IR 05000219/1980017
| ML20052B470 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/13/1982 |
| From: | Donaldson D, Gilchrist G, Murray B, Neely D, Galen Smith, Terc N, Wadman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20052B468 | List: |
| References | |
| 50-219-80-17, NUDOCS 8204300462 | |
| Download: ML20052B470 (63) | |
Text
e.
.
U. S. REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
80-17 Docket No.
50-219 License No.
DPR-16 Priority Category C
--
Licensee:
GPU Nuclear Corporation Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Facility Name:
Dyster Creek Nuclear Generating Station (OCNG_S_1 Appraisal at:
OCNGS, Forked River, New Jersey and JCP&L Co. Corporate Office in Morristown, New Jersey Appraisal conducted:
May 12 through 23, 1980
<//Ms L.
/
.s Team Members: _ D. R. N4ely, Radiation Specialist, NRC
/'dste um, r i
L ( eam Leade()
i D. E. Donald on, Radiation Specialist, NRC date N. M. Terc, R iation Specialist, NRC date B. Murray, Ins ctor Specialist, NRC date W. W. Wadman, Cc nsultant, PNL date
)
G. L. Gilchrist', Broj t Ma ager, PNL date p
Approved by:
e,,e t/
tg 4
'/df/s L G. H.
mith, Director, Division of Emergency
'da te Prep edness and Operational Support
.
8204 a 0 0%W
,
_
_.
'
<
i
,
TABLE OF CONTENTS Page Summary...................................................................V 1.0 Organization, Responsibilities, Staffing and Management Oversight.
I
.
1.1 Documents Reviewed....................... I 1.2 Management Oversight - Audit Program.......
......3 2.0 Personnel Selection, Qualification and Training..........
2.1 Documents Reviewed......................
2.2 Selection Criteria......................
2.2.1 General....................... 4
,
2.2.2 Facility Staff Selection Criteria.......... 5 2.2.3 Contractor Staff Selection Criteria......... 6 2.3 Qualification Program...
..................
2.3.1 General....................... 7 2.3.2 Facility Staff Qualification Program........
2.3.3 Contractor Staff Qualification Program.......
1 2.4 Training Program..
....................10
.
3.0 Exposure Controls......................... 16 3.1 External Exposure Control..................
3.1.1 Documents Reviewed................. 16 3.1.2 General......................
3.1.3 External Dosimetry Program............. 18 3.1.4 Exposure Review..................20 3.1.5 Exposure Limitation................
3.1.6 Quality Assurance.................
4
.
.
_ - -
,
.,. _ _.
._
.
.
...
.
._
.
.
.
-.-
.-
.
I
%
Page 3.1.7 Conclusion.....................
22'
.
3.2 Internal Exposure Control................... 22
'
3.2.1 Documents Reviewed.................
'
3.2.2 Internal Dosimetry Program.
............
d 3.2.3 Internal Exposure Review..............
3.2.4 Internal Exposure Limitation.....
......
,
'
3.2.4.1 Administrative Controls.........
3.2.4.2 Respiratory Protection..
.......
3.2.4.3 Engineering Controls...
.......
3.2.5 Quality Assurance......
.........
.
f 3.2.6 Conclusions...................
3.3 Surveillance Program..
4
..................
3.3.1 Documents Reviewed................
i
'
3.3.2 Instrument Suitability and Use..........
3.3.2.1 Portable Radiation Monitoring ' Instruments... 37 ~
3.3.2.2 Analytical Instrumentation........
1
4.0 Radioactive Waste Management.
4'S -
...................
!
4.1 Documents Reviewed......................
4.2 Program Responsibilities....
46-
...............
l
'4.3 Waste Processing Systems...................
l-4.3.1 General......................
,
4.3.2 Facility / System Modification.
...........
,
4.3.3 Effluent / Process Instrumentation..........
4.3.4 Conclusion..................
'
...
I i
!
'
iii
, --
,
. -. - _,...
-
... -. - -. -... -...
- -
.. - - -... -.
-
-.
_
<
s
,
i
,
!
Page A9 5.0 ALARA~ Program
....
.
-
-
'-
~~ ****
5.1 Documents Reviewed......................
5.2 Program Establishment.
....................
.50 5.3' Intergration with the Radiation Protection Program......
5.4 Tours of the Oyster Creek Facilities.............
'
5.5 Conclusions.........................
52 6.0. Health Physics Facilities and Equipment.
.............
,
6.1 Radiation Protection Facilities..............
~54 6.2 Radiation Chemistry Facilities...............
7.0 Exit Interview and Meetings.................
..
Annex A - Persons Contacted......................
B iv
_ _ _ _ _ _ _ _
5
.
SUMMARY A special health physics appraisal was conducted during the period May 12 through May 23, 1980, to evaluate the overall adequacy and effectiveness of the implementation of the Oyster Creek Station radiation protection programs.
The health physics appraisal team was composed of four Radiation Specialist from the NRC Regions I and IV Offices and 'two health physicists under contract to the NRC. The evaluation included observations of work practices, reviews of selected procedures and records, and interviews with station, corporate and contractor personnel. The areas of the appraisal included:
Radiation Protection Organization and Management Oversight;
-
Personnel Selection, Qualifications and Training;
-
Exposure Controls (Internal and External);
-
Radioactive Waste Management;
-
-
Facilities and Equipment;
-
Results of the appraisal indicate that significant weaknesses existed in the health physics and radioactive waste management programs. Weaknesses were identified in the areas of management effectiveness (Section 1), qualifications and training (Section 2), exposure control (Section 3), radwaste management (Section 4), and ALARA (Section 5).
>
v
.
.
._
_
__.
e s
a 1.0 Organization,-Responsibilities, Staffing and Management Oversight 1.1 Documents Reviewed:
a.
Technical Specification 6.0, " Administrative Controls".
b.
American National Standard (ANS) 3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" dated 1976.
c.
American National. Standard Institute (ANSI) N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."
d.
Regulatory Guide 1.8, " Personnel Selection and Training."
e.
Regulatory Guide 8.8, "Information Relevant to Ensuring That Occupational Radiation Exposures at Nuclear Power Stations Will Be As-Low-As-Is-Reasonably-Achievable" (ALARA).
f.
. Regulatory Guide 8.10, " Operating Philosophy for Maintaining Occupational Radiation Exposures As-Low-As-Is-Reasonably-Achievable (Nuclear Power Plants)".
g.
NUREG-0731, " Guidelines for Utility Management Structure and Technical Resources."
h.
Technical Specifictions Change Request No. 85 (dated May 2, 1980).
1.
Technical Specification Change Request No. 50 (dated August 7, 1980).
,
J.
Station Procedure No. 101, Revision 9, " Organization and Responsi-bility," dated January 15, 1980.
k.
Letter dated February 20, 1980 from Victor Stello, Jr., Director, Office of Inspection and Enforcement to Ivan Finfrock, Vice Presidnt Power Generation, Jersey Central Power and Light Company (JCP&L).
1.
Letter dated March 17, 1980, from Ivan Finfrock to Victor Stello, Jr.
m.
NRC Inspection Report No. 50-219/79-18.
-
.
w ~,. - - -
-v
-
--
-
- - -
-. -
.
.
._
-
-
- _ - -
-
.
-
~
.
.
.
a
n.
JCP&L Quality Assurance (QA) Manual.
,
~
o.
Independent Safety Review Group.(ISRG)' Audit Reports:
-No. 78-25, Training Program.
.
i No. 78-26,' Chemistry
.
No. 78-27, Health Physics
.
,
'
No. 78-28, Environmental Monitoring
.
No. 79-04, Radioactive Materials Shipping
.
a-No. 79-20, Chemistry
.
r No. 79-33, Health Physics
.
f No. 80-15, Radwaste (Draft)
.
l
.p.
General' Office Review Board (G0RB) Meetings No. 74-A, May, 1979
.
No. 75, July, 1978
'
.
"
No. 76, August, 1979
.
No. 77, September,.1979
.
i q.
Audits By Consultants
'
'
Nuclear Utility Services (NUS), Health Physics, February,
.
I-1979 Nuclear Power Consultants, Inc. (NPS), QA Program, December,
.
1979
,
t GD/ Electric Boat, Respiratory Protection, February,1980
.
Stone and Webster, Radwaste Shipping Container, March,
.
1980 General Dynamics / Electric Boat, Dosimetry, April,1980
.
!
Spotts, Stevens, and McCoy, Inc.. Ser,1ce Air System,
.
April, 1980 r.
Instruction No. SQAI-020, " Site Health Physics Surveillance
P_rocedure."
i i
,
-,,. -, - - -
..., -. _., _
_, _., _.,. _.,,.... _,,
.
..
.. _ - _ _, _ _ _. _., _.. _
.
..
_
_.
.
.
s.
Procedure 913.1, " Vendor-Health Physics Control Station General Responsibilities, Revision 0, dated October 13, 1978.
J 1.2 Management Oversight - Audit Program The licensee conducts annual audits (ISRG) of health physics, chemistry and environmental surveillance activities.
These audits are performed under the direction of the Corporate QA Department. The audit teams have usually consisted of consultants and/or a mixture of consultants and JCP&L personnel.
ISRG audit reports for the period January 1, 1978 - May 19, 1980, covering health physics, chemistry, environmental, and emergency planning activities were reviewed.
Timely responses were provided by the onsite departments regarding deficiencies (audit notices) identified in the audit reports.
The most recent ISRG audit of health physics activities was conducted in December, 1979. Acceptable responses were received for the six audit notices issued.
It was noted that the audit teams have not included a member with extensive commerical nuclear power plant experience, e.g. Regulatory Guide 1.8 qualified that would provide the needed insight for evaluating the overall adequacy and effectiveness of the health physics program.
In addition to routine audits conducted by the licensee's Corporate QA Department, several audits of the overall health physics program and/or special areas within the program, were conducted by consultants.
The scope of the audits included:
(1) a general review of the health physics program, (2) QA Program, (3) radwaste shipping con-tainers, (4) dosimetry program, (5) respiratory protection program, and (6) an evaluation of the service air syrtem.
The use of numerous consultant auditors indicated the licensee's efforts to identify program weaknesses within their organization and obtaining recommended improvements upgrading the deficient areas.
Technical Specification 6.5.3.5 requires that audits o' facility activities sha'l be performed under the cognizt.ce of the Manager,
,
Operational Quality Assurance. These audits are to include, at least once per year, a review of the training and qualifications of the entire acility staff. The auditor requested a copy of the 1979-80 audit for his review. The auditor was particularly interested in the audit findings regarding initial and retraining programs for:
(1) general employee radiological training, (2) health physics. staff training and (3) training of personnel for the new radwaste facility operations. The licensee stated that the audit had not been completed.
A licensee representative stated that the audit was started in December 1979, but had not been completed because of additional work requirements placed on the Corporate QA Department as a result of 1980 outage. The licensee stated that a review of the health physics staff training program was included as part of Audit No. 79-33. The auditor noted that health physics training was only briefly mentioned in Audit No. 79-33.
In addition, Audit No. 79-33 stated that radio-logical protection training of station personnel was not included as i
.-.
-
-
.
..
-
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _
_ _ _ _. _- ______ ____ ______
.
,
part of Audit No. 79-33. The previous audit of.the training and qualifications of the-facility staff (Audit No. 78-25) was completed in October 1978.
The onsite QA Department had not implemented a meaningful audit /sur-veillance program with regard to health physics activities. The ineffectiveness of the onsite QA organization had becn identified in previous NRC inspections and private consultant reports (NRC Report 50219/79-18 and NPC Audit No. 2435-A, dated January 31,1980).
In order to correct this deficiency, the onsite QA Department issued Instruction No. SQAI-020, " Site Health Physics Surveillance Procedure,"
in March, 1980 which outlined a program for surveillance activities.
An attempt to perform surveillance inspections on some minor aspects of the health physics program was initiated. However, as of the time of the appraisal, an effective, comprehensive audit / surveillance program.had not been implemented.
Based on the above findings, improvement in the following' area is required to achieve an acceptable program.
Implementation of a comprehensive onsite QA audit / surveillance
.
inspection program of health physics activities.
2.0 Personnel Selection and Qualification (Training)
2.1 Documents Reviewed:
a.
Procedure 101, " Organization and Responsibility," Revision 9, January 15, 1980.
b.
Procedure 913.11, " Vendor-Health Physics Control Station General Responsibilities," Revision 0, October 13, 1978.
c.
Procedure 102, " Training of Nuclear Generating Station Personnel,"
Revision 3, October 2,'1979.
d.
Procedure 915.6, " Training and Radiation Protection," Revision 3, February 29, 1980.
e.
Oyster Creek Training Manual, " Radiation Technician Requalifi-cation," (Draft) dated May, 1980.
2.2 Selection Criteria 2.2.1 General The auditors reviewed available documentation and interviewed licensee personnel to evaluate the adequacy of established criteria for selecting individuals to be qualified to
.
,
_
.
.
,
perform assigned responsibilities in the various staff positions within the radiological controls, radwaste management and training areas.
Data collected were evaluated in relation to existing regulatory requirements, industry standards, and the auditors' professional judgement.
'
2.2.2 Facility Staff Selection Criteria The Radiation Protection Supervisor (RPS) is responsible for determining the number of radiation protection techni-cians necessary for insuring the safe operation of the OCNGS. Curi ently, there is a need for approximately twelve additional JCP&L radiar,1on protection technicians, until these individuals can be hired and trained, these vacancies are being filled by contractor personnel.
There is a general job description to be used in hiring these twelve individuals.
This description is written for a junior technician level.
The current practice does not allow for the hiring of senior ANSI qualified technicians.
This is due to an agreement between the OCNGS and the labor unions.
It the intention of the Radiation Protection Supervisor to send these twelve individuals through a 400 hour0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> formal classroom training program.
In conjunction with this program, the individuals will also receive on-the-job training.
There is no formal selection criteria established for the JCP&L radiation protection technician for specific positions.
Once the technicians have been hired and trained they may be assigned to any job within the plant.
For example, an individual without extensive training in internal dosimetry may be selected and assigned the responsibility of operating the whole body counter and the respirator fitting booth.
The distinction between a level A technician and a level B technician is vague.
Discussions with JCP&L technicians revealed that they are not certain as to what requirements must be met before moving from a level B to a level A.
They are also not certain as to which duties they can or cannot perform in the various levels.
There are no formal jeb descriptions for the Radiation Protection Technicians.
This can and does cause overlap of the job responsibilities.
Because of this overlap, there is misunderstanding in who is responsible for various jobs, which causes some areas to go unattended.
For example, discussions with a JCP&L senior technician revealed (
.
.
that he was responsible on the backshift for the new Rad waste facility.
He indicated that he had never received formal training in that facility and was therefore, not certain about its operations.
Because of this lack of training and no formal job description, he was uncertain as to his responsibilities in the event of an incident.
2.2.3 Contractor Staff Selection Criteria At the time of this appraisal the OCNGS was in the fifth month of a refueling outage.
Therefore, there were approx-imately 40 to 50 contractor technicians onsite at the time of this inspection.
It was determined that during this five month period in excess of 400 technicians have been used.
This large turnover of personnel can and did bring about the use of unqualified personnel.
During the first month of the outage, the resumes of all radiation protection technicians supplied by the contractor were reviewed by the RPS.
However, due to the work load of the outage, the RPS delegated this responsibility to an individual working for the contractor. This individual has since been hired as a full time employee of JCP&L.
Prior to his employment with JCP&L, he was responsible for determining whether contractor technicians met the ANSI N18.1-1971 requirements for senior technicians.
Health Physics Procedure No. 913.1, 10-13-78, Section 3.1 states that the RPS specifies the minimum standard of education anci experience for contractor personnel. Contrary to this, no procedures or guidelines were established for use by the individual responsible for selecting radiation protection technicians performing in responsible positions.
The RPS relinquished the responsibility of personnel selection to an individual who was not fully aware of the
'
qualification requirements of ANSI N18.1-1971 for technicians in responsible positions.
i No attempt on the part of JCP&L was made to verify the l
credentials of the contractor technicians.
Previous l
employers were not contracted by JCP&L staff or their
'
representative. After the initial group of technicians hired during the " rst month of the outage, no personal interviews were made to verify qualifications or to de-termine areas of specialization. This practice has allowed
,
l the assignment of unqualified personnel to the wrong jobs.
l l
l
_.
_
.
._
.-
. _.
_
. _ -.
-_
_ _.
-
.
.
l
i 2.3 Qualification Program.
2.3.1 General The auditors reviewed available documents and interviewed'
'
licensee personnel to evaluate the adequacy of.the program
'
for initially qualifying and maintaining the proficiency i
of individuals selected to fill positions in the radiological controls, radwaste and training areas. Also included were aspects related to the qualification program-for non-licensed personnel in radiation. safety practices. Data collected were evaluated in relation to existing regulatory require-ments, industry standards, the licensee's organizational configuration, and descriptions of job responsibilities.
i 10 CFR 19.12, " Instructions to Workers," states in part,
"All individuals working in or frequenting any portion of
'
a restricted area shall be... instructed in the health
,
'
protection problems associated with exposure to... radio-active materials or radiation _, in precautions or procesures to minimize exposure, and in the purposes and functions of
,
protective devices employed...."
j
'
American National Standards Institute'(ANSI) N18.1-1971,
.
" Selection and Training of Nuclear Power Plant Personnel,"
'
contains criteria for training of nuclear power plant personnel.
Section 5 of ANSI N18.1-1971, " Training,"
states in part, in Subsection 5.1, " General Aspects," "A training program and schedule shall be established for each nuclear power plant to initially develop and maintain an operation, maintenance and technical aspects of the
'
nuclear power plant involved....
Training programs shall be kept up-to-date to reflect plant modifications and changes in procedures. A continuing program shall be used after plant startup for training of replacement personnel and for retraining necessary to ensure that personnel remain proficient."
l-Subsection 5.3, " Training of Personnel Not Requiring AEC Licenses," states in part, "A suitable training program shall be established for managers, supervisors, professionals, operators, technicians and repairman to properly prepare them for their assignments...."
In addition, Subsection
-
5.5, " Retraining and Replacement Training," states in part, "A training program shall be established which
.
maintains the proficiency of the operating organization i
through periodic training exercises, instruction periods,
and reviews covering those items and equipment which relate to safe operation of the facility and through
.. _ _
-
..
.
.
__
_
.___ _ __- _-_ _
..
.
__
. - - -
-.
-.
__
..
.
..
.
special training sessions for replacement personnel...."
Section 5.5.1, " Retraining," and Section 5.5.2, " Replace-ment Training" specifies the minimum subjects to be covered.
2.3.2 Facility Staff Qualification Program At the time of the evaluation, there was no formal organiza-tional description for the training function and-no approved training and retraining programs were in effect for radiolog-ical controls, radwaste, training or non-licensed personnel.
The Radiation Protection Department was reviewed to deter-mine the qualifications of staff members within that department.
This was accomplished through personal inter-views, and review of resumes for the RPS, several group supervisors, and the radiation protection foreman.
Six of the technicians were interviewed to determine their qualifi-cations.
No resumes were available on any of the technicians.
It-was immediately apparent that there were insufficient number of OCNGS permanent personnel to fill the positions of supervisors and of. technicians. Contractor personnel were being used to fill the positions of Supervisor of Operational Radiation Protection and four of the five foreman positions.
It was determined that in the event that the Radiation Protection Supervisor was unable to fulfill his respon-sibilities, no one is currently qualified to replace him.
This is considered an area of major concern.
The technical background of the permanent radiation protec-tion technicians was considered to be barely adequate.
The technicians and the group foreman were found to be lacking in their knowledge of state-of-the-art techniques,
new standards, new Regulatory Guides, and changes in the regulations.
It recognized that it is the intention of the OCNGS radiation technicians. training program to educate the technicians and the foreman over the next year.
.
There is no formal qualification criteria used in selecting individuals for specific jobs.
For example, any of the
technicians could be selected to operate the whole body counter with a small amount of on-the-job training. That
'
individual could then be rotated into another position after a short period of time should the need arise.
.
-.
-.
-
-
..-
-
- - - - -
_
.
.
2.3.3 -
Contractor Staff Qualification Program In the first month of the current outage, the initial contractor technicians were selected for senior positions based on a review of their qualifications by the RPS.
However, after a period of one month that responsibility was delegated to a contractor supervisor. This individual stated that he used ANSI N18.1-1971 as a means of determining the proper selection of the technicians. However, when questioned he was not aware of the qualification requirements specified in ANSI N18.1.
The resumes of ten contractor technicians were randomly selected for review by the auditors. This review and personal interviews with four senior technicians revealed that they were not qualified to be senior ANSI technicians.
This finding was pointed out to the RPS and he was requested to personally review the qualifications of all contractor technicians performing in responsible positions. After his thorough review, he stated that fourteen of the twenty-eight senior technicians were determined to be unqualified and did not meet the ANSI N18.1-1971 qualification require-ments. He subsequently down graded fourteen technicians and replaced them with technicians who met or exceeded the qualification ~ criteria specified in ANSI N18.1-1971.
Two of the five group foremen for the Radiation Protection Department were-found to have marginally acceptable quali-fications. Although these individuals had radiation protection experience, their knowledge and experience with respect to commercial nuclear power plants was limited.
During the exit interview, it was requested that the licensee obtain additional supervisory support in order to insure adequate technical depth existed at the facility in order to continue an effective and timely upgrading of the radiation protection program.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
The job descriptions, training and definition of job
.
responsibilities for the radiation protection staff require improvement.
The radiation protection staff selection criteria
.
need improvement.
In the event that the Radiation Protection Supervisor
.
would be unable to fulfill his responsibilities, no one is currently qualified to replace hi.
.
.
.
2.4 Training Program The Oyster Creek Nuclear Generating Stations (0CNGS) Training Depart-ment and the Radiation Protection Department were reviewed to determine the adequacy and effectiveness of the radiation safety training.
program.
It was concluded that the initial general employee radiation protection indoctrination training was adequate and met the criteria
!
of ANSI N18.1-1971.
However, the radiation protection technician, requalification and the on-the-job training programs were determined to be inadequate. This deficiency rating is based on the current program.
The OCNGS Training Department in conjunction with the Radiation Protection Department are currently developing a radiation protection technician training and requalification program.
Both of these programs are in the initial draft stage and were not completed at the time of this inspection. An appraisal was m'de of the material currently available for these programs and will be discussed in the following sections.
,
The OCNGS has a training supervisor who is responsible for the administration of all Oyster Creek training programs.
These programs include the departmental training, annual plant wide retraining and special training as may be deemed necessary by the various department supervisors. However, the Radiation Protection Supervisor (RPS) is also responsible for various aspects of the training.
It appears that the establishment of a training department without clearly defining responsibilities and discussing these responsibili-ties with the individuals involved in the program had caused a breakdown in communication between the Radiation Protection Department, the Training Department and corporate management. Discussions with the Training Supervisor and the RpS verified conflecting opinions of the primary responsibility for various portions of the radiation protection training program.
Procedure 101, Revision 9, " Organization and Repsonsibilities,"
outlines the responsibility of the Training Supervisor and RPS.
The RPS is responsible for the technical content of the radiation protec-tion program at the OCNGS.
Contrary to this definition, in the draft radiation protection technician training and requalification program, the Training Supervisor is identified as being responsible for the content of the lecture programs.
Procedure No._102, Revision 3, " Training of Nuclear Generating Station personnel," also identifies the Training Supervisor as being responsible for "the assignment of lectures, material and training facilities spaces." These documents seem to contradict one another and lead to confusion over the ultimate authority in providing technical review of all training courses in health physics.
,
I
_
.
_
.
_
...
.
.
Discussions with the Training Supervisor and the RPS verified con-flicting opinions of who is responsible for the technical. content of the lectures provided in the area of radiation protection.
Each.
individual felt that he was ultimately responsible for the review and approval'of these lectures. The RPS is recognized as the techni-cal expert at the plant in the field.of radiation protection.
Therefore, it would seem appropriate that he should be responsible for the technical content of lectures pertaining to his field.-
The RPS stated that there was an agreement between his department and the Training Department that he would interview all radiation protection instructors to insure their technical competency. However, the Training Supervisor stated that he was not aware of such an agreement and had just hired an instructor without consulting the RPS. This is considered an additional breakdown in the communication between the Training Dep'artment and the Radiation Protection Depart-ment.
The Training Supervisor was informed two weeks prior to this inspec-tion that he was responsible for establishing a radiation protection technician training program. This training program is in response to the PAB Team item of noncompliance B.S.b, Inspection 79-18 conducted October and November 1979.
The training program was scheduled for completion one month after the current outage. The_ corporate commit-ment for this program was not discussed with the Training Supervisor.
The Training' Supervisor stated that because of this delay in notifi-cation and lack of communication with him that the' radiation protec-tion technician training-course may not be completed on schedule as per the corporate commitment. This lack of communication is consider'ed poor management control.
The RPS and the Training Supervisor are in disagreement over the
_
technical content of the radiation protection technician training course. Because of this disagreement both individuals are currently developing their own course material and each believes his will be used for the course. The technician training program is scheduled to cover several separate areas.
Two of these areas will be courses in beginning and advanced radiation protection. The training depart-ment has developed a beginning radiation protection-course outline, which was reviewed by the appraisal team and the RPS.
Both the.RPS and,the appraisal team found this document to be. lacking in technical content with inappropriate questions to determine adequacy of. individual learning. Therefore, the RPS has contracted with a vendor to supply a basic and advanced radiation protection training course. This lack of communication is considered extremely poor management com-munication.
I
_ _
_
.
.
The general employee radiation protection training program was reviewed and found to be adequate. However,.it is suggested that additional time t>e given in the area of radiation protection instru-mentation, procedures and Radiation Work. Permits. The~RPS has identified this as an area that needed additional work and agrees with the appraisal findings.
The general employee annual retraining program was reviewed and found to be adequate based on discussion with the Training Instructor.
However, in discussion with plant personnel it was determined that the areas covered on the annual retraining program may be in noncom-pliance with ANSI N18.1, Section 5.5.1.
However, additional inves-tigation will be needed to verify the noncompliance.
It is suggested that the onsite inspector be requested to followup on this item.
Procedure 102, Revision 3, states that all employees will participate in annual retraining lectures.
The Training Supervisor and the Radiation Protection Instructor stated that the attendance at the annual retraining course was insured and verified by the comparison of the personnel dosimetry computer record with the physical attend-ance record of the course. However, the Radiological Support Super-visor and the RPS state that the dosimetry computer record is not adequate for insuring attendance record.
It is possible to not be on the dosimetry record under the column entitled RWP and still be working at the plant.
Therefore, it is possible for an individual to go for an undetermined period of time without annual retraining.
There are no procedures for checking annual retraining attendance
<
records with a complete list of all personnel.
It is suggested that a procedure be developed for insuring attendance of all plant personnel at the annual retraining programs.
,
Procedure 102, Revision 3, Sections 5.5.3 and 5.5.4 requires retrain-ing on an annual basis.
The procedure goes on to state the "100%
attendance is attempted but not required..."
In Section 5.5.4, the statement is made that "in no case will the time between retraining be more than two years." This system does not allow proper confor-mance with ANSI N18.1-1971. With the two year program, changes in plant procedures, safety instructions, and emergency plans would not be adequately addressed. This item of annual. retraining has been identified in earlier inspections.
Specifically, a letter dated January 12, 1979 from John G. Davis, Acting Director, Office of Inspection and Enforcement, states that the OCNGS procedures should-be revised to require that all personnel actually receive health physics retraining within a prescribe interval.
In a letter in response from Jersey Central Power and Light, a commitment to annual retraining was made.
The current OCNGS training program does not have a course in health physics for the radiation protection technicians. The current practice is to hire an individual as a junior radiation protection-technician with little or no experience.
This individual is then
,
!
_.
_
_
._
_
__
-..
-.
.f
.
,
assigned to a senior technician who is responsible for on-the-job
,
training in all areas of health physics pertaining.to the OCNGS.
!
The training continues for a period of approximately two years before the individual is considered for a senior radiation protection technicians position.
There are no formal classroom course for the
radiation protection technicians; however, some offsite courses have been offered over the past few years. The licensee is in the process of developing a radiation protection technician training and requal-ification course. The following items of concern are in regards to i
these courses:
Inspection Reports 79-18 (PAB) list a deficiency in radiation protec-tion technician training and retraining. The JCP&L/GPU letter (March 17,1980) to the NRC listed a corporate commitment to establish an RPT training and requalification course within one month after the current outage. As discussed in Section 1.3 above, this program is currently under development. However, the conflict between the Training Supervisor and the RPS may hinder its completion within the scheduled time. The other obstacle in the development of this program is the hiring of a training coordinator to assit in the development and administration of these training programs.
It is the intention of the RPS to hire this individual by July, which leaves.little time for preparation on his part.
,
The draft radiation technician requalification program requires annual attendance as specified in Procedure 915.6. Section 5.3 of Procedure 915.6, Revision 3 specifies that annual attendance will comply with Procedure 102.
Sections 5.5.3 and 5.5.4 of Procedure 102, Revision 3, allows annual retraining every two years. This would violate the commitment to provide annual requalification of the radiation protection technicians.
It is suggested that amendments be made to Procedure 915.6, Procedure 102 and the draft radiation
.
technician requalification course outline.
There are no formal records maintained on the special training of the radiation protection technicians. Discussions with the radiation protection instructor verified this finding. The training instructor
'
stated that the special training for the radiation protection tech-nicians is given in the form of on-the-job training. However, there are no procedures for providing consistent on-the-job training practices for all staff. This practice lends itself to propagation-of bad work habits and to the personal interpretation of job require-ments.
For example, the following observation was made.
Discussions with a senior ANSI qualified contractor technician revealed that he was assigned o a specific function where he had no previous experience. This individual stated that the on-the-job training provided was given by a junior technician.
The reason given for this practice was lack of qualified personnel to provide the training to this individual.
..
-
.-.---
--
--
-
.-
-.
.
.
.
.
I 14'
Discussions with OCNGS technicians revealed that the above condition was not an abnormality.
It was stated that the on-the-job training was suspose to be the responsibility of the Radiation Protection Foreman. However, due to the large work load, the foreman was not always available to provide the on-the-job training necessary for new positions. Therefore, it became the responsibility of the individual.in that position, whether he be senior or junior, to train the new individual assigned to that position.
Discussion with the contractor radiation protection technicians verify that several had not received proper onthe-job instructions
-
prior to assignments at new positions.
These individuals stated
_
that they were reassigned up to five times in one week to five separate positions.
In numerous cases the previous senior ANSI qualified technician had already moved to a new position and was not available for onthe-job training.
Therefore, it became the respon-sibility of the junior technician assigned to that position to train the new senior technician.
Discussions with two senior ANSI qualified contractor radiation protection technicians revealed a lack of on-the-job training and instructions in the proper use of the radiation detection. instruments
'
assigned to these individuals. Both individuals stated that they had not received specific instructions in the operating charac-teristics or proper use of this instrument. Neither the individuals have had prior experience with this specific model.
The training department is assigned the responsibility for documen-tation and maintenance of all records for training courses.
Procedure 102, Revision 3, Octobar 2, 1979, " Training of Nuclear Generation Station Personnel" states in Section 5.7.1, "All station training records and documentations should be indexed and filed in the Station Document Control Center...." Contrary to this procedure, the training department is currently establishing their own files on training and retraining of general employees and radiation protection technicians.
It is the future intention of the training department to put these records on a central processing unit.
Discussions with other depart-ments, e.g., the Rad Waste Section, indicate that they are currently retaining their own training files,-which is in violation of Procedure 102, Section 5.7.1.
The procedures listed in Section 2.1 above were reviewed to determine their adequacy and completeness.
The following problems were identi-fied with Procedure 102, Revision 3:
Procedure 102, Revision 3, Section 3.3 assigns responsibilities
.
to the Oyster Creek department supervisors and Training Supervisor for the training of OCNGS personnel.
Discussions with the Training Supervisor, the RPS and the Rad Waste Supervisor.
indicate that this section is not currently being complied i
- -
__.,.
.. --
_.
,
,
.
.
--
.
-
.
.
i with. A review of.the departmental training records in the Station Document Control Center verified that Section 3.3 is not being complied with.
Procedure 102, Revision'3, Section 4.1 states " key super-
.
visory personnel must be qualified for their position in
'
accordance with References 2.3 and 2.4."
References 2.3
'
(JCP&L Company'0perating License in Technical Specifica-tions, Section 6) and 2.4 (Oyster Creek-Procedure 101)_.
deal with the requirements of JCP&L.
Section.4.2 of the same procedure states "All other. supervisory _ personnel
'
will be qualified for their positions in accordance with Reference 2.1" (Reference 2.1 is ANSI N18.1-1971). The wording in Sections 4.lLand 4.2 imply that key supervisory personnel unlike all other supervisory personnel are not required to comply with ANSI N18.1.
It is suggested that.
Section 4.1 be amended to include Reference 2.1.
This
item is of concern because some supervisors were found to
~
be unqualified for their jobs.
Procedure 102, Revision 3, Section 4.3 states "All non-
.
supervisory personnel will be qualified for their posi-a tions in accordance with Reference 2.2."
For the same
.
reasons as was stated above, this section should also Reference 2.1 (ANSI N18.1-1971).
'
Procedure 102, Revision 3, Section 4.5 states "Any changes
.
to qualification requirements will_not be retroactive.and shall not disqualify a presencly qualified employee."
,
This statement implies that any changes in the Code of Federal Regulations or USNRC Regulatory Guides would not be foIlowed if disqualification of someone previously
_
qualified was required. Contrary to this, changes. in Regulatory Guide and the Code of Federal Regulations must be followed. Therefore, it is recommended that this Section (4.5) should be eliminated.
Based on the above findings,- improvements-in the following areas are required to achieve an acceptable program:
The radiation protection technician requalification and
-
.
the on-the-job training programs are inadequate in their current-state. A-formal documented program should be developed to ensure adequate onthe-job training is provided.
The disagreement over training responsibilities should be
.
resolved so that technician training and requalification programs can be developed.
)
=- --
,
.
-
. -.
.
.
-
,
,
.
The general employee radiation protection retraining
.
program allows two or more years prior to retraining.
The retraining requirements should be on an annual basis.
3.0 Exposure Control 3.1 External Exposure Control 3.1.1 Documents Reviewed:
a.
Procedure 903.2, " Personnel Monitoring," Revision 13, dated April 30, 1980.
b.
Procedure 903.8, " Cumulative Quarterly Exposure Report," Revision 1, dated June 30, 1979.
c.
Procedure 903.9, " Daily Exposure and Access Control Card," Revision 1, November 10, 1978.
d.
Procedure 906.3, "Preoperational Checkout of TLD Reader," Revision 1, dated May 22, 1978.
e.
Procedure 906.4, " Loading and Unioading of TLD's,"
Revision 3, dated April 30, 1980.
f.
Procedure 906.5, " Receipt of TLD's," Revision 3, dated May 2, 1980.
g.
Procedure 906.6, " Dosimetry Isrue," Revision 3, dated May 22, 1978.
h.
Procedure 906.7, " Reading TLD's," Revision 1, dated May 22, 1978, i.
Procedure 906.8, " Shipment of TLD's," Revision 1, dated May 22, 1978.
j.
Procedure 906.9, "TLD Inventory," Revision 2, dated
.
October 24, 1979.
I k.
Procedure 906.10, " Receipt and Posting Data," Revision 1, dated May 22, 1978.
,
1.
Procedure 906.12, " Personnel Termination," Revision 3, dated May 22, 1978.
m.
Procedure 906.13, " Lost 00simetry," Revision 0, dated December 26, 1975.
{
. _ - _
.
-
.__ -
=.
..
o.
.
i n.
Procedure 906.14 " Spike TLD's,"' Revision 1, dated May 22, 1978.
'
!
o.
Procedure 906.15, " Personnel Files," Revision 1,
-
dated May 22, 1978.
p.
Procedure 906.17, " Spike Testing and Leak ~ Testing
,
Self-Reading Dosimeters," Revision 2, dated December
<
!
13, 1979.
i q.
' Procedure 906.18, "Startup and Preoperational Checkout of the 9100 TLD Reader," Revision 1, dated April 30,
'
1980.
r.
Procedure 906.19, " Reading TLD's on the 9100 TLD Reader," Revision 0, dated January 11, 1979.
,
s.
Procedure 906.20, " Calibration of 9100 TLD Reader,"
Revision 0, dated November 10, 1978.
~
t.
Procedure 906.21, " Backup Area Calibration for 9100 TLD," Revision 0, dated January 11, 1979.
u.
Procedure 906.22, " Reading Backup Areas of TLD's on the 9100 TLD Reader," Revision 0,> dated January 11, 1979.
v.
Procedure 906.23, "Unjamming and Cleaning the 9100 TLD Reader Sample Charger," Revision 0, dated January 11, 1979.
w.
Procedure 906.24, " Shutdown and Standby Condition of 9100 TLD Reader," Revision 0, dated January 11,.1979.
x.
Procedure 906.25. "Startup and Preoperational Check Out of 8300 TLD Reader," Revision 0, dated April 30, 1980.
j
!
y.
Procedure 914.2, " Computerizing RWP Data," Revision 0, dated January 31, 1978.
!-
j z.
Procedure 915.1, " Access Control to Restricted Areas,"
Revision 3, dated January 8, 1980.
aa.
Procedure 915.7, " Personnel Monitoring," Revision 0, dated July 5, 1979.
- 3.1.2 General The external dosimetry program had received three appraisals or audits within the past year prior to the NRC appraisal
.
-.
_._.
_
.
. -
. _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _________.
.
.
team's arrival on' site. Several areas considered weak by previous investigations had'been strengthened or changed, while others were in the process of being changed or upgraded.
The Radiological Support Supervisor had been assigned overall responsibility for implementing and maintaining the Oyster Creek personnel dosimetry program.
This func-tional position is charged with providing internal and external monitoring capabilities and maintenance of radiation experience records support of the Radiological Controls Program.
3.1.3 External Dosimetry Program The Oyster Creek NGS personnel dosimetry program relied upon vendor supplied and vendor read Thermoluminescent Dosimeters (TLD's) for measuring exposures of record since 1973. OCNGS was equipped to read a second TLD " film" contained in the vendor badge holder in 1978. Self reading pocket dosimeters (SRPD) are employed and read daily; this
,
data is entered into the GPU computer daily.
l Dosimetry devices were issued typically Monday through
,
l Friday 8-4:30 by dosimetry group staff.
Off shift was i
handled by a duty H. P. technician.
Individuals received i
dosimetry as a TLD, SRPD and daily reading card (for doses
'
received on various RWP's during each day).
Daily, the reading cards were collected and dose per RWP was entered into the computer.
Unusual readings triggered the reading of the OCNGS TLD " film".
TLD's were issued according to a prepared list.
Badges were loaded after a preissuance reading of the vendor annealled TLDs had been performed, for those regularly on the list (non-visitors).
Change out was performed at 6 PM and 6 AM until all TLDs were changed.
TLD films are removed from the holders, stacked numerically and verified against the issuance log.
" Strays" were tracked'down, (usually 5-6/1000 issues).
Vendor TLDs were shipped to be read. OCNGS TLD's were read and entered into the computer. Data was reconciled with SRPD data. Readout OCNGS TLDs were shipped to vendor to be annealled.
Upon receipt of the vendor dose evaluations, vendor and OCNGS data were reconciled.
Reconciled doses were entered into the computer as the dose of record. The computer records contained detailed accounts of changes and reconcili-ations.
These could be traced in an audit mode. All changes in a dosimetry record were explained in a code or
-_ _ ______- _ ___
__ _
__
_
.
.
_ _ --
_
_
.
.
!
!
l note. Old and new data were retained for audit.
There were 2 working and one backup computer tapes. The computer program was designed to print out daily, monthly, quarterly and annual _ exposure records.
The operator could also obtain such formated data as - dose per individual per RWP, accumulated exposure per job as well as various NRC required data and exposure notices.
.
The dosimetry program is under the direct supervision of one person.
The remaining staff' are an entry level clerk, two personnel that read badges and perform data input / output j,
through the computer.
It appeared, to the appraiser, that all personnel were working at capacity.
It appeared that
,
!
the entry level clerk was working at an assistant technician level in technical knowledge requirements.
The self reading pocket dosimeters (SRPD) are calibrated in accordance with Regulatory Guide 8.4 and ANSI N13.5.
The pocket clips of the SRPDs are painted with a color to
'
indicate the calibration time period.
'
Dosimetry for radiation other than gamma-rays was occa-sionally issued.
Neutron dosimetry employed film badges
- '
supplied by an outside vendor. These dosimeters had not
'
been evaluated in an operationally produced neutron flux against a rem-meter established dose rate.
Beta dosimetry was not an active element-in-the dosimetry program.
The beta calibration and dosimetric response were'not performed at the site and no recent data could be supplied by the vendor.
Beta doses were quoted in the
,
report. Both the site and the vendor were committed to
participating in the University of Michigan dosimetry calibration program.
The appraiser felt that the placement of the OCNGS.TLD behind the vendor TLD would greatly reduce the beta response of the OCNGS TLD film.
TLD wrist badges are used for Extremity dosimetry.
These i
dosimeters are coded on the ()mputer as extremity' dos-imeters and if more than one is utilized the person is i
assigned the highest dose of the series.
Fingertip dosimetry
.
is not employed as most work requires-tools and/or remote handling devices and is spoken to in the procedures to be utilized to minimize direct surface contact of radioactive parts. No procedure exists to convert gamma dose at the
'
wrist to gamma-dose at the fingers in the instance where
hands are inside a valve body.
No attempt is made to assess beta dose under the same circumstances.
!
I
.
..
.
,
The automated TLD reading system does have a manual backup within the office, and a third system is being established offsite in case of an emergency requiring offsite dosimetry reading.
A review of the onsite records was made by the appraiser and the tracking of the various types of forms required, histories required, and data recording from the SRPDs and the monthly TLDs are adequate and timely and seem to carry with them a fairly high degree of accuracy.
Health physics personnel monitoring procedures are covered in the 906 series in 21 different procedures. These procedures from 906.3 through 906.25 were compared with Reg. Guides 8.2, 8.3, 8.4, 8.7, 8.8, 8.10, 8.13, and 8.14 as well as with the following standards: ANSI N13.5, N322, N13.6, N13.7, and N13.11. Based upon the intercompar-ison of these documents and with the interviews of the personnel within the radiation dosimetry section, beta, neutron and extremity dosimetry was determined.to be at variance with the Regulatory Guides and the ANSI standards.
3.1.4 Exposure Review Exposure review was performed by the radiation protection supervisor, the dosimetry supervisor, the health physics supervisor, and several of the supervisors of departments; all received partial listings of the dosimetry output from the dosimetry supervisor.
The appraiser witnessed super-visors calling to obtain recommendations about crew rotation in order to distribute radiation exposure throughout their entire staff.
This indicated that they were performing the review in order to achieve ALARA. Management made use of the data in the main conference room where the running total of Man. Rem was visually displayed on the outage progress board.
Exposure review may have played a part in the ability of OCNGS to reduce radiation exposure doses during the 1980 outage.
3.1.5 Exposure Limitations The initial administrative radiation control procedures are generally directed from the series 100 administrative-procedures and are spelled out in more detail in the 900'
series procedures 901.7 through 904,42. Many of'these procedures are undergoing review and rewrite. Although many administrative procedures seem to be defined and documented, it was not apparent that the staff was aware of the procedures that existed.
<
a
.
..
-
-,.
-
-,
.-
..
.
.
.
Areas which were alarmed for the purposes of evacuating personnel through the sounding of the alarm were under.the control of the operations department. The instrument and electronics. department performed the calibration and/or alarm point settings on area radiation monitors. Other alarms could be manually initiated from the control room.
This permitted operations to sound an audible warring to
,
cause personnel evacuation in the event that some change
.
that they were about to make would produce potentially hazardous radiation levels.
Remote operating and remote handling devices were called
out in several procedures. -There were no opportunities
'
during this appraisal to assess the use and handling of such devices.
There are two access control points to the areas with radiation levels which may be of some concern.
Passage beyond the access control point seemed to be without obvious surveillance.
However, where specialized protec-
tion was required or high radiation levels existed, those
areas were given more local control with a guard logging people in and out.
Usually, a health physics technician was available for assurance that personnel were wearing proper dosimetry and protective equipment.
Several instances
'
were observed by various team members where access was easily gained to areas which had radiation levels from 20
mR/hr to 80 mR/hr.
.
.
3.1.6 Quality Assurance
'
On site quality assurance unless performed within the department itself was not evident in the records of the
!
departments and sections of which I performed appraisals.
'.
This appraiser did not, however, contact the onsite quality assurance group.
Although a moderate level of internal QA is performed
,
within the department, some improvements could be made.
No direct QA on the calibration of instruments is performed.
Except for the records reviewed to insure that the SRPDs are within tolerance, no further QA of those calibrations is made. The-QA of the other radiation dosimetry devices needs to be improved beyond a single calibration point.
ANSI N345 recommends several calibration points be used within the dose range to be expected and allowed. Only one external or offsite audit was performed on the company who read the TLD materials.
This was performed after an offsite appraisal team desired to make such an audit.
I
,
,-r-,
r
-- -
w e
._.
.
.
Documentation exists to indicate that the dosimetry super-visor had requested an audit of the vendors of the TLD and neutron badges.
QA is performed on-the procedures to the extent that there was a period within which the procedures must be reviewed.
No documented procedures exist for user feedback regarding-how well procedures worked.
l Quality assu e,ce, from the departmental level in health physics, is one of the apparent weak points in the program.
'
3.1.7 Conclusion Based on the above findings, improvement in the following areas are required to achieve an acceptable program:
Usable beta calibration data should be obtained and
.
employed to evaluate beta exposures.
i Extremity dosimetry should be improved _to evaluate
.
'
doses more realistically and accurately.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matters should be considered for improvement of the program:
Improvements to the quality assurance program should
.
i be made, such as, improve the accuracy of placement of the dosimeters in relation to the sources during i
calibration.
Neutron dosimetry should be supported with suitable
.
l health physics neutron rate meter measurements in
areas where neutron dosimetry is routinely required.
Perform the calibration exposures of the various
.
dosimeters at several points on their usable dose range.
Perform a statistical analysis of the OCNGS irradiated
.
i badges and the evaluations of the comparisons of the dose obtained through readings at OCNGS and the vendor.
3.2 Internal Exposure Controls l-3.2.1 Documents Reviewed a.
Procedure 915.8, " Bioassay Program," Revision 1, April 24, 1980.
>
~
,
e
- - - - -,,
, - - - - -,..,,
-
-,--,
-,--
- -
.- -
-
.
.
,
'23 b.
Bioassay results for the period December 1, 1979 -
May.13, 1980.
!
c.
Letter to Helgeson Nuclear Services, Inc., " Calibration Sources," from Bruce Watson, April 11, 1980.
d.
Procedure 915.5, " Respiratory Protection," Revision 8, April 15, 1980.
e.
Procedure 904.9, " Respiratory Usage Data Card,"
Revision 0, May 22, 1978.
'
f.
Memo from Ivan R. Finfrock, Jr., " Management Policy Statement - Respiratory Protection Program - Oyster
. Creek Nuclear Generating Station," May 22, 1978.
-
g.
Memo from D. W. Turner, " Bruce Watson Designated as
Respiratory Protection Program Supervisor," April 28, 1980.
I h.
Instruction No. 4.2, " Respiratory Protection-Facial Measurements," Revision 0, August 2, 1979.
'
i.
Instruction No. 4.3, " Respiratory Filter Resistance Testing," Revision 0, August 16, 1979.
J.
Analytical and Engineering Evaluation of-the Oyster
'
Creek NGS Service Air System for Breathing Air, by Spotts, Stevens, and McCoy, Inc., April 18, 1980.
k.
Evaluation of the Oyster Creek Nuclear Generating
'
Station Respiratory Protection Program, by General-Dynamics - Electric Boat Division, February 22, 1980.
1.
Oyster Creek Nuclear Generator Station Respiratory Protection Program, by Bruce Watson, April 15, 1980.
>
i m.
Quick Letter to HP Technicians, "MPC Hour. Log," From Jim Cook, August, 1979.
.
n.
Instruction No. 7.2, " Air Sample Analysis," Revision No. 1, September 4, 1979.
.
o.
Instruction for Qualitative Respirator Fit Testing,
September 5, 1979.
!
3.2.2 Internal Dosimetry Program
The internal dosimetry program responsibilities and activ-ities was described in Procedure 915.8, which addressed the following items:
,
,
-
.
.,e
-. - - -.
.- - -.. -
- -,
- - -, - - -
-,,,
_
_
_
._ _ -
_
__
_
. _.
e.
.
I-
.;
!
References (.tCRP Publications 2, 6, 9,10 and 10A and
.
~
ANSI N343-1978).
Responsibilities.
.
Requirements for.in-vivo bioassay (direct bioassay).
.
Requirements for excreta bioassay (indirect bicassay).
.
t
.
Action levels for followup bioassay.
Collection, handling and-packaging of-excreta bioassay
.
.
'
samples.
QA/QC requirements.
-
.
I
!
Operation of the whole body counter.
.
i
The auditor noted that the information contained in Procedure 915.8 generally followed the recommendation of ANSI N343-1978,
>
" Internal Dosimetry for Mixed Fission and Activation Products."
i A whole body counter was the basic system employed in the i
licensee's internal dosimetry program.
This system obtained'
'
from an offsite vendor, was housed in a mobile van and consisted of a sodium iodide detector and associated multichannel analyzer. The vendor maintains another i
mobile unit at the Oyster Creek Site, which was available
'
from time-to-time to serve as an alternate to the primary i
sy s tem '. The system is used for in-vivo detection and measurement of personnel radionuclide uptake and deposition
-
,
and provides data for assessment of internal exposures.
l Whole body count data in units of counts per minute is immediately available at the site for selected radionuclides.
j Data is relayed via telephone / teletype to the vendor's
!
main office in California where further analyses is perforaed.
l The vendor provides the licensee with a formal report-
,
approximately two weeks later which contains the various radionuclides identified and the associated maximum permiss-
[
ible body burdens (MPBB) or maximum permissible organ
,l burdens (MPOB).
,
=
The auditor reviewed the operations manual provided by the f
system vendor. The sensitivities listed in the manual
!
indicate that detection limits of less than 5% of the MPBB are easily obtainable.
!
!
!
. - -
... ~. - - -.. _.. ~ -..,
.
..
,. -...
. _..,
_
_ -, - -
, _ _...,
_
,. -.. -.
- -
..
.
.
-
.
..
,
The primary whole body counter was located near the main
,
plant entrance where an elevated radiation background area existed due to the accumulation and storage of radioactive
,
waste located approximately 200-300 feet from thc whole
<
body counter. This counter indicated background levels of 2,000-2,300 counts per minute (cpm) where as the alternate system parked near the training center (approximately one mile south of the plant) had a background of only 1,000-1,200 cpm.
Procedure 915.8 did not contain any restriction regarding placement of the counter in elevated background areas.
Personnel from the permanent JCP&L staff had not been assigned to operate the system. The operating records indicated that several contractor HP Technicians, with limited or no previous whole body counting experience, were designated as temporary operators. When one of the
contractor HP technicians terminated, a new inexperienced contractor technician was cycled through as the next system operator.
The auditor noted that this arrangement prevented the licensee from establishing operating personnel i
with long-term experience on the system in order to provide j
the necessary. stability and uniformity for a sound program.
At the time of the appraisal the whole body system was operated by two contractor health physics technicians.
These technicians were instructed to report any abnormal conditions to the Respiratory protection Supervisor. The contractor health physics technician assigned primary responsibility for the whole body system had been employed as a health physics technician since October, 1978.
However, he had no experience with a whole body system until assigned to the Oyster Creek syste.a in late March, 1980.
This technician stated that he had received about I
one month of on-the-job training by the previous con-tractor health physics technician responsible for operating the system.
,
!
The second contractor health physics technician, who
,
{
served as an alternate operator for the system, stated that he had recently graduated from college and had been
involved with operating the Oyster Creek system since mid-April, 1980.
This technician stated that he had no previous health physics experience prior to his employment at the Oyster Creek site in March,1980.
A formal, documented, operator training program has not been established.
The present training program consisted l
of one te.cporary contractor health physicis technician l
i.
.
_. _, _ _ _ _ _
__
_
_ _ - -_
- - _.
.
...
-
_
.
_.
.
.
t
26 l
providing on-the-job training for the next contractor technician that was to be cycled through as a system operator.
The auditor observed that a copy of-Procedure 915.8 was
!
located at the whole body counter, however, no other reference material was present.
Each of the technicians
!.
stated that=they were not familiar with the reference material listed in Section 2.0 of Procedure 915.8, i.e.
ANSI N343, " Internal Dosimetry For Mixed Fission and Activation Products; ICRP Reports No. 2, 6, 9, 10 and_10A; NRC Regulatory Guide 8.9; or NUREG 0041.
The licensee's whole body gamma counting system was supple-mented by excreta samples which are analyzed for tritium, strontium and/or alpha emitters. The licensee's records indicated that during the period January 1, 1980 to May 10, 1980 about 250 urine and two fecal samples had been collected.
The auditor reviewed bioassay results, whole body counts and excreta analysis, for the period December 1, 1979 -
May 13, 1980.
The whole body count reports indicated that 17 separate individuals had counts that exceeded the 5%
MP8B action level; six out of the 17 had exceeded the 10%
MPBB level.
It was noted that there-was close agreement
between whole body and excreta results for special sampling on two workers that exceeded the 50% MPBB level.
I 3.2.3 Internal Exposure Review
i An approved procedure had not been developed to provide j
guidance regarding the back-calculation of whole body i
count results in order to evaluate the adequacy of the respiratory protection program and/or incident situations
>
where respiratory equipment was not in use. -The auditor reviewed the licensee's documentation associated with a March 2, 1980 incident that involved an individual _ receiving an internal deposition of about 1600 nCi of Co60. The licensee calculations regarding MPC present during the incident appeared to conform with accepted practices.
,
l However, the calculations used to evaluate the incident i
had not been documented in a formal procedure for use by l
radiological protection personnel.
3.2.4 Internal Exposure Limitation
!
i 3.2.4.1 Administrative Controls Procedure 915.8 required that all personnel
-
(JCP&L and contractors) be whole body counted i
i
,- -
r
,,
nn-,
,,,,-,-
c
,
--,-n---n----
~, - -,
., -
-,
-
, - -
-
.
-n.
---
.
.
prior to entering a radiation work permit (RWP)
area unless otherwise directed by the Dosimetry Supervisor. All personnel who received a whole body count prior to or during their work assign-ment were also required to receive a whole body count or excreta bioassay _upon'terminaton.
Procedure 915.8 required that all personnel that.
had worked in a RWP area be whole body counted annually. The procedure also contained action levels for more frequent whole body counting if certain levels are exceeded.
Urinalyses were required if (1) whole body counts reveal more than 10% of the MPOB, (2) air samples reveal a high beta to gamma ratio or (3) if alpha contam-ination was found above the neck.
Fecal samples were required after confirmed results that a whole body count exceeded 10% of the MP08.
In addition, each month approximately 10 workers were randomly selected for whole body counts and urine bioassay as confirmatory checks of the routine program.
A program had not been established to account for MPC-hours of exposure to airborne radioactive materials in order to demonstrate compliance with 10 CFR 20.103(b)(2). The licensee had not maintained a tabulated list to demonstrate that 10 CFR 20.103 limits had not been exceeded. The licensee's Instruction No. 7.2 requires that MPC-hours are to be logged for personnel working in areas without respiratory protection where airborne' concentrations were between 2E-09 rCi/cc and 9E-09 uCi/cc gross beta and iodine and SE-13 uCi/cc and 2E-12 uCi/cc alpha.
Instruc-tion No. 7.2 required that MPC-hours were to be logged for personnel wearing respirators where concentrations exceeded 9E-09 uCi/cc gross beta and iodine and 2E-12 uCi/cc alpha. The. licensee's air sample results for the period January 1, 1980 - May 13, 1980 indicated that air samples collected from routine work areas exceeded 9E-09 uCi/cc gross beta on 36 occasions and exceeded 2E-12 uCi/cc alpha (after 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> decay) on 70 occasions. 'However, the MPC-hours calculations associated with these work areas had not been maintained.
Air sample results indicated that when concurrent grab and lapel samples were collected from the same work area, the lap 21 results were typically higher; in some cases bv a factor of 10. A
.
.
-
licensee representative stated that MPC-hour
-
records will be tabulated based on breathing s
zone measurements..The auditor noted the " Lapel Issue Log" indicated that only 13 lapel samples had been collected between January 1, 1980 and i
May 22, 1980.
The apparent lack of sufficient breathing zone sample results was discussed during the exit interview on May 23, 1980.
In the exit interview, a licensee representative stated that they had conducted an extensive, comprehensive, lapel sampling program for work activities conducted during the above mentioned period and apparently the auditor had not reviewed these records.
The licensee stated that establish-ing proper MPC-hours exposures of all personnel based on lapel sample results should be no problem.
The auditor did not review the purported
'
air sampling results.
3.2.4.2 Respiratory Protection Program The basic requirements for the licensee's respira-tory protection program were contained in Procedure 915.5, " Respiratory Protection."
It was noted
that Procedure 915.5 generally conforms with the
requirements of NUREG 0041. " Manual of Respiratory Protection Against Airborne Radioactive Materials."
Procedure 915.5 was supplemented with special instructions and memos that addressed specific aspects of the respiratory protection program.
- A management policy statement was issued by JCP&L on May 22, 1978 regarding the licensee commitment to an adequate respiratory protection program. The policy statement addressed program objectives, applications of engineering controls, equipment limitations, and emergency situations.
c I
On April 28, 1980, the Supervisor-Radiation Protection issued a memo which designated a I
member of the Radiation Protection Department as the Respiratory Protection Program Supervisor.
This memo assigned the Respiratory Protection
,
!
Program Supervisor the responsibilities for evaluating the total hazard and the work to be performed, recommending engineering controls, specifying respiratory protection, restricting the use of respirators if conditions warrant, recommend procurement of respiratory equipment and analyze the adequacy of the respiratory program on a continuing basis.
- -
. -
_
---
- - - - -
-
-. - - -
.
.
As mentioned above, Procedure 915.5 contains selected requirements of NUREG 0041.
The proce-dure contained requirements for the following items:
selection of approved equipment
.
wearer requirements and limitations
.
classification of hazards
.
.
respirator fitting and seal check limitations of various types of equipment
.
.
issuance of respiratory equipment decontamination, cleaning and disinfection
,
surveys, inspection, tagging
.
storage and repair
.
records
.
The Respiratory Protection Program Supervisor stated that adequate inventories of supplies and equipment was available for personnel use.
This inventory included about 400 full face air pur-ifying respirators, 75 air-line respirators, several SCBA units, and 30 air-line manifolds.
A quantative fitting booth had been established in a mobile trailer.
This system consisted of a sodium chloride aerosol man-test fitting booth.
An offsite vendor performed an evaluation of the licensee's service air system used to supply air for air-line respirators in April,1980. The evaluation included 17 recommendations to improve the service air system.
The report specifically noted that:
(1) air quality was within the limit for Type D breathing air and (2) special air-line couplings should be installed for use at the end of each breathing air pipe line.
The auditor noted that Procedure 915.5 does not contain information regarding the respiratory protection training program or medical examina-tions.
Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," as refer-enced by 10 CFR 20.103, permits a licensee to
_
-
-
._
.. -.
__
.
.
i
,
make allowance for the use of respiratory protec-tive equipment in estimating exposures of indivi-duals to airborne radioactive material if the equipment.is used according to established guidance.
Training Regulatory Guide 8.15, Section C.4.b, requires that written procedures be-prepared to ensure proper selection, supervision and training of
,
personnel using protective equipment as refer-
'
enced in NUREG-0041.
Section'8 of NUREG-0041
requires that training in the use of respiratory protective devices is to be given by a qualified and experienced. instructor. The instructor must
+
!
have a thorough knowledge of the application and
,
use of respiratory protective equipment and of
"
the hazards associated with radioactive airborne contaminants.
t The training for workers regarding field tests, wearer inspection and donning'the equipment was covered as part of the fitting booth quantative-tests. However, a formal training lesson outline had not been developed which covered both routine and emergency use of respiratory equipment.
The individual responsible for operating the fitting booth and conducting the training was a contractor HP Technician.
This technician was employed by JCP&L in mid-March,1980.
The technician stated that he had not had any previous HP experience prior to his 1980 employment with the licensee. The technician stated that he had
- not been provided copies of 10 CFR 20.103, Regulatory Guide 8.15 or NUREG-0041 nor was.he familiar with the contents of these documents.
The technician stated that his work assignment since mid-March has been operating the fitting booth and a backup operator for the whole body
,
counter. Accordingly, the instructor had received i
essentially no experience in wearing respiratory equipment in actual work conditions. The auditor noted that the contractor HP Technicians was somewhat confused as to the proper method for field testing (negative pressure) the Willson dual filter respirator.
,
!
l
.
..
Medical Examination The licensee's records indicated that medical
.exminations were conducted by a physician prior to issuing a respirator. However, Procedure 915.5 did not describe the clinical conditions to be investigated by the examining physician in determining an individual's fitness for respirator use.
3.2.4.2 Engineering Controls The licensee had established engineering controls to prevent the spread of airborne activity for several maintenance projects accomplished during the recent refueling outage.
These engineering control activities are' discussed in Section 5.
3.2.5 Quality Assurance The quality assurance (QA) program was for the whole body counter included in Procedure 915.8. This program consisted of a daily calibration with 100 nCi Cs-137 and 100 nii of Co60 placed in a masonite phantom.
Procedure 915.8 contains the acceptance criteria (three standard deviations) for the calibration results.
Calibration points had only been established for 100 nC1 of Cs-137 and 100 nCi of Co60 as rpecified in Section 4.10.8 of Procedure 915.8.
Calibration at points above or below these values are not routinely performed to demon-strate the validity of whole body counting results when internal deposition greater'than 100 nCi are identified.
For example, on March 2, 1980, an incident occurred where two workers became contaminated and followup whole body counts indicated internal deposition of about-1600 nCi of Co-60.
However, the licensee's calibration program did'
not include calibration points above 100 nCi to document the reliability of the measurements associated with March 2 incident. ANSI N343-1978, Section 15.2 recommends that calibration points be established for several points between 60-20,000 nC1.
The calibration sources were not traceable to the National Bureau of Standards (NBS).
The daily calibrations performed by placing 10, Cs-137 and 10, Co60 disc sources of about 10 nCi per sources in a masonite phantom.
The sources were originally provided by the whole body counter vendor who had in turn obtained the sources from an independent isotope laboratory.
The certificate of calibration that was provided with the sources did not indicate that the
-
'..
.
sources were traceable.to NBS.
During April, 1980, the licensee counted 20 of the disc calibration sources on their GeLi system and identified that three sources con-tained no activity (i.e., less than MDA 0.24 nCi).
The-
. licensee expressed their concerns regarding the quality of the calibration sources in a letter to the whole body counter vendor on April 11, 1980. ANSI N343-1978, Section 15.2, recommends the use of sources having calibrations traceable to the NBS.
Calibration reference points had not been established for radionuclides with gamma energies below Cs-137 (0.662 MeV). 'Cs-137 and Co-60 were the two radionuclides used to calibrate the system.
Calibration points had not been determined for such radionuclides as I-131 (0.364 MeV).
A QA/QC audit had not been performed by the licensee on the offsite vendor responsible for analyzing excreta
,
(indirect bioassay) samples.
.
3.2.6 Conclusion
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
An MPC-hour exposure program to demonstrate compliance
.
.
with 10 CFR 20.103 should be established.
'
A training program should be established for technicians
.
responsible for operating the respirator fitting booth and the whole body counter.
The individual conducting respirator training for
.
users should satisfy the experience requirements specified in NUREG-0041.
.
A formal training lesson plan which covers both-
.
routine and emergency use of respiratory protection equipment should be written and the program implemented.
.
A calibration program which is compatable with the
.
recommendation in ANSI N343-1978 for the whole body counter should be established.
3.3 Surveillance Program i
3.3.1 Documents Reviewed
-
a.
Procedure 764.3.007, " Air Particulate Sampler Flowmeter,"-
'
Revision 0, May 31, 1979.
.
- _,
_ _ - -
,,.,, - - _,
_.,..
- - -, - _ _ _ -,.
_.
.
.
b.
Procedure 795.3.001, " Calibration of Radeco High Volume Air Sampler Model H-809V," Revision 0, November -
23, 1979.
c.
Procedure 907.11, " Air Sampling Using a Low Volume Sampler," Revision 4, April 2, 1976.
d.
Procedure 907.13, " Air Sample Using a High Volume Air Sampler," Revision 0, December 1,1975.
e.
Procedure 910.1, "End Window GM Counting System -
Operating Voltage Determination," Revision 3, September 15, 1978.
f.
Procedure 910.2, "End Window GM Counting-System -
Background Determination," Revision 2, March 20, 1978.
g.
Procedure 910.3, "End Window GM Counting System -
Efficiency and Operational Check Determination,"
Revision 2, March 20, 1978.
h.
Procedure 910.10, "High Volume Air Sample Filter Preparation for Counting," Revision 1, June 126, 1978.
i.
Procedure 910.'11, " Radioactivity Analysis - Air Sample," Revision 3, May 15, 1978.
J.
Procedure 910.12, " Count Room Sample _ Preparation and Disposal," Revision.1, June 26, 1978.
k.
Procedure 910.17, " Gain and Linearity Check-Multichannel
Analyzer," Revision 0, September 17, 1976'.
,
1.
Procedure 910.18, " Background Count, Sample Count -
Multichannel Analyzer," Revis' ion 1, June 26,1978.
'
m.
Procedure 910.21, " Alpha Scintillation Counting r
System - Operation Voltage Determination," Revision 0, April 14, 1978.
'
n.
Procedure 910.22, " Alpha Scintillation Counting
,
l System - Background Determination," Revision 0, April 14, 1978.
o.
Procedure 910.23, " Alpha Scintillation - Efficiency and Operational Check Determination," Revision 0, April 14, 197.
.
p.
Procedure 910.31, " Health Physics Gamma Spectrum Analysis Using the TN-ll MCA System," Revision 0, April 14,1978.
q.
Procedure 910.32, " Health Physics Operation of the TN-ll MCA System," Revision 0, April 14, 1978.
r.
Procedure 910.33, " Health Physics Calibration of the GeLi Detector," Revision 0, April 14, 1978.
s.
Procedure 910.34, " Health Physics Calibration of the TN-ll MCA System," Revision 0, April 14, 1978.
t.
Procedure 910.36, " Personnel Allowable Occupancy Time Determination," Revision 0, May 15, 1978.
u.
Procedure 910.41, " Health Physics Gamma Spectrum Analaysis of Activated Charcoal Cartridges Using the TN-11 MCA System," Revision 0, April 14, 1978.
v.
Procedure 910.42, " Health Physics Gamma Spectrum Analysis of Particulate Filters Using the TN-11 MCA System," Revision 0, April 14, 1978.
w.
Procedure 915.2, " Radiation Surveys," Revision 0, July 2, 1979.
x.
Procedure 915.3, " Airborne Radioactivity Analysis,"
Revision 0, July 2, 1979.
y.
Instruction No. 7.1, " Air Sampling," July 27, 1979.
z.
Instruction No. 7.2, " Air Sampling Analysis Instruction,"
September 4, 1979.
aa.
Instruction No. 7.3, " Counting Smears With Count Ratemeter," Revision 0, July 27, 1979.
bb.
Memo to HP Technician, " Particulate Air Sample Analysis Using Glass Fiber Filters," From Bruce Watson, January 12, 1980.
cc.
Quick Letter to HP Technicians, " Gross Beta Counting on Air Samples," from M. L. Vyenielo, August 21, 1979.
dd.
Portable Air Sample Log, for the period January 1, 1980 - May 13, 198.
.
.
ee.
Lapel Sampler Issue Log, for the period January 1, 1980 - May 13, 1980.
ff.
Procedure 101, " Organization and Responsibility,"
Revision 9, January 15, 1980.
gg.
Procedure 112.2, "0yster Creek Calibration and Mainten-ance of Radiation Protection Instruments," Revision 0, November 9, 1979.
hh.
Procedure 764.3.007, " Air Particulate Sampler Flow Meter Calibration Procedure," Revision 0, May 31, 1979, ii.
Procedure 795.3.001, " Multiple Gamma Source Calibrator,"
Revision 0, November 23, 1979.
jj. Procedure 795.3.002, " Calibration of Teletector Model 6112," Revision 2, February 12, 1980.
kk.
Procedure 795.3.003, "Calbration of Xetex 302,"
Revision 0, November 23, 1979.
11.
Procedure 795.3.004, " Calibration of PIC 6A," Revision 0, Novmber 23, 1979.
um.
Procedure 795.3.005, " Calibration of R02 & R02A lon Chamber," Revision 0, November 23, 1979.
nn.
Procedure 795.3.006, "Caibration of PNR-4 Nuetron REM Counter," Revision 0, November 27, 1979.
oo.
Procedure 795.3.007, " Calibration of PRM-6 Alpha l
Meter," Revision 0, November 27, 1979.
pp.
Procedure 795.3.008, " Calibration of Portal Monitor Model PMP4," Revision 1, Jcnuary 30, 1980.
qq.
Procedure 795.3.009, " Calibration of NMC Continuous Air Monitors," Revision 0, November 28, 1979.
rr.
Procedure 795.3.010, " Calibration of Mini Pulser Model MP-L," Revision 0, November 23, 1979.
ss.
Procedure 795.3.011, " Calibration of Radeco High Volume Air Sampler Model H-908V," Revision 1, December
!
21, 1979.
,
tt.
Procedure 795.3.012, " Calibration of Eberline RAS-1 and RAP-1 Air Samplers," Revision 0, November 30, 1979.
,
l l
.
_
_
.
.
.
!
uu.
Procedure 795.3.013,;" Calibration of E530 GM," Revision 0, November 27, 1979.
vv.
Procedure 795.3.014, " Calibration of Laundry Monitor,"
Revision 0, November ~ 27,-1979.
.
w.
Procedure 795.3.014, " Calibration of RM-14 GM's,"
!
Revision 0, November 27,~1979..
'
xx.
Procedure 795.3.016, " Calibration of RM-16," Revision
,
'
0, November 28, 1979.
yy.
Procedure 795.3.017, " Calibration of P-4000A Lapel-Sampler," Revision 1, December 21, 1979.
l zz.
Procedure 795.3.018, " Calibration of Eberline Model
'
SAC-4," Revision 0, January 8, 1980.
aaa. Procedure 795.3.019, " Calibration of Beta Scalers,"
Revision 0, November 30, 1979.
,
m bbb. Procedure 795.3.020, " Calibration of Xetex Alarming
-
Dosimeters," Revision 0, January 3,1980.
ccc. Procedure 795.3.021, " Calibration of Eberline Portable Scaler PS-2," Revision 0, January 17, 1980, ddd. Procedure. 795.3.022, " Calibration of FM-1 Model TA Brand GM's," Revision 0, March 31, 1980.
eee. Procedure 901.8, " Standard Source Activity Decay
Calculations," Revision 0, January 11, 1979.
fff. Procedure 908.9, " Calibration of JSM-5 Instrument,"
Revision 7, January 11, 1979.
ggg. Procedure 9C8.20, "Use of Condensor.R-Meter," Revision
[
20, March 12, 1976, hhh. US Atomic Energy Commission, Regulatory Guide 8.6, i
May 1973, " Standard Test Procedure'for. Geiger Muller l
Counters."
!'
111. American National Standards Institute, (ANSI) N42.3-1969,
"Am'erican National Standard and IEEE Standard Test l
Procedure for Geiger - Muller Counters."
i jjj. American National Standards Institute, (ANSI) N320-1979,
" Performance Specification for Reactor Emergency
.
Radiological Monitoring Instrumentation."
l l
_.
_ - _. ~.
~.,.
,_
, _ _..
--
.
_
.-
.
kkk. American National Standard Institute, (ANSI) N323-1978,
"Radiation Protection Instrumentation Test and Calibra-tion."
3.3.2 Instrument Suitability and Use-3.3.2.1 Portable Radiation Monitoring Instruments A review was made of the health physics instrumenta-tion capabilities, portable and semi portable associated with the radiation protection program.
This included a review of instrument interpretation, maintenance, documentation and records,-and-observation of calibration techniques.
The responsibility for the instrument calibration program is currently divided between the Radiation Protection Department, the QA Department and the Instrument and Control Department.
The Radiation Protection Department is responsible for establish-ing and maintaining an instrument accountability system.
This system is to be capable of identify-ing radiation protection instruments in need of calibration and/or repair and assuring that they
are sent to the Instrument Department when required. The Instrument Department is responsible for repair and calibration of the radiation protection instruments and the generation of calibration data records for each individual instrument.
The Radiation Protection Department is responsible for assuring that these documents-are maintained in the Document Control Center.
The Quality Assurance Department is responsible for the surveillance and audit of this program
,
as well as the receipt and inspection of new instruments.
The current program relies on the radiation protection technicians to identify and send to the Instrument and Control Department all instru-ments which'are due for calibration. These instruments are then stored in either a instrument repair locker, which is currently not locked, or in the instrument calibration room.
It is then the responsibility of the Instrument and Control Department Supervisor to delegate the the repairing of these instruments to one of numerous instru-ment technicians. There are currently no technicians dedicated full time to maintenance of. portable instruments.
-
~e-+
,,,
,
,,,,,.--n---
n.-
-, - - - -,,
,-we
-
n
-
.-e
-
,
_ _ -
.
.
The OCNGS portable instrument inventory includes a variety of' portable ion chamber and GM instru-ments for measuring beta and gamma radiation levels.
It would appear that these radiation
- monitoring instruments along with the other portable instruments noted in the following table should be adequate for routine use.
However, because of several problems, the number of instruments available for use at any given time was significantly less.
In the event of an
!
'
unusual occurrence or emergency requiring extensive emergency capability, the stations ability to i
respond would be significantly limited.
The present accountability system was found to be inadequate for maintaining the current status of all instrumentation. Once the instruments have been calibrated and/or repaired, they are sent to the plant fon use.. Most instruments are usually dispersed through the Radiation Protection Monitoring Office.
However, there is no method
'
of maintaining an accountability of those instru-ments that are issued from the calibration
'
laboratory. A review of the instrument issue.
file in the monitoring office revealed that this file was not adequately maintained.
For example, one instrument was'found to have been issued and not returned three separate times.
Because there are no records for maintaining a location accountability of the radiation protection instrument, it is not possible to determine
,
their location for recall at the termination of the calibration period. At the time of this appraisal, thirty-five instruments were determined
'
to be past their calibration date. After a search of the reactor facility, nineteen of these instruments could not be located.
i
{
i
,-~n-.
,
e n
,-w,
--,--
- ~ ~
,
,
- - _____ _ _ _ - _ -. - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ - - _ - _ _ _
. - _ _
.
,_.. -.
.._.
!
i
.
i
.
l
!
PORTABLE INSTRUMENTS
{
10tal instruments l
Jype of i ns t rismen t s On Site (Records)
Total Working out of Service Past Ca l ibration i
Dose Rate RO2A
12
8 Pi-6A
?
16 High Range XeLux
?
-
Teletector
?
2 (3 to IMI)
Remaining instruments Iriskor
?
7
Total Monitors
7
-
Glis 114
?
-
--
.
-.
o
..
A further review of the instrument file revealed two instruments which were assigned to emergency kits. These instruments were found to be approx-imately seven months past their calibration date. The instruments were later found in the cabinet outside the calibration laboratory with no way to determine if they had been in the emergency kits or in the cabinet for the majority of the time.,This deficiency in instrumentation accountability is considered to be a serious
~
short coming of the program. [
The instrument maintenance program at the station, is adequate to maintain the instruments. 'This is primarily because of the high quality of the instrument technicians available for working on the instruments. However, it is recognized that these individuals receive very little training on the instruments. The technicians may work on the instruments as infrequent as once every two months, therefore, they are not able to keep abreast of the current state-of-the-art.
They were also found to be lacking in their knowledge of the current ANSI. standards.
Under the proposed reorganization, two instrument technicians will be assigned full time within the Radiation Protection Department for calibrating and repairing radiation protection instruments.
This reorganization is considered a positive step toward improving the program.
Items of concern in the portable instrument program follow:
Check sources are not supplied with each of
.
the portable instruments as suggested in ANSI N323, " Radiation Protection Instrumen-tation Test Calibration." The current system relies upon an individual check source located in the Radiation Protection Monitoring Office.
The storage facility for instruments needing
.
repair is considered to be inadequate.
Numerous instruments were piled on top of one another within this storage cabinet, t
.
.
located outside the calibration office. A teletector was being used to keep several instruments from falling out of the shelf, which could have seriously damaged the teletector.
Discussions with an instrument technician
.
revealed that a large problem in maintenance and operability is excessive abuse by the instrument users.
It is recommended that additional instruction be given to all personnel in the proper use of these instru-ments and proper cautions be given to alleviate this problem.
An Eberline, Multiple Gamma Source Calibrator is used for the calibration of portable radiation protection instruments.
The facility where this calibrator is located is adequate for maintenance, repair, and calibration of the instruments.
However, the instruments that are currently stored at the facility awaiting maintenance, repair, or calibration should be stored elsewhere to allow adequate work space.
Discussions with instrument technicians revealed that they had not received specialized training in the operation of the Multiple Gamma Source Calibrator, new instrument calibration techniques or general radiation protection instrument repair procedures.
The technicians stated that the majority of their education came from indepen-dent reading or through discussions with other technicians.
Two of the technicians questioned stated that they had not received formal classroom training, but had taught themseleves by reading the instrument manuals and the Multiple Gamma Source Calibrator users manual.
After observing a technician performing calibra-tions on new R02As, it was noted that the tech-nician failed to perform a survey inside the calibrator chamber to assure all sources were in the shielded position each time the door was opened.
The technician also failed to ensure reproducability of the instrument by exposing the instrument to the radiation field at least three times under identical conditions as recommended in ANSI N32,-
-
-
.
_-
..
..
.
.
s
l-i
The neutron calibration program was not reviewed
'
during this appraisal.
The number of portable instrument types possessed
.
by the licensee for use during an emergency is
)
considered adequate; however, as was noted in Section 3.3.1, these instruments may not be available.
<
The maximum range of instruments available at
,
the OCNGS are considered inadequate when compared to the recommendation in ANSI Standard ANSI
-
N320, " Performance Specification for Reactor Emergency Radiological Monitoring Instrumentation."
~
The ANSI standard recommends an instrument-with
4 a maximum range of 10 R/hr.
,
The OCNGS currently has four Nuclear Measurements Corporation, continuous air monitors located in
.various parts of the facility. During the course of the appraisal, it was determined that two of these monitors were' inoperable and had been for some time. Of the remaining two monitors, i
one was located on the refueling deck at the.119 foot elevation and the other was located in the reactor control room.
There were no calibration records'for these instruments available in the instrument record file.
It was stated by indi-viduals in the radiation protection department that these air monitors had not been calibrated for the past nine months. This nine month
>
period is-contrary to Procedure 795.3.009,
" Calibrations of NMC Continuous Air Monitors."
!
l This procedure calls for calibration at six
month intervals.
It was.further stated that
'
these air monitors are only used as backup to
the portable air samplers.
!
A marginally adequate supply of contamination control monitors, including friskers and portal-monitors are available. On numerous occasions during this inspection, it was observed that an adequate supply of friskers and contamination
control monitors was unavailable at the change i
j room. control area outside the Radiation Monitoring
!
Office.
In addition to these areas friskers were not available on at least two separate occasions outside high contamination areas.
- .
,
I
..,,,, -..
..,,
_., _ _ _, - _., _ _
_. -
_. - _.
,,,. _
_ _ _
e
.--
-._7 _-.
.
.
43
'
Several of the portal monitors were tested during this appraisal using an uncalibrated check source supplied by the appraisers. The sensitivity of the several portal monitors varied significantly.
The check source caused i
an alarm on only half of the portal monitors.
It was' discovered that a person with contamination of sufficient quantity to initiate an alarm could defeat the. logic circuitry'of the monitor.
This could be accomplished by stepping off the monitor just as it initiated.an alarm. The alarm and the red light would deactivate and the
'
green light would activate indicating a go signal. On three separate occasions when the appraisers initiated the alarm intentionally and.
j then stepped through, they were not challanged by any of the guards.
It also appears that no quality assurance program currently exists to test the sensitivity, wall thickness, and other
'
operating characteristics of GM tubes used in portal monitors.
Based on the above findings, improvement in the following area 15 required to achieve an acceptable i
program:
The radiation protection instrument repair
.
and calibration programs require significant L
1mprovement, especially in the areas of technician training and instrument availa-
.
bility and accountability.
I 3.3.3.2 Analytical Instrumentation
.
The licensee's analytical equipment consisted of:
(1) two GM detector / scalers for gross beta and iodine analyses, (2) two ZnS' detector / scalers for alpha analyses, and (3) a GeLi detector / scaler
'
for identification of gamma emitters. Air samples are immediately counted for gross beta and alpha activity using the GM and ZnS systems.
~
Followup counts are performed with the GeLi system on composite samples and individual samples where gross beta levels exceeded established'
action limits.
Followup alpha counts are performed at four and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the initial analysis.
The air sample analysis procedures did not include the verification of minimum detectable i
activity (MDA). Surveys conducted by the licensee
,
,
v.--
., -,
__r-_
, _.
.,s_
-
,
.-,c--
--
~ ~, - - -
- - ~ -
ra a
__.
._ -
.
.. -
-
-
- - -.
-... - -.. -
. _ -.
. - -
-.
- _.
4 t
.
.
f and offsite vendors had identified the presences j
of significant alpha activity in the plant
!
systems. As a result, the-auditor was interested i
to know if the licensee's alpha counting system j
had the necessary sensitivity to adequately evaluate air samples analyzed for alpha emitters.
,
!
The auditor questioned the two JCP&L HP Technicians
,
operating the counting systems on May 17, 1980
j as to the MDA associated with each alpha counter.
The technicians stated that:
(1) they did not
t i
know what MDA had reference to, (2) they had not received training regarding calculating MDAs,
,
and (3) they did not kncw the coaditions that j
would affect MDAs.
The licensee's records indicated that the back-
<
ground count rate for alpha counters SAC 241 and
.l 242 was usually about one count per minute (cpm). However, the counting log contained entries where the background count rate exceeded
.
1 cpm.
Instruction 7.2 required that certain
}
action be taken if gross alpha concentrations exceed SE-13 uC1/cc.
By employing the licensee's established procedures.regarding background count time, sample count time, sample volume, collection efficiency and counter efficiency, a
,
background count rate of 1.1 cpm yields a MDA of 3E-13 uCi/cc.
The licensee's records indicated that between January 23, 1980 and February 1, i
1980,.the background for counter no. 242 varied
'-
between 2.18 cpm and 4.9 cpm. With a background count of 4.9 cpm, the MDA was 6.5 E-13 uCi/cc.
Procedure No. 910.22, " Alpha Scintillation i
Counting System - Background Determination,"
Section 5.2 requires that if a significant change in background count rate is determined ano not corrected, the instrument shall be
,
!
removed from service and the Group Radiation
Protection Supervisor notified. The auditor j
asked the technicians operating the counting i
systems at what background level they consider
'
an increase as being significant. A technician stated that they are instructed to keep the
. background as low as possible, but he did not know if an increase of 10-20 cpm would adversely affect the reliability of the counting data.
Calculations indicate that with a 20 cpm back-ground, the MDA would be about 1.4 E-11 uC1/cc.
i
!
$
.
1'
i
- -,--._,, - -
, - - -..
.
-. -. - - - - - - - -,.
- -. -
-
- -. - -
. -.
-.
--
,
.
The information regarding air sample analyses was found in many fragmented procedures, instruc-tions and department memos.
The information had nnt been consolidated into a readily useable format (formal procedures).
Instruction No. 7.2, " Air Sampling Analysis Instruction," contains most of the guidance regarding the procedures to be used for calcu-lating airborne concentrations. A routing slip was attached to the instruction when it was issued in August, 1979. By signing the routing slip, the individual HP Technician indic6ted that they had read and understood the instruction.
It was noted that only five of the 11 HP Techni-cians had signed the routing slip.
The two technicians operating the counter on May 17 had not signed.
The licensee had the necessary counting equipment to conduct an adequate analysis program.
However, improvement in the following area is required to achieve an acceptable program.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
The technicians operating the counting equipment should receive appropriate training in counting and analyses techniques.
4.0 Radioactive Waste Management System 4.1 Documents Reviewed a.
Procedure 101.3, " Shipment of Radioactive Materials for Offsite Burial," Revision 0, November 14, 1979.
b.
Procedure 351.1, "The Chemical Waste / Floor Drain System Operating Procedure," Revision 1, January 23, 1979.
c.
Procedure 351.2, "High Purity Waste System," Revision 1, January 23, 1979.
d.
Procedure 351.4, " Solid Radwaste Operating Procedure," Revision 2, June 13, 1979.
e.
Procedure 351.11, " Packaging Radioactive Waste for Shipment to Offsite Burial Site in Hitman HN-100 Series Cask," Revision 0, February 20, 1980.
i
-
_ _ _ _ _ -
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _
_ _ _ _ - _ _ _ _ _ _
.
.
f.
Procedure 351.12, " Process Waste Lines Drainage Verification,"
Revision 0, February 20, 1980.
g.
Procedure 351.13, " Packaging Radioactive Waste for Shipment to Offsite Burial Site in Hitman HN-100S Cask," Revision 0, April 3, 1980.
h.
Procedure 351.14, " Packaging Radioactive Waste for Shipment to Offsite Burial in Hitman HN-200 Cask," Revision 0, April 10, 1980.
1.
Procedure 911.1, " Radioactive Waste Material Storage," Revision 0, August 20, 1976.
J.
Procedure 912.1, " Instruction and Requirements for Radioactive Waste Truck Drivers," (Draft).
k.
Memo to E. J. Growner, "0yster Creek Radwaste Modification Operator Training," from Bob McKeon, June 12, 1978.
l 1.
Memo to J. L. Sullivan, "New Radwaste Operators Training," frcm Bob McKeon, May 9, 1980.
m.
Lesson Plan For, "New Radwaste Operations," May 10,1980(Draft).
n.
Lesson Plan For, "High Purity Waste System," (Draft),
o.
Engineering Requesting No. 322.09, "New Radwaste Ventilation System," August 14, 1979.
p.
Audit No. 80-15, "Radwaste Operation" (Draft).
4.2 Program Responsibilities During the course of the appraisal, the Radioactive Waste Management Program was evaluated. This evaluation consisted of a review of:
assignment of program responsibility; waste processng systems (liquid,.
gaseous, solid); waste disposition; effluent / process instrumentation; organiztion, staffing; and personnel training and qualifications.
The Operations Supervisor had the overall responsibility for the new radwaste facility (NRW).
Reporting to the Operations Supervisor was the Acting Radwaste Supervisor. This individual was also function-ing as a part tin:e outage coordinator. Assisting the acting Radwaste Supervisor in the operation of NRW was an individual from the Chemistry
' Department.
Equipment Operators from the station reactor operations shift crews were designated as NRW operators. The usual shift crew consists of about 11 individuals including a Group Shift Supervisor,
,..
.
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
.
.
o
a Group Operations Supervisor, control room operators, and "A" and.
"B" equipment operators. Only "A" equipment operators were designated as responsible NRW operators.
The auditors requested to see copies.
of Jcb descriptions for personnel assigned to the NRW.
.
The auditors were informed that such job descriptions have not been developed, in their response to NRC Inspection Report No. 50-219/78-18,
,
the licensee committed to several changes regarding the organization associated with radwaste activities.
The proposed changes are to include new positions for Supervisor of Radwaste Operations and Radwaste Shipping Supervisor.
In addition, each-shift will have a shift Radwaste Supervisor and assigned Radwaste operators. The proposed Radwaste organization is to be implemented by September 1, 1980.
4.3 Waste Processing Systems 4.3.1 General Several tours were made by the auditors of the old radwaste t
facility (ORW), new radwaste facility.(NRW), and augumented off gas facility (A0G). The ORW was no longer used to process liquid waste. Activities in this facility were-restricted to compaction of solid waste and storage of radioactive waste. The NRW had been in operation since October, 1978.
Liquid waste processing, _ radwaste solidifi-cation, and solid waste packaging were accomplished in this facility.
The A0G was initially operated in 1977.
However, operational problems resulted in the facility being in use only about four weeks during 1977-78.
Extensive A0G modifications were in progress and scheduled for.
completion in June, 1980.
It is planned that the A0G will go on-line at the time of post-outage startup.
4.3.2 Facility / System Modifications i
Discussions with JCP&L employees and the review of inspection
reports and audits indicated that there were several *
chronic design and radiological problems associated with operating the NRW.
To begin with, the NRW was not con-I structed to conform with the original plans.
The facility was designed and constructed by General Public Utilities
(GPU) for JCP&L.
Budget restriction imposed during the final design stages dicated that the original physical layout of the facility be substantially reduced. As a result, both routine and nonroutine maintenance was difficult
to accomplish because of space limitations in equipment, cubicles, personnel entrances, and passageways. Mainte-nance activities are hampered because personnel are recuired to work in cramped quarters. This resulted in the expen-
'
b
.
..
_ - _.. _ - - - _ _ _ _ _. - _, -.-
,,
_-
-.. - -.
,, -, -. -. _, - _
,
.
.
diture of greater man-Rem exposure. The NRW was completed prior to the issuance of ANSI /ANS-55.1-1979, " Solid Radio-active Waste Processing System for Light Water Cooled Reactor Plants," and ANSI /ANS 55.6-1979, " Liquid Radioactive Waste Processing System for Light Water Reactor Plants."
However, it should be noted that the general layout and design of the NRW did satisfy the recommendations of these standards.
Problems associated with the initial startup and operation of the NRW have included:
(1) Faulty tank level gauges have resulted in the overflow of radioactive waste holdup tanks.
Extensive decontamination efforts and the expenditure of several man-Rem were required to cleanup the areas where the overflows occured, (2) Numerous pump motors have failed which required that the motors be replaced, (3)
Improper process line size and flow rates have resulted in plugged lines.
It was necessary to cut out and replace these contaminated lines, and (4) Improper facility ven-tilation resulted in air flow paths from areas of high contamination into clean areas.
The janitorial service personnel had waged a continual battle to keep floor areas clean so that normally expected clean areas were not des-ignated as contaminated areas.
Engineering Request No.
322.09, was submitted on August 14, 1979 to balance the ventilation system, no action had been taken at the time of their audit.
A program had not been implemented to ensure that the NRW HEPA filter system was tested. A licensee representative stated that the filter system was tested in 1978 as part of the original construction, but a program for future tests had not been established.
,
!
Modifications of the A0G were in progress in an effort to place the facility in operation along with the post-outage startup. Without the A0G in operation, gaseous release rates were 30,000-35,000 uCi/sec. Operation of the A0G is necessary to satisfy ALARA requirements. The auditors noted that there had been only limited coordination between
,
l GPU (responsible for completing the modifications and
'
initial startup) and JCP&L (responsible for future routine operation and maintenance of the facility.) JCP&L personnel had not been involved with calibration and acceptance testing of the effluent monitors or training.
The GPU Project Manager stated that his organization was responsible
for completing the specified modifications, including effluent monitor calibration, and taking the A0G through the initial startup. The GPU representative stated that coordination with JCP&L had been minimal regarding acceptance l
'
.
.
criteria, systems operating characteristics, and operator training.
The auditors reviewed the training program associated with the NRW. The licensee's records indicated that a formal training session for operatons personnel was conducted during May and June, 1978. A review of the May, 1980 Operations Shift Roster indicated that the roster included l
four "A" equipment operators that were not members of the
. operations department in 1978. A licensee representative stated that no formal training had been conducted since June, 1978.
It was noted that training program for opera-tions and Health Physics personnel was being developed for NRW systems. This training is scheduled to be conducted in June, 1980.
4.3.3 Effluent / Process Instrumentation The NRW liquid effluent monitor had not been calibrated and/or put into service.. Releases from the NRW were
.
routed through the ORW liquid monitor in order.to provide continuous monitoring during discharges.
It was noted that the NRW monitor provided for automatic termination of a liquid release if a preset release limit was exceeded.
The ORW monitor did not have this' feature and manual isolation was required if an alarm set point was exceeded.
4.3.4 Conclusions Improvement in the following area is required to achieve an acceptable program:
A program for the routine testing of the NRW HEPA
.
filters should be developed implemented.
5.0 ALARA Program 5.1 Documents Reviewed a.
Procedure 915.9, " Implementation of the ALARA Program," Revision 0, July 30, 1979.
b.
Memo to all Employees, " Policy on Maintaining Radiation Exposure ALARA," Approved by S. Bartnoff, President, JCP&L, June 18, 1979.
c.
. Memo to J. T. Carroll, Jr., and T. Snider, " Establishment of
' Joint Union-Management ALARA Committee," from D. A. Ross, May 18, 1979.
i
.
.
d.
ALARA Committee By Laws, August 24, 1979.
e.
Radiological Engineering Request Log, for the Period February 14, 1980 - May 12, 1980.
f.
1980 Outage ALARA Report, Reviewed by L. J. Smialek.
g.
ALARA Committee Meetings Minutes" for the Period June 25, 1979 - December 21, 1979.
5.2 Program Establishment The President, JCP&L issued a memo on June 18, 1979, to all employees regarding the licensee's policy on maintaining radiation exposure as low as reasonably'achieveable. The responsibility for implementation of the licensee's ALARA policy was assigned to the Station Superin-tendent. As part of the licensee's commitment to an ALARA program, a joint, eight member union-management ALARA committee was established.
The committee bylaws specify that the Station Manager was responsible for designating the chairman and vice-chairman. Two members are from the Radiation Protection Department (RPD).
The Radiation-Protecton Supervisor receives comments from the ALARA committee and recommends program implementation to the Station Superintendent.
The committee bylaws specify that the committee was responsible for investigating the expressed concerns of fellow employees in matters related to radiation safety and recommending solutions to the Radia-tion Protection Supervisor.
Specific concerns are submitted to the committee via an "ALARA Report"~which details the particular problem identified by the employee.
Procedure 915.9, " Implementation of the ALARA Program" contains the requirement regarding implementation of the licensee's ALARA program.
5.3 Integration with Radiation Protection Program The ALARA Committee has been ineffective in fulfilling the licensee's commitment for an adequate ALARA program. The committee had not met since November 11, 1979.
It was noted that 10 ALARA Reports (Form HP-914-1) were received by the committee between August 10, 1979 and November 1, 1979 and logged for approrpriate corrective action. The licensee's records indicated that as of May 19, 1980, only four of the 10 ALARA Reports had been closed out.
Between January 1, 1980 to March 22, 1980, eight ALARA Reports were submitted to the committee for action.
The licensee's records indicated that these-eight reports had not been assigned a tracking number nor reviewed by the committee.
Several employeer expressed concern regarding management's recent lack of interest in carrying out their commitment for an effective ALARA Committee program as evidenced by the lack of monthly meetings. Procedure 915.9, " Implementation of the ALARA Program,"
required that a meeting will be held each month.
l
.
.
The auditor noted that many of the activities performed by the recently (early 1980) organized Radiological Engineering Department (RED) involved the implementation of several good ALARA practices.
The auditor reviewed several maintenance projects accomplished during the 1980 outage and noted that recommendations made by the RED included efforts to confine contamination and reduce worker exposure.
The auditor visited selected job sites and noted that the RED had designed and implemented:
(1) several specially constructed tent areas, (2) special bagging procedures for contaminated equipment, and (3) the use of auxiliary ventilation systems.
In addition, the decontamination of local " hot spots" and process lines and the installation of temporary shielding helped to reduce external worker exposure.
Even though the RED responsibilities were not addressed in Procedure 915.9 or the ALARA Committee By Laws, the activities accomplished by this department were in line with the philosophies and recommendations of Regulatory Guide 8.8.
The ALARA Committee activities had been mainly involved with reactive responses to isolated problems identified by individual employees.
The committee had not developed a program regarding preventative goals and objective.
It appeared that the licensee's overall ALARA program could be enhanced if ALARA Committee responsibilities and RED efforts were combined into a coordinated effort.
A program had not been established to ensure that projects initiated by the Corporate Engineering Department received an adequate ALARA review early in the development of the project.
Representatives from the RPD stated that the first opportunity they may have regarding ALARA input was during the PORC review. At the PORC review stage, the design and proposed installation has been essentially completed.
As a result, it is difficult to make significant changes considering the time and effort that had been expended in a project to reach PORC review.
RPD personnel stated that they had reservations, from an ALARA viewpoint, regarding several projects accomplished during the 1980 outage and/or planned for the near future. They believed that significant reduction in man-Rem exposure could be accomplished if provided the opportunity to review a proposed projects during its early development.
The RPD stated that they are usually kept up-to-date on projects / modifications initiated at the site, but this is not the case for projects handled from the Corporate Office.
5.4 Tours of the Oyster Creek Facilities During tours of plant areas and observing work activities, the following was noted:
A formal program for post-operations debriefings regarding
.
observations, experience, and data obtained during nonroutine operations had not been developed to ascertain, record, and analyze problems encountered.
This would provides the bases
e
.
for revising procedures, modifying equipment, or making other adjustments that may reduce exposures during subsequent similar operations.
Interviews with contractor HP Technicians on duty at control
.
points indicated that many technicians were not familiar with radiological conditions in their assigned areas.
In addition, discussions with the radiation technicians and other workers within the plant revealed a general lack of knowledge as to the meaning of ALARA and ALARA principles.
It is recommended that additional attention be given to the concept of ALARA during the general employee indoctrination program.
5.5 Conclusions Based on the above findings, improvements in the following areas are required to achieve an acceptable program.
Management should demonstrate support of their commitment to
.
the ALARA program. This should include holding ALARA committeee meetings as required by Procedure 915.9.4, " Implementation'of the ALARA Program."
The Radiation Work Permit (RWP) program should be improved.
.
Deficiencies noted in the program were:
(1) several RWPs posted at job sites were illegible, (2) workers were not familiar with the conditions specified in the RWPs, (3) workers had signed-in under the wrong RWP.
Training and supervision of contractor HP technicians should be
.
improved to ensure that ALARA practices are being followed.
6.0 Health Physics Facilities and Equipment 6.1 Radiation Protection Facilities Counting rooms were observed as to their physical configuration and suitability for the purpose for which they were ir. tended. The counting room maintained in the health physics technician's office seemed to be quite cramped, and had background values which seemed
,
to exceed statistical variation.
i The analytical counting room for the health physics group was in an auxiliary office building removed from the main health physics control point. The only piece of equipment in operation within that
!
facility was a GeLi gamma spectrometry system. The space was not dedicated solely to a counting area and was utilized as an office
.
i area by other personnel.
!
i l
l -
i I'
.
The area set aside for personnel decontamination was reviewed. The facility consists of a shower at the far end of an alcove and a sink at one side of the alcove. Anyone who was highly contaminated would probably contaminate most of the alcove area in his passage into the shower and would have to walk out over the contaminated area following decontamination. This area should be given prime consideration for redesign.
Change rooms were inspected and found to be cramped although adequate.
At present there are two control points access into the controlled area.
Control is on an honor system and the radiation worker is expected to know which Radiation Work Permit he is going to work under.
Radiation Work Permits are maintained at the local sites along with a supply of appropriate protective clothing. At the inner control areas, where both guards and radiaticn safety techni-cians are stationed, dosimetry checks are made.
Office space for the health physics group seemed relatively cramped.
However, if the philosophy of the radiation protection supervisor is maintained, the technical and technician personnel will be kept moving and the office space will not be a congregating point.
Protective equipment decontamination areas were cramped.
The appraiser noted that highly contaminated articles coming in for decontamination were tracked across areas of lower level contamination.
The decon-tamination machines were vented to the same duct as the chemical fume hoods.
This apparently created problems in assuring an adequate face velocity of air into the hood.
'
Tools and contaminated parts decontamination areas were established on a local basis and were maintained under close surveillance.
Respiratory equipment fit and test areas were adequate for the purposes intended.
However, the area where respiratory equipment was issued and stored was dusty and not adequately sheltered against the weather.
The trailer in which those functions were carried out, had large holes punched through the floor and holes in the roof.
In numerous tours through the facilities, it was apparent that housekeeping was poor.
On sarious levels of the reactor building and turbine building contamination control was found to be marginally acceptable.
Clothing and equipment were found scattered about both in and out of the radiaton contamination zones.
In several locations, respirators were found thrown on top of storage containers, hung on the walls, or thrown on the floo *
,
,
.
.
I
6.2 Radiation Chemistry Facilities Radiation chemistry has several areas throughout the facility in which they perform their functions, however, the analytical chemistry laboratory was cramped and the possibility for radiation exposure
,
during the handling of radioactive samples was possible for personnel that occupied.the laboratory space area.
The fume hood vents are
combined with the vents from the laundry area and as a consequence do not seem to draw adequately. The face velocities of the hoods
were unknown and there was no evidence that they had been measured.
The radioanalytical laboratory was a dedicated space in the auxiliary office building, was well ventilated and well equipped and would serve well to backup the health physics counting needs.
7.0 Exit Interview and Meetings a
j The Appraisal Team members and the Region I Deputy Director met with
!
licensee representatves (identified in Annex A) at the Oyster Creek Nuclear Generating Station at the conclusion of the appraisal on May 23, 1980.
The appraisers summarized the purpose, scope and major findings of
.
!
the appraisal. The Deputy Director expressed concern to licensee represen-
'
tatives the seriousness of the program deficiencies identified by the appraisal team and solicited commitments for immediate actions to be taken in upgrading the radiation protection program in the following areas:
.
Establish provisions to maintain accumulative MPC hours of exposure to airborne radioactive material to demonstrate compliance with 10 CFR 20.103(b)(2).
Improve the quality of the present technician and supervisory staff
.
(contractor and station) by seeking assistance from outside consultants who possess strong supervisory and technical backgrounds.
The licensee representatives stated that they would take immediate corrective action to account for MPC hours but would need time to explore the availabil-ity of outside resources and would report back to Region I management within two weeks with proposed corrective ~ actions.
The licensee had made prior commitments to improve significant weaknesses identified in the emergency preparedness portion of the appraisal which are documented in a letter dated May 16, 1980 to Mr. I. R. Finfrock, Jr.,
Vice President, Jersey Central Power and Light Company from Mr. B. H.
Grier, Director, NRC, Region I.
The letter documented the following actions-were to be undertaken and completed by the end of the current outage and prior to resumption of operation of the Oyster Creek Nuclear Generating Station.
<
<
.. -..,, -
-. -,. -
_...mx-.
.-
-... - ~. - -..
.... - -
-
.
.
. - -...,,
, _. - -. - ~ _ _
.
.
o
A.
A clear description of the Oyster Creek Nuclear Generating Station emergency organization, including Corporate support personnel, shall be formulated to include:
(1) the development of the organizational structure for the command and control relationships of the various functional areas of emergency activities and (2) the assignment of individuals to the various area of functional activity by position or title and name.
8.
A review of all emergency plan implementing procedures shall be performed with appropriate revision to (1) eliminate existing con-tradictions, (2) correctly reflect existing types, locations and
~
uses of facilities and equipment, and (3) delineate the responsi-bilities assigned to the various elements of the emergency organi-zation.
C.
Appropriate training / retraining of all individuals assigned to the various functional areas of emergency response activities shall be conducted, and verification shall be performed that all such indivi-duals understand and are able to perform their assigned emergency duties in an effective manner.
The licensee's corrective actions with regard to the above commitments as they applied to the emergency preparedness portion of the appraisal were reviewed in a special inspection at the Oyster Creek facility, subsequent to the May 23, 1980 interview.
The inspection findings established that the commitments made by the licensee had been met and the results of the inspection were documented in Inspection Report No. 50-219/80-24.
On June 13, 1980, a meeting (requested by the licensee) was held in the Region I office to discuss the licensee's proposed corrective actions to upgrade certain areas of the Oyster Creek radiation protection program.
(NRC and licensee attendees are identified in Annex A).
During the meeting, licensee representatives presented proposed program improvements which included:
Reorganization of the Oyster Creek Radiation Protection Department and formation of the GPU Nuclear Corporation.
Assignment of overall responsibility for the radiation protection
.
program to the Vice President, Radiological Controls.
Outside consultant assistance (2) supervisors are to be edded to the
.
Oyster Creek staff for an indefinite period of time.
The training supervisor is to be transferred to Oyster Creek from
.
Three Mile Island Station to help establish training programs.
An individual from Three Mile Island experienced in performing Radiological Protection Audits, is to be assigned to the Oyster Creek facility with reporting responsibility to Mr. Finfroc a O
Increased Staffing:
There are plans for hiring a (Deputy) Manager
.
Radiation Protection to assist the present Manager, Radiological Control, consultants to assist in the personnel monitoring area and qualified technicians to strengthen the present staff, and to utilize qualified technicians from Three Mile Island to supplement the department staffing while formal training is being provided.
.
Procedures are being reviewed and a Revised Radiation Work Permit procedure will be forthcoming.
There will be extensive cleanup of the facility prior to startup.
.
The NRC personnel present indicated that the licensee's proposed program improvements were adequate and had no further questions at this tim r
.
o
Annex A to Report 50-219/80-17 Persons Contacted
- I. R. Finfrock, Vice President, Generation, JCP&L Co.
- P. R. Clark, Vice President, GPU Nuclear
- D. A. Ross, Manager, Nuclear Generation, JCP&L Co.
- R. W. Heward, Vice President, Radiological Control, GPU Nuclear
- M. F. Miles, Consultant, Basic Energy Technology Associates (BETA)
- J. T. Carroll, Station Manager, OCNGS
- J. L. Sullivan, Unit Superintendent, OCNGS
- W. Garvey, Director Station Administration, OCNGS
- D. W. Turner, Supervisor, Radiation Protection, OCNGS M. Vyenielo, Acting Supervisor, Operational Radiation Protection, General Electric Company L. Smialek, Supervisor, Radiological Engineering, OCNGS D. Arbach, Supervisor, Radiological Support, OCNGS F. Perry, Acting Foreman, Radiation Protection, General Dynamics / Electric Boat Division R. Kobayashi, Acting Foreman, Radiation Protection, General Electric Company R. Heffner, Foreman, Radiation Protecton, OCNGS B. Watson, Radiological Engineer, OCNGS R. Barrett, Training Department Supervisor, OCNGS J. Cook, Radiation Protection Training Instructor, OCNGS T. Gaffney, Instrument and Control Supervisor, OCNGS J. Early, Instrument and Control Supervisor, OCNGS NRC Personnel at the Exit Interview (Other than Appraisal Team Members)
J. M. Allan, Deputy Director, Region I Office L. E. Briggs, Senior Resident Inspector, Region I
- denotes those present at the preliminary exit interview conducted at the Oyster Creek Facility on May 23, 1980.
The auditors also held discussions with and interviewed other licensee and contractor employees. They included engineering, operations, quality assurance /
control, training, maintenance and radiological controls and emergency planning personnel.
Meetings Held Subsequent to the May 23, 1980 Exit Interview June 13, 1980 - Region I Office NRC B. H. Grier, Director, Region I J. M. Allan, Deputy Director, Region I G. H. Smith, Chief, FF&MS Branch, Region I
r a
o Annex A
D. R. Neely, Radiation Specialist, Region I R. R. Keimig, Chief, Reactor Projects Section No. 1, RO&NS Branch, Region I E. J. Brunner, Chief, RO&NS Branch, Region I R. L. Nimitz, Radiation Specialist, Region I 0. E. Donaldson, Radiation Specialist, Region I Licensee P. R. Clark, Vice President, Nuclear Activities, GPU Service Corp.
I. R. Finfrock, Vice President, Generation, JCP&L Company R. W. Heward, Vice President, Radiological Controls, GPU Service Corp.
D. W. Turner, Supervisor, Radiation Protection, JCP&L Company J. T. Carroll, Station Superintendent, JCP&L Company Licensee Contractors E. Clements, Health Physics Supervisor, Nuclear Support Services R. Garland, Health Physics Supervisor, Nuclear Suppport Services