ML20107C261
See also: IR 05000219/1974017
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RO:I' Form 12
(Oct 74) (Rev)
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U.S. ATO.'!IC ENERGY CO>NISSION
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION I
RO Inspection Rep rt No:
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_ Docket No:
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Licensec: Jernov ceneral Pnva'r and T.4cht en.
_ Licence No: DPR-16
Priority:
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Madinon Ave. nt Punch Bqwl Rd
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Category: .
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Morristown. New Jersey
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Safeguards
Location: Oyster Creek Station
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Groul:
BWR, 640 MWe
Type of Licensce: __
Type of Inspection: unnrina Ham 1th Phymica & cham 4mery. Unannounced
Dates of Inspection: November 11-14. 1974
Dates of Previous Inspection:
October 30. 1974
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Reporting Inspector:
Robert R.' Hyson, adiation Specialist
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Accompanying Inspectors:
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Other Acco.apany'un ietm
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P. J. Knapp, Chiefl a cilities
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_R.,adiation Protection Section~~
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SUMMARY OF FINDINGS
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Enforcement Action
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A.
Violations
1.
Failure to follow requirements of Technical Specifications 3.6.A.3. - Failure to continuously monitor stack releases while
the reactor is in an unisolated condition (JCP&L letters to DL
dated October 23, 28 and November 18, Subject: A0 74-53, A0 74-54
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and A0 74-57)
(Details, Paragraph 15)
2.
Failure to properly label containers of radioactive material.
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(Details, Paragraph 10)
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B.
Safety Items
None
Ilcensee Action on Previously Identified Enforcement Items
None
Unusual Occurrences
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The following abnormal occurrence was reviewed:
A.
Failure of the stack gas sampling system to continuously monitor stack
releases on three separate occasions while the reactor was in an unisolated
condition (JCP&L reports to RO:I dated October 14,18 and November 11, 1974,
Subj ect: A0 74-53, A0 74-54 and A0 74-57)
Other Significant Findir,y,i
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A.
Current Findin.gs
The plant was in the state of reducing power at 1115 hours0.0129 days <br />0.31 hours <br />0.00184 weeks <br />4.242575e-4 months <br />, November
'll, 1974, due to the presence of an unidentified leak in the drpwell.
At approximately 1730 hours0.02 days <br />0.481 hours <br />0.00286 weeks <br />6.58265e-4 months <br /> the inspector observed a team of four
plant personnel (2 HP Technicians) make the initial drywell entry in
search of the soirce of leakage.
The team identified the probable
leakage at a one inch bypass valve around a manual feedwater shutoff
valve.
The inspector noted that the drywell entry was consistent with
the procedures established by the licensee. The stack release rate
on hovember 8, 1974, at a power rating of approximately 655 MWe was
21,450 uCi/sec.
tais is less than 10% of the Technical Specification
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The inspection indicated most areas of the health physico
. program well controlled.
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B.
Status of Previously Unresolved Items
None
Management Interview
The following individuals attended the management interview held at the
conclusion of the inspection on November 14, 1974.
p. A. Ross, Manager Nuclear Generating Stations (via telephone intercom)
D. L. Reeves, Chief Engineer
E. D. Scalsky, Radiation Protection Supervisor
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E. Growney, Technical Engineer
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J. Henning, Engineer
R. Swift, Maintenance Engineer
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J. Cook, Radiation Protection Foreman
D. Kaulback, Radiation Protection Foreman
The following subjects were discussed:
A.
The inspector identified the violations observed during the inspection
and stated that he had noted that certain corrective actions had been
completed.
(Details, Paragraph 10)
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B.
The inspector stated that the test given to station personnel covering
the basic radiation protection orientation course did not contain ques-
tions relating to 10 CFR 19.
(Details, Paragraph 2.c)
C.
The inspector stated that he had reviewed the Training, Retraining and
Orientation Program.
(Details, Paragraph 4 a,c)
D.
The inspector stated that he had reviewed a draft of the new Respi-
ratory Protection Manual and accompanying procedures which are con-
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sistent with ANSI 88.2.
(Details, Paragrapt. 12)
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E.
The inspector stated that a licensee representative had assured re-
ceipt of the three new constant air monitors (CAM) by January, 1975 based
on vendor information. However, the licensee indicated at this in-
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terview that there had been a problem with the actual purchase orders
and that at.present no definite delivery date could be assured. The
status of these CAM's will be further reviewed at the next inspcction.
(Details, Paragraph 6.a.2)
F.
The inspector reviewed with the licensee the air sampling program
which, according to the licensee will be initiated by January,1975.
(Details, Paragraph 6.a.2)
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The inspector noted that a new Radiation Work Permit has received
PORC approval and will be in use according to a licensee representa-
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tive by February, 1975.
(Details, Paragraph 8.b.)
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The licensee indicated that the' Radiation Protection Supervisor will
become an official PORC member as per Technical. Specifications by
January, 1975.
1.
The inspector indicated that he had consulted with the authorized
worker representative.
(Details, Paragraph 14)
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DETAILS'
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1.
Persons Contacted
D.. Reeves, Chief Engineer
E.'Scalsky, Radiation Protection Supervisor
J. Cook, Radiation Protection Supervisor
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J. Molnar,' Training Coordinator
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D. Arbach,-Radiation' Protection Supervisor
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J. Maloney, Operations-Supervisor
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R. Pelrine, Chemistry f.apervisor-
R. Stodonour, Environmental Engineer
W. Spoulos, Station Helper Foreman
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2.
Organization
a.
A licensee representative stated ~ that. the organization at the management
level has remained unchanged from that defined in RO:I Inspection
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Report 50-219/73-14.
b.
Minor changes at the Radiation Protection staff level were reported by
a licensee rer-~'entative as follows.
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1.) Two of t.
Assistant Techniciane (Nuclear) have become Radiation
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Technicians which reduces the former to four persons'and increases
the'1atter to six.
2.) The number of permanent station Helpers (Nuclear) has been increased
from 12 to 15.
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c.
The 3 additional station Helpers received the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. basic orientation
radiation protection course and successfully passed their examination
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according to licensee records. The inspector noted that the tests did
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not include questions on 10 CFR 19. A licensee representative indicated
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this would be done by February 1, 1975.
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3.
Audits
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a.
Internal Programs- The inspector reviewed the records of the latest
GORB Audit of the Radiation Protection' Program made on February 26
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and 27, 1974. The audit findings primarily were concerned with
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inadequate. record-keeping,-revision of-survey forms,-and omissions
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made'on various; survey and data forms. The-inspector. reviewed a
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. response dated,. April 3,11974,, to the GORB Audit, from the
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Radiation Protection Supervisor and found it to be complete.
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b.: ,Qu'a11ty Control of TLD Program- The inspector reviewed the 11cpnsee's
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program for auditing the~ services provided'by their personnel dosimetry
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vendor. The program consisted of " Spiking" thermoluminescent
badges. The calculated doses to the badges were then compared with
those doses reported by the vendor and by Oyster Creek Technicians
who also readout the " Spiked" badges. The inspector noted that this
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procedure is followed at least once per month. Records of all the
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results were found complete.
4.
Training
a.) The inspector reviewed the manual covering orientation, training,
and retraining for requalification with the Training Coordinator.
He indicated that the training of plant personnel in the area of
plant radiation protection would include those items described in
RO:I Inspection Report 74-06 with the exception that the basic
orientation program would require less than one week to complete.
He also indicated that the training manual had received management
approval and that the first course outlines in radiation protection
for orientation and retraining for requalification would be pre-
pared and ready for bnplementation by January,1975.
b.) The inspector verified that Revision 1 of the Radiation Protection
Manual contained a statement of Management's commitment to ALAP.
c.) Training and retraining records including tests reviewed by the
inspector were found to be in accordance with established licensee
programs.
Changes in Plant Facilities
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a.) A licensee representative indicated that the only major change in
Plant Facilities affecting radiation protection was the construction
of a locker and change facility at the north end of the plant. This
facility will serve the mobile maintenance and contractor personnel
primarily during shutdowns.
Radiation monitoring services will be
provided according to the licensee representative.
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6.
Records
a.
In-plant Air Sample Program- A review of records for sampling of
particulates, halogens and gases by the inspector revealed-that the
air sampling program appeared to follow established licensee programs.
However, the following apparent weaknesses in this program were in-
dicated by the inspector:
1.) Too few air samples were being taken in the Radwaste Building,
especially during significant operations, e.g. drum filling,
maintenance of contaminated equipment, etc.
(See Paragraph 8)
2.) There is no defined frequency for the taking of routine a$r
samples throughout the facility.
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' With respect to- this latter item a licensee representative
. presented the inspector wi& a copy of an air. sampling survey
' form'which defined frequencies for the routine sampling of ,
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-air throughout the facility, and indicated that it would be'
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implemented by January, 1975.;
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_Informe. tion was requested regarding' the availability of the three
. constant air monitors (CAM) which, according to a previous state-
ment by the licensee,* were -to arrive at any time. The licensee
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representative stated that the CAM's hsd not yet arrived.-
b.z Personnel Dosimetry. - A review of personnel' dosimetry. records for all
employees covering the time since the last inspection showed no ex-
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.posures in excess of regulatory limits.
1') . Forms AEC-4 reviewed for those- individuals who exceedid 1250 ' mrem
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since the last inspection were found to be complete and in accordance
with regulatory requirements.
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2.) One individual's TLD badge report indicated that he had received a
2990 mrem dose thus far in the fourth quarter. Upon receipt of this
report ~ from the' dosimetry vendor, the licensee conducted an investi-
-gation which indicated a much lower dose (1600 mrea). The in-
spector reviewed the licensee's investigation report -and interviewed
- the individual and several radiation protection personnel. After
'the inspector's review,' he indicated to the licensee that in.his
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opinion the licensee's investigation report was not conclusive
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enough to warrant discounting the results of the exposed TLD badge.
On this basis the lic ensee transferred the individual from all
radiation zones for the present time to avoid a possible- overexpo-
sure.-
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Additional investigation. efforts by the lic -aee on this matter were
reviewed by an inspector and reported on in no:I Inspection Report
50-219/74-18.
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3.) The-inspector reviewed the whole body counting results conducted
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during the second quarter of 1974 af ter the last major shutdown.
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No significant amounts of radioactivity were reported during the
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counting of essentially all assigned station personnel..
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Radiation Surveys
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The' inspector reviewed. the radiation survey res tits for the restricted . area
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~ boundary since the =last: inspection and found them to be in accordance with
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regulatory requirements,
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- RO: Inspection Report-50-219/74-06
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8.
Work Authorization Records
a.) A review of numerous Radiation Work Permits (RWP) by the inspector
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revealed that established licensee procedures were being adhered to in
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this area. The inspector raised a question regarding the following RWP:
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Extended RWP #2237-74, 10/24/74
Job: Drumming Filter sludge in operating Galley
Respiratory Requirements: Filter respirator when centrifuge running
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According to a licensee representative this job is performed once per
week.
The RWP did not specify that breathing zone air samples be taken while
the operator performed the job in a filter respirator during centrifuge
operation; nor were there any records present which indicited that such
samples had been taken. A cognizant licensee representative stated
that the operating galley air concentration during centrifuge operation
for filter sludge dewatering have been greater than 10 CFR 20, Appendix B,
Table I, Column 1, limits.
The inspector. questioned the prudence of not
taking air samples at any time during the performance of the job, and
stated that the matter would be further reviewed at the next inspection.
b.) The licensee representative gave the inspector a copy of a revised RWF
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which has received PORC approval and will be in use by February,1975,
according to the representative.
The revised RRP is more comprehensive
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than the one now in use and, therefore, would appear to be an improvement
over the present RWP from the standpoint of "ALAP."
9.
Solid Wastes
The inspector reviewed the licensee's solid waste program as it applies to
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the following:
a.
Storage location
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b.
Evaluation of isotopic quantities before transfer
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Types of containers
d.
Frequency of transfers
Isoptopic quantities and volumes transferred
e.
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Records
The program as reviewed was found to be in accordance with the licensee's
established procedures and regulatory requirements.
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10. Posting and Labeling
During a tour of the facility the inspector determined by observ.ation
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and measurement that posting of radiation areas and high radiation
areas was in accordance with the requirements 10 CFR 20.203(b) and
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(c). With respect to containers of radioactive materials, the in-
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spector determined, by measurements, observations and discussions
with licensee representatives, that certain drums were not labeled
and, therefore, were not in accordance with the requirements of
10 CFR 20.203(f)(1) and (2).
These drums are identified below:
(1) Two 55 gallon drums on the 75' level of east side of the
Reactor Building. These two drums contained control rod
drive filters and were creating a local high radiation
level as posted.
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(2) Fif teen to twenty 55 gallon drums of solid rad waste stored
in Storage Bay #5 of the Rad waste Building (one of these
drums most accessible to the inspector measured in excess of
100 mr/hr 0 3 cms.)
(3) Three drums of Low Specific Activity material which were
measured in excess of 10 mr/hr at 3 cm. located directly
outside (east side) the Radwaste Building awaiting loading.
b.
A return visit by the inspector the day following his tour of the
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area noted in a(1) and (3) above revealed that these drums had been
properly labeled in the interim period.
11. Disciplinary Program
The inspector reviewed documented disciplinary action, taken by the
licensee against those 1ndividuals who failed to conform to company
requirements in the area of radiation protection. These types of
disciplinary actions appear to be a p<sitive approach in demonstrating
managements commitment to "ALAP."
12. Respiratory Protection Program
The inspector reviewed a draft of the new Respiratory Protection Manual
which incorporated ANSI 88.2 recommendations for procedures. Implementa-
tion of the program is expected af ter incorporation of certain facets of
WASH-1287 and PORC approval according to a licensee representative.
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13. Plant Tour-
a.) The inspector made two ters of the plant which covered primarily the
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Reactor Building, Turbine Building and Radwaste Building. During
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these tours surveys were made by the licensee representative and
the inspector. These areas were consistent with regard to good
housekeeping practices. The-inspector noted that most of the
floors-in all of the areas toured were recently painted which will
aid in.their decontamination in the future should such need arise.
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The inspector also noted an inventory of less than 30 drums of
radwaste in the Radwaste Building.:
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14. Worker Representative
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a.
The inspector. interviewed the authorized worker representative as
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per his request. The worker representative expressed concern in
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the following areas:
-1) Worker Representative's rights to consult with Commission
inspectors during inspections as discussed in 10 CFR 19.
The inspector resolved this problem with the representative in a
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telephone conversation with him on November 27, 1974.
2) Justification of the alleged practice of routinely excluding the
beta dose from the whole body dose during the calculation of
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all worker does. The worker representative contends that in
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at least two cited cases that workers had received significant
beta doses which were not included in their whole body dose,
despite the fact that they were, at no time during the period of
exposure, required to wear any form of eye protection against
beta radiation. The worker indicated that previous to June, 1974,
the instances of such cases were wide-spread and expressed concern
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about the situation prior to th's date.
The representative has expressed satisfaction in the calculation
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of worker doses since June, 1974. The inspector indicated that in
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view of the fact that the problem was corrected in June and because
of the time required he would examine the allegations of past
practices at his next inspi.ction.
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15. Stack
r Sampling System Failures *
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The cc..ective actions identified in the November 18, 1974 letter
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from JCP&L to DL (which included replacement of the present circuit
breaker and thermal overload break 3r with larger breakers and provisions
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for a redundant stack sample pump) will be reviewed during a future
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inspection.
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- Referred to in Unusual Occurrence section
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INSPECTIONTLAN
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(FACILITY)
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RADIATION PROTECTION - TI 3200/2
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(Power Operation - Once Per Year)
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Date(s)
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Insp. Rpt. No.
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Insp. Rpt. No.
Date(s)
INSPECTION __ ITEMS
Follow-up
Completed
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Outstanding Items (See Attached List)
Required
Insp. Rpt. No.
ca.,0rganization . Items 7a. (1)-(3)
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a., Licensee Audits - Items 7b. (1)-(5)
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Training - Items 7d. (1)-(5)
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Rsd-Chem Procedures - 7e. (1)-(2)
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Records, Radiation Safety - Items 7f.(1)-(6)
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9. Waste Storage & Transfer - Items 78. (1)-(3)
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Respiratory Protection - Items 7h. (a)-(e)
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Materials Inventory - Items 71. (1)-(5)
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4. Receipt & Transfer - Items 7j. (1)-(5)
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Shipping Accidents - Items 7k.(1)-(3)
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Facilities & Eqtdpment - Items 71. (1)-(2)
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Notifications & Riports - Items 7m.(1)-(2)
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lb. Posting of Noticea - Items 7n. (1)-(6)
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Independent Measurements - Items 7o. (1)-(2)
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Management Interview - Item 7p
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Approved
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(ReportingIgpector)
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Revis!on 1
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OUTSTANDING ITEM LIST
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Facility /Licensce: _ %bkN\\ T 8-I .
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Location:
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License No. _) M -\\\\
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REFERENCE
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