ML20044H212
| ML20044H212 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/28/1993 |
| From: | Joseph Furia, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20044H208 | List: |
| References | |
| 50-219-93-07, 50-219-93-7, NUDOCS 9306080076 | |
| Download: ML20044H212 (8) | |
See also: IR 05000219/1993007
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
9
Report No.
50-219/93-07
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Docket No.
50-219
License No.
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Licensee:
GPU Nuclear Corporation
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l Upper Pond Road
{
Parsippany. New Jersey. 07054
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Facility Name:
Ovster Creek Nuclear Generatine Station
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Inspection At:
Forked River. New Jersev
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.;
Inspection Conducted:
May 17-18.1993
t
b do, b hd
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Inspector:
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J. Furia, fIeoior Radiadon Specialist,
date
Facilities Radiation Protection Section (FRPS),
Facilities Radiological Safety and Safeguards
,
Branch (FRSSB), Division of Radiation Safety
and Safeguards (DRSS)
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Approved by:
/ ff C
C~-d c
5-2M3
W. Pasciak, Chief, FRPS, FRSSB, DRSS
date
Areas Inspected: Reactive inspection of the events involving work in the fill aisle of the
New Radwaste Building on May 7 and May 11, 1993.
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Results: Five apparent violations of NRC requirements were identified. These include:
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failure to follow plant Technical Specifications and procedums in initiating a radiation work -
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permit (RWP) in that the RWP did not clearly define the work; failure to survey a work area
and failure to provide adequate instructions to workers (grouped as a single apparent
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violation); failure to follow plant Technical Specifications and procedures in not conducting
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an ALARA review of the work being performed in a highly contaminated area; failure to
perform air sampling required to properly select respiratory protection equipment, and;
failure to conduct appropriate air sampling during work.
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9306080076 930531-
ADDCK 05000219'
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DETAILS
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1. Personnel Contacted
l.1 Licensee Personnel
,
- F. Applegate, Quality Assurance Monitor
- J. Barton, Vice President and Director, Oyster Creek
- T. Blount, NCSS Staff, GPU Nuclear
- W. Cooper, Radiological Engineering Manager
H. Daniels, Group Radiological Controls Supervisor
- B. DeMerchant, Licensing Engineer
<
J. Derby, ALARA Supervisor
- R. Hillman, Manager - Radwaste Operations
L. Johnson, Radiological Shift Technician
- S. Levin, Director, Operations and Maintenance
D. Morris, Site Supervisor, Chem-Nuclear Systems, Inc.
R. Nash, Radiological Engineer
C. Pollard, Manager, Radiological Controls Field Office
M. Selvage, Radiological Controls Technician
- R. Shaw, Radiological Controls Director
M. Zott, Westinghouse /HydroNuclear Technician
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l.2 NRC Personnel
- S. Pindale, Resident Inspector
- D. Vito, Senior Resident Inspector
.
- Denotes those present at the exit interview on May 18, 1993.
2. Description of Events
On May 7 and May 11,1993, the licensee identified events which were not in
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accordance with licensee expectations, and potentially not in compliance with
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regulatory requirements, regarding work being conducted in the New Radwaste
Building (NRW). Prior to May 7,1993, the license's Radwaste Operations section -
had identified a need to clean-up and decontaminate an area of the NRW on the 23'
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elevation, known as the fill aisle. This area, a posted locked high radiation area
which also required respirator usage, included areas for storage of filled waste liners,
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the processing of waste liners, associated pumps and equipment, and the batch tank.
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The batch tank was located in a shielded cubicle on the nonheast side of the fill aisle,
the shield creating an 8 foot deep pit around the batch tank. Over the course of
several years, the floor of this pit had become covered with spilled powder type resin,
from overflowing the batch tank, and miscellaneous wood, cement and herculite. No
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entries had been made into the pit for several years.
On May 3,1993, a contractor to the licensee submitted a request for a Radiation
Work Pennit (RWP), to allow for the hydrolasing of the fill aisle, and the removal of
all obstructing debris. The RWP (No. 930254) was prepared by an ALARA
technician and approved by the ALARA Group Radiological Controls Supervisor.
Although it was the intention of the Radwaste Operations section to decontaminate all
areas of the fill aisle, which would include entry into the batch tank pit area, this was
not clearly communicated to the ALARA technician orally or by means of the RWP,
as it did not clearly derme the areas to be worked and/or entered. Due, in pan, to
this miscommunication, the licensee determined that an ALARA myiew was not
required for this work. In addition, the miscommunication resulted in the preparation
of an RWP that did not adequately describe the scope of the task, panicularly as it
related to work in the batch tank pit. This is an apparent violation of Technical Specification 6.11, as licensee procedure 9300-ADM-4110.04, " Radiation Work
Pennit," pamgraph 7.2.3, states in pan that the RWP, in Block No. 3: Work
Description, shall provide sufficient detail for Radiological Controls personnel to
understand the scope of the task (50-219/93-07-01).
On May 7,1993 thme contractor workers went to the Radiological Controls (RadCon)
yard office for the purpose of entering the proposed work area and scoping the work
to be perfonned. Two workers, who would be responsible for the hydrolasing
activities, signed in on RWP 930254, and wem involved in a pre-job discussion with
the Group Radiological Contmls Supervisor (GRCS) for the yard area. The
Radiological Controls Technician (RCT) assigned to provide job coverage was not in-
attendance at the meeting. At this meeting it was discussed that entry into the batch
tank pit was going to be made. The GRCS instructed the workers to dress out in the
protective clothing mquired by the RWP, including wearing of alarming dosimeters
by at least one member of each work group, and contacted the RCT by telephone,
instructing the RCT to perfonn a survey, as required by the RWP, of the fill aisle-
prior to anyone in the work group entering the area. The GRCS assumed that the
RCT understood that a survey of the batch tank pit was to be a pan of this survey,
but did not provide explicit instmetions on this point. The RCT assumed that this
entry was like other entries made over the past several years, and that no entry to the
batch tank pit was to be made. The RCT met the work group outside the entrance to
the fill aisle, and instructed them to remain outside the fill aisle for several minutes
while she conducted the survey. After several minutes, the work group entered the
fill aisle and were met by the RCT, who informed them of dose rates in the various
areas, including a dose mte of 350 to 500 millimm per hour (mR/hr) at the batch
tank. This reading was, in fact, taken on top of the shield wall adjacent to the tank,
but was not the reading inside the batch tank pit,'which had not been taken. The two
hydrolasing contractors assumed that such a survey of the batch tank pit had been
conducted, and that the readings given by the RCT were for inside the pit.
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The two hydrolasing contractors proceeded to the batch tank area while the RCr
continued to survey areas of the fill aisle, specifically the pump area, which was not
expected to be an area entered by the workers that day. One of the contractors went
up a ladder onto a block wall around the batch tank, and then went down a second
ladder into the batch tank pit. The worker immediately noticed that the alarming
dosimeter he was wearing was accumulating dose at a rate much greater than he
would expect in a 350-500 mR/hr field. Within approximately 10 seconds, the
worker climbed back up the ladder to the top of the block wall, and asked his co-
worker to get the RCT. The RCT arrived at the pit area, discussed the situation with
the contractor, and the contractor offered to take a meter from the RCT and re-enter
the pit in order to determine dose rates (the RCT was not wearing a set of plastics,
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which were required for entry into highly contaminated areas, such as the batch tank -
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pit, while the two contractors were wearing full plastics) The RCT checked the
contractor's alarming dosimeter and noted a dose of 25 millirem at that time. The
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contractor re-entered the pit, with the RCT observing from on top of the block wall.
Dose rates were measured as high as 12 R/hr on contact with the batch tank and 10
R/hr on the floor. The contractor then exited the pit, and, together with the RCT,
discussed the situation with the other workers in the fill aisle. The RCT determined
that no further entries should be made into the pit, but that the workers could remain
in the general fill aisle areas. The RCT checked the contractor's alarming dosimeter,
which indicated a dose of 55 millirem. The dose of record was subsequently
determined to be 72 millirem for this entry, correcting for dose stratification within
the pit. The RCT then contacted the GRCS and informed him of the events and dose
rate readings.
The worker entered the pit area without a survey having been performed and without
receiving instructions of the radiological conditions. This is an apparent violation of
10 CFR 20.201(b) and 10 CFR 19.12. Surveys of radiation hazards, in accordance
with 10 CFR 20.201(b), are required to be made by the licensee as necessary to
comply with regulations and as are reasonable under the circumstances to evaluate the
extent of radiation hazards that may be present. Further, all individuals working in a
restricted area are required by 10 CFR 19.12 to be instructed of the radiological
conditions, with the extent of the instructions commensurate with the potential
radiological health protection problems. These apparent violations are aggregated as a
single apparent violation. (50-219/93-07-02)
On the afternoon of May 7, the GRCS, together with the RCT, contractors and a
representative from Radiological Engineering conducted a meeting to discuss the'-
cause of that morning's events and to better understand the scope of work to be
performed under the RWP. In spite of the significant work scope changes in the
RWP, the intention of the work to include entries into the batch tank pit, a highly
contaminated area, and to remove highly contaminated materials from the pit, an
ALARA review was not initiated for this work. This is an apparent violation of
Technical Specification 6.11, as licensee procedure 9300-ADM-4010.02, "ALARA
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Review Procedure," paragraph 7.3.2, requires that an ALARA review be performed
if one or more of five criteria exist. Criterion five includes any task inside highly
contaminated systems or components. (50-219/93-07-03)
.
On May 11, with work continuing in the fill aisle, four contractor technicians, split
into two groups of two members each, together with an RCT, entered the fill aisle,
wearing full sets of protective clothing, plastics, and negative pressure full-face
respirators, as required by RWP 930254. Two contractors, one group, went to the
top of the batch tank pit, where, using long-handled tools, they began to remove
debris from the pit, continuing a job that had started on May 10. The RCT covering
the work was principally frisking items removed from the pit, prior to their being
placed in a liner inside a shielded container located nearby. Prior to the start of work
on May 11, the RCT had entered the pit to determine radiation levels and found them
to range as high as 20 R/hr next to the batch tank and floor interface. Only one
member of the work group was wearing a breathing zone air sampler (BZA). The
licensee did have a 500 cfm High Efficiency Particulate Air (HEPA) unit available,
which was utilized when the workers completed the clean-up activities that could be
conducted from the top of the block wall, and was also utilized after the workers
entered the pit in order to complete thejob. Due to the confined space present in the
pit, only one person at a time could enter it and work. The contractor wearing the
BZA sampler entered the pit first, and worked for several minutes, after which the
second worker, not wearing a BZA, entered the pit for several minutes. While in the
pit, the workers were bent over scooping up debris and placing it in a bucket. The
HEPA unit hose was periodically moved around by the workers to keep it near the
work area. The hose extended down approximately four feet into the pit, leaving the
end of the hose four feet above the pit floor. The licensee did not take air samples in
the pit during the time the workers were removing debris with long-handled tools.
Subsequent analysis of the one worker's BZA indicated ' air concentrations equal to
56.1 times the maximum permissible concentration (MPC), while the negative
pressure full-face respirators that were worn gave a protection factor of only 50.
Title 10 CFR 20.103(c)(2) requires that the licensee's respiratory protection program
include, as a minimum, air sampling sufficient to identify the hazard and permit
proper equipment selection. Licensee procedure 9300-ADM-4020.03, "Use of
Respiratory Protection Equipment," paragraph 7.9.2, requires that respiratory
protection equipment be selected to provide a protection factor greater than the
multiple by which peak concentrations of airborne radioactive materials are expected
to exceed the values specified in Appendix B, Table I, Column I, of 10 CFR 20, as
determined by the sampling of airborne contamination. This is an apparent violation
of 10 CFR 20.103(c)(2), as the licensee had the opportunity on May 10 while workers
were removing debris from the pit with long-handled tools to perform air sampling of
the pit air for the purpose of selection of respiratory equipment for the next day when
.
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the pit was to be entered and did not do such air sampling. As a result, respiratory
equipment was selected that did not provide an adequate protection factor. (50-
219/93-07-04)
Having only one of the two workers wearing a BZA sampler, when each had to enter
the pit separately, is an apparent violation of the requirements of 10 CFR
20.103(a)(3), which require that for the purpose of determining compliance with the
requirements of 10 CFR 20.103, the licensee use suitable measurements of
concentrations of radioactive material in air. (50-219/9307-05)
3. Exit Interview
The inspectors met with the licensee representatives denoted in Section 1 at the
conclusion of the inspection on May 18, 1993. The inspectors summarized the
purpose, scope and findings of the inspection.
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Enclosure 2
.Page 1 of 3,
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/ vol. 57,.h us /- Pray, July a 1982 / Notices
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.# a r muelsew
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acessesse: send coma =nte ta:m
secretary a thee--won. u.s.
NuclearRaseteteryc
w.on, -
Washlagteo.DC20555. ATTN:
Dodeting and Servise Braarh-
Head deliver =====to to: One White
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Flint North.11555 Rockville Pike.
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Redvtlle, bdD between 7:45 aJa. to 415
,
pJa.FederalM hp.
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Copies of eesseente may be e==minad
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at the NRC Petdic Docuamat Room.2220
LStreet.NW.(14wer14 vel).
Waeblasten.DC
,
poensmainesomaanomeonraen
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JamesLiebesmen. Director.OtBee of
Enfescement.UA NedearRegeletory
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supptausuramy esponenanose
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coederence wee apseimpacted the -
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confersoon and/or 6-y8==aat the NRCs
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July 10.1981,while commente en the
(2)Wheemr the speaconference
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program are besos received. Submit
impacted the 16a aa==*e participe 2on in -
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comments on or bdere du. _&
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of the triel program scheduled for July
(3)Whether the NRC expended a
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11.1992.r*-=aate received after thle .ignme==t amomet of resources in
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date will be cons.dered if it is practical
making the confavoce public: and ,,
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to do so, but the Commission is.eble to
(4)b extent of public interest in
a seure consideration only for c3mments opening the enforcement confeyenc e .
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received on or before this date.
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Federal Register 3,,, oL 57, No. 233 / Friday, July 10. Isa' iNodose
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aut4ece to .H ecreenes.6:
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As soon as Atle detannised that an
wiu comunee to be a moedag between
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the NRC and the licenses.While b
puW oboarvenoa.the NRC wG orally
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progreat and send the Bcanoes a copy of conferemose are esadada et 0)&
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and
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(3) Tou-free electronic beuses heard
re*w and co-idersdan.
opentothe pehttein specialcasee
wheregoodasasehas been shown a8er
establishmentof thetoD4ree
Detad et seeinelle ndo, thae rik day of J.ly
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tenz.
sbeerenson agalast thepetendal hopect (301) ess-erst to obtela a roomeding of
yor the Nedmar Rayniaeary Comme ian.
cn the agency's enforc=-ar action in a opcondes open omforcement
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confer ==a== The NRCw1H isese esother secrwerye/de<* - %
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De NRC will otrtve to conduct open
Federal Regleter asene eheres toiMree pDec es-seassrund7 4-es:a,ssa.in.)
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enforcement conferences during the -
message erseems are =~h864=d
same onee runw a
two year trial programia accordamos
To easiet the NRC h making
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with the fausering three goale:
e
to arrangemeemts to eigsport
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(1)A,,.
-"* 25 percent of all
observatnamof- 8== ---*
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Corrections. >=' ei =*-
conducted by theNRCwW be open kr
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(2) Atleastame open enforcement
LA==en=d h to meseas motice
vet sr. Na tse
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conference wm be ~=A-r+-d la each of
===--a,4=g the open enforososent
,
the regional omcas:and
. anmieremos me later them Eve businen
yrider. }uly 17 test
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(3) Open enfortmanent conferemens
daye pr6er to the enforcement
wiu be conducted with a verlety of the
conference.
NUCt. EAR REQULATORY
.
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typn of bceasees.
F* et Open Entwonneet
twenesemense
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To avoid potentialWa la the
Confuemosa
niection procese and to attempt to sneet
.
N three goals steted above. every
in eeeerdemos with current proctics.
Two Year Trtal Progrere for
fourth shgible enforcement conference
enforcement conferences wW continus
Comsisceng Open N
tavolving one of three categories of
to nonanUy be bald at the NRC regional
Codwences; Poecy 8tstement
,
liernsees wW marmany be open to the
omoes.Membwe of h public wiD be
Corrwedon
-
pubhc dering the trial pogram.
aBowed access to b NRC regional
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In nodoe Aaa=== ant-16233 W
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However,in casse where there le en
omcas to attend open enforr=-ng
ongoing edluscatory ra,eqi with
confer =araa in accordance wrth the
on P*fe 3ms2 in 6e teaua d
y.
ens or more interrenors. enforcement
" Standard Opereting Procedum For
jdy. SA 1982. on page soft 2. in
P*n=A cohann onder Dans. %
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confereocos involving issues roleted to
Nhie Secartty Sapport For NRC
m the flhh t'.ne.*luly n.1902" should
the subject metier of the ocacing
Hearmgs And Meetings" pubtshed
(
sdjudicedoo mey also be opened. For
Novembar 2 tw1 (55 FR sC31).Tbere
rood *)nly 11. teos .
the pcrposee d tile trial progam, this
procedures provide that visitors may be
emisme was
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