IR 05000219/1993018

Insp Rept 50-219/93-18 on 930823-1020.No Violations Noted. Major Areas Inspected:Alara,Rirs,Qa Audits,Air & Swipe Sample Counting Facilities & Radiological Controls Organization Professional Staffing

ML20062J585
Person / Time
Site:	Oyster Creek
Issue date:	10/28/1993
From:	Bores R, Eckert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20062J581	List: IR 05000219/1993018 ML20062J579
References
50-219-93-18, NUDOCS 9311090009
Download: ML20062J585 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /93-18 Docket N License N DPR-16 Licensee: GPU Nuclear Corporation 1 Upper Pond Road Parsippany, New Jersey 07054 Facility Name:

Oyster Creek Nuclear Generating Station (OCNGS)

Inspection Period:

August 23-26,1993 and October 18-20,1993 Inspector: dm / bLF

@h3 Ienny Ecken, Radiation Specialist Date Facilities Radiation Protection Section m

Approved By: wh" ~~

to/ZK/U I Robdrt Bores ~ Chief Date Facilities Radiation Protection Section Areas Inspected ALARA, RIRs, QA audits, air and swipe sample counting facilities, and radiological controls organization staffin Results Good efforts have been made concerning source term reduction. Improvements were noted concerning the air and swipe sample counting facilities and radiological controls organization professional staffing. The lack of timely corrective actions for some radiological discrepancies developed under the RIR process was considered a radiological controls program weakness. No violations of regulatory requirements were identifie PDR ADOCK 05000219 G PDR

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DETAILS Personnel Contacted Station Personnel

• F. Applegate, OQA Monitor

• J. Banon, Director OCNGS W. Collier, GRWSS

• W. Cooper, Radiological Engineer J. Derby, ALARA** Supervisor

• B. DeMerchant, OCNGS Licensing Engineer

• S. Ixvin, Director, Operations and Enforcement T. Milligan, Radiological Engineer D. Reppen, Radiological Engineer

• R. Shaw, Radiological Controls Director (RCD)

J. Stump, Radiological Engineer Other licensee personnel were contacted during the inspectio .2 NRC Personnel S. Pindale, Resident Inspector D. Vito, Senior Resident Inspector

• Denotes attendance at the exit meetin ** ALARA = As Irw As is Reasonable Achievable ALARA ALARA audits /apprai,als/surveillances NRC Inspection Repon No. 50-219/93-06 provided a brief review of licensee audit S-OC-92-11. The audit review covered a period of September 24,1992 until January 14, 1993 (covering 14R {the fourteenth refueling outage}). No significant ALARA concerns were noted, but several minor discrepancies were noted by the licensee audit team. The licensee audit team noted the following strengths penaining to the station ALARA progra e actions by radiological contrcls staff to modify engineering controls to effectively minimize exposure e actions taken by Radiological Controls Technicians (RCTs) to minimize exposure a worker adherence to radiological work standards improved over the level of performance identified in previous audits

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In summay, sufficient licensee audit team attention was placed on evaluating the ALARA program. Additional QA attention is warranted in this ama to ensure effective new Pan 20 implementation (a January 1,1994 implementation date is planned). ALARA program changes and Engineering Design Instructions A memorandum addressing condenser bay power entries, dated June 16,1993 was reviewe This memorandum provides guidance in the form of a flow chan and directs that Radiological Engineering must become involved in the planning process when a job required

"... more than minor maintenance or observation and inspection? OR Is the dose estimate for this job estimated to exceed 300 person-rem?" The memorandum also noted that Radiological Engineering was responsible for the determination on whether or not to reduce hydrogen injection. This guidance is imponant in that nitrogen-16 is present in main steam during reactor operation; nitrogen-16 emits gamma radiation of 6.13 and 7.11 Me Hydrogen injection helps reduce the amount of oxygen in reactor water which thereby helps to minimize Intra Granular Stress Corrosion Cracking (IGSCC) in the recirculation pipin Also, when power is reduced there are less neutrons available for activation of oxygen-16.

The inspector will follow-up on whether the guidance contained in this memorandum was incorporated into maintenance, operations, and scheduling and planning guidance /pmcedures in a future inspection. Worker Awareness and Involvement in the ALARA Program A memorandum (6630-92-171), dated December 2,1992, was initiated by the RCD and distributed to RCTs. This memorandum provided additional guidance conceming planned uptake (s) of radioactive materials. Several RCTs (including Group Radiological controls Supervisor {GRCS} qualified individuals) were questioned on their views concerning field implementation of ALARA decisions (use/no-use of respiratory protection based on air sample results), the quality of their training in that regard, and the quality of guidance / procedures in that regard. RCTs expressed satisfaction with their training pmgram, in general. RCTs did express concern over the lack of ALARA field guidance and lack of specific training in the area of risk balancing. RCTs have attended several new Pan 20 training sessions, but at the time of the inspection, no specialized class on risk balancing had been provided to RCTs. This was recognized by the licensee who planned to provide a specific training session on risk balancing prior to their January 1,1994 Pan 20 implementation date. R ALARA Goals and Performance In order to provide a complete overview of the licensee's ALARA pmgram, information contained in NRC Inspection Repon 50-219/93-06 is repeated here to avoid referencing.

In general, the licensee's ALARA planning program was successful during 14R. Dose savings accmed from early installation of dgwell shielding prior to commencing any

insulation removal (a wmdow was provided to radiological contmls for shielding emplacement), additional drywell shielding (compamd to previous mfueling outages),

prestaging of tools and equipment for high dose mte jobs, and system mock-up tmining. For example, significant dose savings were realized by placing additional temporary shielding on the recirculation piping, valves, and elbows around the area of the drywell 10' elevatio This additional shielding was estimated to save an additional 30.5 person-rem. The most important aspect of the ALARA performance was the extensive pre-outage planning conducted by all working groups, including early freezing of work scop The inspectors reviewed several radiologically signiGcant jobs that were completed during 14R. The inspectors selected jobs and reviewed post job reviews. The post job evaluations noted good practices and pmblems and areas for impmvement for use in future job plannin A brief summary of these jobs is given as follow Job Person-Hours Person-Rein Person-Hours Person-Ren (estimated) (estimatal) (actual) (actual)

Drywell in-Service Inspection 20 .225 37 .41 Replace 16 CRDs 29 .05 53 .78 DrywellIRM and SRM detector repair / replace 2 .0 3 .517 Recirculation Pump *D* seat replacement 57 .5 35 .2 Drywe!! 46-6 Fana 1-1 through I-5 20 .75 28 .51 Reactor Safety Valve repair (9) 17 .0 83 .0 PASS isolation valve repair 2 .75 5 .3 l Good success was noted during Control Rod Drive (CRD) replacement as the licensee was able to reduce respirator usage by 25 % over 13R (estimated dose savings of 4.8 Person-Rem)

and brought in the services of a vendor with extensive experience in replacing / repairing CRDs (General Electric). The person-hour estimate was off, in part, due to the fact that the l estimate assumed that 15 CRDs needed to be replaced and the estimate had not reflected j l dress-out time (actual person-hours being the same as RWP-hours).

Good success was noted for the Intermediate Range Monitor (IRM) and Source Range Monitor (SRM) repairs as Instmmentation and Controls (I&C) developed a method of i perfonning work on these instruments without damaging their associated cablin The inspectors reviewed the ALARA evaluation generated for work on drywell fans to inspect, lubricate, change filters, and replace fan belts. Radiation Work Permit (RWP) 92-1196 was generated to support this work. Also, surveys taken to support this RWP were reviewed. A formal ALARA committee review was not required as the planned collective exposure was less than Ove rem. Work scope increased to resolve deficiencies found during system inspection; there has been a history of vibrational pmblems associated with these drywell fans. At the time of the inspection, the licensee was evaluating the feasibility of

using fan belts made of an alternative material (e.g., Kevlar was under evaluation). No discrepancies were noted with existing station procedures.

The inspectors reviewed station ALARA Review Number (ARN) 92-046E generated for work in the drywell to install and remove temporary shielding on miscellaneous system ,

RWP 92-1291 was generated to suppon this work. Those general area air samples reviewed by the inspector noted airborne activity ranging from lE-8 miemCuries/cc to IE-11 '

microCuries/cc . As no airborne activity generating work was expected by the radiological I controls staff, no job-specific HEPA usage was prescribed by the ALARA review. Licensee lower elevation drywell (13' and 23' elevations) skin contamination dose assessment repons were reviewed. No significant skin contaminations were noted with the most significant exposure noted as 120 millirem to the skin. Licensee whole body counting records for individuals conducting work on RWP 92-1291 (these individuals may have signed on other RWPs as well) from November 28,1992 until February 16,1993 were reviewed. No internal exposures greater than 10 MPC-hours were noted by licensee whole body counting.

In summary, ahhough such work had been conducted with respiratory protection devices in the past no discrepancies concerning the use of respiratory protection devices were noted with existing station procedures.

As of August 1993, according to licensee ThermoLuminescent Dosimeter (TLD) data, four of the ten lowest dose months (since TLD data has been accumulated as of January 1975)

occurred in the current refueling cycle. At the time of the inspection, the TLD low dose month on record is June 1993 with 10.1 person-rem accmed. Source Term Reduction Technical Data Repon (TDR) 941, " Exposure Reduction," 3/31/89, was reviewed. The study was initiated to provide a prioritization of exposure reduction options in terms of cost / benefit considerations. The study concluded that drywell occupancy was a disproponionately large factor affecting plant exposures and that productivity improvements could lead to significant reduction in total drywell exposure. The study also concluded that chemical decontamination would provide the greatest shon-term benefi l TDR 1109, " Cobalt Reduction Plan," 2/23/93, was reviewed. This document provided information on Cobalt inputs and pmvided prioritization of components for replacement.

The licensee's study concluded that a significant reduction in exposure was achievable through the replacement of cobalt alloy components without adversely affecting component performance. Design Standard 37210, "ALARA Design Considerations," was revised to include guidelines for cobalt reduction of in-plant components during the design pmcess.

A memorandum, dated June 9,1993, was initiated by the Radiological Engineering Manager to the Radiological Engineers to provide direction concerning cobalt reduction through the use of low-cobalt replacement components. Also, a memorandum pmviding similar guidance, dated June 15, 1993, was initiated by the ALARA Supervisor to planning and

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scheduling. Standing Order (SO) and Instmetion SO 93-007, Revision 0, June 21,1993,

" Cobalt Valve Hardened Facing," was reviewed. This instmction directed the selection of non-cobalt hardening materials for valves and other components when it is reasonable to do i so. Geneml Maintenance System Two (GMSII) helped facilitate procurement in this regard ;

as this system contains information on valve stellite surface are Licensee pmgmss in this area is given in Section 2.6 of this report. See Attachment I for a gmphical representation of the licensee's three-year mlling average cumulative exposur While the graph shows OCNGS as being a high exposure BWR, it also shows that source reduction efforts have achieved significant results (the slope of the OCNGS curve is greater than that of the BWR average curve).

In summary, good efforts have been made by the licensee in this area. Tids area will be reviewed in future inspection .6 A Historical Perspective on Licensee ALARA/ Source Term Reduction Projects 2,6,1 Past Proiects/ Modifications The following information is intended to provide perspective on the extent of the licensee's actions in regard to source term reduction and maintaining exposures ALARA over the past l three outages. The lists contain some of the more significant licensee actions and should not l

be considered comprehensiv .

12R

• The licensee began BWR 6 CRD replacement. Previously, the licensee had rebuilt drives rather than replace them. BWR 6 CRDs contain less cobalt and require less maintenance than previous CRD design * The licensee replaced control rod blade guides which allowed quicker refuelin * The licensee replaced all 5 Electromagnetic Relief Valves (EMRVs). The upgraded valves were selected as they require less maintenanc e The licensec began replacement of control cell blades with longer life, low cobalt blade * The licensee started to use I.aw Power Range Monitor (LPRM) replacements with a new design with increased flexibility and quick disconnects (to minimize damage fmm other under-vessel work).

• The licensee fabricated and installed shield plates for the reactor cavity. The shield plates were not used in 14R due to inadequate projected dose savings (a chemical decontamination had been performed in 13R and it takes about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to emplace this shield). The licensee was evaluating alternate rigging methods to reduce the time needed to safely emplace this shieldin * A new reactor water sampling system was installe * The licensee used a new CRD changeout handling machine for the first tim _ - _ _ _ _ _ _ _ _ _ _ _ _

e A drywell fan design modification was implemented in order to reduce maintenance activities conducted on these fans. At the time of this inspection, alternative fan belt materials (such as kevlar) were under evaluation.

e Scram Dump Volume (SDV) hydrolase taps were installed.

13R e The Hydrogen Water Chemistry (HWC) system became operational.

e A charcoal High Efficiency Particulate Air (HEPA) filter was installed on the reactor building refueling floor to control iodine. This allowed the licensee to ventilate the reactor head prior to removal.

• A standpipe was installed on the Equipment Storage Pool (ESP) drain in order to minimize sludge into the drain line and Reactor Building Equipment Drain Tank (RBEDT).

• Eight control rod blades were replaced; the replacements contained less cobalt.

e Seven Safety Relief Valves (SRVs) were eliminated.

• Reactor Water Cleanup (RWCU) and recirculation piping Low Oxidation State Metal Ion (LOMI) decontamination took place.

• The licensee replaced isolation condenser piping.

• The licensee started to conduct CRD exchanges with two individuals rather than three, thereby decreasing collective exposure for this task.

• A new drywell access facility was opened facilitating better RWP tracking and access -

control by radiological controls staff.

• The respiratory protection-risk balancing program was initiated (see hTC Inspection Report No. 50-219/93-01 for a description in this regard).

• The licensee replaced the filter septum on RWCU filter "B". This change was initiated to enhance reliability and minimize pmcoat breakthrough.

14R

• A modification allowing the condensate resin system to be backwashed was initiated to improve iron and cobalt removal in feedwater.

e Fourteen snubbers were replaced with rigid support thereby reducing future ISI requirements.

e A new rigging crane was acquired for the removal of EMRVs and SRVs. Pmviously removal of these components necessitated an in-air swap to another crane (drywell 51'

to drywell 23' to the drywell exit). This eliminated the need for one rigging crew.

e Condenser bay thermocouples were added to determine leakby status of numerous valves to eliminate manual measurements which thereby reduced the need for condenser bay power entries.

e Permanent scaffolding supports were installed in the condenser water box.

• Platforms which improved access and movement in the condenser bay were installed.

• Reactor vessel head removal was accelerated by modification of stud detensioners to latch themselves onto studs, acquisitio1 of a new carrousel for stud detensioner handling, and development of a new detensioning sequence.

• New steam line plegs which required less installation time were use e Fuel bundles (100%) were sipped prior to placement in the reactor core.

e Lighter cavity seal covers were used for the first time.

• The cavity grating was disposed. The grating was a large source in the cavity.

e A new method (tcibes were pressurized with air rather than water) of testing steam reheater tubes reduced the time needed to conduct this activity by about half.

See Section 2.5 for a conclusion on the licensee's source term efforts.

242 Outage. Shielding The following table provides the total amount of shielding emplaced within the drywell for the past several outages. To keep this data in perspective, chemical decontamination was performed during 13R. This action reduced 9e amount of shielding used in 13R. At the time of the inspection, it had been decided at to perform chemical decontarnination of the recirculation loops. In lieu of this action, the licensee's Radiological Engineering staff will attempt to use more shielding dependant on weight loading restrictions.

OUTAGE SHIELDING PACKAGES O.%< Number Outage Dates Number of Total Amount Pat Lages Gbs. of lead)

12R 9/30/8e - 5/11/89 36 80,346 13R 2/16/91 - 6/28/91 24 73,001 14R 11/28/92 - 2/16/93 34 98,926 l

In conclusion, good efforts were noted in the licensee's shielding program as a dedicated outage shielding window was provided by outage planning in 14R (Section 2.4) and seismically qualified shielding scaffolds have been emplaced (the drywell being particularly ,

noteworthy) to minimize dose accrued as a result of emplacing shieldin I

2dj Hot Soot Reduction During an interview with the Radiological Engineering Manager, the inspector was informed that there was no mechanism by which failed flush attempts were documented. The inspector suggested that with the advent of the revised Part 20 ALARA requirement (implementation date of January 1,1994) it would be beneficial to document such a failed system flush :

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2.6,4 Job Comparisons Recirculation Seal Replacement Year Person-rem / Seal Comments 1993 .1 1991 seals,14.6 person-rem total, performed after chemical decontamination 1990 9 1990 16

. 1989 .3 1987 days of operation after chemical decontamination ,

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Refueling Floor Doses Outage Person-rem 14R 44 13R 72 ,

12R 127 11R 123 LPRM Changeout Outage Person-rem Comments 14R 1.7 drywell, .4 refuel floor 9 LPRMs 13R 4.3 drywell, .6 refuel floor 5 LPRMs 2_15 Resciatory Protection As noted in NRC Inspection Repon 50-219/93-01, the licensee has implemented a risk balancing metbodology with respect to use/no-use of respiratory protection equipment in accordance with the existing Pan 20 regulations. Internal exposures are accounted for as MPC-hours in accordance with 10 CFR 20.103. The following table gives perspective of the extent of the licensee's effort in this regard. In summary, the use of respiratory protection devices has declined significantly in the past several outage RESPIRATOR USAGE IN THE DRYWELL Outage Number RWP Hours Rapirator Hours Rapirator Usage 12R 86.873 12.575 14.5 %

13R 70.534 6,073 8.6 %

14R 44.320 1.390 3.1 %

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10 ALARA Program Summary 4 n 1 The licensee's source term reduction program has been commensurate with the source term and good results have been noted (Sections 2.5 and 2.6). Continued licensee attention to this radiological contmis program area is warranted. In general, ALARA planning has been I good. Good efforts were noted in the licensee's shielding pmgram as dedicated outage shielding windows were provided by outage p.aning (Section 2.4) and seismically qualified thielding scaffolds have been emplaced (the drywell being particularly noteworthy) to minimize dose accmed in shielding emplacement (Section 2.6.2).

Significant concerns have been noted (NRC Inspection Report 50-219/934)7) about the mechanisms by which ALARA reviews are initiated. At the time of this inspection, the licensee was still taking corrective actions in this regard. The adequacy of these actions will l be reviewed in a future inspectio I 1 Radiological Incidence Reports (RIRs)

The RIR process is the system by which radiological discrepancies are evaluated by the i I

radiological controls staff. A station-wide human performance evaluation process provides the system by which the licensee investigates discrepancies resulting from human error and i human factors engineerin l l

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For the RIRs reviewed, event investigation was, in general, well performed. Causal analysis was adequate. However, the inspector concluded that additional focus / emphasis should be placed on issues identified during the RIR process that relate to areas of regulatory non-compliance. In several cases, the licensee's process for resolution of RIRs appeared to result in corrective actions of limited scope. While some of the RIRs were completed in an expeditious manner, other RIRs were not completed in a timely manner (see Attachment 2).

For example, it took three months to finish causal analysis and seven months to receive final RCD approval on RIR Number 93002. Licensee personnel were not able to provide a reason why it took this amount of time to resolve and approve the actions taken in regards to this disenyncy. In another case, it took four months to finish causal analysis on RIR 9300 Also, the Radiological Engineering Manager and RCD had not completed their review of the actions taken to resolve a February 3,1993 event (RIR Number 93007) by August 24,199 The responsible manager assigned to RIR Number 93007 had completed their actions on February 26,199 The lack of timeliness noted for some RIRs was assessed as a radiological controls program weakness. RIRs will be reviewed in a subsequent inspectio :

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11 Staffing / Organization The licensee added another Radiological Engineering position and filled this positio Several GRCS positions were not filled at the time of the inspection. As many of the GPU Nuclear technicians were ANSI 3.1 qualified technicians and had been task qualified to serve as GRCSs, no programmatic deficiencies were noted due to these positions remaining unfilled. At the time of the inspection, the licensee was taking actions to fill these position .0 Air and Swipe Counting Laboratory Facilities A review of the licensse's counting laboratory was conducted during this inspection. A Radiological Engirce was responsible for this program area. The licensee has implemented the following changes in this am e Three desktop computers were acquired to control the High Purity Germanium (HPGe) spectral analysis equipment. Data was backed up on Bemoulli drive * New software was implemented for the HPGe spectral analysis systems; this software will help minimize deterministic ermrs (e.g. improper geometry selection or other calculational errors).

• Air and swipe sample analysis was automated with few user dats inputs which will help minimize deterministic error In summary, these changes significantly improved the licensee's air and swipe sample counting facilitie .0 Exit Meeting The inspectors met with licensee representatives at the end of the inspection, on August 26, 1993. The inspectors reviewed the purpose and scope of the inspection and discussed the f'mdings. The RCD acknowledged the weakness noted in Section 3.0 of this report and stated that actions would be taken to resolve i _ _ _ _ _ _ _ _ _ _ _ _

Three Year Rolling Averages Oyster Creek and BWR Average 1800--

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ATTACIBIENT 2 As of 8/24/93, RIR # Event Date immediate RC CA RM REM RCD CA Completion Analysis Completion Approval Approval Date Completion Date Date Date Date 93001 1/13/93 1/I4/93 1C6/93 1C5/93 1C5/93 1C7/93 1/29/93 93002 1/21/93 1/21/93 4/12/93 4/12/93 8/17/93 8/19/93 8/23/93 93003 ICS/93 1/26/93 2/5/93 2/5/93 2/17/93 2/19/93 2/19!93 93004 IC6/93 IC9/93 6/22/93 6/23/93 6C3/93 6/30/93 7/20/93 93005 1/30/93 1/30/93 8/17/93 8/17/93 8/12/93 8/19/23 BC3/93 93006 2/6/93 2/6/93 2/11/93 2/22/93 3/22/93 3/25/93 3C6/93 93007 2/3/93 2/8/93 2/25/93 2C5/93 2/26/93 NC NC 93008 3/11/93 3/11/93 5/20/93 5/20/93 SC0/93 5/21/93 5/25/93 93009 3/16/93 3/17/93 7/20/93 7/20/93 7/20/93 8/6/93 8/6/93 93010 5/7/93 5/15/93 6/22/93 6/22/93 NC# NC# NC#

93011 5/11/93 5/11/93 6C2/93 6/22/93 NC# NC# NC#

CA additional corrective actions required NC not completed RC toot cause determination RCD Radiological Controls Director REM Radiological Engineering Manager RM Responsible Manager

1. These events were investigated by NRC and were detailed in Inspection Report 50-219/93-07. As of 8/24/93, the licensee and NRC had not completed actions taken in regards to 50-219/93-07, the 140tice of Violations and the proposed imposition of civil penalty. .-