IR 05000219/1986013
| ML20211A266 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/29/1986 |
| From: | Lequia D, Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20211A245 | List: |
| References | |
| 50-219-86-13, NUDOCS 8606110099 | |
| Download: ML20211A266 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 86-13 Docket No.
50-219
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l License'No.
DPR-16 Licensee: GPU Nuclear Corporation P.O. Box 388 Forked River, New Jersey 08731
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Facility Name: Oyster Creek Nuclear Station l
Inspection At: Forked River, New Jersey Inspection Conducted: April 21-25, 1986 Inspectors:
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Sami Sherbini, Radiation Specialist date Facilities Radiation Protection Section i
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_arryl LeQuif,JadiaM6n Specialist date
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Facilities Ra'Hiation Protection Section Approved by:
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Mohamed ShanFaky, Chief, Fact 11 ties date
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Radiation Protection Sectior.
Inspection Summary:
Inspection on April 21-25, 1986 (Report No.
50-219/86-13).
j Areas Inspected: Unannounced, routine inspection of refueling outage l
activities, including: health physics program organization and staffing,
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external exposure control, internal exposure control, contamination control, l
ALARA, and training.
Results: No violations identified.
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DETAILS 1.0 Persons Contacted During the course of this outage inspection the following personnel were contacted or interviewed:
1.1 Licensee Personnel
- J. Barton, Deputy Director Oyster Creek
- 0. Turner, Radiological Controls Director
- R. Ritthamel, Manager Industrial Safety and Health
- A. Mills, Industrial Safety and Health Manager J. Leavett, Deputy Director Radiological Controls J. Kowalski, Licensing Manager
- B. Hohman, Licensing Engineer C. Pollard, Radiological / Industrial Safety Assessor 1.2 NRC Personnel
- W. Bateman - Sr. Resident Inspector Other licensee or contractor employees were also contacted or interviewed during this inspection.
- Attended the Exit Interview on April 25, 1986.
2.0 Purpose The purpose of this routine inspcction was to review the implementation of radiological controls relative to the current refueling outage. Areas inspected included:
- Organization and staffing of the HP program.
- External exposure control.
- Internal exposure control.
- ALARA program.
- Some aspects of training with respect to the outage.
3.0 Posting of Radiation Signs and Barriers Inspection of work areas in the radiological controls area (RCA) revealed that the licensee has provided extensive postings of radiation and contamination areas. The signs were generally well placed and clearly visible. High radiation areas and contamination areas were clearly demarcated by ropes and stanchion.
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The whole RCA area was in general remarkably clean and uncluttered.
The anti-contamination dressing points within the RCA were orderly and well-stocked.
Some concern was expressed by the inspector regarding the licensee's practice of controlling the entrances to roped-off high radiation areas.
Entrances to high radiation areas that are also contamination areas are not roped-off but are marked by a step-off pad (clean).
Step-off pads are used in the industry to indicate the access point to contaminated areas. The concern was that personnel may not notice that these pads also served as access points to high radiation areas, thus leading to inadvertent exposures. The licensee assured the inspector that there were no reported incidents of this kind and that there was little chance of such incidents occurring.
This is because the access points were clearly labeled on both sides of the step-off pad, and also because the radiation workers were well indoctrinated regarding this practice. The licensee also stated that they believed that placing a removable rope across such access points would be detrimental in view of the increased effort that would be required of personnel dressed in anti-contamination gear. They stated that there is also a possibility of contamination of such ropes.
The inspector examined all roped-off areas in the RCA, reviewed training course outlines, and discussed this matter with training coordinators. Based on this review it appears that the controls of these areas are adeauate.
Some posting weaknesses were identified in the RCA.
Examples included conflicting labels, such as areas labeled " contamination" and "high contamination" areas simultaneously, or missing "RWP Required" signs.
These instances vere pointed out to the licensee. The licensee stated that posting will be corrected.
Some were corrected before the end of the inspection.
A review of the radiological incident reports compiled by the licensee showed multiple instances of radiation workers entering the RCA without their TLD dosimeters.
Investigation suggested that a possible cause may be inadequate posting at the RCA access points. Signs were provided at these locations indicating that personal dosimetry is required.
The signs, however, were poorly located with respect to the entrance and could be missed. Furthermore, there appeared to be some confusion as to the meaning of personal dosimetry. Correctly interpreted, it means both TLD and self reading dosimeters (SRD).
The SRDs are issued at the RCA access point but the TLD is issued together with the picture badge at the station's access points. These weaknesses in posting were pointed out to the licensee.
The licensee stated that steps will be taken to correct these weaknesse.
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4.0 ALARA The ALARA program and its implementation during the outage were discussed with the licensee. These discussions revealed that both site and corporate organizations include adequate numbers of ALARA engineering staff. ALARA reviews are also being conducted on all jobs involving potentially significant exposure. The main weakness of the ALARA program, however, appears to be in the areas of man-rem goal setting and man-rem accountability for specific jobs. Goals are currently being set on the basis of past outage performance with no account taken of the scope of planned work. The goals, therefore, have little bearing on outage work and cannot serve as a useful management tool for making realistic assess-ments of the degree to which individual tasks are being carried out with proper consideration to ALARA measures.
Furthermore, there does not appear to be any clear accountability for ALARA performance of individual jobs, and little upper management eraphasis on the importance of minimizing exposures. These weaknesses were pointed out to the licensee and were acknowledged.
The licensee pointed out that steps have already been taken to correct the situation.
This item will be reviewed in a subsequent insnection. (50-219/86-13-01)
5.0 Air Sampling Inspection of the licensee's air sampling, respirator programs, and air sample data revealed that the licensee makes decisions relating to res-piratory protection of workers on the basis of a combination of air sampling data and past experience with similar work.
This approach is generally considered to be good health physics practice.
However, the licensee has weakened this practice considerably by placing a major emphasis on past experience and relegating air sampling to a relatively minor role. The current licensee's program may not provide for a timely measurements and assessment of airborne concentrations before and during radiological operations. As a result, the licensee's air sampling program has degenerated to a program devoted almost exclusively to sampling for the purpose of assigning intakes to workers after job completion.
This practice is apparently based on the assumption that jobs performed repeatedly will produce the same radiological conditions and hazards every time.
This assumption is not supported by experience at the licensee's facility and in the industry in general, and therefore may not provide a technically sound basis for a respiratory protection program.
The licensee's practice is to take very few or no air samples prior to the start of jobs in areas that are potentially airborne contamination areas.
For air samples collected during radiological operations, the program does not provide for methods to expedite analysis and evaluation of samples collected. This may result in a lack of timely action by the HP organization. These concerns have been discussed with the
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licensee. The licensee stated that they understand the problem and will
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review the matter and take appropriate action.
This item will be reviewed in a future inspection (50-219/86-13-02).
6.0 Exit Interview
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The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on April 25, 1986. The inspector summarized the scope of the inspection and the findings.
At no time during this inspection was written material provided to the licensee by the inspector.
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