ML20138M083

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Insp Rept 50-219/85-18 on 850603-07.Violation Noted:Failure to Adhere to Radiation Protection Procedures & Apparent False Statements at Time of Insp
ML20138M083
Person / Time
Site: Oyster Creek
Issue date: 06/26/1985
From: Marilyn Evans, Mark Miller, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138M058 List:
References
50-219-85-18, NUDOCS 8512200221
Download: ML20138M083 (9)
v • d • e


See also: IR 05000219/1985018

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, ENCLOSURE 1

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-219/85-18

Docket No. 50-219

License No. DPR-11 Priority -

Category C

Licensee: GPU Nuclear Corporation

P.O. Box 388

Forked River, New Jersey 08731

Facility Name: Oyster Creek Nuclear Station

Inspection At: Forked River, New Jersey

Inspection Conducted: June 3-7, 1985

Inspectors: WM WMfot, G/,:W[5'

M. M Miller 7 Radiation Specialist ' datie

W'~297d4L A 4/aYhr

M. Gau Evan g Reactor Engineer ' date

Approved by:

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. tVPasciak, Chh f, BWR Radiological

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Protection Sectio

Inspection Summary: Inspection on June 3-7, 1985 (Report No. 50-219/85-18)

Areas Inspected: Routine, unannounced safety inspection of the licensee's

Radiological Controls Program including: status of previously identified

items,. exposure control, Radiation Work Permits, and surveillances. The

inspection involved 62 inspector-hours onsite by two region-based inspectors.

Results: One violation was identified: failure to adhere to Radiation

Protection Procedures (paragraph 4.2). In addition, apparent false statements

were made to NRC inspectors (pararaph 7.0).

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8512200221 851213

PDR ADOCK 05000219

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DETAILS

1.0 Licensee Personnel

  • P. Fiedler, Vice President and Director, Oyster Creek

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R. Heward, Vice President and Director, Radiological Controls, GPU

J. Sullivan, Jr. , Plant Operations Director

  • D. Turner, Radiological Controls Director

D. Arbach, Radiological Health Manager

, M. Littleton, Radiological Engineering Manager

P. Scallon, Field Operations Manger

  • G. Simonetti, QC Audit Manager
  • T. Snider, Radwaste Operations Manager

J. Derby, Field Operations Deputy Manager

E. Buruszkowski, Radwaste Operations Engineer

P. Calandra, Group Radcon Supervisor

R. Hurley, Dosimetry Supervisor

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A. Smith, Group Radcon Supervisor

M. Stearns,_ Radiological Instrument Specialist

  • B. Hohman, Oyster Creek Licensing Engineer

D. Holland, Oyster Creek Licensing Engineer

The inspector also contacted other licensee and contractor employees

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during the inspection.

1.1 Nuclear Regulatory Commission - Region I

W. Pasciak, Chief, BWR Radiological Protection Section

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  • B. Bateman, Senior Resident Inspector
  • J. Wechselberger, Resident Inspector
  • Attended the exit interview on June 7, 1985.

2.0 Purpose

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The purpose of this routine inspection was to review the licensee's

, Radiological Controls Program with respect to the following elements:

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  • Status of Previously Identified Items
  • Exposure Control and Assessment
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  • Radiation Work Permits
  • * Surveillances

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3.0 S_ta,tus of Previously Identified Items

j 3.1 (Closed) Inspector Follow-up Item (50-219/85-04-01): Define respon-

sibility of Group Radwaste Supervisor with regard to coordinating with

vendor.who provides onsite solidification processing. The inspector

noted Procedure 106.4, revit. ion 9, " Conduct of Operations: Radwaste and

Augmented Off-Gas Facilities" was revised to address the coordination

respcnsibility of the Grcup Radwaste Supervisor with the senior vendor

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representative for onsite solidification processing. The procedure

revision was issued on May 2, 1985.

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3.2 (Closed) Inspector Follow-up I~ tem (50-219/85-04-02): Review tagging of

,.. inoperative and not-in-use Radwaste Control Room Instrumentation. The

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inspector toured the Radwaste CR and noted that inoperative and informa-

, tion tags were posted, advising Radwaste operators to refer to Administra-

, tive Controls for determining tank levels. The practice of recording

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invalid numbers which had been identified during a previous radwaste

inspection was not observed. With regard to the new radwaste building

release monitors which are not required, a plant engineering request was

issued o January 30, 1985 to physically remove the monttors. The inspec-

tor also noted that a Techr.ical Functions Work Request was initiated on

.. May 17, 1985 to remove the monitors and update the P&ID drawings. The

licensee stated that Alarm Response ' Procedure 501, which addressed specific

' ' - action in response to these monitors will be deleted after the monitors

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are physically ~ removed.

3.3 (0 pen) Inspector Follow up Itera (50-219/85-04-03): Improve ALARA Program

procedures and evaluate,the et fedtiveness of the prog ~ ram. The licensee

implemented an improved exposure tracking system by assigning a more

. ',o descriptive exposure tracking number. In additicn, the radiological

engineer routto.ely interrogste the on-line dose assessment system (i.e.,

REM System) to access current exposure data to perform.on going job

reviews. However, the inspedor oted the criteria for initiation of

, thistypeof,reviewwasnotdefin(gdinthelicensee's.currentALARA

procedures. The inspector noted that the licensee's'ALARA planning pro-

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cedu'es were in.the final review process.

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& With qegard to meanuring the effectiveness of the ALARA Program, the

licensa conducted 1an ALARA effectiveness review based on the site's

, performance during the last outage. The review team consisted of upper

level management from multi-disciplines within the GPU Nuclear Corpora-

tion. The inspector reviewed the management recommendations which were

issued on February 1, 1985. The licensee's implementation of these

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recommendations will be reviewed during the next pre-outage and outage

inspections.

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4.0 Exposure Control and Assessment

4.1 Radiation and High Radiation Area Posting and Control

The inspector reviewed the adequacy and effectiveness of the licensee's

Radiation and High Radiation Area posting and control. The review was

with respect to criteria contained in the following:

10 CFR 20.203, Caution signs, labels, signals and controls

Technical Specification 6.11, " Radiation Protection Program"

The licensee's performance relative to these criteria was determined from

interviews with the Director, Radiological Controls, independent radiation

surveys by the inspector, observations by the inspector during tours of

the Radiation Controlled Area (RCA), and review of selected licensee pro-

cedure, including Rad Con Procedures 9300-ADM-4110.01, " Establishing and

Posting Areas in the Radiologically Controlled Area, Revision 0" and

9300-ADM-4110.06, " Control of Locked High Radiation Areas, Revision 1."

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Within the scope of this review, no violations were identified. The

inspector noted that the licensee had identified an occurrence when a

locked High Radiation Area was left open. The licensee conducted a

critique and reviewed the incident with the staff who were involved. The

inspector verified that entrances to High Radiation Areas in excess of

one rem per hour were properly posted and locked.

4.2 Personnel Dosimetry and Exposure Records

The inspector reviewed the issuance and use of personnel monitoring

devices and the licensee's personnel exposure records program with

respect to criteria contained in the following:

Restricted Areas

a 10 CFR 20.401, Records of surveys, radiation monitoring and disposal

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b ~_of Placement of Personnel Monitoring Devices for External Radiation"

Non-UniformLRadiation Fields."

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.In addition,,the' licensee conformance to Technical Specification 6.11,

f Radiation-Protection Program und to selected program pro 2edures was

reviewed, including:

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915.12, Revision 10, " Radiation Work Permit (RWP)" T

ADM-4241.01, Revision 0, " Dosimetry Issuefand Handling"

ADM-4241.07, Revision 0, " Personnel Dosimetry Requirements"

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ADM-4241.05, Revision 0, " Dosimetry Investigative Reports"

a ADM-4241.08, Revision 0, " Personnel Termination"

  • ADM-4110.15, ' Revision 0, "On-Line Dose Assessment and Manual

Operation of a Control Point."

The licensee's performance in this area was ased on review of selected

personnel exposure records, personnel exposure termination reports,

Dosimetry Investigative Reports (DIRs) for 1984 and 1985, Personnel

Monitoring Report for 1984, issuance of dosimetry, extremity dosimetry

logs and exposure assignment, and discussions with cognizant licensee

personnel. e

Within the scope of this review, the following violation was identified:

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Technical Specification 6.11 requ' ires, in part, adherence-to radiation

protectiop procedures for all operations involving personnel radiation

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exposure. Licensee Procedure 915.12 requires, in part, compliance with

any condition stated on the RWP by all personnel who sign in on the RWP.

Licensee Procedure ADM-4241.05' requires, in part that a DIR be performed

for a malfunctioning self-reading dosimeter or for a violation of

posting /RWP requirements without proper dosimetry. The RWP for entrance

to the Condenser Bay whil< at power, RWP No. 33485, required,,in part that

a 0-200. mrem and 0 -500 mrem self-reading dosimeter be worn. o

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Contrary to the above, a self reading dosimeter'(SRD) in the 0-500

mrem range was not issued to an individual what had signed in on RWP

No._33485 on June 6, 1985.

The-inspector noted the apparent violation of RWP No. 33485 when the

individual reported to the RWP Office that he had dropped his SRD after

exiting the Condenser Bay, which is a locked High Radiation Area. The

inspector observed an HP technician read only one SRD and assign'a zero

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dose after consulting with the Group Radcon Supervisor (GRCS). The GRCS

stated that the SRD lined up with zero and therefore had not malfunc-

tioned. The inspector noted that the licensee, at that time, had not

questioned the individual concerning his stay time in the Condenser Bay or

his movements while in the locked High Radiation Area.

  • Also, contrary to the above, the licensee failed to perform a DIR

based on_the apparent violation of an RWP requirement concerning

proper dosimetry and a suspect SRO value. The inspector noted that

.the Fields Operations Manager stated a DIR was not necessary because

a TLD and at least one SRO was worn. However, the Director of '

' Radiological Controls for both Oyster Creek and TMI-2 stated that a

DIR was required. The licensee reported that a OIR was subsequently

performed after the inspectors had completed the inspection, and

that a dose of 7 mrem was assigned for the above entry.

Failure to adhere to the Radiation Work Permit condition concerning

personnel dosimetry and failure to adhere to the criteria for performance

of a Dosimetry Investigation Report constitutes an apparent violation of

Technical Specification 6.11 (50-219/85-18-01).

Within the scope of this review, the inspector verified that personnel

exposure records and personnel exposure termination reports were

completed, as required by applicable regulatory requirements and by the

licensee's procedures. In addition, the inspector noted agreement

between the exposure data and the Annual Personnel Monitoring Report

submitted to NRC, and that no individual received an exposure greater

than the allowable regulatory limits during 1984.

4.3 Internal Exposure Control

'The internal exposure control program was reviewed again:t the criteria

contained in the following:

= 10'CFR 20.103, Exposure of individuals to concer,trations of Radio-

active Material in air in Restricted Areas

= 10 CFR 20.201, Surveys

  • Selected licensee procedures, including:
  • 915.22, Revision 1, " Air Sampling Procedure"

= ADM-4020.02, Revision 1, " Description and Selection of

Respiratory Protective Equipment"

  • ADM-4025.01, Revision 1, " Bioassay Procedure"
  • ADM-4330.02, Revision 1, " Monitoring for Personnel

Contamination."

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The licensee's performance in this area was based on review of a sampling

of RWPs and the RWP requirements concerning air sampling and respirator

selecticn; MPC-hours Tracking Log for 1985; personnel contamination events

and associated whole body counts; and observations by the inspector.

Within the scope of this review, no violations were identified.

The inspector also reviewed the bioassay results for the five workers

contaminated while performing venting and filling operations on the TN-9

spent fuel shipping cask on April 30, 1985. Whole body counting results

indicated that no regulatory personnel intake or exposure limits were

exceeded. In addition, the inspector noted that the licensee had

critiqued the event and issued a temporary procedure change to ensure

that.a leak from the vent fitting would not reoccur.

5.0 Radiation Work Permits

The issuance, adherence to and adequacy of the licensee's Radiation Work

Permits (RWPs) were reviewed against the following criteria:

Technical Specification 6.11, " Radiation Protection Program"

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ANSI N18.7-1976, " Administrative Controls and Quality Assurance for

the Operational Phase of Nuclear Power Plants"

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Licensee Procedure 915.12, Revision 10, " Radiation Work Permit"

Perfornance relative to these criteria was determined by a review of

selected Standard, Go With, and Extended RWPs issued between June 1984

and June 5, 1985 and their' supporting surveys. IN addition, direct

observations of work in progress were made by the inspector.

Within the scope of this review, no violations were identified except as

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previously discussed in Section 4.2 of this report. However, the inspec-

tion noted that survey information was not readily available for personnel

entering on RWP No. 33485. " Observation and Inspection of Condenser Bay

Areas While Plant is at Power." RWP No. 33485 required an individual to

contact Radcon for survey information. The inspector observed that per-

sonnel performing a fire watch surveillance in the Condenser Bay had not

requested this information, and HP technicians responsible for the RWP

access control were not providing this information unless requested. The

inspector noted that two HP technicians stated they would have to contact

their GRCS to get updated survey information. The inspector observed that

-personnel entering the Condenser Bay were provided a survey instrument to

provide dose rate information and to control their movements in the High

Radiation Area. However, the inspector requested that approved survey

results be made readily available. The licensee stated that for RWPs

that required personnel to contact Radcon for survey information, docu-

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mented survey results would be discussed with the individual (s) before

allowing entry. This area will be reviewed during a subsequent inspection

(50-219/85-18-02).

6.0 Su'rveillances

The licensee's procedures and calibration facility for calibrating survey

instrumentation, portal monitors and self-reading dosimeters were reviewed

against ANSI N323-1978, " Radiation Protection Instrumentation Test and

Calibration," and ANSI N322-1977, " Inspection and Test Specification for

Direct and Indirect Reading Quartz Fiber Pocket Dosimeters." The

licensee's conformance with Technical Specification 4.11 for performing

. sealed source leak tests surveillances, and with Technical Specification 6.10 for retaining records of sealed source leak tests was reviewed

against ANSI N5.10, 1968, " Classification of Sealed Radioactive Sources,"

and licensee procedures 901.4, Revision 7, " Source Leak Test," and 931.5,

"Use and Inventory of Licensed Sources."

Performance relative to this criteria was determined by review of

calibration records and verification of calibration due date stickers,

and review of sealed source leak tests results and inventory records, as

well as discussions with cognizant licensee individuals.

Within the scope of this review, no violations were identified. The

inspector noted-that the licensee had computerized its records for-

instrumentation calibration and licensed source inventory.

7.0 Apparent ~ False Statements to NRC Inspectors

The inspectors discussed their findings, as described in section 4.2 of

this1 report, with a Group Radcon Supervisor on June 6,1985. On the

-following day, statements were made by this individual and an HP techni-

.cian that were contrary to the inspectors observations.. Preliminary

investigation by the licensee found that their statements were apparently

false. . Licensee management completed their investigation on June 12,'1985

and presented their results during an Enforcement Conference on June 13,

1985. (A summary of this meeting is documented in Enforcement Conference

s Meeting 50-219/85-21 which is enclosed).

8.0 Exit

The inspectors met with licensee representatives (denoted in section 1.0)

on June 7, 1985. The inspector summarized the purpose, scope and findings

of the inspection. In addition, the inspector's understanding of the

events related to the apparent false statements were described.

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Management telephone conversations between Mr. T. Martin of my staff and

Mr. Fiedler before and after the exit interview discussed the licensee

planned investigation. We also requested that the results of the

investigation be provided to the NRC.

At no time during the inspection was written material provided to the

licensee by the inspector.

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