IR 05000289/1988019

Insp Rept 50-289/88-19 on 880725-29.No Violations Noted. Major Areas Inspected:Licensee Radiological Controls Program,Including outage-related Radiological Controls, Outage Work Scope & ALARA & Previous Identified Items

ML20151Y142
Person / Time
Site:	Three Mile Island
Issue date:	08/17/1988
From:	Shanbaky M, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151Y109	List: IR 05000289/1988019 ML20151Y106
References
50-289-88-19, NUDOCS 8808260247
Download: ML20151Y142 (7)

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U.S.NVCLEAR REGULATORY C0l#11SSION

REGION I

Report N /88-19 Docket N License No. DPR-50 Priority --

Category J Licensee: GPU Nuclear Corporation P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted: July 25 - 29, 1988

, 3 Inspector: . d% A2 5. Sherbini, Senior Radiation Specialist, 16h8 date Facilities Radiation Protection Section Approved by: . _8Y/7!8 anbaky, Chief, Facilities Radiation ' da'te Protection Section Inspection Summary: Inspection July 25-29,1988(PeportNo. 50-289/88-19)

Areas Inspected: Routine, unannounced safety inspection by a region-based inspector of the licensee's radiological controls program. Areas inspected included outage-related radiological controls, outage work scope and ALARA, and review of the status of previously identified items.

l R_esul ts: No violations were identified during this inspection.

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DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel D. Ethridge, Radiological Engineer E. Hauser, Training

• C. Incorvati, TMI Audit manager

• G. Kuehn, Radiological Controls Director, THI-l

• A. Palmer Radiological Field Operations manager, THI-l

• R. Shaw, kadiological Engineering Manager, TMI-1 1.2 NRC Personnel T. Moslak, Re:,ident Inspector A. Sidpara, Resident Inspector 2.0 Status of Previously Identified Items 2.1 Open Item (289/87-02-02): This item was opened in connection with an RCT in Unit allegation The made allegation bymade was a radiological to the NRCcontrols technician 25,1986.(The) alleger on August stated that he had a radiological health concern and claimed that licensee management was subjecting him to harassment as a result of this concern. A review of the records during this inspection revealed that on July 18 1986, during a routine scheduled meeting between the Unit I radiological controls technicians and their supervisors, the alleger pointed out that the department had been operating in a manner that violated one of their own procedures. Specificallyg one of the 1758.1, "Operation of Portable Air Samplers that all Ben procedures (dix breathing zone air samplers pro and thebe teste flow tester was not at the sampler issue point. Radiological controls supervisors at the time were not aware that the flow testing device was missing. When the alleger brought u this matter during the meeting, he was told to write a Radiolo ical Awareness Report (RAR).

The alleger wrote the report and submit ed it to his management (RAR #

86-0091, July 24, issued a memo 1986)the technicians to the problem (memo dated. As a result, alerting August 26,1986). This memo appears to have resolved the safety concern. A review during this inspection showed that the flow tester is currently in use at the Unit-1 radiological controls access poin However, the harassment issue overlaps the safety issue. On August 19, 1986, the manager of Radiological Controls Field Operations sent a memo to the alleger in which he expressed dissatisfaction with the

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alleger's performance and gave him a four day suspension without pa Two recent failures on the part of the alleger to properly perform his duties were cited (August 9 and August 15,1986). The memo also stated that past counseling did not appear to have been effective. The Manager, Rad Con Field Operations sent the alleger a second memo on 25 August, 1986, in which he informed him that his qualifications as a radiological controls technician had been rescinded. The memo suggested a requalification program. These qualifications were subsequently reinstated as a result of union intervention. The alleger submitted a formal complaint of harassment to the Department of Labor on September 15, 1986. The D0L conducted an investigation and informed the alleger on November 20 1986 that the investigation could not prove discrimination. It also informed him that an appeal was possible. The alleger appealed, and a hearing was set for April 30, 1987. The D0L issued a notice on July 13, 1987, stating that the claims of discrimination had been withdrawn and that the dispute should be settled by means of the labor relations process with the licensee. The union has set a tentative date for arbitration in November 1988. The grievance stated is unjust disci)line involving four days without pay. Since the safety issues in tiis matter have been settled and the only remaining issue is a labor relations matter, this item is considered close .0 7R Outage Work:

Plant tours conducted during this inspection showed plant housekeepin was generally adequate with the exception of some isolated location Access control was good and protective clothing supplies at the dressing area were adequate during the inspection period. However, some areas that needed improvement were identified. These are described in the following section .1 Posting:

Tours of the )lant during the inspection showed that posting of survey results for tie various radiation areas was adequate. However, discuss',ons with tho NRC Resident Inspecter revealed that such postings have been a recurrent problem on site and that many out of date surveys have been observed on numerous occasions. The licensee stated that they were aware of the problem and had taken steps to correct it. The licensee stated that the problem was that all surveys were being made on schedule and were avai!able for review but the updated surveys were not always posted. This matter will be reviewed

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3.2 Training ar.d Qualifications:

A review of the training and qualifications of radiological controls personnel showed that training of all personnel is being cont ::ted according to requirements and on schedule. The qualifications of licensee personnel were also found to be at least up to minimum recuirements. However, a review of the qualifications of contractor raciological controls technicians, particularly technicians classified as senior technicians, showed that some of them diC not appear to be have had sufficient ex)erience to justify the senior e assificatio The inspector stated tlat although the past experience of these technicians adds to a total of over the two years required for the senior classification some of the experience was not directly relevant to the work of radiolocical controls technician and should therefore not be credited towarc that classification. The licensee stated that they currently do not have written criteria or guidelines to use in deciding the type and amount of experience that may be used to classify a technician es a senior technician. The licensee stated that they will develop such criteria soon. In the meantime, the licensee stated that even though some of the technicians with apparently low experience are classified as senior technicians, their plant assignments are based on their past experience, Technicians with low experience are not assigned to critical positions. Progress in developing clear criteria for crediting past experience of technicians will be reviewed during a future inspection (289/88-19-01).

3.3 Cumulative Exposures:

The cumulative exposure estimate for the 7R outage was 134 man-rem, and the goal was 120 man-rem. The estimate is based on actual work scope, and the goal is designed to encourage improved performanc Ma,jor jobs in the estimate included: steam generator work, both pr; .mary Guideand secondary 1.97 work. Thesides; actualrefueling;tive cumula exposure as of Juiy 21 inservice ins Re$8wasabout131 19 man-rem,whichisinexcessofthegoalandwill likely exceed the estimate before the end of the outage. The major areas in which estimates were exceeded were the primary side steam generator work and minor maintenance and inspections. On the other hand, many jobs were completed with exposures well below the estimates. At the time of the inspection, most of the major work had been completed, including fuel shuffle, steam generator work, and reactor coolant pump seal The licensee stated that several faciors contrit'uted to exceeding the exposure estimates. One of the major items was erection of scaffolding. At the time of the inspection, scaffolding work had cost a little under 20 man-rem. The licensee cited the following factors

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for the high scaffolding exposures: hot weather caused difficult working conditions and slowed down the work; the scaffolding crews were often inexperienced in working in radiological areas; the scaffolds were constructed to more exacting specifications than was necessary and the extra work was done at the scaffold locations, which in many cases involved radiation exposures; and more scaffolding was erected in high radiation locations than in the past outage. The licensee stated that the lessons learned from this outage will be used to improve performance in the future. Some of these improvements will include prefabricated scaffolding, more experienced crews and better planning, and the use of chillers to improve working conditions. The licensee also stated that minor maintenance and inspection work was much more than had been antici)ated, and that some of the valve repacking work was done in hig1er than expected radiation field Another problem area was locating items to be inspected, such as welds, etc, that were covered by insulation. The licensee stated that an effort was made during this outage to more accurately document and mark the locations of these items for future inspection wor .0 Hot Particle Contamination Incident:

The contamination incident occurred on the mornir.g July 11, 1988, and the person involved was a contractor radiological controls technicia The technician had entered containment (RWP # 33609) to perform surveys of the uprcr :nd lower steam generator tents for both steam generators. His protective clothing included single PCs wet suit bottoms,andnegativepressurerespirator.Thehotparticlewasfound on the technician's back right shoulder and the licensee believes that it was probably deposited there during removal of the protective clothing. However, there is no firm data to indicate how the contamination occurred. The particle was removed with sticky tape and was kept for analysis (the particle was microscopic). A survey of the shoulder before removing the particle showed a count rate on the pancake probe that was offscale at 500,000 counts per minut The particle was measured on a gamma ray spectrometer and showed the following activities:

Ce-141 1.71E-2 uti Ce-144 2.18E-1 uti Ru-103 7.llE-3 uti Ru-106 2.10E-2 uCi

'ir-95 8.16E-2 uti Hb-95 1.56E-1 uCi

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To the above activities were added the daughter products Pr-144 and Rh-106, known to be in secular equilibrium with their parents Ce-144 and Ru-106, respectively. The total acti'!ity of the particle based on the gamma analysis was thus found to be 0.74 uC Initial dose rate estimates based on survey meter data on the hot particle gave a dose rate of 3.2 rads /hr. Since the exact time of contamination was not known it was assumed to be equal to the time interval from entry into the contamination areas until the time the particle was found. The technician turned on his air sampler (BZA 8:20 and it was estimated to take about 5 minutes to walk to the )

contamination area, giving an initial time of 8:25. The particle was found at 9:5 ,5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Thethe Using contamination initial dose duration was therefore rate estimate app / hr, theroximately of 3.2 rads skin dose is roughly 4.8 rad The hot particle was sent to Unit-2 for analysis in an attempt to estimate the content of strontium isotopes, particularly Sr-90 and its daughter product Y-90. The system used in Unit-2 is essentially a two channel analyzer the division between connected to a scintillation two channels detecto is set at 1.2 MeV. TheThemetiod enerS.ys based on the assumption that beta activity that is detected 4n channel 2 will be that from Y-90 beta rays (2.2 Mev endpoint). This has been found to be the case for many of the sam les taken in Unit- However, in the case of the hot p' article, many hi h energy beta emitters were present (Pr-144, 3 lev endpoint Rh 106 3.5 MeV endpoint).ThesehighenergybetaradiationsInvalidafethe assumptions on which the beta measurements were made. The tentative conclusion that was reached based on these measurements h thattherewasprobablynoSr-90activityintheparticle.owever,was The licensee felt that this conclusion was confirmed by the fact that Cs-137 was not sit 9cted in the hot particle. The licensee stated that Cs-137 and Sr-90 were normally found together and that the absence of the cesium suggests the absence of the strontiu Based on the above analyses and assumptions, the licensee performed a dose assessment in which the skin dose to the technician was estimated to be 5.624 rem. The method used for dose assessment was based on dose '

rate conversion data published in recent health physics literature (Kocher . This dose exceeds the GPUN administrative skin dose limit of 5 rem, a)nd the worker's access into the radiological controls areas was restricted. The licensee has reconsidered some of the assumptions used in this dose assessment, particularly regarding the absence of Sr from the particle. It was realized that the Cs-137 could have been in soluble form and may have been dissolved out of the particle before the contamination incident. The licensee has therefore not closed this incident and is considering alternative methods to determine if the particle contains Sr and if so, how much. This item will therefore be i

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left unnsolved pending completion of the licensee's investigation (289/88-19-02).

5.0 Exit Meeting:

The inspector met with licensee representatives at the end of the inspection on July 29, 1988. The inspector sumarized the purpose of the inspection and the inspection findings, l

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