ML20216G903
| ML20216G903 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/10/1998 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1940-98-20194, 50-219-97-11, NUDOCS 9804200522 | |
| Download: ML20216G903 (2) | |
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j GPU Nuctaar, Inc.
g U.S. Route #9 South NUCLEAR Post Ofhce Box 388 Forked River, NJ 087310388 i
Tel 609-9714000 April 10,1998 1940-98-20194
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U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IR 97-011 Reply to Notice of Violations In accordance with 10CFR 2.201, the enclosed provides GPU Nuclear's response to the violations j
identified in the subject inspection report.
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If you should have any questions, or require further information, please contact Brenda DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.
l Very truly yours, I
NV Il Michael B. Roche Vice President and Director Oyster Creek MBR/BDE/gl
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Attachment cc:
Administrator, Region I NRC Project Manager NRC Sr. Resident Inspector 9804200522 980410 PDR ADOCK 05000219 O
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A'ITACHMENT I Violation 1 Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained that meet or exceed the requirements of NRC Regulatory Guide 1.33. NRC Regulatory Guide 1.33, Appendix A (7.e.2) recommends radiation protection procedures for radiological surveys. Procedure 6630-ADM-4200.11, RadiologicalSurveys, requires that materials being released from the radiologically controlled areas be surveyed, and the results documented on Attachment 10.2, RadiologicalRelease Survey ofMaterialandEquipment Exiting the Radiological Controlled Area (RCA).
Contrary to the above, records of materials released from the RCA at Gate 20 (Yard Trailer Area) were found to have missing pages in all three of the log books for Attachment 10.2 of procedure 6630-ADM-4200.11, and had several pages lacking the required supervisory review for the period November 1,1996, through January 10,1998.
This is a Severity Level IV violation (Supplement IV).
GPUN Response GPUN concurs with the violation as noted.
Reason for Violation The violation occurred when an attachment for a procedure titled " Radiological surveys" was not being fully maintained consistent with our standards and expectations.
A prior self assessment of the equipment and material release survey process noted that the individual loose survey procedure attachment forms in use at RCA exit points could be better controlled if bound into a single book. Bound booklets containing 30 material and equipment release survey forms were created and placed at the RCA exit points. Guidelines were also included in the booklets which describe some key expectations for performing release surveys of material and equipment exiting radiologically controlled areas. Since no significant documentation fmdings were identified during the self assessment, no specific guidance was added regarding the maintenance and review of the records. Subsequent to this process change, no follow-up assessment had been done to evaluate the effectiveness of the changes and identify any potential new challenges which may have been created. Contributing causes identified include the fact that utilizing thirty forms per book results in the booklets remaining in the field for extended periods, supervisors' reviews focused only on current documentation, and lack of direction regarding management's expectations for recordkeeping.
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j Corrective Actions That Have Been Taken to Avoid Further Violations l
The books were immediately removed from the field upon identification of the records i
discrepancies. The release survey forms at all other exit points were also checked to ensure immediate compliance was achieved. Full compliance was promptly achieved during the NRC inspection activities. Since that time, a review of the process was performed and the following i
changes have been implemented as corrective actions to ensure further violations are avoided:
The booklet pages were reduced from 30 to 10 material and equipment release survey attachment forms to ensure they do not remain in the field for extended periods of time.
Information was added to the booklet cover identifying the release surveys as permanent radiological records which are required to be maintained in good condition.
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Specific expectations concerning the daily review of release survey booklets were e
issued to the supervisors which includes a thorough review of the paperwork, a i
verification that all pages are present, entries are complete, and that they be l
maintained in a neat and professional manner. Changes were made to the l
supervisors daily checklist to ensure that these actions are accomplished.
Each supervisor has reviewed and discussed the findings, the changes implemented, and the expectations and standards for future performance with their crew personnel.
The Corrective Steps That Will Be Taken to Avoid Further Violations A follow-up self assessment will be performed before the end of 1998 to assess the effectiveness of the corrective actions and identify any further improvements appropriate to the process.
Date of Full Compliance Full compliance was achieved during the week of January 12,1998.
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l Violation 2 l
l Technical Specification 6.8.4.b.2 states, in part, that a program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall include a land use census to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the monitoring program are made if required by the results of this census.
Offsite Dose Calculation Manual 4.5.1.8.1 states, 'A land-use survey shall be conducted annually during the growing season to determine the location of the nearest milk animal and nearest garden greater than 50 square meters (500 square feet) producing broadleaf vegetation in each of the sixteen meteorological sectors within a distance of 8 kilometers (5 miles), and the locations of all milk animals and gardens greater than 50 square meters producing broadleaf vegetation out to a distance of 5 kilometers (3 miles) for each radial sector.'
Contrary to the above, the inspector determined on February 5,1998, that prior to 1997, the licensee had not performed an annual land-use survey during the growing season to determine the location of all gardens greater than 50 square meters producing broadleaf vegetation out to a distance of Skm ( 3 miles) for each radial sector.
This is a Severity Level IV violation (Supplement IV).
Reason For The Violation:
GPUN concurs with the violation as stated.
The violation occurred due to section 4.5.1.8, " Land-Use Survey Specification" of the Offsite Dose Calculation Manual (ODCM) not being clearly written to preclude misinterpretation of GPUN's intentions regarding the garden census. The violation as written inadvertently leaves out a footnote from the ODCM section 4.5.1.8.1, which states,"2 Broadleaf vegetation sampling may be performed near the site boundary in the 2 sectors with the highest D/Q (Deposition Factor) in 2
lieu of the garden census." Footnote appears after the phrase, "within a distance of 8 kilometers 2
(5 miles)." Because of the placement of Footnote it could be interpreted that both broadleaf q
vegetation sampling at the two locations with the highest D/Q and the identification of all gardens greater than 50 square meters out to a distance of 3 miles are required. GPUN has never intended to require both and believes that our broadleaf vegetation sampling program alone meets the specific intent of the garden census requirement. A census of gardens within 3 miles of the Oyster Creek Station will not add any value to the Radiological Environmental Monitoring Program (REMP) in terms of ensuring the protection of public health or the environment.
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The, purpose of the garden census portion of the Land-Use Census is to identify gardens that may be present at locations that yield calculated doses greater than those previously sampled. Such locations may then be added to the REMP and included in dose assessment, in order to ensure that calculated doses to the public, attributable to effluents from the Oyster Creek Station, are not underestimated and that the REMP provides " representative measurements of radioectivity in the highest potential exposure pathways" (Technical Specification 6.8.4.b.).
The Radiological Environmental Technical Specifications, which were subsequently incorporated into the ODCM, were developed with the intent of performing broadleaf vegetation sampling at the two locations with the highest D/Q, in lieu of performing any garden census. Those locations were identified using site-specific meteorological data and gardens were established at both locations in 1987. We believe that this approach meets the specific intent of the land-use census requirement and have always interpreted the note in that manner. The calculation of radiation l
. dose to a member of the public from the consumption of broadleaf vegetation harvested from the locations experiencing the maximum D/Q would, by definition, be expected to yield the maximum dose. Vegetation from any other gardens identified in a census will not have higher radionuclide concentrations attributable to efiluents from Oyster Creek, and consumption of vegetation from those locations could not yield a higher radiation dose. Therefore, the presence of any other gardens within 3 miles of the Oyster Creek Station would not require the modification of the REMP in order to ensure that the program provides " representative measurements of radioactivity in the highest potential exposure pathways" Corrective Steos That Have Been Taken And The Results Achieved The basis for GPUN's method ofimplementing the Land-Use Survey Specification has been reviewed and Section 4.5.1.8 of the ODCM is in the process of being re-written to clearly state a
the method ofimplementation.
Corrective Steos That Will Be Taken To Avoid Further Violations Section 4.5 "R.ADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM" of the l
ODCM will be reviewed, and revised as necessary, to ensure that all requirements are clearly stated and that the program as implemented meets those requirements.
The Date When Full Comoliance Will Be Achieved 1
The above described corrective actions will be completed by the end of the second quarter 1998.
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