ML19269C000

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Expresses Concern Over Chronic Noncompliances Since 1976 Re Radiation Safety & Plant Security.Proposes $26000 in Cumulative Civil Penalties.Requests Response W/Description of Corrective Actions.Forwards Notices of Violation
ML19269C000
Person / Time
Site: Oyster Creek
Issue date: 01/12/1979
From: Jennifer Davis
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Bartnoff S
JERSEY CENTRAL POWER & LIGHT CO.
Shared Package
ML19269C001 List:
References
NUDOCS 7901190194
Download: ML19269C000 (3)


Text

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NUCLEAR REGULATORY COMMISslON i y%c_A.; !

7 ERA WASHINGTON. D. C. 20555 s'

wf January 12, 1979 Jersey Central Power and Light Company Docket No. 50-219 ATTN:

Dr. Shepard Bartnoff License No. DPR-16 President Madison Avenue at Punch Bowl Road i'orristown, New Jersey 07960 Gentlemen:

The findings of recent inspections of the radiation protection program at the Oyster Creek Nuclear Generating Station, listed in Appendix A to this letter, indicate repeated noncompliance with the same basic require-ments which have been brought to your attention in Notices of Violation issued since January 1976.

The frequency of occurrence of these items of noncompliance has increased since May 1977.

Because of our concern Over this increase, representatives of our Region I office met with embers of your corporate management on July 8,1977, and again on June 21, 1978, to discuss your efforts at corrective action.

Appendix A also lists two items of noncompliance which were observed in

ne area of plant security.

Both are recurrent in that they have been cited in previous Notices of Violation.

The need for management atten-

ion to improving the plant security program was also emphasized during
ne July 1977 meeting.

In our view, the items of noncompliance in Appendix A demonstrate a lack of errective radiation safety and plant security controis.

The chronic and repetitive nature of the items of noncompliance raises serious concerns about the effectiveness of the actions taken by Jersey Central ower and Light Company to correct noncompliances brought to its atten-tion in previous Notices of Violation.

Co'nsequently, we propose to impose civil penalties in the cumulative amount of Twenty-Six Thousand Dollars ($26,000) for these items of noncompliances.

Appendix B to this letter is the Notice of Proposed Imposition of Civil Penalties.

Eight of the nine items of noncompliance liste'd in Appendix A have been listed in previous Notices of Violation.

One of these items,. failure to control high radiation areas, has been cited on three previous occasions.

Another item, failure to folicw radiation protection procedures, has been cited on six previous occasions.

CERTIFIED MAIL RETURN 0,ECEIPT REQUESTED 790119 0l'Ty

. Jersey Central Power and Light January 12, 1979 Company During the past three years, a total of ninety items of noncompliance were identified.

These included fifty-three infractions and thirty-seven deficiencies.

Of the ninety items, twenty-four were associated with the radiation protection program and twenty were associated with the piant security program.

The nine items in Appendix A are not included in these totals.

Civil penalties of $8,000 were imposed in June 1976 as a result of failure to maintain control of the plant's protected area.

While no single item of noncompliance has directly jeopardized public health and safety or compromised the security program, we are concerned that the numerous and repetitive items of noncompliance indicate inade-quate attention by management to proper and effective controls and may lead to more serious situations.

In addition to the items of noncompliance listed in Apandix A, several findings were noted which cause us to be concerned with the adequacy of your calibratir and maintenance program for radiation monitoring instru-men ta ti on.

Specifically, the use of an instrument which responded low by a factor of 2.5 and identification of three out of six instruments which did not respond within the predetermined range when placed on a sealed source used to field. check portable instruments demonstrated an apparent problem with your calibration and maintenance program.

Another area of concern which is not addressed in the Notice of Violation is your health physics retraining program for station personnel.

Based on a randcm selection of training records for thirty individuals, it was determined that nine individuals had not received retraining in health physics practices for a period of three years.

It was further noted that Oyster Creek Procedure No.102, " Training of Nuclear Generating Station Personnel", Revision 2, states that all personnel will be scheduled for annual lectures, however,100% attendence is not reouired.

Illness, vacation, business trips and conflicting requirements are given as examples of acceptable excuses.

Since health physics retraining is' a vital part of an effective radiation protection program, it appears that your procedure should be revised to require that all personnel actually receive health physics retraining within a prescribed interval.

Appendix C, Notice of Deviation, identifies an example of an activity which appears to be in conflict with the basic radiation protection philosophy of maintaining radiation exposures as low as reasonably achievable.

Although your company is committed to this philosophy in your Final Safety Analysis Report, results of surveys showed that adequate efforts were not made to redure radiation levels emanating from work tables used to disassemble and rebuild control rod drive mechanisms.

Jersey Central Power and Light Janua ry 12, 1979 Company You are required to respond to this letter, and in preparing your response you should follow the instructions in Appendix A.

In your reply give particular attention to describing those actions you have taken or plan to take to improve your control of the radiation protec-tion program and the plant security program to prevent further noncom-pliance.

In addition, please include a description of the actions you will take with respect to our concerns regarding your calibration and maintenance program for radiation monitoring instruments, your health physics retraining program for station personnel, and your implementa-tion of the as low as reasonably achievable (ALARA) philosophy.

Your written reply to this letter and Notice of Violation and the findings of our continuing. inspections of your activities will be considered in determining whether further enforcement action, such as additional civil penalties or orders to suspend, modify or revoke the license, may be required to assure future compliance.

We intend to augment the NRC inspection effort in the area of radiation protection at the Oyste.-

Creek Nuclear Generating Station to make a comprehensive evaluation of the effectiveness of your corrective actions.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.

Si ncerely,

I a3 et C, *[W c u, v'sca. -:. e o

_ /b John G. Davis Acting Director Office of Inspection and Enforcement Enclosures :

1.

Appendix A, Notice of Violation 2.

Appendix B, Notice of Proposed Imposition of Civil Penalties 3.

Appendix C, Notice of Deviation

.