IR 05000289/1977018
| ML19209C703 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/06/1977 |
| From: | Donaldson D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19209C693 | List: |
| References | |
| 50-289-77-18, NUDOCS 7910170871 | |
| Download: ML19209C703 (11) | |
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~U.S. NUCLEAR REGULATORY COMMISSION
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,q 0FFICE OF INSPECTION AND ENFORCEMENT
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Region I Report No. 77-18 Docket No. 50-289
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Category C
License No. DPR-50 Priority
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Licensee:
Metropolitan Edison Company
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P. O. Box 542 Reading, Pennsylvania 19603
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Facility Name: Three Mile Island 1 Inspection at: Three Mile Island Station - Middletown, Pennsylvania 1705i
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Inspection conducted: June 7-10,1977 Inspectors:
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D. E. Donaldson, a 1ation Specialist date signed date signed
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date signed
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Approved by:
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J. P. Sydhr4 Chief, Env~ironmental date ' signed and Sp6cial Projects Section Inspection Summary:
Inspection on June 7-10, 1977 (Report No. 50-289/77-18)
Areas Inspected:
Routine, unannounced inspection of emergency planning including:
licensee coordination with offsite support agencies; emergency facilities, equipment, instrumentation and supplies specified in the Emergency Plan and Implementing Procedures; training of emergency personnel; Emergency Plan Implementing Procedures; licensee records relating to emergency drills; the licensee's management centrols in the area of emergency planning; and licensee action on a noncompliance item and unresolved items noted ir. previous emergency planning inspections.
Also included in this inspection were observstions of general health physics practices.
The inspection involved 28 direct-inspection hours by one MRC inspector.
Results:
Of the seven areas inspected, no items of noncompliance or deviations were identified in five areas; five apparent items of noncompliance and one Deviation were identified in two areas:
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1476 068 Region I Form 12 f
(Rev. April 77)
,9910170
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1.
Infraction (77-18-01):
Inadequate maintenance of emergency equipment.
(Paragraph 5)
2.
Infraction (77-18-02):
Failure to perform required calibrations of dosimeters.
(Paragraph 5)
3.
Infraction (77-18-03):
Failure to survey.
(Paragraph 10)
4.
Infraction (77-18-04):
Unauthorized entry into high radiation area.
(Paragraph 10)
5.
Infraction (77-18-05):
Improperly issued Radiation Work Permit, RWP.
(Paragraph 10)
6.
Deviation (77-18-06):
Smoking while handling contaminated mater-
'ials.
(Paragraph 10)
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1 DETAILS 1.
Persons Contacted
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a.
Principal Licensee Employees
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- Mr. G. Miller, Station Superintendent
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- Mr. J. O'Hanlon, Unit 1 Superintendent
- Mr. R. Dubiel, Acting Supervisor Radiation Protection &
Chemistry
- Mr. C. Hartman, Lead Electrical Engineer
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- Mr. V. Orlandi, Lead Instrument & Control Engineer
- Mr. G. Kunder, Supervisor of Operations, 'Jnit 1
- Mr. T. Mulleavy, Radiation Protection Foreman
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Mr. D. Zechman, Training Coordinator l
Mr. B. McCann, Radiation Protection Foreman Mr. E. Gee, Safety Supervisor Mr. F. Grice, Corporate Safety Supervisor j
Mr. H. Shipman, Operations Supervisor Ms. C. Nixdorf, Office Supervisor
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The inspector also contacted seven other licensee employees
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during the course of the inspection.
They included health j
physics technicians, Instrument & Control technicians and nuclear plant operators.
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- denotes those present at the exit interview I
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Other Personnel
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Mr. K. Molloy, Director, Dauphin County Civil Defense Ms. M. Reilly, Chief, Operating Reactor Surveillance Branch, Pennsylvania Bureau of Radiological Health Mr. D. Murray, Chief, Londonderry Township Fire Company Mr. K. Miller, Hershey Medical Center Her.lth Physicist Mr. B. Brosey, Hershey Medical Center Health Physics Technician 1476 070
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l 2.
Licensee Action on Previous Inspection Findings a.
(0 pen) Unresolved item (76-27-01):
Training program for off-site agencies.
During the current inspection, discussion with licensee personnel indicated that the licensee had reviewed
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the emergency plan training program for the various agencies.
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Upgrading of the program, in the form of schedules and lesson plans, is being accomplished concurrent with finalization of i
the Station Emergency Plan and Implementing Procedures as a precondition to the licensing of Unit 2.
The inspector stated
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that this item would remain unresolved pending a subsequent-l review of the completed program prior to the issuance of an operating license for Unit 2.
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(Closed) Unresolved item (76-27-02):
Retraining of local fire departments. The inspector reviewed records of training and j
held discussions with the Chief of the Londonderry Township
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fire Company and licensee representatives relative to emergency plan training.
This review indicated that the licensee had made a refresher training session available to members of four local fire companies on December 15,1976 (Rescue Hose #3, m
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V Liberty, Bainbridge and Londonderry Fire Companies).
Discussions l
with the Londonderry Fire Company Chief indicated that this training was conducted and adequate to insure a continuing
effective response capability.
This item is considered resolved.
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(Closed) Unresolved item (76 27-03):
Retraining of construc-c.
tion personnel. The inspector held discussions with licensee personnel and noted that the licensee had conducted a review
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of personnel on the Unit 2 construction site relative to the proper procedures to be followed in the event of fire at the construction site. Based upon the licensee's meeting the previously stated commitment, this item is considered resolved.
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(Closed) Unresolved item (76-27-04):
Hydrant operability.
The inspector held discussions with licensee representatives
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and determined that the operability of station fire hydrants had received an extensive engineering evaluation to verify that the hydrants were in proper operating condition and that the maintenance program for these hydrants was adequate.
The inspector noted that the results of this evaluation indicated that all hydrants were in proper operating condition and they met established NFPA standards.
The licensee further stated that a firm commitment to continue this maintenance program has been made through the Three Mile Island Technical Speci-fications.
This item is therefore resolved,
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(0 pen) In'raction (IE Report 50-289/76-20):
Improper inven-tory / check of emergency equipment.
The i.nspector noted that while the licensee had apparently implemented corrective actions as outlined in their letter dated October 7,1976, this corrective action had not been adequate.
During the current inspection, the inspector noted conditions similar to
.those previously reported and cited these conditions as an Infraction level item of noncompliance during the current inspection (77-18-01).
(Detail 5)
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(Closed) Unresolved item (IE Report 50-289/76-20) coordination with offsite agencies. The inspector determined through discussions with personnel of four offsite agencies that routine coordination activities had improved and were adequate.
This item is resolved.
3.
Coordination with Offsite Acencies The inspector reviewed records, procedures and written agreements i
relating to the licensee's coordination of emergency planning t th q
agencies listed in the Emergency Plan and Implementing Procedura.
b The inspector discussed this subject with licensee representatives
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and persons of four offsite agencies - Londonderry Township Fire Department Dauphin County Office of Civil Defense, Pennsylvania Bureau of Radiological Health, and the Milton S. Hershey Medical Center.
These discussions verified that the existing agreements between the licensee and these agencies remain in effect, and that the licensee's contact and coordination were adequate for these agencies to maintain an effective response capability.
No items of noncompliance were identified.
4.
Facilities and Equipment The inspector examined facilities, equipment and instrumentation to verify that the items specified in the licensee's Emergency Plan and Implementing Procedures were available for use and maintained in an operable state.
The inspection included examination of:
three emergency equipment kits; the emergency control centers and
' associated equipment; a selection of two items of emergency comun-ications equipment; radioactive release monitoring instruments -
area and process monitors, and meterological instruments; and medical treatment / decontamination facilities, both onsite and at the local hospital.
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6cing the conduct of these inventories and checks, the inspector noteo :everal discrepancies pertaining to the readiness of specified emergency related equipment.
Specifically:
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A high range survey instrument was not available in the control room; c.
Isopleths located in the control room were unreadable; d.
Various items of equipment were missing from the emergency kits; and e.
Dosimeters stocked in the various *its hao out of date calibration stickers, while others had no stickers.
Prior to the completion of the inspection, the licensee had completed a reinventory and operability check of all emergency equipment.
Missing items were restocked, and procedures were replaced with up-to-date revisions, etc.
(See Detail 5 for related items of noncompliance).
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The inspector had no further comments.
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5.
Calibration, Inspection and Checks of Emergency Equipment
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The inspector reviewed and evaluated the adequacy of procedures and
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(J schedules established by the licensee for calibrating, inventorying, and checking the operability of the emergency response equipment i
listed in the Emergency Plan, Implementing Procedures and/or Technical Specifications. The inspector selected a sample of calibration, inventory and operational check records covering the period September i
1976 through May 1977, for four types of preventive maintenance i
operations on the licensee's emergency equipment.
The inspector noted that there were no records of any emergency equipment inventories available for review, nor could they be located by various licensee representatives.
Discussion with these individuals indicated that certain, but not all, of the required quarterly equipment inventories had been performed.
Licensee representatives stated that during the performance of the inventories, all equipment was not checked, per se, but rather assumed to be present if it appeared that the containers in which the equipment was stored had not been opened.
Licensee personnel were not able to recall with certainty the dates that inventories were conducted or the results of these inventories.
The inspector's independent inventory and check of emergency equipment conducted on June 7, details of which are in Paragraph 4, indicated that all emergency equipment had not been maintained in a state of constant readiness.
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t The licensee's failure to conduct complete inventories at the required quarterly frequency and maintain records of such inventories constitutes noncompliance with the requirements relating to emergency equipment readiness contained in Paragraph 2.2 of the Emergency Plan, Technical Specification 6.11, Emergency Procedure 1670.12 and Health Physics Procedure 1778.
The inspector further noted that this finding had apparently gone uncorrected since the previous emergency planning inspection (IE Report 76-20, Details 4.a and 4.f) and represented the third recurrence of this item (77-18-01).
Further review of maintenance records, procedures and schedules indicated that dosimeters are to be, calibrated / leak tested on a semi-annual basis. The inspectors review indicated that dosimeters stocked in the emergency kits were not tested as required.
The failure to test dosimeters in the emergency kits at the required semi-annual freuqency constitutes noncompliance with the requirements of Technical Specification 6.11 and Health Physics Procedure 1749, paragraphs 2.0 and 5.1, and table 1749-1.
(77-18-02)
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6.
Training
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The inspector reviewed training related documentation and procedures to verify that training required by the Emergency Plan and been conducted.
In addition, the inspector interviewed five individuals whose names appeared on attendance lists.
Training conducted since August 1976 included sessions for:
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four local fire companies; b.
personnel of the Milton S. Hershey Medical Center; c.
the licensee's fire brigade; and d.
licensee first-aid personnel.
The inspector determined that required training had been provided within the required schedules.
No items of noncompliance were identified.
7.
Emergency Drills The inspector reviewed records of one medical emergency drill con-ducted since the previous emergency planning inspection on August 24-26,1976 (IE Report 76-20).
This drill was conducted on December 29, 1976 and involved coordination with and participation by the offsite medical treatment facility, emergency transportation service and licensee personnel.
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6 The inspector determined that: the licensee used qualified personnel
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to evaluate the organization's response; a critique was held, during which discussion highlighted improvement possibilities; and appropriate actions had been initiated or completed to correct any areas needing improvement.
No items of noncompliance were identified.
8.
Emergency Plan Implementing Procedures The inspector reviewed and evaluated the Emergency Plan Implementing Procedures and held discussions with licensee personnel relative to the adequacy of these procedures.
In particular, discussion centered on the post =aa.iJent environs sampling procedure.
The inspector's review indicated that the licensee's current field assessment procedures and equipment did not provide a capability sufficient to I
permit rapid evaluation of iodine levels in the post-accident environs.
During discussion with the licensee concerning this item, licensee management stated that appropriate revisions to the
offsite survey and sampling procedures would be made immediately to
j provide a more effective means of perfonning confirmatory field measurements in the post-accident environs.
The licensee further
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lJ stated that these changes would be of an interim nature since an l
upgrading of sampling and counting equipment and the development of an additional means for determining offsite consequences based upon j
field data collection, was being performed in con, junction with the
licensing of Unit 2.
i The inspector was provided a copy of the procedural revisions for i
review.
The inspector observed that the revisions would provide an adequate capability for assessment of the post-accident environs for iodine. The inspector stated that subsequent improvements in this area would be followed by the NRC during a future Unit 2 pre-licensing emergency planning inspection.
No items of noncompliance were identified and the inspector had no further questions at this time.
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9.
Management Control - Emeroency Planning a.
Established / Documented Program The inspector reviewed procedures, applicable technical spec-ifications and held discussions with responsible licensee personnel and verified that a program of management control over emergency planning activities had been established.
This program consists of: the delineation of planning responsibilities and autnorities;' provides for periodic reviews, audits and up-dater of Emergency Plan implementation; and delineates respon-sibility for overall conduct of reviews, audits and updates.
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No items of noncompliance were identified.
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Reviews and Audits The inspector reviewed the report of an internal audit con-ducted in December,1976 pertaining to adequacy of the Emergency Plan.
This report noted five recommendations for improvement,
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all of which related to content of the Plan.
The licensee ( )
stated that these items are to be resolved by the development
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of the Station Emergency Plan covering both Unit 1 and Unit 2.
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No items of noncompliance were identified.
10.
General Health Physics Practices - Plant Tour The inspector made a routine tour of the licensee's controlled area accompanied by a licensee health physics technician for the purpose of verifying the locations of emergency kits and to observe general aspects of the licensee's radiation safety program.
While performing the tour, the inspector carried a recently calibrated E-520 survey meter which deflected more than expected, as the inspector passed the trash compacting area.
The inspector performed a survey at the rope barrier surrounding the trash compactir.g area, which was posted as a radiation area, and noted radiation levels ranging from 30 mR/hr to 140 mR/hr.
Additional surveys outside of the roped barrier indicated dose rates of from 30 mR/hr to 139 mR/hr. The inspector noted that the source of the radiation was a 55 gallon drum located in the trash compacting area.
Discussions
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with licensee supervisory personnel indicated that the drum had been moved to the trash compacting area at approximately 10:00 a.m.
that day, and had not been surveyed after having been placed.
The inspector informed the licensee that failure to survey the area after placing the drum was in noncompliance with the survey require-ment of 10 CFR 20.201 as it relates to 10 CFR 20.203(c) and Technical Specification 6.13.la., posting and barricading of high radiation areas.
(77-18-03)
Additional review of the circumstances surrounding the failure to survey and subsequently post a high radiation area indicated that the 55 gallon drum contained waste generated from maintenance work on a condensate water storage tank pump on June 1,1977.
The inspector determined that a utility man had been directed to move the drum from a posted high radiation area in the vicinity of the condensate water storage tank pump at approximately 10:00 a.m. on
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June 7,1977, and that the entry of the utility man into that high radiation area and subsequent movement of the high level waste to the trash compacting area had been performed without the issuance of an RWP. The inspector informed the licensee that the entry of the utility man into a high radiation area without authorization
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via issuance of an RWP constituted noncompliance with the require-
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ments of Technical Specification and 6.13.1.a. and Health Physics Procedure 1613, pertaining to control of access to high radiation areas.
(77-18-04)
To determine the licensee's provisions for controlling radioactive waste generated by maintenance activities, the inspector reviewed the RWP under which repair of the condensate water storage tank pump Sas performed.
Review of this RWP indicated that a dose rate survey instrument had not been required as part of the protective equipment, i.e. " Dose Rate Instrument" block was not checked on the Work Permit.
Further review of the RWP revealed 1.Mt the area to be worked in was established through survey as a high radiation area with maximum dose rates of 600 mR/hr and an average alue of 140 mR/hr.
Discussion with licensee personnel did not verify whether or not a dose rate instrument had in fact been present des 71te the improperly issued RWP.
The inspector stated that the failure to properly issue the RWP for entry into a high radiation area constituted noncompliance with the various requirements of Technical Specification 6.11 and 6.13.1.a and Health Physics Pro-cedure 1613, Paragraph 5.2.4.1.
(77-18-05)
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In a related observation, the inspector noted that a controlled area wet vacuum and floor scrubber were standing on absorbent paper in preparation for their movement for storage into a radiation area.
Surveys of these items indicated radiation levels of approx-imately 15 mR/hr at 1" from the surface of the tank and arour.d the brushes of the scrubber.
The inspector observed the individual performing the movement of the equipment into the radiation area and noted that the movement and disposal of the absorbent paper waste was accomplished while the individual was smoking.
The inspector informed the licensee that the handling of potentially contaminated waste and internally contaminated equipment while smoking ~ constituted a deviation from standard health and safety practices of the industry.
(77-18-06)
Prior to the completion of the inspection, the licensee had moved the high level waste drum from the trash compacting area and had discussed general smoking practices with the individual involved in the movement of the potentially contaminated equipment.
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Exit Interview I
t The inspector met with lic_ensee management representatives (denoted in Paragraph 1.) at the conclusion of the inspection on June 10, 1977. The inspector sumarized the purpose and scope of the in-spection and the findings.
With regard to the noncompliance items, licensee management stated that immediate corrective actions had -
been or would be implemented.
With regard to the licensee's post-accident environmental assessment provision, the licensee stated that the evaluation of alternate environmental assessment methods and equipment would be pursued and finalized prior co the licensing cf Unit 2 and final issuance of the Station Emergency Plan Implementing Procedures.
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Telephone Conversations The inspector and NRC management contacted Messrs. G. Miller and R.
Dubiel of the licensee's organization on June 24, 1977, to discuss the status of the licensee's emergency offsite assessment action capabilities, i.e., field data collection.
The licensee representative stated that procedural revisions had been implemented and that copies of the revisions would be provided to the NRC for review.
On June 28, 1977, the inspector recontacted Mr. R. Dubiel and discussed the results of the NRC's review of the revised field data collection procedures.
In addition, the inspector summarized and reviewed the inspection findings.
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