IR 05000289/1980014
| ML19347E154 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/14/1981 |
| From: | Knapp P, Nimitz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19347E145 | List: |
| References | |
| 50-289-80-14, NUDOCS 8104240134 | |
| Download: ML19347E154 (12) | |
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-289/80-14 Docket No. 50-289 License No. DPR-50 Priority Category C
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Licensee: Metropolitan Edison Company 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection at: Middletown, Pennsylvania
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Inspection conducted: June 2-4, 16-18, 1980 Inspectors:
k. L N Advu-tlk lBl9o R. L. Nimitz, Radi'ation Specialist date signed f/
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Approved by:
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P. J. Jaapp, Chief, Radiation Support date' signed Secfion Inspection Summary:
Inspection on June 2-4, and 16-18, 1980 (Report No. 50-289/80-14)
Areas Inspected: Special, unannounced inspection by one regional based inspector of the licensee's radiological controls-associated with eddy current testing of t
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the 'B' Steam Generator, drain down of the reactor coolant system, and opening of the primary system for the purposes of high pressure injection tie-in. Areas reviewed included:
respiratory protection, airborne radioactivity sampling, procedures, access control, posting and barricading, planning and preparation, and training.
Upon arrival at the site at 5:00 p.m. on June 2,1980, areas where work was being conducted were examined to review adherance to radiological control procedures and practices.
The inspection involved 30 inspector-hours on site by one NRC regional based inspector.
Results: Of the seven areas inspected, no items of noncompliance were identified in five areas, one item of noncompliance was identified ir each of the remaining two areas (Infraction - failure to establish a training program consistent with Technical Specification 6.4, Paragraph 7; Infraction - failure to adhere to radiation protection procedures as required by Technical Specifications 6.11, Paragraph 6).
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DETAILS 1.
Persons Contacted The following individuals attended the preliminary exit interview on June 4, 1980:
J. G. Herbein, Director, TMI-1 W. E. Potts, Manager, Radiological Controls, TMI-1 R. J. Toole, Manager, TMI-1 C. Wiblin, Radiological Engineer, TMI-1 NRC TMI Program Office; A. N. Fasano, Chief, TMI Resident Section T. A. Moslak, Resident Health Physicist The following individuals attended the final exit interviews * held on June 17 and 18, 1980:
(1)
B. E. Ballard, Sr., Quality Assurance Manager (Modification and Operations)
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E. J. Brown, Training (2)
J. Coody, Training (1)
R. W. Dubiel, Supervisor Radiological Engineering, TMI-1 (1)
R. F. Fenti, Site Quality Assurance Audit Supervisor (1)
J. C. Fornish, Quality Assurance Supervisor, Operations (1)
D. T. Lane, Deputy Manager, Radiological Controls (1)(2)W. E. Potts, Manager, Radiological Controls, TMI-1 (2)
Q. Smith, Training (1)
P. P. Velez, Supervisor, Radiological Control Technicians, TMI-1 NRC TMI Program Office:
W. H. Barley, Resident Health Physicist
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A. N. Fasano, Chief, TMI Resident Section D. A. Haverkamp, Senior Resident Inspector, TMI-1 T. A. Moslak, Resident Health Physicist M. M. Shanbaky, PhD., Senior Radiation Specialist
(1) June 17, 1980 Interview (2) June 18, 1980 Interview The inspector also talked with and interviewed several other licensee employees, including members of the Health Physics (H.P.) staff (station and contractor); chemistry staff and reactor operations and maintenance personnel.
Additionally, due to the unavailability of J. Herbein, Director, TMI Unit 1 at the final exit interviews, this individual was contacted by the inspector via telephone on June 20, 1980 and apprised of the inspection findings.
2.
Purpose The purpose of the special inspection was to review radiation protection activities associated with drain down of the reactor coolant system, opening of the reactor primary system for purposes of High Pressure Injection tie-in and to review the eddy current testing of 'B' Steam Generator.
3.
Eddy Current Testing The inspector reviewed the licensee's preparation for and performance of eddy current testing of 'B' Steam Generator with respect to the requirements of facility Technical Specifications section 6.11, " Radiation Protection Program", and section 6.8, " Procedures".
a.
Pre-Entry Review A review of the licensee's yeparation for personnel entry into the generator was conducted.
The review indicated that prior to personnel entry into the generator, an as low as reasonably achieveable (ALARA) review was performed by the licensee's onsite radiological engineering group. The review included; use of portable ventilation, installation of shielding, use and adequacy of respiratory protection and personnel dose projections i.e. man-rem projections for the eddy current testing. Also included in the licensee's review was the detennination of beta reduction (protection) factors for various articles of protective clothing anticipated to be worn by entry personnel.
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The licensee was noted to have placed thermoluminescent dosimeters (TLDs) inside boots and gloves and place these articles on the steam generator tube sheet.
Subsequent read out of the TLDs indicated no beta radiation penetrated the boots or gloves.
The licensee performed dose rate measurements in the entry way and
' water box' of the steam generator. This latter measurement was performed by use of a TLD ' tree'.
Figure 1 presents the licensee's dose rate profile of these areas.
Following the dose measurements referenced above, inspector discussions with licensee radiological engineering personnel indicated a plexi-glass sheet, approximately one-half inch thick was placed on the tube sheet. This sheet would act as a beta-radiation shield.
No items of noncompliance were identified.
b.
Procedures A review of the licensee's adherence to the following procedures and radiation work permits for preparation and entry into the steam generator was conducted:
Unit 1 Surveillance Procedure No. 1300-48, " Eddy Current Examination
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of 0TSG", dated June 10, 1980.
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Unit 1 Radiological Controls Procedure 1613, " Radiation Work
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Permits", Rev. 10, dated March 14, 1980.
Radiation Work Permit No. 80A-7177, " Move Eddy Current Equipment
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into VC and Set up of Equipment", dated June 13, 1980.
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Radiation Work Permit No. 80A-7243, " Eddy Current Inspection on
'B' Steam Generator and Maintenance on Probe Pusher and Equipment",
dated June 16, 1980.
Inspector review of work in progress, radiological controls in-effect and discussions with licensee representatives indicated the above requirements were adhered to.
No items of noncompliance were identified.
c.
Internal Exposure Control The inspector reviewed the use of respiratory protective equipment and airborne radioactivity sampling performed during the steam generator eddy current testing.
The review was with respect to the following:
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FIGURE 1
'B'
STEAM GENERATOR DOSE PROFILE
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Reactor Plane of
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Coolant In
/ Manway
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f r 400 mR/hr e
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2 Contamination
of Inside " Lip"
. '75 - 85,000 dpm l
100 cm2
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TLD # LOCATION Dose Rate Obtained Gamma (R/hr)
Beta (rad /hr)
18 inches off tube sheet 1.24
2 9 inches off tube sheet 1.48
3 6 inches off tube sheet 1.56 0.1
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- 4 Contact with tube sheet 2.0
- 5 Contact with tube sheet 1.9 0.6
- 6 Contact with tube sheet 2.32 6.76
- NOTE: Licensee estimates variations caused by placement of badges not entirely on tube sheet.
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10 CFR 20.103, " Exposure of individuals to concentrations of -
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radioactive materials in air in restricted areas";
Regulatory Guide 8.15, " Acceptable Programs for Respiratory-
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Protection; Station Health Physics Procedure 1616.1, " Selection and Use of
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Respiratory Protection Devices", Rev. O, October 9,1979, and;
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Station Health Physics Procedure 1616.4, " Implementation of Air-
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Sample Counting, Handling and Actions", Rev. O, October 9, 1979
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Review of the equipment provided indicated that for actual entries into the steam generator, NIOSH/ MESA approved supplied - air hoods were utilized. The breathing air supplied to the hoods was controlled
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by use of Procedure 1104-42, " Station Service Air".
This procedure had been modified by a temporary change notice (June 11, 1980) to
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provide operating instructions when using the Service Air System for personnel breathing air.
Enclosure 3 to this procedure specified air quality and quanttty requirements in accordance with Compressed Gas Association Pamphlet G.7.1 (ANSI Z86.1-1973).
Discussions with licensee Radiological Engineering personnel indicated the breathing air had
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been tested and met Grade D specifications.
The inspector noted this to be acceptable breathing air.
Inspector review of airborne radioactivity sampling indicated samples were being collected near the eddy current equipment controls (refueling floor area), inside the clean " room" leading to the manway of the generator and inside the water box of the generator. The air samples for these latter two areas during the initial generator entry indicated 6.6E-11 and 4.6E-10 uCi/ml (beta / gamma) respectively. An air sample was also collected inside the workers hood during his entry.
Due to the short sampling time and low flow rate of this device a sample activity of less than 9.76E-11 uCi/ml was obtained. Utilizing stay-time and respirator protection factors, actual airborne radioactivity exposures for the initial entry were noted be less than 1% of the Quarterly quantity Limit specified in 10 CFR 20.103.
During review of the licensee's air sampling performed during entries into the steam generator, the inspector noted the licensee's Supervisor of Radiation Protection Technicians to indicate that a lapel air sample had apparently been collected outside of the supplied air hood while an individual made an entry into the steam generator. The battery pack of the air sampler was under the hood while the sampler head was outside the hood.
The hose leading from the sample pump passed through the hood (through a perforation made by the licensee for this purpose) and led outside the hood to the filter sampler head.
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The inspector discussed this with licensee representatives and indicated
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that any modification to an approved respiratory device without specific approval of the approval agency i.e. NIOSH/ MESA invalidates the device's
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approval and consequently the licensee may not make allowances for use of the device in estimating airborne radioactivity exposures of individuals.
As a result of the above, the inspector discussed the steam generator air sampling methods with the licensee's radiological control technicians actually performing the entry air sampling. The insoector could find no indication.that an air sample had been drawn through a perforated hood.
The licensee's Manager, Radiological Controls also reviewed the entry sampling performed and indicated no sampling in this manner had
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the Supervisor, Radiation Protection was in error.
No items of noncompliance were identified.
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Primary System Modification
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The inspector reviewed radiological controls associated with portions of
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the drain down of the reactor coolant system for the purpose of high pressure safety injection tie-in and valve inspection. The review included radiation, l
contamination and airborne radioactivity surveys and use of respiratory protective equipment.
The review was with respect to the following:
10 CFR 20.101, " Radiation dose standards for individuals in restricted
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areas";
l 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive
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materials in air in restricted areas";
Technical Specifications section 6.11, " Radiation Protection" and
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section 6.8, " Procedures" Unit 1 Radiological Controls Procedure 1613, " Radiation Work Permits",
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Rev. 10, dated March 14, 1980; Radiation Work Permit No. 80A-6728, " Draining of Reactor Coolant
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System", dated June 2, 1980; Radiation Work Permit No. 80A-6739, " Inspect and Remove Valve Internals
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and Transport to Hot Shop", dated June 2, 1980 (Valves MU-V-107A/B);
I Radiation Work Permit No. 80A-6663, " Install Tygon Tubing to Top of D-
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Ring for Level Indication from LT line", dated May 30, 1980;
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Radiation Work Permit No. 30A-6784, " Inspect and Modify Internals also
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Transport to ' HOT SHOP'", dated June 3, 1980 (Valve MU-V-86);
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Radiation Work Permit No. 80A-6786, "Jispect and Modify Internals also Transport to 'H0T SHOP'", dated June 3, 1980 (Valve MU-V-94).
j One item relating to adherence to radiation work permit requirements is
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discussed in section 8 of this report.
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5.
Plant Tour The inspector toured the controlled areas upon initial arrival and at various times during the inspection.
The inspector pe.rormed radiation intensity measurements that were necessacy to verify licensee compliance with the requirements of 10 CFR 20.203(f), " Caution Signs, Labels, Signals and Controls" and Technical Specification 6.13, "High Radiation Area".
The inspector's tours indicated Radiation and High Radiation Areas were posted, barricaded and/or controlled in accordance with the above requirements.
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No items of noncompliance were identified in this area.
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6.
Controlled Area Access Points The inspector reviewed routine operations at the Unit 1 Access Control Points to determine if personnel were adhering to applicable sign-in procedures in accordance with Technical Specification 6.11, Radiation Protection Program. This specification requires that procedures for personnel radiation protection be prepared consistent with 10 CFR 20, be approved, maintained and adhered to for all operations involving personnel radiation exposure.
The review encompassed adherence to the following procedures:
Unit 1 Radiological Controls Procedure 1613, " Radiation Work Permits"
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Rev. 10, dated March 14, 1980; Unit 1 Radiological Controls Procedure 1614, " Control Point Instructions"
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Rev. 1, dated April 21, 1980.
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Radiation Work Permit Adherence
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Section 5.3.10 of procedure 1613 requires that prior to personnel entering to perform work, they are to (if not already done for them)
print their last name, first name and social security number on the attachment sheet to the radiation work permit (RWP). Then, in order to signify that they have read and understocd the requirements of the i
radiation work pennit they are required to initial in block #3 of the attachment sheet to the RWP.
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The inspector noted this RWP initialling requirement to provide a means of usuring that radiation workers had read their respective RWPs and were apprised of the job radiological requirements and radiation environs as listed on the RWP prior to commencement of work activity.
During review of RWPs at the access control points on June 3,1980, the inspector noted a number of RWPs to indicate personnel had entered
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to perform work (for periods of up to several hours as indicated by sign-in and sign-out times) covered by their RWP without initialling block' number 3 of the attachment sheet to signify they had read their RWP prior to entering to perform work. One of the RWPs, No. 6770, was established for construction of a clean room at the lower manway of
'B' steam generator. The RWP indicated highest dose rates of 800 mR/hr with general area dose rates of 10-50 mR/hr.
Four individuals were noted not to have initialled this RWP as required. The following RWPs were also noted to lack the required initialling; RWP No. 6726,1 individual; RWP No. 6766,1 individual; and RWP No. 6778,1 individual.
The inspector discussed the above with licensee representatives and indicated that failure to adhere to the requirements of radiation protection procedure 1613 was noncompliance with Technical Specification 6.11 (50-289/80-14-01).
Licensee representatives subsequently located those individuals who l
were in the controlled area and had not initialled their RWP prior to i
their entry to work and required these individuals to read and initial l
their respective RWPs prior to returning to work. The licensee also instructed the control point watch technicians in the necessity to
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ensure workers had read and initialled their RWPs prior to their entry into the controlled area.
b.
Control Point Operation The inspector's review of the control points indicated the licensee had supplied " Control Point Instructions" to each control point and required each control point watch stander to be trained in cach instruction.
These requirements were contained in procedure 1614, referenced above.
Section 5.5 of this procedure requires each watch stander to use current instructions while monitoring control point activities.
Control Point instruction 80-7, " Exposure Control" requires the control point technician to check an individual's weekly, and quarterly exposure
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prior to his entry into the controlled area.
During the inspector's initial entry into the controlled area at approximately 6:00 p.m. on June 2, 1980, the inspector was directed to sign in on a radiation work permit and was permitted to enter.
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Following the inspector's exit from the controlled area at approximately 11:00 p.m. a different control point technician was noted to be present at the access point. Upon exiting this control point the technican checked a computer printout exposure dose record at the control point and found the inspector was not listed in the computer printout.
Consequently, the individual challenged the inspector and questioned him as to how he had gained access to the controlled area since he could not verify the quarterly or weekly exposure of the inspector and therefore could not insure he was within station limits.
The inspector discussed the above with licensee representatives and indicated that the first technician's failure to detennine the inspector's quarterly and weekly exposure prior to permitting his access into the controlled area was noncompliance with Technical Specification 6.11 (50-289/80-14-02).
Following the inspector's discussion with licensee representatives, the inspector noted the licensee's Manager, Radiological Controls to immediately direct the re-instruction of the control point watch standers in this instruction.
7.
Training Technical Specification 6.4, " Training", requires that the licensee maintain a retraining and replacement training program for the facility staff which meets or exceeds the requirements and recommendations of Section 5.5 of ANSI N18.1-1971. Technical Specification 6.2.2 defines the facility staff organization as that functionally shown 'in Figurt 12-1 of the Final Safety Analysis Report.
Radiation and chemistry technicians are shown in this staff organization.
Section 5.5 of ANSI-N18.1, requires the establishment of a training program to maintain the proficiency of the operating organizaticn and recommends l
that some means be provided in the training program for appropriate evaluation of its effectiveness. This training is to include instruction periods and reviews covering those items which relate to safe operation of the plant.
Special training sessions are to be given replacement personnel.
During review of radiation protection operating procedures and changes thereto, the inspector noted several procedure changes to have been made during the period January 1980 to June 1980. Some of the changes addressed such important areas as termination of radiation work permits, allowable time between radiation surveys, contamination limits, changes to 10 CFR 20, and releasing of radioactive material.
The inspector noted the facility radiation protection technicians are routinely involved in the performance of tasks associated with these important areas.
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The inspector discussed these changes with licensee representatives and questioned '. hem as to how radiation protection technicians were apprised of the changes and what means were being used to ensure that the technicians were cognizant of the change. The discussions indicated that the procedure changes were brought to the attention of the technicians by a memo. The changes were placed in a book, titled, " Notifications.of Procedure Changes",
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with an attached sign-off sheet and were required to be signed off by the te'hnicians as having been read.
Licensee representatives also indicated c
procedure changes are addressed at formal technician training sessions which are held on a fixed schedule.
The inspector noted that a technician being trained by this fixed schedule may not receive training in a procedure change or a new procedure by this method for a period of several weeks and may actually be performing work during this time involving the procedure change.
The inspector reviewed the book referred to above at tha radiation protection work area and noted approximately 50 procedure changes with attached sign-off sheets to be in the book, however, in reviewing the sign-off sheets the inspector noted that in some cases procedure changes as much as 10 weeks
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old had not been signed-off by the technicians to indicate review and understanding of the changes.
In some cases, of the 29 technicians listed on the procedure change sign-off sheet, 1 was noted to have signed-off.
Examples include:
change 1-80-85, 10 weeks old,1 of 29 signing-off; change 1-80-107, 2 weeks old, 0 of 29 signing-off; and new procedure 1614, 10 weeks old, 4 of 29 technicians signing off. These changes dealt with such areas as ti.ose mentioncd above, e.g. temination of radiation work permits and changas to 10 CFR 20.
The inspector discussed this matter with the licensee's Manager of Radiological Controls, and noted that training of radiation protection technicians in procedure changes had been addressed in the NRC's investigation of the TMI accident (NUREG-0600) and the report by the NRC's Special Inquiry Group.
The licensee's Manager of Radiological Controls indicated he was unaware that technicians were not signing the procedure changes to indicate reading and understanding of the procedure.
The licensee did have a formal training program for the technicians in place.
However, it was inadequate to assure technicians would be trained in procedure changes or new procedures prior to their implementation by the technicians.
Consequently, the inspect.or indicated that failure to establish a training program consistent with ANSI-N18.1,1971 as required by Technical Specification 6.4, was noncompliance with that requirement (50-289/80-14-03).
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Licensee representatives indicated that action will be taken to ensure all technicians have read and understood recent procedure changes that they have not been trained in. This action was to be completed within 2 weeks (July 1, 1980). Additionally, licensee representatives indicated a documented program for training radiation protection technicians in procedure changes would be established within 4 weeks (July 14,1980).
8.
Additional Item During tours of the Unit 1 containment to review work associated with valves MU-V-107A/B (RWP No. 80A-6739). The inspector noted in initially discussing the repair of these valves with radiation protection technicians involved in coverage of the work that workers apparently began removing valve internals without first contacting the radiation protection group to provide radiological coverage as required by the radiation work permit.
A radiation protection technician had apparently happened on the work while it was in progress.
The inspector subsequently discussed the event with licensee radiation protection representatives and technicians involved and determined that the radiation protection group had been notified and did provide coverage during the valve removal.
Confusion had arisen during the initial work due to a photographer who had been taking pictures of the work in progress and did not require constant radiation protection coverage.
The inspector had no further questions regarding this item.
9.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on June 18, 1980 and summarized the purpose, scope and findings of the inspection.
Licensee representatives stated the following:
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action will be taken to train all radiation protection technicians in applicable procedure changes and new procedures by July 1,1980 a documented program for training of radiation protection technicians
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would be established by July 14, 1980
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