IR 05000289/1990003
| ML20011E747 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/24/1990 |
| From: | Chawaga D, Pasciak W, Sherbini S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011E746 | List: |
| References | |
| 50-289-90-03, 50-289-90-3, NUDOCS 9002220373 | |
| Download: ML20011E747 (10) | |
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U. S. -NUCLEAR REGULATORY COMISSION
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REGION I
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t P9 port No.
50-289/90-03
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Docket No.
50-289
License No.. DPR-16 Licensee: GPONucletrCorporation I
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-P. O. Box 450
,RI3dletown, Pennsylvania 17057-l t
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Facility Name: Three Mile' Island Unit 1
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L Inspection At: Middletown, Pennsylvania
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Inspection Conducted: January 16-19, 1990
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s Inspectors:
MA k,7 U!90 D. Chawagai Radiation Specialist date
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Facilities Radiation Protection Section
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L A, f5 llZ7/rf o Senior Kldiation Specialist date.
5. Sherbini Facilitieskadiation-ProtectionSection i
Approved.byl /7/,
f&ro
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W. Pasciaki Chief, Facllities Radiation
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Protection Section
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. Inspection Summary: Inspection on January 16 19, 1990 (Report No. 50-289/90 03).
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1 Areas' Inspected: Routine unannounced safety ins >ection of the radiological
. controls program, includlng refueling outage wor ( and the status of previously
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identified items.
Results: Within'the scope of this inspection, no violations were identified.
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9002220373 900207
PDR ADOCK 05000289
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i DETAILS
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1.0 Personnel Contacted 1.1 Licensee Personnel r
- D. Etheridge Manager, Radiological Engineering, THI-l
- H. Hukill, Vlce President and Director, TMl-1
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- R. Rolph, Radiological-Assessor
- A. Palmer, Manager,- Radiological Controls Field Operations, TMI-l
- R. Shaw, Director, Radiological Controls, TMI-l
1.2 NRC Personnel i
R. Brady, Resident inspector
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- D. Johnson, Resident inspector
- T. Moslak, Resident inspector
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2.0 Status of Previously Identified Items 2.1 (Closed) Follow up Item 88-19 01 This item was opened in connection with the qualification of senior
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defined criteria regarding the mann(RCT). The licensee did not have clearlyer in Radiological-Controls Technicians toward classification as senior RCT. The licensee has subsequently
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developed a set of criteria for this purpose. The criteria were reviewed and were found to be clear and well defined and address the different possible types of experience. Although these criteria represent a substantial improvement,ideration. These include the following:the inspector stated that needed further cons is to be credited on a 1:gineering Laboratory Technician (ELT) in the Navy
. Experience gained as En
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1 basis with no tite limit for duties as
Radiological Controls Monitor during shipyard, overhaul, tender, and
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training. Other experience in the Navy is to be credited on a case by case basis. Current practice however, is to credit ELT experience on a 2:1 basis (oneyearofcredItpertwoyearsELT)withamaximumtimetobe credited for such experience.
. Ex)erience for jobs such as decontamination, count room technician, fris(ing/ laundry monitor dosimetry technician, and respiratory protection technicianistobecreditedona1:1basiswithamaximumofthreemonths in each of the above areas. However, on this basis, it would be possible to
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accumulate as much as 15 months of the minimum two years of required
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experience for senior RCT classification without performing work that is
most directly related to a senior RCT's duties.
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. There is no minimum amount of power plant experience specified in the i
experience requirements. This is contrary to current practice, which in
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some cases requires up to a minimum of one year of nuclear power plant
experience.
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. The procedures governing qualification of Radiological Controls Field l
9100 ADM 2622.01, ' Radiological Controls Field Operations personnel, Qualifications / Traininglso specifie
Operations Personnel has not been revised to l
reflect the new requirements. The procedure a i
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may progross from Technician C (entry level with no experience) technician A chnician B junior technicianj in three months and from B to
b(seniortechn(cian)inaminimumofoneyear.Theonlystatedrequirements
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for making the transitions is that the technician pass the required oral written, and practical factors examinations. Based on this progression, It
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would be possible to become a senior technician, starting with no (
experience or formal background in health physics, in 15 months. The
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h this may pkeartobethecase,itdoesnot licenseestatedthatalthoukisunlikel hat anyone would be able to pass i
occur in practice because i the required examinations in such a sho t period of time and without going
through a period of formal training, j
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The licensee stated that they will review these concerns and take t
app opriate corrective actions, it should be noted that the above concerns
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app y to the written policies specified in the licensee's memos, policy
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sta ements and procedures. In )ractice the licensee's senior RCTs have a level of ex,perience that puts tiem subs {antially above the levels at which i
the above items would be of concern. The resumes of all the senior
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contractor technicians hired for this outage (22) were reviewed during this
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inspection. It was found that they all had experience that exceeded the I
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ANSI Standard (ANSI N18.1-1971).
t 2.2 (Closed) fcellow Up Item 88 19-02 erformed for Thisitemwasokenedinconnectionwithadoseassessmentbyahot assigning a ski dose to a worker following contamination particle. The hot particle was analyzed on a gamma spectrometer and found I
to be a fuel fragment. The dose assessment was done using the results of j
i the gamma analysis. The licensee had concluded at that time that the i
ll particle probably did not contain any significant amounts of pure beta i
L emitting isotopes and that the dose assessment based on the gamma analysis L
was probabiy accurate. However, since there was no strong basis for the
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assumption of negligible pure beta emitter contribution to the dose, it was
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l decided to analyze the particle for such activity. The licensee has i
subsequently sent the particle out to be analyzed by a vendor. The results j
of the analysis showed that, although the particle did contain some pure
beta emitters, mainly strontium and its daughter yttrium (of the order of IE-3 uCi) the amount was relatively insignificant and did not substantially
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add to the dose already assessed on the oasis of the gamma analysis. The
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dose of record assigned to the contaminated worker will therefore not be
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changed as a result of the latest analysis results.
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3.0 Staffing for the Refueling Outage i
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Much of the needed radiological controls staff for the current refueling l
outage consists of house personnel partly the permanent Unit I staff augmentedbystafffromUnit2onlemporaryassignmenttoUnit1.The licensee has also instituted a novel' system of using cuxiliary operators to i
help man the access control point to the radiological controls areas (RCA).
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Also chemistr technicians are used to hel) operate the health physics
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counk room equ pment. The licensee stated 11at auxiliary operators and
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chemistry tech icians have a reduced work load during outages and therefore l
represent available technically trained personnel. The auxiliary operators were given training to prepare them to assist at the control point. The
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. training consisted of four hours of classroom and computer system
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instruction, and covered topics such as operation of the access computer
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system, issue of dosimetry and air samplers, dosimeters, and filling out source checking of survey
I instruments, adjusting setpoints on alarming I
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the various required forms and logs. The chemistry technician:, received a
similar period of training in the use of the various counting equipment
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used in the count room. Both the auxiliary o>erators and the chemistry
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technicians are meant to assist the health p1ysics staff in these duties.
They are not to perform these duties unless supervised by a health physics
technician. Observation of the auxiliary operators and chemistry
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efficiently and accurately.pection showed that they performed their duties technicians during this ins
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Their experience at these duties would also probably be of assistance to them during their regular duties because of the added perspective on radiological controls activities. The inspector
expressed some reservations concerning the brevity of the training period to prepare these personnel for their duties. However observations of the techniciansatworkdidnotprovideevidencetosubskantiatethese L
reservations.
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L Thelicenseehasaukmentedthehousestaffwith24contractortechnicians, 22 of which are sen or RCTs and 2 junior RCTs. A review of the resumes of the senior RCTs showed that they all exceeded the minimum qualifications
requirements. The licensee also verified their experience with previous employers.
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4.0 Audits and Assessments l
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The requirements for auditing the radiological controls function on site are specified in 1000-PLN-4010,0L "GPU Nuclear Corporation Radiation
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Protection Plan", Section 4.0 " Audits Reviews and Reports of the GPUN
Radiological Controls Program. AccordIng to this plan, the following A
levels of review are required:
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. The Radiological Engineering Section shall audit the program. No-frequency is specified for this function, nor are the areas to be audited
specified. This part is implemented by Procedu,'e 9100-ADM-1201.09, i
" Radiological Controls Internal Assessments". According to this procedure,-
the program is subdivided into 8 areas and at least one area is to be i
assessed every six months. This schedule provides for an assessment cycle
of about four years; that is, each area of the program is assessed once i
every four years.
The inspector expressed concern that a frequency of once every four years j
appears to be too long. The licensee stated that although the procedure
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calls for a minimum of one area per six months, they actually strive to complete an area every three months, giving an assessment cycle of two
years.
. The Plan calls for assessments to be conducted * on a continuous basis"
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and that the results of this activity are to be presented in a monthly
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report to the Director, Radiological and Environmental Controls, a
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corporate officer.
This function is being performed by the Radiological Assessor. The Assessor i
reports directly to the corporate Director and performs this assessment
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function for both Units 1 and 2.
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. The lan calls for a " system... to allow any individual to identify radiol!gical deficiencies and/or suggest improvements". This function is being implemented by"a number of procedures, including 9100 ADM-1201.01,
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" Awareness Reporting, which allows any worker to submit an awareness report that either presents a suggestion for improvement or a concern;
" Radiological Awareness Criti also requires ld and Radiological Incident kUes"[s to be generated l
9100-ADM-1201.01,
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critiques to be he epor and 9100-ADM-4241.05, following specified radiological incidents; ires reports to be generated
" Dosimetry Investigative Report" which requ worker. g incidents involving dosimeters and the assessment of dose to a followin
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. The Plan also calls for audits by the QA department as part of the corporate Quality Assurance Plan. The QA staff performs QA audits of the radiological controls program on an 18 month cycle which normally involves l
auditing one third of the program areas per audit, thus completing review of the program in three such audits.
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The Radiological Controls Department also conducts routine surveillances of an assigned radiological engineer tours the plant. In these surveillances,bserves work in progress,f specified areas of the plant and o posting housekeeping, and similar functions and provides a report o
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Selected reports generated by the above audit and assessment functions were reviewed. Awareness and Radiological Incident Reports were also reviewed.
Most of the reports were found to be of good quality and were being
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performed in accordance with the required frequencies. The inspector stated that the review system lacks a requirement for periodic assessments by an independent expert in the field. The licensee stated that the Plan did -
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in an contain a requirement for such an assessment in the past. However, had been i
effort to reduce dependence on outside consultants, this provision deleted. The licensee further stated that there are independent reviews
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being performed by corporate health physicists on a periodic but
non-routine basis. This function, however, is not required by any company
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policy or procedure. The licensee also stated that they depend on outside organizations for independent reviews such as the NRC the Institute For i
NuclearPowerOperations(INPO),theAmericanNuclearInsurers(ANI)and i
others.
5.0 Posting and Housekeeping
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Tours of the facility showed that general housekee)ing in the radiological
controls area was acceptable in most areas,iliary Buildin. Some locationswith tie po i
some areas in the 281' elevation of the Aux on this level showed isolated instances of peor housekeep ng, flowing fromsuch as tap and some items of protective clothing on the floor and wa er
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leaky components in contaminated areas to areas outside the roped-off i
contaminated areas.
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Posting of radiation and contamination areas and low dose areas was i
generally good. The postings were sufficient in number and clearly defined the posted areas. However, some posting inconsistencies were noted at the lower manway access points to both steam generators. These manways are accessed through two openings in the support pedestals of the steam generators. It was observed that for steam generator
'A', one access point in the 3edestal was closed by a wire mesh barrier and was posted as a locked ligh radiation area. The other access point was covered by a
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tem >orary enclosure with a door in that enclosure. The door was posted as a higi radiation area. Locked high radiation area conditions did not exist at cover was posted as a locked high radiation area.porary manway cover. The
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the manway because the manway was closed by a tem I
In the case of steam generator B', one access point was open and unposted, and the other access point, through the temporary enclosure, was posted as a locked high radiation area. The temporary manway cover was in place over the manway but
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the manway was not posted. The inspector stated that these postings were I
confusing'o1 the postings were probably due to the fact that work on -the and inconsistent. The licensee agreed and stated that the a
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steam gener rs had just been completed at the time of the inspection tour.
j and that the technicians had not had sufficient time to put up the proper.
postings. The licensee stated that postings should be updated more promptly and that they will ensure promptness in future activities.
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6.0 Dosimetry
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Observations during the tours indicated that workers were wearing their-dosimetry in the ) roper locations and the proper dosimetry was beino issued l
in accordance witi procedures and proper practices with one possible i
exce) tion. This was in connection with work that was observed during a tour of tie Containment Building. The work was being done on a platform.
constructed over the reactor head, and the workers were engaged in-disconnecting electrical connections from the reactor head. A review of the
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surveys for that job showed that the radiation field was coming from l
underfoot and that there was a fairly sharp dose gradient from the floor
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up, with-the highest dose beir.g at floor level and the dose dropping by a
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factor of about two at knee level. The workers, however had only chest dosimetry.Theinspectorstatedthatitappearedthatt$edosimeterswere improperly placed and that the current placement would not measure the i
highest dose to the whole body. The licensee stated that they had not i
supplied the workers with knee dosimeters because most of the work was done in a squatting position, which placed the chest dosimeters at knee level and thus measured the required dose. The licensee also stated that this
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question had been n ised several years ago by another NRC inspector and-that the inspector concurred with the licensee's practice. The inspector
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stated that the licensee should make a determination of the adequacy of the
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E current dosimetery placement. The licensee stated that they will provide
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i the workers with several sets of dosimeters at chest and knee levels to
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determine if knee dosimetry registers higher doses than the currently used i
p chest dosimetry placement.
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7.0 Survey Instruments The number of survey instruments available for issue at the access point to
the RCA were found to~t>e ade uate. Instruments are source checked before
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issue and at least once a da if they are in constant use. The source check l-is done using a source jig t at contains three small cesium button sources
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and that allows the instruments to be placed in a reproducible position for
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checking. One weakness that was identified during the inspection was that the source check jig allowed only one range of each instrument to be
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i checked...That range is usually the lowest range on the instrument or the
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cext higher range to that. The other ranges are checked.once every three E.
.inonths during the quarterly ~ calibration of the instruments., The inspector
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stated that there was concern that users of these survey instruments had no'
indication that-the higher ranges of their instruments were functioning-j
- properl. The licensee stated that users'of the instruments know that they
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.should et some indication on the instrument on any scale if the-field.is
E 'i suffici ntly high to register on that scale and that if no such indicationt
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"L is noted the user would not use the instrument. The licensse also stated-
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that they do havea source that can be used to check all the ranges on the
- survey instruments but that it was currently being used in Unit 2. They-also-stated that they will review this-concern and take appropriate action.
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p L-This item will be reviewed during a future inspection, j
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~4 8.0 Program Improvements The licensee has introduced a number of improvements in their program during this outage in an attempt to improve worker performance and to L
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assure. smooth' progress of work. These -improvements include the fc11owing:
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. Erection of scaffolding during the past outage-had been a problem because scaffolding work was not coordinated and the work crew was inexperienced.
Scaffolding work during this outage was more efficient and better planned, E
and the work crew was better trained.
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-. The licensee has issued two-way radios to the radiological controls supervisors and to. radiological controls technicians who are covering important jobs. The system is-equipped in a manner that allows easy ni clear communication, from anywhere in the plant,-including any area-within:
the Auxiliary and Containment Buildin s. The licensee stated that the radios have been found to be very hel ful-in quickly._ resolving any problems
the technicians may. encounter in the. ield:and often-without the need to
stop work,d stay times. The licenser stated that-the radios also-allowwhich may re-transit-an
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< supervisors to k.ep in constant touch with their technicians and to monitor-job progress. 'The health physics 1 staff can also tune in the channel used by operations and maintenance and can therefore keep informed on upcoming-
. activities in-these areas.
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-. The licensee has installed a video recorder system in the dressing area at the containment access point. The video plays continuously-and may be
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watched-while the workers put on their protective clothing in preparation for containment entry. The video shows proper practices to dress and
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W ress-and gives hints on how to avoid contamination.
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. The licensee is using-a laser video disk system to help in pre-job briefings. The inspector reviewed the system and found it to be of high
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quality and'to provide high resolution pictures of important work areas and
components. The system may be used to-visually walk the workers through the l
. plant. areas to reach their job: location and.to show them the components to
.be worked on and their incations.
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9.0 ALARA-t
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t The exposure goal for the upcoming 8R refueling outage is approximately 275 man-rem.- The major job classifications within this overall. goal are as follows:
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. Steam generator cold leg dams 35 man-rem i
. Steam generator plug removal
. Refueling
. Miscellaneous maintenance
. Reactor-Building platforms
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.: Steam generator tube' plugging
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. Steam generator feedwater nozzle replacement
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. Valve maintenance
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.. Reactor coolant pump seals
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.. Support (radiological, radwaste, operations
and surveillance)
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Total 273 man-rem
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The exposure for the remainder of 1990 non-outage operations is projected i
to be'4 man-rem per month,313 man-ren for 1990. The 1989 goalgiving a total of 40
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year, was 75 man-rem. Based on the currently available data, It appears
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that the actual exposure for 1989 will be significantly below'the goal.
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The source reduction measures that have already been implemented include s
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. Partial replacement of fuel bundles with low cobalt bundles.
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'mprove procedures for maintenance of stellite valves to minimize
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e, it'.roduction of-foreign material into the system.
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. Use of high pH chemistry for the-primary coolant system. The pH-L currently in use is 6.9. Improved water chemistry is also being used in the secondary Gide of the system.
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. Consideration is being given to the dose-savings that;may be
'o realized from a prolonged (24 month) cycle.
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..Radwaste volume reduction efforts are being implemented, j
In addition' to th'e above, a " Cobalt Reduction Manual"'is being used by-3' '
- Technical Functions as guidance. in:an effort to convert to low cobalt or-
. modified. The'ys whenever a component is to be ' installed maintained, orstandard
. no-cobalt allo
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use of alloys in any such activities to ensure.that attempts have been.made
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K At the time of this ' inspection, the outage was in the early stages and most-
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of the work' remained to be done. It is therefore too early to determine-l L"
~ whether the established goals will be achieved. Performance during.this outage will therefore be reviewed during a future inspection.
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t 10.0 Exit Meeting
L Tha' inspector met with' licensee representatives on January 19 1990. The.
inspector reviewed the purpose and scope of the inspection and discussed
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