IR 05000320/1982003
| ML20054G751 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/02/1982 |
| From: | Fasano A, Oneill B, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054G746 | List: |
| References | |
| 50-320-82-03, 50-320-82-3, NUDOCS 8206220264 | |
| Download: ML20054G751 (24) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
50-320/82-03 Docket No.
50-320
License No.
DPR-73 Priority
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Category C
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Licensee:
GPU Nuclear Corporation
P.O. Box 480
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Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: March 29, 1982 - May 17, 1982
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Inspector:
[ew d
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B. O'Keill/ Ra ation Specialist date signed Reviewed by:
M.
Io M f!"J/
Z M.' Shantiak~, Seni~or R6diation Specialist d' ate signed y
Approved by:
f c~-, >
ef/>/P2 -
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. Fa9'ano, Chief, Three Mile Island Section dat4 signed Projects Branch No. 2 Inspection Summary:
Inspection conducted on March 29, 1982 - May 1/, 1982 (Inspection Report
No. 50-320/82-03)
Areas Inspected: Special, announced safety inspection of licensee action on
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previous inspection findings in the following radiological controls area:
training, respiratory protection, procedures, external dosimetry, internal dosimetry, instrumentation, control of radioactive materials, and ALARA (as low as is reasonably achievable) program. The inspection involved 145 inspector-hours.
Results: Of the 42 items reviewed, all are considered closed; 3 new Inspector Followup Items were identified (Details, paragraphs 4.b, 6.g, and 6.h).
No items of noncompliance were identified.
t 8206220264 820604 PDR ADOCK 05000320 i
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Details 1.
Persons Contacted General Public Utilities (GPU) Nuclear Corporation
- C. Adams, Quality Assurance (QA Auditor)
S. Bartman, Chemistry Technician R. Borders, Unit 1 Radiological Controls Training
- J. Byrne, Licensing Engineer S. Chaplin, Licensing Engineer W. Collier, Senior Radiological Controls Technician W. Cooper, Foreman Radiological Controls W. Craft, Radiological Assessment R. Croll, Foreman Radiological Controls J. Flanagan, Radiological Engineering Manager E. Gee, Supervisor Respiratory Protection F. Grice, Senior Project Coordinator, Radiological Controls W. Griffith, Foreman Radiological Controls K. Harner, Supervisor Chemistry
- J. Hildebrand, Manager Radiological Controls E. Kulik, Training, General Employee
- G. Kunder, Supervisor, Technical Specifications Compliance J. Larson, TMI-2 Licensing Manager
- D. LeQuia, QA Monitor T. Mulleavy, Radiological Training Supervisor P. Newkirk, Deputy Manager Radiological Field Operation R. Perry, Dosimetry, Bioassay, and Whole Body Count Manager J. Renshaw, Manager Radiological Field Operation P. Ruhter, Manager Radiological Technical Support R. Schauss, Computer Specialist D. Shriner, Manager Instrument Calibration and Repair Shop J. Sprucinski, Administrator Radiological Training D. Smith, Foreman Radiological Controls S. Taylor, Foreman Radiological Controls Porter Consultants, Incorporated G. Lodde, Special Project Coordinator Other licensee personnel were also interviewed.
- denotes those present at the exit interview.
2.
Inspection History of the Three Mile Island Unit 2 (TMI-2) Radiation Protection Program The following is a synopsis of the inspections of the TMI-2 Radiation Protection Program since the accident on March 28, 1979.
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-3-a.
Inspection No. 50-320/79-10. During the period March 28 -
July 31, 1979, IE conducted Investigation No. 50-320/79-10, into the TMI-2 Accident on March 28, 1979, and documented the results of that investigation in NUREG 0600, dated August 1979.
Subsequent discussions of commitments and corrective actions from initial licensee response for all cited items were documented in licensee letters dated February 11, May 19, July 10, December 23, 1980, and January 9,1981; and NRC letters dated January 23, August 27, September 10, and November 21, 1980.
b.
NUREG-0640 dated December 1979 - Report of the Special Panel on Three Mile Island, Unit 2, Radiation Protection Program.
In mid-September 1979, the 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 special panel report (NUREG 0640), the licensee developed the TMI-2 management plan which identified 47 commitments to implement the recommendations of the NRC Special Panel.
Five status reports addressing these commitments were submitted to the NRC.
In a letter dated February 24, 1981, from R. Arnold, GFU, to H. Denton, NRC, the licensee presented an updated status of fulfillment of the management plan commitments.
c.
Inspection 50-320/80-13. A special inspection was conducted concerning the radiation exposure of 6 individuals who entered the north make-up valve room on August 28, 1979.
d.
Inspection 50-289/80-22. A TMI-l radiological controls program evaulation was conducted by the NRC appraisal team July 28 -
August 8, 1980.
Some items addressed in NUREG 0600 were reviewed during the inspection. The inspection report addressed certain radiation protection activities common to both TMI-l and TMI-2.
e.
Inspection 50-289/81-07, Special TMI-l inspection (April 13 -
May 2, 1981). Inspection to assess implementation of corrective actions taken by the licensee as a result of weaknesses and items of noncompliance identified in inspection 50-289/80-22. This inspec-tion addressed the elements of the TMI-2 radiological control program which directly support TMI-1.
f.
Inspection 50-320/80-16, (September 15 - October 25,1980) (first followup to Special Panel Findings NUREG 0640).
Special inspection conducted to verify licensee status of management plan for the TMI-2 Radiation Protection Program.
At the time of this inspection, 33 previous commitments made to the NRC were considered complete by the licensee. The inspection followup on these items resulted in the G9C identifying 28 new open item a
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-4-g.
Inspection 50-320/80-18, (October 7,1980, and November 18 -
24, 1980). Special inspection concerning the entry of personnel into the TMI-2 Fuel Handling Building north and south makeup valve rooms on October 6, 1980.
h.
Inspection 50-320/81-03, (February 25 - April 3, 1981) (second followup to Special Panel Findings NUREG-0640). Special inspection conducted to access licensee action on previous inspection findings in the radiological controls areas. The NRC staff concluded that of the 47 initial commitments by the licensee, only 3 items remained open; 12 new findings were identified.
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Inspection 50-320/81-13, (July 18 - July 20,1981) (third followup to Special Panel Findings NUREG-0640 and to include all other inspection findings).
Special inspection to assess licensee action on previous inspection findings in the radiological controls areas.
Of 61 items reviewed, 59 items were closed.
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Inspection 50-320/81-18 (October 1 - October 15,1981).
Special inspection conducted to access licensee action on previous inspection findings related to the August 28, 1979, and October 6,1980, entries into the TMI-2 Fuel Handling Building.
makeup valve rooms.
3.
Licensee Action on Items Listed / Identified During 1978 a.
(Closed) Inspector Followup Item (320/78-BU-07) - Protection Afforded by Air-Line Respirators and Supplied-Air Hoods. The following documents were reviewed by the inspector.
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Inspection Report 50-289/81-29
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Response letter dated August 11, 1978, concerning 78-BU-07 from J. G. Herbein, Metropolitan Edison Company to B. H. Grier, Director, Region I, USNRC
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Radiological Control Procedure (RCP) 4052, Revision 5, dated February 22, 1982, Selection, Prescription, and Use of Respiratory Protection Equipment Bulletin 78-07 recommended lower protection factors than those listed in Table 1 of Regulatory Guide 8.15 (October 1976) for
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certain air-line respirators and supplied-air hoods.
From discussions with the Supervisor, Respiratory Protection, the inspector determined that the recommendations of 78-BU-07 were acknowledged during 1978 and incorporated into RCP 4052.
The inspector had no further questions in this area.
b.
(Closed) Unresolved Item (320/78-16-01), Environmental Thermol-uminescent Dosimetry Performance Evaluation.
(Closed) Unresolved Item (320/78-16-04), Cleaning, Inspection, and Maintenance of Settling Basins.
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-5-Both items identified above, were common to TMI-l (unresolved items 289/78-08-07 and 05) and TMI-2, and were addressed by the NRC in a Combined Inspection Report 50-289/78-08; 50-320/78-16. The items are further addressed in paragraphs 2.a and 2.c, respectively, of Inspection Report 50-289/82-05.
Based on the results of the TMI-l inspection, these items are also considered closed for TMI-2.
4.
Licensee Action on Items Identified During Inspection 50-320/79-10 a.
(Closed) Violation (320/79-10-07) - Chemistry Foreman's Whole Body Dose Exceeded Quarterly Limit. The following documents were reviewed by the inspector.
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Inspection Report 50-289/82-05, paragraphs 2.i and 2.j (Inspector Followup Items concerning the same violation)
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RCP 4041, Revision 1 dated April 10, 1982, ALARA (As Low As Is Reasonably Achievable) Program
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RCP 4122, Revision 2, dated December 16, 1981, Radiation Work Permit Inspection Reports 50-320/80-12,50-320/80-19,50-320/80-20,
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and 50-320/81-21 concerning TMI-2 emergency drills and planning
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Inspection Report 50-320/80-19, paragraph 7, concerning the temporary nuclear sample system
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TMI-2 Emergency Plan Implementing Procedure 1054.33, Revision 0, dated April 1, 1981, Handling High Activity Reactor Coolant Samples TMI-2 Emergency Plan Implementing Procedure 1054.9, Revision 0,
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dated April 1,1981, In-Plant Radiological Controls During Emergencies In the initial responses to this item, dated December 5,1979, and May 19, 1980, the licensee acknowledged the violation, and listed the following corrective actions.
(1) Radiological (ALARA) Engineers will review all work requests for tasks in areas or on systems having radiological implications (2) Additional training of chemistry and radiological controls personnel (3) Construction of a new Temporary Sampling System in TMI-2
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Based on examination of the licensee's stated actions, discussions
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with licensee representatives, and examination of selective radiological and emergency procedures, the inspector determined that.
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b.
(Closed) Violation (320/79-10-09)- No evaluation of the dose to individuals from skin contamination received March 28 and 29, 1979.
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The following documents were reviewed by the inspector.
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Inspection Report 50-320/81-03 Report dated December 5,19/9 (GQL 1499) concerning
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August 28, 1979 - Personnel Radiation Exposure, from R. F. Wilson, Director TMI-2 to B. H. Grier, Director, Region I, USNRC
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EGG-SD-5159, Technical Assessment of Radiation Overexposures at Three Mile Island from the August 28, 1979, Entry into the Unit 2 Fucl Handling Building Makeup Valve Room, June 1980.
i B. L. Rich and S. R. Adams
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PCI Technical Report-186, Investigation and Assessment of the
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Beta and Gamma Radiation Exposure of Auxiliary Operator "T" on j
March 28, 1979, dated December 19, 1980. Transmitted to V. Stello by G. K. Hovey letter LL2-81-0003, January 15, 1981 a
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i Based on examination of the above documents, the inspector determined that adequate licensee actions were completed for this item.
On May 14, 1982, licensee representatives reported to the Deputy Program Director of the NRC-TMI Program Office (TMIPO) that based on
the conclusions from the studies concerning beta exposure during the 1979 accident, a special 10 CFR 20.405 report was in preparation.
This report will address the beta exposure to the skin of the whole
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body (greater than 7.5 REM) for one individual.
The NRC will review the report, the individual's record, and the adequacy of the
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assumptions which form the basis for the assigned beta dose, once the report is received (320/82-03-01).
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(Closed) Violation (320/79-10-22) - A retraining program meeting or exceeding ANSI N18.1-1971 recommendations had not been maintained i
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The following documents were reviewed by the inspector.
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ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel
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ANSI /ANS-3.1-1978 (Revision of N18.1-1971), Selection and Training of Nuclear Power Plant Personnel
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Regulatory Guide 8.27 dated March 1981, Radiation Protection Training for Personnel at Light Water Cooled Nuclear Power Plants Regulatory Guide 1.8, Revision 1-R dated September 1975,
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Personnel Selection and Training
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TMI-2 Chemistry Procedure 1838, Revision 0, dated March 19,1982, Chemistry Technician Qualification / Training Standard TMI-2 RCP 4022, Revision 1, dated November 25, 1981,
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Radiological Field Operations Personnel Qualification / Training Standa rd TMI-2 Administrative Procedure 1055, Revision 0, dated
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April 1,1981, Emergency Planning Drills THI-2 Administrative Procedure 1056, Revision 0, dated
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April 1,1981, Emergency Planning Training TMI-2 Radiological Controls Training Manual, Revision 5, dated
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October 30, 1981 Based on examinations of the above documents, and discussions with licensee representatives, the inspector determined that the current retraining program for members of the radiation protection and chemistry staffs satisfies requirements of the Technical Speciti-cations (TS) and the recommendations of the ANSI N18.l-1971, and ANSI /ANS3.1-1978.
d.
(Closed) Violation (320/79-10-24) - Results of ground level radiation surveys conducted during March 28-30, 1979, in offsite areas bordering the TMI site were not documented in a manner which permitted a precise evaluation of the type of radiation (Beta / Gamma)
which existed in the environs.
The following documents were reviewed by the inspector.
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Licensee responses dated December 5, 1979, and May 7, 1980, to Investigation Report 50-320/79-10
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Inspection Reports 50-320/80-12, 50-320/80-19, 50-320/80-20, and 50-320/81-21 concerning TMI-2 emergency drills and planning
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TMI-2 Emergency Plan Implementing Procedure 1054.10, Revision 1, dated February 25, 1982, Onsite/offsite Radiological Monitoring
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TMI-2 Emergency Plan Implementing Procedure 1054.12, Revision 0, dated April 1, 1981, Environmental Monitoring
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TMI-2 Emergency Plan Implementing Procedure 1054.11, Offsite Radiological Monitoring
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-8-Previous to this inspection period, the inspector accompanied the offsite monitoring team during an emergency drill held on December 10, 1980. On April 30, 1982, the inspector reviewed current procedures and the contents of an offsite survey kit with TMI-2 Senior Radiological Controls Technician.
Based on examination of documents, observations, and discussions with licensee representatives, the inspector determined that the present method used for documentation of offsite ground level radiation surveys permits an adequate evaluation of the type of radiation in the environs.
e.
(Closed) Violation (320/79-10-25) - lack of complete records of the radiation exposure and dose assessment for individuals exposed during the period March 28, 1979, to June 30, 1979.
The following documents were reviewed by the inspector.
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Licensee responses dated December 5,1979, and May 7,1980, to Investigation Report 50-320/79-10
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NRC memorandum, J. T. Collins, to J. G. Herbein, Required Licensee Actions as a Result of Investigative Report No.
50-320/79-10, dated October 18, 1979
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Met-Ed/GPU letter, GQL-1362, J. G. Herbein to J. T. Collins, Required Licensee Actions as a Result of Investigative Report No. 50-320/79-10, dated October 29, 1979
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Met-Ed/GPU letter, TLL-045, R. F. Wilson, to V. Stello, Commit-ments made in Response to Notice of Violation and Notice of Proposed Issuance of Civil Penalties, (December 5,1979), dated February 11, 1980
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Met-Ed/GPU letter, TLL 655, H. D. Hukill to V. Stello, Investi-gation Report 79-10 Clarification, dated December 14, 1980 l
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Met-Ed/GPU letter, LL2-81-0176, G. K. Hovey to V. Stello, j
Investigation Report 79-10 Clarification, dated July 8, 1981
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GPU Nuclear letter, 4400-82-L-0001, J. J. Barton to H. N. Berkow, Personnel Exposure and Monitoring Record, dated January 12, 1982 By a letter dated January 12, 1982, the liccnsee reported the completion of a project involving the review and updating of 2,373 personnel dosimetry records.
Included with the letter was a revised
" Personnel Exposure and Monitoring Record for 1979" in accordance with the requirements of 10 CFR 20.407.
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l i-9-Based on examination of the above documents, and discussions with
licensee representatives, the inspector determined that licensee exposure records for the period March 28,-1979, to June 30,-1979, are now complete. The inspector had no further questions in this area.
5.
Licensee Action on Items Identified During NRC Radiation Specialist Shift
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Inspections (1979-1980)
I a.
(Closed) Inspector Followup Item (320/79-13-05) - Adequacy of equip-I ment calibration and records of calibration reexamination.
The following documents were reviewed.
i Inspection Report 50-320/79-17
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Inspection Report 50-320/81-03 i
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TMI-2 RCP 4261, Revision 3, dated December 11, 1981, Quality
Assurance Program for Radiological Instruments l
I The portable radiation detection instrumentation used at TMI-2 is I
now calibrated at the onsite calibration facility. A status board
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for all instrumentation showing calibration due dates is maintained at the TMI-2 Radiological Control Office.
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i The inspector interviewed radiological control technicians and foremen, and conducted a review of the current TMI-2 instrument
I calibration status on April 30, 1982. The inspector interviewed the Manager, Instrument Calibration and Repair Shop on May 4,1982.
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Based on examination of licensee procedures, discussions with l
licensee representatives, and observation of an instrument i
calibration, the inspector determined that the licensee's
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calibration methods and records are adequate.
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b.
(Closed) Significant Inspection Finding (320/79-17-17) - Air samples
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collected in the TMI-2 Auxiliary Fuel Handling Building from June 30 j
to July 2,1979, revealed the presence of high concentrations of airborne beta emitters.
Preliminary analysis indicated that, while
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no exposures in excess of regulatory limits were likely to have
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occurred, approximately 100 individuals entered areas while the airborne conditions existed, and appropriate bioassays were
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necessary to demonstrate that no internal depositions occurred.
The inspector reviewed GPU Nuclear Memorandum (9210-0596), Review of the Elevated Airborne Beta Concentrations and Subsequent Bioassay
Results During the Period of June 26, 1979, through July 10, 1979, j
dated May 17, 1982.
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-10-The report ad' dressed the bioassay results of selected individuals, and calculations concerning " worst case" exposure due to the high airborne beta concentrations.
Based on review of the report, the'
inspector determined that no exposure in excess of regulatory limits occurred as a result of the entries into the airborne areas during June and July 1979.
c.
(Closed) Significant Inspection Finding (320/79-22-06) -. Storage of radioactive materials in an uncontrolled area.
The following documents were reviewed by the inspector.
TMI-2 RCP 4150, Revision 0, dated September 29, 1981,
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Radioactive Material Transfer Accountability TMI-2 RCP 4152, Revision 1, dated October 8,1981, Radioactive
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Material Identification TMI-2 RCP 4160, Revision 4, dated March 3, 1982, Establishing
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and Posting Areas
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TMI-2 RCP 4015, Revision 0, dated July 20, 1980, Administrative and Emergency Exposure and Contamination Limits Based on examination of the above procedures, and observations during plant tours, the inspector determined that the licensee had taken necessary corrective actions to ensure control of radioactive and contaminated materials, d.
(Closed) Significant Inspection Finding (320/79-22-08) - Failure to utilize breathing air system properly.
The following documents were reviewed by the inspector.
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RCP 4052, Revision 5, dated February 22, 1982, Selection, Pre-scriptions, and Use of Respiratory Protection Equipment GET (General Employee Training) 103 Training Guide, Respiratory
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Protection for the Radiation Worker, dated April 15, 1982 The inspector discussed the above finding with the Supervisor, Respiratory Protection. The licensee representative stated that this finding had prompted increased efforts during the summer and fall of 1979 to establish a " disciplined" respiratory protection program at TMI to include the following.
(1) Use of only authorized and inspected equipment (2)
Increased frequency of testing the quality of service air (3) Better training of workers
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-11-Based on discussions with licensee representatives, the results of-previous inspection findings concerning the TMI Respiratory Protection Program, and observations of radiological operations involving use of respiratory protection equipment, the inspector determined that the licensee had taken necessary corrective actions.
I e.
(Closed) Significant Inspection Finding (320/79-22-09) -' Calibratiori j
and Operation Deficiencies of Air Sample and Proportional Counters.
(Closed) Significant Inspection Finding (320/79-22-10) - Inaccurate Calibration of " friskers" and Smear Counters.
(Closed) Significant Inspection Finding (320/79-22-11) - Inaccurate
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Cesium-137 Counting Efficiencies for Proportional Counters.
The following documents were reviewed by the following.
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Inspection Report 50-320/79-28 l
Inspection Report 50-289/82-05
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I TMI-2 RCP 4101, Revision 1, dated June 9,1981, Air Sample
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Counting, Handling, and Actions TMI-2 RCP 1712, Revision 6, dated November 25, 1981, Operation,
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Calibration, Maintenance, and Repair of the Ludlum Portable j
Scaler, Model 2000 TMI-2 RCP 1742, Revision 4, dated April 28, 1982, Operation,
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Calibration, and Maintenance of Radiation Monitor Model RM-14
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TMI-2 RCP 1718, Revision 2, dated January 12, 1982, Operation,
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Calibration, Maintenance, and Repair of the PC-4
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TMI-2 RCP 1/22, Revision 2, dated January 7,1982, Operation,
Calibration, Maintenance, and Repair of the PCC-11T/DS-2
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TMI-2 Chemistry Procedure 1989, Revision 0, dated
October 8, 1981, Gross Beta and Y Counting Using a Beta
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Scintillation Detector On April 30, 1982, the inspector provided the licensee with check sources of cesium-137 and strontium-90. The inspector observed the licensee counting of these sources at the TMI-2 Health Physics laboratory, and at the TMI-2 Radiological Control Point Frisking
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Stations. An independent count of the sources was performed using
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onsite NRC counting equipment. The following are the counting i
results.
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-12-TMI Health Physics NRC Measurement Laboratory Cesium-137 0.034 microcurie (uCi)
0.0349 uCi (Ludlum 2000)
0.045 uCi RM-14 Quick Check at Standard 15%
Efficiency Strontium-90 0.021 uCi 0.041 uCi (Ludlum2000)
Using Standard Efficiency of 15% and 7:3 ratio ganna/heta 0.063 uCi RM-14 Quick Check On May 4, 1982, the inspector provided the licensee with a check'
source of the strontium-90. The inspector observed the counting of the check source at the TMI-2 Radiochemistry Counting laboratory.
The source was also counted using the onsite NRC equipment. The following are the counting results.
TMI Radiochemistry NRC Measurement Laboratory Strontium-90 0.0206 uCi 0.0213 uCi (using Beta scintillation counting)
Conclusions:
(1) Counting equipment in the TMI-2 Health Physics laboratory wac, calibrated for Cesium-137.
(2) Licensee's quick check method used at the TMI-2 Health Physics laboratory overestimates Strontium-90 Beta contributions; such estimates appear to be conservative.
(3) Beta Scintillation Counting equipment in the radiochemistry counting laboratory was calibrated for Strontium-90.
(4) "Frisker" efficiencies for Cesium-137 were acceptable, f.
(Closed) Inspector Followup Item (320/79-23-09) - Possible overexposure of six individuals who entered the north makeup valve room on August 28, 1979
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I-13-This item was closed by Special Inspection Report 50-320/80-13 (letter to licensee on July 1, 1981).
Based on review of this report, the inspector had no further questions regarding this item.
g.
(Closed) Inspector Followup Item (320/79-29-04) - Review licensee's evaluation of counting equipment calibration techniques and c
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efficiency determination.
The following documents were reviewed by the inspector.
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Inspection Report 50-320/81-13
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Inspection Report 50-289/82-05
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Based on review of the above documents, and inspector observations, and conclusions regarding Significant Inspection Findings 320/79-22-09, 320/79-22-10, and 320/79-22-11, the inspector
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determined that counting equipment calibration techniques and efficiency daterminations were adequate.
h.
(Closed) Violation (320/79-29-06) - Failure to Secure and Store Licensed Radioactive Materials in Accordance with 10 CFR 20.207(a)
and (b).
On November 14, 1979, at least seven drums of dry waste material which were at that time thought to be non-radioactive were turned over to a vendor to be transported for disposal at the Harrisburg E
city refuse dump.
The material was refused by the operator of the E
facility on the grounds that the dump was not suited for disposal of
steel drums.
The vendor transported the drums to a warehouse for
overnight storage, and returned the material to the TMI facility on November 16, 1979.
Subsequent surveys by the licensee revealed that
3 two of the drums had radiation levels on the external surface of f
3 mR/hr and 0.5 mR/hr.
p Further investigation by the licensee and the NRC indicated that the
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drums were not identified as containing radioactive material; however, one drum had a "LSA" (low specific activity) stencil
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painted over and the other had portions of a radioactive material
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sticker affixed.
Upon discovery the licensee initiated immediate action to better control the handling of material that is normally collected as trash m
to prevent recurrence of this type of incident. A letter to senior Metropolitan Edison staff from the Vice-President and Radiological Controls Manager details the actions that were taken by the licensee
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in immediate response to the event.
Further, a Licensee Event Report (LER) was initiated regarding this event.
g The following documents were reviewed by the inspector.
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-14-Licensee respo ses dated February 5,1980, and October 9,1930,
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to' Inspection Report 50-320/79-29
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TMI-2 RCP 4152, Revision 1, dated October 8,1981, Radioactive-Material Identification
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TMI-2 RCP 1618, Revision.3, dated April 6, 1982, Packaging of Radioactive Material
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TMI-2 RCP 1618F, Revision.3, dated May 4,1982, Non-compactable Packaging (LSA boxes, drums, and other acceptable containers)
This occurrence prompted the licensee to institute a drum color coding system. As specified by procedure, yellow drums contain radioactive materials and contaminated trash, white drums contain radioactive / contaminated laundry, and green drums contain all nonradioactive materials.
Based on the examination of the above documents, and observations, the inspector verified that corrective actions and actions to prevent recurrence of such incidents were completed.
i.
(Closed) Inspector Followup Item (320/80-01-02) - NRC to review report of contaminated TLD (thermoluminescent dosimeter) badges.
An attempt to use 50 previously exposed personnel TLD's to take supplemental environmental dose rate measurements, from November 1 to November 30, 1979, resulted in the discovery that at least 10 of the 50 badges were contaminated with Cesium-134 and Cesium-137.
The lice see's review of the discovery resulted in a decision to count and analyze, first a few, and finally, all of the TLD badge sets.
Five detectable contaminated TLD cards were identified on December 21, 1979, and five more on January 22, 1980.
The most contaminated TLD card was measured at 11,011 disintegra-tions per minute (dpm) Cs-137 and 3,685 dpm Cs-134. All the contam-inated badges were removed from use.
The following documents were revie W by the inspector.
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GPU Nuclear memorandum, 9210-0572, Investigation of Contam-inated TLD Cards and TLD Cases, G. M. Lodde to R. O. Perry, dated April 27, 1982
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Metropolitan Edison Company memorandum, TMI-II-R-12012, Obser-vance of and Recommendations on TLD Contamination, Enclosures:
(1) SAI Isotopic Analysis on TLD #300124, (2) TLD Calculations, W. T. LaBonte to P. E. Ruhter, dated December 28, 1979
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Metropolitan Edison Company memorandum, TMI-II-R-12070, TLD Card Contamination Analysis, R. G. Rolph to I. R. Seybold, dated January 17, 1980
,
.
.
-15-
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Metropolitan Edison Company memorandum, TMI-II-R-12087, Conta-mination of Area Monitoring TLD's (November), M. R. Hurshman to I. R. Seybold, dated January 23, 1980
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Metropolitan Edison Company memorandum, TMI-II-R-12111, Inves-tigation of Contaminated TLD's, M. P. Bryer to Distribution, dated February 1, 1980 Summary Data for TLD's used for Area Monitoring during
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November 1979
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Gamma Analysis Sunmary Sheets for Contaminated TLD's, January / February 1980 Based on review of the above documents, and discussions with licensee representatives, the inspector determined that the TLD contamination incident identified on December 21, 1979, was investigated and evaluated.
The inspector further determined that no licensee recorded measurements were affected and adequate actions to prevent recurrence were completed.
J.
(Closed) Violation (320/80-02-06) - Failure to Adequately Survey for Airborne Tritium Activity in the Fuel Handling Building During Transfer of Water on February 16, 1980 - February 26, 1980.
The following documents were reviewed by the inspector.
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Licensee response dated July 3, 1980, to Inspection Report 50-320/80-02
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Letter dated September 10, 1980, concerning Inspection Report 50-320/80-02, B. Grier, Director, Region I, USNRC, to R Arnold, Senior Vice-President, Metropolitan Edison Company.
9ased on the data submitted to the NRC in the licensee response
.iated July 3, 1980, the inspector determined that this item was c'.osed (Details, paragraph 7.b).
k.
(Closed) Violation (320/80-11-04) - Failure to Properly Post Notices to Workers in Accordance with 10 CFR 19.11.
The licensee's response to Inspection Report 50-320/80-11-04, dated November 13, 1980, was reviewed by the inspector.
On April 12, 1982, and April 19, 1982, the inspector discussed 10 CFR 19.11, Posting Requirements with the TMI Radiological Controls Assessor and determined that five locations at TMI-1, and seven locations at TMI-2 are properly posted.
1.
(Closed) Violation (320/80-11-06) - Failure to Prevent Removal of Contaminated Materials in Excess of Release Criteria.
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,
.
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-16-During June 20, 1979, through June 26, 1980, a number of items were released from the TMI-2 control point to clean areas by several health physics technicians. These items included miscellaneous materials and equipment. Criteria for release of the items varied from technician to technician and was, in some cases, not as stringent as required by the licensee's release criteria.
Resurvey of the materials released disclosed three items were contaminated
above 500 dpm/100 cm beta-gamma.
The following documents were reviewed by the inspector.
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Licensee response dated November 13, 1980, to Inspection Report 50-320/80-11 TMI-2 RCP 4100, Revision 4, dated February 2,1982, Radio-
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logical Surveys TMI-2 RCP 4102, Revision 3, dated November 3, 1982, Radiation
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Surveys
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TMI-2 RCP 4103, Revision 3, dated October 26, 1981, Surface Contamination Surveys Based on review of the above documents, discussions with licensee representatives, and observations of radiation survey and monitoring techniques, the inspector determined that corrective actions have been completed.
m.
(Closed) Inspector Followup Item (320/80-17-02) - During November and December 1980, the licensee identified trace cesium-137 and tritium (H-3) levels in the long term spent resin storage facility.
A Gamma spectroscopic anlaysis of a water sample from the sump used to collect drainage for the long term spent resin storage facility (Module A and B) indicated trace amounts (1.2 x 10-8 uCi/ml) of Cs-137. Tritium analysis indicated 3 x 10-5 uCi/ml. The licensee suspected that this activity could have resulted when rain water entered into the modules and washed down low levels of loose surface contamination.
Module A had been in use as a repository for EPICOR-I and EPICOR-II spent resins since early 1980, (the module has 60 cells, each cell can accommodate one 6' x 6', or two 4' x 4' liners). The A Module contained approximately 50 liners. The B module was empty. The drains from both the A and B modules flow to a common sump.
the occurrence of trace activity in the water from the long term spent resin storage facility sump was closely monitored by the onsite NRC staff, and reported in the following NRC TMIPO weekly status reports.
M
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-17-
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Report dated December 8, 1980 (period November 23 -
December 6,1980)
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Report dated February 9,1981 (period February 1 - 7, 1981)
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Report dated February 13, 1981 (period February 8 - 14, 1981)
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Report dated February 23,1981 (period February 15 - 21, 1981)
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Report dated May 22, 1981 (period May 17 - 22, 1981)
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Report dated August 17, 1981 (period August 9 - 15, 1981)
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Report dated November 9, 1981 (period November 1 - 7, 1981)
To date the quantities of radioisotopes in the sump water have not shown any increase. The TMIP0 staff will continue to trend the results of the analysis of sump samples.
n.
(Closed) Violation (320/80-17-06) - Failure to use current pro-cedure, and required step sign off during transfer of radioactive resin liner from EPICOR-I to onsite staging facility.
The following documents were reviewed by the inspector.
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Licensee responses dated May 5, 1981, and July 23, 1981 to Inspection Report 320/80-17-06
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Letter dated June 25, 1981, regarding Inspection Report 50-320/80-17 from R. Keimig, Region I, USNRC, to G. Hovey, Director, TMI-2 The inspector determined that the EPICOR I system was dismantled and activities involvi19 the transfer of EPICOR I liners were no longer conducted at TMI.
6.
Followup of Inspection 50-20/81-03 Items a.
(Closed) Inspector Follovg Items (320/81-03-01; 320/81-03-04) -
Interviews with the Radio:cgical Controls Department personnel during March and April 198; indicated an apparent attitude problem.
Two areas were noted by technicians as affecting job satisfaction.
One was the procedure control system, and the other was management responsiveness to problems identified by technicians.
The area of inter-department and intra-department interfacing / working relation-ships remained open pending further NRC assessment to assure no adverse affect on the proper implementation of the Radiological Controls Program.
The inspector conducted interviews during April 1982, with 12 members of the Radiological Controls Department (5 foremen and 7 technicians).
Based on these interviews, the inspector determined
-18-that the problem areas noted during inspection 50-320/81-03, e.g.,
the morale, verbatim compliance with procedures, difficulty in obtaining necessary changes to procedures, and operational pressures on the Radiological Controls Department staff, had diminished. With one exception, the staff members interviewed stated that the TMI-2
'
Radiological Controls Program had considerably improved.
Areas of improvement, as stated by the Radiological Controls Depart-ment personnel, were:
(1) Greater visibility and concern by the new Manager of Radiological Controls (2) Assignment of radiological engineers to the Radiological Controls Department (3) New dynamic style of the Deputy Manager Radiological Field Operations (4) CompletOn of all major procedural changes (5) Better work relation with other departments Based on the results of the interviews, the inspector had no further questions regarding these items.
b.
(Closed) Inspector Followup Item (320/81-03-02) - Effectiveness of Radiological Assessment Without Formal Tracking System for Findings.
The inspector interviewed the new Radiological Assessor (assumed position October 5, 1981) on April 12, 1982.
The licensee's management stated that the assessor acts as the " eyes and ears" of management on radiological matters.
During the interview with the inspector, the assessor stated that he informally tracks all findings.
Baed on review of the assessor's reports to management, it appeared that the assessor's findings contribute to improvements in the Radiological Controls Department.
,
c.
(Closed) Inspector Followup Item (320/81-03-05) - All TMI-2 Radio-logical Controls Department documents not issued.
The following documents were reviewed by the inspector.
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GPU Nuclear Organization Plan, dated May 27,1981,(includes program responsibility and functions)
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Position Specifications (maintained in the office of the Senior Project Coordinator, Radiological Controls)
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GPU Nuclear Corporation Organization Chart, as of February 1,1982, (includes personnel charts)
.
-19-The inspector reviewed the above documents for consistency with applicable standards (ANSI /ANS-3.1-1978 and Regulatory Guide 1.8),
consistency with each other, and to ensure that department inter-facing responsibilities were adequately addressed.
Based on this review, the inspector had no further questions regarding this item.
d.
(Closed) Inspector Followup Item (320/81-03-06) - Adequacy of the training of new radiological workers and radiological control technicians.
(Closed) Inspector Followup Item (320/81-03-07) - Verification of the adequacy of instruction on special radiological problems during radiological control technician training.
(Closed) Inspector Followup Item (320/81-03-08) - NRC to review adequacy and implementation of the TMI-2 Radiological Controls Training Manual.
(Closed) Violation (320/80-17-07) - Failure to maintain direction of TMI-2 radiological controls technician training under the Supervisor
- Station Training as required by Technical Specification.
The following documents were reviewed by the inspector.
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TMI-2 Radiological Controls Training Manual, Revision 5, dated October 30, 1981
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Radiological Controls Information Guide (handout to all radio-logical controls technicians)
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TMI-2 RCP 4022, Revision 1, dated November 25, 1981, Radio-logical Field Operations Personnel Qualification / Training Standard
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Letters dated May 5, 1981 and July 23, 1981, in response to Inspection Report 50-320/80-17
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TMI-2 Technical Specification Change Request No. 28, dated March 5, 1982 (4400-82-L-0030)
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Letter dated April 23, 1982, (4400-82-L-0067) from J. Barton, Acting Du ector, TMI-2 to J. Stolz, NRC, describing TMI-2 training requirements summary for Radiological Controls Foremen and Technicians The inspector interviewed members of the TMI-2 Radiological Controls Training staff on April 14, 1982, and April 20, 1982. The inspector attended and observed the examination (oral board) of one junior technician on April 20, 1982.
During the interview of the Radiological Controls Department staff (5 foremen and 7 technicians) conducted during April 1982, the inspector discussed the adequacy of the overall training given to
.
.
-20-new radiological workers, and radiological control technicians, e.g., special radiological problems. The consensus of the Radiological Controls Department staff' interviewed was that this.
training was adequate.
Based on review of documents, discussions with licensee represen-tatives, and observations, the inspector determined that the licensee's current radiological training is adequate.
e-(Closed) Inspector Followup Item (50-320/80-16-13) - NRC to review the Radiological Control Procedure Manual.
(Closed) Inspector Followup Item (50-320/81-03-10) - NRC review of interim measures to expedite radiological controls procedure review.
,
lhe following documents were reviewed by the inspector.
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The three volume TMI-2 Radiological Controls Procedure Manual
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The three volume TMI-2 Radiological Controls Instrumentation Procedures
j The inspector interviewed members of the Radiological Controls staff i
concerning the measures used to expedite changes to the 4000 series of procedures which were placed in use during 1981. The inspector
l determined that although the review process has remained unchanged (still takes two months to revise a procedure), a new temporary-
,
procedure change method has been effective in expediting the-procedure review process (Details, paragraph 7.a).
Based on review of documents, and discussions with licensee
!
representatives, the inspector had no further questions regarding i
these items.
f.
(Closed) Inspector Followup Item (320/81-03-09) - NRC to review General Employee Training (GET) Requalification program.
.
I The following employee training handouts were reviewed.
!
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GET-101, Basic Indoctrination for the Non-Radiological l
Controlled Area Worker, Revision 1, dated November 15, 1981
.
'
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GET-202, Radiation Worker Training Requalification Program l
Student Handout, Revision 0, dated December 24, 1981
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GET-103, Respiratory Protection for the Radiation Worker, Revision 0, dated April 15, 1982 i
Based on review of the above documents, and attendance / participation during employee requalification, the inspector determined GET Requalification Program is adequat.
-21-g.
(Closed) Inspector Followup Item (320/80-13-06) - Licensee to review adequacy of TLD responses to beta radiation and mixed beta-gamma fields.
TLD data indicated problems with response in beta fields.
Penetra-ting (gamma) exposure was overestimated due to the inadequate shield thickness over the gamma chip.
Non-penetrating (beta) exposure measurements using TLD's were orientation and energy dependant. The licensee committed to review the dosimetry problem and provide a solution by December 1,1980.
(Closed) Inspector Followup Item (320/80-16-16; 320/81-18-0) - NRC to review upgrading of TLD capabilities and accuracy of response to different beta energies and mixed beta-gamma radiation fields.
Review of basic TLD data indicated problems with the response of the dose monitoring equipment in beta fields.
During 1981, the licensee reported that a new TLD system (reader and badges) had been purchased,and that field testing of the new system would begin during the first quarter of 1982 on a limited basis.
The following documents were reviewed by the inspector.
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Inspection Report 50-320/81-03
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Inspection Report 50-320/81-18
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Inspection Report 50-320/82-02
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Interim Status Report of the TMI Personnel Dosimetry Project, dated June 1981, by B. L. Rich, J. L. Alvarez, and S. R. Adams (GEND 004)
Based on review of the above documents, discussions with licensee representatives, and observations, the inspector determined that the licensee commitment to review the TMI-2 dosimetry problem had been met. However, full implementation of the system and an independent evaluation to verify the system performance will continue to be followed by the NRC in subsequent inspections (320/82-03-02),
h.
(Closed) Inspector Followup Item (320/80-16-28) - NRC to review implementation of an exposure tracking system and issuance of exposure reports to supervision.
(Closed) Inspector Followup Item (320/81-03-12) - NRC to review effectiveness of man-rem estimates and exposure tracking.
During inspection 50-320/81-03, it was verified that the ALARA group within Radiological Technical Support was tracking exposure for approximately 10 tasks being performed at TMI-2 (i.e., reactor building maintenance, reactor building data acquisition, radioactive
_
.
.
-22-trash handling, etc.).
It was also determined that man-rem estimates had been made for TMI-2 for the year, and also for the data acquisition phase of reactor building entries.
The following documents were reviewed by the inspector.
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GPU Nuclear Memorandum 9240-237, RC# 22.0, Report of Person-Rem Tracking by Exposure Tracking Number (ETN), dated October 27, 1981 Radiation Work Permit Detail List (TMI-2) (computer printout)
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for report period October 2/,1981 - March 26,1982, Reactor Building Entries
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GPU Nuclear Memorandum 9240-842, Decon Experiment, dated April 15, 1982
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GPU Nuclear Memorandum 4200-82-116, Radiation Exposure by Job, dated March 8, 1982
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GPU Nuclear Memorandum 4000-82-108, Radiation Exposure by Job, dated March 10, 1982
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Man-Rem by Job Accounting (computer printout) during period January 1,1982 - March 31,1982 Based on review of the above documents, and discussions with licensee representatives, the inspector determined that the licensee has in-place a man-rem tracking system which sat:sfies all previous ceninitments to the NRC. However, at the time of this inspection, Radiological Controls Procedure 4048, Exposure Tracking, was still in a draf t format. Licensee representatives stated that full implementation of RCP 4048 is expected by the end of July 1982.
The NRC will continue to review the full implementation of the man-rem tracking system, and the setting of dose goals, and dose projections in a future inspection (320/82-03-03).
7.
Licensee Actions on Items Identified During NRC Radiation Specialist Shift Inspections (1981)
a.
(Closed) Violation (320/81-01-02) - Procedural change (removing a radiation limit) implemented without adequate administrative controls.
The following documents were reviewed by the inspector.
Licensee responses dated May 29, 1981, and July 27, 1981, to
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Inspection Report 50-320/81-01
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Letter dated August 17, 1981, from R. Keimig, USNRC to G. Hovey, Director, TMI-2, Concerning Inspection Report 50-320/81-01
l
i
-.
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-23-TMI-2 Administrative Procedure (AP) 1001, Revision 26, dated
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October 20, 1981, TMI Document Control The inspector noted that the present AP 1001 governing TMI-2 Document Control and Temporary Changes (TCN) to procedures includes the following added restrictions, "If the activity of procedure involves any kind of Radiological involvement, impact or interface then a third party Rad. Engineer must review and approve the change prior to implementation." This new method of generating a TCN (involving a radiological concern) to a procedure has become known as "the two man plus rule."
Based on review of documents, discussions with licensee representatives, and observations, the inspector had no further questions concerning this item.
b.
(Closed) Unresolved Item (320/81-06-01) - NRC to review circum-stances regarding apparent elevated tritium (H-3) concentrations in the fuel handling building.
On April 23, 1981, the licensee obtained results for an air sample in the fuel handling building (FHB). The airborne tritium (H-3)
concentration was 3.1 x 10-5 uCi/cc. The results of a second sample showed 2.2 x 10-5 uCi/cc(H-3).
The following documents were reviewed by the inspector.
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TMI-2 RCP 1758.2, Revision 3, dated April 28, 1982, Operation of Portable Air Samplers
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Standing Order Manual - Radiological Controls Department, No. 11, dated March 11, 1982, Tritium Exposure Control Program
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Radiological Investigation Report No.81-020, dated April 30, 1981, to include, Report of Apparent Airborne Tritium, Spent Fuel Pool B Processed Water Transfer for the Period April 27, 1981, through May 1, 1981
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GPU Nuclear Memorandum (9240-874) dated April 22, 1982, Evaluation of Airborne Tritium Sampling Program for the Submerged Demineralizer System During review of this incident, the inspector determined that the reported H-3 concentrations were in error due to an improper setting of the sample pump air flow, and that actual H-3 concentrations were 7.2 E-7 uCi/cc and 5.0 E-7 uCi/cc, respectively. The inspector verified that RCP 1758.2, Operation of Portable Air Samplers, was reviewed and rewritten to allow for accurate and consistent H-3 monitoring.
c.
(Closed) Inspector Followup Item (320/81-13-01) - Licensee to repair roof flashing between the reactor building and adjacent buildings.
]
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._
_ _ _ _ _ _ _
.
-24-The inspector determined that the service building roof had been resurfaced during October 1981, and that the flashing repairs were completea during December 1981.
The inspector noted during plant tours, that these repairs were effective in reducing rain water leakage into the service and control building basement.
8.
Open Findings / Items Open inspection items are findings in which turther action is warranted by the licensee to fulfill the intent of commitments to the NRC or further review by NRC is warranted to assure that the licensee is meeting the intent of committed action. Open items identified during this inspection are addressed in paragraphs 4.b, 6.g, and 6.h.
9.
Unresolved Items An unresolved item is a finding about which more information is needed to ascertain whether it is a violation, a deviation, or acceptable.
Unresolved items reviewed and closed in this inspection report are addressed in paragraphs 3.b and 7.b.
10.
Exit Interview On May 17, 1982, the inspector met with licensee representatives (denoted in paragraph 1) to discuss the inspection scope and findings. No violations were identified.
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