IR 05000320/1981003
| ML20009B127 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/05/1981 |
| From: | Barley W, Conte R, Fasano A, Shanbaky M, Shanbaky W, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20009B116 | List: |
| References | |
| 50-320-81-03, 50-320-81-3, NUDOCS 8107140829 | |
| Download: ML20009B127 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
0FFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-320/81-03
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Docket No. 50-320
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Category c
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Licen' e No.
DPR-73 Priority s
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Licensee: Metropolitan Edison Company P.O. Box 480 Middletown, PA 17057 Facility Name: Three Mile Island Nuclear Station Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: February 25 April 3, 1981 Inspectors: M.[
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N M. ShanbaYy, Senior Ra#ation Specialist date signed
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SO Y arfLw AI.2'7N I W. Barley, Radiation Sjecialist date signed W
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R. Conte, Senior esident Inspector, TMI-2 datt signed-L &
66, L. ~~nonus, adiation Specialist date signed Approved by:
(to m J SIf/P/
A. Fasand, Chief, Three Mile Island Resident d&te' signed Section Inspection Summary:
Inspection on February 25 - April 3,1981 (Inspection Report No. 50-320/81 -03).
Areas Inspected: Special inspection by 4 resident inspectors of licensee action on previous inspection findings in the following radiological controls
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areas: management commitment in support of the radiation safety program;
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organizational structure; technical depth of the radiation safety program; training; audit program; preparation and implementation of procedures; external dosimetry; internal dosimetry; instrumentation program; radioactive material shipping; decontamination; and, ALARA (as low as reasonably achievable) program.
ihe inspection involved 189 inspector-hours by 4 resident inspectors.
Results: No items of noncompliance were identified, however, of the 28 previous inspection findings; 3 findings remain open and 12 new findings were identified.
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Persons Contacted General Public Utilities (GPU) Nuclear Group
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R. Arnold, Chief Operating Executive
- J. Brasher, Radiological Controls Manager, TMI-2
- J. Chwastyk, Plant Operations Manager, TMI-2 P. Clark, Deputy Chief Operating Executive
- R. Fenti, Quality Assurance Audit Supervisor
- R. Heward, Director Radiological and Environmental Controls
- J. Hildebrand, Manager Radiological Health, TMI-2
- C. Kimball, Quality Assurance Auditor
- L. King, Director Plant Operations, TMI-2
- T. Mulleavy, Manager Radiological Controls Training, TMI-2
- R. Perry, Dosimetry and Bioassay Manager, TMI-2
- J. Renshaw, Manager Radiological Field Operations, TMI-2
- P. Ruhter, Manager Radiological Technical Support, TMI-2
- R. Swartzwelder, Licensing Engineer, TMI-2 J. Thorpe, Chairman, General Office Review Board
- denotes those individunis at the exit interview.
The inspector contactea other licensee and contractor employees including members of the radiological controls, operations, and quality assurance staffs.
2.
Licensee Action on Previous Inspection Findings *
By mid-September 1979, uncertainty of the adequacy of the Radiation Safety Program at TMI prompted the Director of the Office of-Nuclear Reactor Regulation (NRR), NRC, to create a special panel to provide an independent review of the Radiation Protection Program at TMI. As a result of the report of the special panel (NUREG 0640),
the licensee developed the TMI-2 management plan which identified actions to implement the recommendations of the NRC Special Panel, i
Five status reports on the progress made to upgrade the Radiation Protection Program at TMI were submitted to the NRC.
Office of Inspection and Enforcement Inspection (Report No. 50-320/80-16),
conducted during the period September 15 - October 27, 1980, documented the status of the close out of licensee commitments made as a result of the special panel review.
Twenty-eight items were left open from that report.
In a letter dated February 24, 1981, from R. Arnold, GPU, to H. Denton, NRR, the licensee presented an updated status of fulfillment of the associated management plan commitments.
The status of the open items were reviewed during this inspection period through the conduct of interviews and a review of documents.
Selected sections of the following documents were reviewed in detail along with various other implementing procedures to verify comitments made by the license _
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4002, Revision 0, January 6, 1981, Records Retention;
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4005,. Revision 0, May 12,1980, Radiological Investigative Reports;
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4006, Revision 2, December 30, 1980, Radiological Deficiency -
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Reporting and Reduction; 4010, Revision 2, February 12, 1981, Department Organization
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and Responsibilities;
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4100, Revision 0, December 19, 1980, Radiological Surveys;
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4102, Revision 0, December 16, 1980, Radiation Surveys;
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4103, Revision 1, March 2,1981, Surface Contamination Surveys;
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4122, Revision 0, December 5,1980, Radiation Work Permit;
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(Draft) GPU Nuclear Organization; and,
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(Draft) Job Descriptions for various members of the TMI-2
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Radiological Controls Department.
Interviews were conducted with the following personnel:
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Chief Operating Executive
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Deputy Chief Operating Executive
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Director Radiological and Environmental Control
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Manager Environmental Control
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Chairman General Office Review Board
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Radiological Controls Director, TMI-2
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Manager Radiological Technical Support, TMI-2
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Manager Radiological Health, TMI-2
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Manager Radiological Training, TMI-2
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Manager Radiological Field Operations, TMI-2
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Senior Project Coordinator Radiological Controls, TMI-2
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Radiological Engineers / Staff Assistants and Associated
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Supervisors (16)
Radiological Controls Technicians / Foreman (16)
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-4-Details on the status of each item are noted in paragraphs 3 through 14. A summary open/ closed status is given below:
320/80-16-01 ' Closed 320/80-16-15 - Closed l
320/80-16-02 - Closed 320/80-16-16 - Open i
320/80-16-03 - Closed 320/80-16-17 - Closed 320/80-16-04 - Closed 320/80-16-18 - Closed
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320/80-16-05 - Closed 320/80-16-19 - Closed 320/80-16-06 - Closed 320/80-16-20 - Closed 320/80-16'-07 - Closed 320/80-16-21 - Closed 320/80-16-08 - Closed 320/80-16-22 - Closed 320/80-16-09 - Closed 320/80-16-23 - Closed
320/80-16-10 - Closed 320/80-16-24 - Closed 320/80-16-11 - Closed 320/80-16-25 - Closed 320/80-16-12 - Closed 320/80-16-26 - Closed
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320/80-16-13 - Open 320/80-16-27 - Closed 320/80-16-14 - Closed 320/80-16-28 - Open 3.
Management Commitment in Support of the Radiation Safety Program The panel confirmed a serious morale and attitude problem in the Radiological Controls Department.
Both operations and radiation
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safety personnel characterized personnel in health physics organ-ization as being treated as second class citizens.
Further, the first line radiation safety foremen were not convinced they had the
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manageme'nt support to stop operations in the interest of worker
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safety.
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The licensee's management plan, dated April 15, 1980, committed to the below listed actions to be taken.
Status as noted by the NRC was also listed.
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a.
Policy Statement Session
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The licensee reported that on November 3,1979, a meeting was held by the Chief Operating Executive with TMI managerial and
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line supervisory personnel to reiterate the licensee's strong comitment to achieving a high quality Radiological Control
Program.
Compliance with the program and the program's stop work authcrity were discussed.
The licensee also reported i
subsequent sessions were conducted in October 1980.
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The NRC assessed the effectiveness of these measures within
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the Radiological Controls Department through the conduct of interviews (320/80-16-01).
All department technicians inter-viewed indicated that they had the authority to stop work for radiological safety concerns and that with respect to this
authority, there was management support for those actions.
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The licensee apparently turned around the second class citizen concept.
The technicians reported several occassions where their authority was actually exercised.
Therefore, this area (320/80-16-01) is considered < ise.
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Although operations personnel were not interviewed it appeared
. to the inspector that the radiological control program could
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- be properly enforced by the shift health physics personnel.
Inspector observations at selected licensee " plan-of-the-day"
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- meetings indicated that there was cooperation between non-
. radiological department personnel and radiological controls department personnel, at least at the supervisory level.
The interfacing of all departments to the Radiological Controls Program continues to be reviewed by the NRC with respect to the licensee's reorganization to the GPU Nuclear Group / Corporation
" it effects TMI-2 cleanup activities.
However, the interviews in the Radiological Controls Department also indicated an apparent attitude problem for different reasons.
Two areas were noted by technicians as affecting job i
satisfaction.
One is the procedure control system and the other is management responsiveness to problems identified by technicians. With respect to the latter, apparently management response to Radiological Deficiency Reports (RDR) and/or memoranda of suggestions had not yet reached the technician i
level at the time of the interviews. There was also some l
discord with respect to the adequacy of management response on
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_one or two isolated RDR's which apparently were still under discussion within the department.
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In the area of procedure controls, the licensee had department personnel sign statements of " verbatim compliance with department procedures".
Concurrently or shortly thereafter many Radiological
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Controls Department procedures were issued where in some j
instances verbatim compliance was not possible or the procedural
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workload of shift health physics personnel was significantly increased and this apparently conflicted with job coverage.
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Specific procedural problem areas were noted in paragraph 8.a.(2).
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-The licensee's management apparently recognized the problem in this area and issued an explanatory memorandum (TMI-II-R-12709, dated February 4,1981) which encouraged the use of the temporary change method to get minor problems corrected rather
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than using the revision system which required pre-implementation
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approvals.
Even in this temporary change effort the technicians l
were met with an obstacle.
The operation shift foremen were i
reluctant to give approval in light of the issues being j
outside of the individual's expertise and department.
In'sumary, the area of inter-department and intra-department i
interfacing / working relationships remains open pending further NRC assessment to assure no adverse affect on the proper implementation of the Radiological Controls Program (320/81-03-01).
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Restructure of the Radiological Controls Department
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Inspection report 50-320/80-16 confinned that the Radiological
' Controls' Department was restructured to corporate reporting status similar to the Quality. Assurance Department. Although
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Revision 2 to Procedure 4010, Unit 2. Radiological Controls Department Organization, was issued on February 28, 1981, the same corporate reporting status was maintained. The inspector had no further connents in this area.
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c.
Radiological Assessment-
- d The licensee further committed to establish a radiological assessment group to independently monitor progress in implementing
.and adhering to a strong radiological control program.
Presently Three Mile Island (covering both units)y one individual at this assessnent function is performed b This individual's
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independence is assured by reporting directly to the Director for Radiological and Environmental Controls (a Vice President position in the GPU Nuclear Corporation) as noted in a department
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organization chart dated February 2,1981, and in a draft GPU
i Nuclear Organization Plan.
Therefore, the establishment of a radiological assessment group (320/80-16-02) is considered
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closed.
Based on an interview with the assessor it appears this
individual is knowledgeable of job responsibilities and the individual has stop work authority.
However, the inspector noted that a formal system of. tracking the assessor's findings did not exist.
TL Director of Radiological and Environmental Controls indicated tt.it the assessor was not responsible for
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closing items but was management's " eyes and ears" on radio-
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logical matters.
Findings would be screened by the Director /
Vice President had if applicable or warranted, would be
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forwarded.to the applicable unit radiological controls manager for action.
These items, if requiring long term action, would be put on a department action item list if warranted.
In light of the lack of a formal tracking system for correction and trending of the assessor's findings NRC review of the radiological assessment group's effectiveness will continue
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(320/81-03-02).
d.
Radiation Protection Plan Management connitment in support of a sound radiological control program is also reiterated in the Radiation Protection h
Plan approved by the NRC on Mard 5,1981, pending incorporation of minor comments to the plan.. This' area is considered closed
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.(320/80-16-03).- NRC verification of incorporation of above
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minor connents in the Radiation Protection Plan is considered
. open (320/81.-03-03).
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On-the-Job Supervision To provide additional support and direction for radiological control technicians working in the field, health physics (HP)
shift foremen were assigned solely on-the-job supervisory duties.
The interviews conducted by the NRC supported the above and therefore this area (320/80-16-04) is considered closed.
However, two fsctors were noted to be apparently distracting HP shift foremen from this primary objective.
One is the recent additional administrative tasks assigned through procedures associated with some of the procedural problems noted in paragraph 8.a(2). The other is recent NRC observatit ;
of operational pressures in conjunction with reactor building entries.
In one inst-nce during a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period before a reactor building entry, the Radiation Work Permit (RWP) for the entry was not prepared until later in the day.
Further, tM catry was obviously capturing all of the HP shift foreman's attention.
In this instance the particular foreman did indicate the job would be stopped if it was not done right or if excessive operational pressure was being exerted.
In light of the above, the NRC will review this area to assure administrative radiological controls and certain operational pressures are not adversel
. performance (320/81-03-04)y affecting supervisory and technician
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Establishment of a Supervisory and Management Development Training Program As of the fifth Quarterly Progress Report (QPR) no action had
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been initiated to establish a Supervisory and Management Development Training Program.
This area was considered open (320/80-16-05) pending completion and implementation of a Supervisory and Management Training Program.
Through discut: ions with licensee representatives and review of records, the inspector verified that plans have been formulated for a supervisory and management training program to be conducted by th* iII-l Training Organization.
The Radiological Controls hpartment supervisors and managers are to be placed in these training progran's as cpenings become available.
In the interim, the management and supervisory personnel are in the process of completing a management correspondence course from the TMI-l Training Organization.
The establishment of a Supervisory and Management Development Training Program (320/80-16-05) is considered closed.
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In sumary the actions taken by the licensee as noted in paragraphs 3.a N'
through 3.f are indicative of the licensee's management commitment l
in support' of the Radiological Controls' Program.
However, the
. specific problem areas noted appear to be the result of an expanding
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department achieving a relatively new status within the organization.
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- The specific opea areas will be monitored by the onsite NRC staff
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to. assure no adverse effect on Radiological Controls Program implementation..
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4.
Organizational Structure The panel observed a.high degree of uncertainty regarding responsi-bilities, function, assignments and lines of authority, e.g. radio-logical engineering functions.
The licensee's management plan,' dated April 15, 1980, con iltted to
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the below listed actions to be taken.
Status as noted by the NRC was also stated.
a.
Department Reorganization
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i The TMI-2 Radiological Controis Department was reorganized
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with the chain of command and major area responsibilities i
delineated in Procedure 4010, Department Organization, Revision 2,
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issued February 28,'1981.
This procedure maintained the corporate reporting structure but it. fused the major areas of dosimetry and radiological support services under the Radio-
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logical Health Manager.
Other areas addressed include Radiological
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Technical Support, Radiological Field Operations, and Radiological l
Training.
The Manager of TMI-2 Radiological Controls Department
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and two other managers in these major areas were hired since
the panel's review. These managers work for GPU with all GPU Department i
and contractor p(ersonnel reporting to these managers.
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reorganization 320/80-16-06) is considered closed.
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Detailed delineations of job responsibilities and job quali-
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fication for all department personnel are listed in draft Job Descriptions and Position Specifications.
In general, personnel
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interviewed were knowledgeable of their responsibilities, however these documents are under review of licensee's Personnel Department and therefore were not formally approved as yet.
The licensee *s status report of February 24, 1981, indicated that these documents were completed by February -11,1981, but this was later clarified verbally by. the licensee representative in that the Job Description / Position Specifications were l'
completed from the Radiological controls Department point of view.
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-g-Further, during the last quarter of 1980, the TM.-i Health Physics Evaluation, Inspection Report 50-289/80-22,and subsequent management meeting, documented in Combined Inspection Reports 50-289/80-32 and 50-320/80-21, identified. that many support functions for TMI-1 Radiological Controls we,e oerformed by the TMI-2 Radiological Controls Department.
Examples of these support functions are Respiratory Protection, Dosimetry and, the Bioassay Program.
It was determined that interfacing responsibilities between the units was not clearly delineated.
Further the special panel finding in this area was reiterated in that the 1ntra-department (TMI-2) responsibilities were not clearly defined down to non-supervisory level personnel.
As a result, on December 17, 1980, in the management meeting the. licensee indicated that the following documents will address organizational structure, delineation of job responsi-bilities, qualification and training requirements for job types and unit interfacing responsibilities including the corporate element:
GPU Nuclear Organization Plan;
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Department Plan Organization;
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Program Responsibility Document and Personnel Chart;
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TMI-2 Radiological Controls Department Procedure 4010,
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Department Organization; Position Specifications; and.
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Training Department Manual.
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Aside from Procedure 4010, and the Training Department Manual, the other documents, in general, were drafted and were in various stages of approval.
In a subsequent response, dated February 2,1980, to Inspection Report 50-289/80-22, the licensee indicated that the position specifications will be issued before August 21, 1981.
The licensee representatives verbally indicated that the remaining documents will be issued prior to that date with priority given to Unit 1 restart items.
This area (320/81-03-05) is considered open pending (see also paragraph 5):
Licensee approval and issuance of all of the above noted
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documents; and,
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Consolidated NRC review of the above noted documents to assure all documents once approved, are consistent with each other and adequately address department interfacing responsibilities.
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Use of Only Trained Radiological Control Technicians In the management plan the licensee committed to use only trained radiological control technicians to provide radio-logical control coverage for work at TMI-2.
In the past operations personnel were utilized to perform radiological control functions during outages to alleviate manpower shortages.
Based on a review of licensee's organizational documents and conducted interviews, no instances were noted where the organization plan and/or implementation called for the use of personnel other than radiological control technicians to cover radiological work at TMI-2.
Examination of the licensee's training records showed that radiological control foremen / technicians have successfully completed a training course.
The inspector verified that Radiological Control Procedure (RCP) 4022, Revision 0, December 16, 1980, Radiological Control Personnel Qualification /
Training Standard, formalized the training program for radio-logic..1 control formen/ technicians.
RCP 4022 has been reviewed and a iproved and this item (320/80-16-07) is considered closed (see.tiso paragraph 6.a).
In summary with respect to the Radiological, Controls Department the licensee has gone from a book of memoranda in the HP Office and majority of contract personnel to a set of controlled department procedures and GPU management / supervision of contractor personnel.
Considerable progress was noted in the delineation of Radiological Controls Department organization structure.
5.
Technical Depth of the Radiation Safety Program The panel noted that professional input for the Radiation Safety Program was lacking.
The licensee's management plan, dated April 15, 1980, committed to the actions below as it related to a recruiting program for supervisory / technical expertise.
Status as noted.by the NRC was also listed.
The licensee representative believed sufficient professional depth was always available to TMI-2 and indicated the problem was a-matter of coordination and management of activities.
However, a Recruiting Program was initiated as a result of the panel cormient.
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The licensee reported in a letter, dated February 24, 1981, to the Director of NRR that although the number of personnel listed in the original management plan commitment was not achieved, the overall
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objective of reinforcing the Radiological Controls Program with sufficient professional depth was accomplishe _
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It was further reported that all management positions in the.TMI 2 f
Radiological Controls Department down to third tier were filled by
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company personnel except as follows:
Field Operations Deputy j
- Manager and Radiological Engineering Manager. These exceptions t
were contractor personnel. The licensee reported this organizational
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set up still permitted the department to carry out required i
responsibilities.
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Thereforethisarea(320/80-16-08) is considered closed.
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- Inspection ' Report 50-320/80-16 considered this area open pending l
NRC review of qual.ification records for existing personnel and i
assessment.of staffing levels to meet the cleanup efforts of l
j TMI-2. With respect to the latter the _ licensee is in a reduced j
workload mode as of November 1980 due to financial considerations.
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I Therefore, manning requirements are at a minimal level (approximately f
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110-120 people in TMI-2 Radiological Controls Department).
The licensee's management recognizes that any increased efforts with i
respect to TMI-2 cleanup evolutions will be limited by how fast the i
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TMI-2 Radiological Controls Department can set up to cover increased
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radiological work. One aspect is to acquire additional technicians
(primarily) and engineers to cover this. increased radiological work l
activity in light of the present commitment to utilize only trained i
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technicians to cover radiological work.
In addition to the acquisition -
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.of personnel, the department will be faced with assuring these
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department individuals meet qualification / training standards.
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Further training will be needed for new radiological workers when
additional personnel are needed.
This area is to be reviewed by
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i NRC (320/81-03-06).
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Although time did not permit a detailed review of personnel quali-
firstian records during the course of this inspection, a related i
document, Position Specifications, was not due to be issued until
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August 21, 1981, as noted in the previous paragraph.
One aspect of l
these position specifications was to reflect qualification require-i ments for various jobs in the department.
The issuance of the Position Specifications is open (320/81-03-05,
. paragraph 4.a) pending:
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. Licensee approval and issuance of Job Position Specifications;
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Consolidated NRC review of these Position Specifications for j
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consistancy with applicable standards and qualification i
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6.
Training
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The panel identified' inadequate understanding of risk of low level
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radiation by radiation safety and operations personnel.
In addition,
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specific training deficiencies were identified in:
(1) operation
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standing of the radiological hazm ds associated with the recovery activities, (3). familiarization with plant systems, and (4) radiation and contamination control measures.
The licensee's management plan, dated April 15, 1980, connitted to
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the below listed actions to be tak'en.
Status as noted by the NRC
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was also listed.
t a.
Establishment of a Radiological Training Group
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A radiological controls training group reporting directly to the Manager of Radiological Controls was to be established.
i This training group was to be charged with developing a fonnal training program for radiological control technicians and foremen. The, program for this training was to state required minimum acceptable knowledge, understanding, practical abilities and experience standerd for qualified individuals.
All assigned radiological control technicians and foremen were to be qualified or be restricted in their assignmente prior to
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July 31, 1980. Verified actions in this area ire discussed
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below.-
l (1)- Radiological Controls Procedure (RCP) 4022, Revision 0, l
December 16, 1980, Radiological ^ Controls Personnel Qualification / Training Standard has been reviewed and
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i approved to formalize qualifications and training requirements for radiological control foremen / technicians.
The procedure specifies required practical factors worksheets, i
formal classroom training, written examinations, oral examinations and cyclic training for various levels of foremen / technicians within the radiological field opera' ions group. Based upon ap(proval and issuance of the above procedure, the area 320/80-16-07), formalization of the
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radiological control technician / foremen training program, is considered closed (see also paragraph 4.b).
(2) ' Inspection Report No. 50-320/80-16 specified that the revision of the radiological control technician training
pmgram to satisfy the specific training deficiencies
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identified by the NRC Special Panel would remain an open
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item (320/80-16-09) pending NRC verification of actual
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instruction and assessment of subsequent technician
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qualifications.
During this inspection, the inspc.ctor attempted to audit the presentation of a formal technician
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training session, however no training was scheduled.
The inspector verified that the REP 4022, Appendix A, specifies minimum knowledge requirements for technicians concerning _ sources of radiation and radioactivity specific
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to TMI-2.
Additionally, special discussions concerning systems and areas with -special radiological problems
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were conducted with field operations personnel on past
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occasions.
Therefore, the area (320/80-16-09) is considered cl o sed. _.
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-13-Verification of actual and adequate instruction on special radiological problems during the technician training program is considered open pending NRC review (320/81-03-07).
f (3) Another finding (320/80-16-10) addressed formal training programs for all staff members of the Radiological Controls Department. As of the last inspection, draft procedures for training of dosimetry and radiological instrument maintenance and calibration personnel had been reviewed.
No training program had been developed for radiological technical support (RTS) personnel particularly ALARA (as low as is reasonably achievable) engineers and radiological training personnel.
During this inspection, the inspector verified approval of procedures covering training of dosimetry and radio-logical instrument maintenance and calibration personnel.
Also, personnel within RTS and radiological training were individually assessed based upon past experience and training, as needing further developmental training and were sent to technical courses consistent with their job requirements.
The training of the RTS and radiological training personnel was formalized by the recent issuance of a Training Manual for the radiological controls personnel.
This area (320/80-16-10) is considered closed.
NRC will review the adequacy and implementation of the TMI-2 Radiological Controls Training Manual (320/81-03-08).
b.
Revie's of Radiological Safety Training by Supervisor-Radiological ContrcTTraining Radiological safety training for all personnel employed at TMI-2 was to be performed by the site Training Department.
The responsibility to assure the training meets the minimum standards for safe radiological work in the TMI-2 environment was to be assigned to the Supervisor of Radiological Controls Training.
The Supervisor of Radiological Controls Training was directed to review, change as necessary, and approve course material examinations, presentations and practical factor performance.
The action due date was May 1,1980, for changes to the radiological safety training.
The review and necessary changes to the radiological safety training will be an ongoing process.
The inspector detennined, through discussion with the licensee, that the May 1,1980, date for implementation of major improvements in the training had been completed.
However, the procedure formalizing the radiological safety training had not been &pproved.
Approval of the radiological safety training procedure was considered to be open (320/80-16-11).
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During this inspection the inspector verified that RCP 4021, Revision 0, December 23., 1980, Training Requirements, has been reviewed, approved, and issued, formalizing the radiological safety training. -This area (320/80-16-11) is considered closed.
However, during this review it was noted that the General
Employee Training Requalification Program was being revised.
During observations of a training session the inspector noted
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learning objectives given-to the students were more appropriate for a Radiological Controls Technician.
As an example, knowledge of NIOSH (National Institute of Occupational Safety and Health) numbers for respirators was expected.
This area
,
continues to be reviewed by the licensee and NRC (320/81-03-09).
I c.
Use of Special Training
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In addition to radiological safety training, the licensee comitted to the use of special training such as mock-ups, walk-through exercises and. detailed worker briefings for
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major evolutions and those tasks which may result in unusual
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or uncertain radiological er~ironments.
The RTS group was to
establish the guidelines foi making determinations of which
.:
tasks require additional special training by July 1,1980.
Inspection Report 50-320/80-16 indicated that although special training had been provided for certain '.'high risk tasks",
criteria for jobs which required special training had not been established..The~ development of criteria for special training was an open item (320/80-16-12).
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The inspector verified RCP 4030, Revision 0, January 6,1981, Mock-up Training and Job Briefings, has been issued and approved.
This procedure specifies that as a minimum for major jobs as defined by the procedure Radiological Review of Work Instruction-(RCP 4045), pre-job briefings shall be performed prior to work in radiologically c% trolled areas.
In addition, perfonnance of mock-up trainq shall be con-
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sidered for major jobs, based upon job complexity and expected
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benefits gain'ed by the mock-up training.
Based upon the above, this area (320/80-16-12) is considered closed.
- 7.
Radiological Audit Program The licensee's corrective actions were found to be complete in Inspection Report 50-320/80-16.
The area was re-inspected to assess the licensee's continuing implementatica of comitments and
corrective actions.
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-15-After initial implementation of Procedure 4076, Rcvision 1, November 14, 1980, Audit Response Procedure, the licensee experienced
. some administrative difficulties.
NRC inspection findings were administered through the licensee's licensing organization.
The response to NRC inspection findings in the radiological controls area were assigned to licensee organizations without first going thro' ugh RTS audit coordinator and being listed on the RTS tracking list. This only affected the RTS tracking system not the licensee's ability to respond to NRC findings; it did not affect the tracking of audits internal to the licensee's organization (i.e. quality assurance (QA) audits).
The item was found during a licensee QA oudit. The RTS audit coordinator indicated that a change in the routing of NRC inspection findings had been instituted to correct this item. NRC inspection findings in the radiological controls area are routed from the licensing organization to the manager of radiological controls to the RTS audit coordinator to the organization responsible for corrective action.
The inspector reviewed several of the licensee's audit responses, the audit response tracking system and the most recent status report of open items (which goes to the Radiological Control Manager on a monthly basis). A random sample of six radiological deficiency reports (RDR) and three radiological investigation reports (RIR) were reviewed as were the status books for the RIR and RDR systems.
Both systems were functioning, RIR's and RDR's were being followed until closecut.
The area of licensee audits was closed.
8.
Preparation and Implementation af Procedure The panel determined that many procedures are written in such a manner that strict compliance is not possible.
The licensee's management plan, dated April 15, 1980, committed to the below listed actions to be taken.
Status as noted by the NRC was also listed.
a.
Radiological Control Procedures (RCP) Manual (1) The format for all radiological control associated procedures was to be restructured to achieve verbatim compliance.
These procedures were to be incorporated into the RCP manual, separate from the TMI site procedures.
The following five procedures were listed as priority procedures:
(a) Radiation work permit (RWP) use; (b)
Investigative reports; (c) ALARA review;
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-16-(d) Administrative procedure; and, (e) Administrative exposure guidelines.
These five procedures were due to be revised by April 1,1980, and the following status was reported in the fifth QPR submitted to the NRC on October 15, 1980:
Two of the initial procedures were issued (investigative report procedures and administrative exposure guidelines); the remaining procedures were developed and were currently.in the approval cycle.
Completion af an RCP manual was due by December'1,1980.
The fifth QPR listed procedures as a continuing effort based on the priority list as issued on January 22, 1980.
During this inspection, the inspector reviewed the status of the above five priority procedures as well as the supporting procedures of the RCP manual.
All of the above five priority procedures and all but two or three supporting procedures anticipated to be included in the RCP manual were issued.
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(2)
Further during this review the inspectors noted imple-mentation problems with some of the procedures as observed in the following instances:
RCP 4100, Revision 0. December 19, 1980, Radio-
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. logical Surveys, Table 1, required an extensive amount of survey work on a per shift basis to be in verbatim compliance.
The HP technicians reported difficulty in meeting these requirements along with radiological work coverage.
RCP 4104, Revision 0, December 30,1980, Air S Procedure, required a minimum volume of 2 x 10gmpling
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ml for an adequate sample but this did not address the unique situation of " Lapel" sampler where strict compliance would cause excessive exposure in an area i
to wait for that volume size.
l RCP 4122, Revision 0, December 5,1980, Radiation
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Work Permit, provides little technical guidance of
permit issuance.
It detailed the administrative t
workings of an RWP.
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Other procedures were noted as referencing sections /
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procedures that did not exist (apparent typographical errors) (eg 4046 was referenced in 4047 but 4046 was not planned to be issued).
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i-17-i The review indicated that apparently little or inadequate field testing was conducted on some of these procedures in
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order to meet licensee commitment dates in this area. As noted before the situation was compounded by frustration on the HP technician's part to change minor problems with the procedures (see paragraph 3).
Further in a separate inspection the inspector noted that
'
operations personnel changed a radiation limit (by deletion)
on compacting trash using a temporary change method without formal notification of the Radiological Controls Department and Plant Operator Review Coninittee (PORC) review.
This specific issue is being addressed in Office of Inspection and Enforcement Inspection Report No. 50-320/81-01.
Further review of the licensee's procedure control system indicated excessive delays (8-14 weeks) in the issuance of procedure revisions.
This problem was recognized by licensee's managenant as being deep rooted in the system addressed by Technical Specifications.
This is addressed in subsequent paragraph 8.c.
This area (320/80-16-13) remains open pending the followuq Licensee approval and issuance of the completed RCP
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Manual as noted above; Licensee review / revision of procedures to assure health
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physics shift personnel are not adversely impacted on performance of primary objectives, that is, radiological work coverage; Licensee revision of the procedural control system to
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address Radiological Controls Department interfacing with respect to procedure changes / revision; and, NRC review of the results of the licensee's action as
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stated above.
b.
Action Sign Off Steps Action sign off steps were to be added to all work procedures for work on major evolutions during the procedure review performed by ALARA engineers.. A procedure defining the use of sign off steps was to be implemented by August 1,1980.
The
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status of the QPR submitted to the NRC on October 15, 1980, I
stated that a draft procedure was being prepared, i
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-18-It was noted in inspection 50-320/80-16 that action sign off steps were used for several major evolutions such as makeup filter changeout and reactor building entry.
A procedure establishing criteria for action sign off steps, was planned.
Approval and implementation of this procedure was an open item (320/80-16-14).
.
The inspector verified that criteria for which jobs require consideration of incorporation of radiological controls hold points into the work procedure was established.
RCP 4045, Radiological Review of Work Instructions, requires in part that where major job review by radiological controls personnel determines that review of the actual work process is required prior to continuation of the process, an appropriate " hold" step shall be included in the work instruction wf G required radiological control sign off.
This area (320/86-16-14) is considered closed.
c.
Technical Specification Change to Expedite Procedure Review A revision to the TMI-2 Technical Specifications was submitted to the NRC in February 1980.
However, after much discussion between the NRC and licensee'.s staff the licensee representatives
-
requested termination of NRC review on this change.
This is documented in a letter, dated November 25, 1980, from B. Snyder, TMI Program Office, to R. Arnold, GPU.
Apparently resolution on an issue of independence of review could not be made.
By letter, dated February 24, 1981, the licensee indicated that a revision to the TS in this area is expected by January 1982.
This apparently is a realistic date in light of major change anticipated to TS Section 6 similar to a change being prepared for TMI-1.
This area (320/80-16-15) is considered closed.
The inspector i'ndicated interim measures are warranted in light of some of the procedure control problems noted above.
<
The licensee representative agreed to review this area.
This is open pending completion of licensee review as noted above and subsequent NRC review (320/81-03-10).
9.
External Dosimetry Several inadequacies in the licensee's external dosimetry program were identified by the panel.
The licensee's management plan, dated April 15, 1980, caninitted to the be'ow listed actions to be taken.
Status as noted by the NRC was also listed, a.
Evaluation of Thermoluminescent Dosimetry (TLD) System and Implementation of Modifications The licensee comitted to evaluate the TLD system and implement needed modi?ications by December 1, 1980.
The licensee reported tha c eva!uation of the TLD system was initiated, how3ver, accion was not completed.
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Since the last inspection, the licensee has completed studies of comercially available and experimental TLD's.
The results of these studies have allowed the licensee's staff to make a
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recomendation to management based upon technical considerations.
A discussion of financial considerations is presently being prepared to assist with the overall decision of how to best upgrade the TLD's accuracy of response to different beta energies and mixed beta-gama radiation fields (320/80-16-16).
This item will remain open pending upgrading of TLD capabilities, including QA checks of upgraded system to verify capabilities for different beta energies and mixed beta-gama radiation fields.
b.
Coordination and Direction of Contracted Services The licensee comitted to coordinate and direct contracted
.
technical expertise in the assessment of external exposures by February 1980.
The licensee reported that the technical expertise for assessment of external exposures is currently being coordinated and directed by the Manager of RTS.
The organization and responsibility procedure (RCP 4010) defining the current organization was issued in May 1980 and the comitted action in this area was completed.
Inspection 50-320/80-16 identified that no mechanism was established to cause the external dose assessment by the licensee / licensee contractor dose assessment group within the RTS group.
The above was identified as an open item (320/80-16-17).
Through discussions with licensee representatives the inspector verified that several mechanisms now exist for requesting a dose assessment by the RTS group.
Among these mechanism:: are comparison of self-reading dosimeter to TLD results, comparisons of extremity to whole body dosimetry, comparisons cf different TLD chips within a given badge and actual observance of lost / forgotten dosimetry by radiological controls technicians.
The inspector verified that adequate controls exist to ensure external dose assessments should be performed as required and item 320/80-16-17 is considered closed.
c.
QA Program for TLD System The licensee comitted to develop a QA program for the TLD system by April 30, 1980.
The licensee reported that action in this area was completed.
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During inspection 50-320/80-16 the licensee had approved necessary procedures for the QA program for TLD system, but procedures were in various stages of implementation.
Of primary importance to the QA program for the TLD system was
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RCP 4220. TLD System Quality Assurance. tImplementation of RCP 4220 and resolution of TLD response problems to mixed
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field radiation was considered an open item (320/80-16-18).
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The inspector verified licensee progress to implement procedures
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RCP.4220 Revision 0, November 10, 1980, TLD System Quality
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Assurance and RCP 4201, Revision 0, November 21, 1980, Dosimetry Personnel Training Standard.
RCP 4201 appears to be fully
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.implanelted with some on-going training required as new per, onnel are hired into the group.
The inspector reviewed both quarterly and monthl;* results from RCP 4220. These results test capabilities for gamma fields only. This area is considered v. lot ed.
However, the required annual test of RCP 4220 testing capabilities for response to mixed radiation fields is presently scheduled for some time
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within the next month or two. This continues to be reviewed
!
by the licensee and NRC (320/81-03-11) pending completion of the annual test.
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I d.
Computerized Exposure Tracking by Specific Tasks A system capable of tracking exposures by specific tasks was due to be implemented b'y December 31, 1980. The QPR submitted to the NRC on October 15, 1980, listed the status of this commitment as actions in progress to meet the committed date.
As of inspection 50-320/80-l', in order to gather all of the exposure data associated wicn a specific task, all of the i
RWP's associated with the specific task had to be accessed individually.
Presently specific tasks, which are being
traced, have an ALARA number assigned to each RWP written for that task.
By use of the assigned ALARA number, personnel can later access all of the information contained on the RWP's assigned that same number.
i During this inspection, the inspector verified use of ALARA
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numbers and tracking of exposures on certain specified tasks.
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Item 320/80-16-19 is considered closed.
i 10.
Internal Dosimetry Program The panel identified several specific technical deficiencias with evaluations performed.in determining interiial dose.
In addition, no assessment to demonstrate adequate procedures to detect Sr-90 based _upon Cs-137 internal levels was evident.
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The licensee's management plan, dated April 15,~1980, comitted to the below listed actiont to be taken.
Status as noted by the NRC was also listed.
l a.
Evaluation of Internal Exposure Monitoring Results
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The efforts to evaluate results obtained from the internal exposure monitoring program were to be coordinated and managed
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by the RTS group of the Radiological Control Department.
The-status as reported in the fifth QPR submitted to the NRC on
October 15, 1980, stated that action has been completed.
The
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inspector verifieo that.this reorganization to include respon-
sibility for coordination and management of internal evaluations
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by the RTS group has been completed.
j At the time of inspection 50-320/80-16 use of suggested i
evaluations as required by Code of Federal Regulations (10 CFR 20)
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and ANSI standards were not listed (320/80-16-20).
During
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this inspection, the inspector verified that minimum requirements
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for the above mentioned evaluations have been added to RCP 4238,
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Revision 2, February 6,1981, Bioassay Program.
Item 320/80-16-20 is considered closed.
b.
Bioassay Program Formalization The bioassay program was to have been revised to formalize the basis for bioassays under both routine and non-routine circum-stances by April 1,1980.
Under the revised program all measurements which require dose assessments and evaluations of internally deposited radionuclides are to be referred to the RTS group.
The status reported in the fifth QPR stated the procedure defining the program has been developed and has been issued and action is complete.
During inspection 50-320/80-16 the criteria for Sr-S0 bioassay
'
based. upon Cs-137 uptake as measured by whole body counting was reviewed. Through discussions with licensee personnel during this inspection, the inspector detennined that the i
licensee has initiated a change to lower the criteria from 150 nCi Cs-137 to 100 nCi Cs-137.
This lowered limit for Sr-90 bioassay along with the established program of air sampling (see paragraph ll.b) and required whole body counting following contamination or significant MPC hr airborne exposure should prevent significant Sr-90 uptake gois;g undetected.
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General p ogram deficiencies identified during inspection 50-320/8C.16 included approval and implementation of RCP 4239, l
QA of Biom.aay PNgram, criteria for eceaptance of daily source checks of the whole body counter, and review and approval of contractor supplied operating procedures for the whole body counter. Through review of procedures, records, i
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interviews with licensee personnel, the inspector verified that RCP 4239 has been approved, issued, and appears to be
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implemented.. In addition, criteria for acceptance of daily source checks have been supplied to the whole body counter
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operators.
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Through discussions with various licensee representatives, the inspector verifiea that the vendor supplied operating instructions
have been reviewed by both the RTS group and the Manager Radiological Health. The TMI-2 Radiological Controls Manager has directed the Manager Radiological Health to be
'
responsible for approval of the vendor operating procedures, and therefore following his review, the manager issued a cover letter to the procedures authorizing their use.
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Because of the above, implementation of an improved QA program and the approval of vendor operating procedures (320/80-16-21)
is considered closed.
11.
Instrumentation Program The panel indicated a.possible lack of sufficient professional input into selection, installation, calibration, and maintenance of
radiation protection instrumentation.
The licensee!s management plan, dated April 15, 1980, committed to the below listed action to be taken.
Status as noted by the NRC was also listed.
a.
Radiological Instruments QA Program
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To ensure that all portable instrumentation used'at TMI-2 is properly calibrated, a QA program for radiological instruments was to be developed by July 1,1980.
The status as listed in the fifth QPR submitted October 15, 1980, indicated completed action.
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Implenentation of RCP 4261, Quality Assurance Program for
Radiological Instruments, along with development and imple-menation of a formal training / retraining program for radio-logical instrumentation maintenance and calibration technicians i
was considered an open item (320/80-16-22).
'
Durir.g this inspection, the inspector verified through review of records and observation of instrumentation in use, RCP 4261, Revision 2, January 16, 1981, implementation appears to be
- complete.
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-23-In addition, the inspector reviewed a manual (Training Program for Radiological Instrument Repair and Calibration Technicians)
and training records for technicians in this area.
The above represents an adequate training and retraining program for radiological instrumentation maintenance and calibration technicians.
Through the training / retraining progren and' implementation of RCP 4261, item 320/80-16-22 is considered closed.
.
b.
Air Sampling Frequencies Portable air sampling frequencies were to be increased.
For work evolutigns which were identified as having a potential
~
for generating airborne contamination, portable air samples were to be taken at the start, during, and after work.
The fifth QPR submitted October 15, 1980, indicated that action was complete.
!
The assessment of air sampling practices was not completed during inspection 50-320/80-16 and this remained an open item (320/80-16-23) pending further NRC evaluation of work activities and adequacy of air sampling practices.
During this inspection,
'
through review of procedures, survey records, air sampling analysis results, and discussions with licensee personnel, the inspector verified the licensee's current air sampling practices i
,
appear to be adequate.
Item 320/80-16-23 is considered closed.
'
c.
Survey Frequency Schedule A new schedule for survey frequencies was to be implemented by February 1, 1980. The fifth QPR listed the status as a schedule developed and incorporated into a procedure that was in the approval cycle.
The review of survey frequencies was not completed during inspection 50-320/80-16 and survey frequency adequacy remained
!
an open item (320/80-16-24) pending further NRC review.
I
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During this inspection, through review of procedures, survey records, smearable contamination results, and discussions with licensee personnel, the inspector verified the licensee's current survey frequencies appear to be adequate.
Item
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320/80-16-24 is considered closed.
12. Radioactive Material Shipp M No specific parel finding addressed this area, however, the licensee, in their management plan, dated April 15, 1980, did make commitments in this area as a result of a separate internal audit.
Status as noted i
by the NRC was also listed.
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a.
Procedure Revision The current revision of RCP 1620 no longer conflicts with the 90Sr fraction developed by the RTS group.
The licensee is in the progress of revising their procedures for loading and handling casks of radioactive material.
Cask handling procedures are being developed for each of the cask types the licensee plans to use.
Cask loading procedures are being developed for each type of expected cask content (55 gallon drums, 4 ft. by 4 ft. liners, and 6 ft. by 6 ft. liners).
The procedures are currently in the review cycle and will receive NRC review prior to implementation. The area of procedure revision is closed (320/80-16-25).
Further review of licensee radioactive material shipping procedures will be accomplished by the aformentirned routine NRC review of licensee procedures and in review of inspection item 320/80-17-06, which dealt with a procedural implementation noncompliance.
b.
Curie Estimations The area of curie estimations was closed in inspection 50-320/80-16.
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The licensee periodically reviews and revises isotopic mix and estimations factors as reported in inspection 50-320/80-16.
The licensee's current estimations factors are conservative and isotopic mix was updated based upon periodic sample and review.
c.
Radioactive Material Shipment Training The licensee has instituted an annual requalification training requirement for radioactive material shipment training.
In addition to the required training and retraining, departmental training is conducted and certain individuals have attended commercially offered courses.
d.
Staffing The licensee's radioactive material shipping staff was adequate.
Currently the entire staff consists of contractor personnel.
The licensee has recognized the desirability of incorporating licensee personnel into the organization to enhance the stability and continuity of the staff.
A recruiting effort to hire licensee radioactive material shipment personnel is ongoing.
The inspector had no further coments in this area.
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Decontamination
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No specific panel finding addressed this area, however, the licensee, in their management plan, dated April 15, 1980, did make commitments in this area as a result of a separate internal audit.
Status as noted by the NRC was also listed.
The licensee had under construction a central decontamination facility on the 328 ft. elevation of the auxiliary building.
On March 4,1981, the inspector examined this facility which will house the licensee's freon decontamination unit and electrolytic decontamination unit. The licensee expected the facility to be completed in April 1981.
The licensee completed the transition from a largely contractor supplied workforce to an in-house decontamination workforce.
The decontamination organization was under authorized staff levels and management was involved in a recruiting program in an effort to increase staffing level.
Current principal decontamination efforts include:
Decontamination of the control and service building sump and
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installation of a stainless steel liner; Decontamination of the diesel generator building sump and
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installation of a stainless steel liner; Limited decontamination on contaminated areas in the auxiliary
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building; Maintaining status of clean areas in the auxiliary and fuel
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handling buildings; and, Lowering inventory of radioactive trash in the auxiliary and
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fuel handling buildings.
The inspector had no further comments in this area.
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14.
Implementation of a Program to Reduce Personnel Exposure to ALARA The panel indicated that the Radiation Protection Plan did not include adequate emphasis or reduction of personnel exposures to ALARA.
The licensee's management plan, dated April 15, 1980, committed to the below listed actions to be taken.
Status as noted by the NRC was also listed.
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-26-a.
Implementation of a Radiation Protection Plan in Confonnation with ALARA The licensee committed to the implementation of a Radiation Protection Plan which stresses management comitment to a strong Radiological Control Program within the concept of ALARA.
The licensee reported that an ALARA program is now in effect, however, the Radiation Protection Plan was awaiting NRC approval.
Inspection 50-320/80-16 stated that an ALARA program remained anopenitem(320/80-16-26) pending implementation of an adequate ALARA program in accordance with written detailed procedures.
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Through review of procedures RCP 4041, Revision 0, December 23, 1980, ALARA Program and RCP 4045,' Revision 0, January 5, 1981, Radiological Review of Work Instructions, as well as records of several major jobs requiring ALARA review, the inspector verified that the licensee now had an adequate ALARA program founded in formal procedu'es.
Item 320/80-16-26 is considered closed, b.
Implementation of a Progi..: for Exposure Tracking To aid in radia in exposure reduction, man-rem goals were to be established for each major task each year.
Information
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from the computerized exposure tracking system was to be used to perform trend analysis to assess progress while the job was being performed.
The reports will be issued to the responsible supervisors in order for them to monitor the effectiveness of their performance.
The procedure f ar implementation of the
,
program was to be ready following tae implementation of the computerized exposure tracking systee.
The due date for this commitment was listed as September 1, 1980.
The licensee's fifth QPR listed the status as not complete.
The program was being integrated into a revised work tracking program being developed at the corporate level.
Use of man-rem goals and exposure tracking for jobs was considered an open item (320/80-16-27) during inspection 50-320/80-16.
Through uiscussions with various licensee personnel during this inspection, the inspector verified that the ALARA group within RTS is tracking exposure for approximately 10 tasks
'
being performed (ie. reactor building maintenance, reactor building data acquisition, radioactive trash handling, etc.).
' The inspector also detennined that man-rem est mates have been
,
made for the site for the year and also for the data acquisition j
phase of reactor building entries.
This area l320/80-16-22)
1s considered closed.
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-27-However, the inspector noted that only the reactor building data acquisition task had a man-rem estimate.
The inspector inquired why man-rem estimates for the other tasks were not made. The licensee representative indicated that man-rem estimates for the other tasks were not warranted with respect to total exposure.
The inspector stated this area is open pending NRC review of the effectiveness of man-rem estimates coupled with exposure tracking to aid in radiation exposure reduction (320/81-03-12).
c.
Issuance of Exposure Reports to Supervision Computerized exposure reports were to be issued to all Met-Ed/
GPU and contractor supervision to ensure that radiation exposures received by individuals reporting to them were ALARA. These reports were also to be used as an aid in identifying operations which may need ALARA engineering reviews to reduce personnel exposures.
No due date was given for this item in the fifth QPR and the status was listed as a continuing effort upon implementation of the exposure tracking program.
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Inspection 50-320/80-16 identified issuance of exposure
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reports to supervision as an open item (320/80-16-28).
.Similar to the last inspection in this area, exposure listings, alphabetically by individuals, are available to supervisors at radiological control points.
However, the licensee is presently investigating the expansion of the individuals work identification code to allow for a more detailed breakdown of exposures by specific work groups within the current radiological exposure maintenance program.
Issuance of exposure reports to supervision remains an open item (320/80-16-28).
15.
Open Findings / Items Open inspection items are findings in which further action is warranted by the licensee to fulfill the intent of commitments to the NRC or further review by NRC is warranted to assure licensee is meeting the intent of committed action.
Open items reviewed / discussed in this inspection report are addressed in paragraphs 3 through 14.
16.
Exit Interview On March 23, 1981, the inspectors met with licensee representatives (denoted in paragraph 1) to discuss the inspection scope and findings.
Subsequent discussion of inspection findings occurred on April 3,1981.