ML20147F239

Responds to Four Findings Noted in Integrated Performance Team Insp Rept 50-219/87-24.Corrective Actions:Alara Procedure 1000-ADM-4010.02 Formalizing Util ALARA Program in Draft Form & Targeted for Implementation in Feb 1988

ML20147F239
Person / Time
Site:	Oyster Creek
Issue date:	01/15/1988
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8803070293
Download: ML20147F239 (10)

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GPU Nuclear Corporatlon Nuclear =en:r388 Forked River.New Jersey 08731-o388 609 971 4000 Writers Direct Dial Number:

January 15, 1988 William F. Kane, Director Division of Reactor Projects U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report No. 87-24 GPUN Response to Integrated Performance Assessment Team Findings As requested by the subject report dated November 9,1987, Attachment I provides responses to the four findings identified by the inspection team.

An extension of the aue date for this response to Jaauary 15,1988 was l requested by GPUN and granted by Mr. J. Wechselberger.

If you have any questions please contact Brenda DeMerchant, Oyster Creek Licensing Engineer at (609)971-4642.

Very truly yours, P er . iedler Vice President and Director Oyster Creek PBF/BD/ dad (0427A) cc: Mr. William T. Russell, Administrator Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406 Mr. Alexander W. Dromerick, Project Manager U.S. Nuclear Regulatory Commission Division of Reactor Projects I/II 7920 Worfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 NRC Resident Inspector Oyster Creek Nuclear Generatina Station 8803070293 000115 PDR ADOCK 05000219 0 PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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,; 7, ATTACHMENT I Finding No.1:

Definition and coordination of your ALARA program (inspection report paragraph 3.3.)

Response

The performance of the Oyster Creek plant with respect to radiation protection issues has been a matter of concern and a matter which has received considerable attention over the last several years. It is clear that our performance with regard to the key index of collective dose has not been at a desirable level. Other indicies such as the number of skin contamination occurrences 'and extent of contaminated areas are not at levels considered to meet our standards. Actions have been taken, however, and further efforts are underway to improve these indicies and others which collectively constitute the ALARA program at Oyster Creek.

The IPAT team identified a number of concerns which fall under the tiroad category of ALARA performance. These concerns listed below are addressed individually as follows:

NRC ALARA PROGRAM CONCERNS

1. There is no documented overall ALARA plan or program

2. No individual is designated as "ALARA Coordinator"

3. There is no overall long range plan to meet the ALARA objective /

Dose estimates are not prepared by careful analysis 4 The Radiological Review process for work commences at a too high threshold

5. Radiological Controls technicians have not received formal training in ALARA concepts and responsibilities

6. Goal setting for collective dose is not realistic

! 1. ALARA Program Documentation GPUN ALARA Procedure,1000-ADM-4010.02, has been issued in draft form and l

is targeted for implementation in February 1988. This procedure formalizes the GPUN ALARA Program. Program oversight is vested in Dose Management Committee with the charter to l " .. review the status of collective dose, recommend modifications to

j. work plans, effect actions to reduce collective dose and provide

! management overview of ALARA Program effectiveness."

The committee will be chaired by the station's Deputy Director and each department will be represented.

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The ALARA procedure discusses

. The GPUN committment to the ALARA objective

. The management system for ALARA implementation including senior level oversight and site level . awareness reporting

. Organizational Responsibilities and Authorities - each affected GPUN Division's requirements are set forth

. Records requirements

. Training requirements for all radiation workers, engineers, architects, site maintenance personnel, contractors, and management.

. Work Planning

. Long Range Planning

. Radiological Engineering review of work and the RWP process

. Dose optimization and cost benefit analyses

. System for Analyzing ALARA Performance

. Audits of ALARA Program effectiveness

2. ALARA Coordinator The Radiological Engineering Manager is assigned functional responsibility for the following aspects of the ALARA program and as such acts as the ALARA coordinator:

. Review of radiation exposure and effluent release data (effluent release data is currently monitored by Environmental Controls).

.- Interface with other departments. l

. Modification design review.

. Maintenance nf procedures, data and records.

. Periodic reports to plant and corporate managements.

, Reconnendations for exposure reduction activities including decontamination, shielding, modification, et cetera.

. Input to outage planning.

. The Radiological Engineering Manager and the Dose Management Committee will enable GPUN to effectively coordinate its ALARA program within a matrix organization.

3. Long Range Plan to Achieve ALARA Objective / Dose Estimate Preparation A. Long Range Plan GPU Nuclear is pursuing long range exposure reduction objectives.

. The base document for planning all future work is the Long Range f Plan (LRP). The document has been prepared and developed by a multi-disciplinary group - the Long Range Planning Group (LRPG) - in conjunction with the Long Range Planning Department. The Corporate Radiological Engineering Department has been represented on the Long Range Planning Group since its inception and has played a very active role in its activities. The LRPG reviews all proposed work for inclusion into the LRP and has as one of its authorities the ability to limit job scope based on projected radiation exposure.

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The Corporate Radiological Engineer assigned to the LRPG is specifically responsible- for providing conceptual radiation exposure estimates and dose reduction suggestions for these activities which I are approved for inclusion into the LRP. From these estimates, Radiological Controls can plan for. future operating cycles and outages as well as give appropriate attention to high exposure activities on a prioritized basis. The 1988-1989 exposure estimates are currently being documented. A procedure is under development to allow exposure estimates to progress commensurate with the engineering / development of projects and activities.

B. Long Term Exposure Reduction Activities GPUN is now pursuing specific projects and activities directed towards long term radiation exposure reduction. Furthermore, there has been significant effort in dose reduction in the recent past.

During the outages in 1983-84 access platforms were installed in the drywell as was a chiller system. These actions improved access and habitability thereby reducing dose. In 1986, the recirculation loop risers received a chemical decontamination saving nearly 900 person-rem.

A major source term reduction activity being purrued by the Company in its Long Range Planning activities is a chemical decontaniination of the entire reactor system. This chemical decontamination is currently being examined for applicability and scheduling into the 14R outage (1992) in conjunction with in-service inspection and stress improvement of the recirculation piping safe end welds. The reason for scheduling this activity during the 14R outage is to ellow sufficient time to develop the engineering and feasibility for >

4 this project as well as to take advantage of industry restorc? and j development in this area.

The GPUN Technical Functions Division has been evaluatir.g other activities in an effort to reduce the radiation source term in the plant.

Two major activities that have been evaluated include (1) reduction of the cobalt inventory and (2) zine addition. A Technical Data Report (TDR #776) has been issued which delineated an action plan for cobalt reduction. Zinc addition has been evaluated for use at Oyster Creek however the Company decided that it would not be prudent to implement at the current time. ,

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Another aspect of' exposure reduction that ths Company is pursuing is in the use of special tooling and robotics. Currently, plans are .in -

place to install a new control rod drive (CRD) handling machine for the 12R outage (1988)~ This machine is estimated to save 30% of the

-radiation exposure associated with removing CRDs. Also, early in

.1988 a pilot study will be conducted to evaluate the feasibility of using robotics to perform various surveillances that are radiation exposure intensive.

Other activities instituted by the Company to er. hance plant performance, productivity, and reduce radiation exposure include:

(1) the Work Simplification Program, (2) an enhanced material management program and (3) an automated access control system pilot project.

4. Trigger levels for Radiological Review of Work All work to be performed within the radiologically controlled area does receive a review by knowledgeable persons within the Radiological Controls Department. There are two levels of review. For routine activities t.ke process by which a Radiation Work Permit (RWP) is prepared constitutes thJ first level of review. All work in the radiologically controlled area ls performed within the scope of an RWP. A Radiological Engineer reviews eah Radiation Work Permit (RWP). If necessary, he specifies - directly on the RWP - any needed exposure reduction measures. A Group Radiological Controls Supervisor reviews each RWP and makes needed ALARA imprtevements as regaf red. This individual, by signing the RWP, verifies and atwsts to this review.

A Radiological Controls ?rocedure 9300-ADM-4010.02 "ALARA Review Procedure" sets forth the criterie by which nork is judged to require a more comprehensive review for implementation of ALARA actions. These criteria include the f ollowing:

. Any task in which the airborne radioactivity concentration is expected to exceed by a factor of 50 the limits specified in 10 CFR 20, Appendix B, Table 1, Column 1.

. Any task that could release radioactive material directly to the environment. ,

. Any task inside highly contaminated systems or components as defined i

by Radiological Engineering.

. Any task for which the dose / dose rate to the skin and/or extremities may be limiting without special radiological controls.

. Any task anticipated to accumulate 5 person-rem or more of total exposure.

It should be noted that the collective dose "trigger" referred to in the IPAT report is just one of the criteria used to determine the need for a Radiological Engineering review.

Furthermore, the Radiological Controls Department may conduct a Radiological Engineering review even though the work does not exceed any of the criteria triggers referenced above.

Our analysis of work has'shown that more than 85% of all work in the Radiologically Controlled Area receives a review by Radiological Engineering. Over 90% of the total collective dose has occurred on jobs covered by formal Radiological Engineering ALARA reviews. We believe that the 5 rem 7 trigger" in conjunction with other criteria in use is appropriate to ensure that work receives a sufficiently high level of revi ew.

5. ALARA Training for Radiological Controls Technicians Radiological Controls Technicians (RCTs) are formally trained in ALARA through various training programs. One such program is General Employee Training which, in accordance with the GPUNC Radiation Protection Plan, provides training in ALARA-philosophy and concepts.

Another program which provides formal ALARA training is the RCT training program. In this program, technicians receive training on ALARA (concept, purpose, and methods of implementation) in accordance with the Oyster Creek Radiological Controls Field Operations Personnel Qualification / Training Standard. This training is provided during initial training to Step 1 RCTs. Additionally, various forms of ALARA training are periodically provided to the RCTs during cyclic training, a portion of which was noted as a good practice under "Training" on page 22 of the U. S. Nuclear Regulatory Commission Report Number 50-219/87-24.

The responsibility of ALARA is, in fact, a formal responsibility for

' Radiological Controls Technicians. It is primarily set forth in the GPUNC Radiation Protection Plan which calls for each employee to maintain individual and collective exposure to workers and the public ALARA and also states that radiological surveillances (performed by RCTs) of jobs are to be accomplished to maintain radiation exposure in accordance with the ALARA objective,

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The formal tasking of RCTs with the responsibility of ALARA is also accomplished through the RCT doo Description which states one of the duties of the RC' is the minimization of exposure to radioactive material in the work area.

6. Collective Dose Goal Setting Needs Improvement GPUN realizes the need for realistic long range collective exposure goals. As part of the long range planning process, goals are being developed for 1988 and beyond. Management's selection of a goal for 1988 has already served a useful purpose because it has caused all departments to evaluate .he work planned for the year in terms of an exposure budget. A goal of 280 person-Rem for nine morths of operation has been selected. The goal for the 12R Outage has not yet been determined.

GPUN does apportion the total exposure budget among the various Oyster Creek departments and this has been the practice for several years.

Radiological Engineering tracks department status versus the goal using computer software and distributes reports to department managers to increase the effectiveness of goal setting as noted by the inspection report.

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' Finding No. 2:

Appreciation of the need for clear and effective administrative controls for Plant Engineering'(PE) activities (paragraph 6.3.1).

6.3.1- We would like to clarify the last sentence of the first paragraph.

The last sentence should read "... is taking a more active role in day to' day lant activities;" not, "... is taking a more active role in day to ay _ activities."

6.3.1 Paragraph Six (6) states: PE has prepared several modification packages for non-safety-related equipment and intends to expand its scope to include safety-related work. PE is presently using Technical Functions Procedure EMP-019 (Plant Modifications Engineered by PE) to perform this wor!c. A procedure aligned to the PE organization, which specifies in detail how modification work is to be performed, when 'done under PE cognizance, is needed to enhance the quality and control of work. It is the team's understanding that a procedure is being prepared and that PE will not perform safety-related modifications until the new procedure is approved.

(This understanding was confirmed at the exit interview.)

gsoonse:

It should be noted that all Plant Engineering performad mods were done in full compliance to EMP-019. The development by PE of a procedure aligned to the Oyster Creek Division was initiated to simplify and clarify the requirements of EMP-019. The Technical Functions '(TF) Division (to which EMP-019 is aligned) has the responsibility to establish and maintain the modification control process for GPUN. Consequently, the Oyster Creek Division mcdification control procedure implements the requirements previously established by the TF Division. This procedure has been prepared and has substantially completed the review process. It is expected to be issued in February 1988.

6.3.1 Paragraph Seven (7) states: PE calculations reviewed, although technically adequate, were inconsistent and missing key elements. PE calculations did not clearly state purpose, identify references and list assumptions. The team believes that the guidance contained in OCNGS Procedure 125 concerning engineering calculations is inadequate and a procedure for performing engineering calculations should be prepared.

Response

PE procedures have been revised to require use of EP-006, "Calculations" and EP-009, "Design Verifications", which provide greater formality in the documentation of calculations.

In addition Procedure 125, "Conduct of Plant Engineering," has been revised to reflect the requirements to use EP-006 for calculations.

=,. ,e i 6.3.1 Paragraph Nine (9) states: OCNGS Procedure 125, Plant Modification Control," contained several references' to the Plant Operations Review Committee '(PORC), which indicates that the procedure has not been updated- to reflect the new safety review organization that has.been in effect for several years.

-Response:

The procedure reference number _ is incorrect. It is 124 not 125. The procedure-has been changed to reflect the new safety review process.

We'would also like to provide the following comment concerning our Systems Engineering Program status (paragraph 6.3.4):

6.3.4. Systems Engineering and System Working Groups, Paragraph Three (3) sta tes: The Plant Engineering Division has begun the implementation of the system engineer program by making the individual assignments.

However,the job responsibilities and minimum training requirements are not specified. In order for the program to be effective, the team believes a formal commitment to the project has to be made by means 'of a PE procedure or policy statement that should include as a minimum the statement of responsibilities, formal training and experience requirements, guidelines for resolving potential interface problems, and a policy commitment outlining the PE Division's planned implementation schedule (Observation).

C0t94ENT A formal program description has been developed for the system engineers which establishes responsibilities, training requirements, interdepartmental interfaces, formal system engineer certification process, and schedule for implementation.

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' Finding No'. 3:

Control of temporarily; stored equipment in-plant, including gas bottles',

-ladders, and equipment on rollers.

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-Response:

. Guidelines for controlling temporarily stored equipment have been developed and issued to plant personnel. This direction shall be followed pending developoent of a formal procedure which is scheduled for issuance by February 15, 1988.

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. Finding No. 4:

Enhancement of-facility staff's risk perspective and comprehension of design base's (paragraphs 2.2.3 and 7.0).

Response

GPUN agrees that increased knowledge of the design basis of the facility will increase risk perspective and enhance safety. Our training department will review applicable lesson plan Training Content Records (TCRs) for licensed operator, non-licensed operator, and maintenance training and where appropriate, include FSAR references and integration of appropriate design basis information into the content of the lesson plan. An overview orientation to the FSAR, which is one of the principle sources for plant system design basis, will be developed. The goals of this orientation training is to increase the sensitivity of our non-licensed operators and maintenance technicians to the purpose, basis and description of safety systems.

GPUN is developing a coordinated Nuclear Safety Awareness Program. The objective is to increase employee awareness of the existence and function of the Ombudsman, of the nuclear safety process, and of the Human Performance Evaluation System (HPES) program. All of these are directed at improving Auclea? safaty. . Heightened employee awareness of nuclear safety will provide a better enoerstanding of the rotationship of the impact of their work activities and nuclear safety.

In addition, several upgrades are planned for safety review process training.

GPUN believes that an increased awareness of design basis information among the originatcrs, the Responsib'e Technical Reviewers, and the Independent Safety Reviewers will enhance the direction and guidance provided for non-licensed operators and maintenance staff. Procedure 1291.01 is being revised to specifically identify those documents which make up the "Safety Analysis Report" (SAR). 10 CFR 50.59 requires that licensees address those aspects of safety contained in the SAR. The definition of.SAR has been taken from 50.34 (b). In addition a listing of compliance documents mandated by various regulations will be available for their review. This will provide the originator with a listing of various documents which can be reviewed to ensure the specific task being proposed does not invalidate the design basis.

Originators of safety evaluations will also be formally included in the safety review process training program.