ML20138M083
| 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) | |
See also: IR 05000219/1985018
Text
- _ - _ _ _ _ _ _
-
.
!
'
ENCLOSURE 1
,
-
,
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/85-18
Docket No.
50-219
License No.
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
MC [ff
Approved by:
u g:.
. tVPasciak, Chh f, BWR Radiological
'
' date
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).
~
8512200221 851213
ADOCK 05000219
O
-
..-
.- - - - - - .. .
- .- .
- -. -
-
-
.-
. - .
'
.
.
f
DETAILS
1.0 Licensee Personnel
'
- P. Fiedler, Vice President and Director, Oyster Creek
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
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
during the inspection.
'
1.1 Nuclear Regulatory Commission - Region I
W. Pasciak, Chief, BWR Radiological Protection Section
- B. Bateman, Senior Resident Inspector
,
- J. Wechselberger, Resident Inspector
- Attended the exit interview on June 7, 1985.
2.0 Purpose
I
The purpose of this routine inspection was to review the licensee's
Radiological Controls Program with respect to the following elements:
,
<
Status of Previously Identified Items
Exposure Control and Assessment
- .
Radiation Work Permits
,
Surveillances
,
-*
w-4,
.
.--.-.-,,;
y_
.-., - . -,e-
, - -
.-
,---w---,-c.--.,,,
. -e,
=y----
--
-3
-
-
_
_
r
.
,1
9
'
'
J
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
representative for onsite solidification processing.
The procedure
1
revision was issued on May 2, 1985.
s
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
,..
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
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
-
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-
-
cedu'es were in.the final review process.
&
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
recommendations will be reviewed during the next pre-outage and outage
~
inspections.
\\
y
e
'
\\b
-
[
gi;g
M
l_ <
\\.
,
.
-l
4
. , - .
g,---.
, - ,
- - - .
-r.
.--
, - - . .
_ _ . . - ,
--
.
--
.
4
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"
Technical Specification 6.13, "High Radiation Area."
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."
-
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:
10 CFR 19.11, Postir.g of notices to workers
10 CFR 19.13, Notification and reports to individuals
10 CFR 20.101, Radiation dose standards for individuals in
Restricted Areas
10 CFR 20.102, Determination of prior dose
10 CFR 20,202, Personnel monitoring
10 CFR 20.401, Records of surveys, radiation monitoring and disposal
a
10 CFR 20.407, Personnel monitoring reports
-
,
'
y
<
.
,
'
5
,
.
Information Notice 81-26, Part 3, Supplement No. 1: " Clarification
- >
'
b
~_of Placement of Personnel Monitoring Devices for External Radiation"
Information Notice 83-59: " Dos [AssignmentforWorkersin
Non-UniformLRadiation Fields."
'\\
. z
.In addition,,the' licensee conformance to Technical Specification 6.11,
f
Radiation-Protection Program und to selected program pro 2edures was
reviewed, including:
s,
,
,
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"
- ~
ADM-4241.05, Revision 0, " Dosimetry Investigative Reports"
ADM-4241.08, Revision 0, " Personnel Termination"
a
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:
~
Technical Specification 6.11 requ' ires, in part, adherence-to radiation
protectiop procedures for all operations involving personnel radiation
~
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
s
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
a
.
.
.
'
6
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."
.
.
.
.
7
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:
10 CFR 20.201, Surveys
Technical Specification 6.11, " Radiation Protection Program"
ANSI N18.7-1976, " Administrative Controls and Quality Assurance for
=
the Operational Phase of Nuclear Power Plants"
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
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-
.
__
___ _ _ _
--
_
-
__
.
.
8
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
Meeting 50-219/85-21 which is enclosed).
s
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.
.
.
9
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.
et