ML20107B219
See also: IR 05000219/1973002
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U. S. ATOMIC ENERGY COMMISSION
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION I
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RO Inspection Report No.:
50-219/73-02
Docket No.:
50-219
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Licensee:
Jersey Central Power & Light Company
License No.: DPR-16
Madison Avenue at Punch Bowl Road
Priority:
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Morris tomi, New Jersey
Category:
C
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Location:
Forked River, New Jersey
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Type of Licensee:
BWR, 1930 MWt
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Type of Inspection:
Special, Unannounced
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Dates of Inspection:
February 13-16, 1973
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Dates of Previous Inspection:
January 2, 5, & 6, 1973
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Reporting Inspector:
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R.J.keyer,RadiationSpecialist
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Accompanying Inspectors:
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F.S.Cantrell,Re[9t'o'/ Inspector
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l# FL
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R.sF/ fess, Environmental Specialist
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Other Accompanying Personnel:
None
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Reviewed By:
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R. H. Smith, Act18g Senior, Facility Radiological
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Protection Section
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D. L. Caphto , Senior Reactor Inspector, Facility
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Operations Branch'
9604160135 960213
DEKOK95-258
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SUMMARY OF FINDINGS
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7 nforcement Action
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A.
Violations
'1.
Excessive radiation levels in an unrestricted area.
(Details,
Paragraphs 2a, b, and c)
2.. Failure to provida personnel monitoring equipment to an indi-
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vidual.
(Details, Paragraph 3c)
- 3. Failure to instruct personnel.
(Details, Paragraph 3d)
.4.
Failure to. properly post and control access to high radiation
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areas.
(Details, Paragraph 5)
5. : Failure to properly post radiation areas.
(Details,-Paragraph 6)
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6.
Failure to properly label containers of radioactive materials.
(Details, Paragraph 7)
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7.
Failure to properly post entrances to a building containing
radioactive materials.
(Details, Paragraph 8)
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Failure to conduct required surveys.
(Details, Paragraph 9)
9.
Failure to properly store solid radioactive vaste.
(Details,
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Paragraphs 10a and b)
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10.
Failure'to direct catch basin drains to the 1-9 radwaste sump.
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(Details, Paragraphs 11a and b)
B.
Safety Items
1.
Deficiencies in management control systems relative to the radia-
tion protection program.
(Details, Paragraphs 12a - 1)
2.
Deficiencies in the exposure control program.
(Details, Paragraphs
13a - c)
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Licensee Action on Previously Identified Enforcement Action
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Not inspected.
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Design Changes
Not inspected.
Unusual Occurrences
Exposures to excessive air concentrations described in licensee's letter
to Director of Regulatory Operations, dated February 8,1973.
(Details,
Paragraph 4a)
Other Significant Findings
A.
Current Findings
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Inspection findings showed that radiological conditions were not
accordance with 10 CFR Part 20 requirements, total annual exposures
were increasing, solid radioactive waste handling, storage, and dis-
posal problems existed, and management control systems were deficient.
B.
Status of Previously Reported Unresolved Items
Not inspected.
Management Interview
The following individuals attended the management interview held at the
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conclusion of the inspection on February 16, 1973.
T. McCluskey, Station Superintendent
J. Sullivan, Technical Supervisor
J. Carroll, Operations Supervisor
D. Reeves, Technical Engineer
D. Kaulbach, Radiation Protection Supervisor
F. Walshe, Operating Foreman, Radwaste
The following subjects were discussed:
A.
Each of the items identified above in Summary of Findings - Enforcement
Action, were described.
B.
The inspector stated that he had reviewed the licensee's investigation
and evaluation of exposures to noble gases that had previously been
reported.
(Details, Paragraph 4a)
The following individuals attended a management meeting held at the Region
1, Regulatory Operations Of fice on Fbrch 3,1973:
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' Jersey Central Power and Light Company Representatives
I. Finfrock, Vice President
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D. Ross, Manager,_ Nuclear' Generating Statio.s
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T. McCluekey, Station Superintendent, Oyster Creek, Unit I
J. Sullivan, Technical Supervisor, Oyster creek, Unit I
Region I-Representatives
J. P. O'Reilly, Director
R. Carlson, Chief, Facility Operations Branch
R. Smith, Acting Senior,-Facility Radiological Protection Section
F. Cantrell, Reactor Inspector
R. Meyer, Radiation Specialist
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The following subjects were discussed:
A.
The intent of the meeting was described as being for the purpose of
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discussing with corporate management the current methods by which
the Directorate of Regulatory Operations enforces federal regulations;
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the findings of our inspectors during the subject inspection; previous
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inspection history; the position of management with respect to the
findings during the subject inspection; and management's plans to
correct tha. violations and safety items.
B.
The violations and safety items were described in detail by Region I
20E
representatives.
It was noted that the inspection findings indicated
that the management control system was not responsive to providing a
radiation protection program consistent with that required to assure
compliance with AEC regulations and plant procedures.
It was noted
that assignment of responsibility and administrative accountability
were not sufficient to measure, evaluate, and implement the program.
C.
The radwaste management prograra was described as being deficient, in
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particular, the large inventory of waste drums, some of which were
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stored outside a shielded structure. Licensee evaluations showed
that the said inventory had resulted in excessive radiation levels in
unrestricted' areas, and was also contributing to personnel exposures.
Region I representatives stated that radiological housekeeping prac-
tices were not in keeping with maintaining exposures to personnel as
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low as practicable.
D.
Region I representatives stated that the inspection had been limited
in; scope and that more detailed inspection would be conducted at later
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E.
The licensee stated that corrective action had been initiated, and
described in general terms the' overa,
.ns to improve management,
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control' systems. .The licensee was into.med that the violations and
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' safety items would be specifically doetmanted in a letter.to them-
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which.would. require a written response describing their corrective
actions.
F...The Director stated that incrassed emphasis would be placed on the
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review of management control systems during future inspections.
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DETAILS
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1._
Persons Contac ed
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T. McCluskey, Station Superintendent
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J. Sullivan, Technical Supervisor.
J. Carroll, Operations Supervisor
D. Reeves, Technical Engineer
D. Kaulbach, Radiation' Protection Supervisor
B. Cooper,-Shift Foreman
F.-Walshe, Operating Foreman, Radwaste
R. Pelrina,. Head Chemist
T. Raymond, Radiation Technician
2.
Radiation Levels in Unrestricted Areas
a.
During a pr6vious inspection * a review of survey records and
actual measurements indicated a potential for excessive levels
of radiation having occurred in an unrestricted area adjacent
to the radwaste facility. A program to evaluate the radiation
levels along the fence line was initiated by the licensee on
November 20, 1972. The evaluation program consists of placing
film dosimeters at seven locations along the north, south and
east fence lines.
b.
A review of the dosimeter results showed that radiation levels
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existed at the east fence line for two seven day periods and at
the south fence for one seven day period. 'The results of film
dosimeters #3, #4, and #5 which were in place on the east fence
line and #6 which was in place on the south fence line are shown
below:
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Dates
mrem /wk
mrem /wk
mrem /wk
mrem /wk
11/20 - 11/27/72
100
141
161
151
11/27 - 12/3/72
230
230
161
100
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Inspection findings indicated that the radiation levels resulted
from the storage and handling of radioactive waste in and near
the radwaste building. The inspector made radiation measurements **
in the general area of the radwaste building on February 13, 1973.
- RO Inspection Report No. 50-219/72-05
- All measurements made by the inspector were made with an Eberline E-120-G,
Geiger Counter survey' instrument.
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Radation levels -of 100 millirem per hour existed outside the
east door and 25 millirem per hour outside the south door of,
the radw aste building.
Additionally, drums containing radio-
active waste were stored north of the radwaste building. Me as ure-
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ments made by the inspector on the above date, at the restricted
area fence line showed the maximum level to be 0.2 millirem per
hour.
3.
Pe rsonnel - Monito ring (external)
a.
As evidenced by a review of exposure records and statements from
licensee representatives, personnel monitoring is accomplished
by the use of film badges, supplied by a film processing vendor.
Badges are exhanged on a monthly frequency.
Day to day exposure
is controled by the use of pocket dosimeters. As a result of
exposures to personnel in excess of 3 rem during the third quar-
ter of 1972*, administrative controls and limits were established.
These limits and controls are define'd in Radiation Protection
Procedure 903.5.1.
This procedure requires written authorization
and approval by the plant superintendent for an individual to
receive exposure over 1250 mrem and up to 2500 mrem in any one
quarter. Exposure over 2500 mrem requires approval by the Man-
ager, Nuclear Generating Stations. A review of first quarter 1973
records showed that written authorizations were in order for those
individuals that were over 1250 millirem.
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b.
A review of exposure records for 1973 through February 12, showed
that 38 individuals have exposures in excess of 1250 millirem,
the maximum being 2310 millirem.
In general, personnel with the
higher exposure accumulations are involved in maintenance work
and radwaste processing and handling. According to licensee rep-
resentatives, radwaste processing and handling was contributing
to personnel exposures. The solid waste inventory contained in
55 gallon drums, was estimated to be about 600 drums on February
14, 1973, as estimated by a licensee representative, some of which
was stored outside. Background radiation levels outside the rad-
waste building ranging from 25 millirem per hour to 100 millirem
per hour were measured by the inspector on February 13, 1973.
Levels to 10 millirem per hour existed at the edge of the outside
drum storage area.
Drums of high level waste were stored both out-
side the radwaste facility and within the reactor building, that
were not
propriately posted or barricaded for access control
purposes, . hus contributing to personnel exposures.
- RO Inspection Report No. 50-291/72-05
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c.
On February 19, 1973, while the inspector was making an inspec-
tion'in the reactor building, and approached the area where new
reactor fuel was being unloaded, the instector noted that the
reading on his survey meter increased. The inspector identified
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the source of radiation as being a 55 gallon drum located adjacent
to the' rear to the fuel truck. Radiation levels to 1000 millirem
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per hour at about 6 inches from the barrel and 200 millirem per
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hour at about 18 inches were measured by the inspector. The drum
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was not posted or barricaded to inform personnel of existing
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radiation levels. One individual near the rear of the truck was
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identified by a licensee representative as the driver of the truck
and not a licensee employee.
It was later determined by a review
.of the dosimeter records that the licensee had not issued a badge
or pocket dosimeter to the truck driver.
In the s'nstant case
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the driver had uncontro17 d access to an area in which existed
radiation levels to 200 milliram per hour. The individual could
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have received a limiting dose (a'312 mram) in approximately 95
minutes. According to licensee representatives the driver may
have been in the area up to six hours.
d.
The inspector observed licensee employees in the same area who
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were involved in unloading the new fuel and others observing
the unloading operation. The inspector questioned one individual
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as to his knowledge of the presence of the subject drum and the
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existing background radiation levels in the general work area.
The individual stated that-he was not aware of either. He further
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stated that ks guessed he should be aware of them. The inspector.
requested the employee to take the inspector's survey instrument
to the center of the work area and read the dial. The employee
stated that it was reading 20 (20 millirem per hour) and that he
was not aware of the existing levels.
In the instant case the
employee had not been informed by survey results, verbally, or
by benefit of posting, labeling, or barricading.
e.
With respect to personnel exposure history at the plant the
inspector reviewed the yearly totals for 1970 through 1972 and
the current year through February 12, 1973. Totals are as shown
below.
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Year
2 to 5 rem
5 to 7 rem
7 to 9 rem
9 to 10 rem
1970
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1971
29
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1972
31
22
14
8
1973
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NOTE:
38 employees had exposures in excess of 1250 mrem through
February 12, 1973.
4.
Exposures to Concentration of Airborne Radioactivity
As evidenced by records and licensee statements exposure to air-
a.
borne concentrations of radioactivity are controled by an estab-
lished air sampling program.
It was noted that procedures require
centrationsexceed3x10-1glingbeaccomplishedwhenaircon-
that investigation or resam
uCi/cc which includes a spectrum
analysis for isotope identification. Exposure times are then
calculated on the basis of the mixture MPC. A review of records
showed that in those cases where air concentrations were in excess
of the applicable values defined in Appendix B, Table 1, 10 CFR Part 20, exposure times were calculated and documented. Additionally,
respiratory protection is used in the event of needing extended
exposure times. A review of records showed one case in which three
employees were exposed to excessive concentrations of noble gases.
The exposures had been reported * by the licensee. The inspector
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reviewed the exposure evaluation data and the corrective action
and found both to be as reported.
b.
Results of air samples taken in the radwaste building were reviewed
in detail. Typically air concentrations were less than Appendix B,
Table I limits for the identified isotopes.
Typical isotopes
identified were cobalt-58, cobalt-60, cesium-134, cesium-137, and
manganese-54. Three air samples were taken in the radwaste building
on February 16, 1973.
It was noted that solid waste was being
processed at the time. A review of the results showed that con-
centrations in the three locations were less than the applicable
limits for the identified isotopes.
Inspection findings showed that a whole body counting program is
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employed to back up the effectiveness of the air sampling program.
- Letter, Donald A. Ross to F. E. Kruosi. DRO, dated February 8,1973
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Personne1'are counted on a routine basis ~ (normally af ter refueling
outages) and on an as needed basis in the event of a suspected,
exposure. Approximately 120 individuals were counted during 1972.
Results of whole body counts were not indicative of any exposures
to excessive air concentrations.
5.
Posting and Control of Access to High Radiation Areas
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a.
The inspector observed areas and buildings in which high radiation
levels _ existed, as determined by measurements, that were not
appropriately posted, barricaded, or the access controled by a
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locked door, as required by the licensee's Technical Specifications.
'The subject areas are as follows:
(1) The outside door at the east end of the radwaste building was
not posted as a high radiation area.
Radiation levels to 1500
mil 11 roentgen per hour existed within the building on February
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13, 1973.
(2) The large pump room in the radwaste building was not posted
as a high radiation area on February 13, 1973.
Radiation
levels to 300 mil 11 roentgen per hour existed as general
background levels.
(3) The area adjacent to a drum containing radioactive materials,
located at the 23 foot elevation in the reactor building near
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the new fuel truck unloading station was not posted as a high
radiation area. Additionally, access to the barrel was not
controled by a barricade. Radiation levels to 200 milliro-
entgen per hour at 18 inches from the barrel existed on Feb-
ruary 14,1973.
(4) The area adjacent to a drum containing radioactive material,
located at the 75 foot elevation in the reactor building
was not posted as a high radiation area. Additdonally, access
to the area was not controled by a barricade.
Radiation
levels to 200 mil 11 roentgen per hour at 18 inches from the
barrel existed on February 14, 1973.
It was noted by the
inspector that the subject drum had been moved to inside
storage prior to completion of the inspection.
(5) The area outside the northeast corner of the radwaste building,
adjacent to a drum containing radioactive materials was not
posted as a high radiation area. Additionally, access to
the drum was not controled by a locked door.
Radiation levels
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to 1050 mil 11 roentgen per hour at 18 inches from the barrel
existed on February 13, 1973.
(6) The outside drum storage area north of the radwaste building,
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was not posted as a high radiation area. Additionally, access
to the area was not controled by a locked door.
Radiation
levels to 1500 mil 11 roentgen per hour existed adjacent to
the drums on February 13, 1973.
(7)
The door to the drum storage room inside the radwaste build-
ing was not posted as a high radiation area.
Additionally,
the door was not locked on February 13, 1973.
Background
radiation levels to 1500 m1111 roentgen per hour existed in
the center of the room on the above date.
6.
Posting of Radiation Areas
The inspectors observations and radiation measurements showed
a.
that the following radiation areas were not appropriately posted.
(1)
The area around a drum containing radioactive materials which
was located at the northeast corner outside the radwaste
building. Radiation levels to 10 millirems per hour at
approximately 15 feet existed on February 13, 1973.
(2) The area outside a door at the east end of the radwaste
building. Radiation levels to 100 millirems at approximately
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18 inches existed on February 13, 1973.
(3) The area around a drum containing radioactive materials
located on the south side of the radwaste building. Radiation
levels to 10 millirems per hour at approximately 18 inches
existed on February 13, 1973. The inspector noted that
the subject drum had been moved to inside the storage prior
to the completion of the inspection.
(4) The area outside a door on the south side of the radwaste
building where radiation levels to 25 millirems per hour
at approximately 18 inches existed on February 13, 1973.
(5)
The area around the drums containing radioactive materials
which were stored north of the radwaste building.
Radiation
levela to 10 millirems per hour at approximately 20 feet
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existed on February 13, 1973.
(6)
The north side of the area around the outside waste storage
tanks in which radiation levels to 10 millirems per hour
on the walkway exiated on February 13, 1973.
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(7). The RB Tip Drive area in the reactor building where radiation
levels to 15 millirems per hour ' existed on February 14, 1973.
(8) The area adjacent to a drum containing radioactive material
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which was being used as a stanchion to define a barricaded ~
radiation area on the operating floor of the reactor building.
Radiation levels to 10 millirems per hour, in the walkway,
along the barricaded area, existed on February 14, 1973.
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(9) The area around the emergency condensers at the 95 foot
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elevation in the reactor building. General background
radiation levels to 15 millirems existed in the area on
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February 14, 1973.
(10) The liquid poison storage area at the 75 foot elevation in
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the reactor building. Radiation levels to 10 millirems
per hour existed inside the area on February 14, 1973.
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7.
Labeling of Containers
The inspector's observations and radiation measurements showed that
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the containers described in paragraph 6, identified as al, a3, a5,
a0, and the fiberglass storage tanks containing chromated water were
not appropriately labeled.
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8.
Posting of Areas
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The inspector observed that the doors on the south and east sides
of the radwaste building were not appropriately posted. Waste inven-
tory and disposal records showed multicuries of licensed material had
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been and was in storage within the building.
9.
Radiation Survey Program
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A review of the survey program showed that a routine survey schedule
had been established; however, it was not currently being implemented
up to the schedule requirements. A licensee representative stated
that the survey program was outdated and that they could not meet
the commitment in light of the work load caused by increased main-
tenance work, and the problems associated with radioactive waste
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handling and storage. The inspector questioned licensee representa-
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tives about their knowledge of radiological conditions that were
observed by the inspector. They stated that they were not specifically
aware of those described conditions. The inspector's review of survey
records and the health physics log showed that the conditions as ob-
served were not identified. The inspector also noted that the extended
radiation work permits, posted at various locations, did reflect the
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existing conditions.
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10.
Radioactive Waste Storage
As evidenced by records there were soproximately 600 drums
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(55 gallon) of solid waste in inventory at the time of the
inspection. As observed by the inspector about 25 drums were-
stored in an outside area north of the radwaste' building. As
evidenced by survey records and licensee statements, the sub-
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ject area had been used to store drums for a period in excess
of one year. A survey rece-d dated January 11, 1972 showed
that drums were in storage at the subject location on the sub-
ject date,
b.
Technical Specification 6.2.C requires that plant procedures
will be followed. Radiation Protection Procedure 907.4.1 states
that drummed radioactive waste will be stored in the radwaste
facility. .The above identified outside storage was not in
accordance with procedural requirements.
It was noted by the
inspector that the subject drum' storage area had been discon-
tinued prior to completion of the inspection.
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11.
Liquid Waste _ Storage Tanks (outside)
a.
The subject tanks are located adjacent to the west side of the
radwaste building. A concrete catch basin is provided for the
tanks.Section IX, Subsection 3, Item 3.1.1 of the FDSAR states
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that leakage and spills from tanks containing potentially radio-
active wastes will be collected and returned to the waste system
for processing. Additionally, in a letter to the Directorate of
Licensing dated December 19, 1972, the licensee stated that the
drains from the subject catch basin will be directed to the
1-9 radwaste sump. This was reported as corrective action to
prevent a recurrence of an uncontroled release to the discharge
canal that had occurred on December 6, 1972.
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b.
On February 13, 1973, the inspector noted that water (identified
as rainwater by the licensee) which had collected in the catch
basin was frozen solid.
It was further determined that plugs
had been inserted in the catch basin drain to keep the water from
draining to the 1-9 sump. The drain plugs effectively blocked
drainage from the catch basin and defeated the intent of catch
basin.
Additionally, the ice in the catch basin prevented access
to the plugs for removal.
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12.
Management control Systems
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a.
Inspection findings showed that proceduces, rules and indivi-
dual responsibilities relative to radiation safety are defined
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in Section 900 of the Oyster Creek Nuclear Electric Generating
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Station - Unit I, Procedures Manual.
Radiation Protection Pro-
cedura (RPP) requires that all personnel shall know the concepts
'of radiological safety and are required to be familiar with and
follow the philosophy, standards, and safety procedures as out-
lines in the RPP's.
The procedure further requires that indivi-
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duals must demonstrate a working knowledge of application and
implementation of said procedures before receiving authorization
for unrestricted access to radioactive materials area.
In general,
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all permanently assigned personnel have this authorization and
are classified " unrestricted personnel".
b.
Inspection findings indicated that individuals, had not demon-
strated familiarity with procedural requirements and 10 CFR Part 20 requirements as referenced in the procedures.
This was
evidenced by the violations previously identified in this report,
discussions with licensee representatives in which they stated
that they were not aware of the violations identified by the
inspector, and discussions with licensee personnel in which they
stated that they did not know the existing radiation levels at
their work location.
It was noted that plant procedures speci-
fically identified individual responsibilities in these areas.
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c.
It was further datermined that there were no formal requirements
for first line supervision to audit individual performance relative
to radiological practices. There were no formal reporting require-
ments for line organization supervisors to define to higher man-
agement, program deficiencies, procedural violations, and problem
areas. There was no retraining program established to instruct
and inform personnel of requirements in the area of radiological
practices.
Specifically, no additional training has been given
relative to the current existing radiological conditions and the
high exposure use.
The training provided to the radiation tech-
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nicians does not include training relative to 10 CFR Part 20
requirements.
d.
It'was noted that the General Office Review Board (CORB) consisting
of individuals not stationed at the plant site had conducted in
plant audits in the area of radiological protection and the rad-
waste systems. The records showed that audits were performed as
noted below:
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July 2, 1969
February 17, 1970
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January 12-13, 1971
April 12-13, 1971
November 19, 1971
February 10, 1972
e.
A review of the audit results showed that at least one violation
or poor practice was identified in each of the audits. Typically
these were identified as problems only and not identified specifi-
cally as violations of procedures or AEC regulations.
In each of
the audits housekeeping was spoken to in terms of fair, improved,
very dirty, and poor.
In one audit (January 12-13, 1971) the
committee noted that they were unable to determine responsibility
for clean up of contaminated areas.
In all but one of the audits
the committee commented on various problems associated with the
radwaste facility. There was no evidence in the audit reports that
their findings were indicative of program deficiencies.
It was
noted that findings as reported were subsequently corrected; however,
audits at later dates identified some as being recurring problems.
f.
Inspection findings showed that the Plant Operations Review Committee
(PORC) consisting of onsite personnel, had meetings on a routine
frequency. A review of PORC meeting minutes did not' reflect a
knowledge of existing radiological conditions as noted by the inspec-
tor during the inspection; neither did it reflect any cognizance
,Nd*,
of program deficiencies.
It did reflect that problems with the
radwaste facility existed.
It was noted that a special committee
had been appointed to investigate and recommend a program to resolve
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the problems.
In addition to this, a licensee representative stated
that a consultant had been retained to provide input to the pro-
gram and that an architectural firm had been retained to provide
design for proposed modifications to the radwaste systems.
Progress
reports from the special committee were not documented.
g.
Inspection findings showed that approximately 85,000 gallons of
watercontainingchromateconcentrationsofagproximately800 ppm
'
and radioactivity concentrations to 2.6 x 10- uCi/cc were currently
stored at the plant site.
It was noted that 30,000 gallons were
stored in permanent fiberglass storage tanks. These tanks also
contain the water of highest radioactivity concentrations.
The
remaining water is stored in temporary mobile tanks and a rubber
tank in a lower level of the reactor building.
The inspector
observed that some of the water f rom two of the temporary tanks may
have leaked to the ground.
It was noted that the subject tanks were
leaking at the time of the inspection; however, catch pans were in
place to collect the water.
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h.
Relative to the above storage, the following deficiencies were
noted as determined from procedure reviews and licensee state-
monts:
(1) An evaluation of a gross tank failure had not been made.
(2) Written operating and emergency procedures had not been
established.
(3) A program to prevent overflow or provide routine leak repair
had not been initiated.
(4) A catch basin at the fiberglass storage tank had not been
provided. The licensee stated that a dike installation was
in the planning stages.
1.
Radiation Protection Procedure (RPP) 903.7, in part, requires that
Radioactive Work Permits will provide a general description of
the hazards involved for the work being performed.
RPP 903.7.4
allous for issuance of an extended radiation work permit for those
areas in which routine and repetitive work is performed.
It further
requires that revisions will be made to the permit as necessary,
or at frequencies of no greater than monthly.
It was noted by
the inspector that the extended permits at various locations in
the reactor building, dated January 10, 1973, did not reflect the
ggg
current (February 14, 1973) radiological conditions as observed
and as meas..=d by the inspector. Radiation and high radiation
areas existed that were not properly posted to inform individuals
of radiation levels up to 200 mrem hour.
Contaminated equipment,
tools, and drums containing radioactive materials were accessible
to personnel without benefit of labeling or other information rela-
tive to contamination or radiation levels.
13.
Exp_o_sure Use
.
_
a.
On February 14, 1973 during discussions with licensee representatives
it was determined that drums containing concentrated radioactive
waste from the liquid waste processing system, were being manually
capped without the benefit of a survey to establish exposure rates
prior to capping. As described, the exposure to the individual
performing the work is determined after the fact by reading a
pocket dosimeter. The inspector had observed (February 13, 1973)
waste drums that were in storage with posted radiation levels of
up to 20 roentgen per hour.
Reportedly, the drums were being manu-
ally capped because the drum capping machine was out of service; an
intermit tently recurring problem.
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b.
The inspector identified numerous containers and areas (described
in preceding paragraphs) that were contributing to background radia-
tion levels in general. The inspector also observed individuals
working in some of the areas and receiving exposure without know-
,;
ledge of the existing conditions at their work locations. Specific
to this, the individuals unloading the fuel truck (paragraph 3d)
received exposures up to 20 millirem for the subject day as deter-
mined from the pocket dosimeter records. According to licensee
representatives the subject area is normally a low background area
and should contribute little to personnel exposure. The large pump
raom in the radwaste building had been identified by GORB audits
and by the PORC on numerous occasions, to be a continuing problem
relative to contamination on the floor, f rom recurring floor drain
stoppages. This problem was further identified in survey records .
The inspector measured radiation levels to 300 millirems per hour
in the room on February 13, 1973. Contamination on the bottom of
the inspector's rubbers, after exit from the area was 60 millirems
per hour.
c.
Inspection findings showed that the solid waste inventory was fur-
ther contributing to personnel exposures. At the time of the
inspection the inventory of waste drums totaled about 600. This
was down from an inventory of about 800 drums that had been on site
in late 1972.
It was noted that drums were stored in the open,
outside a shielded structure, at a planned location, and unplanned
(previously described) locations. The licensee had not established
%hd
a formal plan or program that maintained control of, or provided
for, disposal of solid waste that was consistent with the shielded
storage capacity at the site, or consistent with maintaining radia-
tion levels in unrestricted areas (paragraph 2a, b, and c) within
the applicable 10 CFR Part 20 limits. Additionally, the inspector
measured radiation levels to 100 millirem per hour outside the east
door of the radwaste building on February 13, 1973.
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