ML19331E198

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Forwards IE Insp Rept 50-219/80-03 on 800121-25 & Notice of Violation.Details Withheld (Ref 10CFR2.790)
ML19331E198
Person / Time
Site: Oyster Creek
Issue date: 05/19/1980
From: Grier B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Finfrock I
JERSEY CENTRAL POWER & LIGHT CO.
Shared Package
ML19331E197 List:
References
NUDOCS 8009090168
Download: ML19331E198 (2)


See also: IR 05000219/1980003

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION I

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$31 PARK AVENUE

KING OF PRUSSIA, PENNSYLVANIA 19406

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Orckst No. 50-219

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Jersey Central Power'and Light Company

ATTN:

Mr. Ivan R. Finfrock, Jr.

Vice President

Madison Avenue at Punch Bowl Road

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Morristown, New Jersey 07960

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Gentlemen:

Subject:

Inspection No. 50-219/80-03

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This refers to the inspection conducted by Mr. R. L. Nimitz and Mr. G. P.

Yuhas of this office on January 21-25, 1980, at the Oyster Creek Nuclear

Generating Station of activities authorized by NRC License No. DPR-16 and to

the discussions of our findings held by Mr. Nimitz with Mr. J. L. Sullivan at

the conclusion of the inspection, and to subsequent telephone discussions

between Mr. D. Turner of your staff and Mr. Yuhas on January 31, 1980 and

Mr. J. Devlin of this office and Mr. Carroll on March 10, 1980 and telephone

discussions between Mr. Nimitz and Mr. Turner on April 2,1980.

Areas examined during this inspection are described in the Office of Inspection

and Enforcement Inspection Report which is enclosed with this letter.

Within

these areas,-the inspection consisted of selective examinations of procedures

and representative records, interviews with personnel, measurements made by

the inspector, and observations by the inspector.

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Based on the results.of this inspection, it appears that certain of your

activities were not conducted in full compliance with NRC requirements as set

forth in the Notice of Violation, enclosed herewith as Appendix A.

These

items of noncompliance have been categorized into the levels as described in

our correspondence to you dated December 31, 1974.

This notice is sent to you

pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations.

Section 2.201 requires you to

submit to this office, within twenty (20) days of your receipt of this notice,

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a written statement or explanation in reply including:

(1) corrective steps

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which have been,taken.by you and the results achieved; (2) corrective steps

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which will be taken to avoid further items of noncompliance; and (3) the date

when full compliance will be achieved.

In addition to the need for corrective

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action regarding these specific items of noncompliance, we are concerned about

the implementation of your management control systems that permitted them to

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occur.- Consequently, in your reply, you should describe in particular, those

actions taken or planned to improve the effectiveness of your management

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control systems.

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Item number.B, C, and D, shown in the Notice of Violation enclosed with this

letter are recurrent items.

In your response to this letter please give this

matter-your particular attention.

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J:rs:y C' ntral Power cnd Light

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Company

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In addition, we are concerned with the implementation of your facility ALARA

program.

Although your response to Inspection 79-18 addresses ALARA requirements

associated with work procedures, the description does not include methods of

assuring ALARA concepts are applied to day to day activities and activities

not necessarily associated with written procedures.

In your response, please

address this matter.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, code of Federal Regulations, a copy of this letter and the enclosures

will be placed in the NRC's Public Document Room.

If this report contains any

information that you (or your contractor) believe to be proprietary, it is

necessary that you make a written application within 20 days to this office to

withhold such information from public disclosure. Any such application must be

accompanied by an affidavit executed by the owner of the information, which

identifies the document or part sought to be withheld, and which contains a

statemen: of reas m s which addresses with specificity the items which will be

considered by the Commistion as listed in subparagraph (b) (4) of Section

2.790.

The information sought to be withheld shall be incorporated as far as

possible into a separate part of the affidavit.

If we do not hear from you in

this regard within the spuified period, the report will be placed in the

Public Document Room.

Additionally, and in accordance with Section 2.790(d) of the NRC's " Rules of

Practice, Part 2, Title 10, Code of Federal Regulations, documentation of

findings of your control and accounting procedures for safeguarding special

nuclear materials and your facility security procedures are exempt form dis-

closure; therefore, the pertinent section of the inspection report will not be

placed in the Public Document Room and will receive limited distribution.

Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Sincerely,

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Boyce H. Grier

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Director

Enclosures:

1.

Appendix A, Notice of Violation

2.

Office of Inspection and Enforcement

Report No. 50-219/80-03

(Contains 2.790 Information)

cc (w/o pages 15 and 16 of Report):*

J. T. Carroll, Station Superintendent

R. J. Hunter, Manager, Safety and Security

Contains 10 CFR 2.790 Information

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Inspection 80-03

APPENDIX'A

NOTICE OF VIOLATION

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Jersey Central Power and Light Company

Docket No. 50-219

License No. DPR-16

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Based on the results of an NRC inspection conducted on January 21-25, 1980, it

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appears that certain of your activities were not conducted in full compliance

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with NRC regulations and the conditions of your license as indicated below.

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Items A, B, and D are Infractions. Item C is a Deficiency.

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A.

10 CFR 20.201, " Surveys", states in Paragraph (b), "Each licensee shall

make or cause to be made such surveys as may be necessary for him to

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comply with the regulations in this part." A survey as defined in Para-

graph 20.201(a) means, "an evaluation of the radiation hazards incident

to the production, use, release, disposal, or presence of radioactive

materials or other sources of radiation under a specific set of conditions.

When appropriate, such evaluation includes a physical survey of the

location of materials and equipment, and measurements of levels of radiation

or concentrations of radioactive material present."

10 CFR 20.202, " Personnel Monitoring" states in Paragraph (a) that "Each

licensee shall supply appropriate personnel monitoring equipment to, and

shall require the use of such equipment by . . . (1) Each individual who

enters a restricted area under such circumstances that he receives, or is

likely to receive, a dose in any calendar quarter in excess of 25 percent

of the applicable value specified in paragraph (a) of 6 20.101."

Contrary to the above, as of January 25, 1980, individuals entering parts

of the restricted area were exposed to intensities of beta radiation up

to 1500 mrad /hr and a survey was not performed to determine if appropriate

personnel monitoring devices were required or provided pursuant to 10 CFR 20.202.

B.

10 CFR 20.103(c), " Exposure of individuals to concentrations of radioactive

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materials in air in restricted areas" requires in part that: When respira-

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tory protective equipment is used to limit the inhalation of airborne

radioactive material pursuant to paragraph (b)(2) of this section, the

licensee may make allowance for such use in estimating exposure of indivi-

duals to such materials provided that such equipment is used as stipulated

in Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection."

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Section c.4 of Regulatory Guide 8.15 states in part, "The licensee is to

maintain and implement a. respiratory protection program that includes, as

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a minimum...e. Written operational and administrative procedures for con-

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trol, issuance, proper use, and return of respiratory protective equipment..."

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Contrary to the above, as of January 23, 1980, no adequate operational or

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administrative procedures addressing control and issuance of breathing air

fittings was included in the licensee's respiratory protection program.

Licensee procedure 915.5 addressed responsibility for this area, however,

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this guidance was inadequate to prevent improper use of the fittings.

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C.

10 CFR 20.203(f) requires that each container of licensed material shall

bear a durable,. clearly visible label identifying the radioactive contents.

The label shall bear the radiation caution symbol and the words

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" Caution Radioactive Material"

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or

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" Danger Radioactive Material"

The label shall also provide sufficient information to permit individuals

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handling or using the containers, or working in the vicinity thereof to

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take precautions to avoid or minimize exposures.

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Contrary to the above, on January 21, 1980, two 4' x 4' x 6' containers

located outsidt .he Old Radwaste Building contained licensed radio-

active material and were not labeled and no exemption applied.

2.

Contrary to the above, on January 25, 1980, two 55 gallon drums

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located on the floor of the torus contained licensed radioactive

material and were not labeled and no exemption applied.

The drums

indicated up to 5000 millirem /hr on' contact.

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D.

Technical Specification 6.11, " Radiation Protection Program" requires

that procedures for personnel radiation protection shall be prepared

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consistent.with the requirements of 10 CFR Part 20 and shall be approved,

maintained and adhered to for all operations involving personnel radiation

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exposure.

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1.

Procedure 902.7, Revision 1, "Drywell Occupancy and Evacuation

During Fuel Handling Operation", developed pursuant to the above,

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requires in section 5.4 that the alarm set point of the radiation

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monitors shall have alarm set' points set between two and five times

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the value of the background in the area of the detector.

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Contrary to the above, during fuel movement on January 24, 1980, at

9:00 p.m. one of the two' radiation monitors, used for evacuation

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purposes, was found to have an alarm set point twelve (12) times the

value of the background in the area of the detector.

2.

Procedure 915.7, Revision 0, " Personnel Monitoring", developed pur-

suant to the above, states . in section 5.3, "the TLD and self-reading

dosimeters shall normally be worn in the front of the body between

the head and waist".

Contrary to the above, on January 21, 1980, one individual was

observed wearing his TLD and self-reading dosimeters suspended about

three inches below and behind his belt against the left rear pocket.

The individual was operating an instrument calibrator containing

161.4 curies of Cs-137.

The location of the dosimeters precluded

proper personnel monitoring in the event of the calibrator monitor

failure.

3.

Procedure 9.11.1, Revision 0, " Radioactive Waste Material Storage",

developed pursuant to the above, states in procedure section 5.1,

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that "all radioactive waste material shall be stored in such a

manner so as to reduce to a minimum:

. . 5.1. 2 The radiation exposure

dose rates for working personnel."

Contrary to the above, on January 24, 1980, radioactive waste was

found at the personnel entrance to the torus and on the torus catwalk

emanating contact dose rates of 40 millirem /hr and 3000 millirem /hr,

respectively.

Personnel, in going to and from their work locations,

repeatedly passed by the drums of waste and were at times observed

to be leaning against the drums at the torus entrance.

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