ML20236M936

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/97-11 on 980310

ML20236M936
Person / Time
Site:	Oyster Creek
Issue date:	07/08/1998
From:	Marilyn Evans NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Roche M GENERAL PUBLIC UTILITIES CORP.
References
50-219-97-11, NUDOCS 9807140333
Download: ML20236M936 (2)

See also: IR 05000219/1997011

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July 8,1998

Mr. Michael B. Roche

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Vice President and Di ector '

GPU Nuclear, Inc. )

Oyster Creek Nuclear Generating Station

P.O. Box 388

Forked River, New Jersey 08731

SUBJECT: INTEGRATED INSPECTION 50-219/97-11

Dear Mr. Roche:

This letter refers to your April 10,1998 correspondence, in response to our

March 10,1998 letter.

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

letter regarding violations VIO 50-219/97-11-03 and VIO 50-219/97-11-04. With respect

'to the changes to the Offsite Dose Calculation Manual, we will review and assess your

technical justification regarding conformance with the Branch Technical Position, "An

Acceptable Radiological Environmental Monitoring Program", Revision 1, November 1979,

during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Original Signed By:  !

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Michele G. Evans, Chief

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Projects Branch 7

Division of Reactor Projects

Docket No.: 50-219 I

cc w/o cv of Licensee Resoonse Letter:

M. Laggart, Manager, Licensing and Vendor Audits

G. Busch, Manager, Nuclear Safety and Licensing

cc w/cv of Licensee Response Letter:

State of New Jersey

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9807140333

ADOCK90070805000219 .,'!

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Mr. Michael B. Roche 2

Distribution w/cv of Licensee Resoonse Letter:

Region I Docket Room (with concurrences)

Nuclear Safety Information Center (NSIC)

PUBLIC

NRC Resident inspector

H. Miller, RA/W. Axelson, DRA

M. Evans, DRP

N. Perry, DRP

D. Haverkamp, DRP

C. O'Daniell, DRP

J. Yerokun, DRS

B. McCabe, OEDO

C. Thomas, PD1-3, NRR

R. Eaton, PD1-3, NRR

T. Colburn, PDI-3, NRR

R. Correia, NRR

F. Talbot, NRR

DOCDESK

Inspection Program Branch, NRR (IPAS)

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! DOCUMENT NAME: G:\ BRANCH 7\REPLYLTR\oc9711.rpy

T),eceive a copy of this docum..t, Indicate in the box: "C" = Copy without attachment / enclosure "E" - Copy rnth attachment / enclosure "N* = No copy

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OFFICIAL RECORD COPY

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l GPU Nuclear, Inc. .

( U.S. Route d South l

NUCLEAR Post Office Box 388

Forked River, NJ 087310388

Tel 609-971-4000

April 10,1998

1940-98-20194

U. S. Nuclear Regulatory Conunission

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

identified in the subject inspection report.

Ifyou should have any questions, or require further information, please contact Brenda

DeMerchant, Oyster Creek Regulatory Affairs Engineer, at 609-971-4642.

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Very truly yours,

Michael B. Roche

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Vice President and Director

Oyster Creek

MBR/BDE/gl

Attachment

cc: Administrator, Region I

NRC Project Manager

NRC Sr. Resident Inspector

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ATTACHMENT 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 survcys. 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 relcase surveys of

material and equipment exiting radiologically controlled areas. Since no significant

documentation findings 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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Corrective Actions That Have Been Taken to Avoid Further Violations

The books were immediately removed from the field upon identification of the records

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

changes have been implemented as corrective actions to ensure further violations are avoided:

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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.

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Information was added to the booklet cover identifying the release surveys as

permanent radiological records which are required to be maintained in good

condition.

Specific expectations concerning the daily review of release survey booklets were

issued to the supervisors which includes a thorough review of the paperwork, a

verification that all pages are present, entries are complete, and that they be

maintained in a r. eat and professional manner. Changes were made to the

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 Steos 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 Comoliance

Full compliance was achieved c._ _ng the week of January 12,1998.

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Violation 2.

Technical Specification 6.8.4.b.2 states, in pan, 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 l

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.'

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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 determme the l

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:

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GPUN concurs with the violation as stated.

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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 Broadleafvegetation sampling may

be performed near the site boundary in the 2 sectors with the highest D/Q (Deposition Factor) in

lieu of the garden census." Footnote? appears after the phrase, "within a distance of 8 kilometers

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(5 miles)." Because of the placement ofFootnote it could be interpreted that both broadleaf J

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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 3

Creek Station will not add any value to the Radiological Environmental Monitoring Program l

(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

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underestimated and that the REMP provides " representative measurements of radioactivity in the

highest potential exposure pathways" (Technical Specification 6.8.4.b.).

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l 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

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 radionuclides

concentrations attributable to effluents 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" i

Corrective Stens 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

the method ofimplementation.

Corrective Steps That Will Be Taken To Avoid Further Violations

Section 4.5 " RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM" of the

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

The above described corrective actions will be completed by the end of the second quarter 1998.

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