ML20107A241
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4 ENCLOSU'RE 1 Description of Violatians
. Jersey Central Power and Light Company Madison Avenue at Punch Bowl Road Morristown. Neu Jersey 07960-
. Docket No. 50-219 Certain. activities under your license appear to be in violation of' AEC regt'irements. - These apparent violations are considered to be of' Category II' severity.
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10 CFR '20.203(b), " Caution ' signs, labels, signals, and controls,"
. requires that.each radiation area-be conspicuously posted with a sign or signs' bearing the radiation caution symbol and the nords,
" Caution - Ra'diation Area." A " Radiation Area" is defined in Part 20 as any area accessible to personnel in which radiation exists, originating in whole or in part within licensed material,
-at such levels that a major portion of the body could receive in any one hour a dc.sc in excess of 5 millirecs, or in any five con-secutive days a dose in excess of 100 millirems.
Contrary to this requirement, radiation levels greater than 5 milli roentgens per hour ev'sted for periods of greater than one hour in the Radwaste Facility Control Room on September 5, 1973 which was not posted with the required sign. We note that this is a recurring item.
It was identified as Item 5.a. and 5.b., Enclosure 1 of our letter dated March 7, 1973.
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10 CFR 20.206(a) " Instruction of Personnel..." (Replaced by 10 CFR 19.12. " Instructions to workers" on September 17, 1973); requires, in part, that individuals working in a restricted area be instructed
,in the safety problems associated with exposure to such materials or radiation as may be found in the area and in precautions or procedures to minimize exposure.
Contrary to this requirement, on September 5, 1973 two individuals
'in the Radwaste Facility Control Room were not aware of the 5 milli-roentgen per hour dose rates in their work area. We note that this is a-recurring item.
It was identified as Item 3, Enclosure 1 of our letter dated March 7, 1973-1
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Technical Specification 6.2.C states that standing instructions to the operating staff shall require that procedures defined in 6.2.5 j
are to be followed in conducting activities identified therein. The subject procedures are contained in Section 900, Oyster Creek Nuclear i
Electric Generating Station, Procedures Manual.
Section 901 requires that individuals be familiar with procedures and shall follow than at all times. Section 903.7.1 requires that each Radioactive Werk l
Permit will provide a description of the hasards involved. Section 903.9.7 requires that notification of overeuposures will be given to i
the Plant Operattag Review Commtittee (PORC).
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Contrary to the above, requirements of these procedures were not
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i fu11 filled as noted below:
i a.
On September 15, 1973, the inspectors observed four employees l
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working at the 95 foot elevation of the reactor building. They were not wearing protective clothing as prescribed by Radioactive Work Permit 657-73, dated August 29, 1973.
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The radioactive Work Permit covering the rernoval of radioactive materials from the roof of the Radwaste Facility on August 24, 1973 did not provide a description of the hasards involved.
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There is no documentation existing that indicates that the PORC was notified or acted upon a personnel overexposure that occurred l
in April 1973.
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Technical Specification 6.1.C.2.f. requires that the minutes of the General Operating Review Board (CORB) meetings be provided to the I
i Plant Superintendent.
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Contrary to this requirement, minutes of 00RB meetings conducted i
i af ter January 25, 1973 had not been provided.
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Technical specification 6.1.C.2.d.(4) requires that the 00RB conduct periodic audits ef plant operations at lease. quarterly.
i Contrary to this requirement, audits were not conducted a: the required frequency.
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Technical Spesifiestions 6.1.C.1.d. (1). and 6.2.F. require j
that proposed changes and temporary abanges to procedures he promptly reviewed and approved by the PORC and the Station Superintendant.
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Contrary to this requirement temporary obenges to Procedura 903.1 were made en Marsh 30 and April 10, 1973 which were not reviewed and approved as of September 7, 1973.
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ENCLO8URE _2__
j Description of safety Items J-Jersey Central Pever and Light Osupany 1
-Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Docket No. 50-219 Certain items appear to raise questions ceaseraing the safety of operations as identified belev 1.
Prudent practies dictates that to protest health and safety, l
Management must have adequate staff and sufficient control
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to; assure that a satisfactory health and safety program is
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developed and maintained, provide audits of this program's quality and effectiveness and enforce procedures to assure 2
that employees understand radiation hazards and work in accord j
with procedures provided for their protection.
i Contrary to the above, the following deficiencie:: were observed during the inspection of your facility and safety program records:
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In response to 'our observation at a previous inspection that your radiation protection staff was not sufficient, your letter, dated March 28, 1973, stated, "This area is receiving our most j
immediate attention."
We note that at the time of the inspection, the only permanent addition you had made was the addition of a j
single Assistant Radiation Protection Technician.
We understand that you have since filled the position of Supervisor of Radiation j
i Protection and have indicated that two new Radiation Protection Foremen will be working in presently vacant positions by the end of November 1973.
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We note that one more Radiation Protection Technician and two more Assistant Radiation Protection Technicians are still to be hired.
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b.
Administrative controls which include internal audits of L
L radiological practises and problem areas, including violations l
of plant precedures and ABC regulations have been implemented.
Although some of these audits and inspections are identifying problem areas and violations, they have not been effective in j
prevonting recurreneea of problems and violations of the eame type.
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2-1 Station Radiation Protection Precedures, gestion 900, require c.
that employees follow radiation safety rules and practices; however, in spite of repeated examples of employees failure.
to follow these rules, your program does not provide plant enanagement with assaramos that individuals are fulfilling this obligation. We note that this is a resurring ites. It was identified as Item 1.2, anciesure 2 of our lettor dated Marsh 7, 1973.
Management sentrole relative to disciplinary action against d.
employees observed violating plant prosedures are minimal.
j The plant management does not appear to be exercising the l'
sentrol necessary to require oonpliance with radiation protec-tion procedures.
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Responsibi;ities of the FORC, as defined in the Technical Specifications, include the review of radiation protection e.
i problem areas, exposure control and housekeeping activities.
i' A review of the minutes of PORC meetings for the last 5 months revealed no case where these matters were considered I
by the committee.
A procedure was not provided for the removal and disposal of l
contaminated filter elements from the Radwaste System in which f.
This radiation levels up to 3 roentgens per hour existed.
operation was performed on August 24, 1973 and resulted in a i
radioactive spill.
Personnel working in the Control Room portion of the Radweste A
Facility were unaware that they were in a Radiation Area.
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j foreman in the same area was also unaware of radiation levels These personnel had not received in the small pump room.
proper instruction in radiation levels inherent in their work (Thir matter is referred to in Item 2 of the descrip-areas.
tien of violattens.)
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