IR 05000289/1990016
| ML20059E325 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/23/1990 |
| From: | Chawaga D, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059E317 | List: |
| References | |
| 50-289-90-16, 50-320-90-07, 50-320-90-7, NUDOCS 9009100142 | |
| Download: ML20059E325 (8) | |
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i U.S.-NUCLEAR REGUIATORY COMMISSIONc
REGION I
Report No.
50-289/90-16 50-320/90-07 Docket No.
50-289 50-320 l
License No.
DPR-50 E
PPR-73 I
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i Licensee:
GPU Nuclear-Cornoration P.
O.
Box 480 j
Middletown. Pa 17057
Facility Name:
Three Mile Island. Units 1 and 2 I
Inspection At:
Middletown. Pennsylvania
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Inspection Period
&ggust. 6-10. 1990.
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bm8 de 2h Inspector:
D. Chhwaga, Radiation Specialist,
'Date l
Facilities Radiation Protection Section L
L Approved by:
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W..PascIER, Chief, Facilities Radiation batd Protection Section Inspection Summary:
Inspection on August 6-10, 1990 (Report No.
50-289/90-16, 50-320/90-07)
Areas Insoected:
The inspection was a routine, unannounced radiological safety inspection of the licensee's radiological controls program with: respect.to the following elements:
corrective actions relating to NRC follow-up' items,. organization and staffing, applied health physics, Radiological' Occurrence Reports, and general control of the plants' radiological L
environment.
Results:
Within the scope of this inspection, no violations were
identified.
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9009100142 900824 PDR ADOCK 05000289;.
O PNU.
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DETAILE 1.0 Persons Contagind 1.1 GPU Nuclear Personnel R. Shaw, Director, Radiological Controls
- D. Ethridge, Manager, Radiological Engineering
- D. Baldwin, Group Radiological Controls Supervisor A. Paynter, Radiological Controls Field Operations Manager, Unit II
- R. Wells, Licensing Engineer
- P. Velez, Radiological Engineer J. Stein, Radiological Controls Technician 1.2 NRC Personnel
- D. Beaulieu, Resident Inspector D. Johnson, Resident Inspector
- Denotes attendance at the exit meeting.
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2.0 Purpose
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The purpose of this inspection was to review the licensee's radiological controls program with respect to-the following elements:
corrective actions relating to NRC follow-up items, organization and staffing, applied health physics, Radiological Occurrence Reports, and general-control of the plants' radiological environment.
3.0 Status of Previously Identified Items 3.1 (Closed) Follow-un Item 50-320/89-09-01'
This item was opened based on the licensee's failure to properly notify the-Nuclear Regulatory Commission (NRC) of personnel overexposure to radiation.
The applicable notification requirements are delineated in 10 CFR 20.403
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(b).
This incident resulted in the issuance of an NRC I
Severity Level IV violation.
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j In a retrospective analysis and reply to this violation, GPU Nuclear personnel determined that 10 CFR 20.403 requirements
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could have been considered applicable earlier in the post-
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incident investigation.
GPU Nuclear attributes the failure to make formal report to the NRC to both.the complexity of-the dose assessment process and their limited experience with 10 CFR 20.403 interpretation.
In the early stages of the dose assessment process, uncertainty in calculational assumptions made it difficult
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for GPU Nuclear personnel to determine if extremity exposures would exceed 75 ren.
The situation
' the criteria as established in 10 CFR 20.403 which, an part, requires NRC notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when licensed i
material may have caused or threatens to cause an extremity exposure in excess of 75 rems of radiation.
The licensee notified the Resident Inspector as soon as the incident was discovered but failed to submit a timely formal report to l
the NRC Operations Center.
GPU Nuclear informed the NRC that in the unlikely event of recurrence, a formal report would be effected much earlier and in accordance with
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regulatory requirements.
Station management appears well
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informed regarding the proper interpretation of 10-CFR-
20.403 at this time.
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.Th s item is closed.
si 3.2 (Closed) Follow-un Item 50-320/89-09-02 This item was opened as a' result of the licensee's failure I
to maintain personnel radiation exposures in accordance with the limits established in 10 CFR 20.101.
After an extensive
review, GPU Nuclear personnel determined that the personnel radiation exposure limits contained in 10 CFR 20.101 were exceeded at the TMI-2 facility on September 25, 1989.
This
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unplanned exposure occurred when two personnel unknowingly handled a highly radioactive fuel fragment.
Final calculations estimated the highest extremity exposure at 55 rem.
GPU Nuclear has taken actions to improve planning, preparation, control and oversight of radiological work s
activities, improvements in the physical work environment, and work party communication with Radiation Protection personnel.
These corrective actions are detailed in the
" Licensee Presentation at Enforcement Conference" found as an enclosure to the memorandum from the Regional Administrator, Region 1~to the Director of Enforcement dated December 12, 1989.
The memorandum states that the corrective actions presented at the enforcement conference were adequate.
During the course of this inspection, the inspector found no indication to the contrary which could result in recurrence.
This item is closed.
3.3 (Closed) Follow-uo Items 50-320/89-13-01 and 50-320/89-13-02 Follow-up Item 89-13-01 was opened based on the licensee's failure to comply with 10 CFR 20.201(b) which requires, in part, that each licensee shall make or cause to be made such surveys as may be necessary and reasonable to assure compliance with the requirements of 10 CFR 20.
On November
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28, 1989, a hose end fitting was removed from the Unit 2 reactor and handled by two technicians prior to radiological survey.
Although regulatory limits were not exceeded, the incident resulted in an unplanned radiation exposure to one
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of the technicians.
This incident resulted in the issuance of an NRC Severity Level IV violation.
Peripheral program weaknesses were found as a result of the reactive inspection initiated to investigate this incident.
Resolution of these weak areas, which contributed to the occurrence of this violation, is the subject of Follow-up Item 89-13-02.
GPU Nuclear concurred with the violation and has implemented adequate corrective actions in response to this incident.
Work was stopped in the Reactor Building pending a review of the event and corrective actions to prevent recurrence were implemented.
A training program was implemented to increase worker awareness regarding identification of unsafe radiological conditions.
The training included a practical factors demonstration of techniques to be used and actions to be taken when uncontained reactor internals debris is encountered.
This training is mandatory for all reactor building personnel.
One-on-one management meetings were held with all Radiological Controls personnel regarding the proper handling of material containing fuel debris.
Disciplinary action has been taken against the Radiological controls Technician (RCT) involved in the incident and all other RCTs have again been instructed on the importance of performing radiological surveys prior to handling material removed from the reactor.
The inspector considers the r
j actions taken by GPU Nuclear to be adequate and l
comprehensive.
These items are closed.
4.0 Oraanization and Staffina
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The Radiological Controls organizations at TMI 1 and TMI 2 are now consolidated into one organization.
This transition was extensively planned and analyzed prior to a gradual implementation process.
As a result, a smooth transition was accomplished.
Under the new organization, the Director of Radiological Controls is responsible for all functional health physics areas for both units.
These areas include:
whole body counting, radiological engineering, respiratory protection, dosimetry, field operations, transportation, etc.
The Director also oversees non-radiological industrial safety efforts at both units.
The current Radiological Controls organization is well staffed and appears to be effective.
The inspector identified no weaknesses in this
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5.0 Applied Health Physics
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-S.1 Radiation Work Permit (RWP)-and ALARA Review Process
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l The inspector reviewed 15'RWP packages'for. completeness,
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legibility and adequacy of radiological controls.
Each L
package U.s'found to be adequate and in accordance with L
ste. tion procedures, i
The inspector noted that RWPs may require beta protection:
i for the lens of the eye.
The use of safety glasses and respirator facgpieces which hava a density-thickness of less than 700 mg/cm are often considered acceptable by the:
y licensee for this purpose.
The-licensee informed the
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inspector that beta dose equivalent is: recorded by -
thermoluminegcent dosimeters:(TLDs) at a density thickness.
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r of 300 mg/cm.
If an ALARA evaluation indicates'the need.
for greater beta' protection or if the ligensee wishes to record the dose equivalent at 1000 ag/cm, the eye is
protected with a minimum density thickness of 700;mg/cm,
The licensee has evaluated the density thickness of many.
types of protective clothing.and has-incorporated a table of
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these values in the RWP procedure.
The procedure also includes " Percent Beta Transmission vs. Density 1 Thickness" graphs.for TMI l-and,TMI 2 reactor facilities.
- l The inspector did not identify. any weaknesses specific 'txt the RWP program or ALARA review. process during the course of i
this inspection.
5.2 Radiation Surveys The inspector reviewed several radiological surveys of both reactor facilities.
survey results were' generally observed to be complete-and legible.
The sample of surveys reviewed indicated that radiological conditions on temporary scaffold platforms are not routinely documented.
Notification'of the Radiological Controls Department is not required prior to-
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accessing these scaffold areas.
However, notification is=
required for climbing elsewhere.in the overhead of the RCA.
In discussions with licensee representatives, the inspector expressed concern that personnel could enter these infrequently surveyed areas without adequate knowledge of current radiological conditions.
During the current y
inspection, the inspector did not observe personnel working
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on any of the scaffold platforms:within the RCA.
The method
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for informing workers of radiological' conditions in these areas will be reviewed during future inspections.
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6.0 Portable Survey Instruments
Instrument calibration practices and procedures were reviewed by.the inspector.. Direct observation of calibration practices and a documentation review did not
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l-reveal any technical or programmatic weaknesses.
The calibration facility appeared organized and well equipped.
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The inspector selected (8) survey instruments and, with.the
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assistance of a Radiological Controls Technician, performed
a field response check of precision between instruments.
Instrument detector types included (4) ion chambers, (2)
extendable Geiger-Mueller (G-M) tubes, and (2) " hotdog" G-M
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tubes.
The instruments exhibited similar photon response
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characteristics when placed.in radiation fields inside the-i'
RCA.
The licensee was provided with the results of this test.
All instruments available for field use at the health
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physics control point were found to have current source check and calibration labels attached to them.
The licensee has recently initiated for portable-instruments a daily source check practice which evaluates response on all scales.
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7.0 Radioloalcal Occurrence Reports (RORs)
i The inspector reviewed the licensee's ROR program.which provides criteria for identification of significant radiological events and implementation of corrective action related to those events.
All RORs for the year of 1990 were reviewed-by the inspector.
Observations made-by the inspector indicate that the licensee has developed an effective system.
In the RORs reviewed, descriptions of t
events were recorded in adequate detail and specific corrective actions were unambiguously assigned to responsible. individuals.
The inspector's investigation of one ROR (90-0508) resulted-in the finding of a program weakness.
Three personnel received a radioactive iodine uptake during the removal of a lower steam generator manway cover.
The inspector calculated the exposure for one individual to be 43.6 MPC-
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hours based on whole body count results and.ICRP-2 l
methodology.
However, the input to the access control computer was based on air sample results and. indicated that the individual had received 9.76 MPC-hours.
A review of the individual's official dose records indicated that the whole body count results had been used and that the individual had been correctly assigned 43.6 MPC-hours.
The inspector
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expressed concern regarding the availability of misleading personnel exposure data for use by the Radiological controls personnel.
The licensee will review the process for updating internal dosimetry information on the Radiation Exposure Monitoring System.
This issue will be reviewed in future inspections.
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8.0 Source Tara Reduction l
GPU Nuclear has developed Source Reduction Programs at the oyster Creek and Three Mile Island facilities.
Current projects at TMI include reductions in the use of high cobalt containing components, elevated lithium and pH levels in the reactor coolant system, fission product vs. activation product characterization. studies-and reduction.in. letdown
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filter pore size.
Hot spot and contaminated area reduction efforts are coordinated.under a separate program.
Licensee personnel informed the-inspector that the station is committed to effective source reduction as an important
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method for lowering future personnel exposures.
9.0 Tour of the Radiolocical Controlled Area (RCA) in Unit 1
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The inspector toured the RCA accompanied by a Group Radiological Controls Supervisor (GRCS).
Housekeeping was well performed in all areas inspected.
Radiological postings were clear and concise.
Radiological boundaries were apparent and well defined.
Some temporary shielding installations were observed in the course of the inspector's tour.
Those shielding installations observed were well secured and adequately posted.
In summary, the physical controls established for radiation protection in Unit 1 were observed to be well maintained and appeared effective.
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10.0 Tour of the Radioloaical Controlled Areas in Unit 2 In a tour of the RCA of Unit 2,.the inspector observed no items of noncompliance with regard to postings, boundaries
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and other physical radiological controls.
The inspector noted that lead blankets are extensively used as. shielding throughout the facility.
The shielding installations
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i observed appeared to be well secured and posted with the requirement to contact Radiological Controls Department prior to removal.
Housekeeping practices in Unit 2 were generally poor in comparison to Unit 1.
Several areas were observed to have protective clothing and trash scattered on the floor.
The inspector noted that, although housekeeping practices could
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be improved, no areas exhibited.significant degradation of radiological controls.. Poor housekeeping practices often.
indicate improper attention to detail and could impact the maintenance of adequate radiological controls.
Progress in this area will be reviewed-in future inspections.
11.0 Exit Meetina
A meeting was held with licensee representatives at the and of this inspection on August 10, 1990.
The purpose and scope of the inspection were reviewed and the findings of-
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be improved, no areas exhibited significant degradation of radiological controls.
Poor housekeeping practices often indicate improper attention to detail and could impact the!
maintenance of adequate radiological' controls.
Progress in
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this area will be reviewed in future inspections..
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11.0 Exit Meetina A-meeting was held with licensee representatives at the end of this inspection on August 10, 1990.. The purpose and-scope of^the inspection were reviewed and the findings of the inspection were discussed.
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