ML20032C443
| ML20032C443 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/20/1981 |
| From: | Phyllis Clark JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20032C437 | List: |
| References | |
| NUDOCS 8111100421 | |
| Download: ML20032C443 (9) | |
Text
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July 20, 1981 Mr. Thanas T. Martin Division of Engineering and Technical Inspection U.S. Nuclear Regulatory C:mmission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection Report 81-04 " Notice of Violation" In ac w rdance with 10 CFR 2.201, Enclosure 1 presents our response to the Notice of Violation involving the renoval of lumber fran a contamination mntrol point without the performance of smear surveys -
prior to raroval. Please note that this lunber was surveyed with a portable frisker prior to renoval which indicated that renoval was warranted; however, as stated in the Notice of Violation, a tauporary procedure change was not initiated to allow this.
While JCP&L accepts the Notice of Violation as " correct as stated",
certain other portions of the inspection report are not in agreanent with our understanding of the inspection results. Enclosure 2 presents a discussion of these areas of disagreanent based on what we perceived -
as occurring during the inspection and subsequent exit interview as ~
opposed to what appears in the inspection report. Mditionally, our concerns were also discussed with Mr. P. Knapp, Mr. R. Nimitz, and Mr. J. Joyner by telemn on July 9,1981.
Should you have any additional questions conce ning this response, please contac". Mr. Michael Laggart at (609) 693-6932.
Very truly yours, kl
/
S Philip R.7, Clark Vice President - Nuclear Jersey Centeral Power & Light Executive Vice President -
GPU Nuclear 8111100421 811103 PDR ADOCK 05000219 G
PDR GPU Nuclear is a part of the General Pubhc Utihties System
s Mr. Thomas T. Martin Page 2 July 20, 1981 Signed and sworn to before ne this
,4D day of 1981.
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OttA Notary Public du V TJ!t:L (lC..W k"U f El' Cf Nld JtRsty
% Lw.%n byan wnu,31. Ins attachmcnts cc: Director Office of Inspection and Enforcertent U.S. Nuclear Pcgulatory Ocnmission Nishington, D.C.
20555 Director Office of Inspecticn and Enforcamnt U.S. Nuclear Regulatory Conmission Region I 631 Park Avenue King of Prussia, PA 19406 NIC R2sident Inspector Oyster Creek Nuclear Generating Station Fbrked River, IU 08731 A
r-o Mr. % mas T. Martin Page 1 July 20, 1981 ENCIOSURE 1 he Notice of Violation contained in IE Inspection Report 81-04 states in part:
Technical Specification 6.8, Procedures, states, in part:
"6.8.1.
Written pro dures shall be established, inpl mented, and maintained that meet or exceed the requirenents of
... Appendix 'A' of the Nuclear Regulatory Ommission's Regulatory Guide 1.33-1972...". Regulatory Guide 1.33-1972, Section A.4, lists procedure adherence and tarporary change method as an activity to be covered by written procedures.
Mministrative Procedure No.107, Procedure Control, Revision 13, developed pursuant to the above, requires in Section 5.4.2 that procedure changes which cannot be delayed for normal review and approval may be made as "Tenporary Changes" provided they do not change the intent of the original procedure and are approved by No (2) members of the supervisory staff, one of which must be a Group Shift Supervisor or SRO Licensed Group Operating Supervisor, and the other mernber must be responsible in the area or category covered by the prooAure.
Rac11ation Protection Procedure 915.4, Contamination Control, Revision 0, requires in Section 5.8 that objects brought out to the contamination control point for release be surveyed for smearable and fixed contamination.
Contrary to the above, on March 3, 1981, a contractor ram ntion protection supervisor authorized the removal of lumber fran a contamination control point without the performance of smearable contamination checks prior to the retoval and without making a tatporary change to Procedure 915.4. The Supervisor was unaware of the procedure change requirenents.
i This is a Severity Level V Violation (Supplanent IV).
JCP&L has determined that the Notice of Violation is correct as stated.
The.following presents our response to the violation indicating:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full empliance will be achieved.
1.
Corrective steps which have been taken and results achieved.
1 Upon identification of the failure to perform smearable contantination surveys on the lunber retoved frm the contaminated area, the lumber was resurveyed and found acceptable for release on March 3, 1981.
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r Mr. 'Ihmas T. Martin Page 2 July 20, 1981 Additionally, on March 4,1981, a temporary procedure change was inplemented to allow release of certain itms frm contaminated areas based on direct frisking with portable instr ments without the need for smear surveys. All Radiological Control Field Technicians were instructed on March 5,1981, as to the new requirments delineated by the tenporary procedure change which was subsequently approved by the Plant Operations Review Ccunittee on April 2, 1981, and issued as a permanent change on April 22, 1981.
'1he actions above resulted in confirmation that the material removed frun the contaminated area was free of adverse contamination and a procedure revision to prevent reccurrence of this non-ocmpliance was initiated.
2.
Corrective steps which will be taken to avoid future violations.
With regard to the failure to initiate a tsporary procedure change, training was conducted during February 1981 pertaining to Procedure 107 and the actions required to perform work not authorized by the procedure (i.e., initiate ta porary procedure change). In order to reinforce this' training, a directive was issued on July 17, 1981 to all Radiological Control personnel sphasizing the need for strict adherence to all procedures and that deviations nust be supported with a tmporary procedure change per the requirements of Procedure 107.
3.
Date when full ccmpliance will be achieved.
Full empliance with Technical Specification 5.8 Procedures in this regard was achieved on March 3, 1981. It is expected that the actions taken above will preclude a recurrence of this situation in the future.
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Mr. 7hmas T. Martin Page 1 July 20, 1981 ENCIDSURE 2 Upon reviewing IE Inspection Report 81-04 dated June 24, 1981, it became apparent that there was sme inconsistency between the written report and our understanding of the inspection results based on the exit interview and other discussions during the course of t'ie inspection. Consequently, on July 9,1981, we contacted Mr. P. Knapp, Mr. R. Nimitz, arxi Mr. J. Joyner by telecon in order to discuss our concerns. During this discussion, it was agreed that in our response to the Notice of Violation we would formally specify the areas of concern with the inspection report indicating our perception of the inconsistencies. The following discussion itmizes those areas which we feel do not accurately reflect the inspection results.
1.
Report Section 3, Page 2 The licensee is redesigning and rebuilding the control rod drive rebuild area (75 ft. elevation reactor) to provide operator control and confin m ent of the control rod drive rebuild work. Included in this work is the installation of glove box hoods to be utilized for airborne radioactivity control during the control rod rebuild work.
Each hood will be connected to a 1250 CEM ventilation syst s.
Clarification:
While this se: tion is essentially correct as stated, we did not specify that glove box hoods would be utilized nor did we specify a 1250 CFM ventilation connection. Our intent is to provide containment hoods connected to a ventilation syst s; however, since this modifi-cation is still in the design stage it is not possible to specify at this time the type of hoods nor the ventilation flow rate.
2.
Report Section 3, Page 3 The licensee is currently reviewing the supply of radiation survey instrtrnents and airborne radioactivity sanpling equipnent at the facility to ensure adequate instrumentation will be available for the upordng outage. Due to a backlog of instruments to be repaircd and calibrated at the facility, the licenscm3 plans to ship these to the Three Mile Island calibration facility to eliminate the backlog.
Clarification:
The first sentence of this section is correct as stated; however, the planned resolution is one of several alternatives that we proposed to the inspector. Subsequently, it was decided to acquire additional technicians to perform this work in lieu of the other options (i.e.,
send to UMI).
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Mr. Thmas T. Mrtin Page 2 July 20, 1981 3.
Report Section 3, Page 3 ihe licensee is currently performing extensive clean-up of the facility in preparation for the upaming outage. The clean-up is beirg performed to eliminate and maintain clean any previous contaninated areas, and to maintain the facility in a clean and easily accessible condition.
Clarification:
Strict interpretation of this statment infers that all contaminated areas would be decantaminatod. This is inpractical frm both an operational and ALARA viewpoint. Our intent was to decontaminate as nuch of the area as feasible and to make every effort to maintain the area in the cleanest possible condition recognizing operational considerations and ALAPA goals.
4.
Report Section 3, Page 3 The licensee has constructed shielded frisking booths on each elevation of the Reactor Building for personnel frisking purposes. The licensee will place additional booths, such as at the drywell entrances and exits, as needed during the outage.
Clarification:
Presently, as well as at the time of the inspection, there is no frisking booth on the 75' elevation of tha Reactor Building. Although, a friskirg booth will be provided at this elevation in the future.
5.
Report Section 5, Page 6 Upon inspector identification of this it s to the licensee's Radiological Controls Manager, the release of the lunter was innniiately halted.
Since none of the lunber had yet left the site, the lumber was re-checkal to ensure it met Procedure No. 915.4 requirments. In addition, because of the Group Radiation Protection Supervisor's lack of knowledge regarding procedure changes, the licensee's Radiological Lbntrols Mamiger indicated a directive would be issued by March 11, 1981 to the entire Radiological Controls Department not to change any procedures unless the change was performed in accordance with Procedure No. 107.
The Radiological Controls Manager indicated trairdng sessions would be held to instruct the Department in Procedure No.107 requirments (50-219/81-04-03).
Clarification:
We do not agree that a ccmnitment was made to issue a directive by the March 11, 1981, date. During our telecon with the NRC inspection personnel, it was agreed that this its was not addressed in the exit inter /iew; however, the inspector stated that he had obtained this camnitment during the course of his inspection.
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Mr. % mas T. Martin Page 3 July 20, 1981 Clarification:
(Continued)
While we do not disagree with the stated action, see Attachment 1, we do not believe we cmmitted to the date specified. In the future, we will make every effort to ensure that all itms of this nature are specifically discussed at the exit interview and all parties are in agrement with the resolution decided upon. As discussed with the trRC inspection personnel, we too are deeply concerned that this type of misunderstanding could occur.
6.
Report Section 6b, Page 9 As a result of the above, the licensee's Radiological Controls Manager will require all field radiological control technicians involved with use of respiratory protective equipnent to review Procedure 915.5,
" Respiratory Protection" to ensure they are thoroughly familiar with the requirments for use of supplied air. The technician review of this procedure is to be empleted by March 12, 1981. Documentation of this procedure review will be available for NRC review (50-219/81-04-06).
Clarification:
Again, while we take no issue with the action stipulated, we do not believe we agreed to a cmmitment date of March 12, 1981 for empletion of this action. As with Its 5, this ommitnent was not discussed at the exit interview. We specified action was accmplishal on March 12, 1981, and the appropriate documentation is available. Additional training was also given on June 12, 1981, which u.cluded personnel frcm the Operations and Maintcnance Departments.
7.
Report Section 7b, Page 11 The inspector could not couplete the entire review of the procedures since, as indicated above, the licensee was revising current procedures and was issuing aMitional procedures to fully inp1 ment his Radioactive Material Management Program. The licensee was utilizing a contractor to provide aMitional review of radioactive waste procedures. Licensee representatives indicated the procedures were to be in place within approximately two weeks.
Clarification:
This statment is incorrect in that a contractor is not providing the indicated review. This review is being acomplished by in-house personnel.
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Mr. Thcmas T. Martin Page 4 July 20, 1981 8.
Report Section 7d, Page 12 During the above reviews, the inspector noted the licensee to be estimatim the total weight of dry ocmpacted material for the purposes of determining ccmpliance with the ISA shipping requirenents -(i.e.,
millicuries /gm). The inspector discussed this matter with the licensee's Radioactive Waste Shipping Supervisor and determined that the licensee had recently obtained a new scale for weighing the waste and was reviewing the need to construct a weighing area.
The licensee is, in the interim, utilizing conservative weight estimates to ensure ocmpliance with applicable regulatory requirenents. The licensee evaluated the weight limits with respect to the LSA limits and determined that the limits would not be exceeded. The inspector indicated this area would be reviewed during a subsequent inspection (50-219/80-04-08).
Clarification:
Although a scale was received, it was not acceptable for this purpose and a new scale has been ordered. All other aspects of this staterant are correct as stated.
9.
Report Section 8, Page 16 The licensee's Radiological Controls Manager indicated he would take action to reduce the number of extended RWPs in use. This action is to include a directive which will be issued to the R;wiinlogical Centrols Department to limit the use of extended RWPs and to require the Radiological Field Control Manager's approval of any new extended RWPs. A procedure change to inplenent the above is also to be provided.
This action is to be cmpleted by March 11, 1981. 'Ihe licensee is to reinstruct the technicians in the necessity to maintain the survey status board up to date (50-219/81-04-11).
7 Clarification:
This statenent is incorrect in that our ocmmitment was to issue a directive, not a procedure change. This action was accmplishal. As a result of the inspection report, we initiated a tauporary procedure change in accordance with the objective stated above. This was acocmplished on July 15, 1981, and is currently being reviewed by the Plant Operations Review Comnittee for penranent change approval, t
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Mr. '1hcmas T. Martin Page 5 July 20, 1981 In sumary, it is unfortunate that misunderstandings of this nature have occurred. We are particularly concerned that a misconcq: tion of specific cmmitments (Items 5, 6, and 9) for specified dates has resulted. In our conversations with the NIC inspection personnel, all parties were concerned that scznewhere inaccurate information developed. Please be advised that it is our ocanpany policy that all enployees cooperate fully with NIC inspection personnel in providing accurate information by whatever means necessary (i.e., reference to cognizant personnel, production of appropriate documentation, etc.).
In the future, we will make every effort to assure that all inspection findings are appropriately discussed at exit interviews with upper level managenent in order to prevent misocumunications such as those that occurred during this inspection. To this end, we request that all cmmitments be discussed during the exit interview so they can be concurred in/ approved by upper level managenent.