ML19256D322
| ML19256D322 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/26/1977 |
| From: | Nelson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Herbein J METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19256D314 | List: |
| References | |
| NUDOCS 7910170829 | |
| Download: ML19256D322 (2) | |
See also: IR 05000289/1977020
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION I
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631 PARK AVENUE
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KING OF PRUS$1 A, PENNSYLVANI A 19406
JUL 2 61977
Docket No. 50-289
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Metropolitan Edison Company
ATTN:
Mr. J. G. Herbein
Vice President
P. O. Box 542
,
Reading, Pennsylvania
19603
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Gentlemen:
Subject:
Inspection 50-289/77-20
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This refers to the inspection conducted by Mr. K. Plumlee of this office
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on June 13-15 and 20-21,1977, at the Three Mile Island Nuclear Generating
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Station of activities authorized by NRC License No. DPR-50 and to the
discussions of our findings held by Mr. Plumlee with Mr. G. Miller and
others of your staff at the conclusion of the inspection, and to a
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subsequent telephone discussion between Mr. Miller and others of your
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p . staff and Mr. P. .Knapp, Mr. A. Davis and Mr. Plumlee of this office on
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June 16,1977.
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Areas examined during this inspection are described in the Office of
Inspection and Enforcement Inspection Report which is encicsed with this
letter.
Within these areas, the inspection consisted of selective
examinations of procedures and representative records, inteiviews with
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personnel, measurements made by the inspector, and observations by the
inspector.
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Based on the results of this inspection, it appears that certain of your
activities were not conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation, enclosed herewith as Appendix
A.
These items of noncompliance have been categorized into the levels
as described in our correspondence to you dated December 31, 1974.
This
notice is sent to you pursuant to the provisions of Section 2.201 of the
NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations.
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Section 2.201 requires you to submit to this office, within twenty (20)
days of your receipt of this notice, a written statement or explanation
in reply including:
(1) corrective steps which have been taken by you
and the results achieved; (2) corrective steps which will be taken to
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Metropolitan Edison Company
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avoid further items of noncompliance; and (3) the date when full com-
pliance will be achieved.
Item number A, shown in the Notice of Violation enclosed with this
letter, is a recurrent or uncorrected item.
In your response please
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give this matter your particular attention.
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In accordance with Section 2.790 of the NRC's " Rules of Practice"s Part
2, Title 10, Code of Federal Regulations, a copy of this letter ano the
enclosures will be placed in the NRC's Public Document Room.
If this
report contains any information that you (or your contractor) believe to
be proprietary, it is necessary that you make a written application
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within 20 days to this office to withhold such information from public
disclosure. Any such application must be accompanied by an affidavit
executed by the owner of the information, which identifies the document
or part sought to be withheld, and which contains a statement of reasons
which addresses with specificity the items which will be considered by
the Comission as listed in subparagraph (b)(4) of Section 2.790.
The
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information sought to be withheld shall be incorporated as far as possible
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into a separate part of the affidavit.
If we do not hear from you in
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this regard within the specified period, the report will be placed in
the Public Document Room.
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Should you have any questions concerning this inspection, we will be
pleased to discuss them with you.
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Sincerely,
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Paul R. Nelson, Chief
.s Safety
Fuel Facility and Materi
Branch
Enclosures:
1.
Appendix A, Notice of Violation
2.
Office of Inspection and Enforcement Inspection Rcport
Number 50-289/77-20
cc w/ enc 1:
L. L. Lawyer, Manager, Generation Operations - Nuclear
G. P. Miller, Superintendent
R. W. Heward, Project Manager, GPUSC
Miss Mary V. Southard, Chairman, Citizens for a Safe Environment
(Without Report)
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Metropolitan Edison Company
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Three Mile Island Nuclear Station Unit 1 (TMI-1)
Docket No. 50-289
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License No.'DPR-50
Inspection No. 77-20
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RESPONSE TO DESCRIPTION OF APPARENT VIOLATION
Infraction A
10 CFR 20.203 (c)(1) requires that each high radiation area shall be conspicuously
posted with a sign or signs bearing the radiation caution symbol and the
words:
" CAUTION - HIGH RADIATION AREA", and your procedure OP 1104-28 " Solid
Waste Disposal" in Section 28.2.1.8 requires that radiation varning signs
shall be utilized prior to the start of any packaging operation as required to
restrict access of personnel into areas which may be subject to high radiation
levels.
Contrary to this requirement at 4 P.M. on June 15, 1977, a high radiation area
around two solidified radvaste containers in the Auxiliary Building, an area
accessible to personnel, was not posted as a high radiation area.
The sign
had been removed earlier in the day even though the radiation level was 150
mR/hr at 12 inches from each of these containers.
Restonse to Infraction _A_
It is not felt that this item is recurrent in that it is not identical in
nature to previous infractions. The difference is that the area was properly
posted, however, a worker took the rope and posting down to pass through and
neglected to put it back in the proper location.
The infraction is part of the subject matter presented to plant personnel in a
one hour special training session to increase awareness of proper Health
Physics practices.
Additionally, vacancies previously existing in the Health
Physics supervisory staff have been filled to increase supervisory capabilities,
thereby, providing additional assurance of proper Health Physics practices.
Full compliance was achieved on June 15, 1977
The training vill be completed
by September 1, 1977
Infracticn B.1.a.
"All shipments of radioactive materials will co= ply with DOT Regulations."
(1003.6.3 1 3)
Contrary tc this requirement solidified radioactive vaste shipment No. 77-60
was not provided adeque_ce leak-resistant and corrosion-resistant inner containers,
enough absorbent material and an adeqt te secondary container to retain the
radioactive contents under normal conditions of transport as required by h9
CFR 173.393(g)(1), (2) and (3) and this resulted in releasing in excess of 105
microcuries of liquid radioactive material into the transport trailer and
dripping a small but detectable quantity of radioactive material on the public
highway on June 13, 1977
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Restonse
g.)
Although a shipping container containing radioactive vaste material did in
fact leak a small amount of radioactive liquid to the environment during
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ship. lent, the container was not considered inadequate at the time of shipment.
The containers were ordered to meet DOT Specification TA type A packaging
criteria. -Record of certifications that the criteria vere met was =aintained
by the container vendor and was subsequently supplied to Met-Ed.
Changes to
the solidification procedure (OP 110h-28) shall be =ade to more closely control
storage and draining of the container prior to shipment.
Certification of
compliance with the container specifications shall be insured by the Quality
Control Department with records of future shipments maintained on site.
Full
compliance vill be achieved by September 1, 1977
Additionally, Met-Ed is
investigating possible cdministrative re-organization to improve overall
control of Radvaste Operations.
Infraction B.1.b. & c.
"All shipments of radioactive materials vill comply with DOT R'gulations".
(1003.6.3.1.3)
b.
Conf,rary to this requirement the containers used for shipment No. 77-60
were not marked with the shipping name of the hazardous material, the
transport index and the gross veight of each container, and the proper
size letters for some of the information as required by h9 CFR 172.100, -
173.310 (a)(1) and (2), and this could have caused errors in transporting
and receiving this shipment.
c.
Contrary to this requirement specific instructions to the carrier for
maintenance of vehicle exclusive uae controls were not provided in the
shipping papers as required by 49 CFR 173.393 (J) even though six of the
containers of shipment No. 77-60 each had a transportation index greater
than 10 and the aggregate transport index was greater than 50, and this
could have caused errors in transporting this shipment.
Restonse
Changes to the Health Physics Procedure for shipping radioactive =aterials
(HPP 1618) will be made to correct the deficiencies identified in the violation
and to insure proper container labeling.
Full compliance vill be achieved
prior to shipping additional solidified radioactive vaste and no later than
September 1, 1977
Infraction B.2 & B.3
2.
"The Shift Fore =an shall enter instructions for the sampling, analysis
and packaging of batches of vaste. . .in the " Process Instruction and Data
Sheet" prior to the initiation of any transfer frem these tanks and the
operater(s) perfor=ing these function (s) shall enter all subsequent data
concerning sampling, analysis and packaging of a batch of solid vaste."
(110h-28.2.1.1)
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Contrary to this requirement no entries were made on " Process Instruction
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and Data Sheets" for any batch of solid vaste prepared during the period
January 1 to June 13, 1977, and specifically there was no infor=ation on
the eight solidified radioactive vaste containers composing shipment No.
77-60, and this could have resulted in errors in managing this material _,
and prevented any such errors being identified.
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"The Supervisor of Operations, or his designee, designates on the applicable
data log that a sufficient amour.t of radvaste has acct ulated in specified
tanks to warrant initiation of the packaging operation."
(110h-28.3.1.a)
Contrary to this requirement, no such data log appeared to be maintained,
and this could have resulted in errors in radvaste operations.
Resuonse
The event occurred because deficiencies in the solidification procedure
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(OP 110h-28), made use of the " Process Instruction and Data Sheet" and other
administrative controls unvorkab >. The procedure (OP 1104-28) vill be
extensively modified to provide workable controls for the solidification of
radioactive vaste.
The modification vill include a more workable instruction
sheet (" Rad Waste olidification Process Sheet") and step by step control of
the process.
The completed process sheets and procedures vill be maintained
to document plant activities in this area.
Corrective action vill be taken by
Sertember 1, 1977 or prior to solidifying radioactive materials.
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Infraction B.h
4.
"All work or entry for surveillance purposes in radiation areas that
could cause exposure to radiation in excess of the following limits vill
reguire a Radiation Work Permit - 5 mrem /hr... greater than 2200 DPM/100
cm
Beta-GA-a," and ". . .it is the responsibility of the persorsa involved
to adhere to instructions listed on the Radiation Work Permit.
(1003-2.10)
Contrary to this requirement an individual was found on June 21, 1977, at
2 P.M. Who was in a posted high radiation area and conta=inated area,
wherein 150 mR/hr and 50,000 DFM removable contamination existed, without
the shoe covers, gloves and protective garment listed in the applicable
Radiation Work Permit, No. 11962.
Restense
The individual, an Auxiliary Operator "A", was counseled by the Supervisor of
Operations regarding the importance of complying with the Health Physics
requirements.
Disciplinary action was also ad=inistered.
Full cc=pliance was
achieved on June 22, 1977
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Infraction b.5
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Contrary to the referenced requirement of MSI N18.7-1972 no written approved
procedure was provided for the draining of solid radvaste containers and for
patching radvaste containers that leaked prior to shipment, and the failure to
effectively perform these operations resulted in radioactive liquid escaping
from four containers during shipment No. 77-60 on June 23, 1977,
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excess of 105 microcuries of radioactivity into the transport trailer and
dripping a detectible quantity on the public highway.
Restonse
Changes shall be made to the solidification procedure OP 110h-28 to include
detailed instructions regarding the draining of solidified radioactive vaste
containers.
This vill be completed by Septe=ber 1, 1977
A Special Operating
Procedure was issued to provide guidance on draining the containers prior to
=aking a change to OP 1104-28. The effective date of the SOP was June 20, 1977
Infraction C
10 CFR 20.203 (f)(1) and (2) require that each container of licensed =aterial
shall bear a label showing the radiation caution symbol and the words " Caution-
Radioactive Material", and identification of the radioactive contents.
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Contrery to this requirement,on June 15, 1977, there vere two 50 cu. ft.
containers of solidified radioactive vaste stored in the Auxiliary Building,
an area accessible to personnel, without labels shoving the required infor=ation,
and the radiation level was measured to be 150 mr/hr at 12 inches frem each of
these containers which were not part of any shipment or 4-mediate planned
shipment.
, Response to Infraction C
Iull compliance was achieved on June 16, 1977, when the two subject dru=s were
posted. A procedure change to solidification procedure OP 110h-28 vill be
implemented which requires that i= mediately after a container has been filled
with radioactive vaste =aterial a " Caution-Iadioactive Material" sticker vill
be placed on the container. Additionally, vacancies previously existing in
the Health Physics supervisory staff have been filled to increase supervisory
capabilities thereby 7 ovidir , additional assurance of proper Health Physics
practices.
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