ML19305C433
| ML19305C433 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/17/1980 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8003280542 | |
| Download: ML19305C433 (60) | |
Text
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Jersey Central Power & Ught Company h'(f g-)
Madison Avenue at Punch Bowl Road Momstown, New Jersey 07960
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(201)455-8200 March 17, 1980
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Mr. Victor Stello, Jr., Director j
Office of Inspection and Enforcement I
U. S. Nuclear Regulatory Ccmnission l
Washington, D. C.
20555
Dear Mr. Stello:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report No. 50-219n9-18 This letter is in response to your letter of February 20, 19'80, regarding the findings of the inspection conducted by the NRC Performance Appraisal Branch (PAB).
Enclosed as Attachment A are the responses to each of the items of alleged nonconpliance.
Attachnent B, also enclosed, describes the actions which Jersey Central Power & Light Company (JCP&L) has taken, or has future plans to take, to improve our overall management controls in each of the seven areas requested in your letter.
You will note that many of the actions we plan to take to improve our overall management controls will involve a substantial strengthening of our operating organization.
It is our goal to proceed as quickly as we can to I
obtain the experienced people where possible and conduct the needed specialized training programs if the required talent is unavailable in the industry.
Any realignment of our organizational structure which requires Technical i
l Specification Changes subject to NRC review and approval will be promptly sutxnitted.
In any event, it is our objective to enhance our program in an orderly fashion so as not to unduly upset or impede the safety of prograns we presently have in effect.
As you know, the intention to form a new GPU Nuclear Subsidiary has been announced; and it is anticipated that our Oyster Creek operation will becane part of the new subsidia y.
The actions we have proposed in Enclosure B are consistent with present plans for the new subsidiary but are not contingent upon its eventual formation.
We believe, however, that the formation of the new subsidiary will even fbrther strengthen the effectiveness of our organization.
Regarding your request for a meeting with the Director of the NRC's Region I to discuss our corrective action, JCP&L will make the appropriate individuals available for such a meeting. It is our understarding that Region I will notify JCP&L regarding the date and place for the meeting.
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0032805,3g Jersey Central Power & Lght Company is a Memoer of tne General Pubhc Utihties Systern j
J4 Mr. Victor Stello,'Jr.
Page 2 March 17, 1980 We look for,rard to having an opportunity to discuss the steps which have
' been taken or are planned ' to improve our progran.
If there are any questions regardint the enclosed information er additional information is required, please contact me.
i Very truly yours,
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Ivan F. Finf k,
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Vice Presid at cc:.Boyce H. Grier, Director U.S. Nuclear Regulatory Cannission 4
Region 1 631 Park Avenue J
King of Prussia, Pennsylvania 19406 i
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ATTACHMB!T A e
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Mr. Victor Stello, Jr.
Attachm:nt A
- l March 17, 1930 Page I 2e following is our response to Appendix A, Notice of Violation that was attached to the letter, from Mr. Victor Stello Jr. to Mr. I. Finfrock, dated i
February 20, 1980. We referenced letter was received in my office on February 26, 1980.
For clarity, each alleged item of non-compliance is repeated in its entirety and followed by our response.
A.
Technical Specification 6.8.1 requires that written procedures be established, implemenced and maintained that meet or exceed the requirements of Sections 5.1 and 5.3 of icerican National Standard N18.7-1972. Section 5.1.5 of ANSI N18.7-1972 specifies that procedures provided for control of equipent require independent varificacion, where appropriate, to insure that necessary measures, such as tagging of equipent, have been taken correctly.
Contrary to the above, Procedure 108, " Control of Tagging, Electrical Jumpers, Lif ted Electrical Leads, Keys and Iocked Valves," Revision 12, did not provide for independent verification, as appropriate, for the placing / removing of tags, electrical jumpers, and liftirg of electrical leads.
This item in an infraction.
RESPONSE
The item of noncompliance is correct as stated.
Procedure 108 did not provide for independent verification for the placing and removing of tags,
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electrical jumpers and liftire of electrical leads. mis omission of the independent verification was due to unintentional oversight in applying the requirement of ANSI N18.7-1972 to Procedure 108.
Corrective Action Taken:
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- Procedure 108 was revised on December 6,1979, to require independent verification of tags on electrical jumpers and lifted leads.
Corrective Action to be Taken:
- The procedure will be revised prior to May 1,1980, to specify, as appropriate, verification of tags placed on or removed from valves, switches, and breakers.
- Applicable procedures will be audited to assure compliance with this section using checklists. Bis will be completed by January 1,1981.
- Future procedure developent ard revision will be accomplished by using checklists to assure compliance with Technical Specification 6.8.1.
B.
10 CFR 50, Popendix B, Criterion V, " Instructions, Procedures, and Drawings," and Operational Quality Assurance Plan,Section X, " Management and s
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-a Mr. Victor Stollo, Jr.
Attachmsnt A March 17, 1980 Page 2 Use of Documents," Revision 2, require that activities affecting quality be prescribed by documented instructions, procedures or drawings, and be accomplished in accordance with those instructions, procedures or drawings.
B.1 Procedure 120. " Fire Hazards," Revision 5, October 12, 1979, paragraph j
5.1.4, requires that stairway and fire doors be kept closed at all times when not being used for passage.
Paragraph 5.1.12 requires that all wood used in safety related areas be fire retardant.
Contrary to the above, on October 24, 1979, the inspector fourd that three fire / hall doors were blocked open. he doors included the 480V hall door, the cable spreading room door, and the 119 foot elevation fuel storage area door.
Additionally, the fuel storage area contained wooden crates and boxes which were not fire retardant.
This item is an infraction.
RESPONSE
1.
Fire Coors The item of noncompliance is correct as stated. With regard to the blocked open doors, at the time of the infraction a site protection officer was present in the immediate area of each door, as required by security procedures, and was instructed to close the door i~n a fire emergency.
Procedure 120, " Fire Hazards" did not, however, recognize this acceptable alternative.
The immediate corrective action was to close the doors in question and comply with Procedure 120.
Corrective Action Taken:
- Procedure 120, " Fire Hazards", section 5.1.4 has been revised to state,
" Stairway and fire doors should be kept closed at all times except when being used for passage or when an individual is stationed at the door."
Corrective Action to be Taken:
- Applicable procedures will be reviewed to insure that the individual will be instructed to close the door in a fire emergency and upon leavirg the area. %is will be completed by May 1,1980.
2.
Fuel Assembly Shipping Container:
The item of noncompliance is correct as stated. The wooden crates and boxes, which were not fire retardant, resulted fran the uncrating of new fuel assemblies in the fuel storage area. %e situation had been identified by station personnel prior to the inspection, however, the necessary work to correct the situation had not yet been completed.
Corrective Action Taken:
- he fuel suppliers have been requested to ensure that future crating and packirg materials are fire retardant.
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-i Mr. Victor Stollo, Jr.
Attachment A March 17, 1980 Page 3
- A memorandum has been written to all plant personnel outlining the fire retardant requirements of wood used in safety related areas and directing efforts be taken to preclude a recurrence of this situation.
Corrective Action to be Taken:
- Ietters of Agreement to cc. sly with the corrective action taken will be requested of the fuel suppliers.
- The appropriate receipt ard inspection procedures will be reviewed and revised, if necessary, to include the requirement of fire retardant fuel crating and packing materials. 7his will be completed by June 1,1980.
B.2 Drawing A-800-204-002, " Type 2 Support", requires the use of two nuts for the installation of the "U" clamps for the described pipe support.
Contrary to the above, on October 24,1979, "U" clamps were fourd installed with one nut. The installation was at the 51 foot elevation of the Reactor Building.
The pipe supports were attached to the new fire protection water system piping.
This item is an infraction.
RESPONSE
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The facts are correct as stated. However, at the time the inspection took place, the system in question was under construction.
The system had not yet received final inspection by the installer or received quality.
assurance approval as conforming to installation specifications.
We are confident that our inspection of the system prior to declaring it operational would have been found and corrected.
Corrective Action to be Taken:
- None required l
B.3 Procedure 700.1.009, " General Concrete Core Drilling Procedure", Revision j
2, Document Serial No. 217, paragraph 3.1, requires that a job supervisor sign the data sheet and attach it to the Job Order form. Paragraph 5.1.4 requires the completion of the requirements of the Job Order.
Procedure 6009, " Installation, Fabrication, Engineering, Test and Inspection Specifications," Revision 0, paragraph 5.7.2, addresses installation, fabrication, engineering, test or inspection requirements with respect to A!EI Standards. Paragraph 5.7.2 of Procedure 6009 specifies some examples of the types of requirements to be considered for inclusion, including:
" grouting requirements for equipment foundations and for penetrations; bolt torquing and k
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-t Mr. Victor Stello, Jr.
Attachment A March 17, 1980 Page 4 locking requirements". We Operational Quality Assurance (QA) Plan, Revision 2, Page 59, prescribes the use of ANSI N45.2.8 guidance in conjunction with the OQA plan. Part I of Appendix A of the OQA plan lists the fire protection system as one of the systems covered by the Quality Assurance Program.
a.
Contrary to the above, on October 30, 1979, the inspector, on reviewing field records for concrete core drilling, determined that a Job Order had not been completed.
b.
Contrary to the above, on October 24, 1979, an abandoned anchor boring was identifier 1 in the Reactor Building at the southeast corner of the 51 foot elevatior. The hole had been drilled in connection with installation of a fire protection pipe support but had not been properly grouted.
In addition, there were no written instructions available to address action when rebar was contacted, the relocation distance allowed for the placement of a new anchor bolt or for grouting abandoned holes.
Eis item is an infraction.
RESPONSE
B.3.a.
The item of noncompliance is correct as stated. The noncompliance was an oversight on the part of the contractor performing the work, resulting fran a lack of understandirg of procedural requirements.
Corrective Action Taken:
- Discussions have been held with the contractor to assure that he is aware of the requirements for any future work he may do at the plant to complete the file on the job.
The file for this job was completed on January 13, 1980.
Corrective Actions to be Taken:
- The subcontractor requirements will be reviewed to assure that each contractor is explicitly required to instruct his employees to follow applicable plant procedures. Bis will be completed by May 1,1980.
- The mechanism for auditing this will be reviewed and strengthened, if required. Bis will be completed by May 1,1980.
B.3 b.
The facts are correct as stated. However, the abandoned anchor boring, identified by the inspector, had been abandoned because of interference with rebar and was identified on a Jersey Central Inspection Report dated July 31, 1979.
It was on a list of deviations requiring resolution prior to completion of the fire protection system. Instructions for the installation of anchor bolts did not include corrective action for abandoned anchor bolt holes since this was not expected to be a frequent event and it was adequate to resolve them as deviations.
Corrective Action Taken:
- 2e procedure has been revised to include corrective action for abandoned k
Mr. Victor Stello, Jr.
Attachm3nt A i
March 17, 1980 Paga 5 bolt holes including specification of minimum distances for additional drilling in cases where the bolt hole is not filled, or in cases where it is regrouted.
- No instances of inadequate installation relating to nearby abandoned anchor bolt holes have been identified.
Corrective Action to be Taken:
- Corrective action on any abandoned anchor bolt holes due to the fire protection project will be completed by May 1,1980.
B. 4.
Administrative Procedure 105, " Maintenance, Repair, and Modification Control," Revision 5, requires that the following steps be accomplished.
Step 5.2.7 requires that the Plant Operations Review Committee (PORC) ensure that plant operating procedures are updated to include changes required as a result of modifications.
Step 5.2.8 requires that, following the implementation of a modification, the Manager, Generation Engineering, assure that "as built" ' drawings have been revised.
Step 5.1.3 requires that maintenance which could affect the performance of safety related equipnent be properly preplanned and performed in accordance with written procedures, documented instructions, or. drawings.
Contrary to ' the above, Operating Procedures 316, " Main Condensate System", and 316.1, " Condensate Transfer System", and Burns and Roe drawings 2003 and 2004 were not revised af ter completion of modification 213, CRD Water Quality, in November 1978. Also, during this modification, additional work, consisting of weld removal and replacement, was perfonned on a Q-list valve (an item of safety related equipment) without using writting procedures, documented instructions or drawings.
This item is an infraction.
. RESPONSE:
1.
Drawing / Procedure Revision h e item of noncompliance is correct as stated. Burns & Roe (B&R) Drawings 2003 and 2004 were affected by the CRD water quality modification #213 and the' master drawings were not corrected imediately after the modification because a flow meter, which was to be installed as a major part of the modification, could not be ma$e available until after the 1978 outage. Se project engineer decided to wait to revise the drawings until after the flow meter was delivered and installed so that the revised drawings would accurately reflect the modification. After the flow meter was delivered it was decided that it would not be installed during operation and the drawing
Mr. Victer Stallo, Jr.
Attachm:nt A March 17, 1980 Paga 6 revisions were again delayed.
Corrective Actions Taken:
- The B & R drawings 2003 and 2004 were revised immediately af ter identification of the problen on November 12, 1979.
- Procedures 316 and 316.1 have been revised to reflect the modification.
-All project engineers have been instructed that the drawings and procedures are to be promptly revised to reflect the portion of the modification that has been completed.
Corrective Actions to be Taken:
- Procedure 2006 addressing the control of modifications will be revised to require the drawings and procedures be updated in a timely manner. This will be complets3 by September 1, 1980.
2.
Weld Repair The item of noncompliance is correct as stated. As part of mod fication
This welding was done by a qualified welder in accordance with the technical requirements of the code for such a weld. 'Ihe installation specification, as written, did not allow for such a weld repair since the modification only included pipe welding and did not anticipate weld repair of a procured comporent.
A change to the installation specification to broaden the welding requirements was not requested prior to the valve repair.
Furthermore the welding procedure specification was not signed off until after the work had been acccrnplished.
Corrective Action Taken:
- The specifics of this event have been discussed with all parties involved.
Corrective Action to be Taken:
- The same actions described in the response to B.3.a will be taken in addressing this item of noncompliance.
B. 5 QA Procedures 5002, " Training of Nuclear Generating Department Staff Personnel," Revision 0; 6002, " Training of Generation Engineering Personnel,"
Revision 0; and 9002, " Training of Generation Maintenance Personnel," Revision 0, describe the training requirements for corporate staff personnel and include requirements for formal schools of training programs, procedure training and QA familiarization training.
Administrative Training Manual,Section IV, describes specialized employee I
Mr. Victor Stollo, Jr.
Attechm:nt A lbrch 17,1980 Pago 7 l
training, including lectures and on-the-j ob training (0JT) which cover maintenance performance, procedure review and change review.
10 CFR 50, Appendix B, Criterion II, " Quality Assurance Program", and OQA Plan,Section III, " Operational Quality Assurance Program," Revision 2, require the licensee to develop a training program for employees as described in ANSI N18.1-1971. ANSI N18.1-1971 requires that a training program be established for the " operating organization".
The " operating organization" includes those personnel concerned with the day-to-day operation, maintenance, and certain technical services.
a.
Contrary to the above, as of November 2, 1979, formal training had not been conducted for Nuclear Generating Station, Generation Engineering or Generation Construction Maintenance Department personnel nor had hourly personnel in the Mechanical Maintenance Department participated in formal lectures or OJT relatirg to procedure review and change review.
b.
Contrary to the above, as of November 2,1979, a formally prescribed and documented training program for the Health Physics Department had not been established.
This item is an infraction.
RESPONSE
B.5 a.
The iten of noncompliance is correct as stated. Although training has been conducted for both licensed and non-licensed individuals, it is recognized that the present training program is not adequate in many areas.
'Ihis is especially true in recognition of the more recent events in our industry which further support the need for a more extensive and formal program.
Corrective Action to be Taken:
- Improvements in the training program as described in Attachment B are to be implemented. The schedule is as described in Attachment 8.
B.5.b 'Ibe item of noncompliance is correct as stated. In 1979 two courses were given by outside vendors to Radiation Protection personnel.
Approximately 140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br /> of additional individual instruction and required reading was presented to Radiation Protection personnel.
Corrective Action Taken:
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- A written commitment to establish a Health Physics training program
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within one month of the end of the present refueling outage was sent to Mr.
Boyce Grier, Director USNBC Region I, in December 1979.
Corrective Action to be Taken:
- The Health Physics training program is being prepared and will be completed on schedule.
Mr. Victor Stello, Jr.
Attachr.nt A March 17, 1980 Paga 8
- A continuing : raining and requalification program including written and oral exams plus periodic drills will minimize future noncompliance.
- The training program described in Attachment B, Health Physics,Section III will,be implemented.
The implementation schedule is as described in this section.
s B.6 Generation Department Procedure 2002, "Nonconformance and Corrective Action", Revision 2, establishes a system for the control and implementation of nonconformance and corrective action.
This procedure requires, in part, the establishment of a corrective action target completion date within a ten working day period following notification of the nonconformance, ard the resolution of the nonconformance in a timely and complete manner.
Contrary to the above, the September 1,1979, Open Nonconformance/ Corrective Action Report identified 143 outstanding items. Of these, 71 were overdue for establishing a target completion date, and 29 target dates were past due in that the nonconformances had either not been resolved or the target dates changed as required. his item is an infraction.
RESPONSE
The item of nonccupliance is correct as stated. E nonconformance program has been utilized as an all inclusive tracking system to follow those items which require attention, without regard to the significance of the item.
The primary issue in the control of nonconformance is the impact of the nonconformance on nuclear safety. Bis is clearly recognized by JCP&L and addressed in our procedures. All nonconformances must be dispositioned, inmediate action taken (including work stoppage if appropriate), and limits i
established on further work on or use of an item.
Corrective Action to be Taken:
- JCP&L is re-evaluating the system and will upgrade the procedure as necessary to address the recognized' concerns. This action will include
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modifying the procedure to separate nuclear safety related nonconformances from all the others so that it is clear that the nuclear safety related nonconformances receive prompt attention.
Action will be completed by September 1, 1981.
- Additional corrective action is provided in our response to the j
management control question on OA Audits.
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B.7 Procedure 3005, " Site Material Conformance Identification", Revision 3, i
December 7,1977, paragraph 5.3.1, requires that Quality Assurance identify the 3
r Mr. Victor Stollo, Jr.
Attachment A March 17, 1980 Page 9 conformance status of the item being returned to storage and that the item be retagged or restickered, if required. Paragraph 5.1.P specifies that, prior to removal from storage, re-inspection is required for items (such as weld rod) used in various systems that are subject to obsolescence due to code changes.
Contrary to the above, on October 20, 1979, returned weld rod was observed to be in storage with tags identifying the iten as released for use, without having been designated for re-inspection before reuse.
This item is a deficiency.
RESIGSE:
The item of noncompliance is correct as stated. Procedure 3005, Site Material Conformance Identification, Revision 3, requires items which conform to specified requirements be placed in storage and require inspection prior to removal frca storage. Beinspection would be required for items used in various systems that were subject to obsolescence due to code changes. During the period of this inspection, the storeroom was relocating materials from other areas of the plant to the new warehouse facility. Betagging of material was snd is being done for all material brought into stock. Due to the large volume of material coming to the new warehouse, the retagging of the weld rod noted above had not yet taken place.
Corrective Action Taken:
-An operating instruction has been established that requires reinspection of all QA specified material prior to issue.
- All weld rod in stock has been inspected by the Quality Assurance Department and the arpropriate identification tags applied.
- A newly issued set of procedures for operation of the warehouse which address this issue have been implemented as of January 25, 1980.
Corrective Actions to be Taken:
- Instructions given to the appropriate personnel will be reviewed to assure a clear delineation of weld rod control. This will be completed by May 1, 1980.
- The audit procedures will be reviewed ard modified, if needed, to assure that weld rod control is a topic audited. 'Ihis will be completed by May 1, 1980.
C.
Technical Specification 6.10.3 requires that Quality Assurance Records be i
retained as specified by the Operational Quality Assurance Plan.
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Operational Quality Assurance Plan,Section III, " Operational Quality Assurance l
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-e 14r. Victor Sts11o, Jr.
Attachment A March 17, 1980 rage 10 Program," Revision 2, requires that the licensee maintain a duplicate file system, consisting of a corporate document center and a duplicate document center at the Oyster Creek site.
Contrary to the above, modification packages 211, 297 and 313 were not filed at the Oyster Creek site document center as required.
The modification packages were filed at the corporate office except for modification package 297, which the licensee could not find.
This iten is an infraction.
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RESPONSE
- The item of noncompliance is correct as stated. Document Control Center procedures require that a duplicate copy of all documents filed in a Document Control Center be made and sent to the other Document Control Center.
It is apparent that in come cases this Modification package 297 cannot be located. procedure is not carried out.
Corrective Action Taken:
- Document Control Center personnel have been instructed to completely follow the procedures in order to insure that duplicate files are maintained.
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- All project engineers have been reinstructed to promptly file all completed engineering modification packages in the Document Control Center.
Corrective Action to be Taken:
- Attempts are being made to reconstruct as much as possible of this modification package. A notification will be placed in the file indicating the extent of the modification and the fact that the package is incomplete.
- A complete audit of all engineering modification packages will be performed and any necessary corrective actions completed by January 1, 1981.
- D.
Technical Specificat '.on 6.5.3.3.b requires that the training and qualificatons of the entire facility staff be audited at least once per year.
Contrary to the above, for the three year period of 1977 through 1979, one audit in this area ~was started in 1977 and completed on January 1,1978, and another audit was scheduled for completion in 1979. Therefore, only two audits have be' n performed in a three year period.
e This item is an infraction.
RESPONSE
-r Mr. Victor Stallo, Jr.
Attachm:nt A March 17, 1980 Page 11 We item of rioncompliance is correct as stated. Se 1977 audit was credited for both a 1977 and 1978 audit, because it was conducted during Decemoer 1977 and January 1978. 2 e audit scheduling procedure, that permitted this error, was revised in 1978.
Wis revision will avoid recurrenbe of this item of nonectnpliance Corrective Action Taken:
-The audit scheduling procedure, that permitted this error, was revised in 1978.
Corrective Action to be Taken:
-None required.
E.
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, ard maintained that meet or exceed the regairements of Appendix A of the NBC's Begulatory Guide 1.33.
Contrary to the above, calibration procedures had not been written and implemented as of November 2,1979 for the following equipent:
New Radioactive Waste Facility Effluent Monitors New Radioactive Waste Facility Area Radiation Monitors Model RO-2A Portable Survey Meters Portal Monitors Constant Air Monitors Whole Body Counter Hand and Foot Monitors Environmental Air Samplers Multiple Source Gama Calibrator This item is an infraction.
RESPONSE
Our response for each item of equipent is provided below.
New Racioactive Waste Facility Effluent and Area Monitors The item of noncompliance is correct as stated. The requirement for the monitor calibration was not recognized when the new radwaste facility was placed into service.
Corrective Action Taken:
- The vent monitor gaseous, iodine, and particulate monitors have been calibrated.
- Routine iodine and particulate filter removal and analysis has been k
Mr. Victor Stello, Jr.
Attachm:nt A
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March 17, 1980 Page 12 performed since November 1979.
- By use of analysis data and a thorough review of recorder charts, effluent releases for 1979 have been calculated and are reported in the Oyster Creek Semi Annual Report #79-2 of Radioactive Effluent Releases.
- Procedure #621.3.010 was written and approved on January 9,1980 for the new radwaste area radiation monitorirg ard calibration test.
Corrective Action Taken:
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- Permanent calibration procedures have been written and are being reviewed. Bis should be completed by March 31, 1980.
- The liquid effluent monitor will be calibrated after modifications are made to the system.
- An engineering request has been issued to evaluate and implement the necessary changes. mis activity will be completed by December 31, 1980.
During the interim period, the old radwaste liquid monitor is operational ard will be used.
- A more formal turnover procedure for placing a new system into operation, which will address items such as instrument calibration, will be developed ard implemented by September 1,1980.
Model R02A Portable Survey Meters The facts are correct as stated. However, the instruments in use had been borrowed from General Electric and had been calibrated at General Electric and were within the prescribed calibration period. Calibration Procedure 795.3.004 was written and approved on November 22, 1979.
The borrowed instruments were returned and the new instruments were calibrated and then issued for use on December 12, 1979.
Corrective Action To Be Taken:
- None required.
Portal Monitors The item of noncompliance is correct as stated. Were was a calibration procedure 908.3 approved January 11, 1979 for the calibration of portal monitors. The procedure was determined to be inadequate, as documented by field tests, and was deleted.
Corrective Action Taken:
- Calibration Procedure 795.3.008 was written and approved November 23, 1979.
- Explicit instructions have been issued to the health physics personnel that all health physics instruments for which an approved calibration procedure does not exist shall be removed from or not placed in service.
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.I Mr. Victor Stallo, Jr.
Attachm:;nt A March 17, 1980 Page 13 Constant Air Monitors The item of noncompliance is correct as stated. Se Constant Air Monitors were only used as an indicator of increases or decreases in air concentrations in the past.
Corrective Action Taken:
- Portable grab samples were obtained for purposes of determining ccenpliance with regulations.
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- Constant Air Monitor calibration procedure 795.3.009 was approved November 28, 1979.
- All functioning CAM's have been calibrated. All nonfunctioning CAM's have been tagged out of service until repaired and calibrated.
Full compliance was achieved November 28, 1979.
Whole Body Counter The item of noncampliance is corrected as stated. However, this equignent
'was only on site for JCP&L evaluation at the time of the audit.
In December,1979, JCP&L entered into a contract with the vendor to lease the Whole Body Counter, perform repairs, and analyze data.
Corrective Actions Taken:
- In February 1980 a masonite phantom and NBS traceable point sources of the isotopes Cobalt-60 and C sium-137 were purchased.
- The vendors' QA program has been reviewed, and we have established our own OA-QC program for the Whole Body Counter.
- A Whole Body Counter calibration procedure (915.11) was written on March 11, 1980 and approved on March 14, 1980.
Hand and Foot Monitors The iten of nonccznpliance is correct as stated. S e Hand and Foot Monitors were being used while being evaluated for use at the Oyster Creek Nuclear Generating Station and have subsequently been determined unsuitable for our intended use.
Corrective Action Taken:
- We equipment has been returned to the manufacturer.
- RM-14 count rate meters and thin window On pancake type detectors are being used as a final personnel survey for greater sensitivity.
An approved procedure for these count rate meters was available at the time of audit.
Multiple Gamma Source Calibration h
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Mr. Victor Stallo, Jr.
Attachmtnt A March 17, 1980 Page 14 Tne item of noncompliance is correct as stated.
The source values were decayed quarterly and partial calibration uti izing a Condenser R meter traceable to NBS had been started when a mechanical reproducibility problem was discovered. The old multiple Gama source calibrator was tagged out of service October 30, 1979.
Corrective Action Taken:
- A new Multiple Gama Source calibrator was purchased in December 1979. A calibration procedure was written and approved on November 23, 1979.
- Source values will be corrected quarterly by decay calculations and recalibration will be performed ~ annually, utilizing an NBS traceable Condenser R meter.
- Full procedural compliance was achieved November 23, 1979. The new Multiple Gama Source Calibrator was received and calibrated in December, 1979.
Corrective Actions Ib Be Taken:
The following corrective actions to be taken address the areas discussed.
The appropriate procedures and instructions will be reviewed to assure that no radiation protection instruments are used 'unless calibration procedures are approved and calibration is performed prior to use.
This will be completed by May 1, 1980.
- Explicit instructions will be sent to each of the appropriate department heads reemphasizing their responsibility to assure that the instruments being used have been calibrated with approved calibration procedures, any.
instruments found in violation of this directive shall be removed from service immediately until they are in full compliance.
This will be completed by April 15, 1980.
A review of the QA audit program will be performed and modified if necessary to assure that the calibration of instruments is beirg performed as required by procedure. This will be completed by May 1, 1980.
F.
10 CFR 20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary to comply with the regulations in this part.
As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive material or other sources of radiation under a specific set of conditions.
10 CFR 20.106 limits the amount of radioactive material that a licensee may release to an unrestricted area during possession, use or transfer of radioactive material.
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Mr. Victor Stello, Jr.
Atttchm:nt A March 17, 1980 Page 15 Contrary to the above, as of November 2,1979, surveys of effluents released from the New Radioactive Waste Facility had not been performed in that the continuous gas and liquid effluent monitors had not been calibrated nor had samples been collected and analyzed in the laboratory since initial introduction of radioactive materials into this facility in October 1978.
This item is an infraction.
RESPONSE
The item of noncompliance is correct as stated.
The requirement for monitor calibration was not recognized when the new radwaste facility was placed into service.
Corrective Action Taken:
- The ventilation duct monitor system has been calibrated and alarm set points established for the gaseous, iodine and particulate detectors.
- Routine iodine and particulate filter removal and analysis has been performed since November 1979.
- By use of analysis data and a thorough review of recorder charts, effluent releases for 1979 have been calculated and are reported in the Oyster Creek Semi Annual Report No. 79-2 of Radioactive Effluent Releases.
Corrective Actions 'Ib Be Taken:
- The liquid effluent moniter will be calibrated after system engineering review and modifications are completed. thtil this is completed, liquid effluents are monitored using the old radwaste monitor which is operational. Completion date is December 31, 1980.
- A formal turnover procedure for placing a new system into operation, which will a$ dress items such as instrument calibration, will be developed ard implemented by September 1,1980.
G.
Technical Specification 4.5.K.1.a. (2) requires that at least once per 18 months a sample from the Standby Gas Treatment System charcoal absorbers be analyzed to demonstrate 90 percent radioactive methyl iodide removal efficiency.
)
Contrary to the above, as of November 2,1979, no analysis of charcoal absorber j
efficiency has been performed to indicate compliance with the above specification since initial operation of the Standby Gas Treatment Systen in 1969.
This item is an infraction.
RESPONSE
)
-c Mr. Victor Stallo, Jr.
Attachm:nt A March 17, 1980 Paga 16 he item of noncompliance is correct as stated. Bis was an oversight in that the sampling and analyzing of the charcoal absorbers in the Standby Gas Treatment System (SGIS) was not included on the master surveillance schedule.
Corrective Action Taken:
- The SGTS charcoal absorber removal efficiency was determined by our vendor during the period November 26-28, 1979.
Both systems met tne Technical Specification requirements. Ris analysis was reviewed and concurred with by a regional inspector on Janury 4,1980, pending documentation of the test report.
The test report was documented on January 14, 1980.
Corrective Action 'Ib Be Taken:
- This surveillance item will be added to the master surveillance schedule by April 1, 1980.
- Technical Specification changes will be reviewed to insure that all other surveillance requirements have been added to the master surveillance schedule. Ris will be completed by the end of the 1980 outage.
- The procedures will be reviewed and modified, if required, to assure that any future surveillance requirements incorporated in the Technical
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Specifications is included on the master surveillance schedule. This will be completed by the erd of the 1980 outage.
i H.
10 CFR 50.54 (p) requires that changes made to the Security Plan which do not decrease the safeguards effectiveness of the Plan are to be reported to the 1
Director of Nuclear Reactor Regulation, with a copy to the appropriate NRC l
Regional Office, within two months after the change is made.
Contrary to the above, on April 1,1979, a new position, Assistant Site j
Protection Supervisor / Training, was added to the Security Organization. As of October 19, 1979, a description of the change had not been furnished to the Director of Nuclear Reactor Regulation to the appropriate Regional Office.
" This item is a deficiency.
RESPONSE
The item of noncompliance is correct as stated. De failure to report the
" Assistant Site Protection Supervisor / Training" position to the Director of Nuclear Reactor Regulation or to the appropriate Regional Office is attributed to the following: S e amendment incorporating the " Oyster Creek Physical Security Plan" into the operating license was received on September 14, 1979.
It was not recoonized that changes to the Plan that did not decrease the effectiveness of the Security Plan had to be reported until after formal approval of the Plan by the NRC.
The addition of the
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Mr. Victor Stallo, Jr.
Attachm:nt A 1
March 17, 19SO Page 17
" Assistant Site Protection Supervisor / Training" was conceived at the time of appointment to be a temporary position until the training department could obtain the necessary approvals for addition of a security training position. Because the position was temporary and the belief that reporting of changes was not necessary until af ter formal approval of the Plan, the addition of the position to the security organization was not reported.
Corrective Action Taken:
- Compliance was achieved on this item by informing NRC, by letter dated October 31, 1979, that the position of " Assistant Site Protection Supervisor / Training" had been incorporated into the security organization on April 1,1979 and subsequently deleted on October 1,1979, at which time it was incorporated into the training department.
Corrective Action to be Taken:
- The appropriate security procedures addressing this issue will be reviewed and modified, if required.
This will be completed by June 1, 1980.
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k ATTACIBENT B O
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Mr. Vicar Stallo, Jr.
Attachment B March 17, 1960 Page 1 FIRE PROTECTION Jersey Central management recognizes the importance of fire protection and prevention at Oyster Creek. In order to mere effectively control the direction of the fire protection / prevention program, anc in an effort te convey managenent's attitude to all staff personnal, a mere active role will be taxon by upper managment in the field of fire protection. The following actions are viewed as necessary steps to obtain these goals, and are viewed as improvenents to the managenent control of the fire protection / prevention progran.
As committed in the Oyster Creek fire protection plan and recognized by JCP&*,
m anag em ent, the Fire Protection Specialist is responsible fer the cetaile implementation and assesscent of the pro 3 ram. Following the 1930 cutale, the individual in this p3sition will report to the Plant Support Superintendent for matters pertaining to the program. The individual filling this position will be formally trained in fire protection and have a tnorough knowledge of tne fire protection equipment at the plant, nuclear safety and the systems at the plant including their location in the facility and function in mitigating an accident or precitding uncontrolled release of radiation within and outside the facility.
Recognizing the conplexity of the systens which have been installed and the neEd to assure their operability when called upon te perform, as well as the-training, drills, interface with outside fire canpanies, etc, five new positions will be created to assure that this important area receives the necessary technical support and priority it deserves.
The Station Panager has directed the Fire Protection Specialtst to provide him a periodic status of the fire protection progran. Tne' status will be in the for:n of a meeting or a written report which will delineate prograss, accomplishments or problems in the program.
The update will be provided on a quarterly basis with the first being scheduled for September 1980.
In addition to the quarterly update, all fire drill reports will be reviewed by the Manager-Nuclear Generating Stations. The fire drill report will delineate the drill scenario, the post drill critique, and any reccmerded corrective actions. The quarterly updates and fire drill reports will provide the Manager-Nuclear Generating Stations with the necessary information to evaluate the effectiveness of the Fire Protection program.
The Fire Protection Specialist has been directed to notify, directly, the Station Panager of fire hazards which could compromise the safety of the plant.
This will insure pranpt action will be taken to correct the situation.
The Plant Manager confirmed by memo to the PORC Chairman his instructions that the PORC utilize the expertise of the Fire Protection Specialist is available to assist in the evaluation of potential fire hazards in plant safety related activities.
A job description for the Fire Protection Specialist position will be written to incorporate the responsibilities, functions, authority and qualifications presently described in Procedure 101.2.
Alternates to this position will receive training and will be available to assune the duties of tne Fire Protection Specialist in his absence.
These activities will be completed by December 1, 1980.
The administrative control procedures for fire protection l
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Mr. \\'ictor S2c110, Jr.
Attachment B March 17,1080 Page 2 cre being reviewed and, if necessary, revised to assure that the necessary centrols are in place which address, for exsr:pic, contrel'ing the storage of cc.:.bustibles in safety related areas of tne plant, assuring.ne valving cut er otherwise disabling of autanatic fire protecticn systens is properly contrclie',
tne use of ignition sources is centrolled through a permit system and periodic housekeeping inspections are scheduled ard performed. Tne review will assure that the responsibilities are explicitly defined where possible.
This review will be canpleted by the end of the 1930 outage.
Tne required fire protection modifications and associated procedures will also be canpleted by the end of the 1930 outage.
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Mr. Victor Stello, Jr.
Attachmr.t B March 1~,
19S0 Page 3 TPAI"ING JCPM. Company recognizes the importance of training througtrut the Generation Division to ensure overall sound cperation of the Oyster Creex 1uclezr Generating Station.
In recognition of this a Manager of Training wh: v 1 report to the Vice President of Generation will be appointed by May 1, 15 Establishing the trainir6 function at a manager levC. will result in the desire:
improvements in management's awareness and control over all generation divisien training.
The Manager of Training will be responsible for:
-Developing and adninistering an everall training progran plan
-Providing resources and support to the statien training depar::nent
- Assure the content of training prograns is adequate and meets all regulat:ry requirements.
Tne Manager of Training will be responsible for developing the lesson plans and conducting the training to meet the course objectives. He will develop,ourse objectives through interaction with the other functional managers win will establish the performance requirements.
He will assign individuals not-responsible for training to review the conduct of training at the plant and h:2ne office areas. This will include monitoring instructor performance, evaluation of on the job training and student performance reviews to ensure the adequacy of his training organization.
The ccupany is currently developing a long term sustained prograa to ensure qualified hourly employees are continually available to cperate the Dyster Creek Muclear Generating Stadon. The program is referred to as Time Oriented Proficiency Progression Syste:n (TOPPS). E:nployees can advance in this program through established grades for their line of work on a prescribed time schedule with successful ccepletion of classrocm wrk, on-the-jcb training, capability demonstrations and work experience in each grade, they can reach the top skill level for their classification. Those not capable of achieving the required levels of proficiency will be removed fran the progran.
Professional and supervisory enployees will have training provided in accordance with the requirements established by the individual department managers. These requirements muld encompass such areas as engineering modification procedures, quality assurance program requirements, management skills, and supervisory training.
To acccmplish the necessary training the ccmpany recognizes its cccmitt:nent to an expansion of its training organization as well as supplementing the work force to ensure adequate training manhours are available fer c11 employees both hourly cnd supervisory.
The organization planned to accomplish the training cc:nmitment is stuwn in Figure 1.
This organization is scheculed to be in place by January, 19o1. Tne staitional persennel necessary to ensure that sufficient trainee manhours are available are also planned to be in place January 1981.
The training program
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Mr. Victor Stello, Jr.
Attachment B March 17, 1980 Page 4 plan w'11ch outlines the philosophy, basic policies, and objectives will be available by Septenber 19c0 along with a management plan,and for schedule accc:aplishing the training program.
In the interim, existing basic trainiac prograns for nore-licensed personnel such as operators, mechanics and techniciar.s will be implemented thrcugh the maximu:a utilizatien of our present training staff and werk force. Tne training progra:
for the Health Physics Department is addressed in Attach:nent B, P.adiation Protection,Section III.
The need for facilities as well as tne manpower associated with this training requir ement, are recognized.
Currently tne requirencnt for full control rccm and part-task simulators are being evaluatec alcng with other training facility needs. Peccanencations fraa special trainirs study groups are beirg evaluatec by ccrporate management. In the near term, however, training facilites wi.i. some hards-on training aids are being established in the area adjacent to tne :nachine shop at the plant. Existing office space will be utilized for meeting the home office trainirs needs.
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Mr. Victor Stello, Jr.
AttachmInt B
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March 17, 1980 Page 6 FAINTENANCE IE Inspection Feport No. 50-219n9-18 forwarde: by NFC Eegion I letter of January 4,1930, listed several findings and observations related to maintenance and concluded that "the licensee appeared to have a well-defined written prograa to assure that maintenance work would be performed and tracked in an acceptble manner".
Fbwever, the NRC also concluded that the written progran had not been adequately implemented, resulting in questionable quality of some maintenance work.
The NRC also noted that there were morale problems in the Maintenance Cepartment. These conclusions then alluded to tr.e positive steps taken by Cyster Creek to correct problens in the Maintenance Department but noted tnat Cyster Creek had made no official commitment regarcing wnen the planned program changes would be fully implemented.
Neither had Cyster Creek identifiec all goals and cbjectives necessary to parsue an effectite maintencnce program nor had interim measures which will assure a minimun impact on safety been clearly identified.
Finally, the NRC concluded that Cyster Cr eek's maintenance managenent controls were poor.
It is the purpose of this section to identify Oyster Creek's actions, some of which are in response to conclusions of the NRC, and to ccanit officially to a schedule for fully implementing all planned maintenance progra:n changes.
Although the NRC concluded that Oyster Creek's written.aintenance program-appeared to be well defined and muld produce and track acceptable maintenance work, Oyster Creek has undertaken the following changes to the written program to increase the scope and to provide greater definition of previously issued
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procedures:
a) To provide for improved control of maintenance work in all areas, Oyster Creek has undertaken to develop and implement a new procedure entitled,
" Conduct of Maintenance".
Basically, the precedure will provide standard administrative, management, and radiological centrol practices for advance planning and conduct of maintenance jobs, including staging of material, selection er training of mechanics and technicians, establishirg prerequisites, specifying precautions, insuring the required approved procedures are in hand, and conductng pre-shift briefings.
All phases of this planning and implementation will take note not only of the craftmanship, manning, sequence, schedule, and plant conditions, but also the radiological work practices that will provide contamination centrol and reduce exposure associated with doing the work. All Maintenance personnel, Supervisors, Group Supervisors, Mechanics, and Technicians-will be trained in this procedure which will establish the conditions under which maintenance work will be performed.
Effective implementation of this procedure will improve management controls for maintenance work at Oyster Creek. The procedure will be issued, training completed, and the prescribed centrols implemented by August 1,1930.
b)
The Performance Appraisal Branch coserved in their report of the inspection that the Preventive Maintenance Program had not been adequately implemented and referred to a reported lack of manpower as the reason. Since that time, Oyster Creek has hired two preventive maintenance engineers (cne mechanical, the other instrunentation and electrical) to administer the program and, as subsequently mentioned in this section, additional supervision and manning have been added to both Maintenance Departments. 'Ihe existing Preventive D"D
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Mr. Victor Stello, Jr.
Attachment B March 17, 1980 Page 7 Maintenance Prcgram will be reviewed for coup 11ence with specificaticns and upated to increase effectiveness. Maintenance crews will be. establishcd which will be dedicated to preventive maintenance exclusively.
The revised Preventive Maintenance Progran will enphasiae updating the equipnent history files with preventive maintentnce information and will use the equipnent history files to detect trends in equipnent performance that justify chardes ir.
preventive maintenance practices. The planned improvenents in the content and per formance of the Preventive Maintenance Program will be implemented by September 30, 1980.
'Jhen referring to Gyster Creek's failure to implenent adequately the written maintenance program, the tiRC conclWed that this had raised questions relative to the quality of sane of the wcrk per formed in the maintenance area. Oyster Creek considers that the principal problem here was with the job order syste:r.
anc tne failure to canply fully with the requirenents of the approved written proced ure. To cover this problem, all conpleted Jcb orcers are now reviewed by tne appropriate department head for ccmpleteness and accuracy. This review inclWes checking for material traceability, work procedure co:npliance, post-maintenance testing, ano equipaent histcry entries. This has been successful for job orders presently being completed, with the exception of equipment history entries.
For the purpose of equipnent history entries, additional staffing is required and is planned to be in effect by September 1, 1960 to assure all job orders are being canpleted in accordance wiu: the requirunents of-the procedures.
Another facet which raised questions for the NBC relative to the quality of maintenance work is the noncompliance / corrective action required (NC/ CAR) system.
To ensure that NC/ CAR's are properly processed and that indicated actions are taken properly, Oyster Creek is now establishing a procedure wnereby all NC/ CAR's assi6ned to the Operations and Maintenance Departments are routed to the Managenent Control Supervisor. The Managenent Control Supervisor will assign each NC/ CAR to the department head responsible for establishing completion dates, for taking the indicated corrective action, and for returning the dispositioned NC/ CAR's to the Ouality Assurance Department expeditiously.
In perfor:ning this function, the Managenent Control Supervisor will maintain a l
log of commitment dates, status of action in progress, and NC/ CAR's properly completed.
This log will be the basis for mana;ement action which may be required to maintain the NC/ CAR program up to date.
This new procedure for controlling and expediting NC/ CAR's will be fully implenented by August 1, 1980.
When taking note of morale problems in the Maintuance Department, the NRC referred to poor communications, inadequate corpor ate management support regarding manpower needs, and inadequate training.
In this regard, a nunoer of actions have been taken:
a) A new Supervisor of Station Mechanical Maintencrae has been assigned.
A new Maintenance Department Engineer has been assig ed tc nim as well as two newly promoted Group Mechanical Maintenance Supervisors.
A third Group Mechanical Maintenance Supervisor is approved and will be availaole for assignment after the current outage is canpleted. In adcition, the Meenanical Xaintenance Department has been authoriaed eight (3) additional personnel to cover the increased effort which will be devoted to maintenance training, preventive maintenance, and radiological waste processing systen maintenance.
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Mr. Victor Stello, Jr.
Attachm:;nt B
-l Shrch 17, 1980 Page 8 i
In the Instru:ent and Elcetrical Faintenance Department, two Group Superviscrs have been added, one each to the Instrunent group and the Electrical group.
Similarly, the Instruaent and Electrical Maintenance Depart:nent has been authorized seven (7) additional personnel to cover the increased effort wnich will be devoted to maintenance training and preventive maintenance.
This increased supervision, manning, and training is calculated to imprevs scrale in the Vaintenance Department. It is apparent to Oyster Creek manastentnt that the desired effect is being achieved.
Cyster Creek believes that the plans and ccnmitments cutlined above adequately address the concerns expressed in the Performance Appraisal Branch report of 19~3 in the Faintenance section of the report. Similarly, the conmitments made and the changes described will improve everall manage:nent controls of
- nt.intenance.
a Me14Am I
Mr. Victor Stello, Jr.
Attachment B March 17, 19S0 Page 9 RADIOACTIVE hM TE Fadwaste shipping procedures have undergone extensive changes and are continuing to be reviewed and revised to bring our solid waste shipping program to acceptable standards in all aspects.
Since the PAB team inspection, the following procedures have been developed in response to the concerns expressed in the report ard as comitments to IE Bulletin 79-19:
1.
Administrative Procedure 101.3 - Shipment of Radioactive Materials for Offsite Burial - issued November 14, 1979 - To define areas of responsibility and to address the shipment documentation and reference the documents governing shipnent of radioactive wastes.
2.
Operating Procedure 351.10 - Packaging Radioactive Wastes for Shipment to Offsite Burial Sites - issued November 14, 1979 and revised December 11, 1979 and January 18, 1980 - To provide detailed instructions for packaging radioactive wastes for shipnent to offsite burial sites.
However, in order to assure full procedural coverage, a new set of shipping procedures is presently being prepared. An individual procedure will exist for each type of cask.
Upon completion, the procedures will be reviewed and evaluated against the requirements set forth in 10CFR71, 49CFR170-189, and the.
individual burial site requirements. It is expected that the procedures will be completed by April 30, 1980, ard the evaluation to be completed by May 31, 1980.
Oyster Creek considers that this procedural effort is responsive to the concerns of the PAB team report in the areas of radioactive waste and shipping.
To improve management control of radioactive waste, the organization for operation and support of the Radwaste facilities will be revised by creating and filling the position of Supervisor of Radwaste Operations.
He will have the overall responsibility for processirg and shippirg of radioactive waste, as well as overall planning and license compliance of all aspects of radwaste.
Until the proper person has been assigned to this new position, the function will be fulfilled by the Operations Supervisor. Each shift will have its own Radwaste Shift Supervisor and dedicated Radwaste Operators to assure the effect and efficient operation of the facility.
The Radwaste Shif t Supervisor and Operators will have the responsibility for both the Radwaste and Augmented Off Gas (AOG) building operations.
Also in the Radwaste organization will be the position of Radwaste Shipping Supervisor for all radwaste shippire.
This position will be responsible for monitoring compliance with all applicable shipping requirements and procedural i
controls in this area.
i Plans are to fill the Radwaste Shift Supervisor and radwate operators as soon as i
possible but no later than September 30,1980. 'Ibe Radwaste Shippirg Supervisor will be filled by May 1,1980.
Other areas being actively pursued to upgrade our Radwaste Operations include:
- Engineerirg support to correct identified design deficiencies and upgrade the capability of the processirg systems.
- Complete review ard revision of all Radwaste operating procedures to assure
Mr. Victor Stello, Jr.
Attachmznt B March 1"',
1980 Page 10 current system status is reflected - complete by June 30, 1980.
The above organization changes, which result in responsible supervisory coverage of the Radwaste facility activities, along with the planned revision of our procedural controls and the dedicated engineering support to upgrade the processing systems, demonstrate our commitment to upgrade management control of the radioactive waste program.
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Mr. Victor Stollo, Jr.
Attachetnt B
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March 17, 1980 Page 11 0'JA*.ITY ASS'JRANCE Starting in early 1979, JCP&L QA identified the need to evaluate the CA progra:a effectiveness and undertook an extensive effert to evaluate the effectiveness cf basic prcgrams. The initial effort was that of analyzing NRC inspection items,
?cp rtable Cccu-rences, Audit Notices, and !! nconformances for the purpose f
establishire any unsatisfactory trends in specific areas. The areas which have been evaluated include: maintenance, Health Physics, surveillance testing, fire protection, warehousing, and security.
In addition to this effort, I&E inspection reports, Audit Notices, and Nonconformances have been evaluated en an individual basis to establish broad prcgraanatic trends.
(Reference Iter. 6.c.9 cf your PAB report, Page 40).
This effort has been quite effective in identifying areas requiring further attention (reference Unresolved Ite:a 21?/79-l'-22, the last paragraph en Page 65 which centinues en to Page 66 of the c
PA.9 report).
The maintenance survey ciscussed on Page 65 and 66 of tne PAS report was the result of compiling identified concerns in the " Findings Analysis-Maintenance Report", dated March 27, 1979, and a recomendation to perform the survey to better understand the maintenace program.
Likewise, tne JCP&L internal audit program has been focusing on programnatic concerns and cocunenting shortcomings.
In addition to the efforts mentioned above, JCP&L utilized a highly qualified, independent consultant to perfonn an extensive review of the effectiveness of-the Operational Quality Assurance Progran. Progressive review techniques were utilized to evaluate the program effectiveness, JCP&L personnel understanding of the program, attitudes toward the progran, and recomendations which personnel at all levels have. Approximately sixteen manweeks of consultant time went into this effort and extensive JCP&L time was expended.
The objective of this extensive evaluation discussed above was to study fundanental issues and assess appropriate changes which would better address the heightened awareness towards Quality Assurance.
On i ebruary 20, 1980, the initial evaluation effort was canplete and the Quality Assurance Depart:nent submitted a report to upper management.
This report conbines the major concerns identified by all sources, including PAB, and makes reccnmendations on how to address the concerns. The recommendations fall into three basic categories:
QA progran scope, QA organization, and program upgrades. Until the organizational upgrading is well underway, the expansion of prcgran scope and the program upgrades cannot be staffed internally.
As a result, JCP&' QA has three contractor agreements and a GPUSC agreement in place to help address these areas in the short term.
An extensive ar.ount of work is being carried out in accordance with tnese agreements.
The organizational changes are extensive.
The staff supporting the Manager-Operational Quality Assurance at the corporate office will be increased s ig ni ficantly.
The objective of tnis action is to place the bulk of the engineers into the areas of audits, QA trending, ano training and qualification.
The procurenent quality assurance area staff will be increased to bring more of this work in house. The Site QA organization is the area receiving the mcst attention and the most dramatic cnange.
Changes will be made to greatly strengthen tue technical capability on site by establishing a separate QA engineering organization and hiring OA ergineers into that group. This group, along with the strengthened staff QA engineering group, will greatly improve the I
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Mr. Victcr Stello, Jr.
Attachment B March 17. 1980 Page 12 ccrrective action followup and closecut, and the CA trending capability.
It will also permit a greatly improved capability in prograx.atic planninc an:
developaent, training and qualificaticn of personnel, CA Department interface witn engineering and oper ating organizations, CA engineering support, and A review of cperations data and Technical Specification canpliance.
The current Site CA Organization responsibility is primarily one of CA inspection / surveillance. 21s function will continue under the Site Quality Assurance Inspection Superviscr. The scope of this organization's responsibility will be expanced significantly and incitxie personnel to provide CA coverage of radiation protection, radwaste shipping, and chenistry.
In addition, a full time 2 S;,ecialist will be assigned to the site. All of these site functicas will be placed under a new, higher level position of Site Quality Assurance Manager to emphasize the increased awareness of the significance of this crganizatien.
This comittnent is a significant canaitment on JCP&L's part and represen'.s a significant step in addressin3 the new, heightened awareness of the Cuality Assurance role in the operating phase of the nuclear industry. Tne new Quality Assurance organizational structure is shcun on the attached organzatien chart.
The organization is approved and the JCP&L Cuality Assurance Organization will be actively recruiting to fill the new positions by June 1, 1930. Our goal is to have all of these positions filled by the end of 1930.
In addition to implenenting a new ordanization, a significant commitment to training is required.
In'this light, the Quality Assurance Department is developing an extensive training progran. It is scheduled to start right after -
the canpletion of the present refueling outage at Oyster Creek with a forty-rour course in visual inspection and welding end then a twenty-hour course in nondestructive examination.
During 19o0, fcnnal courses on the Operational Quality Assurance Plan and Quality Assurance practices will be established, and the initial pertions given to Quality Assurance Department personnel. There is a need to broaden the Quality Assurance Department personnel's knowledge of Oyster Creek systems and. plant operation.
This need is being evaluated and training will begin in this area in 1931.
In addition to classical subjects, JCP&L has recognized a need to train its Quality Assurance personnel in the area of cawunications.
Efforts are already underway in this area.
The programatic upgrading will require a significant effort in defining programmatic specifications and caaputer program developnent. Tnis effort will continue on a high priority basis which is consistent with resource availability.
It is not passible to determine a schedule for this effort at this time.
The specific NRC concern for the followup and closecut of audits and nonconformances is in part addressed by the extensive efforts described above.
Approximately 40% of the open Audit Notices address the need for administrative control procedure revisions and pose no significant nuclear safety concern.
Fesources are being dedicated by the various departments to fulfill the comitments made relative to revising procedures.
he following action has already been taken, Quality Assurance is utilizing a consultant to help it manage its audit program until the organizational upgrading is complete. Generation Engineering hired a consultant to help draft the administrative control procedures to close out its Audit Notices.
Caneration Maintenance and Construction is writing and issuing precedures to close out many of its Audit Notices. Within nine months, essentially all of the I'
Mr. Vic2or Stello, Jr.
A22achmen2 B
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March 17, 1980 Page 13 open Audit Notices pertaining to procedure revisions, will be closed.
In addition to the corrective action described aoove, the non-Cuality Assurance Department portion of this concern will be addressed through an imprcvec management control mechanisa which makes management more aware of the statas of efforts to close out nonconformances and Audit !!stices.
This mechanis:n will focus on overdue items and establish responsibility for resoluticns.
Tne Nanasers of the various departments will continue to be responsible for the ec,rrective action associated with items identified as within their responsibility.
The Vice President-Generation will increase his direct involvement in the program by means of reviewing overdue items and taking apprcpriate corrective action.
An initial system of this type will be implenented by August 1980.
With regard to the nuclear safety significance of Audit !!atices, tne JCPIL
- uclear Safety & Licensing Depart:nent looks at Atdit :!otices when issued fcr potential safety concerns and takes immediate action if appropriate.
This action is independent of Audit flotice closecut. To this end, JCP&L is confident that Audit tiotices which identify t!uclear Safety Concerns are identified
- pranptly, b
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!!r. Victor Stollo, Jr.
Attachment B March 17, 1980 page 14 INSEFYICE I::SPECTION The managenent control of the Inservice Inspection Progran is based upon the concept of providing technical direction and support from the Generation Department staff level and implementation at the plant level.
The "anager-Generation Engineering is responsible for the establishment a n.:
maintenance of the Inservice Inspection Program requirenents and evaluatir.3 those technical concerns which cannot be resolved within the scope of tue plant's routine maintensnee progran. These requirenents are within the scope of Generation Engineering's responsibility because it provides staff level attention to the prc3ra:n and places the responsibility in the department which has the engineering capability to adoress the technical aspects of tne progra::a.
The Manager-Generating Stations-Nuclear throu;h the Station Manager is responsible for the develegnent of implementation procedures and schedules, anc the overall planning and implenentation of the progran in accordance witu tne program requirements. When carrying out this responsibility, the plant will have an assigned ISI engineer who obtains technical support from Plant Engineering, Generation Engineering, and nondestructive excuination support fron Ouality Assurance; however, the ISI Ergineer retains the overall responsibility for program implementation.
As the Inservice Inspection Progran has becane more extensive and conplex, JCPC recognized that it had a weakness in the area of program implementation. -
Since the first ten year Inservice Inspection Program was primarily one of nondestructive exanination, the plant requested that Quality Assurance provide sone assistance in acconplishirg program implenentation; however, the plant did retain ultimate responsibility for implementation. JCP&L recongizes that the second ten year Inservice Inspection Progran will go far beyond the first ten year program.
In this light, JCP&L has thoroughly reviewed the Inservice Inspection Program and has decided not to change any of the basic progran responsibilities, as identified above. However, majcr steps have been and will be taken in the area of Inservice Inspection Progran.v.anagement Control.
The responsibilities for Inservice Inspection Program implementation will be reassigned to an ISI Engineer who reports to the Ergineering Supervisor. The Eniineering Support rupervisor reports to the Plant Support Superintendent. Tnis action has been taken to place the responsibility in the Plant Engineering section where there will be technical expertise to organize and direct implenentation of the Inservice Inspection Progran.
The formal reassignment of responsibility will be made at the end of the current refueling outage at Oyster Creek.
Sufficient manp:wer will be assigned to tne ISI Ergineer. to support the second ten year program implementation effort. The formal implementation schedules and procedures will be complete by April 1981. In the interim, implementation of the program will continue in accordance with written procedures that will be prepared and approved on an as-needed basis.
The personnel assigned responsibilities in the area of program implementation will be given appropriate training to assure that they have a thorough understandirg of the program and their responsibilities. Generation Engineering and Quality Assurance will perfonn technical and quality audits of the progran on a frequent basis starting in the fou-th quarter of 1930 to assure that the progran is being implenented in accordance with the progran requirenents.
With regard to the first ten year program, JCP&L, for many reasons, has been D f
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Mr. Victcr Stello, Jr.
Attachmsnt B Shrch 17,1980 Page 15 concerned about whether it had car.pleted all of the requirements. The PAB Tea.:
inspecticn occurred during the preparatien for the final outage in the first tur.
year cycle.
I,s a result, the PAB team recc,nized that we did hs.ve questions on e
the program ccmpletion status and that we were addre* sing the concern with the cbjective of completing the program during the upcanics refueling outage. ihen it was discovered that the problem would require mere effort than originally envisioned, JCPL'., initiated, with the help of the censultant that develcped Cyster Creek's second ten year progran, a review of the status of the first ten year program. Tne purpose was to identify those items that were complete with no outstanding deficiencies, those which have yet to be accanplished, anc specific problems that neede.1 to be addressed.
The review is essentially complete, the results have been reviewed and dl questionable areas resolved. A p-esentation en the status of the first ten year program was presented to I & E Fecion 1 inspectors en Tarch 11, 1930. The enly outstanding issues is that of reporting those few inspecticn commitments that cannot be inspeer.ed.
These ccmmitments were made by JCP&L before it was reccanized that the certain items could not be inspected.
The completion of this review with the' NPC and resolution of open items will cceplete the first ten year program. Tne first ten year program will be completed by the end of the 1980 outage.
The required Technical Specification Changes, to address inspections which cannet be done, will be submitted to the I;RC by September 1, 1980.
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Attachment B March 17, 1980 Page 16 MANAGD1ENT PLAN FOR THE OYSTER CREEK IUCLEAR GENERATING STATION BADIOIDGICAL COITTR1 PROGRIJ1
Mr. Victor Stello, Jr.
Attechmtnt B March 17, 1950 P3E' l' i
'DSLE OF COtmNTS I.
Introduction II. Padiological Control Organization III'. Training IV.
Deficiency Analysis /Comitment Tracking V.
Exposure Reduction / Procedure Preparation l
VI. Respiratory Protection VII. Dosimetry, Internal and External VIII. Radioactive Material IX.
Plant /Equipnent Decontamination
Mr. Victor Stello, Jr.
Attachment B March 17, 19S0 Page 18 1.
INTRODIX'1' ION The purpose of this plan is to identify the planned corrective actions in the Oyster Creek Nuclear Generating Station (OCNGS) management's commitment to eliminate the identified weaknesses in the OCIE Radiation Protection Program and to present a schedule for implementation and completion of these corrective actions.
The progress made in implementing and completing the identified corrective actions will be closely monitored by the Station Manager and tr.e Supervisor of Radiation Protection. A quarterly status report on the prcgress made in each of the major areas of deficiency listed below will be prepared by the Station Manager and Supervisor of Radiation Protection for the presentation to the Manager, Generating Stations-Nuclear, Oyster Creek Station. '1he progress made implementing this plan will be independently monitored by auditing groups and the Radiological Engineering Group. A status report of the Audit group's findirgs will be reviewed monthly with the Manager, Generating Stations-Nuclear, Oyster Creek Station, and the managerial personnel assigned responsibility for the specific corrective actions.
Certain actions have already been taken to improve the Radiation Protection Program performance. These actions are as follows:
1.
We President and Vice President-Generation, of Jersey Central Power & Light Company, held meetings with all of Oyster Creek's managerial and line supervisory personnel to express Oyster Creek's strong commitment to achieving a high qual'ity Radiation Protection Program. 'Ihey pointed out at these meetings that the Radiation Protection Department is responsible -for. establishing and maintaining the Radiation Protection Program, which includes the stoppage of any work.not being conducted in a radiologically safe manner. It is, however, the responsibility of all personnel at Oyster Creek to ensure compliance with the Radiation Protection Program.
2.
A permanent Supervisor cf Radiation Protection has been hired.
3.
Radiation Protection field operations has been reorganized to provide more supervision in the field, each with specific areas of responsibility. This reorganization, performed expressly for the outage, consists of a Radiation Protection Supervisor on each shift with four (4) Foremen on the first shift and two (2) Foremen on the back shift.
4.
Efforts have been made to improve contamination control and to emphasize management's commitment to a high quality Radiation Protection Program.
These efforts include:
a.
Inctures to all personnel at the station by the Station Manager and the Supervisor of Radiation Protection which discussed the Station's comitznent to a high quality Radiation Protection Program and techniques used to minimize contamination.
b.
Consultants were brought in to review the current Radiation Protection Program and associated contamination control practices and make recomendations for ir:provements. %ese recommendations are being included in the actions cited herein.
c.
Improved dressing / undressing areas were provided in an effort to minimize 3l
Mr. Victor Stello, Jr.
March 17, 19S0 Page 19 contamination spread.
d.
Improved frisking areas have been provided nearer to some work sites as well as at exit points.
In a!dition, new frisking instructions were developed and increased technician surveillance is provided to enforce these instructions at exit points. Significant improvements have been noted in frisking performance.
e.
Lectures specific to the radiological controls associated with refuelirg operations have been given to individuals working in the refueling area.
5.
Decontamination operations have been initiated in both the Reactor Building and some outlying areas with the goal to minimize arecs requiring protective clothing.
6.
A major effort is currently underway to remove " Hot Spots" from the Reactor Building floor drain system.
Hot Spots of up to 38 B/hr have been reduced to less tnan 100 mR/hr.
7.
Calibration procedures have been written for those radiation detection instruments identified in NBC letter Docket No. 50-219.
8.
The use of contamination containment areas and tents to keep contamination confined has been initiated and will continue to be increased.
9.
A major " housecleaning" effort is underway to remove extraneous material from within controlled areas.
10.
A Refueling Technical Director has been assigned to each shif t to coordinate activities on the refueling floor which includes radiological control practices.
- 11. All work was stopped on the refueling floor for several days while the area was decontaminated.
The following portion of this plan presents the future planned corrective actions, assigns responsibility for completion of the corrective actions, and assigns a due date for each action planned to correct the identified weaknesses in the Radiation Protection Program.
1.
Objective:
Estabish firm, visible commitment to a high quality, strictly adhered to Radiation Protection Program via a Radiation Protection Plan / Policy Statement, as well as with all levels of supervision and with workers on the subject.
A morale and attitude problem existed, and continues to exist to some degree today, in the radiation protection organization.
Personnel within the organization felt that they did not have the authority nor the management support to stop operations in the interest of radiological safety.
A Radiation Protection Plan, outlining the philosophy, basic policies and a.
objectives of OCNGS and Jersey Central Power & Light Company has been draf ted.
This plan will outline the Radiological Program, delineate each worker's responsibilities to support the program, and stress the management's commitment to a high quality Radiation Protection Program.
Action Due Date: April 15, 1980.
I.
Mr. Victor Ste lo, Jr.
Attachment B Mar:h 17,1980 Page 20 Eesconsible Individual: Supervisor, Radiation Protection b.
Supervisory and Management Development prog ams will be utilized to upgrade supervisory and management skills of the Radiation Protection Department witn emphasis in the Radiological Planning and Control areas as promulgated by tne Fadiation Protection Plan / Policy Statements.
Action Due Date:
Initiation 1 month after outage completion.
Responsible Individual: Supervisor Radiation Protection.
4
Str. Victor Stello, Jr.
Attachten: B ll3r:h l~,
1980 Page 21 II.
RADICIDGICAL CONTROL ORGANIZATICN l.
Objective:
Formalize the organizational structure for the Oyster Creek Nuclear Generating Station Radiation Protection Program.
Corrective Actions:
Reorganize the Radiation Protection organization to eliminate production a.related functions and provide better visibility and authority through a direct chain to senior site (or corporate) management.
Publish this organization and define areas of responsibility.
Action Due Date:
Subnit Technical Specification change by May 1, 1980.
Resconsible Individual : Nuclear Safety & Licensing Supervisor b.
The Supervisor of Radiation Protection reorganized the Radiation Protection Department. The department reorganization identifies the chain of command and delineates areas of responsibility within the Radiation Protection Department.
All contractor controlled radiological functions are included within this organization along with Oyster Creek employees under the management and direction of Oyster Creek / Jersey Central Power & Light Company supervisory personnel.
The Radiation Protecticn Department activities and functions were reorganized into four groups under the direction of management personnel as follows:
- 1) Radiological Engineering Group. An outline of this group's functions is as follows:
a)
Prepares procedures used in the Radiation Protection Department.
b)
Reviews radiation work meeting certain specified criteria to assure that radiological engineering concepts are employed for control of exposure (both internal and external), contamination spread and identifies other unique radiological problems and/or provides solutions.
c) Provides technical support for all Rad Con operations, such as evaluation of survey types and frequencies, instrument usage, contamination control techniques, etc.
d) Assists in performing internal audits of the Rad Con Program.
e)
Implements ard controls the exposure reduction program.
l f) Coordinates the respiratory piogram.
g)
Implements and controls a Radiological Deficiency Reporting system.
h) Reviews and approves radiological support material specifications.
i)
Reviews Surveillance Reports, Radiological Deficiency Reports, audit findings and incident reports to assist in determining program weaknesses and developing solutions.
I
Mr. Victor Stellop Jr.
Attachner.: E March 17, 1980 Page ::
j)
Evaluates exposure control levels and evaluates justifications for additional exposure requests.
- 2) Radiolocical Field Ooerations: An outline of this group's functions is as follows:
a)
Perform radiological monitoring and implement radiological controls in the field.
b) Staff to assure detailed supervision / review of routine work in order to obtain a quality product.
c) During outage conditions, ensure contractor technicians are supervised by, or work in conjunction with, JCP&L Rad Con personnel.
d)
Insure that all work in controlled areas goes through Bad Con responsible for that area.
e) Minimize standing Radiation Work Permits.
f) Provide areas near the work site to frisk ard rapidly evaluate samples.
- 3) Radiation Health and Dosimetry Grouo. An outline of this group's functions is as follows:
a)
Implament medical programs to establish adequacy in today's environment.
b)
Implement a bio-assay program including whole body counting, fecal and urine analysis.as required, and internal dose commitment.
c)
Develop job classification for dosimetry technicians along with a training program establishing minimum standards and requalification cycle.
d)
Establish a Quality Assurance Program, which consists of both internal audits and checks, as well as checks against NBS standards.
e)
Review systems ard procedures to determine adequacy and develop a plan for upgrade.
f)
Perform radiation instrument calibration, repair and accountability.
g)
Perform respirator testing.
h)
Perform specific radiological laboratory analysis associated with radiation health activities.
i) Tests, maintains and issues respriatory equipnent.
j) Maintains official radiation protection records.
- 4) Radiolocical Training. An outline of this group's functions is as follows:
a.
Responsible to the Supervisor of Radiation Protection to ensure adequate k
Mr. Victor Stello, Jr.
Attachmznt B March 17, 1980 Page 23 training is provided radiation protection personnel consi' stent with the department's responsibilities.
Action Due Date:
Continuing Responsible Individual: Supervisor Radiation Protection.
C.
To assist in providing the Radiation Protection Organization with the necessary documents, a reference library will be assembled in a central location.
Action Due Date: July 15,1980 Responsible Individual:
Radiological Engineering Supervisor.
l Mr. Victor Stello, Jr.
Attachment B
'l March 1~,
1980 Page 24 III. 'IRAINING
- l. @::tive: L4x;rade the knowledge, understanding and ability of Radiation Protection Technicians and radiological workers for performing their job assignments in the radiological environment by improvirg the training program.
Corrective Actions:
a.
The reorganization of the Radiation Protection Department includes the assignment of a Radiation Protection Training Coordinator reporting to the Radiation Protection Supervisor.
This individual will be responsible for formalizing the training program for Radiation Technicians and Group Supervisors. He will establish the minimum acceptable knowledge, understanding, practical abilities and experience for qualification of these personnel.
Qualification will be verified by the satisfactory performance on a written examination, demonstration of practical abilities and satisfactory performance on an oral examination covering the response to abnormal situations.
Particular emphasis will be placed on communcations with others, the Technician's responsibility to enforce radiological requirements and direct others during unusual situations.
Problem-solving sessions which review past abnormal situations or postulated potential situations with student participation will be used by having the students analyze the initial data, state imediate and supplementary protection and corrective actions, comunications with workers and operations personnel, takirg of additional radiological measurements, and a review of the radiological consequences of the postulated situation.
Training in the performance of practical abilities to assure personnel understand what is expected of them in performing the routine duties will be followed by verification of the performance of the practical abilities by supervision or specially qualified Technicians.
These practical abilities include performance during radiological spill drills.
1 The Radiation Protection Training Coordinator, will administer the program. The practical abilities performance will be verified by training or other qualified Radiation Protection personnel.
Procram Description Action Due Date: July 1, 1980 Responsible Individual: Supervisor Radiation Protection Start of Training Action Due Date: August 1, 1980 Resoonsible Individual: Supervisor Radiation Protection Qualification Procram Comolete Action Due Date: August 1, 1980 Resoonsible Individual: Supervisor Radiation Protection Note:
Radiation Protection Technician / Group Supervisor not qualified after the
$1
Mr. Victor Stello, Jr.
Attachment B March 1~,
1980 Page 25 above date will be restricted in duties, in writing, until qual'ified.
b.
Radiation orientation and retraining for all personnel except radiation protection personnel employed at OCNGS is being performed by the Training Department.
The Radiation Protection Training Coordinator will review the existing program, develop the criteria for minimum qualification of workers base (. on their trade / craft and provide guidance to the Training Department in establishing / implementing the Radiation orientation and retrainirg program for workers. 'Ihe procram will have both written and practical ability demonstration requirements.
This program will continue to inform the worker of the risks of radiation exposure, define radiation and contamination, state the limits and administrative control levels, state the worker's responisbilities and rignes, familiarize him/her with protective clothing, dosimetry and instruct in proper use of these devices. The worker will also have typical sources of radiation, contamination and airborne radioactivity identified and related to his/her type of work.
ALARA principles, procedures and response to abormal situations will be covered.
The Radiation Protection Training Coordinator will periodically audit / evaluate training, recomend changes to the training program, approve course materials, pesentations ard practical ability performance.
Program Description Action Due Date:
July 1, 1980 Responsible Individual: Training Supervisor Procram Start Action Due Date: August 1, 1980 Responsible Individual: Training Supervisor Program Conplete Action Due Date: Continuing Responsible Individual: Training Supervisor In addition to the trainirs programs identified above, special trainirg such c.
as mock-up training, walk-through exercises and detailed worker briefire will be required for ma]or evolutions and/or those tasks which may result in encountering unusual or uncertain radiological conditions with significant radiological risk or exposures expected.
The determination of the necessity for this special training will be made by the Radiological Engineering personnel based on the review of work procedures or task definitions. 'Ihe actual training / briefings will be conducted by technical, operations or maintenance personnel in conjunction with Radiation Protection personnel.
The guidelines for makirg this determination will be established by Radiological Engineering and disseminated to others.
In the interim, this determinat, ion will be made by the Radiation Protection Supervisor.
sb
,~
Mr. Victor Stello, Jr.
Attachter.: B March 17, 19S0 pag, 3 Establish and Distribute Guidelines Action Due Date:
2 months after plant start-up.
Resoonsible Individual:
Radiological Engineering Supervisor i
4 i
9 I
e
Mr. Victor Stollo, Jr.
Attachment B March 17, 1980 Page 2-IV.
DFEICIENCY ANALYIS/CCNMITMDTI TRACKING '
l.
Objective:
Improve self-analysis of problems and assure that identified corrective actions are taken.
Corrective Actions:
a.
To identify weaknesses in radiological work practices in a more timely fashion and reduce the number of findings resulting from formal audits, an "in house" surveillance program will be developed. It is the intent of this program to document all deficiencies noted, no mattter how apparently insignificant and whether or not they are immediately corrected, to monitor radiological work practices and identify weaknesses in the Radiation Protection Program. These deficiencies can be documente by any worker observing the condition. Copies of the deficiency reports will be distributed to the Radiological Engineering group for review and trend analysis.
Recurring minor deficiencies in a particular area or category may indicate a large underlying problem area which necessitates identification on the Radiological Deficiency Reporting System described below.
Action Due Date: May 15, 1980 Rescosible Individual:
Radiological Engineering Supervisor b.
Tb identify and track the more generic problems associted with the Radiation Protection Program on either an engineering or management level, a Radiological Deficiency Reporting (RDR) system will be imple'mented.
This system will identify the deficiency noted, the recommended corrective action, the response and an evaluation of that response. The Radiological Engineering section will be responsible for administering the system, but it will be available for use by others to identify and track radiologically related problems and their solutions.
Action Due Date: May 15. 1980 Resoonsile Individual:
Radiological Engineering Supervisor c.
Upgrade the current Radiological Audit Program to provide more frequent and indepth audits of various phases of the Radiological Program. These audits will divide the program into areas, such as those listed below and will be performed both by assigned in house personnel, including Quality Assurance, and by individuals recognized as experts in the specific fields. Frequency of these audits will be at least annually in each area and more frequently in areas that would be considered more likely to have problems or where small problems have a higher potential.
Tvpical Audit Areas' Exposure Control Instrumentation Contamination Control Radioactive Material Surveys Training Airborne Radioactivity Control Emergency Response Respiratory Protection Environmental Monitoring Ibsimetry AIARA t
Mr. Victor Stello, Jr.
Attachmens: B
~ :
March 17, 1980 Page 3 Conduct of these audits will be in accordance with pre-deve16 ped audit plans developed in consideration of statutory requirements, applicable regulatory guides and ANSI standards, etc., as well as state-of-the-art techniques.
Findings will be formally addressed and tracked, and responses will be reviewed by individuals capable of assessing the adequacy of the response.
Beainning Date: June, 1980 Resconsible Individual: Supervisor - Quality Assurance Engineering d.
In order to assure adequate management involvement and subsequent corrective actions, all incidents having radiological significance (see listing below) shall be thoroughly investigated, documented and follow-up corrective actions developed. Inclusive in this is immediately stopping associated work in all instances where job continuation could result in a recurrence or deteriorating situation.
CRITERIA FOR HOLDING CRITIQUE / PREPARING INCIDENT REPORT
- 1) External expos ~ure in excess of 10 CFR 20 limits.
2)
Internally deposited radioactivity greater than 5% of MPC.
- 3) Radioactive skin contamination.
- 4) Unplanned personnel exposure to concentrations of airborne radioactivity above the 40 hr MPC without respiratory protection.
- 5) Loss of Control of radioactive material.
- 6) Spread of contamination in excess of:
- 50,000 dpn above surrounding contamination levels within a contaminated area
- spread of contamination outside contemination area.
- more than 1 gallon of contaminated water 3 x 10 uci/cc (Co60)
- 7) Personnel entry into a radiation area or higher radiation area without proper dosimetry.
8)
Improper control of high radiation areas.
- 9) Unauthorized or improper disposal of radioactive material.
10)
Other reportable radiologically oriented violations of Technical Specifications, 10 CFR 19, 10 CFR 20.
Action Due Date: April 18, 1980 Resoonsible Individual:
Radiological Engineering Supervisor I
l
Mr. Victor Stello, Jr.
Attachmen: B March 17, 1980 Page 29 V.
EXPOSURE FEDUCTIOil/P?OCEDURE PREPARAT*0;;.
1.
Objective:
Revise and implement procedures which will ensure strict verbatim compliance and revise the procedure review practices to expedite implementation of radiation protection procedures and practices.
Corrective Acticns:
a.
The format for all Padiation Protection associated procedures will be restructured to achieve verbatim ccmpliance.
The revision for all radiatien protection procedures is estimated to require six ncntns of work. A pricrity li::t for procedure revision will be compiled with procedures which are in non-canpliance er important in assuring centinuing work is done in a safe manner Siven the highest pricrity. Incitded in tnis review will be the findings anc r acc:::nendations made by the !!uclear Regulatcry Comissicn Manage:nent inspection Peport: Docket !!c. 50-219/79-18. Following revision, each procedure will be field tested prior to formal implementation to ensure verbatim conpliance is possible.
Acticn Due Dcte: Priority listing, and schedule April 15, 1930 Bewrite Procedures October 15, 1980 Resocnsible Individual: Radiological Engineering Supervisor b.
A requirement shall be established that all work procedures which exceed any of the below noted requirements will be reviewed anc signed off by-RMiolcgical Engineering prior,to issue.
Radiological Engineering Review Criteria
- 1) Total job > 1 Rem
- 2) Airborne > MPC
- 3) Surface Contanination
> 100,000 dpn
> 50,000 dpn for airborne activity generating operations
- 4) Release of contaminated water > 3 x 10-5 uci/cc
- 5) Radiation levels > 1 F/hr Ganma
> 2 Rad /hr Beta
- 6) Non-routine Release to envirorment This will insure that ALARA concepts are being e:nployed, exposure budgets are developed, that contanination (airborne and loose surface) is being controlled, and, if there are any special Rad Con precautions, they are so noted. A policy statement is required to implement this innediately, as well as a procedure to be followed over the long term.
Action Due Date:
(a) Policy Statement May 1, 1980 (b) Procedure May 1, 1980 Resocnsible Individual: Radiological Engineering Supervisor
Mr. Victor Stallo, Jr.
Attachment B March 17, 1980 Page 30 c.
Action sign off steps will be added to all wrk procedu es for work on majcr evolutions auring the procedure review performed by Faiiolcgical ergineers. T:u purpose of these sign off steps is to ensure a responsible individual verifies by signature that the radiological safety requirenents have been satisfiec prior to continuing with the work evolution.
Acticn Due Date: September 1, 1980 Pesconsible Individual: Radiological Engineering Supervisor d.
To aid in radiation exposure reduction, man rem goals shall be establisned for each majcr jcb and approved by the Radiological Engineering Section.
In cddition, annual goals will be developed by radiation en;;;ineering. These goals will then be compared to actual returns for trend analysis and to deter: cine wast operations should be reviewed in more detail to further reduce exposure.
A revised system to accomplish the above, provide reports to cognizant supervision and to docunent action taken to reduce exposure is required.
Action Due Date: September 1, 1980 Responsible Individual:
Radiological Engineering Supervisor e.
A Radiological Work Practice Manual will oe developed which will establish routine techniques for working in a radiological envircnment. These techniques -
shall be directed towards minimizing the impact (e.g., reduce exposure, miniraize contamination spread) of working with radioactivity. This manual will continue to be upgraded as improved techniques are developed.
Action Due Date: June 1, 1930 Responsible Individual: Radiological Engineering Supervisor l
?!r. Victor Stello, Jr.
Attachment B March 17, 1980 Page 31 VI FESPIRATORY PROTECTICS 1.
Cbjective: Upgrade the Fespiratory Protection Program to assure compliar.ce with tiuREG-0041.
i A review of the Fespiratory Protection Program revealed that improvenents should be made in certain areas to further minimize the possibility of irgestion of radioactivity and to assure such ingestion, in fact, has not occurred.
The efforts described elsewhere in this plan support and cm.pliment the Fespiratory Protection Program, particularly in tne training, procedures, decontamination and dosimetry.
Ccrrective Actions:
a.
Management evaluation of the sources of airborne activity and engineering controls is necessary to:
1)
Identify and reduce the sources of airborne radioactivity
- 2) Minimize airborne concentrations 3)
Monitor airborne radioactivity in more probable areas.
In order to acconplish this evaluation, the Respiratory Protection Supervisor must have available and -review surface contamination, air sample and planned work evolution information along with known ventilation air flow information and whole body counting results. This continuing evaluation should identify trends and results in reccmmendations to minimize airborne radioactivity concentrations in the workplace.
Management Evaluation Program Description Action Due Date: May 16, 1980.
Responsible Individual: Radiological Engineering Supervisor Initial Management Evaluation Report and Recommendations Due Date:
Ma y 16, 19S0.
Responsible Individual: Radiological Engineering Supervisor i;0TE: Periodic evaluation reports will be issued, as well as special evaluation reports, where required.
b.
A review of existing respiratory protection equipment, air sampling equipment, portable ventilation, small and HEPA filters for use in venting operations, along with a review of facilities, is necessary tc identify engineered controls, reduce airborne sources and provide early warning of increases in airborne radioactivity concentrations.
Perferm Review and Identify Equipment and Facility Requirements
~
(Priorities and Target Dates) Action Due Date:
Pay 16,1960 Pespcnsible Individual:
Radiological Engineering Supervisor I
. =
Mr. Victor Stello, Jr.
Attachmtnt B March 17, 19SO Page 32 Precurement of Ecuipment Action Due Date: Continuing Fescensible Individual: Radiclogical Engineering Supervisor c.
Currently the administration of medical exaninations dces not specifically certify compliance with h"JREG-0041 nor de existing procedures give definitive guidelines for the handling of contaminated employees or those having ingested / inhaled radicactivity. Tne bicassay and medical exmination procedu es require revision to assure compliance with NUREG-0041 and ANSI N343-7c. Tne medical exmination for respiratory protection device users will be combined as a separate section with radiation worker physical exmination requirements for ease cf a.inistratien. Tne procedu e for routine and special bicassays will be revised and made compatible with the procedure for handling contaminated persennel, including follow-up actions such as decontamination, investigatien, dose asses =ent and medical evaluation.
Medical Examinatien Revision Acticn Due Date: September 5,1930 Fesocnsible Individual:
Radiological Engineering Supervisor / Supervisor of Faciclc51 cal health and Dosimetry.
Bicassay Precedure Revision Action Due Date: April 1, 1980 Fescensible Individual: Radiological Engineering Supervisor c.
The administration of the Respiratcry Protecticn Progran requires a policy statement and designation of the supervisor in writing and formalization / qualification of personnel who train / operate / test / issue respiratory protective devices. Be program will be described and qualified individuals designated in writing as required by NUREG 0041.
Action Due Date: Policy Statement April 4, 1980 Program description April 15, 1980 Responsible Individual: Vice President-Generation Radiological Engineering Supervisor e.
Be Respiratory Protection Supervisor must be made cognizant of the service air system as it relates to the air breathing system and approve all mcdifications, maintenance and operating procedures and changes to the system and procedures to assure the integrity of the systen is not ecmpranised and personnel are protected during these evolutions. The system will be certified as is to assure no previous work has canpranised it, s
Certification of System Action Due Date:
May 2,1930
?escensible Individual: Radiological Engineering Supervisor e
L
,ia Mr. Vic*or Stollo, Jr.
Attachment B March 17, 1980 Page 33 VII DDSIMETRY, IllTEFI;AL AND EXTERHAL 1.
Objective: Improve the internal and external personnel dosimetry prograr..
The TLD progran utilized by the Oyster Creek Nuclear Generating Station consists of the licensee's in-house system plus TLDs supplied and processed by an off-site carmercial vender.
The official dose records are established fran data supplied by the off-site vender. The licensee's in-house program serves as a back-up and provides information for high exposure jobs usually encountereJ during maintenance and refueling outages.
Acceptance criteria has not been established for the TLD Quality Control (Q:) Program. Procedural deficiencies exist regarding the type of personnel dosimetry equipment required for individuals allowed inside the restricted area.
Corrective Acticns:
a.
The current TLD system Quality Control Pro 5ran is being expanced to inclu.fe comparison with outside agencies. Tne outside agency will provide exposure of TLDs to known quantit~ies of Beta energies, Gamma energies (including energy dependence curves), and mixed beta-gamma fields commensurate with the levels of exposure anticipated to be encountered during routine operations and outage conditions.
Acticn Due Date:
May 16, 1980 Fesponsible Individual:
Radiological Health & Dosimetry Supe-visor b.
Inter-comparison of monthly processing results, both by the vendor and the licensee, will be performed to resolve processing techniques that do not meet an acceptable criteria of 25'. of the applied dose.
Action Due Date:
September 6, 1980 Responsible Individual:
Radiological Health & Dosimetry Supervisor c.
Personnel neutron dosimetry has not been utilized by the licensee.
!!eutron doses have been established based on survey data.
Neutron film has recently been established in key locations to determine ambient dose rates.
An evaluation of the need for Albedo neutron mcnitoring for personnel use anc/or for area monitoring will be perfonned, l
Action Due Date: November 21, 1980 Fespcnsible Individual:
Radiological Engineering Supervisor / Radiological Health
& Dosimetry Supervisor d.
Cosimetry procedures were upgraded to define the types of dosimetric devices required for personnel allowed inside the licensee's restricted area.
Additionally, associated dosimetry forms were upgraded to reflect the requirements for individuals wha are exempt fran dosimetry ist,uance.
Action Due Date:
Completed i
e.
Developnent of job classification for permanent dosimetry technicians, along
,,a Mr. Victor Stello, Jr.
Attachment B bbrch 17,1980 Page 34 with a training program setting minimun standards, subsequent certifications, and requalification cycle, is being prepared for the possiole processirq of all II.Ds on site. Initial training by the vender of the Desimetry Supervisor and at least one permanent dosimetry technician qualified in I & C repairs is required as a basis for this program.
Action Due Date: Job Classification - August 1, 1930 Training Program - September 1, 1980 Pespcnsible Indivicual:
Radiation Protection Supervisor f.
Through contractor support, technical expertise has been available and utilized to evaluate results obtained from the internal exposure monitorir.;
program.
In the future, these efforts will be coordincted and managed by tne Fadiation Health and Desimetry group formed in tne Radiction Protection Department reorganization described earlier in this plan.
Action Due Date: See Section II.
g.
The current bicassay program is being revised to formalize the basis for bicassays under rcutine conditions, following skin contamination or internal deposition, and evaluations for 90 sr oepositions.
All dose assessnents and evaluations of internally deposited radionuclides will be performed by the Radiation Health and Dosimetry group when established.
Action Due Date: April 18, 1980 Responsible Individual:
Padiological Engineering Supervisor i
Mr. Victor Stello, Jr.
Attachment B 4hrch 17, 1980 Page 35 VIII PADICACTIVE MATERIA *.
1.
Objective: Upgrade the labeling, packaging, handling and transporting of radioactive material within controlled areas, within the protected area, upon receipt and prior to shipment.
In order to control radioactive material, minimize the generation of solid radioactive waste, assure canpliance witn shipping cnd burial site packaging anc identification requirements, a well defined, organized and managed rmioactive material handling program is necessary.
Corrective Actions:
a.
In order to properly coordinate and effect tne necessary identification, radiocctive contents, package itegrity and minimize exposure due to rehancling, a ecmprehensive Radioactive Material Handling Program is required with a Radwaste Shipping Supervisor who is responsible to assure safe, effective handling, control, identification, packaging and shipping of this material. Tne designation of the individual and his responsibilities for procedures, equipnent, facilities and coordination of the progran is necessary.
Designate Radwaste Shipping Supervisor and Assign Specific Responsibilitie's hetion Due Date L August 1, 19o0 Responsible Individual: Unit Superintendent NOTE: During the interim, the designated individual will be responsible for taking the necessary pronpt actions to assure canpliance is realized in handling and preparing radioactive material for shipment to burial sites or other off-site shipnents.
b.
Preparation of procedures which define how radioactive material is received, monitored, identified, packaged, labeled, stored, transported from controlled areas, protected areas and off-site, including release criteria, shipout procedures, and the means for maintaining status, location and closecut of items, is required.
Identify Procedural Requirements, Date for Precedural Completion Action Due Date:
September 1, 19o0 Responsible Individual: Unit Superintendent I
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Attachment B hkrch 17, 1980 Page 36 IX PLA!.T/ECUIPMENT DECONTA'4INATION 1.
Objective: Decentaminate the reacter building, ecuipment and other cutlying areas to tne maximum extent practical.
Corrective Acticns:
a.
Assign.a task force consisting of representatives of Radiation Protection Operations and Maintenance to:
s 1) identify radiological conditions
- 2) develop priorities for decontamination 3) identify Hot Spots and evaluate renoval/ shielding 4) establish a plan / schedule for action Action Due Date: August 1, 1930 Respensible Individual: Station Manager b.
Establish an enforceable tousekeeping policy to minimize extraneous material fro.n within controlled areas.
Acticn Due Date: June 1, 1980 Responsible Individual: Station !'anager c.
Consistent with a. above, review and identify the sources of contanination and develop a plan of action to prevent or minimize recontamination.
Action Due Date: September 1, 1980 Responsible Individual:
Radiological Engineering Supervisor d.
Develop a program to reduce solid waste generation through minimizirg material which becomes contaminated, increase reuse of contaminated items and improve decontanination techniques.
Acticn Due Date:
September 1,1980 R_espcnsible Individual: Task Force I
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SUPERVISOR OF.
RADIATION PROTECTION 1
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