ML20153D818
| ML20153D818 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/29/1988 |
| From: | Amato C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153D795 | List: |
| References | |
| 50-219-88-06, 50-219-88-6, IEIN-83-28, IEIN-84-80, NUDOCS 8805090299 | |
| Download: ML20153D818 (10) | |
See also: IR 05000219/1988006
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/88-06
Docket No.
50-219
License No.
OPR-16
Priority
Category
C
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Licensee:
GPU Nuclear Corporation
P. O. Box 388
Forked River, New Jersey 08731-0388__
Facility Na:ne:
Oyster Creek Nuclear Generating Station
Inspection At:
Forked River, New Jersey
Inspection Conducted:
February 22-26, 1988
Inspectors:
[ M/98 / f/ [
C.G.Amago,EmergencyPreparedness
y date
C
Specialist, EPS, FRSSB, DRSS
E. F. Fox, Sr., EPS, EPS, FRSSB, DRSS
R. K. Christopher, EPS, FRSSB, DRSS
Approv:d by:
wt4 t ccs --
Y J9
W. J.dazarus(Jhief
date
Emergency Preparedness Section FRSSB, DRSS
Inspection Summary:
Inspection on February 22-26, 1988 (Report No.
50-219/88-06)
Areas Inspected:
Routine, announced inspection of emergency preparedness
activities including: Emergency Plans and Implementing Procedures; Emergency
Facilities, Equipment, lastrumentation and Supplies; Organization and Management
Control; Independent Reviews / Audits; application of NRC Inspection and Enforce-
ment Division Information Notices Nos. 83-28 and 84-80; Emergency Operation
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Procedures - Emergency rian Implementing Procedure interfa.e; software for
backup dose projections program; Plant Engineer Training; Emergency Preparedness
Training; operation of the Parsippany Technical Functions Center; and Security-
Emergency Preparedness Interface.
Results: One violation was identified, (failure to evaluate for adequacy the
State interface) two outstanding, non exercise-related inspector follow-up
items vere closed, and five were opened.
8805090299 880503
ADOCK 05000219
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OETAILS
1.0 Persons Contacted
- J. Barton, Deputy Director - Oyster Creek
G. Bond, Director, Systems Engineering, Technical Functions
Division, GPUNC - Parsippany
- J. Bontempo, Lead Emergency Planner, GPUNC - Oyster Creek
P. Clark, President, GPUNC
R. Coe, Director, Training and Education - GPUNC
G. Cropper, Senior Reactor Operator - Oyster Creek
E. Demonch, Group Shift Supervisor - Oyster Creek
- B. DeMerchant, Licensing Engineer, GPUNC - Oyster Cree't
- M. Douches, Lead Monitor Operations, Quality Assurance
R. Ewart, Security Lieutenant, GPUNC - Oyster Creek
- P. Fiedler, Vice President and Director, Oyster Creek
S. Kempf, Jr., Emergency Of fsite Planner, GPUNC - Oyster Creek
J. Kowalski, Site Licensing Manager, GPUNC - Oyster Creek
H. Lapp, Manager, Plant Training, Training and Education
Division, GPUNC - Oyster Creek
A. Lindherg, Manager, Southern District, JCP&L Co.
"D. Mat.arlane, Manager, Site Audits, GPUNC - Oyster Creek
S. Parsons, Manager, Corporate Training - Parsippany
S. Polon, Manager, Public Information, GPUNC - Oyster Creek
A. Rone, Director, Plant Engineering, Oyster Creek
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M. Roche, Vice President and Director, Quality and Radiation
Controls - GPUNC
J. Rogers, Licensing, GPUNC - Oyster Creek
C. Ruth, Operations, Quality Assurance
J. Sevelle, Security Sergeant, GPUNC - Oyster Creek
"J. Sullivan, Director, Plant Operations, Oyster Creek
- R. Sullivan, Emergency Preparedness Manager, GPUNC - Oyster Creek
S. Surgeoner, Manager, Public Relations, GPUNC - Oyster Creek
- M. Slobodien, Director, Radiological Controls, GPUNC - Oyster Creek
- P. Thompson, QA Audits, GPUNC - Oyster Creek
- I. Wazzan, Emergency Planner, GPUNC - Oyster Creek
- J. Williams, Manager, Support Program Training, Plant Training,
Training and Education Department, GPUNC - Oyster Creek
T. Wilson, Vice President and Director, Technical Functions -
Parsippany
- K
Wolf, Manager, Radiological Engineering, GPUNC - Oyster Creek
The inspectors also observed the actions of, and interviewed, other
licensee personnel.
- Denotes those present at the exit interview.
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2.0 Operational Status of the Emergency Preparedness Program
2.1 C0rporate Emergency Plan
The GPU Nuclear Corporation Plan for Three Mile Island and Oyster
Creek Nuclear Station has been revised (Revision 1) and submitted to
the NRC.
The equipment lists in those sections of Revision 1
relating to Emergency Response Facilities and Equipment at Oyster
Creek were checked against facilities, equipment, communications
systems and monitors.
The facilities, equipment, communications and
monitors were determined by the inspector to be in agreement with the
description.
Comments on the Revision are being provided separately.
2.2 Emergency Plan Implementing Procedures (EPIP)
a.
EPIPs at Emergency Response Facilities (ERFs) were verified to
be current and appropriately reviewed. A review of the EPIPs
indicates changes made since the last inspection have not
affected the overall state of emergency preparedness.
were distributed and reviewed in accordance with GPU procedures.
Based on this review, this area is acceptable.
2.3 Emergency Facilities, Equipment, Instrumentation and Supplies
EP!Ps, equipment, instruments, communications equipment and supplies
stored or maintained in the Emergency Command Center, Technical
Support Center, Operations Support Center, Emergency Operations
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Facility, Environmental Assessment Command Center and the off-site
monitoring team assembly area were reviewed.
Equipment and supplies
matched inventory lists, EPIPs were current, and with one exception,
which was promptly corrected, instruments were within their
calibration period and operable.
Based upon the above review, this area is acceptable.
2.3 Organization and Management Control
a.
GPU Nuclear Corporation (GPUNC) is one of the five subsidiaries
of the GPU System. GPUNC is the Oyster Creek operator,
The
site organizational structure is divided between line
(operations) and staf f (support). Operations reports to the
Vice President and Director - Oyster Creek, while support units
report to GPUNC headquarters in Parsippany, NJ.
Of the sixteen
units identified at Oyster Creek by the inspectors, seven are
operations related reporting to the Vice-Pr.esident Oyster Creek,
while nine report to headquarters.
Seven of the nine support
units are involved in site Emergency Preparedness, as are a
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large percentage of the Initial and Support Response Organiza-
tion staffs.
Included in this group are:
the Emergency Pre-
paredness Program; Training and Education; Radiation Controls;
Communication (including Public Information); Security; Site
Audits; and Environmental Controls. A review of the current-
call-out roster inc:icated that five of the six qualified
Emergency Directors and Emergency Support Directors report to
Operations.
b.
Effective June 1, 1987, Emergency Preparedness was transferred
from the Nuclear Assurance Division of GPUNC to the Quality and
Radiation Control Olvision (Q&RC), headed by the Vice President
and Director for Q&RC.
However, the Corporate Manager for
Emergency Preparedness no longer reports directly to the Vice
President Q&RC, but rather to the Director, Emergency Prepared-
ness and Environment, Q&RC. This reorganization eliminates
direct contact by the Corporate Emergency Preparedness Marager
with a Corporate Officer and alters the status of the site
Emergency Preparedness manager to that of fifth level manager.
Consultants responsible for off-site planning have been replaced
by an experienced emergency responder with an active history in
Ocean County. An Emergency Preparedness Program vacancy has
been filled by a nuclear engineer,
c.
The inspectors interviewed the President of GPUNC and two Vice
Presidents. The President estimated from five to ten percent
of his time is devoted to Emergency Preparedness. He maintains
qualification as an Emergency Support Director.
The GPUNC
President displayed a strong working knowledge of Emergency
Preparedness issues, required action (s) and additionally, tracks
corrective actions. He also maintains an on-going high level
interface with Commonwealth of Pennsylvania and State of New
Jersey officials. The Vice President and Director Quality
Radiation Control tracks Emergency Preparedness on a daily basis
and conducts monthly reviews.
He showed extensive current
knowledge of Emergency Preparedness operations and problems.
The inspectccs concluded that corporate restructuring has not
adversely affected the status of emergency preparedness
readiness.
Corporate officers are active in Emergency
Preparedness, are aware of and track problems and issues.
Based upon the above review, this item is acceptable.
2.4 Training
a.
Emergency Preparedness training is provided, in selected areas oy
the Training and Education Department (TED).
TED staff numbers
about 100 GPU system-wide with 49 assigned to Oyster Creek. Two
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hundred and eighty (280) Oyster Creek site personnel are cur-
rently qualified for one or more of the 58 Emergency Response
Organization (ERO) staff positions. This figure includes:
members of the On-Shift Initial Response Organizations (IR0s)
who staff on-site Emergency P.esponse Facilities; and members of
the Emergency Support Organization (who staff the Emergency
Operations Facility and the Parsippany Technical Functions
Center). The Corporate Manager for Emergency Preparedness
trains and requalifies Corporate officers. Plant Training has
completed a job task analysis for ERO positions and maintains
a hard copy and computerized database of craining records.
The
database is currently undergoing modification which involves a
transition between two systems and GPU's Reading, Pennsylvania
computer staff. As a result, the inspectors noted inconsisten-
cies and encountered difficulty in tracking requalifications.
A check of hard copy records verified the accuracy of training
data.
Plant Training may acquire the training record tracking
software of another licensee.
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b.
Technical staff and management training is provided in ten weeks
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of training over a two year period on a modular basis. The
course titles and sequences were checked by the inspectors and
discussed with the TED staff. This sequence does not include
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training for engineers assigned to the Technical Support Center
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(TSC) and Parsipanny Technical Functions Center (PTFC) in severe
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accident analysis,.
The Plant Engineering Department provides
four hours of training in Core Damage Assessment (CDA). Various
GPU staff members, when questioned by the inspectors about the
adequacy of training in this area, responded that the engineer's
academic training is adequate and the Emergency Operations
Procedures (EOPs) will take an operator from an entry event to
core melt.
TSC engineers are trained in TSC operations.
Core
engineers in the TSC receive the CDA training.
c.
The GPU Corporate Emergency Plan (1000-PLN-1300.01, Rev 00)
states in Section 8.1.2 that one of the purposes of drills is
verification of the emergency preparedness of all personnel.
Oyster Creek Administrative Procedure 9473-ACM-1300.01, Rev 5,
Section 5.3.5 states that drill attendance should be recorded.
After the inspectors noted the fact drill attendance was not
recorded, the licensee's staff agreed to record such attendance
in t5e future.
In addition, the inspectors noted one senior ERO
manager had not been drilled in a year.
The licensee agreed to
schedule this individual for drill (s),
d.
The Plant Training staff assists in drill and exercise scenario
development, observes drills and exercises and participates in
debriefings.
e.
A check of EP training written requests and follow-up verbal
requests for rescheduling indicated a large number of repeated
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requests, rescheduling and EP training sessions. Attitude,
quality of training, perception of the importance of EP Training
and priorities were discussed as possible causes. A definitive
cause was not identified.
f.
Senior operators receive Emergency Director training. When on
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the simulator and responding to an incident scenario, operators
are evaluated as to their ability to go from the Emergency
Operations Procedures to event classification, emergency notifi-
cations and call-in of the Initial Response Organization.
The inspectors determined that adequate resources have been committed
to Emergency Preparedness training.
Lessons plans are current. Hard
copy training records are adequate, but the computerized data base is
not yet fully functional.
Training of engineers assigned to the TSC
is limited to COA, an unidentified cause persists resulting in
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repeated training requests, drill attendance records are not
maintained for key staff members, reactor operators are trained in
event classification and emergency communications, and 280 staff
members are qualified in Emergency Preparedness.
With the exception of improvemants to the computerized training
record system, repeated EP training scheduling, limited TSC engineer
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training, and drill attendance records the inspectors concluded an
adequate training program is in place.
The exceptions are inspector
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follow-up items (50-219/88-06-01) subject to future inspections.
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2.5 Independent Reviews / Audits
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The inspector interviewed licensee personnel and reviewed Quality
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Assurance (QA) audit S-0C-87-01 and determined that the internal
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review / audit of the emergency preparedness program had been d;qe
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within 12 calendar months.
It was ascer*sined that management does
review and support QA determinations ano that commitments are made
and corrective actions are timely and technically adequate. With
regard to QA audit scope and depth, it was determined that audit
report S-0C-87-01 did address the offsite interface. However, only
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the local government inter' ace was addressed and the State interface
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was not evaluated.
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10 CFR 50.54(t) requires licensees to review their emergency
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preparedness plan at least once every 12 months.
This review shall
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include an evalcation for adequacy of interfaces with State and Local
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governments. Contrary to this equirement, an evaluation for
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adequacy of the State interfacs was not audited.
This is a violation
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(50-219/88-06-02).
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Exercise / drill reports and audit records were reviewed; emergency
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preparedness personnel were interviewed and it was determined that
the licensee has an adequate corrective action system for
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deficiencies and weaknesses identified during drills and exercises.
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Interviews with corporate management indicates that management does
review and support, as well as follow through on r9 solution and
correction of deficiencies and weaknesses in a timely manner.
Based on these observations, the inspectors concluded that with the
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exception of the State interface adequacy evaluation, the
requirements o' 10 CFR 50.54(t) were met,
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2.6 Security / Emergency preparedness Interface
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The inspector interviewed both Security and Operations licensee
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personnel and reviewed procedures to determine if a
security / emergency preparedness interface is present. NUREG/CR-4093,
"Safety / Safeguards Interactions During Safety-Related Emergencies at
Nuclear Power Reactor Facilities," was used as a basis for this
portion of the inspection.
It was determined that a triggering
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mechanism to alert both operators and security personnel to sabotage
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is in place. Guidelines are present for the security of other safety
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systans, and procedures specifying counter measures to consider have
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been developed.
It was noted that radiological protection equipment is not available
to security forces at the main gate.
The licensee stated that should
a radiological emergency occur and affect that area, these guards
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would be evacuated.
Security forces sent to assist in the evacuation
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of on-site personnel also would not have radiological equipment if a
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radiological emergency were to occur at their post.
Another area of
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concern is there appears to be no rapid way for these guards to put
on protective clothing should their search pattern require them to
enter into a radiation area.
Finally, the Main and North gates are
not shielded or provided with filter ventilation for protection
against radiation.
The Central and Secondary Alarm Center are located
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within the Main Gate building.
In the event of an evacuation of this
facility, an alternate access point is needed.
There is no provision
for such an alternate.
The licensee is reviewing this area for possible improvements.
This will be reviewed during a future inspection.
(50-219/88-06-03)
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2.7 Public Information Program
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The inspector reviewed "Emergency Information for Neighbors of the
Oyster Creek Nuclear Generation Station and for Visitors in Ocean
County" dated April, 1987, and determined that this brochure was in
the process of being updated and distributed to the public.
It was
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further determined, through interviews, that the material had been
coordinated with and concurred in by offsite authorities.
Additionally, FEMA had acknowledged receipt of the brochure from the
State of New Jersey.
It was verified that the local telephnne
directory and the brochure contain the requisite information required
in 10 CFR 50.47(b)(7), Appendix E, Part IV.0.2 and NUREG 0654,
Planning Standard G.
Signs which provide emergency information for
transients are posted along routes which they would use.
A phone
number is provided in both the brochure and phone directory for the
public to acquire additional information.
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In addition to providing an information brochure to the public, the
licensee has provided, quarterly, a news letter entitled "0yster
Creek Neighborhood Update" to the public which provides a reinforce-
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ment of previously provided emergency preparedness information to
include Offsite emergency preparedness.
It also provides additional
information on plant status as well as human interest stories.
Based upon the above review, this area is acceptable,
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2.9 Emergency Operating Procedures (EOPs)
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The E0Ps were upgraded and became effective January 1988.
They are
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in flow chart format. One set will be laminated and kept in the
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control room.
There are four, color coded sets covering the reactor
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vessel; primary containment; secondary containment (the reactor
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bu11 ding); and release to the en"ironment.
The E0Ps contain
"prompts" referring operators to the appropriate emergency
classification in Exhibit 1 to EPIP 9430-!MP-1300.01, Rev. 4,
"Classification of Emergency Conditions." Reactor operators were
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trained and knowledgeable in E0P-Emergency Plan Implen.enting
Procedure interface.
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Based on the above, this area is acceptable.
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2.10 Dosimetry
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a.
The inspectors reviewed the Oyster Creek Emergency Dose Manual
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(9300-ADM-4010.3, Rev. 0) and discussed calculation of projected
doses and dose commitments with Radiation Control staff.
Cal-
culations are made using one of three computer systems: MIDAS;
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the Radiological Assessment Computer Program (called RAC) and
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the Back-up Dosimetry Program (DVD).
The last two programs are
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run on personal computers and may be used in any Emergency
Response Facility as long as input data is available. A MIDAS
intelligent terminal is available only in the Emergency Opera-
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tions Facility when the Environmental Accident Assessment Center
is functional.
Projected thyroid dose commitment calculations
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requires measured iodine release rates or, in absence of these,
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a partition of a gross release rate into noble gas and iodine
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components using measured or default iodine to noble gas ratios.
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At Oyster Creek the stack release is measured and reported as a
count rate which is converted to a gross activity release rate
using a calibration factor. Until a sample of the release can
be obtained and analyzed, a conservative iodine to noble gas
ratio would be used following procedures in the Emergency Dose
Manual resulting in over-estimates of projected thyroid dose
commitment.
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b.
The actual iodine to noble gas ratio can be obtained from
analysis of silver zeolite cartridge located in a sampling point
for the stack.
This point is within a room at the stacks base
and the collection point is a component of the Radioactive Gas
Ef fluent Monitoring System (RAGEMS),
Under severe accident
conditions the dose rate in the RAGEMS room might preclude entry
or restrict access time to a value which might preclude
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successful sample collection assuming the Emergency Director
would authorize an informed volunteer to collect the sample by
approving an emergency worker dose limit. GpU recognizes these
problems and has completed a time and motion study with respect
to collection of a RAGEMS sample, posting administrative limits
for the RAGEMS room and providing RADCON support for the
Chemistry Technician collecting the sample,
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c.
The NRC has addressed the problem of over-estimating calculated
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doses in IE Information Notice 85-52, noting that such values
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could lead to confusion, delay protective action or lead to
unnecessary protective action.
The licensee's Radiation Control
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staff acknowledged the problem and that stated steps would be
taken to correct the default rates to a realistic value, but no
timetable was given for completing the corrective action.
This will be reviewed during a future inspection.
(50-219/88-06-04)
2.11 Field Sampling
The volume collected for iodine analysis by on and off-site monitor-
ing teams was reviewed by the inspectors with the staff of
Environmental Controls.
It was agreed, that a volume of one cubic
foot was sufficient if the sample were to be analyzed by a Ge-Li or
Na! detector.
However, such agreement could not be reached for
off-site sampling when a field analysis using a Distenfeld Collector
and a G-M tube. The licensee agreed to review this matter and
compute the minimum sample volume needed for a specified statistical
performance specification.
The licensee acknowledged collection of
an excessive sample was not consistent with dose minimization practices
and reduces the time available for field teams to undertake additional
field measurements.
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This item will be subject to future inspection.
(50-219/88-06-05)
3.0 Exit Meeting
The inspectors met with licensee personnel listed in Section 1 at the
conclusion of the inspection. The licensee was informed that one viola-
tion was identified.
The inspectors also discussed areas for improvement.
The licensee acknowledged these finding and agreed to evaluate them,
institute corrective action as necessary and include needed corrections
in the Consolidated Plan and Implementing Procedures. At no time during
the course of the inspection did the inspectors give the licensee written
material.