ML20236M936
| 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
Vice President and Di ector
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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:
Michele G. Evans, Chief
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Projects Branch 7
Division of Reactor Projects
Docket No.: 50-219
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 900708
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ADOCK 05000219 .,'
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Mr. Michael B. Roche
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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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GPU Nuclear, Inc.
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U.S. Route d South
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
Vice President and Director
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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:
The booklet pages were reduced from 30 to 10 material and equipment release
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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
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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
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implemented, and the expectations and standards for future performance with their
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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
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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
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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
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vegetation sampling at the two locations with the highest D/Q and the identification of all gardens
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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
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Creek Station will not add any value to the Radiological Environmental Monitoring Program
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(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 radioactivity in the
highest potential exposure pathways" (Technical Specification 6.8.4.b.).
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The Radiological Environmental Technical Specifications, which were subsequently incorporated
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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"
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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