IR 05000219/1980018
| ML19318A284 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/20/1980 |
| From: | Briggs L, Keimig R, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19318A283 | List: |
| References | |
| 50-219-80-18, NUDOCS 8006190153 | |
| Download: ML19318A284 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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Report No.
50-219/80-18 Docket No.
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Licen'se No. DPR-16 Priority Category C
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Licensee:
Jersey Central Power & Light Company
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Madison Avenue at Punch Bowl Road
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Morristown, New Jersey 07960
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Facility Name:
Oyster Creek Nuclear Power Station Meeting at:
USNRC, Region 1, King of Prussia, Pennsylvania Meeting conducted:
April 29,
Prepared by:
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[.E. Briggs,Reac ector date signed O
date signed
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~a s-m -cm Approved by:
P. J. Kna ief, Radh bion Support date signed
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Approvad by:
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[SectionNo.1,RO&NSBranch.R.KeimiNChief,f[eactorProjects date signed Meeting S cnary:
Enforcement Conference on April 29, 1980 (Report No. 50-219/80-18)
Special enforcement conference convened by Region I management to discuss NRC concerns and licensee corrective actio'ns arising from the NRC's Performance Appraisal Branch (PAB) inspection findings, radiation protection concerns resulting from recent Region I inspections, and actions to improve overall management controls. A forthcoming inspection by the Health Physics Appraisal Team was also discussed. The meeting was attended by senior licensee and Region I management and involved three hours in the Region I office by all attendees.
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Region I Form 12-1
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(Rev. August 77)
800619015 3 g
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DETAILS 1.
Attendees Jersey Central Power and Light Company Dr. S. Bartnoff, President, JCP&L J. Carroll, Station Manager P. Clark, Vice President, Nuclear Activities, GPU Service Corp.
T. Crimmins, Manager, Generation Engineering I. Finfrock, Vice President, Generation D. Gaines, Manager, Quality Assurance D. Ross, Manager, Nuclear Generation J. Sullivan, Unit Superintendent T. Tipton, Manager, Environmental Affairs D. Turner, HP Supervisor US Nuclear Regulatory Commission J. Allan, Deputy Director, Region I L. Briggs, Senior Resident Reactor Inspector, Oyster Creek E. Brunner, Chief, Reactor Operations and Nuclear Support Branch, Region I R. Keimig: Chief, Reactor Projects Section No. 1, RO&NS Branch, Region I
P. Knapp, Chief, Radiation Support Section, Fuel Facilities and Materials Safety Branch, Region I R. Nimitz, Radiation Specialist, NRC Region I G. Smith, Chief, Fuel Facilities and Materials Safety Branch, Region I J. Thomas, Resident Reactor Inspector, Oyster Creek Other US Nuclear Regulatory Commission Personnel Present P. McKee, DROI/IE:HQ D. Neely, Radiation Specialist, Region I S. Nowicki, Project Manager, OR/ DOR /NRR W. Paulson, Project Manager, OR/00R/NRR J. White, Radiation Specialist, Region I 2.
Meeting Summary Opening remarks by the Deputy Director, Region I, summarized the concerns further described below and included a discussion of the need to communicate these concerns directly to the senior licensee management j
present.
The purpose of the meeting was to discuss the licensee's corrective action concerning the items of noncompliance cited during the NRC's Performance Appraisal Branch (PAB) inspection (50-219/79-18)
and in the Notice of Violation transmitted by letter from V. Stello, Jr., Director, Office of Inspection and Enforcement dated February 20, i
1980.
Radiation protection concerns resulting from recent Region I
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inspections (50-219/80-03 and 80-11) and a forthcoming inspection by the Health Physics Appraisal Team were also discussed.
The necessity for improved communication from the licensee, particularly in the area of commitment date slippage, was emphasized.
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3.
Radiation Protection, Radioactive Waste Program, and Training of Non-Licensed Personnel As a result of the PAB inspection, the licensee had made 65 commitments for corrective action in the areas under discussion.
Within the 10 days preceeding this meeting, a status review, including a site visit,
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had been completed and showed that, of the 65 commitments,14 had been completed and action on the remaining 51 was in progress and on schedule.
Regional management requested and received confirmation on the following points relating
+n the inspection, subsequent enforcement correspondence and the licens0e's response to the Notice of Violation from I. R.
Finfrock Jr., JCP&L Co. Vice President, Generation, dated March 17, 1980.
(Items in parentheses refer to the licensee's reply or attachments to it.)
a.
Radiation Protection In connection with the radiological control program, the licensee stated that a Technical Specification change request was to be submitted May 1, 1980 to change, among other things, olant-staff organization to have the Supervisor of Radiation Protection report directly to the Station Manager.
Regional management requested written confirmation of this commitment.
b.
Radioactive Waste Program Regional management requested information and a completion date i
for filling the position of Supervisor of Radwaste Operations (Attachment B, Page 9). The licensee responded that an individual, presently employed at the site was being interviewed and evaluated for this position.
If the outcome is satisfactory he will be appointed by July 1, 1980 or an acting Supervisor of Radwaste Operations, who will be able to devote his full time to this' position, will be appointed by that date.
Regional management requested written confirmation of this commitment.
In response to a similar request regarding the position of Radwaste Shipping Supervisor, (Attachment B, Page 9), the licensee stated that an individual was appointed as acting Radwaste Shipping Supervisor the previous week and that the position will be filled on a permanent, rather than acting, basis in the near future.
Regional management indicated that proper packaging and shipping of radioactive waste is a particularly important matter.
The
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licensee acknowledged t'
and described 'the. steps being taken
to illustrate the degree of attention ;?fs area is receiving at Oystar Creek.
c.
Trainina of Non-Licensed Personnel Regional management indicated that, in accordance with a licensee
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commitment, a Manager of Training was to be named by May 1,1980
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(Attachment B, Page 3) and emphasized that this position was
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considered to be extremely important.
The licensee agreed and
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l reported that every effort would be made to meet this deadline;
if not, Region I would be notified and a new date would be established.
Regional management also indicated that, in accordance with a licensee commitment, the Radiation Protection Training Coordinator is to audit / evaluate the training program for radiation workers
" periodically." The licensee was asked to specify the frequency i
of audit / evaluation.
The Supervisor of Radiation Protection stated that the Radiation Protection Training Coordinator would
conduct this activity on a continuing basis and would report
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findings to hin monthly.
d.
Calibration of Air Monitors
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Regional management stated that calibration of environmental air monitors had not been addressed in the-licensee's response to the enforcement correspondence.
The licensee stated that this had occurred through oversight r.nd that the procedures would be implemented and the samplers would be calibrated by June 30, 1980.
Regional management requested written confirmation of this commitment.
4.
Concerns Identified as a Result of Recent Health Physics Inspections Regional management stated that inspection and. enforcement actions in the radiation protection area over the past 19 months had been reviewed
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and that, including the previously mentioned commitments resulting from the Performance Appraisal Branch inspection, the 1icensee has made a
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total of 102 commitments in the radiation protection, radioactive waste program and training areas.
Data gathered by a regional inspector supplemented by information supplied by the licensee during and after the meeting established that of the 102 commitments, 42 had been completed on time, action on 56 commitments was in progress and on schedule, and 4 commitments were met but not on schedule.
(Audit of the Oyster Creek radioactive waste program and placement of a notice on respiratory face seal in the log book were both approximately one month late; realignment of the station organization was completed 5 months late and review and revision of CRD rebuild procedures was completed 8
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months late.)
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Regional management stated that commitments must be completed on schedule unless extenuating circumstances, beyond the licensee's control, are encountered.
If this should occur, the licensee must inform the' regional office and obtain agreement on a new date.
Regional management further stated that greater licensee attention to this matter was required.
Regional management indicated that recent Health Physics inspections (especially inspectio1s 50-219/80-03 and 50-219/80-11) were a scurce of heightened concern.
With regard to inspection 80-11, it was noted that as a result of rewriting and simplifying procedures,the Radiation Work Permit (RWP)
procedure had been weakened to an unacceptable level.
This combined with the lack of qualified radiation protection technician coverage had resulted in a r
- r breakdown of basic Health Physics protection.
With regard to inspection 80-03, Regional management stated that the finding of inadequate control of the fittings for the breathing air
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supply was particularly disturbing because it created a condition under which a worker could be exposed to unsafe breathing air.
It was noted that corrective action was taken immediately by the licensee
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upon inspector discovery to eliminate this problem.
Regional management's review of the 22 radiation protection and radioactive waste system related items of noncompliance since the civil penalty action in January 1979 revealed that 8 items were related to inadequate audits or technical evaluations, 8 were related to the use of inadequate procedures and 6 were related to inadequate training or qualification of personnel.
However, licensee commitments had been made in each of these areas and are among the 102 commitments previously discussed.
Through full implementation of licensee' commitments,the problems, indicated by the item of noncompliance, should be fully corrected.
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Health Physics Appraisal inspection Regional management explained that a NRC appraisal of the Health Physics Program at Oyster Creek was to begin in May, 1980 and would include several manweeks of inspector time at the site.
The Health Physics Appraisal inspection was described as a comprehensive review of the radiation protection program at all nuclear power plant licensees.
This review will include matters beyond current NRC regulations and is a substitute for routine NRC radiation protection inspections.
This appraisal also will provide a clear picture of further licensee (Jersey Central Power & Light Company) progress in meeting commitments and eliminating items of noncompliance.
Regional management stated that major negative findings in this appraisal would have a direct bearing on continued plant operation and that the NRC would not hesitate to shut down operations whenever inspection findings warranted this action.
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6.
Quality Assurance Program and Audits At the time of the PAB inspection, there were 143 open Nonconformance/Cor-rective Action Required Reports (NC/ CAR's).
This appeared to be an excessive number of open items; in addition, there was no system to segregate safety related from non-safety related items.
The licensee stated that 143 NC/ CAR's is not a large number since there are over 1000 issued per year.
There were over 400 issued in the first three months of 1980 and 451 closed out in the same time period.
The majority of NC/ CAR's are non-safety related with approximately one third addressing procurement items.
The licensee committea to segregate safety related from non-safety re'ated items; in addition, all presently open safety related NC/ CAR's will be closed out prior to restart and in a prompt, timely manner thereafter.
7.
Maintenance and Modifications Program The PAB inspection identified areas in the maintenance and modification program that were considered to be less than satisfactory.
In response to Region I concerns in this area, the licensee stated that additional engineers had been assigned specifically to the preventive maintenance program.
This increased effort should reduce the problems in this area which were due primarily to sloppy bookkeeping and improve licensee performance in the areas of equipment history, documentation of post maintenance testing, material traceability and general paper work followup.
8.
Fire Protection / Prevention Region I management asked the licensee to further explain their program concerning the new fire system installation and, in particular, the method used to detect deficiencies in construction quality prior to system turnover to the plant for operation.
The licensee stated that near the completion of system construction or modification, a system walk down is performed and all identified deficiencies are documented.
All identified deficiencies must be corrected or engineering justification provided prior to system turnover.
The licensee further stated that many items identified by PAB were already identified by their own personnel and that system construction had not yet progressed to the point that the licensee considered sufficient to initiate a full system walkdown.
Vnen questioned about the open fire doors, the licensee responded that a guard was stationed at the subject doors, as directed by security procedures, and had been instructed concerning appropriate actions
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should a fire emergency occur.
It was also noted that security procedures i
take precedence over fire protection procedures.
The Fire Hazards procedure has been revised to agree with security procedures.
The licensee also stated that other procedures had been reviewed and no other conflicts with security procedures had been identified.
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9.
_ Inservice Inspection and Pump and Valve Inservice Testina Region I management addressed the areas of the Inservice Inspection (ISI) program that PA8 perceived as poor, principally the fractionization of responsibilities between the QA Department, plant staff and contractors.
The licensee stated that the ISI program was under the Management Control Supervisor in September 1979.
Due to experience during this current outage, and the magnitude of the next 10 year program, the ISI program will be assigned to the Plant Engineering Department and under direct control of the plant staff.
The licensee further stated that
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the first 10 year ISI program was almost 100 percent complete and that all documents required to verify the first 10 year cycle had been accumulated into one manual. The comprehensive review of the ISI program performed by the licensee indicated that no additional ISI needed to be performed other than what was previously scheduled for the current outage.
This documentation and the ISI accomplished and scheduled was reviewed and found acceptable by Region I inspectors (Report No. 50219/80-09).
Region I expressed concern about the Pump and Valve ISI Program.
This program was due to be implemented on December 8, 1979.
Recent Region I inspection (50-219/80-10) of the subject program resulted in an item of noncompliance for failure to implement the subject program.
The licensee stated that program development was in an active status and that the previously discussed reorganization would correct the current problem.
10.
Commitment Dates Review Regional management stated that several commitment dates appearing in the response respresented an excessively extended time period and specific dates were addressed by the region.
The licensee responded that any shortening of the time period would have to be done at the expense of another commitment.
The licensee noted that one date (Item B.6) was a typographical error and should be September 1, 1980 vice 1981.
Region I reviewed the specific items and corrective actions and determined that none were sufficiently significant to warrant setting aside other more significant actions to speed up completion.
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11.
Concluding Comments The Deputy Director, Region I, in review, commented that the NRC has identified 82 licensee commitments stemming from the PAB inspection,
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including the 65 commitments identified in Section 3 of this report.
Completion of these commitments and the additional commitments identified in Section 4 of this report should result in a general
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improvement of management controls in the areas of training, radiological controls, maintenance / preventive maintenance, modifications, Inservice Inspection, and quality assurance controls.
However, in view of past performance in meeting commitments, it was emphasized that the licensee
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must closely monitor progress on these items and keep NRC informed of commitment dates that may not be met due to extenuating circumstances.
As soon as management perceives that a commitment date may not be met, this fact must be communicated to Region I management with firm rationale for not meeting that date.
Each matter will be reviewed by Region I and judged as to its significance and affect on public health and safety before an extension is granted. The licensee's progress will be closely monitored by the NRC and the effectiveness of current Health Physics programs and corrective actions will be examined by a Health Physics Appraisal Team inspection which will commence on May 12, 1980. The inspection will consist of a minimum of three inspectors who will conduct a general overview of the Health Physics Program.
It was again emphasized that failure to meet the commitments.to take corrective actions could result in a delay of the plant startup.
The licensee representatives acknowledged the above comments and stated that the matters would be taken under serious advisement.
They further stated their intention to improve performance in the areas discussed.
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