IR 05000219/1993001

Insp Rept 50-219/93-01 on 930104-08.No Radiological Safety Concerns or Violations Noted.Major Areas Inspected:Postings & Other in Plant Radiological Controls,Work in Progress, Housekeeping & Self Reading Dosimeter Use

ML20128C389
Person / Time
Site:	Oyster Creek
Issue date:	01/29/1993
From:	Chawaga D, Eckert L, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128C376	List: IR 05000219/1993001 ML20128C372
References
50-219-93-01, 50-219-93-1, NUDOCS 9302040005
Download: ML20128C389 (7)

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U. S. NUCLEAR REGULATORY COMMISSION 4

REGION I

Report N /93-01 Docket N License N DPR-16 Licensee: GPU Nuclear Corporation i Upper Pond Road Parsippany, New Jersey 07054 Facility Name: Oyster Creek Nuclear Generating Station Inspection Period: January 4 -8 1993 Inspector: / . W-- / l * D - David J. Chawaga, Senior Rad (gtion Specialist Date Facilit' s Radiation Protection Section Inspector: . _Y //27 13-

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LVnny Ebkeit,'Radiati Specialist Dae scilities Radiati Pro etion Secti n Approved By: e dA /h7CLc- ' ' *O alIe'rl.Pa , Ch"ief Date Facilities Ra . tion Protection Section -

Airas Inspected: Postings and other in-plant radiological controls, work in progress, housekeeping, self reading dosimeter use, intemal exposure control, Radiological Incident Reports, qualification of outage personnel, and outage plannin Results: Posting and other in-plant radiological contmls were adequate. Housekeeping was i good. Self reading dosimeter use was acceptable. Good performance was observed in l intemal exposure controls and the Radiological Control gmup's planning for support of outage work. Causal analysis and corrective actions documented in Radiological incident

. reports were acceptable. Health physics staffing was sufficient to support work in progres No radiological safety concems or violations of regulatory requirements were identified, i:

L 9302040005 930129 i- PDR ADOCK 05000219

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DETAILS Personnel Contacted GPU Nuclear Personnel

• W. Cooper, Manager, Radiological Engineering J. Derby, Radiological Controls, ALARA C. Dissinger,12ad General Employee Training Instructor A. Judson, Radiological Engineer S. Hepfner, Industrial Safety and Health Manager

• S. Levin, Operations and Maintenance

• B. Merchant, Licensing Engineer C. Pollard, Radiological Field Operations Manager

• D. Robillard, Manager, Operations - Quality Assurance

• M. Slobodien, Director, Radiological Controls

• R. Sullivan, Emergency Preparedness N'RC Personnel

• D. Vito, Senior Resident Inspector

• Denotes attendance at the exit meetin .0 Purnose The purpose of this announced inspection at the licensee's facility was to review the implementation of field controls such as postings, barricades, barriers, shielding, briefings, HP job coverage practices, and housekeeping. Radiological Incident Reports (RIRs), ALARA planning, self reading dosimeter use, and respiratory protection practices were also reviewed. Additionally, the licensee's Emergency Preparedness staff provided a tour of the Oyster Creek Emergency Response Facilities and a demonstration of their capabilitie .0 Plant Tours The inspectors toured all major outage work locations within the Radiologically Controlled Area (RCA). Work was progressing safely from a radiological perspective in all cases observed. Housekeeping was adequate and materials stored within the RCA did not obscure postings, compromise contamination controi boundaries or otherwise negatively impact radiological control efforts. Postings and barricades clearly indicated the presence of High Radiation Areas (HRAs). All Locked High Radiation Area (LHRA) doors challenged by the inspectors during plant tours were adequately secured or guarded to prevent entry by unauthorized p::rsonne . _ - - - - _ _ . - - . _ - - - - _ _ - _ ~ - - - - .

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Many large areas within the RCA were posted as Radiation Areas (ras). Large portions of some ras exhibited exposure rates of less than 1 mR per hour, but in some cases, RA postings provided little guidance regarding dose gradients and sources of radiation. Supplemental postings such as "ALARA Caution" and " Low Dose Rate Waiting Area" signs were not widely used to assist workers in lowering their radiation exposure. Radiological information was typically communicated to workers through briefings and by worker review of survey results contained in Radiation Work Permit (RWP) packages. Although little information was available to workers in the field, all workers interviewed had an adequate understanding of radiological conditions in their work location .0 Self Reading Dosimeter Use Personnel working in contaminated areas where radiation levels were below 100 mrem per hour did not typically have a Self Reading Dosimeter (SRD) available for their use. The Radiological Controls Staff directed personnel to wear their SRD under their protective clothing. The licensee stated that this practice was implemented to prevent the SRDs from becoming contaminated. Additionally, the licensee stated that it was difficult to read an SRD that had been bagged and taped to outer protective clothing coveralls. In HRAs, workers were typically issued a Digital Alarming Dosimeter (DAD) which provided continuous indication of accumulated radiation -

dose. The DADS were placed in plastic and were worn on the upper arm outside protective clothin The inspectors expressed concern witn the practice of wearing SRDs under protective clothing for the following reasons:

e Workers could not closely monitor their radiation exposure for contaminated Radiation Areas wor * Radiological Control Technicians (RCTs) could not easily determine if personnel were wearing dosimeters in contaminated areas. One incident was recorded (Radiological Incident Report 92002) where a worker failed to wear both a Thermoluminescent Dosimeter (TLD) and a' SRD in a HRA. The worker was equipped with a DAD. The DAD reading was taken as the dose of recor The inspectors reviewed station procedure requirements and General Employee Training lesson plans regarding the use of SRDs. Station practices regarding SRD use were consistent with documented program requirement _ _ _ _ _ _ _ _ - _ - - - _ _ - _ _ -

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The inspectors reviewed station policies and procedures regarding the resp.tratory !

protection program, interviewed the Rad Con Director (RCD) and the Industrial j Safety and Health Manager, and reviewed selected survey results to determine i whether the licensec's internal exposure control program met requirements in ' -I 10 CFR 20.10 I Policy Number 1000-POL-4020.01, " Respiratory Protection Policy," and Number 1000-POL-4020.02, "GPU Nuclear Policy for the Wearing of Respiratory Protective Equipment,," were superseded by Policy Number 1000-ADM-4020.01, " Respiratory Protection Program", 6/21/91. No significant changes in station policy were note In October of 1992, Rad Con personnel issued a memorandum which explained station policy regarding the use of respirators and the need to balance internal and external radiation exposures for work when both hazards were present. The memo contained three sample problems which described how the risks from internal radiation exposure could be compared to the risk from external trAiation exposur The RCD assured the inspectors that the memorandum was not intended to partially implement the revised Part 20 regulations. The internal exposures were being accounted for as MPC-hours in accordance with 10 CFR 20.10 During a review of the licensee's program relative to the NRC concerns' documented in NRC Information Notice 92-75, " Unplanned Intakes of Airborne Radioactive Material by Individuals at Nuclear Power Plants", licensee personnel informed the inspectors of a determination they had made regarding the use of respirators for work during insulation removal / installation in the Drywell. In the past, such work had been done using respiratory protection. It was determined that respiratory protection would slow the work process and result in higher external exposures to personnel. It was also determined that intakes would be very small without respirators and as a result, respirators were not used for the work. Inspector review oflicensee survey results identified no weakness in this determination and no significant intake of radioactive material resulted during that work. The inspectors had no further que=tions on this matte .0 Radiological Incident Reoorts (RIRs)

The inspectors reviewed RIRs in order to determine whether the licensee had an effective program for identifying and correcting radiological problems. The 16 self-identified RIRs generated during 1992 were reviewed with the cognizant Radiological Enginee . . - . . - .

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In general, corrective actions taken in response to incidents captured by the RIR system were adequate. At times, licensee personnel were not aggressive in determining the root causes for identified problems and did not perform a detailed -

follow-up on some issues. For example, one RIR noted galvanic corrosion as the root cause of a leak in a line to a waste surge tank rather than inadequate system surveillance or inadequate system lay-up. Had weaknesses in system surveillance been identified, corrective actions could have been put in place upgrading system surveillance in order to provide early identification of similar problems in the futur In another RIR, a hot perticle was not recovered for further analysi Overall the work performed during the 14R (fourteenth refueling) outage on the Turbine Building Condenser Bay Reheaters was well controlled by the Rad Con Group. However, a few problems occurred which resulted in unplanned intakes of radioactive material. These incidents were well documented in the RIR syste During the 13R Outage in 1991, the tubes in one Turbine Building Condenser Bay Reheater were inspected using water to pressure test tube integrity at a cost of 4 person-rem. Air pressure testing was used during the 14R outage which was much faster than water testing and respirators were not used which allowed workers to communicate more efficiently. In addition, the internal surfaces of the reheaters were decontaminated which reduced dose rates in the work area. As a result of these combined efforts, the total dose incurred to test the three remaining reheaters totaled approximately 1.2 re A review of the RIRs found two instances concerning unplanned intakes of radi%ctive materials during the 14R Outage Turbine Building Condenser Bay Reheater tt.be inspectio e RIR Number 92014 detailed the first incident. In this incident, one of the:

reheater tubes was not properly plugged. When this tut >e was pressurized with air, water blew out from the lower tube sheet hole, hit a worker's protective clothing, and deflected into that worker's face. The resultant facial contamination was measured at 2,000 net counts per minute with a friske The worker had not worn a lapel air sampler. The immediate corrective actions taken by the licensee were to: decontaminate the worker, whole body count the worker, and restrict the worker from the RCA; stop work until an -

investigation was performed; and initiate an RIR. A' whole body count on 12/23/92, at 1809, showed 254 nCi of.Mn-54 and 185 nCi of Co-60. A second whole body count on 12/24/92, at 1024, showed 17 nCi of Mn-54 and 20 nCi of Co-60. A third whole body count on 12/26/92, at 0936, showed-minimum detectable levels of Mn-54 and Co-60. This quick elimination of the radioactive material led the licensee to conclude that this incident was an ingestion of radioactive material rather than a inhalation of radioactive

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material. The worker was assigned 4.9 MPC-hours for this intake. Causal analysis concluded that there was inadequat: usessment of potential i

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radiological problems for the lower tube sheet worker, Long-term corrective actions included development of a splash guard, inclusion of the event in the required reading material for RCTs, and RWP modification to require Full-Face Negative Pressure (FFNP) respirators for the worker performing tube testing on the lower tube shee * RIR Number 92016 detailed the second incident. In this incident, improper use of a High Efficiency Particulate Air (HEPA) filter led to an unplanned intake of radioactive material. This incident occurred because the HEPA hose -

was not placed inside the Condenser Bay Reheater which was the location of the worker who received the unplanned intake. Additionally, the Radiological Engineer stated that the tube sheets had dried out which increased the airborne contaminants. The worker was assigned 27.5 MPC-hours for this intak Corrective actions included inclusion of the event in the required reading material for RCTs and increased Rad Con inspections for future reheater tube inspection .0 Training and Ouali6 cation of Outage Personnel The inspectors reviewed Technical Specifications (TS), ANSI Standard 18.1, station procedures, and RCT resumes to determine whether RCTs have sufficient knowledge in order to work unsupervised as Senior RCT TS 6.3.2, Amendment 134, states in part, "in the case of radiation protection technicians, they shall have at least one year's continuous experience in applied radiation protection work in a nuclear facility dealing with radiological preblems similar to those encountered in nuclear power stations..."

The in oectors reviewed 10 of 106 resumes for contract RCTs employed te augment the normal plant staff during the outage. The inspectors noted that station policies and procedures allowed full credit for shipyard and/or tender health physics work. In some cases, RCTs were given senior RCT status based exclusively upon time spent working in a shipyard and/or a tender. Further inspection is required to evaluate this area.

a . Outate Plannine

The inspectors reviewed the station's program for planning and preparation for outage work. The systematic approach to ALARA planning was described in NRC

. spection report Number 50-219/92-15. No significant changes were noted in the implementation of this program since that inspection. Computer tools were effectively used to search plant records and help anticipate the radiological challenge l i

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The ALARA planning personnel accessed the General Maintenance System 2

{(GMS2) the Maintenance Department's job order and componuit data base} to determine if there_were any changes in work scope which might necessitate RWP modification. This was done on a daily basis prior to the 9:00 a.m. morning meetin In summary, the licensee's program for planning and scheduling health physics support remained stron The 14R Outage exposure estimate was 544 person-rem. The licensee also provided-an additional 20 person-rem for contingency exposures. As of January 3,1993, the outage exposure was 317 person-rem. This represented approximately 70 percent completion of the projected outage tasks with expenditure of about 58% of the estimated exposur >

9.0 }ixit Meeting The inspectors met with licensee representatives at the end of the inspection, on January 8,1993. The inspectors reviewed the purpose and scope of the inspection and discussed the findings. The licensee stated that they would evaluate the findings and institute corrective actions as appropriate.