group Radiation Protection Supervisor who was also present at this meeting stated that he had initiated corrective action.
The inspector expressed his concern to the Plant Manager regarding the radiological conditions that existed on 119' elevation.
c.
Posting of Radioactive Material Areas 10 CFR 20.203, " Caution signs, labels, signals and controls," requires in paragraph (e)(1) 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, to be conspicuously posted with a sign or signs bearing the radiation caution symbol a7d the words: " CAUTION, RADIO-ACTIVE MATERIAL."
Paragraph (a) of this section, requires that, except as other-wise authorized by the Commission, the symbol prescribed by this section shall use the conventional. radiation caution colors (magenta or purple on yellow background).
In regard to identifying the Radioactive Waste Building and surrounding storage areas as containing radioactive material, the inspector noted that the licensee does not consnicuously post discreet areas or rcoms but relies on posting of the surrounding perimeter fence to meet the requirements of 10 CFR 20.203.
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Upca arrival at the facility on September 6, 1978, the inspec-toes observed that the major portion of the east and south perimeter fence that encloses the Radioactive Waste Building and surrounding storage area, an area containing greater than 10 times Appendix C quantities of radioactive material, was not conspicuously posted as required. The majority of the " Caution, Radioactive Material" signs on the perimeter fence had faded to the point where the radiation sysmbol was recogniz-able only on close examination.
That portion of the signs originally magenta in color no longer exhibited the character-istic hue of that color.
The inspector noted that there were at least five signs posted within fifty feet of the Main Guard House on the east perimeter fence that were conspicuously posted but the remainder of the signs from this point back to the forward security post (a distance of at least 200 feet) were not posted in accordance with 10 CFR 20.203(e)(1).
At the entrance interview on September 6,1978, the inspectors discussed their observation with the Plant Superintendent.
It was stated to the inspectors that the signs had previously been replaced. The inspectors again observed on September 7-8, 18-19, and 26-29, 1978 that, except for the same 5 conspic-uous signs within 50 ft. of the Pain Guard House, the areas in question were not conspicuously posted as required.
This instance represents an item of noncompliance with 10 CFR 20.203(e)(1).
(50-219/78-23-06) This item is recurrent in that the same exact item of non-compliance was identified during inspection No. 78-09.
7.
Surveys The inspector reviewed records and toured controlled areas to verify compliance with the following: -- 10 CFR 20.201, " Surveys" -- 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in restricted areas".
Technical Specification 6.13, "High Radiation Areas".
-- -- Health Physics Procedure 902.2, " Identification and Posting Controlled Areas".
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-- Health Physics Procedure 907.1, " Radiation Survey".
Health Physics Procedure 907.2, " Contamination Surveys".
-- 10 CFR 20.201, " Surveys", requires in paragraph (b), that each licensee make or cause to be made such surveys as may be necessary to comply with the requirements specified in 10 CFR Part 20.
Another requirement,10 CFR 20.103(a)(3), equires that the licensee use suitable measurements of concentration of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
During tours of the controlled area on September 28, 1978, the inspector interviewed a contractor health physics technician assigned to the Rad Waste Building.
The discussion between the inspector and the health physics technician dealt with the types of work in progress or performed recently in the Rad Waste Building.
The inspector also reviewed the area log book and recent contami-nat'on, radiation and airborne radioactive material surveys.
The in;pector noted that smear survey record No. 2158-78, dated September '.o,1978, revealed that removable contamina ion levels as high as 1,355,740 djsintegrations per minute per 1C0 square centimeters (dpm/100 cm ) were present on the floor surface of the Centrifuge Room.
In addition, the inspector noted that smear survey record No. 2228-78, dated September 28, 1978, revealed that removable contamination levels as high as 986,210 dpm/100 cm2 were present on the floor surfaces of the Centrifuge Room and that loose contami-nation levels on the Centrifuge Motor, located in the room, were as high as 504,440 dpm/100 cm2 The inspector asked the health physics technician if personnel had been permitted to enter the Centrifuge Room when the above contamination levels were present.
The tech-nician stated that on September 28, 1978, two individuals were permitted to enter the room for inspection purposes, wearing half masks with air ;urifying cartridges.
A review of the licensee's records showed that several individuals had signed into the area under RWP Nos. 274678, 275078, and 277378 on September 28, 1978.
The inspector asked if an air sample had been taken in the Centri-fuge Room prior to their entry or during the time they actually were in the room.
The technician stated no air samph.s had been taken nor was he aware of the level of m airborne concentrations in the room prior to permitting the individuals to enter the room.
The licensee uses the services of contractor personnel in imple-menting certain areas of the respiratory protection program.
One specific area of the program that these individuals are used for is 1945 293
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to provide assistance to maintenance personnel when jobs require the need for air supplied respiratory protection equipment.
The individuals who support this function are known as hose tenders.
These individuals are responsible for assuring that the air supply hoses are blown out (free of moisture) prior to the workers using the equipment and assure that adequate air supply is being provided to the workers.
On Septembe 28, 1978, the inspectors noticed that two individuals assigned as hose tenders, were involved in blowing out air supply hoses (used for breathing air) in anticipation of a job requiring those hoses.
The inspector noticed that the hose tenders were wearing halfmasks with air purifying cartridges.
The inspector asked if an air sample was being taken while the in-dividuals were blowing out the hoses.
The health physics technician stated that an air sample was not being taken.
This individual instructed another health physics technician to take an immediate air sample where the hose tenders were working.
The inspector learned that the hose tenders were directing a rapid flow of air from the supply hoses against the contaminated floor.
The inspector noted that smear survey record No. 2233-78, dated September 28, 1978 revealed that removable contamination levels ranged from 10,000 to 163,000 dpm/100 cm2 in the Operating Aisle where the hose tenders were blowing out the air supply hoses.
The most recent air survey (No. 1619-78) taken approximately three hours prior to the hose tenders entry into the area revealed that the airborne concentrations of radioactive material in the Operating Aisle resulted in an occupancy time of 83 hours.
The air sample (No. 1618-78) taken fifteen minutes after completion of the work revealed that the airborne concentration of radioactive material had changed substantially, resulting in an occupancy time of 51 hours.
During the course of the inspection, the inspector interviewed Plant Equipment Operators responsible for operating the Centrifuge in the Rad Waste Building.
The %pector learned frow discussions with a Plant Equipment Operator and a review of the Rad Waste Control Room log book that on September 27, 1978, radioactive material had been processed through the Centrifuge.
A Plant Equip-ment Operator stated that he made four entries into various areas of the Rad Waste Building while the Centrifuge was processing radioactive waste.
Specifically, the individual stated he entered the controlled areas of the Rad Waste Building on one occasion to cap drums; on two occasions to check the level of material in the drums located in the Drum Filling Aisle; and one other occasion to 1945 294
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enter the Centrifuge Room because the equipment had failed.
The individual stated that the Centrifuge was processing waste during all entries except for his last entry at approximately 11:00 p.m.
when the centrifuge had malfunctioned.
The operator stated that an air sampler was located in the Operating Aisle during his shift.
He stated that during his entries into the Rad Waste Building he was wearing a full face supplied air respirator and that he had to enter the Small Pump Room (at least 100 feet from the sampling point in the Operating Aisle) and the Centrifuge Room (an unventilated room at least 100 feet from the sampling point in the Operating Area) on different occasions.
The inspector noted that the Operating Aisle is located on ground level, the Small Pump Room is located in the basemant and the Centrifuge Room is located on the upper elevation of the Rad Waste Building. As a result of discussions with the operator and a review of air sample records and log books the inspector determined that no air surveys had been taken in the Centrifuge Room on September 27, 1978, during the time the individual was required to enter that area.
The inspector noted that the licensee's air sample records showed that a subsequent air sample, No. 1577-78, taken between 1:15 a.m. and 1:30 a.m. on September 28, in the Centrifuge Room indicated that airborne concentrations were such that an occupancy time of 30 hours was applied to this area.
The centrifuge was not operating or processing at this time.
Air sample No. 1585-78 taken by the licensee in the Operating Aisle between 5:45 p.m. and 7:20 p.m. on September 27, 1978 indicated an occupancy time of 44 hours for that particular area.
The inspector reviewed the following information on the operator's access card to verify that the individual had entered the Rad Waste Building on September 27, 1978.
Radiation Work Radiation Exposure Permit (RWP) No.
Time of Entry Received (Mrem)
- 265078 4:00 p.m.-5:ll p.m.
265078 5:35 p.m.-5:55 p.m.
265078 8:30 p.m.-8:41 p.m.
265078 8:50 p.m.-9:26 p.m.
265078 11:20 p.m.-ll:40 p.m.
- RWP No. 2650-78 " Centrifuge Operation" was issued September 24, 1978.
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The inspector also reviewed the individual's " Respiratory Usage Data Card" which indicated that the individual made the above entries at those specific times.
The card also indicated that the individual wore a full face supplied air respirator for each entry.
The above findings represent noncompliance with 10 CFR 20.103(a)(3) in that suitable measurements of concentration of radioactive material in air to determine compliance with 10 CFR 20.103(a) were not made as required.
(50-219/78-23-07) This item is recurrent in that similar instances of nonccmpliance with the same basic requirement were found during inspection Nos.
76-01 and 77-13.
8.
Exposure Control The inspector observed work throughout the controlled area for adherence to the following: 10 CFR 20.1, " Purposes," states in Section (c), that, " persons engaged in activities under licenses issued by the Nuclear Regulatory Commission...should, in addition to complying with the requirements set forth in this part make every reasonable effort to maintain radiation exposures,...,as low as reasonably achievable."
Regulatory Guide 8.8, "Information Relevant to Ensuring that Occupa-tional Radiation Exposures at Nuclear Power Stc'. ions will be As low As Is Reasonably Achievable," states: a.
in Section 2.b, Radiation Shields and Geometry, paragraph (1), " exposure of personnel servicing a specific component (such as a pump, filter, or valve) to radiation from other components containing radioactive material can be reduced by providing shielding between the individual components that constitute substantial radiation sources and the receptor."
b.
in Section 3.a, Preparation and Planning, paragraph (5), "The existing radiation levels frequently can be reduced by draining, flushing, or decontamination methods or by removing and trans-porting the component to a lower radiation zone."
The Oyster Creek Unit No. 1 Final Safety Analysis Report (FSAR) Chapter XII, Conduct of Operations, states in Section 3.3.1, "It is the policy of the company to keep personnel radiation exposure within the regulations, and beyond that, to keep it as low as practicable."
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During tours of the 75' elevation Reactor Building, the inspector observed work in progress at the control rod drive (CRD) rebuild room. The inspector noted that the room was posted as a High Radiation Area.
Upon entry into the room, the inspector made radiation intensity measurements and found the general area dose rate to be 20 mrem /hr.
Further measurements made by the inspector revealed that work tables, used for rebuilding of CRD's produced radiation levels over an extended area as high as 600 mrem /hr on contact and consequentiy produced a whole body dose rate at the edge of the table as high as 100 mrem /hr.
The inspector brought these findings to the attention of two licensee representatives who subsequently verified these radiation measurements.
In addition, the inspector noted that the table was not posted in any manner.
The inspector asked the health physics technician assigned to the area if any attempt had been made to decontaminate or shield the work tables so as to reduce the radiation exposure personnel might receive during the rebuilding of CRD's.
The technician stated that no attempt at exposure reduction was made.
The inspector noted that since no reasonable effort was made to maintain radiation exposure as low as is reasonably achievable, this activity constituted a Deviation from FSAR commitments, re-gulatory guide provisions and the Code of Federal Regulations.
(50-219/78-23-08) 9.
Dstruments and Eauioment On the evening of September 6,1978, subsequent to the inspectors t ur of the 119' elevation of the Reactor Building (details covered in paragraph 6), the inspector examined the supply of portable raoiation monitoring instruments maintained in a locker in the Monitor and Change Room.
The inspectors observed that the locker contained approximately 10 radiation monitoring instruments.
The calibration stickers on the instruments indicated that the instru-ments had been calibrated at the frequency specified by Oyster Creek Procedure No. 908.1, Revision 2, dated November 14, 1975, " Portable Radiation Survey Instrument Calibration".
The inspector selected six instruments from the cabinet and per-formed a field check on each instrument using the sealed source (8 uCi Csl37) taped to the instrument cabinet.
Licensae representa-tives stated that the sealed source would produce an instrument response of 6-8 mR/hr.
The results of the field checks performed by the inspectors are shwn in the following table: 1945 297
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Table Field Check Results for Portable Radiation Monitoring Instruments Meter No.
Type of Meter Results (mR/hr) A E-510
B E-400
C Teletector
D Pic-6A
E Radector
F E-530
The inspectors pointed out to licensee representatives that in-struments D, E, and F did not adequately respond to the check source.
The inspectors expressed concern regarding the adequacy of the calibration and maintenance of radiation monitoring instruments to licensee management.
The inspectors noted that a similar situation was identified in an inspection conducted in May,1978, at which time the inspectors expressed concern with the quality and maintenance of instruments. This matter is further addressed in the cover letter tronsmitting the Notice of Violations for this inspection to the President, Jers7y Central Power and Light Company.
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11.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on September 29, 1978.
The inspector summarized the scope and findings of the inspection as presented in this report.
In addition, meetings were held on September 8 and 19,1978.
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