IR 05000289/1975020
| ML19256D572 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/09/1975 |
| From: | Nelson P, Shepherd R, Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D570 | List: |
| References | |
| 50-289-75-20, NUDOCS 7910190540 | |
| Download: ML19256D572 (22) | |
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U. S. NUCLEAR 'REGUIATORY C010iISSION
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OFFICE OF INSPECTION AND ENFORCDiENT
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RIX; ION I
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IE INVESTIGATION REPORT NO.
50-289/75-20 Docket No:
50-289 Licensee:
Metropolitan Edison Con:pany
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License No:
DPR-50 Three Mile Island Unit 1 Priority:
N/A
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Category:
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Location:
Middletown, Pennsylvania
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I Eype of Licensee:
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f f Investigation:
Allegations, Unannounced
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Jats of Investigation:
August 5.and 6, 1975
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leporting Investigator:
(d<.f h < 4 7 m
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d H. Smith, Investigation Specialist
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/I tecompanying Investigators:
Raymend Sh'epherd, Physical Security DATE
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Inspector
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/Ni alas Panzar[no, Radiation Specialist /'
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)ther Accompa:.f ng Personnel:
None i
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DATE
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leviewed By:
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Ya'ul R. Nelson, Chief, Radiological and DATE
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Environmental Protection Branch
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1 SHO 7910'90
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SUMMARY OF FINDINGS
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A.
Allegations Made During a Meeting at NRC, Region I On August 5,1975, the complainant met with Region I representa-
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tives and provided Information regarding the radiological working conditions existing at the Three Mile Island Nuclear Station, Unit I.
According to the complainant, the work involved grinding and buffing on the spent fuel racks located in the Fuel Handling Build-ing.
The complainant also stated that the week'was being performed by the Crouse C mpany, Incorporated.
The complain nt also discussed what he felt was laxity of the plant security prcgram.
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The complainant requested no.t to be identified by the NRC and
refused to providt a residential address or telephone number.
The complainant did agree to contact the Region I office by telephone on August 7, 1975.
Based on a review of the complainant's allegations described during the meeting an unannounced investigation was initiated immediately.
B.
Allegations and Investigation Findings
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The NRC,' Region I representatives interpreted a total of nine
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alleb'tions frar the complainant's discussion.
The nine allega-tions and NRC findings on each are as follows:
1.
Allegation No '1
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It was alleged that the hand and foot counters at the work
locction and at the exit to the control area were not always working.
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The NRC investigation finds that during the period from July
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14 to August 6, 1975, the hand and foot monitor located at the exit to the-controlled area was out of service on August 2, 3 and the morning of August 4, 1975.
In addition to the portal monitor an operable portable survey instnument with pancake probe and alarm vas placed at the counter that was out
of service.
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Allegation No. 2
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It was alleged that there is inadequate control of personal r
monitoring devices in that the complainant's film badge and
=7 pocket dosimeter had been moved from the rack location where
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The NRC investigation finds that the control of personal monitoring devices is commensurate with the radiological health protection problems of the work in progress.
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Allegation No. 3
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It was alleged that during one shift, from 7 to 8 individuals entered the work location without personal monitoring devices.
The NRC investigation finds no information or documentation to substantiate the allegation that individuals entered the se controlled area without personal monitoring devices.
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4.
Allegation No. 4
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It was alleged that the complainant was instructed, for radia-
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tion control purposes, to avoid some 55 gallon drums that were
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The NRC investigation finds that the 55 gallon drums were barricaded with rope and the area posted as a high radiation
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area on August 5, 1975. Individuals were instructed not to
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stand at' the rope where a radiation exposure level of 15
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milliroentgens per hour was measured on August 5,1975.
The iuvestigation also finds that there may be periods of time.
when drums are present in the area and posting is not re-quired.
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Failure to post the radiation area in accordance with 10 CFR 20.203(b) was noted as a deficiency and corrected prior to conclusion of the investigation.
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5.
Allegation No. 5 It was alleged that there were several doors to various rooms in the vicinity of the work location that were not identified, posted or locked to provide radiation control.
The NRC ' investigation finds that the doors and areas con-
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taining radioactive material in the work location vicinity and
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from the controlled area entrance at the 305 foot level to the 348 foot level were either posted as radiation areas and/or locked.
6.
Allegation No. 6
It was alleged that candy and coffee vending machines were located in an area where they shoulo not be, due to the work in progress..
The NRC investigation finds that all coffee and vending machines were located in areas free of radiation and radio-active contamination.
There were vending machines located in the turbine building where a work location was established for
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non-radiation work.
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7.
Allegation No. 7
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It was alleged that tools could be taken from.the work area without being surveyed for contamination and the complainant did remove a grinder from.the work location without it being surveyed for contemination.
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The NRC investigation finds no indication that tools were removed from tb> controlled area without a release survey.' A.
release survey is not required for tools removed from the work location established in the turbine building which is outside of the controlled area.
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8.
Allegation No. 8 It was alleged that the complainant's request regarding ex-posure information was denied.
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The NRC investigation finds that each individual reads and
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records pocket dosimeter results at the beginning and end of each shift and is aware of his accumulated exposure.
These pocket dositeters and film badges are worn although the radia-tion levels at the work site are less than one milliroentgen per hour and individuals appeared to be aware of the radiation level.
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Allegation No. 9 It was alleged that the security program was lax in regard to access control of terminated e=ployees to the site.
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The NRC investigation finds that the physical protection pro-
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gram is adequate for controlling access of terminated individ-uals to the nuclear plant site.
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Conclusions
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There was no information or evidence obtained.during the
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investigation to substantiate any of the eight allegardr.nr
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alluding to the described deficiencies of the radiological protection program nor the one allegation regarding t he security program being lax.
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Within th'e scope of the investigatico, there was one item of
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noncompliance observed that was corrected prior to cenclusion of the investigation.
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DETAILS
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A.
Introduction
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This investigation was initiated as a result of information pro-vided by an individual during a visit to the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region I, on August 5, 1975.
The individual stated that his concerns related to work being perforr.ed at the Three Mile Island Nuclear Power Reactor Site by
the Crouse Company.
According to the individual, the work involved grinding and buffing for modification of the spent fuel racks.
The individual provided information regarding the work being performed and this information c.ontained the eight allegations rela:ed to radiological working conditions and one allegation related to the Am~
security program.
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The individual requested that he not be identified and refused to provide a residential addrees or telephone number.
He did state that he would contact the Region I office by telephone on August 7, i
1975.
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B.
Scope of Investigation
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The investigators met with the Met-Ed Manager of Nuclear Operations
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and his staff for a discussion of the work being performed in the fuel building by the Crouse Company.
During this discussion it
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was determined that the work being performed by Crouse Company
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craftsmen k_gan on July 21, 1975.
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Following this discussion the investigators examin2d security ree-ords, logs and reports; radiological survey reports; exposure records; procedures; training records; and sample analysis.
During
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an examination of th'e work area on both the day and evening shifts,
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individuals involved with the work were contacted.
Individuals having significant information were interviewed.
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C.
Perrons Ditectly Interviewed and/or Contacted During the NRC
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Investigation
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Co=plainant
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(Name withheld by NRC pursuant to 10 CFR Part 9.6)
2.
General Public l'1111 ties Serv.ce Corporation
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R. Rice, Security Coordinator 3.
Metropolitan Edison Ccmpany
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J. Herbein, Manager, Generation Operations-Nuclear G. M111er, Superintendent - Unit 2 W. Poyck, Coordinator of Services J. Stacev, Security Specialist K. Beale, Radiation Protection Supervisor J. O'Hanlon, PORC Chairman G. Wallace, Shife. Supervisor
- s R. Zechman, Administrator Nuclear and Technical Training J. Floyd, Operating Supervisor R. McCann, Health Physics Foreman
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D. Trout, Assistant Engineer, Health Physics
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J.' Thompson, Radiochemistry Technician
i T. Mulleavy, Radiation Protection Foreman
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Crouse Company, Incorporated H. Bailey, Project Superintendent
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L. Carter, Timekeeper K. Frederick, General Foreman
J. Borowick, General Foreman
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J. Murphy, Foreman R. Fuhrmann, Foreman S. Schickley, Foreman Individual craftsmen (Names not obtained)
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5.
Attorneys Investigation Services T. Williams, Guard Supervisor W. Brown, Security Guard D.
Interpretation of Allegations From Complainants Information 1.
Allegation No. 1 a.
Allegation It was alleged that the hand and foot counters at the,
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work location and at the exit to the control area were not always working.
b.
NRC Comments
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A hand and foot monitor was observed at the exit from the fuel handling building.
A test of the instrument showed it to be functioning in accordance with TMI Unit 1 pro-cedure HP1757.
Because of the highar background in the
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area the alarm points were set higher than the hand and foot monitor located at the control point exit.
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ing to Met-Ed representatives this instrument was not
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required to be used by construction personnel but that
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most individuals used it on the way out of the area.
A hand and foot monitor was also located at the exit from
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the control point and all personnel are required to use it.
A test of the instrument showed it to be functioning properly.
According to Met-Ed representative's the in-
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strument was identified as being out of service on Augus,t 2, 3 and the morning of August 4.
This was the only
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period the instrument was out of service from July 14 to August 6, 1975.
According to the Met-Ed representatives, a portable survey instrument with alarm device was pro-vided to replace the hand and foot monitor until it was placed in service on the afternoon of August 4, 1975.
These representatives also stated that as individuals left the controlled area on both shifts they were in-structed in the use of the portable survey instrument.
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Contacts with Crouse Company employees confirmed the
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routine use of the hand and foot monitors and also the
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instrument being out of service with a portable instru-i ment provided.
The investigators observed cevaral in-dividuals using both hand and foot monitors when leaving
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the.vork area.
In addition each individual also passed
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through a portal monitor following use of the hand and l
foot monitor.
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NRC Investigation Findings
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"The NRC investigation finds that during the period from
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July 14 to August 6, 1975, the hand and foot monitor located at the exit to the controlled area was out of
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service on August 2, 3 and the morning of August 4,1975.
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In addition to the portal monitor, an operable portable
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survey instrument with pancake probe and alarm was placed y
at 'the counter that was out of service, i
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Allegation No. 2 p --
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a.
Allegation
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It was alleged that there is inad' equate control of per-
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sonal conitoring devices in that the cc=plainants' film
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badge and pocket dosimeter had been moved from the rack location where they were placed and that -any individual
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could also use another's personal monitoring device.
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b.
NRC Comments
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The investigator determined that film badges and TLD's-are used to mcnitor personnel exposure.
Pocket dosi-
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meters are used to provide an estimate of an individual's
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current exposure.
A badge rack is located at the entrance i
and exit to the control area in which personal dosimetry devices are stored.
Film badges and TLD holders are
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labelled with the name of the person to whom they are issued.
Each individual having dosimeters issued is
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assigned a permanent location for storing them in the rack.
In the case of new hires there may be a period of, two to three days before a rack location number is assigned.
During this period, the individual places the dosimeters in an unnumbered section of the storage rack.
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During the training instruction provided each employee, the individuals' responsibilitity for picking up, wearing
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properly, signing in and out of the controlled area and storing personal dosimeters in the rack is emphasized.
This was cenfirmed by contacts with individuals working inside the controlled area and the investigators observa-
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tions of individuals entering and leaving the controlled
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. area, c.
NRC Investigation Findings The NRC investigation finds that the control of personal u
monitoring devices is commensurate with the radiological health protection problems of the work in progress.
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Allegation No. 3 i
a.
Allegation
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It was alleged that during one shift, from 7 to 8 in-dividuals entered the work location without personal
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monitoring devices.
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NRC' C'omments
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The cognizant licensee representatives stated that no.
cases of individuals not wearing personnel monitoring devices had been reported nor were they aware of such an occurrence.
The investigators observed the records for recording pocket dosimeter results and noted that only one indi-vidual had failed to record a result when leaving the
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controlled area..
The investigators also noted that one of the questions appearing on the training examination test referred to the proper location on the body for wearing the personal monitoring devices.
The investigators observed individuals working on both shifts during the investigation an'd each was noted to be wearing the required monitoring devices.
Contacts with individuals confirmed that instructions ringarding proper wearing of monitoring devices were inc3cded in training instructions and in no case did the inaividuals know of any other individuals not wearing their assigned mon-itoring devices.
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NRC Investigation Findings The NRC investigation finds no information or documenta-tion to substantiate the allegation that individuals entered the controlled area without personal monitoring devices.
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4.
Allegation No. 4 r,
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Allegation (
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It was' alleged that the complainant was instructed for radiation control purposes, to avoid some 55 gallon drums
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that were not identified, posted or barricaded.
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NRC. Comments The investigators observed eight 55 gallon drums being
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stored in an area adjacent to the work location in the-new fuel receiving area.
The storage area was barricaded by a rope with a sign attached designating the scorage area as a high radiation area.
On August 5, 1975, the investigator measured the radiation level at the rope and
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found about one fourth of the barricade to be in excess of 5 milliroentgens per hour with a maximu=' of 15 milli-roentgens per hour.
The occupied work 1ccation also'in
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I the area had.1 radiation level of 0.1 milliroentgens per
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(mR/hr)
The investigators determined that of the eight drums only g.7--
three contained radioactive vaste and each had radiation
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levels of 25 mR/hr.
On August 6, 1975, the investigator
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observed that five drums remained stored in the area and
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that it was not designated as a radiation area.
The
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investigator confirmed that the three waste drums had
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been removed from the area during the first shift on j
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August 6, 1975 and that the radiation levels in the
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area were less than 2 mR/hr.
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i Contacts with craf tsmen working in the area confirmed
that each was aware of t'he meaning of the posted area and had been instructed not to stand next to the rope barri-m cade or, adjacent to any other radiation areas that they might encoin.ter.
None of the craftsmen or foremen had observed the drums not being barricaded or posted prior
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to August 6, 1975.
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Licensee representatives stated that approximately once i
each week the accumulated radioactive waste drums were s
removed from the area and that the area was posted con-
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tinuously as a high radiation area since.a waste drum
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would intermittently be stored inside the area requiring this posting.
They also stated that it was necessary to enlarge the work area for the spent fuel racks beginning August 6, 1975 and that usa of the area for storing radio-active waste drums would be discontinued until the work
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was' completed.
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NRC Investigation Findings n :-
The NRC investigation finds that the 55 gallon drums were
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barricaded with rope and the area posted as a high radia-tion area on August 5, 1975.
Individuals were instructed not to stand at the rope where e radiation exposure level of 15 milliroentgens per hour was ceasured on August 5,
1975.
The investigation also finds that there may be periods of time when drums are present in the area and
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posting is not required.
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j Failure to post.the radiation area in acccrdance with 10 CFR 20.203(b) was noted as a deficiency and corrected
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Allegation No. 5
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Allegation u;nr
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It was alleged that there were several doors to various
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rooms in the vicinity of the work location that were not h=
identified, posted or locked to provide radiation con-
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trol.
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NRC Comments v :-
The investigators observed that the radiochemistry lab-
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oratory, the decontamination room, the machine shop,.and
~ he health physics office were the only rooms that an
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t individual working on the 348' or 305' elevation in the
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fuel handling building would have to pass to go to and from his work on the spent' fuel racks.
The radiochem-istry laboratory and the health physics office were posted as " Caution - Radioact$ ve Material" and "Radia-
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tion Areas" respectively.
The health physics office is
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usually staffed with technicians.
On August 5, 1975,
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the door to the radiochemistry laboratory was open.
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There is no requirement that the door be. locked.
The entrance to the decontaminstion room was locked on August 5, 1975.
According to tha cognizant licensee representa-
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tives the key is maintained by Health Physics and the door is continously locked.
The machine shop door was open on August 5 and 6, 1975, and two clearly designated 1-contaminated areas (step off pads, signs, ropes) were r
noted in this room.
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The investigators also observed areas within walking distances of the job on the 305' elevation of the fuel handling building.
These areas included the precoat
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filter room, the cation demineralizer room '(both posted
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as high radiation areas and locked), the spent fuel pool cooling room, the contaminated tool storage room on the 281' elevation of the auxiliary building, mdkb up filters 2A and 2B, the drum storage area, the decay heat valve area and the make up valve alley and others.
Doors to
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areas posted as high radiation areas were locked.
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areas such as radiation or contamination areas were
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appropriately posted and controlled (e.g., step off pads,
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signs on doors).
To observe the areas and rooms de-scribed above would require the individual to leave the fuel storage rack job-site and walk through the other areas of the auxiliary building.
According to the cognizant licensee and Crouse Company
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representatives each foreman is responsible for the areas occupied by his crew membcrs.
The investigators contacted
. individual craftsmen and each appeared knowledgeable that
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they were to remain in the work locations of the spent fuel racks and to pass by certain doors to and from the work location.
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NRC Investigation Findings The NRC investigation finds that the doors and areas
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vicinity and from the controlled area entrance at the 305
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foot level to the 348 foot level were either posted as radiation areas and/or locked.
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Allegation No. 6 a.
Allegation
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It was alleged that candy and coffee vending machines were located in an area where they should not be, due to the work in progress.
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NRC Comments
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The investigators noted that there were several vending machines located on the site.
The cachines are located in clean areas (i.e., the hallway from the administration building to the turbine building and in the turbine
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building itself).
This facility is a pressurized water
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reactor and the turbine building was not a controlled
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area.
According to the cognizant licensee representa-tives the turbine building has remained a clean area.
.The investigators observed a work location established in
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the turbine building for grinding and buffing portions of the spent fuel racks being modified.
The work involved is free from radiation and radioactive contamination.
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NRC Investigation Findings i
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The NRC investigation finds that all coffee and vanding machines were located in areas free of radiation and radioactive contamination.
There were vending machines located in the turbine building where a work location was established for non-radiation work.
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A1_ legation.No. 7
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a.
Allegation
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It was alleged that tools could be taken from the work
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complainant did remove a grinder frem the work location without it being surveyed for contamination.
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b.
NRC Co=ments
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The investigator examined procedures for controlling the removal of tools from the controlled area.
According to
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the cognizant licensee representatives tools used on the racks and in the pools of the spent fuel building are free from contamination because the work area is clean.
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According to the licensee representatives work in a
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contaminated area would require that the contractor
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employees work under a Radiation Work Permit and that a health physics (EP) qualified individual would be as-
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signed to observe the work.
It is the responsibility of the HP qualified individual to make sure tools a-bagged
and stored in the proper location for a HP technician to
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check and tag the tools after the job.
The licensee representative also stated and the investigator confirmed that surveys taken on the job in the fuel handling build-ing showed no contamination above background and con-
. tractor employees were instructed to have all tools
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checked for contamination prior to removal fr a cne controlled area.
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A smear and fixed contamination survey was made of various tools in the contractor tool shed located outside of the controlled area.
Tools such as grinders and drills which were in use on the job in the spent fuel handling building were examined and all were found to be free of radioactive material.
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The-investigator contacted Crouse Company employees and
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each individual confirmed that the requirement for having all tools or other items taken into a coAtrolled area
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surveyed prior to renoval was included in the training
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instruction when hired.
They also stated that the fore-man routinely e=phasized the requirement during work.
None of the individuals had seen tools being removed without a survey or knew of it being done.
Each of the individuals performing work at the turbine building
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locatien were aware that tools used at the location did
.not require a release survey since it was outside the controlled area.
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NRC Investigation Findines The NRC investigation finds no indication that tools were
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removed from the controlled area without a release survey.
A release survey is not required for tools removed from the work location established in the turbine building
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which is outside of the controlled area.
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Allegation No. 8 a.
Allegation
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It was alleged that the complainant's request regarding
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exposure information was d2nied, b.
NRC Comments
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The investigator determined through contacts with indi-
.viduals and survey records that the Crouse Company e= ploy-
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ces were not working under the authority of a Radiation Work Permit.
The work location occupied showed exposure
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levels of 0.1 mR/hr and there was no radioactive con-tamination present.
Ir.dividuals performed work in their personal clothing.
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The use of personal monitoring devices and a discussion of exposure rates and exposure are included in the
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training instructions.
Prior to being authorized for entry to a controlled area each employee is required to pass a test which includes questions regarding these
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matters.
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According to licensee and Crouse Company cognizant repre-sentatives the e=ployees were informed that no exposure rates or radioactive contamination were present in the work locations associated with the spent fuel racks.
Personal monitoring devices were to be worn, however, for
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all work inside of the centrolled area.
The understanding
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of this infor=ation and these instructions was confir=ed
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by contacting craftsmen performing the work.
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The investigator observed that data' sheets used to record pocket dosimeter results upon entry and exit, were avail-able at the entrance to the controlled area.
These sheets are also used each week to update a computerized summary of accumulated exposure for each individual.
An examination of the computer su=maries and the leg sheets showed no exposure received for the period from July 14
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1451 321
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through August 5, 1975.
One entry of a pocket dosimeter reading was noted as missing for one individual who left the area to terminate.
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The investigator observed Crouse Company employees using the pocket dosimeter log sheets uhen entering and leaving the area.
Further questioning of the employees by the investigator showed that they were aware of the system for knowing accumulated exposure through pocket dosi-meter reading and that the film badge dosimeters would be processed at a later date for the official exposure
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record.
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According to licensee and Crouse Cc=pany representatives they were not aware of anyone requesting information about their exposure or the exposure rate at the wor.k
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location and not receiving an answer to the request.
p c.
NRC Findings The NRC investigation finds that each individual reads and records pocket dosiceter results at the beginning and (
}
end of each shift and is aware of his accuculated exposure.
These, pocket dosimaters and film badges are worn although
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the radiation levels at the work site are less than one
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milliroentgen per hour and individuals appear to be aware of the radiation level.
9.
Allegation No. 9 a.
Allegation
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It was alleged that the security program was lax in re-gard to access control of terminated ecployees to the site.
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b.
NRC Comments
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The investigators examined records and documentation of the physical protection program related to the nuclear
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plant site access controls for terminated employees.
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b )
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The investigators also contacted cognizant representa-
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tives of the licenree, the AIS guard force, and the i =
Crouse Co=pany relative to the procedures and actions
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which are implemented at the time an individual ter-
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minates his e=ployment.
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c.
NRC Investigation Findings
!
The NRC investigation finds that the physical protection program is adequate for controlling access of terminated
' individuals to the nuclear plant site.
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.7..
E.
Management Meeting At the conclusion of the investigation, the investigator held a
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meeting at the site with the following personnel:
General Public Utilities Service Corporation
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R. Rice, Security Coordinator
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Metropolitan Edison Cocoany J. Herbein, Manager, Generation Operations-Nuclear'
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G. Miller, Superintendent, Unit 2 W. Poyck, Coordinator of Services J. Stacey, Security Specialist K. Beale, Radiation Protection Supervisor J. O'Hanlon, PORC Chairman 1.
The investigator, reviewed the reason and scope of the in-
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vestigation.
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2.
The investigator infor=ed the. licensee that within the scope of the investigation, one item of noncompliance had been
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observed regarding the failure to post a radiation area, r-The investigator also noted that this item was gorrected
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prior to the conclusion of the investigation.
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1451j)23
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