IR 05000219/1987014

Insp Rept 50-219/87-14 on 870504-08 & 18-22.No Violations Noted.Major Areas Inspected:Organization,Staffing & Qualification of Radiological Protection Personnel, Respiratory Protection & Bioassay & Hot Particle Control

ML20216G271
Person / Time
Site:	Oyster Creek
Issue date:	06/22/1987
From:	Mcfadden J, Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216G193	List: IR 05000219/1987014 ML20216G188
References
50-219-87-14, NUDOCS 8707010056
Download: ML20216G271 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-14 Docket N License N DPR-11 Priority - Category C Licensee: GPU Nuclear Corporation 01ster Creek Nuclear Generating Station P.O. Box 388 Forked River, NJ 08731 Facility Name: Oyster Creek Nuclear Station  !

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Inspection At: Forked River, New Jersey Inspection Conducted: May 4-8 and May 18-22, 1987 2 - Inspectors- Al Ak 6 - 7 'L - Q' 4 - S. Sherbini,1adiation Specialist

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date l]'){ / ~ c 0 8 d' , -- h .% 5~$ j . McFadden, Senior Radiation Specialist date i Approved by: M M. Shanbaky, Chief

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Facilities Radiation Protection Section Inspection Summary: Inspection on May a-8 and May 18-22, 1987 (Inspection Report No. 50-219/87-14) i

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Areas Inspected: Routine, unannounced safety inspection of the radiological protection activities on site. Areas inspected included: organization, staffing and qualification of radiological protection personnel; the respiratory protection and bioassay programs; and hot particle control and skin dose assessmen Results: No violations were identifie plg7188's8?88%9 , G m

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DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel F. Applegate, Supervisor, Respirator Maintenance D. Arbach, Manager, Radiological Health

 *J. Barton, Deputy Director, Oyster Creek
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i P. Canale, Group Supervisor, Dosimetry K. Cielecy, Senior Administrator, Compensation

 *B. DeMerchant, Licensing Engineer   ,
 *M. Douches, Ops /QA    j M. Glashan, Supervisor, Station Services   i R. Hurley, Dosimetry Supervisor D. Kaulback, Manager, Station Services
 *J. Kowalski, Licensing Manager, Oyster Creek
 *B. Leavitt, Deputy Director, Radiological Controls M. Littleton, Manager, Radiological Engineering D. Miller, Radiological Engineer
 *D. Robillard, QA Lead Auditor   1 M. Slobodien, Director, Radiological Controls  I
 *J. Sullivan Jr. , Plant Operations Director  j K. Wolf, Radiological Engineer 1.2 NRC Personnel W. Bateman, Senior Resident Inspector   l
 *J. Wechselberger, Resident Inspector   i I
 * Indicates attendance at the exit meeting   '

2.0 Organization, Staffing and Qualifications The organization, staffing and qualifications of personnel in the Radiological Controls Department was reviewed as part of this i inspection. The following areas of weakness were identifie I The qualifications of some of the personnel in the department did not

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appear to meet the minimum educational and experience requirements of their positions as described in the position description sheet l These sheets were provided to the inspector by the section managers of the Radiological Controls Department. Further discussions with ' licensee representatives to resolve the discrepancies revealed appar-ent inconsistencies between company departments regarding the minimum requirements for the positions in question. Furthermore, some posi-tions did not appear to have any position description or minimum requirements. The licensee acknowledged that the position descrip-tion sheets give a misleading impression regarding the staffing level in the department. The licensee further stated that, despite the

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apparent in the discrepancie sheets are qualified to and the s between the stated that actual minimum occupy theirqualifications requirements

 - updated soon.the position  currentdescript positionsof the staff, theas presented The    ion  .

respiratory sheets The licensee staff Respiratory of both Protectiprotectionwill program be reviewedi also and at Oyster Creekon isthe s un Oyster Creek Supervisor (RPS) der the dire Engineering sectionand TMI progra s. This person is ction of a in that ment w might arise at a

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Radiological Engin the site. as His site.functioneer is toin the RadiologicalThe de protection stated Accordingprogram i toreNUREG

    - isTheno licensee 00 address adopted because the stated routine probl e RPS that s to be  need for that this f ems vested  a full in41, responsibility administered logical  by this individual n

two i d i time RPS at eacharrange-contr o po ls forControls s the RPS.one individual.or respiratory the into airborne isdepartmentependent in charge However, on the departments progrThe licensee program.tential airborneactivity, sit of air respirator am is ment is charge in The Maintenance The Radio-rwell as the areas, assignment of requirements forsampling, engineerin espirators. serviceof respirator g appeared to air , Construction, and intakes Facili , ent ry and The inspector systemcleaning, that provides maintenanc member of stated that ties e (MCF) departthe bioassay the Radiological The licenseeresponsible forCviolate the s intent of N function him activities i ontrolsUREG-0041 this divisionof department in that function thair for ,uppl even though responsibility for th that histhe positistated, RPSdepartment however,n e RPS, a at Oystat TMI theUnitMCF 2, is not The licensee licenseecooperation er furth e MCF on in the stated between MC also thatpersonnel this is organization assigned t doesdoes se this indeed exer stated that F, the RPS, The inspectorprogram has and beenhi i o s designeeaccomplished becauserespira the letter of statedn place forthis division of the on site The wor of the satisfy the intent does the recommendatiothat althougha respiratory. long time this and this doesand hasto proved effectiprotection appear arrangement wille beto func, tion that ffect ive ly. pection the notinsn appearin oes NUREG-0041, satisfy v it d The revea led that theappear to Review of the reviewed periodicallcontinued system effectivene respiratory y in future inspecti ss of on Respirators sMaintAir Sample ncluded Analy i protection program i

- Whole Body Counti enance ng   the following are and Issue    a Procedures  rogramdealing- Excreta Bioassay P with the above ar ea '

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. J apparent discrepancies between the minimum requirements as presented in the sheets and the actual qualifications of the staff, the staff are qualified to occupy their current position The licensee also stated that the position description sheets will be reviewed and updated soon, l The respiratory protection program is under the direction of a

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Respiratory Protection Supervisor (RPS). This person is in charge of both the Oyster Creek and TMI programs. The designee for the RPS at Oyster Creek is a Radiological Engineer in the Radiological Engineering section. His function is to address routine problems that might arise at the site. The licensee stated that this arrange-ment was adopted because there is no need for a full time RPS at each , site. According to NUREG-0041, responsibility for the respiratory j protection program is to be vested in one individua The licensee j stated that this individual is the RP However, the program is l administered by two independent departments on site. The Radio-logical Controls department is in charge of air sampling, engineering controls for airborne activity, respirator requirements for entry into potential airborne areas, assignment of intakes, and the bicassay program. The Maintenance, Construction, and Facilities (MCF) depart- ) ment is in charge of respirator cleaning, maintenance, and issue, as ! well as the service air system that provides air for supplied air q respirators. The inspector stated that this division of function I appeared to violate the intent of NUREG-0041 in that the RPS, a ' member of the Radiological Controls department at TMI Unit 2, is not responsible for activities in the MCF department at Oyster Cree The licensee stated, however, that the RPS does indeed exercise this 4 function even though his position in the organization does not give him responsibility for the MCF personnel assigned to respirator wor The licensee further stated that this is accomplished because of the cooperation between MCF, the RPS, and his designee on site. The licensee also stated that this division of the respiratory protection program has been in place for a long time and has proved effectiv l The inspector stated that although this does not appear to satisfy the letter of the recommendation in NUREG-0041, it does appear to satisfy the intent, and that the inspection revealeo that the system does appear to function effectively. The continued effectiveness of this arrangement will be reviewed periodically in future inspection .0 Respiratory Protection Program l Review of the respiratory protection program included the following area J

- Air Sample Analysis
- Respirator Maintenance and Issue
- Whole Body Counting
- Excreta Bioassay Program
- Procedures dealing with the above area :

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The following weaknesses were identified during the inspectio Air Sample Analysis l

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The sample counting procedure allows samples suspected of containing over 25% maximum permissible concentration based on field measurements to be counted on the gamma spectrometer without gross beta measurements. Although this is generally sound, the gamma ; spectrometer will not identify pure beta emitting isotopes if I presen This may result in underestimating the intake if based on gamma analysis alon Background checks on the counting instruments are made on a daily basis. However, the procedures do not specify quantitative criteria to allow a decision to be made regarding the acceptability of the background readin The guidance given the technician is qualitative and states in essence that a significant change in ; background is not acceptabl !

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The results of air sample counting are not recorded directly on the I air activity log sheet used to record counting data. Instead, the technician records the net count rate obtained from the sampl This practice makes it impossible to check the data sheet because the original data is not recorde Good practice requires that all ; data be recorded before any calculations are carried ou l

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Source checks are made daily on the counting instruments, and three i sigma acceptance criteria are established for these test However, there is little quality control performed on the counting instruments. Such quality control normally includes control charts for background and check sources, as well as the chi squared test, among other This ensures close control of the quality of the l counting dat Such practices are standard in quantitative analysis ; laboratorie ' Whole Body Counting

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The procedure for operation of the whole body counter requires that a QA duplicate count be performed approximately every fif tieth personnel count. This duplicate count is being performe However, there is no guidance in the procedure or otherwise to indicate how the results of this duplicate count are to be evaluated for acceptabilit The review of such data is being performed by visual examination of the duplicate count result Whole body counting procedures require, as part of the QA on the counter, that Radiological Engineering conduct a blind spike test of the counter using an NBS traceable source. This function appears to be performed only irregularly. No criteria are specified regarding the manner of determining acceptable performance, nor apparently are any explicit criteria being used to evaluate the test result m j F J l l

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The whole body, counter calibration procedures require that the efficiencv

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curves generated by the system computer during calibration be verified to ensure a good fit with manually generated points. The i procedure, however, does not indicate what manually generated points are, nor the criteria to use to determine that a good fit was obtaine Furthermore, this verification .is not being performe Procedure requires that the technician operating the whole body counter be provided periodically with decay-corrected activities for the sources used in calibrating the counte This is not currently being done, and the technicians are doing the decay corrections themselves. Although this is not in itself a serious problem, it ! does represent an example of deviation from procedural requirements without a good reason to do so. Since the validity of the counter ; data is dependent on the accuracy of the calibrations, such deviation ! frc crocedure should have been formalizec, and formal review of the decay corrections should have been implemente Whc's body counting QA procedures specify acceptance criteria for . eff'ciency calibrations in terms of the standard deviation of the' ! source activity. The procedure, however, cid not describe how the i sta-card deviation of the source activity is to be determine Rev'sw of the QA data revealed that the standard deviation was being inc:--ectly calculated and that the incor-ect standard deviation be' ; used led to acceptance limits that eere much wider than intence The licensee corrected the error before the end of this inspectio The caily source check of the whole body c anter uses acc?ptance I cr':s-ia based on the standard deviation c' the source check used in these test The procedure, however, provides an incorrect equation to calculate the star.dard deviation for use in determining the acceptance limits. The technicians were apparently not using this equation and were calculating the standard deviation correctl )

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The whole body counter operation is monitored under a contract with the manufacturer, Canberra. Licensee represertatives stated that, i as part of the contract, Canberra reviews the QA data performed on J the system. The inspector reviewed the reports provided to the l licensee by Canberra, but there was no indication in these reports i that Canberra does review the QA data. - Further discussions with the licensee indicated that there was no clear agreement between licensee representatives as to exactly what Canberra does.with the dat The licensee stated that this' situation is to be corrected soon because the licensee will take over this function from Canberra. This will be accomplished after licensee representatives are trained by Canberra on the details of operation of the whole body counter and the computer softwar i

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.      o Excreta Bioassay
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Bioassay procedure requires that the licensee ensure that the vendor performing the excreta bioassay participate in a recognized QA ; program. Bioassay procedure also requires that the results be

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reviewed and maintained by Radiological Engineering. The. licensee-was unable to provide the inspector with any data to indicate that this requirement is being me The licensee stated that it has been a practice to use urine

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analysis in place of the required whole body count upon employee termination in some cases. This practice has been used when the whole body counter was not available.because of equipment problem The inspector pointed out that urine analysis does not provide the same type of data as the whole body counter, and the two are therefore not directly interchangeable. This practice had been identified as inappropriate in a-licensee audit performed in 19841 but it has not been discontinued since the audit was published, '

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4.0 Radioactive (hot) particle Discussions with licensee representatives and review of skin , contamination reports and laundry records suggest that hot particles are l not encountered frequently at the sit Laundry records indicate one ! recent incident of a hot particle remaining on protective clothing after the clothing was laundered and returned to the site. Review'of th laundry operation and of skin dose assessment records revealed two ' weaknesses in this are R i

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Contaminated laundry is decontaminated and cleaned by an off-site contracto Clean laundry returned to the site is randomly sampled' to check for residual contamination. 'About 2% of the; returned pieces are checked. Discussions with the licensee, however, indicated that there does not appear to be any QA program to ensure consistent

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service and also to verify that the radiation survey methods used at i the laundry are sufficiently sensitive to detect any activity not l removed by the laundering proces The skin dose assessment method used by the licensee involves the - assumption that the' activity on the skin is uniformly distributed over an area equal to that of the window of the detector probe used to measure that activity. That area is typically.about'20 squar cm. The effect of this assumption is to lead to underestimation of' ol the skin dose by a factor of 20-30 if the contamination is in fact' , localized, such as in the case of a' hot particl j

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5.0 General Comments The general finding in this inspection concerns the audit functions on - site. As pointed out in several' instances above, many of the audit functions required by procedure are not being performed. Even-in the'

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0 cases of those that are performed, some audit findings are not being reviewed with sufficient care. Many quality control checks do not have quantitative criteria established to enable determination of the acceptability of the results. Closer technical overview appears to be needed in several areas of the Radiological Controls operation. These areas include the whole body counter, excreta bioassays, QA oversight of contractor operations, and general quality control practice Discussions with the licensee concerning these issues indicated that the licensee has already developed a procedure that specifies the types of audits to be performed and the frequencies of the audits. This procedure is in the review process and is expected to be in effect soo .0 Exit Meeting The inspector met with licensee representatives at the conclusion of the inspection on May 22, 1987. The inspector summarized the scope of the inspection and the finding .

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