ML20212N412

Responds to NRC Re Violations Noted in Insp Rept 50-219/86-41.Corrective Actions:Individual Involved Disqualified,Counseled & Officially Requalified as Senior Radiological Controls Technician Through Addl Training

ML20212N412
Person / Time
Site:	Oyster Creek
Issue date:	03/02/1987
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8703130012
Download: ML20212N412 (4)

Text

o. .

GPU Nuclear Corporation NUCIMf Post Office Box 388 Route 9 South -

Forked River,New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

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

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 )

P . FiedTer Vice President and Director Oyster Creek PBF/8D/ 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 G703130012 870302 i DR ADOCK 05000219 PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation SC- O\ rlI

i .

~

ATTACHMENT A Yiolation

.,A "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 70.101(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 to 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 limit 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 oualification.

Th'e individual involved was disqualified, counseled and officially requalified as a senior RCT through additional training and testing prior to assuming his former duties.

a r c.

. ; . r

' 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 Commission 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. Also, 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 i

RCT of dose rates on the top of tne 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 i 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]

j 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 l quickly. Thus, the RCT was adequately forewarned of the need to proceed i

i

T'.'

cautiously even at the expected levels. The GPUN training program 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.

i m _ . _ _ _ . -m._ _ . . , . . _ , , - ,, . - - _ - . - - - . _ _ - , , _ .- . . - ~ , - _ . . . , - , . , -, . . . _ . _ , ~ , _ _ _ _ . - - _ . . , _ - _ . - - . . . _ . _ . _ - , _ . . , _ ,

-