ML20052B467
| ML20052B467 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/16/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20052B468 | List: |
| References | |
| NUDOCS 8204300458 | |
| Download: ML20052B467 (6) | |
See also: IR 05000219/1980017
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16 APR 1992
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Docket No. 50-219
GPU Nuclear Corporation
to
A
ATTN:
Mr. P. B. Feidler
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Vice President and Director
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Oyster Creek Generating Station
P. O. Box 388
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Forked River, New Jersey 08731
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Gentlemen:
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Subject: Health Physics Appraisal
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The NRC identified a need for licensees to strengthen the health p ysics
program at nuclear power plants and undertook a significant effort to assure
that actions were taken in this regard. As a step in this effort, the Office
of Inspection and Enforcement conducted special team appraisals of the health
physics programs, including the health physics aspects of radioactive waste
management at all operating power reactor sites. The objective of these
appraisals was to evaluate the overall adequacy and effectiveness of the total
health physics program at each site and to identify areas of weakness that
need to be strengthened.
Findings from these appraisals are used as a basis
not only for requesting individual licensees action to correct deficiencies
and effect improvements but also for effecting improvements in NRC requirements
and guidance.
During the period of May 12 through 23, 1980, the NRC conducted the special
appraisal of the health physics program at the Oyster Creek Nuclear Generating
Station. Areas examined during this appraisal are described in the enclosed
report 50-219/80-17. Within these areas, the appraisal team reviewed selected
procedures and representative records, observed work practices, and interviewed
personnel. The findings of this appraisal were discussed with senior management
personnel at the Oyster Creek site on May 23, 1980 and in the Region I Office
on vune 13, 1980.
Unfortunately the enclosed report of this appraisal effort
was delayed.
It is requested that you review the findings in this report and
determine if the observed weaknesses still exist and consider effecting improve-
ments to your health physics program.
The findings of the appraisal at Oyster Creek indicate that although your
overall health physics program was adequate for continued operation, several
significant weaknesses existed.
These include the following:
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(1) Job descriptions; training and definition of responsibilities for
the radiation protection staff and the radiation protection technician
requalification and on-the-job training programs need improvement.
(2) The existing respiratory protection training program needed improvement.
(3) The radiation protection instrument repair and calibration programs
required improvement, especially in the areas of technician training
and instrument availability and accountability.
(4) Management should demonstrate support of the ALARA program.
These findings are discussed in more detail in Appendix A, "Significant Appraisal
Findings." We recognize that an explicit regulatory requirement pertaining to
each weakness identified in Appendix A may not currently exist.
However, you
are requested to submit a written statement within sixty (60) days of your
receipt of this letter, describing the corrective action for each weakness
identified in Appendix A including:
(1) steps which have been taken; (2)
'
steps which will be taken; and (3) a schedule for comrletion of action.
This
request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of
Federal Regulations.
You should be aware that the next step in the NRC effort to strengthen health
physics programs at nuclear power plants will be the imposition of a requirement
that each licensee develop and implement a Radiation Protection Plan.
You
will be expected to include in the Radiation Protection Plan sufficient measures
to provide lasting corrective action for those weaknesses identified in Appendix
A.
Guidance for the development of this plan has been developed in draft form
and was published as NUREG-0761, " Radiation Protection Plans for Nuclear Power
Reactor Licensees."
In accordance with 10 CFR 2.790 of the Commission's 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 contractors)
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
1
that you (a) notify this office by telephone within ten (10) days from the
date of this letter of your intention to file a request for withholding; and
(b) submit within 25 days from the date of this letter a written application
to this office to withhold such information.
Consistent with section 2.790(b)(1),
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 full statement of the reasons on the basis which it is
claimed that the information should be withheld from public disclosure. This
'
section further requires the statement to address with specificity the consid-
erations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld
shall be incorporated as far as possible into a separate part of the affidavit.
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GPU Nuclear Corporation
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16 APR [992
If we do not hear f' rom you in this regard within the specified periods noted
above, the report will be placed in the Public Document Room. The telephone
notification of your intent to request withholding, or any request for an
extension of the 10 day period which you believe necessary, should be made to
the Superisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.
The responses directed by this letter are not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
NI inal Signed Byr
E
George H. Smith, Director
Division of Emergency Preparedness and
Operational Support
Enclosures:
1.
Appendix A, Significant Appraisal Findings
2.
Office of Inspection and Enforcement
Report No. 50-219/80-17
cc w/encls:
M. Laggart, Licensing Supervisor
J. Knubel, BWR Licensing Manager
Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
State of New Jersey
bcc w/encls:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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APPENDIX A
SIGNIFICANT APPRAISAL FINDINGS
'
GPU Nuclear Corporation
Docket No. 50-219
Oyster Creek Nuclear Generating Station
Based on the results of the NRC Health Physics Appraisal conducted May 12-23,
'
1930, it appears that the following weaknesses existed in your health physics
program as indicated below. Details regarding these weaknesses are found in
the referenced sections of the appraisal report.
A.
Organization, Responsibilities, Staffing and Management Oversight
A comprehensive onsite QA audit / surveillance inspection program of health
physics activities should be implemented.
(Section 1.2)
8.
Personnel Selection, Qualification and Training
1.
The job descriptions, training and definitions of job responsibilities
for the radiation protection staff need improvement.
(Section 2.2)
2.
The radiation protection staff selection criteria need improvement.
(Section2.2)
3.
In the event that the Radiation Protection Supervisor would be
unable to fulfill his responsibilities, no qualified individual on
the staff was available to perform his duties.
(Section 2.3)
4.
The radiation protection technician requalification and the on-the-job
training programs were inadequate in their current state. A formal
documented program should be developed to ensure that adequate
on-the-job training is provided.
(Section 2.4)
5.
Training responsibilities should be resolved so that technician
training and requalification programs can be developed.
(Section
2.4)
6.
The general employee radiation protection retraining program permits
two or more years prior to retraining.
Retraining should be required
on an annual basis.
(Section 2.4)
C.
Exposure Control
1.
Usable beta calibration data should be obtained and employed to
evaluate beta exposures.
(Section 3.1)
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Appendix A
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2.
Extremity dosimetry should be improved to evaluate doses more realis-
tically and accurately.
(Section 3.1)
3.
An MPC-hour exposure program to demonstrate compliance with 10 CFR 2.103 should be~ established.
(Section 3.2)
,
4.
A training program should be established for technicians responsible
for operating the respirator fitting booth and the whole body counter.
,
(Section 3.2)
5.
The individual conducting respiratory training for users should-
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satisfy the experience requirements specified in NUREG-0041.
(Section
3.2)
6.
A formal training lesson plan which-covers both routine and emergency
use of respiratory protection equipment should be written and the
program implemented.
(Section 3.2)
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7.
A calibration program which is compatible with the recommendations
in ANSI N343-1978 for the whole body e.ounter should be established.
(Section 3.2)
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8.
The radiation protection instrument repair and calibration programs
require significant improvement, especially in the areas of technical
training and instrument availability and accountability.
(Section
3.3)
9.
The technicians operating the counting equipment should receive
appropriate training in counting and analyses techniques.
(Section
3.3)
D.
Radioactive Waste Management System
A program for the routine testing of the NRW HEPA filters should be
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developed and implemented.
(Section 4.3)
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E.
ALARA Program
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1.
Management should demonstrate support of their commitment to the
ALARA program. This should include holding ALARA committee meetings
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as required by Procedure 915.9.4, " Implementation of the ALARA
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Program." (Section 5.3)
2.
The Radiation Work Permit (RWP) program should be improved.
De-
ficiencies noted in the program were:
(1) several RWPs posted at
job sites were illegible, (2) workers were not familiar with the
conditions specified in the RWPs, and (3) workers had signed-in
,
under the wrong RWP. (Section 5.4)
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Appendix A
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3.
Training and supervision of contractor HP technicians should be
improved to ensure that ALARA practices are being followed. (Section
5.4)
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