ML20062A960

Responds to NRC 900720 Ltr Re Violations Noted in Insp Rept 50-219/90-09.Corrective Actions:Issues Identified During Insp Being Incorporated Into Radiological Controls Cyclic Training Program

ML20062A960
Person / Time
Site:	Oyster Creek
Issue date:	08/16/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062A933	List: IR 05000219/1990009 ML20062A960
References
NUDOCS 9010230252
Download: ML20062A960 (3)

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- OPU Nuclear Corporation .

Nuclear

.on:r388: . .

l Forked River, New Jersey 08731-0388 % ,

i 609 971 4000-- 'l Writor's Direct Dial Numberf i

August 16,;1990.

! Mr. Thomas T. Martin '

Regional Administrator ,

U.S. Nuclear Regulatory Commission ,

475 Allendale Road '[

King of Prussia. PA 19406 i

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Dear Mr. Martin Subjects Oyster Creek' Nuclear Generating Station '

Docket No. 50-219 g

-Response to, Notice of Violation' i  ;.

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NRC letter dated July 20, 1990 forwarded Inspection Report 90-09:and a~Noticefof.'

Violations pertaining to radiological' controls:- at Oyster Creek. Attachment I: to this  !

letter provides CPU Nuclear's response to the violations.

.' f If further information is required,.please call Mr.5 Michael Heller, Licensing': M Engineer, at (609)971-4680.

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l- h ivery truly yours, <

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.E.Ei Fitzp ick- +~

jVice President'and,D'irector, t M l Oyster'Creeki ]

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, Attachment J Violation As .)

Technical Specification 6.11 requires that procedures for personnel radiation protection shall be adhered to for all operations involving. personnel radiation exposure.

Procedure 9300-ADM-400G.11, revision 0, Rules for Conduct of Radiological Work, Section 7.2, requires that all personnel.who enter the Radiological Controls Area shall obey Radiation Work Permits.

Contrary to-the above, procedures for personnel radiation protection were.not adhered-to in that, on October 18, 1989, on at least one occasion, a maintenance worker entered an area posted as a High. Radiation Area without a dose rate. meter as specified by Radiation Work Permit No.89-950.

This violation is severity level IV (Supplement IV).

posponse GPUN concurs with the violation. ,

When the NRC brought the allegation to our attention in Merch'1990, an investigation was undertaken immediately. However, it was Very diffictit to establish the facts five months after the incident.

CPUN has concluded that this violation was caused by personnel error on the part of a ,

supervisor, a mechanic, and a radiological controls technician.- Corrective actions ,

taken to prevent recurrence are as follows:

1. Individuals involved were counselled (written and/or-verbal).

2. This incident will be covered in the General' Employee Training (GET)~ program to emphasize the importance of proper entry into high' radiation areas. It will be included in the " industry events" section of the GET program'for a period of six months.

3. A memorandum was issued to all. radiological 1 controls technicians to discuss established policy on reaction to radiological problems'.

There have been no indications of similar violations since October, 1989. CPUN has therefore been in compliance with the above requirements since'that time.

Violation B:

10 CFR 20.201(b) tequires that each licensee make such surveys as (1) may be necessary to comply with all sections of Part 20, andL(2) are: reasonable under .the circumstances to evaluate the extentlof radiation hazards thatimay be present.. 3 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; naterials or other sources of radiation underfa'epecific= set:of conditions. When

. appropriate, such evaluation. includes measurements of levels of radiation or.

concentration of materials present.

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. Contrary to the above, a reasonable survey was not made under the circumstances,3 whens r

1. On April 26,-1990, Instrument'and Control technicians performed' maintenance under.

the reactor vessel on top of the carousel under Radiation Work Permit No. , ,

90-0488. The current radiological survey,- 90-4927, did not include measurements  ;

or evaluation of the' radiological conditions on the carouselc .The technicians performed work on the carousel without adequate evaluation of the radiological- i hazards created by. working in close proximity the the control rod drive mechanisms.

2. On April 25, 1990, a radiological controls technician and station services helper. ,

performed work in close proximity to shutdown cooling valve,-V-17-56, without surveys that made reasonable and adequate evaluation of the radiological hazards created by the accumulation of radioactive material'in this valve. The radiation' levels generated by this valve were subsequently measured as'2.8 rem /hr on contact.and 600 mrem /hr at one foot. The original general ~ area survey showod 3 only a general area dose rate of 150 mrem /hr.-

This violation is severity' level.IV (SupplementRIV).

Resoonset.

GPUN concurs with the violation.

E The cause of the first incident is attributed to inadequate communication.between-the.

instrument and control technicians and the, group radiological controls supervisor.

The cause of the second incident is attributed to<an error on the part.ofsthe radiological controit technician in the. performance of his duties. ' corrective i actions taken to prevent recurrence are as follows:. j

1. The relevant sections of Inspection Report 90-09 are beingoissueo asirequired-j reading as appropriate-for all maintenance and radiological; controls; personnel.

This action will be completed by September 30, 1990. .,

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2. The issues identified and concerns expressed;in:the subject inspection 7 report will bo incorporated into the radiological.controle' cyclic training' program.= The I training on these matters will also be. included in management interfaces >

l: conducted with the radiological controle staff. .These actions =will:be ongoing.

Cyclic training in there matters will' conclude by October 131, 1990. '

L 3. Immediate corrective actions included management discussions with the. -i i radiological controls staff and a ' disciplinary action ~1etter to the1 radiological j l controls supervisor involved., This' action was' designed to: achieve. full i' compliance by July 31, 1990.

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