IR 05000320/1981013
| ML20010E113 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/19/1981 |
| From: | Barley W, Boslak T, Fasano A, Moslak T, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010E109 | List: |
| References | |
| 50-320-81-13, NUDOCS 8109030101 | |
| Download: ML20010E113 (26) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-320/81-13 Docket No.
50-320 License No. DPR-73 Priority
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Licensee :
Metrogolitan Edison Company P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name:
Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: June 18 - July 20,1981 Inspectors-
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M. Shanbaky, Senioq Radiation Specialist date signed
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Approved by:
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A. rasan6, Chief, Three Mile Island Resident Section dafte sign'ed
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Projects Branch #2 Inspection Summary:
Inspection on June 18 - July 20,1981 Areas Inspected : Special, announced inspection by NRC resident inspectors of licensee action on previous inspection findings in the areas of radiological instrument calibration, radiation monitor.ng, respiratory protection, radioactive waste processing and transportation, procedures, personnel dosimetry, and exposure control.
The inspection involved 225 inspector-hours by 3 radiation specialist (resident) inspectors.
Res ul _ts : Of sixty-one items reviewed, fifty-nine are considered closed and two remain"open. No items of noncompliance were identified.
8109030101 810819 PDR ADOCK 05000320 G
Detail s 1.
Persons Contacted General Public Utilities Nuclear Group D. Benzel, Supervisor, System Support Engineering K. Bucher, Foreman, Respirator Decontamination S. Chaplin, Nuclear Licensing Engineer W. Clark, Sample Coordinator D. Collins, Foreman, Radiological Controls E. Gee, Supervisor, Respiratory Protectian E. Gischel, Director, Plant Engineering, Unit 2 F. Grice, Senior Project Coordinator, Radiological Controls J. Hildebrande, Manager, Radiological Health K. Hofstetter, Supervisor, Radiochemistry G. Juteau, Supervisor, Decontamination Laundry G. Lodde, Special Project Coordinator D. Merchant, Foreman, Radiological Controls P. Newkirk, Foreman, Radiclogical Controls H. Peterson, Ingineer, Radiological Technical Support
- P. Ruhter, Manager, Radiological Technical Support D. Shriner, Manager, Instrument Calibration and Repair Shop
- R. Swartzwelder, Nuclear Licensing Engineer R. Warren, Plant Mechanical Engineer
- denotes those present at exit interview.
2.
Licensee Action On Previous Inspection Findings a.
Radiological Instrumentation and Calibration
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(0 pen) Unresolved (320/79-29-04), Licensee to evaluate Counting Equipment Calibration and Efficiency Determination.
The inspector noted progress in an on-going licensee radiation instrument calibration audit.
To date, the licensee has evaluated 70% of its radiation counting instruments to identify and correct deficiencies in procedures and calibration practice:.
Completion of the evaluation is scheduled for September 1981.
The inspector determined that the adequacy of the licensee's instrunent calibration is considered unresolved pending completion of the evaluation.
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(Closed) Significant Inspection Finding (320/79-26-02),
Air Sampler Not Calibt ated.
On September 21, 1979, an inspector toured the Unit 2 auxiliary building and discovered an air sampler that was overdue for calibration.
Upon being notified of this finding, the licensee removed the sampler and had it calibrated.
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-3-During this inspection, Unit 2 Health Physics Procedure 1758,
" Operation, Calibration, Maintenance and Repair of Portable Air Samplers," effective July 22, 1980, was reviewed.
Air samplers were randomly selected by the inspector and verified to be calibrated.
Calibration records were examined to verify that an ongoing calibration program was in effect.
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(Closed) Significant Inspection Finding (320/79-17-12),
Failure to Use Approved Procedures and Certified Calibration Equipment for Calibration of Portable Air Samplers.
During a previous inspectiori, a review of the instrument calibration program indicated that no approved calibration procedures were being used for calibration of portable and breathing zone samplers.
Additionally, the flow calibration was in question due to the lack of certification of flow calibration instrumentation.
A review of contractor calibration records, procedures, calibration frequencies and certification of calibration instrumentation had indicated the following discrepancies.
No certificates of traceability to the National
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Bureau of Standards (NBS) were on-site for certain instruments.
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Instrumentation was 410t being removed from the Unit 2 auxiliary building for calibration at the required frequencies.
Examples included Eberline R0-2A lon Chambers, Serial Numbers 285 and 287.
These particular instruments were utilized for beta and gamma radiation field measurements.
During this inspection the following approved procedures were reviewed.
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Health Physics Procedure (HPP) 1758, " Operation, Calibration, Maintenance, and Repair of Portable Air
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Samplers," Revision 2, July 22,1980
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'PP 1762, "Calibracion, Maintenance, and Repair of the Eberline Instrument Company (EIC) R0-2A,"
Revision 4, April 21,1981 Also, R0-2A instruments were randomly selected by the.
i inspector and verified to be calibrated within the required frequency.
Certificates of traceability to NBS were examined for the
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following calibration i.istruments.
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Radeco Model 828 (High Flow Calibrator) Serial No. 1128 Radeco Madel 312 (Low Flow Calibrator) Serial
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No. 1147 The Fisher-Porter Flowrator Kit has not been calibrated; however, the licensee is processing the requisition (No. 9211-1016) to purchase a calibrated Fisher-Porter kit.
Based on this examination of the licensee's corrective actions, this item is considered closed, b.
Surveys and Monitoring
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(Closed) Unresolved Itam (320/80-19-05),
Cork Seam Contarai nation.
The inspector reviewed the licensee's actions to monitor and control the spread of contamination discovered in the cork seam of the auxiliary building floor.
The inspector determined that adequate measures had been initiated.
To date, a strippable coating has been applied to the seam and the water and contamination levels are being periodically monitored to detect any spreading of the contamination.
An engineering review
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of the causes and aggravating conditions has been completed.
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The review indicated a need to repair the roof flashing between the reactor building and adjacent buildings to prevent rainwater from reaching the cork seam and potentially spreading the contamination further.
A contract for repair is being processed.
The inspector stated that the i
roof repair would be examined to verify completion during a future inspection (320/81-13-01).
(Closed) Infraction (320/80-02-02), Failure to Use Suitable
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Measurements of Concentrations of Radioactive Materials in Air for Entry into Make-up Pump Room 18.
On February 11, 1980 suitable measurements of concentrations of radioactive materials in air were not made when members of an Emergency Repair Team entered into an airborne radioactive material area inside the Make-up Pump Room.
No air sample was taken from inside the room during the emergency.
During this inspectien. the following procedures were reviewed.
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Unit 2 Emergency Plan Implementing Procedure No.1054.9,
"In-Plant Radiological Controls During Emergencies,"
dated April 1,1981
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Unit 2 Radiological Controls Procedure (RCP) 4045,
" Radiological Review of Work Instructions," dated January, 5,1981
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Unit 2 RCP 4052, " Selection, Prescription, and Use of Respiratory Protective Equipment," dated December 11, 1980 Unit 2 RCP 4100, " Radiological Surveys," dated
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March 6,1981 Airborne sampling requirements dictated by these procedures are considered adequate to address emergency action res pons es.
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(Closed) Unresolved Item (320/19-29-03), Veri fy Licensee is Submitting Samples for Sr-90 Analysis in Accordance with HP Procedure 1616.4.
During a previous inspection, an inspector reviewed the licensee's air sampling program against the requirement of Health Physics Procedure 1616.4, " Implementation of Air Sample Counting, Handling and Actions."
Procedural steps 3.8 through 3.11 require the licensee to submit selected samples for Sr-89 and Sr-90 activity analysis on a weekly basis.
Though the procedure was first implemented on October 9,1979, the licensee had failed to submit air samples for the strontium evaluation.
The inspector had determined that this failure did not constitute a health and safety problem but did require monitoring by the NRC onsite staff to assure that the licensee adheres to procedural specifications.
During this inspection, air sampling practices and records were reviewed against the following procedures which superseded Health Physics Procedure 1616.4, (cancelled by Procedure Change Request 2-80-657, dated January 26, 1981).
Unit 2 RCP 4100, " Radiological Surveys," dated
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March 6,1981 Unit 2 RCP 4101, " Air Sample Counting, Handling, and
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Actions," dated December 28, 1980
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Unit 2 RCP 4104, " Air Sampling Procedure," dated May 4,1981
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- 6-Based on this procedural and record review, and discussions with licensee representatives, adherence to procedural specifications is being maintained.
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(Closed) Inspector Follow Item (320/79-23-05), Review Inconsistency in Unit 2 Auxiliary Building Vent Monitor Dose Rates.
The Unit 2 augmented (supplemental) exhaust ventilation system was taken out of service in June 1980.
Auxiliary building ventilation exhaust is now being monitored by the vent stack monitor, HPR-219A.
Since the supplemental vent radiation monitoring system has not been in use since that date this item is no longer pertinent.
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(Closed) Significant Inspection Finding (320/79-17-11),
Non-representative Sampling of EPICOR-II Building Ventilation.
On June 29, 1979 an inspector identified deficiencies in the EPICOR-II exhaust duct monitoring system which prevented the licensee from obtaining a representative air sample.
During this inspection effort, an examination was made of the licensee's Engineering Change Memorandum (ECM No. 3475-134), that was initiated to correct the identified deficiencies, and an inspection was made of the EPICOR-II exhaust monitoring system to verify completion of the corrective actions.
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(Closed) Inspector Follow Item (320/79-23-04), High Composite Offsite Samples (Liquid).
During a previous review of liquid effluent monitor RML-7 composite samples, analysis results indicated concentrations greater than 10 CFR 20, Appendix B limits due to sample cross contamination.
Licensee recounts of re-prepared composite samples indicated no detectable activity greater than the lower limit of detection of the counters used.
During this inspection, a review of RML-7 sample collection, preparation and counting was conducted.
Observations of licensee practices in these areas, discussions with licensee representatives, and review of the below listed procedures indicate that effluents are being adequately monitored.
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RCP 1621.2, " Releasing Radioactive Liquid Waste from Unit 2," Revision 5, July 17,1980
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RCP 1699A, " Liquid Release from Three Mile Island, Administrative Controls," Revision 4, November 4,1980
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(Close f) Signi ficant Inspection Findings (320/79-22-12 and 320/79-22-13) and Inspector Follow Item (320/79-17-21),
Failure to Perform Gross Beta Analysis on Liquid Effluents.
During a previous inspection of licensee liquid. ef fluent release practices, the inspector discovered that Gross Beta Analyses were not being performed on liquid waste prior to release from the site.
During this inspection the following procedures were reviewed.
RCP 1621.2, " Releasing Radioactive Liquid Waste from
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Unit 2," Revision 5, July 17,1980.
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RCP 1699A, " Liquid Release from Three Mile Island, Administrative Controls," Revision 4, November 4,1980 Station Chemistry Procedure 1800.5, " Sampling
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Procedure," Revision 0, September 30, 1980
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Station Chemistry Procedure 1950, " Determination of Gross Beta-Gamma," Revision 4, February 5,1981 l
Review was made of sample collection, preparation, counting, and liquid release records per RCP 1699A.
Based on this review, monitoring of effluents by the licensee appeared l
to be adequate.
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(Closed) Significant Inspection Finding (320/79-22-07),
Improper Posting of Radioactive Material Storage Area.
During a previous inspection,an inspector identified a failure of the licensee to label a radioactive materials storage area.
During this inspection, tours were made of controlled and noncontrolled areas to verify compliance with the require-ments of 10 CFR 20.203, " Caution signs, labels, signals and controls."
In addition, the following approved procedures were reviewed.
Health Physics Procedure (HPP) 1682, " Control of
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Contaminated Tools, Equipment, and Material,"
Revision 4, June 13,1980 RCP 4100, " Radiological Surveys," Revision 1,
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March 6,1981.
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RCP 4150, " Radioactive Material Transfer Account-ability," Revision 0, June 1,1980
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RCP 4160, " Establishing and Posting Areas," Revision 0, December 23, 1980 The results of area tours conducted during this inspection and the results of those conducted daily by the NRC onsite staff indicate that the licensee is adequately posting controlled areas.
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(Closed) Significant Inspection Finding (320/79-17-14),
Failure of Personnel to Frisk.
The inspector reviewec Radiological Controls Procedure (RCP) 4105, " Monitoring for Personnel Contamination"
.nd RCP 4120, " Operation of a Control Point".
Further discussions with licensee's representatives occurred and observations of frisking at control points were made (Closed) Significant Inspection Finding (320/79-17-13),
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Failure to Label Drums and Samples for Analysis.
On July 5,1979, an inspector observed licensee failure to label radioactive air samples removed from a restricted area for analysis and failure to label drums of radioactive samples being returned from the counting facility.
During this inspection the following procedures were reviewed.
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RCP 4100, " Radiological Surveys," Revision 1, March 6,1981
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RCP 4150, " Radioactive Material Transfer Account-ability," Revision 0, June 1,1980
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RCP 4101, " Air Sample Counting, Handling and Actions,"
Revision 0, December 28, 1980 Based upon this review.the procedures provide adequate instruction for labeling.
The daily tours conducted by the inspector confirmed that the licensee is maintaining an adequate surveillance program to label and account for the transfer of radioactive materials.
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(Closed) Significant Inspection Findings (320/79-13-04 and 320-79-17-10), Inadequate Airborne Survey of Work Area.
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-9-During an inspection in June 1979, the inspector determined that general area air samples of airborne radioactivity concentrations had been used for job specific airborne a cti vi ty.
Breathing zone air samples were not routinely collected.
A technical meeting was held with the licensee on taking breathing zone samples and the licensee committed to the review and revision of the airborne radioactivity sampling program.
The licensee's air sampling program was reviewed in February 1981, (Office of Inspection and Enforcement inspection 50-320/81-03).
Based upon the results of that inspection these items are considered closed.
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(Closed) Significant Inspection Finding (320/79-17-15),
Unit 2 Air Sampling Program Deficiencies.
A previous inspection of Unit 2 revealed air sampling not being performed at a frequency adequate to demonstrate compliance with 10 CFR 20.103, " Exposure of individuals to concentrations of radioactive materials in air in unrestricted areas."
During this inspection the following procedures of the revised air sampling program were reviewed.
RCP 4100, " Radiological Surveys," Revision 1,
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March 6,1981 RCP 4101, " Air Sample Counting, Handling and Actions,"
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Revision 0, December 28, 1980
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RCP 4104, " Air Sampling Procedure," Revision 1, July 4,1981
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RCP 4051, " Respiratory Protection Program," Revision 3, June 1,1981
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RCP 4052, " Selection, Prescription, and Use of Respiratory Protective Equipment," Revision 2, December 11, 1980 RCP 4054, "Calculatinn of MPC Hours and Stay Times,"
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Revision 0, September 5,1980 On the basis of the procedural review, discussions with
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l licensee's representative, and an examination of air sampling records, this item is considered closed.
l (Closed) Significant Inspection Finding (320/79-17-01),
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I Unmonitored Release Path to the Environment.
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-10-In June 1979, an inspector identified that the Tri-State Laundry mobile unit used for decontamination of protective clothing had a filtered ventilation exhaust which was not monitored.
The filtered air was discharged directly to the environment.
The current status of the laundry exhaust system was inspected and associated procedures reviewed.
An AMS-3 air sampler has been installed to monitor air that is discharged directly to the environment.
This modification and associated approved monitoring procedures provides adequate ventilation monitoring for airborne radioactive contaminants.
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(Closed) Violation (320/79-10-06), Overexposure Due to Failure to Survey.
On March 29, 1979, a Nuclear Engineer entered an area of the auxiliary building where the radiation level was greater than that which could be measured (2 R/hr) by his portable survey instrument.
Failure to perform a survey of the exposure rate in this area contributed to the individual receiving a whole bot'y dose of 3.14 rems for this entry. When this dose was idded to the engineer's previous dose for the quarter, t ie engineer's quarterly whole body dose was 4.175 rems a s measured by personnel dosimetry devices.
The licensee stated that the cmergency Plan would be modified to include exposure guidelines in emergency situations, improved training and retraining would be developed for radiological controls personnel, and radiological safety training for all site personnel would be expanded.
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During this inspection, the actions that the licensee stated would be taken were reviewed.
The inspector verified implementation through discussions with licensee representatives, observation of licensee activities, ar.d review of the following procedures.
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Emergency Plan Implementing Procedure (EPIP) 1054.3,
" Site Emergency," Revision 0, April 1,1981 EPIP 1054.9, "In-Plant Radiological Controls During
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Emergencies," Revision 0, April 1,1981
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EPIP 1054.16, " Contaminated Injuries / Radiation Overexposure," Revision 0, April 1,1981 Administrative Procedure (AP) 1055, " Emergency
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AP 1056, " Emergency Planning Training," Revision 0, April 1,1981
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AP 1057, " Emergency Equipment Readiness," Revision 0, April 1,1981
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RCP 4015, " Administrative and Emergency Exposure and Contamination Limits," Revision 0, July 28,1980 RCP 4041, " ALARA Program," Revision 0, December 23,1980
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RCP 4045, " Radiological Review of Work utstructions,"
Revision 0, January 5,1981
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RCP 4000, " Radiation Protection Plan," Revison 1, January 14, 1980 (Closed) Violation (320/79-10-04), No Airborne Measurements
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were made for Auxiliary Building and/or Primary Sample Room.
No measurements were made of the concentrations of airborne radioactive materials in the Unit 2 auxiliary building for periods during which individuals were exposed from 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979 through midnight March 30,1979, nor in the primary sample room and primary chemistry laboratory for periods during which individuals were exposed from 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on March 28 through 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on March 30, 1979.
During this inspection, it was confirmed that since the accident continuous monitoring instruments capable of measuring particulate, iodine, and gases were installed.
The licensee also has 27 continuous monitors for particulate activity and 30 portable particulate sampling devices in use within Unit 2.
Training in the use of this equipment was found to be included in the qualification program for all radiciogical control technicians and foremen.
These corrective actions are considered to be satisfactory.
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(Closed) Violation (320/79-10-03), Auxiliary Building Entries Without Continuous Radiation Monitors.
Certain individuals did not have radiation monitoring devices which at all times indicated the dose rate when these individuals entered high radiation areas of the Unit 2 Auxiliary Building on the evening of March 28, 1979.
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-12-To correct this violation, the licensee committed to placing emergency monitoring equipment dedicated to be used only for emergency situations at strategic locations.
This equipment is to be maintained in a state of readiness at all 'imes.
During this inspection the emergency equipment was examined and verified to be maintained in accordance with Unit ? AP 1057, " Emergency Equipment Readiness," Revision 0, April 1,1981.
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(Closed) Inspector Follow Item (320/78-31-04), Review Radiation Levels on Containment Dome to Verify that Surveys are made oefore Personnel Perform Tendon Surveillance on Dome During Reactor Operation.
During an inspection conducted prior to the Three Mile Island Unit 2 accident, the inspector noted that no confirmatory gamma surveys were performed on the containment building of Unit 2 to determine that the design objectives given in the FSAR are met.
The licensee committed to naking radiation measurements at 75% and 100% power of Unit 2 that would be reviewed by the NRC during a subsequent routine inspection.
Based upon surveys conducted on the containment dome on March 31,1979, it was concluded that the design objectives of the FSAR have been met.
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Respiratory Protection
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(Closed) Inspector Follow Item (320/79-23-11), Review Field Implementation of New Respiratory Protection and Sampiing Procedures.
The licensee utilizes respiratory protective equipment to limit the inhalation of airborne radioactive material.
As specified in 10 CFR 20.103(c), the licensee may make allowance for the use of such equipment provided that the respiratory protective equipment is used as stipulated in Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection".
As a result of significant deficiencies identified in the licensee's respiratory protection program, particularly with respect to implementation of the requirements of Regulatory Guide 8.15, meetings were held with the licensee on August 17 and August 28, 1979, to discuss the deficiencies.
The discussions included:
(1) upgrading of respiratory protection procedures (2) review of supplied air systems, and (3) improving sampling of airborne radioactive material.
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-13-During this inspection, the below listed Unit 2 procedures were reviewed.
The review focused on the compliance of the licensee's respiratory protection program with Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection," and NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials."
RCP 405!, " Respiratory Protection Program," Revision 3,
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June 1,1981 RCP 4052, " Selection, Prescription and Use of
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Respiratory Protective Equipment," Revision 2, December 11, 1980
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RCP 4053, " Inspection, Maintenance and Repair of Respiratory Protective Equipment," Revision 1, December 5,1980
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RCP 4054, " Calculation of MPC Hours and Stay-Times,"
Revision 0, September 5,1980 RCP 41C0, "Padiological Surveys," Revision 0,
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Janaury 22, 1 981 RCP 4101, Air Sample Counting, Handling, and Actions,"
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Revision 0, Decemoer 28, 1980
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RCP 4104, " Air Sampling Procedure," Revision 1, July 4,1931 RCP 4238, " Bioassay Program," Revis'
3, April 8,1981
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RCP 4239, " Implementation and Quality Assurance of
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Program," Revision 1, April 8,1981
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Health Physics Procedure 1758, " Operation, Calibration, Maintenance ard Repair of Portable Air Samplers,"
Revision 2, J.ly 22,1980
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RCP 1758.2, " Low Volume Tritium Sampling," Revision 0, August 22, 1980 RCP 1616.3, " Respirator Cleaning and Testing Facility,"
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Revision 6, February 25, 1981 RCP 1616.3A, "Q-127 00P Respiratory Fil ter Tester,"
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Revision 2, April 28,1981 RCP 1616.3B, " Operating TDA-2D DOP Respiratory Leak
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Testor," Revision 0, February 26, 1981
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-14-Based upon this procedural review, observation of activities and examination of records at the respiratory fitting booth, Radiation Work Permit Training, Health Dhysics Control Point Unit 2, Respiratory Decontamination Facility and the whole body counter, the Respiratory Protection Program meets the criteria of Regulatory Guide 8.15 and NUREG-0041.
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Padioactive Waste Processing and Transportation
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(Closed) Inspector Follow Item (320/79-17-19), Proper
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Numbering of Radioactive Material Shipments.
During a previous inspection,the inspector identified the use of the same radioactive material shipping number for two different shipments in June-July 1979.
The licensee revised Health Physics Procedure 1618 to prevent recurrence.
The review of RCP 1618A, " Radioactive Material Shipping,"
Revision 5, Attachment 3, indicated that adequate direction is provided for proper numbering of radioact4:<e material shipments.
In addition, records of past shipments during a preceeding six month period were reviewed with no observed problems of shipment numbering.
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(Closed) Violation (320/80-14-01), Packages at Burial Ground not Properly Sealed (Loose or Broken Locking Rings).
On June 10, 1980, an inspection of trailer 440571 loaded with radioactive waste packages from Three Mile Island, arrived at the burial site with at least 15 drums with loose locking rings (could be rotated by hand) on the lids.
One of these rings was physically broken at the wel d.
The licensee responded that procedures had been I
implemented which provided for verification of tightness for each drum ring.
In addition, the licensee initiated the use of electrical impact wrenches to achieve tightness i
and to detect faulty welds associated with the locking ring.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and review of RCP 1618A and RCP 1618D, " Radioactive Material Packaging,"
the inspector determined that adequate corrective actions were taken and completed in this area.
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(Closed) Inspector Follow Item (320/79-23-03), Inclusion of Requirements for Labeling of Packages for Shipment in Revised Procedure.
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-15-During a previous inspection,it was noted that a package of radioactive material was nct labeled in accordance with 49 CFR 172.403(d)(1).
Based on discussions with licensee representatives and examination of RCP 1618A and RCP 1618D, the inspector determined that adequate direction for labeling of packages of radioactive material for shipping is contained in current shipping procedures.
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(Closed) Inspector Follow Item (320/79-17-20), Curie Content Estimations of Radioactive Waste Shipping Containers.
A review of determination of the curie contents of radio-active waste shipping containers indicated that the curie content was only valid for gamma emitting isotopes.
Based on a review of RCP 1620, " Radiological Controls for Processing Radioactive Solid Waste," and RCP 1655, " Curie Estimates for Radioactive Material Shipments," and discussions with licensee representatives, the inspector determined that current methods of estimating curie content of packages includes factors based upon measured beta to gamma enntter ratios.
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(Closed) Inspector Follow Item (320/79-13-01), Qualification of Licensee Contractor Health Physics Personnel.
A review of qualifications and backgrounds of contractor supplied health physics (HP) supervisors and technicians performed during inspection 50-320/79-13 identified that i
no procedural controls specifying qualification require-ments for contractor HP personnel existed.
The licensee committed to develop procedural controls for HP personnel quali fication.
The inspector reviewed applicable procedures, training records, the radiation protection plan, and had dis-l cussions with licensee representatives.
The inspector determined that adequate procedural control for health physics contractor personnel qualifications and back-grounds exists.
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(Closed) Oper Item (320/81-03-03), Incorporation of NRC Comments inte Radiation Protection Plan.
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-16-The licensee submitted a proposed radiation protection plan to the NRC staff for apprcial.
The proposed plan was approved with several minor comments which were to be incorporated in the plan.
The inspector reviewed the pret. tnt controlled copies of the licensee's radiation protection plan and verified that the NRC comments had been incorporated.
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(Closed) Noncompliance (320/80-19-04), Failure to Follow Procedures Associated with Coolant Sampling and Analysis.
A review of reactor coolant sampling and onsite analysis performed during inspection 50-320/80-19 identified two instances of failure to follow applicable procedures.
Based on discussions with licensee representatives, observation of sampling operations and review of selective procedures, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Inspector Follow Item (320/79-22-14), Radiological Concerns Identified During EPICOR-II Preoperational Review.
Inspection 50-320/79-22 listed six discrepancies to be followed by the NRC onsite staff concerning EPICOR-II operations.
These items were identified during a pre-operational review of the EPICOR-II system and procedures.
During startup and operation cf the EPICOR-II system, the items were satisfactorily reso ved by the licensee.
(Closed) Violation (320/80-10-0'), Failure to Use Leak-
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resistant Containers.
During March 1980, the licensee shipped water samples in which the inner containers of three of the ten samples had leaked contrary to the reqJirements of 49 CFR 173.393(g)
and 10 CFR 71.5.
Based on examination of the licensee's submitted corrective actions, discussions with licensee representatives, and review of RCP 1618J, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Violation (320/80-10-02', Failure to Use Authorized Packaging for Shipment of Type " A" Liquid Radioactive Material.
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-17-Prior to March 23, 1980, on at least two occasions type
"A" quantities of liquid radioactive material were shipped in 17H drums.
At the time of the shipments,17H drums were not authorized for radioactive liquid shipments in that the licensee's safety analysis failed to derronstrate that the packaging would meet the requirements of paragraph 49 CFR 173.393(g)(1).
The licensee modified his packaging requirements for type
"A liquid radioactive material shipments and completed a safety analysis for the same.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, examinations of several subsequent shipments, and review of RCP 1618D, " Packaging of Radioactive Material," the inspector determined that adequate corrective actions were completed in this area.
(Closed) Significant Inspection Finding (320/79-17-08),
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ALARA (As low As Is Reasonably Achievable) Review of Facility Procedures.
During inspection 50-320/79-17. the inspector identi fied that certain recovery procedures and associated operating procedures were receiving little or no review to assure that adequate ALARA and Health Physics consideration were incorporated.
The licensee issued RCP 4041, "ALARA Program," Revision 0, December 23, 1980 and RCP 4045,
" Radiological Review of Work Instructions," Revision 1,
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Fe bruary 12, 1981, to identify criteria for ALARA review, designate personnel to perform reviews, and to include ALARA sign-off on applicable facility procedures.
Based on examination of the licensee's corrective actions, discussion with licensee representatives, and examination of selective radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area.
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Dosimetry
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(Closed) Significant Inspection Finding (320/79-17-04),
Identified Concerns with TMI Personnel Dosimetry System.
Inspection 50-320/79-17 included an in-depth review of the TMI personnel dosimetry system.
During this review, ten significant findings were identified and brought to the attention of licensee representatives on June 15, 1979.
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-18-Based on review of licensee dosimetry procedures, docu-mentation, and interviews with licensee representatives, all of the above identified concerns with the TMI personnel dosimetry system have been corrected.
Presently the only open item concerning personnel dosimetry is proper response to beta and mixed beta-gamma fields and is being carried as open item (320/80-16-16).
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(Closed) Unresolved Item (320/79-29-05), Incorporation of 10 CFR 20.102, " Determination of Prior Dose" Requirements Into Dosimetry Procedures.
During combined inspections 50-289/79-22 and 50-320/79-29 the inspector determined that the licensee had not fully implemented dosimetry program changes to comply with a new regulation,10 CFR 20.102, " Determination of Prior Dose".
The licensee initiated a procedural change to comply with the new regulation.
The change was to be monitored by the NRC staff.
The status of the licensee's current procedure to determine prior dose was inspccted during inspection 50-289/81-07 and item 289/79-21-02 was closed.
Based upon this inspection and common dosimetry processing for both units, itcm (320/79-29-05) is considered closed.
(Closed) Inspector Follow Item (320/79-23-10), Review of
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Contractor Report Concerning Thermoluminescent Dosimeter (TLD) System Accuracy and Consistency.
In connection with significant inspection finding 3M/79-17-04, an audit conducted by a contractor prior to the March 28, 1979 accident was submitted to the NRC for review.
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l The report was reviewed and in light of significant modifications in the dosimetry procedures, staffing, documentation. calibration and training as documented in the health physh.
MI Unit 1 evaluation, the section on personnel dosimetry is no longer applicable.
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(Closed) Unresolved Item (320/79-29-07), Review Revised Procedure and Training of Dosimetry Personnel.
On October 29, 1979, a dosimetry technician preparing TLD
l extremity devices for issuance failed to realize no TLD elements were in the devices.
Upon discovering the mistake,the licensee removed the extremity devices from service.
Also, a revision to the applicable procedure was initiated along with instruction to personnel in the proper method for extremity dosimeter device preparation.
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-19-Based on discussions with licensee representatives and examination of dosimetry procedures and training records, the dosimetry procedures and instructions for dosimetry personnel were determined to be 6dequate.
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(Closed) Inspector Follow Item (320/ 79-13-03), Performance of Annual TLD Quality Assurance (QA) Test.
During review of the personnel dosimetry performed as a portion of inspection 50-320/79-13, the inspector identified that the licensee had not performed the annual QA test as required by procedure 1643, " Quality issurance Tests for TLD Dosimetry System".
Subsequent to inspection 50-320/79-13, the licensee issued a nev; QA procedure which required monthly, quarterly and annual QA tests.
Through review of records and discussions with licensee representatives, the inspector veri fied performance of these required tests.
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(Closed) Open Item (320/81-03-11), Performance of Annual (QA) Test for TLD's as Required by RCP 4220, "TLD Sy:> tem bality Assurance".
The status of the licensee's (QA) program for personnel dosimetry was reviewed during inspection 50-320/81-03.
RCP 4220 required monthly, quarterly, and annual irradiations of TLD's.
During inspection 50-320/81-03 the inspector verified performance of the monthly and quarterly tests.
Based on discussions with licensee representatives and review of selective records, the inspector verified performance of the required annual QA test for TLD's.
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Exposure Control
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(Closed) Infraction (320/80-02-05), Failure to Properly Post a Radiation Area.
On February 2,1980, an inspector was performing independent radiation surveys for verification of licensee's posting and labeling of radiation / radioactive material areas.
While performing surveys outside the EPICOR-I processing building, the inspector discovered the 7-10 millirem /hr unposted area.
These dose rates were verified by licensee surveys, using licensee survey meters.
The radiation levels were caused by a bag of contaminated material, reading 90 millirem /hr on contact, which was stored inside the EPICOR-I processing building, directly adjacent to the inner building wall.
This bag of contaminated material was subsequently shielded and later removed from the building.
This unposted radiation area was accessible for unrestricted access.
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-20-Based on examination of the licensee's stated corrective actions, discussions with licensee representatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Significant Inspection Findings (320/79-26-03 and 320/79-26-04), Failure to Follow Radiation Work Permit (RWP) - Procedure 1613.
On October 15 and 17,1979,the inspector examined the implementation of certain RWP's including RWP Nos. 2P777 and 28741.
The inspector noted that the licensee's failure to comply with protective clothing required by RWP No. 28777 resulted in one individual receiving contamination below the left knee.
The RWP called for coveralls and wet suit.
Paper coveralls were substituted for the wet suit by the shift HP foreman for the Unit 2 control post.
Only dry decontamination was to be performed; wet suits were not thought to be necessary.
During the decontamination, the individual accidentally knelt in a wet / oily spot, feeling slight wetness through the coveralls.
The RWP substitution was in violation with the procedure 1613, Section 5.0(d) which required changes to RWP's be approved and reflected on all copies by the Radiation Protection Supervisor / Foreman or the Shift Supervisor or their designees (320/79-26-03).
The inspector also noted that standing RWP's (SRWP)
required workers to have a dose rate instrument for entry
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to an area controlled by a SRWP.
On October 17, 1979 workers in the Cap Gun 1 area, controlled by SRWP 28741, did not have a dose rate instrument during moving and wipe down of resin liners.
Failure to have a dose rate instrument for an operation where high ri.diation levels are likely resulted in the inability for a proper evaluation of the radiation hazards to be performed as required by 10 CFR 20.201(b).
Radiation levels were later measured by licensee personnel to be up to 0.8 R/hr on contact (320/79-26-04).
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selective radiological operations and l
applicable procedures, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Significant Inspection Finding (320/79-26-01),
l Failure to Adhere to Adminstrative Procedures for High Radiation Areas.
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-21-On September 26, 1979, the inspector reviewed the imple-mentation of procedure 1050 which establishes administrative controis for high radiation areas.
As a result of the inspector review, at that time, several inadequacies were noted, including failure to perform the required audits of the high radiation areas key locker, failure to provide a unique lock to each high radiation area as required, failure to prepare and maintain a current list of high radiation area keys, and failure to document the status of high radiation area barricades.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Inspector Follow Items (320/79-23-06, 320/79-23-07, and 320/79-23-08), Contamination of Individuals.
On August 13,1979,one individual sustained contamination of the fingers of both hands as a result of handling a torn bag of used respiratory protection equipment.
Initial surveys of finger contamination indicated a maximum of approximately 100,000 dpm.
The individual underwent decontamination and whole body counting (320/79-23-06).
On August 27,1979.a second individual sustained radio-active contamination.
The contamination was of the arm and right thigh with measurements indicating a maximum contamination of 35,000 dpm (320/79-23-07).
On August 30,1979,thi ee licensee contractor employees sustained skin contamination while kneeling near pipe supports on the 281' elevation of the fuel handling building.
One individual was noted to have a maximum contamination level of 200,000 dpm of the right knee l
(320/79-23-08).
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Based on examination of these contamination incidents and
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review of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and ar plicable procedures, the inspector determined that adequate corrective actions i
were completed in this area.
l (Closed) Significant Irspection Findings (320/79-22-04,
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320/79-22-05, and 320/79-23-01) Failure to Control High l
Radiation and Radiation Areas Through Posting and Barricading.
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-22-During July and August 1979, tours of controlled and noncontrolled areas were made to verify licensee compliance
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with the requirements of 10 CFR 20,203, " Caution signs,
labels, signals and controls", Technical Specification Section 6.12, "High Radiation Area" and Station Health Physics Procedure 1610 " Establishing and Posting Areas".
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I During area tours and the performance of independent
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radiation intensity measurements, the inspector identified licensee failure to post, barricade and control access to
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radiation areas and high radiation areas.
The licensee, in a letter dated August 6,1979,
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committed to the review and revision of those procedures dealing with the control of Hign Radiation Areas.
The revised procedures were to include: 1) specific steps for
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the control of High Radiation Area access 2) a surveillance program for identification of new High Radiation Areas
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and 3) a surveillance program to ensure all High Radia-
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tion Areas are properly controlled.
i Based on examination of the licensee's stated corrective l
actions, discussions with licensee representatives, and
current examination of selected radiological operations i
and applicable procedures, the inspector determined that
adequate corrective actions were completed in this area.
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l (Closed) Significant Inspection Findings (320/79-13-02,
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320/73-17-05, 320/79-17-06 and 320/79-17-18), Failure to Post and Control High Radiation Areas.
During June and July 1979, tours of areas (both controlled i
I and uncontrolled) were made to verify licensee compliance l
with 10 CFR 20.203, " Caution Signs, Labels, Signals and i
Controls," Technical Specification Section 6.12, "High Radiation Area" and Station Health Physics Procedure 1610,
" Establishing and Posting Areas," dated September 30, 1977.
During area tours and the performance of independent radiation intensity measurements,the inspector identified failure to control and post access to high radiation areas.
Based on examination of the licensee's corrective actions, l
discussions with licensee representatives, and current l
examination of selected radiological operations and I
procedures, the inspector determined that adequate l
corrective actions have been completed.
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(Closed) Significant Inspection Findings (320/79-17-13
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and 320/79-17-16), Inadequate Radioactive Material Control.
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-23-During an inspection in July 1979, radioactive and contaminated material controls were reviewed for compliance with 10 CFR 20.203, " Caution Signs, Labels, Signals and Controls," and HPP 1682, " Control of Contaminated Tools, Equipment and Material," Revision 2, dated April 28, 1977.
Several instances of fai.ure to comply with the above requirements were noted.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed.
(Closed) Significant Inspection Finding (320/79-17-09),
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Improper Container Posting.
During a review of radioactive waste storage on June 26, 1979, it was noted that posting and labeling of radioactive waste at the south-east storage area was not consistent with the requirements of 10 CFR 20.203(f), " Containers,"
and Station HP Procedure 1620, Section 5.4, " Identification of Shipping Containers."
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed.
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(Closed) Inspector Follow Item (320/79-13-06), Failure to Follow Radiation Work Permit (RWP).
During May and June 1979,the inspector examined a sample (
of RWP's to verify adherence to RWP requirements.
Several I
instances of failures to follow RWP requirements were identi fied.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed.
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(0 pen) Violation (320/79-10-09), No Evaluation of Skin Contamination Exposure.
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-24-On March 28, 1979 and March 29, 1979, several individuals received skin contamination of the hand and other parts of the body sufficient to cause exposure rates in the range of 20-100 mR/hr when measured with a hand-held survey instrument and no evaluation of the dose to the skin of these individuals was made.
Licensee's corrective actions and the submitted licensee's dose evaluation report are still undergoing NRC review.
This item remains open pending ccmpletion of NRC assessment.
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(Closed) Violation (320/79-10-08), Chemistry and Radiation
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Protection (HP) Foremen Extremity Over Exposure.
On March 29, 1979, a chemistry foreman and a radiation protection foreman were permitted to handle a highly radioactive reactor coolant sample without adequate personnel monitoring and without first performing a survey of hand and forearm exposure rates.
Handling of this sample resulted in a calculated dose to the hands and forearms of the chemistry foreman of about 147 rem and a calculated dose to the hands and forearms of the radiation protection foreman in the range of 44 to 54 rem.
Based on examination of the licensee's corrective actions in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Inspector Follow Item (320/79-13-07), Adequate
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Instructions to Workers on Radiation Hazards Had Not Been Provided Pursuant to 10 CFR 19.
Adequate instructions to workers on radiation hazards had not been provided pursuant to 10 CFR 19.
Plant and contractor personnel must be fully informed about radiation health hazards associated with their work at the facility.
The licensee developed an ir.struction list, in the form l
of a check-off, which was posted at appropriate radiological
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work location Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed.
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(Closed) Violation (320/79-10-05), Overexposure in Excess of the Quarterly Limit.
On March 29,1979,an auxiliary operator was permitted to enter areas of the auxiliary building where exposure rates of up to 100 R/hr existed.
Radiation survey information and appropriate personnel monitoring were not provided to the operator for this entry. This contributed to the operator receiving a whole body dose of 3.170 rem for that calendar quarter.
Based on examination of the licensee's corrective actions in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current exumination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area.
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(Closed) Violation (320/79-10-02), Auxiliary Building High Radiation Area Not Locked.
From 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979 until the afternoon of March 30,1979, the doors to the am,iliary building were not locked and access was not otherwise controlled even though the building was known to be a high radiation area with radiation levels much greater than 1000 mrem /hr during this period.
Based on examination of the licensee's corrective actions as stated in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined thrt adequate co rrecti ve-actions were completed.
(Closed) Inspector Follow Item (320/79-04-01), Low Water
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Levei 'n Neutron Shield Tanks.
On March 9,1979, following a reactor trip, the neutron shield tanks were checked.
The inspector found that several of the tanks were dry and the remainder had low water level.
The licensee stated that this area would be
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examined.
A licensee representative stated that no level indication and no provision to refill these tanks at power was included in the design.
I During this inspection, the inspector examined this item and determined that,after the March 1979 accident at TMI and under the current plant condition,this concern is not appl ica bl e.
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-26-3.
Inspector Follow Items Inspector follow items are inspector concerns or perceived weaklerses in the licensee's conduct of operation (hardware or programmatic)
that could lead to noncompliance if left uncorrected.
Inspector follow items are addressed in paragraph 2.
Open Items Open 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 comnitted action.
This classification of findings was used primarily for licenser-commitments made as a result of the Special Panel that reviewed the TMI-2 Radiation Protection Program in October-November 1979.
Open items are addressed in paragraph 2.
5.
Significant Inspection Findings From March 1979 to October 1979, inspectors closely monitored licensee daily activities during post accident efforts.
At that time normal NRC enforcement actions were deemed inappropriate for the situation at TMI-2.
Accordingly inspector findings were termed "Signi ficant Inspection Findings" (SIF's) and these dealt with concerns in the following areas: containment of radioactive material; maintainance of core cooliny; and reduction of radiation dose to personnel.
A SIF could be a, mcompliance, deviation or unresolved item.
It could also be acccptable from a strict regulatory viewpoint but i
represented a weakness warranting improvement iri licht of the accident situation.
SIF's are addressed in paragraph 2.
6.
Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is an item of noncompliance, a
deviation, or acceptable.
Unresolved items are addressed in paragraph 2.
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Exit Interview On July 20, 1981 the resident inspectors met with licensee repre-sentatives (denoted in paragraph 1) to discuss the inspection scope
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and findings.
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