IR 05000289/1977001
| ML19256D382 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/11/1977 |
| From: | Knapp P, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D373 | List: |
| References | |
| 50-289-77-01, 50-289-77-1, NUDOCS 7910170942 | |
| Download: ML19256D382 (11) | |
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IE:I Form 12 (Jan 75) (Rev)
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U. S. NUCLEAR REGUMTORY CC2CitSSION OFFICE Of INSPECTION AND ENFORCDiENT
REGION I
IE Inspection Report No: _
50-289/77-01 Docket No:
50-289 Licensee:
Metrooolitan Edisnn Onmoany License No:
DPR-50 P. O. Box 542 Priority:
Reading, Pennsylvania 19603 Category:
C Safeguards Group:
Location:
Three Mile Island 1, Middletown, Pennsylvania Type of Licensee:
Typ.e of Inspection:
Special, Unannounced
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Dates of Inspection:
January 11-12, 1977
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Dates of Previous Inspection:
December 28-30, 1976 1/#O/77 Reporting Inspector:
/f L0th 6 Aarl E. Plumlee, Radiation Specialist DATE Accompanying Inspectors:
NONE DATE
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DATE DATE NONE Other companying Personne_.
DATE Reviewed By:
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't P h er J. Knapp, Chief, %diation Support Section
'DATI Fuel Facility and Materials Safety Branch
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O SUMMARY OF FINDINGS
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Enforcement Action A.
Item 3 of Noncompliance 1.
Violations i
None.
2.
Infraction
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77- 01 - 01 Failure to Follow Procedures Technical Specification Section 6.11 states that radiation protection procedures shall be prepared consistent with the
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requirements of 10 CFR 20 and shall be approved, maintained
and adhered to for all operations involving personnel radiation
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exposure.
Procedure HPP 1715 " Operation and Calibration of the thermo-f, luminescent Dosimetry System", developed pursuant to the above, specifies information to be entered in the Log Book when op-
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erating the TLD Equipment and, in Revision No. 2, dated September 10, 1976, requires that the Log Book will be reviewed weekly and then signed and dated by a Radiation Protection Foreman /
Supervisor at this time.
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Contrary to the above, as identified by a review of the Log Book on January 12, 1977, there were recurrent omissions of required Log Book entries and there were no weekly entries or signatures by any Foreman or Supervisor after September 10, 1976.
(Details,3.b)
3.
Deficiencies None.
Licensee Action on Previously Identified Enforcement Action Not inspected.
Design Chances None applicabl _ __
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Licensee Events None.
Other Significant Findings
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A.
Current Findings 1.
Acceptable Areas
No inadequacies were identified during inspection of the j
following areas:
I a.
Equipment Calibrations between August,1976 and i
January 12, 1977
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b.
Personnel dosimetry records cetween September,1976 and December 31, 1976 2.
Unresolved Items
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None.
3.
Deviations None, i
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Status of Previously Identified Unresolved Items None.
Management Interview A management interview was conducted at Three Mile Island Facility on January 12, 1977.
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Persons Present W. Cotter, supervisor of Quality Control R. Dubiel, Radiation Protection Supervisor (Acting Supervisor of Radiation Protection and Chemistry G. Miller, Unit 2 Superintendent (Acting Unit 1 Superintendent)
J. O'Hanlon, Engineer Senior Nuclear I m
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Items Discussed A.
Purpose of Inspection This was an inspection of,the TMI personnel dosimetry program and alleged inadequacies described by an anonymous worker by telephone on January 6,1977, pursuant to the Code of Federal Regulations in Part 10 CFR 19.16.
(Details, Paragraph 2)
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B.
Acceptable Areas i
The items dfscussed are as identified under the "Other Significant
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Findings" section of this report.
C.
Items of Noncompliance i
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The items discussed are as identified under the " Enforcement Action" l
section of this report.
f D.
Procedures i
The licensee representative stated that TLD procedures will be re-
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viewed and revised as appropriate.
E.
Staffing for Radiation Protection and Chemistry The licensee representative stated the previous Supervisor of Radiation Protection and Chemistry was transferred to another site effective December 31, 1976, and the Radiation Protection Supervisor was as-signed the additional responsibility of Acting Supervisor of Rad-fation Protection and Chemistry. He stated that documentation of the change was forthcoming.
The inspector stated that the allegations had included a comment re-lated to the above transfer, however, the inspection findings in-dicated that the item of noncompliance commenced before the transfer.
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DETAILS 1.
Persons Contacted W. Deimler, Health Physics Technician R. Dubiel, Radiation Protection Supervisor C. Hartmann, Vice Chairman, Plant Operations Review Committee F. Huwe, Radiation Protection Foreman 2.
Scope of Inspection
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This was a special inspection of alleged problems (see following items a through d) with the TMI performance of personnel dosimetry.
These allegations were made by an anonymous caller by telephone on January 5,1977. The caller requested that an inspection be
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performed pursuant to the provisions of the Code of Federal Reg-ulations, Part 10 CFR 19.16.
The caller stated a concern that inadequate dosimetry was provided as alleged in items a through d.
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a.
Alleged lack of familiarity with the job on the part of the individual e ssigned te process TLDs, because this monthly (j assignment was rotated down a list of 18 individuals, b.
Alleged lack of care and interest in TLD processing on the part of both the assigned individuals and the foreman assigned for the job. The transfer of personnel was also discussed.
c.
Alleged errors in the insertion of TLD cards into the cor-responding individual's badges; causing record errors.
d.
Alleged equipment problems including (1) illegible numbers on the TLD cards, (2) data printing errors, (3) inability to use the punched tape for computer input, resulting in manual trans-cription errors; (4) residuals remaining in exposed dosimeters, after repeated processing, and (5) calibration errors.
(Details, Paragraph 5)
During the above telephone conversa. tion the caller stated that he was unable to provide specific information as to dates and details to be inspected.
Discussion of the residuals and the calibration errors resulted in agreement that none of these allegations necessarily indicated that personnel exposures were being underestimated and this was acknowledged by the caller.
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3.
Review of TLD Equipment Use and Upkeep The inspector observed the processing of TLDs on January 12, 1977 paying particular attention to the alleged problems.
a.
Requirement for Log Book entries.
HPP 1715, section 5.2.5 and HPP 1715.1, section 5.3.4 require that when operating the TLD equipment specified entries will
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be made in the Log Book including (in part) the: date and
time; reason for operation; name of operator *; number of l
badges evaluated; high voltage setpoint; background average reading; standard card average reading; cleaning; nitrogen i
supply pressure; test results*; arrors incurred; maintenance
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performed * and date, time and name of the individual involved; and findings of maintenance inspections.*
I Another requirement is*:
"The Log Book will be reviewed weekly by a Radiation Protection Foreman / Supervisor who will
inspect the TLD equipment and the TLD room and enter comments i
in the Log Books as required. This individual will then sign
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and date the Log Book at this time."
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l-b.
Observation of TLD Processing and the Logging of information.
The inspector observed that typically only three or four of the entries required above had been made monthly, although the foreman stated that the TLD equipment was operated during each month of 1976.
Specifically, examples of recurrent and total omission after September 10, 1976, were numbers of badges evaluated, dates and times of operation, cleaning (which is a procedural prerequisite for operation), nitrogen pressures, errors, test results, names of operators, foreman or supervisor signatures, and maintenance description.
The licensee representative stated that most of the required information could be found elsewhere or inferred and that all of the dosimetry data had been reviewed, however, further review indicated a lack of maintenance records as shown below.
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- Added requirement - Revision 2 to HPP 1715, dated September 10, 1976
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The inspector identified the failure to follow the procedural requirements to log specified information as a item of non-compliance with the Technical Specification (6.11) requirement to adhere to procedures. (77-01-01)
c.
Servicing and maintenance.
The inspector selected the cooling fan filter for a check of the licensee's upkeep of the TLD equipment.
The manufacturer's manual states that monthly or more frequent filter cleaning is n.;cessary and that the phototube in the TLD equipment is ef..itained at a controlled temperature of 500F (apparently by a device that rejects heat to the cooling air).
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Observation of the accumulated dirt on the filter indicated
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that the cleaning had not been done for several months prior to January 12, 1977, and that the cooling flow could be improved
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by cleaning the filter.
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l A licensee representative stated that he did not know of the filter being cleaned and had no record of anyone clear.ing it.
i Another licensee representative subsequently stated that he
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had cleaned the filter during August,1976, but made no record l
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of it.
Although servicing was scheduled on a monthly basis commencing in January 1977 there was no list of items to be performed.
The licensee representative stated during the exit interview that all of the manufacturer's recommendations will be followed.
4.
Review of Personnel Assignments a.
Foreman's experience and responsibilities.
The licensee representative stated that the on-site responsibility to schedule and look after the TLD processing and the personnel dosimetry records was assigned to a Radiation Protection Foreman. The Foreman 'eports to the (on-site) Radiation Protection Supervisor and, in addition, has frequent contact by telephone with a Metropolitan Edison Company representative located at Reading, Pennsylvania, who provides technical information on TLD processing.
The licensee representative stated that this Foreman was hired on October 11, 1976, for the dosimetry assignment but this is not his only duty.
The licensee representative stated that the Foreman's previous experience included a total of twelve years in the U.S. Navy, part of this being in the Radiological Control Division of a nuclear support tender, and that this ir.dividual had completed a one year course in Naval Nuclear
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(l Nuclear Power school and a twelve week cocrse in Naval Engineering
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Laboratory Technical Training in radiation protection and chemistry.
The Foreman stated that he observed each Health Physics Technician's performance of TLD equipment operation and made certain that each operation was performed properly before the technician was considered checked-out on the equipment.
The Foreman stated that he reviewed all data output by the TLD equipment and reviewed this information again in the computer j
printout of the personnel exposure records.
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The Foreman stated that he had overlooked the requirement to i
make a weekly review of the Log Book.
(Detail, Paragraph 3.a i
and 3.b)
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The inspector reviewed the computer summary of exposures to personnel for the last quarter of 1976, and the TLD equipment
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printout.
No discrepancies or uncorrected data were identified.
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A review of recent film badge data did not identify any substantial differences from the TLD data.
(Details, Paragrt.ph 5)
The inspector noted that it appeared that the Foreman Iad
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performed his responsibilities essentially as describec above.
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b.
Technician's responsibilities.
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The inspector observed the assigned Technician's operation of the TLD equipment on January 12, 1977.
Except for his omission to make required Log Book entries (Details, Paragraph 3.b) the Technician followed the procedure.
i The Technician stated that he had been checked-out on this job by the Foreman (see above) during January,1977, while performing the monthly calibration of the equipment prior to processing the personnel dosimeters.
The inspector observed that greater than half of the Technician's time was spent on cleaning of equipment and on clearing faults, during the period of observation.
The Foreman stated that the cleaning and clearing of faults was necessary and was not a reflection on the Technician's job performance.
The inspector noted that although 10 technicians had been recorded as having completed a training session on the TLD equipment, the individuals assigned to process TLDs for the months of November,1976, and January,1977, were not on this roll. The Foreman stated that he had not checked on this prior to the inspection but he would require the assigned technicians to view the available video tape as a prerequisite to processing TLDs.
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5.
Review of Calibrations The TLD equipment and procedures were previously inspected by another inspector during August 30 - September 2,1976, (Inspection No.
50-289/76-22, Details, Paragraph 7), and no problems were identified.
A subsequent review of personnel exposure records identified three instances of significant discrepancies between film badge information and TLD information however no exposures exceeding regulatory limits were indicated by either badge system (Inspection No. 50-289/76-26,
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Details, Paragr1ph 15).
Procedure HPS 1715 and HPP 1715.1 require monthly and annual tests j
of the cal 1 oration of the TLD system.
The TLD card exposures are
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performed cq-site by the licensee and off-site by the manufacturer j
and by a service organization. The gamma radiation sources used for the tests were all 137-Cesium (0.66 mev).
Beta radiation tests were done only on the annual test and the results had not been reported at the time of the inspection.
A review of TLD data printout and the Log Book on this inspection in-dicated that, although many of the required Log Book entries were
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not made, the required monthly and annual calibrations after August, J
1976, generally appeared to have been performed in accordance with the procedures.
The inspector observed, and the licensee representative acknowledged that the TLD evaluations typically overestimated the calibration badge exposures. The licensee representative stated that a 20% margin
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was intentionally provided to prevent any underestimation of personnel
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exposures resulting from TLD " fading" which is described in the manufacturer's documentation on TLD evaluations.
The licensee representative stated that the written report of the re-cent annual calibration would be available for inspection in the near future and that their evaluation in accordance with the procedures indicated that the calibration was acceptable.
This information will be reviewed on a subsequent inspection.
(77-01-02)
The inspector's review of the raw data did not identify any unacceptable calibration data, after making allowance for the conservatism described above.
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6.
Review of TLD Processing Problems a.
Loading of TLD cards into the corresponding badges.
A licensee representative stated that he knew of one example during March 1976, where two TLD cards had been inadvertently piaced in the wrong badges, but this had been corrected in the personnel dosimetry records.
The Foreman attributed this problem to a failure to keep the cards and badges in order during processing.
The Foreman now requires the badges to be placed in numerical order and the TLD cards to be kept in order during removal from the badges,
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evaluation, and subsequent reinsertion into the badges.
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The inspector noted that the printed numbers of the TLD cards were sometimes difficult to read, but the licensee representative printed out the punched holes (for automatic identification it the TLD equipment) were readily distinguished and readable once the code was recognized.
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No uncorrected problems we: e identified during this inspection
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involving TLD card identification and loading into th'e badges.
b.
Automatic printout of exposure data and TLD card numbers.
Observation of the TLD equipment operation, discussion, and a review of printed output indicated that the following problems occur.
(1)
Overprinting when the paper fails to advance fully.
(2)
Miscolumnation combined with lateral overprinting.
(3)
Printing of letters where numbers are required.
The Foreman stated that he always reviewed the printed data before it was input to the computer and he had always been able to read and correct any of the above by hand, thus the input to the computer was correct in his judgment.
The licensee representatives stated that the planned corrective action to reduce the above problems included monthly servicing and the provision of a regulated power supply (on order).
The inspector noted that care was necessary in reading the printed output, which includes both a decimal point and an exponent.
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The inspector observed that LSe allegations concerning residuals may have been in part a result of misreading the printed output or possibly a printer error, and that th' difficulty in reading the printed output is a potential minor problem with this equipment.
c.
TLD residuals.
The licensee representative stated that some highly irradiated TLDs appeared to retain residuals after being read out and
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that all such TLDs were retired from use except where the r.esidual would not present a problem.
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The inspector observed several check; for residuals and none were found among tnose used for personnel dosimetry.
The inspector also reviewed previous printed output.
(Details,
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Paragraph 4.a)
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The Foreman stated that he reviews the computer printout and typically finds and corrects one or two input transcription
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errors each month for about two hundred individual records.
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The Foreman stated that he is confident that the individual
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exposure records are correct.
(Details, Paragraph 4.a)
No item of noncompliance was identified involving the processing
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of TLD data.
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