IR 05000320/1986009

Safety Insp Rept 50-320/86-09 on 860719 & 0829.Violation Noted:Failure to Dispose of Contaminated Tripod Properly

ML20214T495
Person / Time
Site:	Three Mile Island
Issue date:	09/18/1986
From:	Bell J, Dan Collins, Cowgill C, Moslak T, Myers L Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214T482	List: IR 05000320/1986009 ML20214T479 ML20214T487
References
50-320-86-09, 50-320-86-9, NUDOCS 8609300313
Download: ML20214T495 (14)

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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/86-09 Docket No. 50-320 License No. DPR-73 Priori _ty --

Category C Licensee: GPU Nuclear Corporation P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2

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Inspection At: Middletown, Pennsylvania

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Inspection o ducted: JyJy 19f1384 - August 29, 1986 Inspectors: 9 / /T /F(,

T. M5slak,' R'esideY liispector (TMI-2) dat'si4ned

' % ll$b J Be , S 'n ' o r diat: on Specia D t te fign d

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date s'igned D. Collins,fadiationSpecialist O{wG%wa)

\ ~. W r ,Ifa i tion /SpeciaTist WMJsl tidte figned Approved By: 9ff286 C. Cowgill', Chief, TMI-2 Project Section date signed Inspection Summary:

Areas Inspected: Routine safety inspection by site inspectors of plant operations (long term shutdown) including licensee action on previous inspection findings, core stratification sampling, core drilling, bulk defueling, selected maintenance and surveillance activities, control of contaminated articles, radioactive waste packaging and shipping, and reactor building activitie Results: One violation was identified in that a contaminated tripod was improperly disposed of (paragraph 8.0).

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8609300313 860922 gDR ADOCK 05000320 PDR

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DETAILS 1.0 Ongoing Recovery Operations

- Routine Plant Operations

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Inspections of the facility were conducted to assess compliance with the requirements of the Technical Specifications and Recovery Operations Plan l in the following areas: . licensee review of selected plant parameters for abnormal trends; plant status from a maintenance / modification viewpoint, including plant cleanliness, control of switching and tagging, and fire

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protection; licensee control of routine and special evolutions, including i ' control room personnel awareness of these evolutions; control of

. documents, including log keeping practices; radiological controls, and

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security plan implementatio Random inspections of the control room during regular and backshift hours

! were routinely conducted. The Shift Foreman's Log and selected portions .

of the Control. Room Operator's Log were reviewed for the period July 19 t through August 29, 1986. Other logs reviewed during the inspection period included 'the Submerged Demineralizer System (SDS) Operations Log, Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log l

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} Operability of components in systems required to be available for response to emergencies was reviewed to verify that they could perform their intended functions. The inspectors attended selected licensee planning meetings. Shift staffing for licensed operators, non-licensed

' personnel, and fire brigade members was determined to be adequate.

No violations were identifie .

j 2.0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (320/79-20-11): Procedures controlling drawing distribution have not been reviewed or approved by PORC.

i New procedures controlling drawing distribution (4000-ADM-1218.04, TMI-2 Document Control and Distribution) have been implemented. These procedures have been reviewed and approved by the Safety Review Group.

The inspector had no further. questions regarding this item.

, (Closed) Unresolved Item (320/79-20-13): Licensee to provide documentation certification qualifications of QA Receipt Inspecto The subject individual terminated employment at the TMI site in December i

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f f (Closed) Inspector Follow Item (320/83-06-10): Review Rems-on-Line for

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security and proceduralization.

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The adequacy of system access security practices was determined in report 50-320/84-25. However, it was noted that the process whereby access was controlled had not been stabilized by a formal, written procedure. This process is now covered by the procedure, " REM System Access Control" (9200-ADM-4000.09), effective August-29, 1986, which provides for control of access to the system, and " password" security, including periodic updating of access lists by department manager . The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/83-16-02): Define Procedure Changes and Revision The licensee's transportation program, including segments within the scope of this item, has been reviewed on three occasions since this item was opened. In addition, licensee waste shipments are reviewed on a continuing basis by site-based inspector Based on these reviews, the inspector had no further concerns in the area of the licensee's program covered by this ite (Closed) Inspector Follow Item (320/83-16-03): NRC to perform an

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independent test of curie estimat The inspector reviewed documents generated by Radiological Engineering and Radiochemistry in support of sample identification and quantification. The inspector reviewed the primary computer program generating rajwaste conversion factors. The licensee's use of IS0SHLD-II is an accepted industry practic The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/83-20-01): Review of Licensee Evaluation of Change in Reporting HP-R-219A Value The licensee evaluated the feasibi'lity of installing a monitoring system capable of measuring krypton-85 in effluents at much lower levels than attainable with existing plant vent monitors. This would allow the reporting of absolute values for krypton-85 releases in place of the

"less than the lower limit of detectability" entries in licensee effluent report The licensee determined that such a system could not be justified based on a consideration of need and cost. Present vent monitors are consistent with regulatory requirements and krypton-85 releases are small fractions of regulatory limit The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/84-15-02): NRC to Review Durability of Reactor Building Coatings After Scabblin The condition of coatings applied over scabbled areas of the reactor building has been examined by the inspector during several reactor .

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building entries since the opening of this item in 1984. Although there has been, and continues to be, minor chipping and scuffing of the i

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protective coatings applied to floor areas; overall, the coatings have effectively maintained their integrity. The licensee is aware of the potential for recontamination of the underlying . concrete and has .taken 1 appropriate action to protect the coatings in cases where they could be exposed to unusually severe attack as a result of work in the reactor 4, building. The licensee is also taking the precautions necessary to minimize recontamination of intact surface coating The inspector had no further questions regarding this ite (0 pen) Inspector Follow Item (320/84-21-02): Control of the Procedure

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Issue and Cancellation / Replacement Process In October 1984 there were two procedures in effect concerning radiological support technician training, one under the old format and

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another under the new standard format. The current procedure for Procedure Revision,-Review and Approval, 9200-ADM-1218.02, does not provide instruction or designate responsibility to assure that . superseded procedure.is cancelled. The licensee is preparing a Procedure Change Request to provide a cancellation instruction in the procedure.

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The inspector will review the revised procedure in a future inspection.

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(Closed) Inspector Follow Item (320/84-21-03): Resolve Administrative, Logistical, and Computer Software Issues Regarding New Extremity Dose

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Assessment Method.

The inspector determined that the administrative,: logistical and computer software issues involved in implementing the licensee's new extremity dose assessment system have been resolved. It was further determined

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that the licensee expects to meet its commitment to implement the new system, including retroactive data modification, by October 1, 1986.

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! The inspector had no further questions-regarding this ite ,

i j (Closed) Violation (320/85-03-01): Failure to perform survey required

for entry into a locked high radiation area. Violation (320/85-03-02)

Failure to follow instructions on Radiation Work Permit. Violation

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(320/85-03-03): Exceeded administrative, but not regulatory, quarterly dose to skin of the whole bodyd. Inspector Follow Item (320/85-03-04):

Review of licer.see actions taken after incident in Seal Injection Valve

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The inspector determined through document reviews and interviews with

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training personnel and technicians, that actions had been completed. The action items were stated in a licensee letter to NRC Region I dated April i 4, 1985. The inspector also reviewed the work package and job 4 performance associated with the current decontamination of the Seal

~ Injection Valve Room. The licensee's performance has been modified by the lessons learned for the January 1985 inciden ~% 'i[spector had no further questions regarding these items.

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(Closed) Unresolved (320/85-08-01): Licensee to produce letter from the vendor'regarding manufacture of the 14/190 shipping cask to the requirements of the NRC issued Certificate of Complianc The inspector reviewed a certificate of manufacturing conformance now included as part of the licensee's copy of NRC Certificate of Compliance 9159/A for the NUPAC 14/190M cas The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-08-02): Resolution of ventilation monitoring system in leakag The inspector has reviewed the status of the ventilation monitoring system and determined that the sample lines have been leak tested. Where needed, the connectors were tightened. The systems now are acceptably leak resistant. The licensee also reinforced training to individuals on the correct method of changing filter paper rolls and closing the sample cabinet The inspector had no further questions regarding this ite (Closed) Violation (320/85-08-03): Failure to adhere to instructions regarding ventilation syste As noted in the licensee's June 5, 1985 response letter to NRC Region I, the corrective actions included discussions with all lead foremen and others who may have a need to access the ventilation syste The inspector reviewed attendance sign-off sheets and determined through discussions that the plant staff has retained an adequate understanding of the need to secure ventilation cabinet doors and penetration The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-08-04): Follow critique correction The inspector reviewed the actions taken to correct the errors made in the Seal Return Cooler Room. Licensee personnel were instructed in methods to reduce generating airborne activity from handling contaminated materials. Additional instructions were given about balanced airflow for the cubicle. Also stressed were the importance of sealing room penetrations ~, keeping filter media from drying out and prompt removal of mpilled/ dropped filter material The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-10-02): Wires Impeding Access on the 349' elevation to the ladder on the 349' elevatio Based on discussions with licensee staff members, licensee memo 4370-85-0291, and the inspector's observation of the "A" D-Ring during recctor building entry 1013 on August 22, 1986, it was determined that

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access to the 349' elevation of the D-Ring was not impeded by wires or any other obstructio The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-10-04): ' Safety Concern Associated with Mirror Insulation Sheets on 349' elevation of "A" D-Rin Based on discussions with licensee staff members, licensee memo 4370-85-0291, and the inspector's observation of the "A" D-Ring during reactor building entry 1013 on August 22, 1986, it was determined that the 349' elevation of the D-Ring was free of extraneous materials that might hinder access and that the mirror insulation had been removed and shipped off site as wast The inspector had no further questions regarding this ite (Closed) Inspector Follow Items (320/85-10-05 and 320/85-16-03):

Suitability of Workers' Condition for Performing Assigned Work and Alertness of Anteroom Personne Anteroom workers have exhibited an appropriate degree of alertness on numerous occasions when observed by the inspector during plant walk-through inspections. These items are closed; however, the. inspector will routinely observe the condition of plant personne (Closed) Inspector Follow Item (320/85-16-05): Review investigation and corrective actions of respirator inspection The inspector has reviewed the licensee's corrective action Licensee respiratory maintenance personnel are now responsible for upkeep and inventory at remote issue points. The method now in use requires that no respirator be left at a remote issue point with an inspection due date of less than one week from the date of inventory. The inventory sheets are dated and signe The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-19-01): Changes Related to Fire on Defueling Platfor The inspector reviewed actions (Rer: y the licensee in response to this event. The licensee's actions ir ove procedures, communications, training and equipment relatJ Lo . m prevention and mitigation on the work platform were determined to be appropriat The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/85-20-01): Licensee to issue permanent changes to procedures for strontium-90 analysi The inspector verified the licensee had issued permanent changes to the analysis procedures which incorporated the precautions to be taken and

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the results of the independent laboratory review conducted in November 198 The inspector had no further questions regarding this ite !

3.0 Defueling Operations During the reporting period, the core stratification sampling (core bore)

program was completed. The program which began on June 21, 1986 was completed on July 28, 1986 following the acquisition of ten (10) core samples in the N-5, N-12, G-8, G-12, K-9, D-8, K-6, D-4,~0-7 and 0-9~

locations. The stratified samples were placed in fuel canisters and shipped to Idaho National Engineering Laboratory for detailed analysi Subsequent to core boring operations, a series of holes were drilled, using solid faced bits, in the hard crust layer of the damaged cor These perforations were made so that other defueling tools coulv be more effectively used in breaking up and removing the debris during the bulk defueling phase. Attempts at penetrating the crust were made at forty-eight(48) locations. Of these, twenty-eight (28) resulted in holes ranging in depths from 12 inches to 48 inches. The remainder were less than 12 inches in depth. Following this activity, the drilling equipment was disassembled, removed from the work platform, and staged in the reactor building. On August 12, 1986, bulk defueling operations commenced using a variety of hydraulically operated tools. These operations are being conducted 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> a day, 6 days a wee To date, progress has been slow, resulting in three filled canister Poor visibility due to recurring growths of microorganisms has hampered defueling efforts. Measures to improve in-vessel visibility, including filtration and chemical treatment have been marginally effective. The licensee is continuing to evaluate various techniques to increase the visibilit Two industrial type injuries occurred to members of defueling crews during this period. On August 19, 1986, a worker lacerated a finger, when a long bandled tool was dislodged from a temporary storage location pinning the worker's hand between the tool and the tool rack. On August 24, 1986, a second worker fractured his ankle when descending the temporary stairwell in the reactor building. No root causes were identified by the inspector for these accidents; however, the inspector will continue to evaluate industrial safety practices to identify adverse trend (320/86-09-01)

4.0 Defueling Support Activities During the removal and storage of the core boring equipment in the reactor building, the inspector observed activities in the Coordination Center, attended mock-up training and prejob briefings, and reviewed RWPs and ALARA reviews associated with the activities. It was noted that workers and task supervisors were reading the RWPs and asking questions regarding special instructions. The mock-up training used actual equipment that was to be handled, including seal cover dust cover The mock-up training resulted in revisions to the work activity to reduce the time required to handle the covers. The prejob briefing included

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discussions of the RWP requirements. All task supervisors directing the work activities in the Coordination Center signed the prejob briefing for The inspector noted that the ALARA review includes specific instructions that if-the work activities in the reactor building do'not require a Radiological Control Technician in constant observation, a Senior Radiological Control Technician shall be at all times at the Coordination Cente The inspector had no further question .0 Surveillance Activities Station Batteries On August 13, 1986, the inspector witnessed the testing of the station storage batteries and chargers. Weekly testing is required per Technical Specification (TS) 4.8.2.3.2a. The inspector reviewed the surveillance procedure (4223-SUR-3734.02) and determined that the testing frequency and acceptance criteria conformed to TS requirements. The inspector also determined that the procedure was properly reviewed / approved, that limiting conditions for operations (LCO) were met, and that the prerequisites were completed. The inspector verified that the test instrumentation was calibrated, and that testing was performed by qualified personne The inspector observed the testing of twelve pilot cells in each of-the redundant (red / green) 250/125 volt battery banks and determined that the following operability criteria were met:

-- The electrolyte level of each pilot cell was between the minimum and maximum level

-- Each pilot cell's specific gravity was 2 1.20 when corrected to 77 The pilot cell voltage was 2 2.13 volts

-- The overall battery voltage is 2125 volts / bank and 2 250 vol ts/ba tter The inspector audited copies of past battery surveillance procedures performed weekly and those performed quarterly (4223-SUR-3734.01) and determined that the tests were performed as required. The inspector verified that exceptions and deficiencies identified during these tests were rectifie No violations were identifie Reactor Bui_lding Air P_r_es_s_ure On August 8 and 9, 1986, the inspector observed portions of the reactor building air pressure channel calibration. The surveillance test is

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required to be performed every 18 months in accordance with Section 4.3.3.5 of the Recovery Operations Pla The inspector reviewed the calibration procedure 4221-SUR-3214.01, and verified that the LCOs were met, that tagouts were obtained prior to test initiation, and that test instrumentation was calibrated. During portions of the test, the inspector observed that the radiological controls specified by a radiation work permit were implemented by the Instrumentation and Control (I&C) techniciar.s. The- inspector observed that certain "as found" data points were slightly outside the acceptance band stated in the procedure. Through discussions with licensee personnel, the inspector determined that technicians were knowledgeable of the mechanism of how this data'would be evaluated by appropriate management levels to determine what action would be taken if require The inspector observed the technicians adjusting the instruments to the proper setpoints, recording "as left" data, and determined that the calibration record accurately reflected what took plac No violations were identifie .0 Maintenance Activities On August 8, 1986, the inspector witnessed the leak rate testing of the reactor building equipment hatch airlock following the change out of "0" ring seals on the airlock door. The change out of the "0" ring seals was a safety-related corrective maintenance resulting from the deterioration of the seals caused by hauling equipment through the airloc During the test, the inspector verified that a redundant component was operable, no LCOs were violated, radiological controls were appropriate for the task, test instrumentation was calibrated and the required administrative approvals were received prior to initiating the tes Th'e inspector independently verified leak rate measurements and determined that the auxiliary operator conducted the test in accordance with an NRC-approved procedure (4210-SUR-3244.03). The inspector observed the failure of the initial test on the outer door, followed by a wipe down of the seal and reapplication of a sealant compoun Results of the retest met the acceptance criteria stated in the procedur No violations were identifie .0 Health Physics and Environmenta_1_ R_evie_w Plant Tours The NRC site Radiation Specialists performed plant inspection tours which included all radiological control points and selected radiologically controlled areas. Among the areas inspected were:

the Auxiliary and Fuel Handling Buildings; EPICOR-II; Radiochemistry Laboratories; radioactive waste storage facilities; Respirator Cleaning and Laundry Facility; and, the Radiological Controls Instrument Facilit ._- ._ - - _ _ _ _ _ . _ _ _ _ _

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Among the items inspected were:

-- Access control to radiologically controlled areas

-- Adherence to Radiation Work Permit (RWP) requirements

-- Proper use and storage of routinely used respirators and associated equipment

-- Maintenance and storage of emergency respiratory ~ equipment

-- Adherence to radiation protection procedures

-- Use of survey meters and other radiological instrument The inspectors reviewed the application of radiological controls during normal hours, on backshifts, and on weekends. Log books maintained by Radiological Controls Field Operations and Radiological Engineering to record activities in the Reactor Building and the balance of the plant were reviewed. All the log books contained appropriate entrie No violations were identified, b. Radiological Sh_ipmen_ts

.1 The first shipment of TMI-2 core debris arrived at the Idaho National Engineering Laboratory in Idaho on July 24, 1986. The U. S. Department of Energy (D0E) was the shipper having assumed responsibility at the TMI site boundar The inspector observed the processes of loading, sealing and radiological surveys involved with the cask. The cask is NRC-licensed under Certificate of Compliance 9200, Revision The inspector reviewed the conduct of operations which used the following:

4200-ADM-3255.01 Canister Vessel Traveler Data 4231-ADM-4450.04 Shipment and Transfer of the TMI-2 Fuel Canisters to the DOE 4215-0PS-4450.15 NUPAC 125-B Rail Cask Disassembly 4215-0PS-4450.16 NUPAC 125-B Rail Cask Loading 4215-0PS-4450.17 NUPAC 125-B Rail Cask Assembly 4215-0PS-4450.18 NUPAC 125-B Rail Cask Maintenance Verification Leak Test The inspector observed the licensee make preparations for the second and third casks to be shipped on one train. During the preparations, minor operating problems were experienced with the equipment, but no unsafe conditions were identifie The inspector observed the final closure and maintenance verification leak test which is required by the Certificate of

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Compliance Section 1 On each cask, leak test results complied with the acceptance criteri No violation was identifie ,

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.2 Deformed Waste Containers On July 29, 1986, site inspectors met with members of the licensee's Waste Management Department regarding the disposition of two liners containing radioactive resin beads and contaminated sand that had been solidified in concret Licensee personnel detennined that the liners (Nos.19 and 23)

had become deformed, resulting in bulging sides. The cause of the deformation has not been determine The licensee informed the inspectors that a program is being established to assess the transportability and structural stability of the liner Site inspectors will inspect the liners and supporting evaluation to determine if the shipment complies with the applicable regulations and standards for transport and disposal in a future NRC inspection. (320/86-09-02) Measurement Verificati_on_s Radiological measurements were made by the inspector to verify the quality of licensee performance in radioactive material shippin No violations were identified, Reactor Buil_ ding Wo_rk Reactor Buil_d_ing Entr_ie_s A radiation specialist entered the reactor building (RB) during entry No.1013 on August 22, 1986, to assess radiological and industrial safety conditions. The inspector traversed or observed approximately fifty percent of both the 305' and 347' levels of the reactor building and the tops of the D-Rings. Observation of the interiors of the D-Rings was accomplished from the D-Ring upper surfaces. Lighting was such that there was a fairly clear view of the D-Ring interiors down to the 349' level. Work activities and conditions on the defueling work platform were also observe The inspector confirmed that (1) appropriate corrective actions had been taken by the licensee with respect to certain concerns for worker safety in the D-Rings, (2) the protective coatings applieu to scabbled (decontaminated) areas on the 305' and 347' levels are proving to be adequately durable, and (3) the coatings are being appropriately protected from damage by work activities in these areas so as to prevent recontamination of the underlying concret All areas observed were, with minor exceptions, found to be in satisfactory condition. In those cases where minor safety problems were observed, prompt action was taken by the licensee to correct these condition _ _ _ __

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The pre-entry briefing was thorough and specific to the route to be traversed within the R No violations were observe Overall, the inspector monitored work in the RB during the inspection period. The following were examined on a sampling basis:

-- The RB entry had properly planned and coordinated so as to-ensure that ALARA review, personnel training, and equipment testing were conducte Radiological precautions were planned and implemented including: use of an RWP, locked high radiation access authorization, specific work instructions, use of alarming self-reading dosimeters, and use of breathing zone air sampler Individuals making entries into the RB had Leen properly informed, trained, and understood emergency procedure Specific procedures were developed and used for performance of unique task Entries 979 through 1020 were conducted during the reporting perio Reactor building entries have been conducted around the clock for the most part. Defueling activities ( transfer to the fuel' handling building)have g. pick beenand place, canister routinely performed by 4 - 5 person teams working four-hour shift l No violations were identifie Records Review The inspector reviewed selected radiological records during the period to assure the accuracy and completeness of the licensee's documentation of occupational exposure. The records reviewed included Radiation Work Permits (RWPs), Dosimetry Investigative Reports, TMI-2 Event Reports, Radiological Awareness Reports, and Dosimetry Exception Report Additionally, the inspector reviewed various licensee records and periodic reports concerning the radiological controls program, including current data and trends .in such areas as manrem per RWP hour, decontamination status, skin contaminations, environmental monitoring, radiological events, whole body counting, training, l

. dosimetry, shipments, progress toward achievement of goals and objectives, storage tank radioactivity content, airborne radioactivity, and manrem by work category; effluent releases, including sump releases and sources of sump contamination; and the cumulative dose (manrem) to all plant personne No violations were identifie . _ _ _ _ . . _ _ _ _

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8.0 Control of' Contaminated _ Materials

.1 Contaminated Tool in _Uncontro_1_le_d_ _0_n_ site Ar_ea The inspector reviewed Licensee Event Report 86-06, dated August 12, 1986,-concerning a contaminated camera ~ tripod which was discovered in an unrestricted area on July 15, 1986. This item was originally opened in Inspection Report 50-320/86-08. The tripod was found in a scrap bin near the sandblasting / paint sho The release limit set for unrestricted use by the Radiation Protection Plan and implemented by Radiological Controls' Procedure (RCP) 9200-ADM-4200.02, Release Surveys, is 1000 disintegrations'per 100 square centimeters (1000 dpm/100 cm2) for removable beta-gamma radioactive contamination. Licensee surveys determined removable contamination on the tripod to have been up to 20,000 dpm/100 cm2 The scrap bin was found to have contamination on its surfaces which .

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was subsequently removed. No other items in the scrap bin, on the surrounding grounds or in nearby buildings were found to be contaminate .2 Licensee. Investigatio_n_s Radiological Controls initiated TMI-2 Event Report 86-56 on July 17, 1986. The tripod was thought to have been part of a-1983 purchase, but this could not be verified. The licensee has stated that a search of purchasing and equipment storage records has not identified the origin of the tripod nor its pathway to the scrap bi The inspector noted that a smear sample (No. 86-10195; taken on the tripod indicated that cesium-134 and -137 were present, and that strontium-90 had not been detected in the sampl The licensee's investigation and review were completed on August 12, 1986 and reported in LER 86-06. The licensee characterizes the root cause as personnel error. No evidence was found to indicate an intentional bypass of the controlling Radiological Controls procedure .3 Inspector Review The inspector's review of t_e h data and the licensee's investigation did not determine the mechanism of placement into the scrap bin ~and as a result, no actions could be specifically identified to preclude recurrence. Th'e inspector's review of the LER,Section VIII,

" Assessment of the Safety Consequences and Implications of the Event" indicates two sequential surveys of each scrap bin is made prior to removal. The licensee states this was not to be implied and that normally one survey is made before a scrap bin is released, but that one survey may not be made immediately prior to release from the sit The licensee indicated that a clarification of Section VIII would be issue ._, _, _ _ _ _ _ , . _ _

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.4 Inspector Findings The. inspector determined that the tripod had been released-for unrestricted use. The tripod had removable contamination from 8,000 --12,000 dpm/100 cm2 These levels exceed the contamination limit of 1000 dpm/100 cm2 specified by Radiological Controls Procedure 9200-ADM-4000.02, Revision 1, paragraph 4.1.2.1, Surface Contamination Limits which references the GPUNC Radiation Protection-Plan 1000-PLN-4010.01, Revision 1. The release of the tripod is a violation of the control requirements in these document (320/86-09-03)

9.0 Inspector Foll_ow It_ ems

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Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operation (hardware or progrannatic) that could lead to violations if left uncorrected. Inspector follow. items are addressed in paragraphs 2.0, 3.0, 7.0, and >

10.0 Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether they are violations, deviations, or acceptable. An unresolved item is addressed in paragraph .0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On September 4, 1986, the site inspectors sunmarized the inspection findings to the following personnel:

J. Byrne, Manager, TMI-2 Licensing W. Craft, Manager, Radiological Controls Field Operations C. Dell, Licensing Technical Analyst A. Miller,-Manager, Plant Operations J. Renshaw, Manager, Waste Management i R. Rogan, Director, Licensing and Nuclear Safety At no time during the inspection was. written material provided to the licensee by the TMICPD staff except for procedure reviews pursuant to Technical Specification 6. .

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