IR 05000320/1987002
| ML20215H202 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/08/1987 |
| From: | Bell J, Dan Collins, Cowgill C, Moslak T, Myers L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20215H179 | List: |
| References | |
| 50-320-87-02, NUDOCS 8704200210 | |
| Download: ML20215H202 (14) | |
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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/87-02 Docket No. 50-320 License No. DPR-73 Priority
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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 C cted:
Rbruary 14,rL987 - March 31, 1987
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4/7/77 Inspectors:
T. Moslak Ret identlnspector (TMI-2)
da1(e signed O Yb.D100-417187 J.
ell, Sehior Radiatio'n Specialist ditFsigned Y
Y D. Col 'ns Ra i io Specialist d' ate' signed la 1/2/77 t
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M ers' Radia n
ecialis~t date signed
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^l/%/R7 Approved By:
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C. Cowgill, Chidf, TMI-2 Project Section date signed e
Inspection Summary:
Areas Inspected: Routine safety inspection by site inspectors of routine plant operations, defueling operations, control of radioactive materials, licensee event report followup, radiological and housekeeping conditions within the reactor building, and licensee action on previous inspection findings.
Results: Two violations were identified:
one violation resulted from an operator failing to properly implement a procedure when returning the deluge system for the control room ventilation system to service.
The second violation resulted from the licensee failing to properly maintain control of licensed material on two occasions.
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8704200210 870410 PDR ADOCK 05000320
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DETAILS 1.0 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; 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.
Inspections of the control room were performed during regular and backshif t hours. The Shift Foreman's Log and selected portions of the Control Room Operator's Log were reviewed for the period February 14, 1987 through March 31, 1987. Other logs reviewed during the inspection period included the Submerged Demineralizer System Operations Log, Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log Sheets.
Operability of components in systems <ecuired to be available for response to emergencies was reviewed " verify that they could perform their intended functions. The inspeu.or t ttended selected licensee planning meetings.
Shift staffing for litensed operators, non-licensed personnel, and fire brigade members was determined to be adequate.
No violations were identified.
2.0 Defueling Operations The licensee suspended defueling operations for a two-week period (February 8 - 22, 1987) to characterize the quantity and consistency of core debris in the reactor coolant piping and to conduct detailed examinations of the condition of reactor in-vessel components.
Video inspection results of the reactor coolant system cold leg piping and reactor coolant pumps showed a layer of very finely divided material.
Similar material was found in the "B" hot leg. The decay heat drop line was full of material of apparently larger average particle size. Video surveys of the top of the current core, the core support assembly and lower reactor vessel head were also obtained.
Localized damage, including melting of incore instrument guide tubes and small portions of the Core Support Assembly, was observed. The information gathered will be of significant value in understanding the course of the accident at TMI-2.
Defueling operations resumed on February 23, 1987.
The principal effort was focused on removal of end fittings and fuel pins from t.ie peripheral fuel assemblies.
The efforts were largely successful, bd a few end fittings were deformed such that they would not fit in the fuel canister opening. After removing the end fittings from peripheral fuel assemblies, the upper section of in-place peripheral fuel assemblies were
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cut into nominal five foot segments and placed into fuel canisters. Two canisters were filled using this method.
During the week of March 16, 1987, a new tool, the hydraulic cam clamp lifting tool, was used to remove two standing peripheral fuel assemblies (A-6 and A-7).
The assemblies were removed essentially intact, then cut, and placed into fuel canisters.
Cutting was required because intact assemblies are approximately one (1) foot longer than the available space in a canister.
Removal of these two assemblies improves access to the core support assembly and provides potential access to the lower head.
Attempts at removing degraded fuel assemblies using the hydraulic cam clamp lifting tool were unsuccessful, because the tool could not adequately grip these partial length assemblies.
Defueling teams are presently cutting fuel pins, using the heavy duty hydraulic shear, in the area of the test pattern.
The test pattern was initially made in October 1986 to test the feasibility of using the core drilling rig to fragmentize the core. Subsequent to trimming the pins around this test pattern, teams will try to remove core debris from this area.
3.0 Licensee Action on Previous Inspection Findings (Closed) Non-compliance (320/86-06-01): QA program not in place to monitor dewatering of resin liners shipped to a land disposal site.
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The inspector determined that the Quality Assurance (QA) Department is now aware of dewatering activities so that a programmatic decision can be made on a case-by-case basis with respect to implementing the QA function in assuring that resin liners contain less than one percent by vclume free-standing liquid. This action was taken as stated in the GPUN letters to NRC Region I dated August 8, 1986 (4410-86-0135 Document ID 0065P) and September 26, 1986 (4410-86-L-0159 Document ID 0065P).
The inspector has determined the action taken to be acceptable and adequate to prevent recurrence.
(Closed) Non-compliance (320/86-06-02): QA did not review procedures for dewatering resin liners.
The inspector determined that the QA Department reviewed the EPICOR-II dewatering and transfer procedures and has issued a memorandum to managers to ensure that their writers, reviewers, and approvers of
"Important to Safety" procedures include the QA Department in the review cycle. These actions were taken as stated in the GPUN letter to NRC Region I dated August 8, 1986 (4410-86-0135 Document ID 0065P).
The inspector determined the actions to be acceptable and adequate to prevent recurrence.
(Closed) Unresolved (320/87-01-01): Transfer of filter canister from reactor building (RB) to spent fuel pool without notification of Radiological Controls.
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On January 11, 1987, the Fuel Handling Senior Reactor Operator (FHSRO)
authorized the transfer of a loaded filter canister from the RB via the fuel transfer system to the fuel handling building (FHB) without informing Radiological Controls Field Operations (RCF0) as specified by Radiation Work Permit (RWP) No. 15261. The transfer was stopped by the RCF0 technician on duty at the Coordination Center as the canister arrived in the FHB via the fuel transfer system. A Radiological Awareness Report was initiated.
The RWP requirement for notifying RCF0 was initiated in response to an incident in January 1986, when a fuel canister was transferred without notification of RCF0.
Because of the small amount of data available to support the results of calculations pertaining to the effectiveness of the shielding around the fuel transfer canals in the annulus area, there were concerns about personnel access to the RB annulus during transfers.
In the interim, additional data was obtained confirming the adequacy of the shielding.
Corrective actions consist of revising the applicable RWP and transfer procedure. The RWP was revised to require that the FHSR0 inform the RCF0 technician on duty at the Coordination Center or the duty Group Radiological Controls Supervisor (GRCS). Operating Procedure 4211-0PS-3252.01, " Canister Transfer System" was revised to incorporate a sign-off to assure that RCF0 is notified of the intent to transfer a canister.
The transfer of the filter canister without informing the RCF0 balance-of-plant GRCS is an apparent violation of Technical Specification 6.11 which states, in part, that personal radiation protection shall be
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consistent with the Radiation Protection Plan. The Radiation Protection Plan states, in part, that each worker shall obey instructions on Radiation Work Permits.
However, the inspector determined that the circumstances of the incident meet the criteria of 10 CFR Part 2, Appendix C for self-identified items and, therefore, a Notice of Violation will not be issued.
The inspector will review the revised procedure in a future inspection.
(320/87-02-01)
4.0 Licensee Event Report (LER) Review /and Onsite Followup The inspector reviewed the LER listed below to verify that the details of the event were clearly reported, including the accuracy of the description of the causes and the adequacy of corrective actions. The inspector determined whether further information was required from the licensee, whether the event should be classified as an Abnormal Occurrence, whether generic implications were indicated, and whether the event warranted onsite followup.
LER 87-01, dated February 25, 1987, addressed a licensee identified condition in which both Control Room Bypass Fans were inoperable for approximately sixty-three hours.
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The cause is attributed to operator error in that the system was not properly returned-to-service following completion of surveillance testing.
Details At 0850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br /> on January 23, 1987, operators commenced the surveillance of the Control Room (CR) Bypass Charcoal Filter Deluge System per Procedure 4210-SUR-3811.04 " Fire System Deluge / Sprinkler System Functional Test". This procedure requires placing the interlock switch for the CR Bypass Fans AH-E-4A/B in the " Bypass" mode prior to actuating the heat detector for the deluge system.
This procedure also requires that the deluge system be returned-to-service per Procedure 4210-0PS-3810.01 " Fire Protection System". At 1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br /> on January 23, 1987, operators completed the surveillance of the deluge system. At 0001 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on January 26, 1987, operators were initially unable to start AH-E-4A/B during the performance of a different surveillance test, 4210-SUR-3826.01, " Control Room Ventilation System".
However, operators were able to start AH-E-4A/B by pressing the reset button.
This indicates that the referenced operating procedure was not implemented when returning the system to service following completion of the surveillance performed on January 23, 1987.
Instead, the operators relied on their knowledge of the system to perform the return-to-service.
A contributing cause of this event was the failure to include the specific return-to-service requirements in 4210-SUR-3811.04.
Instead, this surveillance procedure states "... return the deluge system as per 4210-0PS-3810.01." This operating procedure is bulky (i.e. 226 pages)
and the specific section for returning the system to service is not referenced within the surveillance proc 3 dure. Additionally, the instructions given within 4210-0PS-3810.01 are of a generic nature and not specific for the CR Bypass Ventilation system.
Corrective Actions Immediate - The fans were verified to be operable at 0120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on January 26, 1987. The operators who performed the surveillance of the CR Bypass Filter Deluge System were counselled on the importance of attention to detail in the performance of surveillance testing.
Long Term - Procedure 4210-SUR-3811.04, " Fire System Deluge / Sprinkler System Function Test" is being revised to include the specifications for returning the CR Bypass Filter Unit Deluge System to service following completion of the surveillance.
This procedure will also be revised to require operators to start these fans to detect any abnormalities before placing them in a " standby" condition.
Inspector In-Plant Review The inspector interviewed the Plant Operations Manager and walked through the steps required to perform the Surveillance (4210-SUR-3811.04) and for returning the system to service (4210-0PS-3810.01). The inspector detennined that 4210-0PS-3dIO.01 was a lengthy and confusing procedure in that referett.es to other plant systems are made within the
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return-to-service section and that requirements are not specifically addressed for the CR Bypass Fans.
The inspector examined the licensee's corrective actions. The inspector reviewed Procedure Change Request (PCR) 2-87-0126 and determined that this revision to 4210-SUR-3811.04 more clearly identifies the requirements for returning the CR Bypass Fans to service. This PCR also includes steps for performing an operational check of the fans to verify that they have been properly reset.
Based on recent correspondence between the licensee and the NRC Office of Nuclear Reactor Regulation (NRR), the inspector determined that the incident has minor safety significance.
On February 9,1987, the licensee was granted a partial exemption from the requirements of 10 CFR 50 Appendix A, General Design Criteria (GDC) 19, " Control Rooms". Because TMI-2 is in a long term cold shutdown, no actions on the part of control room personnel are required to maintain the facility in a safe shutdown condition. Therefore, continuous manning of the control room is not necessary under accident conditions and continuous operability of the control room emergency air cleanup system need not be provided by an onsite backup emergency power source.
Accordingly, this event did not present a significant hazard to plant personnel or the general public.
Through interviews with licensee representatives and review of licensee records, the inspector determined that the condition of both CR Bypass Fans being inoperable was an isolated event and is not considered symptomatic of program deficiencies in performing surveillance testing.
However, the condition resulted from a failure on the part of operators to follow a procedure or to take the necessary actions to correct the procedure to ensure that it could be readily implemented. Such disregard for attention to detail in returning a safety-related system to service is contrary to the requirements of Technical Specification 6.8.1 which states, in part, " Written procedures shall be implemented and maintained covering...surveillances and test activities of safety-related equipment." This is an apparent violation of regulatory requirements (320/87-02-02). As such, failure to implement the required procedure resulted in both CR Bypass Fans being inoperable from 0850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br /> on
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January 23,1987 to 0120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> on January 26, 1987.
When the licensee identifies a violation of regulatory requirements, initiates immediate and long term corrective actions to preclude a recurrence, promptly reports the condition to the NRC, and has not experienced events of a similar nature, a Notice of Violation is generally not issued, in accordance with Appendix C of 10 CFR 2.
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However, the circumstances surrounding this violation, involving
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activities required by the facility license, represent a failure of licensee personnel to act responsibly and in conformance with licensee training and established procedural controls. Accordingly, a Notice of Violation is being issued.
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- 5.0 Health Physics and Environmental Review
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a.
Plant Tours
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The NRC site Radiation Specialists performed inspection tours of the plant, including all radiological control points and selected radiologically controlled areas.- Among the areas inspected were:
l the Auxiliary and Fuel Handling Buildings, EPICOR-II, Radiochemistry i
Laboratories, radioactive waste storage facilities, the Respirator Cleaning and Laundry Facility, the Radiological Controls Instrument Facility and the Waste Handling and Packaging Facility.
l Among the items inspected were:
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Access control to radiologically controlled areas
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Adherence to Radiation Work Permit (RWP) requirements
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I Proper use and storage of routinely used respirators and
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associated equipment Maintenance and storage of emergency respiratory equipment
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Adherence to radiation protection procedures
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Use of survey meters and other radiological instruments.
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The inspectors reviewed the application of radiological controls
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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
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building and the balance of the plant were reviewed. All of the log i
books contained appropriate entries.
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No violations were identified.
b.
Radioactive Material Shipments The NRC site Radiation Specialists inspected radioactive materials shipments on February 14, 19, 23, 24, 25, 26, and 27; and March 6, i
16, 17, 22, and 24, 1987, including observation of the preparation and dispatch of two railcar-mounted cask shipments of Unit 2 core
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debris.
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The inspector's review covered:
Compliance with approved packaging and shipping procedures
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Proper preparation of shipping papers, including certification
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j that the radioactive materials had been properly classified, described, packaged and marked for transport
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Warning labels on packages and placarding of vehicles
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Compliance with regulatory limits for radioactive contamination
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and radiation dose rates.
The inspector's review consisted of (1) examinations of shipping papers, procedures, packages and vehicles, and (2) performance of radiation and contamination surveys.
No violations were identified.
c.
Reactor Building Work Reactor Building Entries The inspector monitored the licensee's conduct of RB work during the inspection period. The following were reviewed on a sampling basis during the inspection period:
RB entries were planced and coordinated so as to ensure that
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ALARA review, personnel training, and equipment testing had been conducted.
Radiological precautions were planned and implemented,
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including: use of an RWP, locked high radiation area access authorization, specific work instructions, alarming self-reading dosimeters, and breathing zone air samplers.
Individuals making entries into the RB had been properly
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informed, trained, understood emergency procedures, and possessed appropriate communications equipment.
Unique tasks were performed using specifically developed
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procedures, and mock-up training had been conducted where warranted.
An NRC site radiation specialist entered the RB on March 9, 12, and 20, 1987. The inspector observed portions of the routine daily surveillance activities in the RB, and evaluated radiological and industrial safety conditions.
During these entries the inspector observed the results of licensee efforts to improve posting of areas.
Efforts have been underway since January 1987 to remove redundant radiological signs. The results of the licensee's efforts, with the exception noted below, have led to easier recognition of the different radiological control requirements as a worker proceeds from area to area.
The licensee is required to control access to " locked high radiation areas."
It is appropriate for these controls to be applied at the access points to the RB. The inspector noted that there were
" Caution, Locked High Radiation Area" signs posted at the entrances to the RB. The inspector also noted that, in many cases, there were no signs within the RB to warn workers of the existence of individual, separate high radiation area _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
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Most accessible areas of the RB have radiation levels below 100 mR/hr and, therefore, do not constitute "high radiation areas".
Therefore, it is appropriate that individual, separate high radiation areas within the RB be posted as such in order to make workers aware of the existence of relatively high radiation levels in these areas.
However, on March 9, 1987, several separate, discrete areas in the RB, each of which constituted a high radiation area, were not posted as high radiation areas, but, instead, were posted with a sigr, stating that Radiological Controls should be contacted prior to entry. Examples include the area where high level trash is stored under a core flood tank on the 305' elevation; the incore seal table area on the 347' elevation; the defueling tool repair area on the 347' elevation; the areas inside the D-rings; the open area at the access to the reactor vessel shielded work platform slot; and the shielded area at the north end of the rotating work platform over the reactor refueling canal.
The inspector expressed his concerns to the licensee in a meeting on March 9, 1987. The licensee explained that the posting changes were made as part of its program to reduce posting redundancy, and stated
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that the individual high radiation area signs in the RB would be
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restored. The inspector noted during his March 12, 1987 entry that the signs were in place.
Housekeeping in the defueling tool repair area on the east side of the 347' elevation of the RB had deteriorated since the inspector's January 1987 entries.
On March 9, the area was essentially inaccessible because of tools and contamination control packaging in the walkway and on top of the decontamination bath. On March 12 the situation had only marginally improved, despite the hold placed on the RWP for the tool repair area. On March 20 the area was much improved. Ccnditions in the RB are subject to continuing NRC review.
No violations were identified.
d.
Radiological Controls Instrumentation Shop Building The Radiological Controls Instrumentation Repair and Calibration Section has been relocated from their temporary quarters to a permanent facility at the base of the Unit I natural draft cooling towers. The Section staff consists of nine technicians, two supervisors and one clerk. The building is steel framed, masonry block walled, with one interior shielding wall of masonry block. The facility contains a calibration range for using radiological instruments, a ventilated painting booth for reconditioning instrument cases, storage, heating and ventilation equipment, fire protection services, office areas, instrument repair and service areas, and eating and lavatory facilities. A nearby, separate, shielded building continues to house the thermoluminescent and self-reading dosimeter calibrator.
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e.
Waste Handling and Packaging Facility On March 5, 1987, the Three Mile Island Unit 2 Cleanup Project Directorate (TMICPD) issued a letter to the licensee approving a Technical Evaluation Report on the newly constructed Waste Handling and Packaging Facility (WHPF). The THICPD letter stated that maintaining a negative pressure within the radioactive material handling areas with respect to the outside atmospheric pressure (-0.125incheswatergauge)wasacceptable. The letter stated that the building isotopic inventory may be up to 10 curies (C1)
defueling waste or 7.5 C1 each of defueling waste and normal wastes.
The WHPF building is steel framed with poured concrete and masonry block walls. The building areas containing radioactive materials have no connection to the plant water discharge systems; and any liquids in these areas must be sampled prior to being removed.
There is a fire protection system consisting of detectors, alarms (local and in the Unit 2 Control Room), and sprinklers.
The radioactive materials handling area ventilation system is filtered and has a monitor in the exhaust stream. The airflow in the WHPF is from low to higher radioactive contamination areas, and spot air exhaust suction is provided at work areas to assure airflow is into tne ventilation system rather than into the atmosphere around the workers. A separately ventilated section of the building contains office, sanitary, personnel areas, and uncontaminated equipment areas.
6.
Licensee Loss of Control of Radioactive Material The inspector reviewed two events involving licensee loss of control of radioactive material during the inspection period.
First Event In the first event, occurring February 24 and 25, 1987, a small amount of radioactive material was inadvertently taken offsite and returned.
Exposures to workers, including the vehicle drivers, and the public were very small due to the short time offsite, the even shorter times that the vehicle was parked in public areas, and the low radiation levels outside of the truck.
The radioactive material was contained in a 500 milliliter polyethelene sample bottle inside two plastic bags, cm inside of the other, and tagged as required to show associated W.iation and internal contamination levels.
The critique of the event established that the radioactive material was placed in the truck bed on Tuesday, February 24 without being specifically noted by those loading the truck. The container apparently escaped notice as a consequence of its small size, light weight, and its intermingling with much larger plastic bags being moved to a waste staging area. Similarly, the small container of radioactive material was overlooked when the larger containers were off-loaded.
(When found on February 25, 1987, the small container was positioned so as to be partially hidden by a broom in the truck bed.)
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The truck was parked overnight onsite in an unrestricted area at the Waste Handling and Packaging Facility. The vehicle was utilized the next day (2/25) by several individuals at different times over the period 0700
-- 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />.
The radioactive material was identified and reported to Radiological Controls (Rad Con) by the last driver at about 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />.
The longest possible period of exposure of any individual offsite(other than the driver) to the low levels of radiation at the truck was about 15 minutes during the approximately two hours (0830 -- 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />) that the truck was offsite. The estimated "whole body" dose (based on the lens of the eye) is in the range of from less than 0.2 millirem to 11 millirem.
Based on a review of licensee calculations, the inspector determined that it is very unlikely that the dose could have exceeded 1 millirem.
Si.nilarly, the inspector determined that any extremity (hand) dose that could have occurred was almost certainly less than 120 millirem.
Second Event The second event occurred in the morning of March 18, 1987, when two, used (internally contaminated) submerged demineralizer leakage containment vessels (LCV) were removed from the " paint shed" storage facility within a fenced, locked, and posted radiological waste storage area (" South East Acres").
The vessels were contained in plastic and tagged as required to show radiation and internal contamination levels.
The vessels were moved on an open stake-bed truck. The truck, bearing the vessels, was parked, unattended, in an unrestricted area near the Unit 2 Processing Center for approximately 45 minutes at mid-day.
The LCVs were identified as radioactive material by a Rad Con Technician who posted the vehicle and established control over the radioactive material.
The vessels were then moved to their intended destination in the Unit 2 auxiliary building.
Inspector Findings In both events the licensee did not maintain control of the radioactive material. Also, the two events involved common contributing problems.
In both instances, procedurally required transfer tags were not completed and the personnel involved did not demonstrate a level of knowledge and awareness consistent with their responsibilities. The latter is demonstrated by the fact that the small container was overlooked in the first case, and by the lack of positive action to involve Rad Con and the lack of attention to the LCVs left on the truck in an unrestricted area in the second case. However, the inspector determined that the root causes of the two events were different.
Root Causes In the first case, had the container been off-loaded as planned, there would not have been any problem.
There is little reason to doubt that the container would have been off-loaded properly had those unloading the truck been aware of its presence.
The completion of a transfer accountability tag would have made those involved aware of the presence of all containers, including the one that was overlooked. Also, a radiation survey of the vehicle as it left the radiologically controlled
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area after being unloaded would have identified the container as containing radioactive material.
Interviews of involved personnel established that there was confusion concerning the necessity for a transfer tag in this case, resulting from a lack of clarity in the
" Radioactive Material Transfer" procedure. The performance of a radiation survey was optional at the discretion of the cognizant Rad Con foreman who, in this case, waived the survey based on information provided to him by telephone.
Based on the above, the inspector determined that the primary cause of the first event was procedural inadequacies.
In the second case, Rad Con was not aware of the intended transfer of the LCVs.
Completion of a transfer tag would have resulted in such an awareness. However, the radiation levels associated with the LCVs were not such that a Rad Con technician escort would have been required.
In the absence of such a Rad Con escort, the parking of the truck without the required control may still have occurred, although those moving the LCVs would probably have been made aware of their responsibilities by the Rad Con technician.
In light of these considerations, the inspector determined that the primary cause of the second event was an inadequate level of knowledge of procedural requirements, and a lack of worker awareness of worker responsibilities with respect to radioactive materials under their control.
It was also noted by the inspector that although information concerning the first event was disseminated to employees, this information was not effective in preventing the occurrence of the second event.
Non-compliances In both cases, the licensee did not comply with Commission regulations or the requirements of its own procedures. Technical Specification 6.11 requires that licensee personnel radiation protection be consistent with 10 CFR 20 and the licensee's approved Radiation Protection Plan. The licensee's " Radiation Protection Plan" requires in Section 9.1.5 that radioactive materials removed from the protected security area be controlled so as to ensure that the materials are not lost or improperly handled or subject to unauthorized removal.
Procedure 9000-ADM-4430.01,
" Radioactive Material Transfer", requires in Section 4.3.2 that radiological controls be notified of intended transfers of radioactive material and in Section 4.3.4 that a " transfer accountability tag (Form El-1)" be initiated to include an inventory of items being transferred.
Section 20.201 of 10 CFR 20 requires surveys as necessary for the licensee to comply with the requirements of 10 CFR 20 and as reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Procedure 9000-ADM-4200.02, " Release Surveys", as modified after the first event by a Temporary Change Notice on February 27, 1987, requires in Section 4.6 that vehicles exiting a radiologically controlled area be surveyed upon leaving the area.
In addition, Section 20.203(e)(1) of 10 CFR 20 requires that each area in which licensed material is used or stored and which contains radioactive material exceeding certain limits be conspicuously posted as containing radioactive material.
Further, Section 20.207(b) of 10 CFR 20 requires
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that licensed materials in unrestricted areas be under the constant and immediate control of the licensee.
Notwithstanding these requirements, the radioactive material was open to improper handling and unauthorized removal while untended, radiological controls was not notified of the intended transfer of the LCVs, transfer tags were not initiated in either event, surveys of the vehicles bearing the radioactive material were not made to evaluate the radiation hazards in and around the vehicles, and the vehicles were not posted as containing radioactive material. These failures to comply with NRC requirements and licensee procedures resulted in an apparent violation of 10 CFR 20.207 in that the licensee left the radioactive material untended in unrestricted areas both onsite and offsite (320/87-02-03).
Accordingly, a Notice of Violation is being issued.
Licensee Corrective Actions The licensee conducted evaluation and fact-gathering efforts following each event, including the initiation of an " Event Report" for each occurrence.
Following a preliminary evaluation by Rad Con and prior to the first shift of the day following the first event, Rad Con personnel were instructed, via the Rad Con log, to perform a radiation and visual survey of each vehicle exiting the protected area.
(Such surveys are normally performed at the option of the cognizant Rad Con foreman.) This instruction was later modified to apply only to vehicles carrying radioactive material or that had been in a radiologically controlled area. Licensee management and supervisory personnel discussed the nature and causes of the event with Rad Con and Waste Management personnel at a critique the day following the event. The event was also discussed at separate meetings within the Rad Con and Site Operations Departments and the Event Report was circulated as required reading.
Following the critique of the first event, the licensee's " Release Surveys" procedure 9200-ADM-4200.02 was modified by means of a " Temporary Change Notice" (TCN) consistent with the instructions provided earlier to Rad Con personnel. Action on a permanent change to the procedure was also initiated and an assessment of possible personnel radiation exposure was completed. The licensee also completed a TCN modification of its
" Radioactive Material Transfer" procedure 9000-ADM-4430.01 to clarify requirements for the use of the transfer accountability tag (" Radioactive i
Material Transfer Tag") for the type of transfer involved in the event.
Following the critique of the second event on March 19, 1987, the licensee initiated actions to post supplementary signs at radiologically controlled areas, publish an article in a plant newsletter, discuss the event at a " Rad Awareness" meeting, circulate a copy of the " Event Report" to all affected departments, and supplement its training program in order to make all personnel aware of the requirements and their responsibilities with respect to the transfer of radioactive material.
The inspector determined that the licensee's corrective actions, when fully implemented, should prevent similar events.
The implementation of the corrective actions will be reviewed by the inspector.
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9.0 Review of Reports Required by Technical Specifications Per tLe requirements of Technical Specification (TS) 6.9.1.5, the licensee submitted its report of occupational radiation exposures for 1986 and the annual report of aircraft movement near the plant site.
The inspector reviewed the annual Exposure Report and determined that it is complete and more detailed than required by the TS.
The TS only requires information be reported for personnel who receive greater than 100 mrem during the reporting period. The submitted report, however, lists exposures received by job function for all monitored personnel, regardless of exposure.
The annual Aircraft Movement Report lists aircraft movements for the Harrisburg Airport for 1986. Accounting of the overflights of large aircraft is a requirement for information collection with respect to the potential for impact on containment structures.
The inspector determined that both reports provided the information required by the TS and had no further questions.
10.0 Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operations (hardware or programmatic) that could lead to violations if left uncorrected.
Inspector follow items are addressed in paragraphs 3.0, 4.0, and 8.0.
11.0 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 parcgraph 3.0.
12.0 Exit Interview The inspectors met periodically with licensee representatives to discuss i
inspection findings.
On March 30, 1987, the site inspectors summarized the inspection findings in a meeting with the following personnel:
J. Byrne, Manager, TMI-2 Licensing C. Dell, Licensing Technical Analyst T. Demmitt, Deputy Director, TMI-2
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S. Levin, Site Operations Director A. Miller, Manager, Plant Operations K. Pastor, Defueling Operations Director R. Rogan, Director, Licensing and Nuclear Safety
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D. Turner, Manager, Radiological Controls, TMI-2 At no time during the inspection was written material provided to the licensee by the TMICPD staff except for procedure reviews pursuant to
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Technical Specification 6.8.2.
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