IR 05000219/1989026
| ML20005D937 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/12/1989 |
| From: | Pasciak W, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005D936 | List: |
| References | |
| 50-219-89-26, NUDOCS 9001020289 | |
| Download: ML20005D937 (16) | |
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U. S. NUCLEAR REGULATORY COMISSION i
REGION I
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f Report No. 50-219/89-26 i'
Docket No. 50-219 f
License No. DPR-16 q
Licensee: GPU Nuclear Corporation
P. D. Box 355 Forked River, New Jersey 08731
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Facility Name: Oyster Creek Nuclear Generating Station
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Inspection At:
Forked River, New Jersey Inspection Conducted: October 30 November 3 and November 13-16, 1989
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IlhM'27 P
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Inspector:
5. 5herbin1,7enior Radiation Specialist d4te Facilities Radiation Protection Section
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Approved by:
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8^7 Chief, facilities Radiation
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W. Pascisk, ion Section, DRSS Protect TJB9 (Report No. 50-219/pection on October 30 - November 3 and November 13 Inspection Summary: Ins 89 26)
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Areas Inspected: A routine unannounced inspection of the radiological controls program on site. The inspection was devoted mainly to reviewing actions to resolve items previously identified during NRC inspections, and the program elements related to these items.
Results: Within the scope of this inspection, no violations were identified.
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9001020289 891215 PDR ADOCK 05000219
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i DETAILS 1.0 Personnel Contacted 1.1 Licensee personnel J. DeBlasio, Manager, Plant Engineering
- M. Heller, Deputy Director, Oyster Creek (Mechanical)
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J. Barton
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D. Miller, Licensing Engineer
, Radiological Engineer J. Rogers Li
- M.Slobodlen,censingEngineerDirector, Radiological Controls Oyster Creek
- D. Smith, Manager, Radiological Controls Field Operations
- D. Tuttle, Chairman Rad Con Performance Task Force
- K. Wolfe, Manager, kadiological Engineering 1.2 NRC Personnel
i E. Collins, Senior Resident Inspector
- D. Lew, jeeReskdentinspector M. Baner Resident inspector
- Indicates attendance at the exit meeting.
2.0 Status of Previously Identified items The items shown as closed in this report were closed on the basis of the immediate corrective actions taken. In some cases, the corrective actions were not expected to produce observable improvements in the program immediately following their initiation because of their long term nature.
In such cases, the success of these measures will be reviewed during future inspections. Also, here were several weaknesses in the radiologicala review of the c
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items showed that t
controls program on site that appeared to have contributed to several of l
the observed deficiencies. A review of licensee documents showed that most,
if not all, of these weaknesses were identified by the licensee during
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internal audits and critiques.
A discussion of these programmatic weaknesses and licensee actions to correct them is given in Sections 3.0 and 4.0 of this report.
2.1 (Closed) Noncompliance Items (86 41-01) and (86-41-02)
i A contractor technician received an unplanned radiation exposure that resulted in him exceeding his administrative whole body limit of 1250 mrem by a small amount. Activities in progress when the exposure was received involved working on top of a cask containing highly radioactive resin that caused the radiation fields in the work area to reach levels of 40 R/hr at some locations. The noncompliance items were failure to instruct the
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i workers on the huards and hold points that should be observed in this ty)e of work and the radiological controls technician who was covering the jo)
failed lo survey the work area before the workers started their activities, The NRC inspection identified the following as contributing factors:
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. Non specific RWP requirements. The RWP covered all aspects of the resin i
operation, including transfer and dewatering, and consequently the survey
requirements were non-specific in that no survey hold points were specified.
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. The ALARA review attached to the RWP did not amplify on the requirements I
and precautions to be observed, as is usual for jobs involving the risk of i
exposure to intense radiation fields.
. The radiological controls technician assigned to cover the job was an experienced senior technician but wa'; not familiar with resin transfer operations. He was not instructed or trained before being assigned to the job.
The licensee disagreed that the RWP or ALARA review may have been inadequate. They also disagreed that the training of the radiological controls technician may have been inadequate. The licensee maintained that the technician was a senior technician and should have been able to use his knowledge and experience to control the job better than he did. The licensee also maintained that the technician was aware that the exposure rates in the area would be in the neighborhood of 10 R/hr and that, although the actual rate was unex ectedly higher, and was close to 40 R/hr, the 10 R/hr value was sufficienti high to alert him to exercise appropriate care in controlling i e job.
Corrective actions following the incident included disqualifying the radiological controls technician, followed by retraining and requalification. The ALARA review was modified to inc'ude more s)ecific information and the details of the incident were made part of tie required ongoing training for all the radiological controls technicians.
2.2 (Closed) Inspector Follow up Item (87 02 01)
A Service Air line feeding a s)arger in the Filter Sludge Tank of the Reactor Water Cleanup System 1WCS located in the Reactor Building was contaminated by back flow of r(adioa)ctive water into the line. The back flow
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was apparently caused by a stop valve that was left open.
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The licensee completed a study to determine all potential pathways that could lead to cross contamination of the Service Air System. The study showed that, in addition to the line from the RWCS, another potential
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l Resin Tank in the New Radwaste Building.ying air to the Radwaste SpentThe lines l source of contamination was a line suppl Air System to these components have been modified and have been fitted with backflow preventers that include double check valves. These modifications should prevent contamination of the Service Air System from these sources of radioactivity.
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2.3 (Closed) Inspector follow up Item (87 02 02)
, of the Environmental Section 3.3, "Onsite Meteorological Monitoring" inadvertently deleted from TechnicalSpecificationsforthefacilityIsion.Thisdeletionwas was the Technical Specifications during a rev identified during an NRC inspection, and the licensee had committed to submit to the NRC an application to reinstate that section. The licensee subsequently determined that the section was in fact redundant because onsite meteorological monitoring is mandated by other regulatory mustinclude,(H)statesthat requirements.SpecificallylysisReport(PSkR 10 CFR Part 50 ppendix E II the Preliminary Safety Ana in part,
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.. methods for identifying the degree of ser ousness and potential scope of
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radiological consequences of emergency situations within and outside the meteorologicalinformation...*.Alsoincludingcapabilitiesfordoseprojectionusingrealtime site boundary NUREG 0737, Clarification of TMI Action Plan Requirements", Section llI. A.2, * Improving Licensee Emergency Preparedness - Long Term", states that "..a meteorological measurements program.....shall provide the basic meteorological parameters direction and speed and an indicator of atmospheric stability)(windon display in the control room". This requirement is also included in the licensee s Emergency Response Plan. The licensee's meteorological tower is located in forked River and is described in the Final Safety Analysis Report (FSAR),
Section 2.3.3. Based on the above requirements the licensee is currently required to have a real time meteorology capability. This satisfies the
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requirement that would be im)osed by the deleted section of the Technical
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Specifications. Therefore, tie deleted Section 3.3 of the Technical Specifications is considered redundant, and the licensee need not apply for its reinstatement.
2.4 (0 pen) Inspector follow-up Item (87-02 03)
NRC Bulletin 8010,itored, Uncontrolled Release of Radioactivity To The* Contamina Potential for Unmon Environment" required licensees to review their facilities for possible cross contamlnation of clean systems and the possible existence of unmonitored release pathways. As corrective action, the Bulletin specified that if the clean systems are, or become, contaminated, they are not to be used until they have been decontaminated. If the system is radioactive and it is found acceptable to operate as such, then any potential release must be monitored and controlled and maintained ALARA. If operation of the system as a radioactive system constitutes an unreviewed safety question, the operation of the system must be suspended until Commission approval.
The licensee commissioned a study to examine the problem. That study, performed by a contractor engineering firm, was completed in 1982. The report, TDR-393 " Drain Identification Study for the Oyster Creek Nuclear Generating Station"is area (RCA) as potential pathways for unmonitor identified several building and area drains within the radiological contro
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releases of radioactive effluents to the environment. The study also identified potential cross contamination pathways between contaminated and clean systems.
The licensee stated that one potential release pathway identified in the report, namely the discharge from Turbine Building Sump 1-5, is now being the licensee was unable to monitored by a radiation detector. However locate,duringthisinspection,documentatIondescribingactionsregarding the other identified release pathways. This item will therefore remain open and will be reviewed during a future inspection.
2.5 (Closed) Inspector Follow-up Item (87-02-04)
including lack of This item addressed weaknesses in the ALARA program,f jobs in progress, methodology or requirements for performing reviews o lack of clear criteria for assessing the effectiveness of the ALAfiA program, and questionable utility of ALARA goals and objectives in view of the large and repeated discrepancies between these and actual man rem values.
Although these weaknesses in the ALARA program have not been corrected to date, the licensee has initiated improvements, both short and long term. It is premature to assess the success of this effort, but the program will be reviewed during a future inspection.
2.6 (Closed) Inspector Follow-up Item (87-02-05)
The NRC inspector noted that survey information for entry on certain RWPs was not readily available. Personnel were being allowed entry into high radiation areas without ensuring that they were aware of the latest survey data for these areas.
Access control into the radiological controls areas of the plant has been improved since this item was identified. The access control system was improved, and procedures for access into high radiation and locked high radiation areas were also improved. These areas will be reviewed during future inspections to ensure continued adherence to the improved methods of control.
2.7' (Closed) Inspector Follow up Item (87-02-06)
This item addresses concerns regarding air sampling practices on site.
Specifically, there was concern that air samples were not always collected prior to entry into areas of potential airborne contamination and that in some cases the collected air samples were not analyzed and reviewed in a timely manner.
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Corrective actions on this item included purchase of a real time iodine monitor to provide )rompt warning of airborne iodines in the work area.
This action diminisies the urgency for counting iodine samples in the counting room. Routine samples are field checked immediately after collection and before being sent to the count room to quickly identify any sample that may indicate airborne activity. The licensee also planc to expand the sampic counting capabilities by purchase of an additional gamma spectrometer. This weald bring the total number of spectrometers in the count room to three, thus relieving sample backlogs that have been observed during outages. Plans are also in place to upgrade the computer capabilities in the count room, allowing automation of some functions involved in sample counting and analysis, and therefore further increasin the efficiency of this facility and the accuracy of the results produced.g 2.8 (Closed) Noncompliance Item (87 39 01)
Access to the Drywell, which is a locked high radiation area, was not maintained under positive control at all times, in violation of the requirements of Technical Specifications Section 6.13. Contributing factors included the following:
. Misunderstanding of the functions of the security guard at the Drywell access point.
. Misunderstandings regarding the functions of radiological controls in manning the access point.
. Vagueness of the requirements in the procedure that addresses these functions (Station Procedure 233).
Corrective actions taken by the licensee included providing clarification and directions to the radiological controls personnel regarding requirements for mar.ning the Drywell access point; the procedure genrning access to locked high radiation areas has been revised to improve control over such areas; and radiological controls personnel were required to review Station Procedure 233 as well as the NRC Inspection Report that discussed this incident. A review of the revised Drywell access procedure showed that the responsibilities of the security guard have been clarified.
According to the procedure, the security guard may assume responsibility for the access point provided there is nobody in the Drywell and that he does not allow anybody to go into the Drywell unless a radiological controls technician is present at the access point. The security guard must be briefed on these responsibilities, and the briefing must be logged in the Drywell log book.
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2.3 (Closed) Noncompliance items (87-39 02) and (87 39 03)
These items address the same incident involved in the item of noncompliance discussed above (Section 2.8 of this report)ithout the instrumentation
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the Drywell, a locked high radiation area, w specified in the RWP and without the instrumentation required by Technical Specifications.
The licensee stated in response to this item that a review of their rmrds indicated that this was an isolated incident and did not represent general work practices on site. Disciplinary action was taken against the workers i
involved, ranging from written reprimands to termination. In addition, the i
pre-job briefing format has been improved to ensure that the requirements of the job and those specified in the RWP are clearly understood by the workers involved. These briefings will also be documented.
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2.10 (Closed) Inspector Follow-up Item (87-39 04)
i The noncompliance items discussed above (Sections 2.8 and 2.9) appeared to suggest that radiation worker training may not be sufficiently effective in ensuring that radiation workers understood the requirements for entry into radiologically controlled areas and the role of the RWP in controlling such
entries. The radiation worker training program was to be reviewed to determine its adequacy. See Section 3.0 of this report for further
discussion of this issue.
2.11 (Closed) Noncompliance Item (88-1101) and Unresolved item (88 11 02)
Work in the torus rocm to install a cathodic protection system started on February 19, 1988. On April 5,d during this period were nonuniform and that it was discovered that the radiation fields i
in which the workers had worke the placement of dosimetry was not appropriate for these nonuniform fields.
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The noncompliance item was for failure to perform an adequate survey of the radiation area prior to and during work in the torus room. About thirty workers were involved in this incident. The unresolved item was 03ened because the licensee's official critique of the incident had not seen completed at the time of the NRC inspection cf the incident.
The immediate corrective action was to suspend work pending investigation.
The RWP was modified to require appropriate placement of dosimetry. Other i
corrective actions included improving job briefings and reviewing the incident with the radiological controls technicians. Dose assessments were also done for the workers involved in that job during the period in question. The licensee also completed the formal critique of the incident.
i Findings in the critique included the following:
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. The radiological controls technician (RCT) did not understand the implications of the non-uniform fields in the torus roo w;
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. There was no record indicating that the RCT had read the applicable procedure on performing radiation surveys.
. The RCT was poorly supervised by the radiological controls supervisory staff.
. The technical and supervhory staff of the radiological controls department had available to them information that would have alerted them to the problem but did not identify the potential for such a problem.
. Procedural compliance was not strictly enforced by the supervisory and management staff of the radiological controls department.
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. Contractor technicians often lack adequate experience or are poorly trained.
The findings of this critique suggest that the root causes of the problem
are broader than the actions connected with this particular incident and
. involve significant weaknesses in the radiological controls program on site. See Section 3.0 of this report for further discussion of these issues.
2.12 (Closed) Noncompliance Item (88-31-01)
i This item involved two instances of failure to follow procedures:
h(a)d removal showed positive iodine activity above(RB) following reactor lodine samples taken in the Reactor Building ea an action level i
specified in station procedures. The required action activity to the appropriate supervisor) was not taken(reporting theby the counting roo
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(b) A radiation worker entered the Drywell with two low range self reading dosimeters (SRD) instead of a low range and a high range dosimeter. Both low range dosimeters were offscale when the worker exited the Drywell.
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A number of root causes for item (a)itique of the incident. These included:
were identified in the NRC Inspection
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report and also in the licensee's cr
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. There is no effective program in place to assign priorities to samples received in the count room depending on their importance for worker safety.
. Samples requested by the radiological controls supervisor in charge of the area in question were w t taken when they were requested but at a much later time.
. The technicians who collected the sample took the wrong type of sample.
The supervisor had requested samples to verify iodine concentrations in the area but the technicians collected particulate samples without using iodine sampling cartridges.
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. The counting room is not adequately equipped and there is often a backlog of samples waiting to be counted.
. There was poor shift turnover in the counting room. The outgoing technician did not adequately explain to the incoming technician the situation regarding samples waiting to be counted.
. A long time elapsed between collecting the samples and counting them.
This was partly due to lack of sample prioritization and partly due to sample backlog in the count room.
. The radiological technicians in charge on the refueling floor of the RB were inexperienced and had problems collecting air sam)les. Two of the
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technicians had been on site for one week and two had seen on site for one
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. The technicians assigned to collect the air samples had not been signed off ~ on their practical factors training.
The licensee's corrective actions for item (a) included counseling the radiological controls staff on the need to report radiciodine activities in excess of the action level to the cognizant supervisor as soon as possible.
A real time iodine monitor was also purchased for use on the refueling floor.
The corrective actions for item (b) included briefing the radiological controls technicians regarding the need to verify that the proper range pocket dosimeters are used in accordance with the RWP. See also Section 3.0
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of this report.
2.13 (Closed) Noncompliance Item (88-31-02)
Two workers were.sent into the Drywell to work in an area that had not been surveyed. The area was highly contaminated, and the workers were contaminated and shcwed small intakes of radioactivity.
Findings in the NRC inspection report showed that the RCT who briefed the workers did not know the exact location of the work and used general area surveys in the briefing. Alsc, the workers did not know the radiological conditions of the work area they were assigned to work in an mistingoftheworkcomponentstokeepairborneactivitylow,ddidnotuse as was required for work on contaminated items. In addition, it was found that scaffolding work was being done in an area directly above the work area in which the workers were working. It is not known, however, whether this work contributed to the contamination and intakes of the workers. The Drywell coordinator and a radiological controls supervisor are charged with scheduling work to ensure that work conflicts such as this do not occu.
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The corrective actions taken by the licensee included briefing the RCTs on the issue involved in the incident, and the NRC inspection report was made required reading for all RCTs. Production work supervisors were briefed on the need to discuss details of all work in the radfological controls area and ensure.that surveys are available before starting work.
2.141 Closed) Noncompliance Item (87-37-01)
This noncompliance item was issued for failure to have an adequate procedure to control work in the Control Rod Drive (CRD)he work had been Rebuild Room. The NRC findings indicated that the procedures controlling t altered without adequate consideration of the radicio9ical impact of these changes. The job order for the activities connected with this incident allowed the job supervisor to change the procedure at his discretion.
The licensee disagreed with the NRC finding and stated that the changes made in the procedure had been carefully considered by the job supervisor and the radiological engineering staff. Nevertheless, the licensee stated that the practice of allowing the job supervisor to change )rocedures at his discretion will be discontinued as a practice on site w1ere the changes are construed to be procedural changes. See also item 2.15 below for additional corrective actions.
2.15 (Closed) Noncompliance item (67-37-02)
This item of noncompliance stems from the same activities discussed in the
' previous section (Section 2.14)CRD Rebuild Room. Procedural changes were and it refers to a failure to perform an adequate survey of work in the
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made that involved the order in which components were flushed and removed from the CRDs without adequate review of the consequences such changes would have on the radiological conditions in the area. These changes, as well as poor radiological practices during the work, led to high contamination levels in the room and subsequent transport of this contamination via the ventilation system to other parts of the Reactor Building. The ventilation system in the room was also inadequate for the type of work and the configuration of the work area. Contributing factors included lack of radiological experience on the part of many of the workers involved in the CRD Room activities and their inadequate training for this job.
Corrective actions included briefing the workers on proper work practices; addition of specific contamination control measures to the ALARA review for the job; assignment of additional decontamination personnel to the area; enclosing the work area of the room and modifying the ventilation system to to the rebuild area; path; control of the rate at which CRDs are delivered improve the air flow and individually wrapping the contaminated filters removed from the CRDs before disposing of them in the waste receptacle.
This last measure was designed to minimize drying out of the filters with subsequent generation of contamination that can become airborn _
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2.16 (0 pen) Unresolved Item (89-15-01)
This item addressed the Technical Specification requirement that the American National Standards Institute's (ANSI) qualifications specified in radiological controls staff meet or exceed the N18.1-1971 standard for the licensee did
_ qualification of personnel. At the time of the inspection,in the ANSI not know the relationship between the positions described standard and the positions in the licensee's organization. It is not possible,is in compliance with the Technical Specifications requirements.without est licensee At the time of this inspection,be reviewed during a future inspection.the licensee had correspondence. This item will 3.0 Radiological Controls Performance Task Force This task force was established by the Executive Vice President GPU Nuclear in May 1989 on the basis of results of self-assessments, as well as assessments by the NRC and the Institute for Nuclear Power Operation (INPO). The Task Force was chaired by a radiological controls manager with j
experience from TMI Units I and II. Members included the Radiological ex officio), the Catalytic Core Group Manager, the Controls Director (Manager, the Radiological Controls Field Operations Operations Support Manager,-the Manager of Maintenance,)and the Manager of Materiel Assessment (w was to "... analyze human performance aspects of our radiation protection program at Oyster Creek and identify discrete actions which should be taken to achieve a higher degree of-adherence to the rules of conduct set forth in the GPUN Radiation Protection Plan... as well as other sound radiation protection practices".
The Task Force is one of two broad measures
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designed to improve radiological controls performance at Oyster Creek. The second measure is a ".. reduction in the amount of radiation present in the work areas of the plant".
The Task Force presented a re) ort to the Executive Vice President in July,-
1989. The report summarized tie recommendations reached by consensus amongst the members. The report emphasized that many of the recommendations were not new but had been made previously. However, they were included because no action had been taken to resolve the issues involved. The recommendations made by the Task Force included the following:
3.1 Improve training: this training recommendation is broad ranging and includes the following elements:
. Training for all department heads, managers, and supervisors in the basic elements of the radiation protection plan. The training is to include discussion of the Plan, relevant procedures, the NRC SALP for 1989, and various relevant industry reports and guides, such as INP0 88-010 " Guidelines for Radiological Protection at Nuclear Power Stations".
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. Training for all managers and supervisort, in practical skills that may be used to enhance their ability to identify and correct problems.
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This is to include observation techniques, proper protective clothing techniques, a review of violations and deficiencies, supervision techniques, and techniques for pre-job briefings, mockup training, job planning, and post job reviews.
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. Supply the same type of training to contractor managers and i
i supervisors used to augment the permanent staff during outages, t
. Upgrade initial radiation worker training and radiation worker requalification.
. Develop an advanced radiation worker training course for those l
workers who are to be involved in high-risk radiological work.
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3.2 Establish radiological performance goals for each department as well as for contractor projects and discuss these goals periodically with the Director,
Oyster Creek.
3.3 Managers and supervisors are to become more involved in the radiological controls for the work they supervise. They should be more involved in root cause analysis and in suggesting ways to improve performance. Data on events such as skin or clothing contamination, whole body count results, j
and similar data should be reformatted so as to classify it by department or i
section involved. Supervisors should also monitor work in progress more i
l closely and discuss problem areas with their workers.
L 3.4 Strictly enforce the requirement to comply with all procedures and good radiological controls practices.
3.5 Decontaminate as much of the work areas and plant components as possible.
This includes chemical decontamination of systems, prevention of spread of area contamination, reduction of airborne contamination areas, elimination of hot spots, and minimization of locked high radiation areas.
3.6 The Radiological Controls Department should take steps to improve performance in a variety of areas, including:
. Better control of locked high radiation areas.
. Increase the use of job specific RWPs rather than rely on routine RWPs.
. Increase the detail and specificity of RWPs.
. Increase monitoring of work in progress by the radiological controls technicians.
. Perform spot checks in the field of the worker's knowledge of the RWP requirements for the job being performed, the area dose rates, and other relevant radiological data.
. Increase in the staffing level in the department to achieve the above recommendations.
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3.7 Better planning of jobs, includin use of specialized contractors for l
turnkey jobs, better training of lanners in radiological considerations, and increased use of mockup train ng.-
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The licensee stated that schedules have been established to accomplish the I
recommendations made by the Task Force and that assignments have already been made to start work on these recommendations. The licensee stated that
the function of the Task Force was essentially completed when their report was issued. However, the committee has been maintained as a forum for further discussions on details of implementation. The chairman of the Task Force was assigned to provide details for implementation of the recommendations, and to ensure completion of the necessary work. The Excellence,g details are to be incorporated in the site director's Plan for implementin
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l which is a plan with specific items the implementation of which is designed to improve performance in all, areas at Oyster Creek.
As part of the Plan For Excellence effort, an important reorganization is i
to take effect at Oyster Creek. The most significant from the point of view of possible radiological impact is that the Maintenance, Construction and Facilities (MC&F) department is to be abolished. That department had reported directly to corporate officers. In its place, a Maintenance
department is to be established that reports to the site Director. The
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remaining responsibilities of MC&F are to be taken up by a new department called Site Services. Previously, plant decontamination was done by MC&F.
This function is now to be taken over by the Radwaste Manager.
Decontamination personnel are to be organized into two groups: one group charged with ongoing contamination control to maintain contamination levels low, and another group charged with recoverina contaminated areas after the sources of contamination have been removed. This new organization is expected to improve performance significantly in the radiological area.
4.0 Weaknesses Identified In Section 2 of the Report In reviewing many of the open items discussed in Section 2.0, several areas were identified that suggest possible weaknesses in the radiological program on site. The areas include the following:
. The Radiation Work Permits (RWP and the attached ALARA review, where applicable, are sometimes too broa)d in sco)e to give adequate guidance in some work situations. This means that the RWP may cover too many phases of
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the work, so that information regarding survey hold points, contamination control etc cannot be specific. Changing conditions in the work areas would also no,t be reflected in such broad scope RWPs. In such cases the RWPs tended to rely on the Group Radiological Controls Supervisor (GRCS) to provide the necessary additional information, but this was not always done.
This issue was one of the items identified for corrective action by the Task Force (" Increase the use of job specific RWPs and reduce reliance on
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RWPs which do not contain specific radiological control details for conduct of work" and also " Increase the specificity and details of the RWPs;
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require the job supervisor to interface with the RWP writer to assure that the RWP adequately protects the worker").
. The GRCSs sometimes do not provide sufficient guidance to supplement the guidance provided in the RWP and attached-documents. This is particularly important in situations where the workers or the radiological controls do not have much experience in the work covered by the technician (RCT)important in view of the tendency to rely on broad range RWP. It is also RWPs that do not contain sufficient specific information on radiological conditions and precautions to be observed during the more hazardous parts of the job. This situation should improve with the use of more specific
RWPs, but guidance and supervision of RCTs by their GRCSs also needs to be improved.
waiting to be counted,peared to be subject to periodic backlogs in samplesparticu
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acute when one of the two gamma spectrometers is out of service for any l
reason. The licensee stated that this problem is not as acute as it may l'
appear because samples are checked in the field as soon as they are taken, using a pancake probe. The licensee stated that this method provides sufficient accuracy to allow iaentification of samples above the specified action levels, particularly for airborne radioactivity. The licensee further stated that since this field screening is not applied to iodine samples, a real time iodine monitor has been purchased for use on the refueling floor during outages. The backlogs in the count room are being eliminated by purchase of a third gamma spectrometer as well as increased l
use of computers in the count room.
. Radiation worker training does not appear to be sufficient to
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indoctrinate the workers regarding basic requirements for entry and work in radiation areas. Some instances in which RWP or other basic entry requirements were violated involved workers who had recently completed their radiation worker training or regualification training and had scored very high marks in the exams given following such training. This item was also identified as an area for improvement by the Task Force.
" Improve radiation worker training and requalification training by upgra(ding the course material for personnel actively involved in radiological work".
Also, "The training department should develop an advanced worker training course to train personnel who perform high-risk radiological work").
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. Contractor radiological controls technicians are often significantly less qualified and less experienced than the utility's own technicians. The licensee stated that they are revising the procedure specifying the minimum qualifications requirements for contractor technicians. The new procedures will specify in more detail the minimum requirements for contractor and house senior technicians.
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t The above items were discussed with the licensee during this inspection.
Many of them are part of the Plan for Excellence items for which a schedule has been developed and responsibilities for completion have been assigned.
They will be reviewed during a future inspection.
5.0 Allegations
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Two allegations were received by the NRC Resident's office from a worker at the licensee's facilities. These allegations claimed the following:
a. Mechanical Maintenance was still being inappropriately controlled i
radiologically. Significant maintenance was performed under general was specified in the job orders. posed to generating job specific RWPs as radiological work permits, as op L
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b. ALARA practices at the site were not effective. Examples were entering the condenser bay to remove scaffolding material while the plant was at power and going into the trunion room to perform torquing evolutions on a feedwater check valve which were not effective. No scaffolding was provided j-and people had to walk on hot piping on which shoe covers were burned.
The inspector attempted to identify the specific instances referred to in
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the allegation by review of licensee documents and by discussions with licensee re)resentatives. However, the specific instances could not be identified aecause of a lack of detail in the allegations. Reviews of the licensee's program during this and past inspections suggest that the
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allegations address acknowledged areas of weakness in the licensee's L
program. The use of general RWPs has already been addressed in Section 4 of
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this-report and has been identified as a weakness by the Task Force.
Corrective actions regarding this item will be reviewed during future
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inspections.
The allegation of the general ineffectiveness of ALARA measures was also discussed with the licensee. The practice of conducting work in the condenser bay at power was also reviewed. The licensee stated that work is
occasionally performed in the condenser bay with the reactor at full power.
Much of this work consists of inspections and repair of leaks in valves located in that area, as well as tightening of valves that had been repaired when the system was not under pressure. The licensee stated that o
such valve leak repairs are usually priority items that cannot wait until
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an outage to be repaired. The inspector reviewed documents relating to some work performed in the condenser bay at power. One of the ALARA reviews in
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these documents, dated May 1989, was for repair of three valve leaks and one level switch leak on a moisture separator drain tank in the condenser
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bay. The estimated exposure for the job, which was to be done at 100%
L Sower, was 7.5 man-rem, with the estimated dose rates ir the work area l
performed at the planne/hr. The document review showed that the job was not 3etween 600 and 1000 mR l
d time but was delayed, the reason not being known at the time of this review. However, when the job was completed, it was not
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done at full power and the total exposure for the job was 0.134 man-rem.
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The inspector stated that if this job had been delayed from the planned time, it may not.have been urgent:and possibly could have waited until a radiologically more suitable time. The inspector further stated that the documentation did not show any indication that the matter of delaying or postponing the job or reducing power level was seriously considered, and that the saving of over 7 man-rem of exposure was inadvertent..The inspector also stated that the licensee s ALARA program does not include a jobs such as valve re) quire the various departments to formally justify formal mechanism to re airs at power that cost 7.5 man-rem of exposure, nor is there a formal mec1anism to allocate dose budgets to the various departments and to hold the managers and-supervisors accountable for these
allocations. The licensee did not concur with the inspector's assessment of their program and stated that they do have a mechanism that required justification of dose intensive jobs and that the forum for this function-is usually the daily meetings attended by the department managers and directors and also by radiological controls representation. The licensee L
further stated that personnel are held accountable for doses expended but I
that there is no documentation of these since most accountability is
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conducted on a personal basis between the various managers during discussions at formal or informal meetings. The licensee also stated that they have their own methods of holding people accountable for doses expended. The licensee, however, did not state how this is done, and suggested that it is done informally and without documentation. The l-inspector stated that the ALARA program will be reviewed during a future inspection.
6.0 Exit Meeting l
Theinsectormetwithlicenseerekheinspectorreviewedthepurposeand-resentatives at the end of the
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inspect on on November 16, 1989.
scope of the inspection and discussed the findings.
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