IR 05000320/1986010

Safety Insp Rept 50-320/86-10 on 860830-1015.No Violations Noted.Major Areas Inspected:Routine Plant Operations, Licensee Action on Previous Insp Findings,Ie Circular Followup & LER Followup

ML20207B160
Person / Time
Site:	Three Mile Island
Issue date:	11/03/1986
From:	Bell J, Dan Collins, Cowgill C, Moslak T, Myers L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207B152	List: IR 05000320/1986010 ML20207B149
References
50-320-86-10, IEC-78-06, IEC-78-19, IEC-78-6, IEC-79-18, IEC-79-24, IEC-79-25, IEC-80-15, IEC-81-02, IEC-81-2, NUDOCS 8611110519
Download: ML20207B160 (15)

Text

. -

U. 5. NUCLEAR REGULATORY COMMISSION Report No. 50-320/86-10 Docket No. 50-320 License No. DPR-73 Priority -- Category C Licensee: GPU Nuclear Corporation P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania Inspection ducted: August _30 /1986 - October 15, 1986 Inspectors: -

\1/ s /RL T~ MUsTak,NResident Inspector (TMI-2)

. date Vlgned

, b'

J. B ll, Senior Radiation Specialist

/Oh.9/86 date s'igned O1 ins, Radiation 0h s

Spe~cialist

/4h9h(e>

ddte s'igned q u rs W i n w s- /o/zR/sb VMb , di i pecialist date signed Approved By: c 1 . it \ \ /3 VA C. Cowgfll, Chief, TML-7 Pr'o ject Section date s/gned Inspection Summary:

Areas Inspected: -Routine safety inspection by site inspectors of plant operations (long term shutdown), including routine plant operations, licensee action on previous inspection findings, IE circular followup, licensee event report followup, defueling operations, licensed operator requalification, and health-physics and environmental revie Results: No violations were identifie {DR ADOCK 05000320 PDR

- . . - - - ..- .. -. = .. .. . - . _ . . -. .

, E. ,

J

-

DETAILS

- Licensee Action on Previous Inspection Findings (Closed) Unresolved (320/78-30-01): . Correct NaOH tank level values on

. annunciator window and in alarm response procedure. Conduct generic

'

review of alarm value Present plant conditions-do not require the NaOH . tank for safety related

'

functions. Those procedures addressing alarm setpoints and responses are subject to review / approval by the NRC site staff prior to implementation, per the requirements of Technical Specification 6. ;

The inspector had no further' questions regarding .this item.

4=

(Closed)1 Unresolved (320/78-36-01): ' Review licensee corrective actions.

to assure proper: operating procedure implementation, review selected-operating procedure ~

.

'

No violations were identified. . Technical . Specification.6.8.2 require that operating procedures be submitted to' the NRC TMI-2 Cleanup. Project .

'

! Directorate for review / approval prior to implementatio ,

I The-inspector had no further questions.regarding this ite (Closed) Unresolved (320/78-36-02): Review controlled copies of.

,

operating procedures to assure that there are no improper annotation i The' inspector reviewed copies of operating procedures located in the controlled file.and determined that no improper annotations were made to the. procedure The . inspector had no further questions regarding this ite '

'(Closed) Infraction (320/79-20-06): Drawingdistributionandelimination; of obsolet'.e drawings was not being controlle A modified drawing control / update program has been implemented to. ensure that the.most current ~ drawings are readily available to support

engineering modifications and the operation of recovery system The inspector had no further questions regarding this item.

!- (Closed) Unresolved (320/79 20-07 and 320/83-08-02): Procedures were overdue for biennial review.

~

No violations were identified. Evaluation of the effectiveness and

,

completeness of the licensee's biennial review will be performed in a future NRC. inspectio (320/86-10-01)

1; .

.

(Closed). Unresolved (320/80-11-08): Review licensee system for consolidated view of plant status, i

!

'

_ . _ _ u-._____- _

_. _ -._,- __,..,_ _ _ ..

C *

From a review of surveillance procedures, operating procedures, switching and tagging records, control' room logs, locked valve logs, and status boards, the inspector detennined that a program is in place to provide a consolidated view of the status of plant equipmen The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/84-04-01): Issuance of a formal, separate and explicit corporate level statement of policy for ALARA implementatio Part 2.0, ALARA program, of the Corporate Radiation Protection Plan, 1000-ADM-4010.01, issued May 1, 1986, describes the implementation of the corporate ALARA program. This part describes the implementation of the ALARA program; includes a testament of corporate level desire to implement the ALARA concept by means of the program, the assignment of general responsibilities for ALARA program implementation and attainment

of program goals; and a brief description of the management system for program implementatio The inspector had no further questions regardir.g this ite (Closed) Inspector Follow Item (320/84-04-02): Definition and documentation of an ALARA implementation management syste (Closed) Inspector Follow Item (320/84-04-06): A documented, proceduralized process for the review and/or approval of ALARA implementation procedures issued at the planning and direction leve .

(Closed) Inspector Follow Item (320/84-04-07): Development of procedures, including criteria, for the use of currently performed cost / benefit analyse THI-2 Unit Plan / Policy procedure,-4000-PLN-4010.01, TMI-2 ALARA Program Plan, implements the corporate ALARA program, defines responsibilities, the methods of implementation, and establishes a coordinating group (the Dose Reduction Working Group) to evaluate, monitor, and recommend a systematic approach to implementing the ALARA concept in planning activities. Administrative procedure, 4000-ADM-4010.01, Ti1I-2 ALARA Program, implements the ALARA program plan; assigns responsibilities; requires the establishment of objectives and goals, including criteria; requires an ALARA coordinator in each department; establishes training and qualification criteria for ALARA implementation; and describes the documentation process, including cost / benefit analyses. Radiological Controls is required to provide advisory support to the departments and to perform an annual audit of the departmental ALARA program The inspector had no further questions regarding this ite (Closed) Inspector Follow Item (320/84-04-08): Establish requirement for corporate' assessments of ALARA implementation effectiveness, and proceduralized methods for determining ALARA implementation goals and objectives and implementation effectiveness.

,

- . - - . . - . - - . -- - . -- . - -.

.

.

..

,

Radiological Engineering performs an annual audit of the ALARA 1 implementation arogram effectiveness evaluations in accordance with the established met 1ods, criteria, and procedure .

-The inspector had no further questions regarding this item.

_(Closed) Inspector Follow LItem (320/84-04-09): Audit results should i become:a part of'the basis for overall ALARA implementation evaluations performed at the corporate leve The_ licensee requires that each department assigned ALARA implementation responsibilities perform an annual audit of the departmental . program ,

i effectiveness, and. reevaluate goals and objective An independent ,

annual audit of the ALARA program is performed by Radiological Engineering, including all departmental procedures,-goals and objectives, criteria, documentation, and methods. The Quality Assurance Department

' has;provided timely, independent, corporate. level audits of the AL ARA program._ - Audit results have provided _information which has been  ;

-incorporated into the evaluations of the effectiveness of the program by

'

the Quality Assurance ~ Department.

. - The inspector had no further questions regarding this item.

'

- (Closed)' Violation (320/84-04-10): Failure to perform post-job reviews according to procedur ~

Post-job' reviews are performed according to procedure, 9200-ADM-4010.0 '

ALARA Review Procedure, which specifies that reviews are necessary_when worker dose for a specific task exceeds 10 manrem or the cumulative dose exceeds the projected dose by greater than 25 percent and is greater than 1 manre The inspector had no further q'uestions regarding this item.

j (Closed) Inspector Follow Item (320/84-21-04): Implement new extremity dose assessment method.

~

. ,

, -The inspector determined that the new extremity dose assessment method has been implemented, including retroactive data modification. The new-

~

- method and software support now provide for tracking of each of the four extremity doses with reporting-of the maximum extremity dose and the combining of "whole body" dose with extremity dose when appropriate.

.

- The inspector had no further questions regarding this ite (Closed)InspectorFollowItem(320/85-12-02): Evaluation of possible unmonitored' airborne radioactive material release pathways.

Licensee progress.in evaluating unmonitored airborne release pathways j will continue to be followed by~ site irspectors and reported with respect

.to open item 320/85-21-04.

l (Closed) Violation (320/86-07-01): Failure to obtain a survey to evaluate the hazard associated with handling radioactive raaterial, ,

, -

e -w -, <,m- -=,,.L, ,te -----n--- - - - -W--* - - - - - -

. . _ .. _ _ _ . _ . , - . _ _ _ . - _ . . - _ _ _ . . .

'; -

.

$1 As noted by the inspector:in report 50-320/86'-07, the immediate corrective actions taken by the licensee and documented in the licensee's

.

August.13, 1986 letter to NRC Region I were appropriate. The inspector

-

has determined that the actions taken should help to prevent recurrence

- of events of_this_ natur ' The' inspector had no further questions regarding this _ ite (Closed) Inspector Follow Item.(320/86-07-02)

Follow actions to train and inform defueling workers and Radiological Controls technicians about small pieces of fuel. debris.

! The inspector reviewed lesson plans,-attendance sheets and interviewed defueling. workers and Radiological' Controls technicians. Each individua ',

contacted exhibited an enhanced sense of the dangers and methodology needed to handle small pieces of core debri The inspector had no further questions regarding this ite (Closed)' Violation (320/86-07-03): Failure to implement requirements of a Radiation Work Permit (RWP) when removing tools from the reactor vesse .

I Failure of Task Supervisors and workers to read, understand and implement provisions of the applicable RWP resulted-in the removal of tools from the reactor vessel without being scrubbed, brushed and radiologically

, surveyed prior. to being stored. The licensee by letter to NRC_ Region I'

}. dated August 13, 1986, described corrective actions to prevent a

recurrence'of the event. The inspector reviewed and determined these corrective actions to be acceptable.

{

The inspector had no further questions regarding this' ite (Closed) Inspector'FollowItem(320/86-07-04): Review of the corrective p ' actions in the tool removal event.

. . -

The task supervisors at'the Coordination Center responsible for directing

'

worker activities supporting defueling in containment were counseled to

read, understand and implement RWP requirements; ensure that specific RWP L . requirements are discussed at pre-job briefings of workers, that the i workers understand and. comply with the requirements, and that relief task supervisors are appropriately briefed, that is, receive all appropriate

i task-related.information at task turnover, including RWP requirements.

The licensee has formalized training in these areas for task supervisors and assigned an engineer responsibility for training and record

maintenance. Also, this event has been-included in the licensee's

- General Employee and Radiation Worker training programs. The inspector

'

,

,

observed that legible RWPs are being posted where it is convenient for workers to review their requirements before and after pre-job briefings j_ and that all task supervisors, including relief task supervisors, are signing the pre-job briefing form.

L The inspector had no further questions regarding this item.

!

? -

i

'

,

- = . . , . . . -.--- - . . - . - . . - - - - - -

.

.

2.0 IE Circular Followup For the IE circulars listed below, tiie inspector verified that the circulars were received by licensee management and that a review ter i applicability was performed. The inspector found that these circulars were determined not to be applicable to the plant's present configuration or for the performance of recovery operations:

79-CI-24 Proper Installation and Calibration of Core Spray Pipe Break Detection Equipment 79-CI-18 Proper Installation of Target Rock Safety Relief Valves 80-CI-15 Loss of Reactor Coolant Pump Cooling and Natural Circulation Cooldown 78-CI-06 Potential Comon Mode Flooding of ECCS Equipment Rooms at' BWR Facilities 78-CI-19 Manual Override (Bypass) of Safety Systems Actuation Signals The inspector also determined that the licensee's evaluation for the following circular was addressed in the licensee's response to IE Bulletin 81-01:

79-CI-25 Shock Arrestor Strut Assembly Interference For the following IE circular, the inspector determined that the coverage

-

of the performance of licensed individuals by site NRC inspectors is ongoing and addressed in routine inspection reports:

81-CI-02 Performance of NRC Licensed Individuals While on Duty 3.0 Licensee Event Report (LER) Followup The following LERs were reviewed. The inspector verified that reporting requirements had been met, causes had been identified, corrective actions appeared appropriate, generic applicability had been considered, and the LER forms were complet /86-09 Failure to establish hourly fire watch when deluge system was taken out of service 320/86-08 Failure to perform a monthly surveillance ~ for verifying the valve lineup for the Fire Suppression Water Systeu 320/86-07 Failure to obtain and analyze an airborne grab sample when -

ALC-RMI-18 became inoperable'

320/86-05 Rotation of the Canister Positioning System without direct licensed supervision 320/86-04 Exceeding the Safety Evaluation Report limit for the number of transfers of spent filter media to a storage drum

. . . - .. . . _ - .- - . . .- - . . .- -

,-. .

4.0 Routine Plant Operations Inspections _of the facility were conducted to assess compliance with the requirements of the Technical Specifications and Recovery Operations Plan 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

-

protection; licensee control of routine and special evolutions, including

,

control. room personnel awareness of these evolutions; control .of documents, including. log. keeping practices; radiological. controls; and security plan implementation.

i- Inspections of the control room were performed during regular and backshift hours. The Shift Foreman's Log and selected portions of the

~

. Control Room Operator's Log were reviewed for the period August 30-through October 15, 1986.. Other logs reviewed during the inspection period included the Submerged Demineralizer System (SDS) Operations Log, a Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log Sheet 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 Itcensee planning meetings. Shift staffing for licensed operators, non-licensed personnel, and fire brigade members was determined to be adequat i

'No violations were identifie ,

f 5.0 Defueling Operations

!~ On October 8,1986, two inspectors entered the reactor building with the.

- ? first shift to. ascertain whether defueling operations were being

..

conducted in conformance with approved Safety Evaluation Reports and l implementing procedures._ One inspector accompanied the defueling crew to I' the shielded work platform (SWP)-to observe defueling activities. The l second inspector accompanied a radiological controls technician while th ;

i' technician performed. surveys and operational checks of radiation

'

monitoring equipment in various areas within the buildin >

The inspector observed airborne particulate samples being taken from the service air system, filter changeouts of three AMS-3 airborne particulate F monitors, sample changeouts'of two airborne tritium samplers, and smear sampling of surfaces.on the 305' and 347' elevations; and confirmed l radiation exposure instrument readings on the 305' and 347' elevations.

t The pre-entry briefing was thorough and specific for the entry.

b The inspector verified that, prior to the handling of fuel, plant

-

!

conditions and operability of the support systems (e.g. communication,

! offgas, criticality monitoring, and level indication) were as required by

,

Technicai_ Specifications and NRC-approved procedures. The inspector also l

'

.

Y

-_a.- ,,,,n . .. r - ~ - - - , - - .--,,,---r- , ,- ,.---w- -----.--m-n----, ,

. . _ . _ . - . . _ . ~ .. . _ . . _ . ___ . ._ . _ _ _ _ __

+. .

.. verified that, during the defueling, operators complied with the limits and preca'utions specified in the implementing procedure The: inspector identified the following weaknesses that reduced the overall efficiency and safety of the operations:

.1' Housekeeping on:the 347' elevation was poor. There was an excessive  :

F buildup of bagged trash.. Metal filings / chips were scattered on the metal sheeting covering the floor in the fabrication area (near the

,

open hatch) making ~ walking in plastic foot covers hazardous. The

'-

pathway. leading to the stairway to th constricted by load handling equipmen,e'defueling Ingress / egressplatfonn along this was pathway was particularly difficult because of the snagging of respirator hoses, BZA lines, and protective clothing on the ,

,

equipmen .2 Housekeeping on the SWP was. marginally acceptable. An excessiv number of slings and ancillary equipment were staged near the SWP

,

making work more cumbersome in-an already cramped work area.-

! .3 The in-vessel video viewing system was marginally effective in

!- providing operators the visibility required _for their activities' .

Although water clarity had improved, fogged camera' lenses,

-electronic interferences,.and short focusing range severely _

restricted;the operator's ability to rapidly identify and acquire core components.

.

Additionally, operator manipulation of the camera controls was . _

difficult and time consuming. These controls have not been modified to facil.itate their operation while wearing multiple rubber gloves and the platform lighting is inadequate for easy reading of the control label .4 Multiple interferences exist when rotating the SWP. Hydraulic lines-

! must be moved to prevent them from being caught between the SWP and

its supporting structure. Jib Crane booms must be repositioned to prevent contacting cable trays on D-ring walls. Tools suspended from the Service Crane through the shielded work platform's "T"-slot- '

, must be repositioned to prevent them from jamming the canister

- positioning system.

i .5 Positive engagement of the camera /defueling tools on the Service-Crane hook was not always assured. The inspector observed the

'

movement of a camera using the Service Crane in which the camera was solely supported by-the hook's safety latc .6 The AMS-3 monitor located near the step-off pad to the SWP alarmed twice during the 31 hour3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> work shift without any apparent purpos These alarms distracted operators from the task at hand and contributed to a complacency regarding future alarm .7 Manual wipedowns of the defueling tool end effector appeared to be a l i needless exercise. Once an operator obtains a load of core debris,- .

the tool is raised and then moved to the funnel to deposit the ,

.

- _ _ _ _ _. _. _ _ ._ _ _ __ _ _ _ . _ _ .

. . - . -

-- . . - . - - - . . - -

. .

.

i 9

,

-debris in a defueling canister. Since the end effector remains in -

the tool slot;throughout the movement any drippage would flow back to the vessel. The wipedown. subjects-the operator to the higher dose rate over the tool slot and has resulted in contaminated water

'

.

flange. It

.appears drippingthat on the

-

operator's wipedowns plastic'

should behood limited from the tool. ions when tools to the.occas e

i are completely removed from the vessel.

1 The-inspector also noted the use of two types of. tool washdown --

!

devices: a brush with two spray ports, and a bent ~1" pipe. Both

- styles appeared to;be-ineffective in their coverage of the end

, effecto Based on these observations, the inspector concluded that although .

defueling operations are conducted --in accordance with ~the requirementsf of l Safety Evaluation Reports and implementing procedures, operational .

A problems e hampering.defueling activities. The inspector recommended

to the lic see that cognizant middle managers become more deeply.

1 involved in identifying and resolving the day-to-day problems faced by the defueling crews.-

. Progress in resolving these operational problems will be reported in a

future NRC inspectio (320/85-10-02)

T 6.0 Licensed Operator Requalification

.

One. licensed operator at TMI-2 was certified to the ARC as having

'

completed all requalification program requiremen ts ord had his license ,

renewed. Due to a TMI training' staff administrative error, one of the t- required reactivity manipulations . performed at the Penn Stato. University

"' research reactor did not conform to the requicaments of the TMI-2 i- . requalification program. The TMI training staff notified the NRC and removed the operator from licensed duties until .the requalification requirements were. fully met. This occurrence was documented in a letter from'the licensee to'NRC Region I' dated August 20, 198 ,

i

~ *

17.0 Health Physics and Environmental Review Plant Tours

- The NRC site Radiation Specialists performed plant inspection tours-

-

which included all radiological control points and-selected

,i radiologically controlled areas. .Among the areas inspected were:

i the Auxiliary and Fuel Handling Buildings; EPICOR-II; Radiochemistry Laboratories; radioactive waste storage facilities;- Respirator

-

- Cleaning and Laundry Facility; and, the Radiological-Controls

Instrument Facility.

I Among the items inspected were:

> -- Access control to. radiologically controlled areas

-- Adherence to Radiation Work Permit (RWP) requirements

.

L i- ,

.

vw m- e v -rm. ~ Aw-,,.,,e.-.e- ,y v.e --

.,,-,ow-.-,-.s-+ . , -.,,--,--ws---e---w--,r~we---ewre-s w w - v- w-- ---,-w -s w we =- e -r w m-'- w-<r-- - - -ws'

. .

-- 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 alid 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 reacto building and the balance of the plant were reviewed.. All the log books contained appropriate entrie No violations were identified, Reactor Building Work-Reactor Building Entries The inspector. monitored the licensee's conduct of reactor building (RB) work during the inspection period. The following were reviewed by sampling basis during the inspection period:

-- The RB entry was planned and coordinated so as to ensure that ALARA review, personnel training, and equipment testing had been conducte Radiological precautions were planned and implemented including: use of an RWP, locked high radiation access authorization, specific work instructions, alarming self-reading dosimeters, and breathing zone air sampler Individuals making entries into the RB had been properly .

informed,. trained, and understood cmergency procedure .

-- Unique tasks were perfomad using specifically developed procedures, and mock-up training had been conducted where warrante Entries 1021 througn 1067 were conducted during the reporting period. The licensee has removed a quantity of fuel assembly end fittings from the reactor vessel. These end fittings were placed inside shieldea, water-filled drums which were then placed on the 347' elevation next to the D-ring wal Personnel access to this area is restricted and radiation exposure levels have been reduced

- by the addition of shielding around the barrels. Criticality monitors have been installed on the D-ring railing above the barrels. Observed operations and facilities were found to be consistent with applicable Safety Evaluation Reports and implementing procedures.

.

.

. . _ . - - . ._ . . - . - . _ . .

-

.-_

'

.. .

~

Respiratory Protection The-inspector reviewed records and interviewed licensee personnel

- concerning the use of respirators on the shielded.defueling work platform (SDWP) in the reactor building. The exposure;of workers on the SDWP to airborne particulate radioactive material was closely

,

followed as defueling operations were initiated in the fall.of 198 Based on. inefficiencies, discomfort and stress associated with the l wearing of. respirators, and the .results of measurements of worker

exposures showing that airborne-particulate radioactive material -

'

concentrations were very low,- workers were allowed to perform defueling tasks on the SDWP without the' encumbrance of respirators for about nine months. The licensee continued to monitor worke exposure to airborne radioactive materials on the platform. The i result:, of licensee analyses of breathing zone airborne particulate t

samples showed upward trends in exposures to airborne radioactive materials of workers on the SDWP during the latter part of August- ,

and the beginning of September. There were significant increases in i both individual exposures and. exposures averaged over.the entire.

defueling' work crews. Although the exposures were, for the most part, far below regulatory limits,'they were .significant relative.to -

i the licensee's administrative limits which are more restrictive than NRC -limits. ~ As a result, a decision was made by.the licensee to.

i- reinstitute the use of respirators on the' SDWP. The inspector wil continue to monitor the use of respirators on the platfor , Radiological Shipments The NRC site Radiation Specialists inspected select TMI-2

..

radioactive material shipments during the inspection period to verify the following:

! -- 'The licensee had complied with approved. packaging and shipping procedure The licensee had prepared shipping papers, certifying that the materials were properly described, classified, packaged, and marked for transport.

! -- The licensee had applied warning labels to all packages and vehicles were placarded.

"

--

The licensee had controlled radioactive contamination and radiation levels below the-regulatory limits.

[

-- The intended recipient possessed an appropriate license.

-- The licensee _ was an approved user of the NRC-licensed packages

!

used, and had in its possession, and complied with, the F provisions of.the Certificate of Compliance.

,

The inspectors examined shipments from the site on August 29, i September 12, 24, 25, and October 2, 1986.

'

,

, - - -, -_- , . - --, - ,- ,_,- . .-.

. Railroad Shipments The second rail shipment, consisting of two rail-car carried casks with seven fuel canisters each, departed the TMI site during the inspection period. The Department of Energy (00E) assumed responsibility for the shipment at the site boundary. The inspector performed a radiation survey'of the casks and reviewed the shipment documents associated with the loading and sealing of the casks. The inspector observed the performance of either the internal lid leak test or the external lid leak test for each cesk and verified that the; casks met the requirements of the NUPAC 125-B Rail Cask Maintenance Verification Leak Test (4215-0PS-4450.18).-

No violations were identified, Measurement Verification Radiological measurements were made by the inspectors using NRC equipment to verify radiation levels inside radiologically controlled areas, at the boundaries of areas, at shipment packages, and around transportation vehicle ~ 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 Pemits (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, radioiogical events, whole body counting, training, 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 .0 ALARA Program Review l Scope of Review  ;

i The inspector reviewed' the licensee's program for implementing the As Low l As Reasonably Achievable (ALARA) concept. Included in the review were ;

the statement of policy, the management system, the organizational !

responsibilities, procedure implementation, and the licensee's program l evaluation process and its results; and worker's knowledge regarding the ALARA program. Licensee actions with respect to previous inspection findings concerning the ALARA Program are reported under the heading l

" Licensee Actions on Previous Inspection Findings."

- - -. - - . -- .. . - .. ~

. .. .

.

Plans'and Implementing Procedures

~

Part 2.0 of the Corporate Radiation Protection Plan, 1000-PLN-4010.01,

- effective May 1, 1986, includes a corporate level statement of policy with respect to implementation of the ALARA. concept. Contained within this Part is a definition of a program for ALARA implementation, a

~

testament of corporate level-desire to implement the ALARA concept, the

,. assignment of responsibilities for ALARA program implementation, the intent of the ALARA program, a statement of the importance'of attaining

.

the goals and objectives of the program, and a brief description of the

!

management system for implementation of the program.

Procedure 4000-PLN-4010.01, TMI-2 ALARA Program Plan, effects the

~

corporate Radiation Protection Plan policy concerning implementation of an ALARA program at TMI-2. It assigns implementation-responsibilities to

-- each _ department and charters the Dose Reduction Working Group as an aid

, to the implementation.of the-TMI-2 ALARA program. The Dose Reduction- ,

Working Group is tasked to control occupational doses at an ALARA level by applying a systematic approach to dose reduction activities. The ALARA program is implemented administrative 1y by procedure-4000-ADM-4010.01, TMI-2 ALARA Program, which requires that each department prepare supporting implementing procedures, designate an ALARA coordinator, define objectives and goals, provide training in ALARA implementation to appropriate personnel, document decision and cost / benefit analysis according to established criteria, and prepare a

.

report of departmental ALARA activities on a semi-annual basis. The

'

procedure assigns specific _ responsibilities to each ALARA coordinator. and to each department. The Radiological Controls Department acts in.an advisory capacity for each department and perfoms annual reviews and reports-on each departmental ALARA program to help ensure an _ adequate and ,

consistent implementation of the progra Each department has issued a procedure implementing the departmenisal

"

ALARA program; has designated an ALARA coordinator; trained appropriate

personnel; and, with the exception of Defueling Operations, issued a report of departmental ALARA activities including its goals and objectives! The Defueling Operations department was only recently organized and a report of its activities is not yet required.

Program Audits Radiological Engineering, under Radiological Controls, issued in July 1986, a report of an audit of the departmental ALARA Programs, which

noted that several departments had not established goals and objectives.

This has been corrected. However, the audit performed by Radiological Engineering was not of sufficient depth to ensure a thorough evaluation i- of the adequacy and consistency of implementation of the ALARA-progra Radiological Engineering recognizes this deficiency and is preparing an  ;

i

'

audit procedure and providing training for auditing personnel in this >

aspect of the ALARA program. The preparation of audit procedures and training of auditors will be reviewed in a future repor (320/86-10-03)

!

i

, - . . _ - , , , _ , __,,,,,_y _,_.y, , ,,,,

O

Program Ccordination .

The inspector noted that departmental ALARA coordinators do not have any

- procedural basis for coordination of the ALARA program between-departments and the Dose Reduction Working Group. The minimal communication between departmental ALARA coordinators, consisting only_of informal . liaison, contributes to the lack of close cooperation between the various departments. .This weakness in the program will continue to be followed. (320/86-10-04)

Goals and Objectives Annually, Radiological Controls establishes goals and objectives for the upcoming year. Radiological Controls issues a monthly report which tracks the progress towards meeting the rJals and objective Radiological Awareness meetings are held monthly in which ALARA goals and objectives are discussed and issues are identified and corrected. These meetings are open to all personne Working Level ALARA The working level ALARA program is generally. adequate. There is close cooperation between the planning groups of the departments responsible for the work in radiologically controlled areas and Radiological Engineering which performs the ALARA reviews. ~ Survey data, shielding considerations,' mock-up us~e, work sequence studies, and pre-jeb briefings are used commensurate with the demands of the task. There is evidence of revisions to ALARA reviews when the nature of the work changes or complications arise. Tracking of the estimated versus the actual dose is goo Post-job reviews based on dose criteria are evaluated for improvement to the program and pertinent findings are incorporateo into future review Training and Worker Knowledge Worker knowledge of the ALARA concept and the ALARA program indicates that workers are receiving adequate training in these area .

.

9.0 Planned Decontamination and Radiation Level Reduction Activities On October ~1, 1986, licensee staff briefed the TMICPD staff on decontamination and radiation level reduction accomplishments since the May,1986 briefing and plans for further activities in this area.

Significant progress has been made in refining ex-vessel fuel estimates and decontaminating cubicles in the Fuel Handling and Auxiliary Buildings. Transit doses to workers in the reactor building have been reduced as a result of shielding portions of the enclosed stairwell and modifying the access route between levels in the reactor building so as to shift traffic from the open stairwell to the enclosed stairwel Further progress was reported in preparing for desludging of sumps and-the reactor building basement, and robotic activities in the reactor building basement. It was reported that some adjustments will be made in Radiological Controls and Decontamination Operations so as to better accommodate the radiation safety needs of the decontamination effor Decontamination and radiation level reduction is progressing satisfactorily. Monitoring of this progress will continu . .

10.0 Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operation (hardware or programatic) that could lead to violations if left uncorrected. Inspector follow items are addressed in paragraphs 1.0, 5.0, and .0 Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether they are violations, deviations, or acceptabl Unresolved items are addressed in paragraph .0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On October 17, 1986, the site inspectors summarized the inspection findings to the following personnel:

J. Byrne, Manager, TMI-2 Licensing C. Dell,- Licensing Technical Analyst J. Frew, Defueling Director S. Levin, Site Operations _ Director R. Rogan, Director, Licensing and Nuclear Safety M. Slobodien, Manager, Radiological Controls J. Tarpinian, Radiological Engineering Manager 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. _.