ML20209E315

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/86-41
ML20209E315
Person / Time
Site: Oyster Creek
Issue date: 04/20/1987
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8704300021
Download: ML20209E315 (2)


See also: IR 05000219/1986041

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Docket No. 50-219

GPU Nuclear Corporation

ATTN: Mr. P. B. Fiedler

Vice President and Director

Oyster Creek Nuclear Generating Station

P. O. Box 388

Forked River, NJ 08731

Gentlemen:

Subject:

Inspection 50-219/86-41

This refers to your letter dated March 2,1987, in response to our letter

dated February 2, 1987.

Thank you for informing us of the corrective and preventive actions documented

in your letter. These actions will be examined during a future inspection of

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your licensed program.

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Your cooperation with us is appreciated.

Sincerely,

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Division of Radiation Safety

and Safeguards

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M. Laggart, BWR Licensing Manager

Licensing Manager, Oyster Creek

Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of New Jersey

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GPU Nuclear Corporation

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Post Office Box 388

Route 9 South

Forked River. New Jersey 08731-0388

609 971-4000

Writer's Direct Dial Number:

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Thomas T. Martin, Director

Division of Radiation Safety and Safeguards

Region I

U.S. Nuclear Regulatory Commission

631 Park Avenue

King of Prussia, PA 19406

Dear Mr. Martin:

Subject: Oyster Creek Nuclear Generating Station

Docket No. 50-219

IE Inspection Report 86-41, Response to Violation

The purpose of this correspondence is to provide you with GPU Nuclear's

responses to the two (2) violations identified in the subject inspection

report dated February 2,1987. These responses are contained in Attachment A

of this letter.

Should you require further information please contact Brenda DeMerchant,

OC Licensing Engineer at (609)971-4642.

Very truly yours,

JYm )

Pw T FiedTer

Vice President and Director

Oyster Creek

PBF/BD/ dam

Attachment

(0293A)

cc:

Dr. Thomas E. Murley, Administrator

Region I

U.S. Nuclear Regulatory Commission

631 Park Avenue

King of Prussia, PA 19406

Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Commission

7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014

Mail Stop No. 314

NRC Resident Inspector

Oyster Creek Nuclear Generating Station

-$3V5?!!!Q:- {\\ GPU Nuclear Corporation is a subsidiary of the General Pubhc Utihties Corporation t

l . ATTACHMENT A ,

Violation "10 CFR 20.201(b) requires, in part, that each licensee make such surveys as may be necessary to comply with all sections of Part 20. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. Contrary to the above, during the preparation of a resin liner and cask for shipment in the New Radwaste Building truck bay, no surveys were made to assure compliance with 10 CFR 20.101(a), which limits radiation dose to individuals in restricted areas. Specifically, on December 8, 1986, no surveys were made at the unshielded part at the top of the resin liner, before work to cap the liner was undertaken. As a result, an unplanned radiation exposure .;o one of the workers in excess of the licensee's administrative limits did occur." Response GPUN concurs with the violation. While an internal GPUN administrative exposure Ifmit was exceeded, no quarterly or yearly regulatory exposure limit was exceeded. The Radiological Controls Department examined the written requirements governing this evolution and the training of the involved Radiological Controls Technician (RCT). We conclude that the existing written requirements were adequate to cause the survey of the cask top to be performed prior to capping. The RCT failed to perform the degree of job coverage expected of his high level of training, experience and qualification. The individual involved was disqualified, counseled and officially requalified as a senior RCT through additional training and testing prior to assuming his former duties. -1 - L

_ ' l ' Violation , "10 CFR 19.12 requires, in part, that all individuals working in or frequenting any portion of a restricted area be kept informed of the storage, transfer, or use of radioactive materials or of radiation in such portions of the restricted area; in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; and be instructed in, and instructed to observe, to the extent'within the worker's control, the applicable provisions of Comission regulations and licenses for the protection of personnel from exposure to radiation or radioactive materials occurring in such area. Contrary to the above, on December 8,1986, one Radiological Controls Technician and two Radwaste Technicians did perfonn work on a highly radioactive resin liner (85 R/hr contact) in the New Radwaste Building truck bay without adequate instructions concerning the radiological hazards associated with the job and the proper hold points and precautions for conducting radiological surveys." The report also stated: "In the case of the cask incident, the technician assigned to the job, although experienced as a radiological controls technician, was unfamiliar with the liner / cask job he was assigned to cover. Furthermore, he was not instructed on job-specific considerations for appropriate hold points for surveys. The ALARA review attached to the RWP did not discuss these considerations, but referred the reader to instructions on the RWP and the Group Radiological Controls Supervisor (GRCS). The procedures did not specify any hold points. Al so, the' Radwaste technicians are not instructed to wait until a survey was conducted before approaching the unshielded opening on top of the cask. These failures to instruct the Radiological Controls and Radwaste Technicians constitute an apparent violation of the requirements of 10 CFR Part 19 (50-219/86-41-02)." Response We agree that the Radwaste Technicians were not adequately warned by the RCT of dose rates on the top of the cask prior to capping. The cause and corrective actions are the same as in the first violation. We do 'not agree that the RCT was provided inadequate information of the expected high dose rates, their location and when they would occur. The ALARA review stated "The dose rates from resin transfer loading and shipment can be expected to be as high as 10R/hr in unshielded areas. Areas of concern are ... the unshielded areas on top of the shielded ' shipping cask surrounding the HIC [high integrity container] liner". The Radwaste Supervisor warned the RCT of radiation levels [20-25 R/hr] after the fill head was removed on the morning of the exposure in excess of administrative limits. While the stated expected radiation levels were lower than the actual levels, they were of such a nature to cause high exposures very quickly. Thus, the RCT was adequately forewarned of the need to proceed -2- L

- - _ . . . . . . , 9 cauticusly svan at th2 expIcted 1svals. Th2 GPUN training pr gras ' , provides training on responses to unusual situtions such as the one cited in the Report. As an additional action, the applicable ALARA Review was changed to better define the required surveys for this evolution. This occurrence will'be used as a case study in the ongoing RCT training

program. Full compliance has been achieved. l t -3- .- _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ }}