ML19308B478
| ML19308B478 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/22/1978 |
| From: | Herbein J Metropolitan Edison Co |
| To: | Brunner E NRC Office of Inspection & Enforcement (IE Region I) |
| Shared Package | |
| ML19308B473 | List: |
| References | |
| GQL-2047, NUDOCS 8001030259 | |
| Download: ML19308B478 (2) | |
Text
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Metropolitan Edison Company e l; Post Office Box 542 Reading Pennsylvania 19640 215 929-3601 December 22, 1978 Writer's Direct Dial Number GQL 2047 Mr. Eldon J. Brunner, Chief Reactor Operations & Nuclear Support Branch U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Brunner:
Three Mile Island Nuclear Station, Unit 1 Operating License No. DPR-50 Docket No. 50-289 Inspection Report No. 78-18 This letter and the attachment are in response to your inspection letter of November 21, 1978, in which it was noted that the information necessary to verify the steps taken to correct an item of noncompliance, identified in Inspection 50-289/78-06, was not available for examination. This letter is being submitted on December 22, 1978, in accordance with the December 15, 1978, telecon with Mr. Plumlee of your staff.
Sincerely,
'l J. G. Herbein Vice President-Generation JGH:ajm Attachment o
01030N N 80 1
e
.,e Mstropolitan Edison Company Three Mile Island Nuclear Station Unit 1 Docket No. 50-289 Lictnse No. DPR-50 Inspection No. 78-18 i
Tho fonoving information is provided in response to your letter of November 21, 1978, combined Inspection 50-289/78-18 and 50-320/78-31, referencing your letter of May n.
1978, Inspection 50-289/78-06.
Mat-Ed's response of June 1,1978 (GQL 1002) to your May n,1978 letter, took cxesption to the item of non-compliance and provided justification for that exception.
It cppeared that the item of non-compliance was a result of a misinterpretation of cvailable information, and in our response of June 1, 1978, Met-Ed attempted to idIntify the misinterpretation and c1Arify the information.
During a phone conversation on June 14, 1978, between Mr. R. W. Dubiel of Met-Ed and your Messrs. Knapp and Plumlee, further clarification of Met-Ed's June 1, 1978 rssponse was provided. Also during the phone conversation, it was agreed that if any specific questions remained unanswered, NRC would provide those questions in writing and Met-Ed would respond accordingly.
Yodr letter of July 31, 1978, made no request for specific information, and to date, no specific questions have been received by Met-Ed.
It is Met-Ed's position that the item of non-compliance was not warranted for the fonoving reasons:
a.
The contact dose rates were measured to be 9R/hr with the template in place.
b.
The dose rates were measured to be a maximum of 5R/hr.
c.
The extremity dose to whole body dose ratio was a maximum of 2 based on the readings.
d.
The whole body dose is administrative 1y limited to 1 Rem / quarter without written permission.
e.
The maximum extremity dose was limited to 2 Rem, which is below the limit for selective extremity monitoring.
All the documentation and information regarding the specific incident which led to tha apparent item of non-compliance has been available onsite since April 1978, and this documentation and information has been reviewed by NRC inspectors.
r
y e
UNITED STATES NUCLEAR REGULATORY COMMISSION y
j j
REGION I 4
631 PARK AVENUE KING OF PRUS$1A PENNSYLVANIA 19406 November 21, 1978 Docket Nos. 50-289 50-320 Metropolitan Edison Company ATTN: Mr. J. G. Herbein Vice President - Generation P. O. Box 542 Reading, Pennsylvania 19603 Gentlemen:
Subject:
Combined Inspection 50-289/78-18 and 50-320/78-31 This refers to the inspection conducted by Mr. K. Plumlee of this office on October 6, 10-12, and 17-19, 1978, at Three Mile Island Nuclear Generating Station, Units 1 and 2, Middletovca, Pennsylvania, of activities authorized by NRC License Nos. DPR-50 and DPR-73, and to the discussions of our findings held by Mr. Plumlee with Mr. J. Seelinger and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, measurements made by the inspectcr, and observations by the inspector.
Our inspector also verified the steps you have taken to correct the item of noncompliance brought to your attention in a letter dated March 28, 1978. We have no further questions regarding your action at this time.
In addition to the above, our inspector found that the information necessary to verify the steps you had taken to correct the item of noncompliance brought to your attention in a letter dated May 11, 1978, was not available for examination during this inspection. This is the information referred to in our letter dated July 31, 1978, and previously discussed with Mr. Dubiel of your staff by telephone on June 14, 1978.
In your response to this letter, please include a description of the corrective actions you have taken to prevent recurrence of this non-compliance.
7Fr/z z7ect/7
Metropolitan Edison Company 2
Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance m th NRC requirements, as set forth in the Notice of Violation, enclosea herewith as Appendix A.
These items of noncompliance have been categ)rized 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.
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 avoid further items of noncompliance; and (3) the date when full compliance j
will be achieved.
i In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and 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 witain 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 information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in i
this regard within the specified period, the report will be placed in the Public Document Room.
Should you ha 1 any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, fj.
N eorge H. Smith, Chief Fuel Facility and Mate ials Safety Branch
Metropolitan Edison Company 3
Enclosures:
1.
Appendix A, Notice of Violation 2.
Office of Inspection and Enforcement Combined Inspection Report 1
Numbers 50-289/78-18 and 50-320/78-31 i
cc w/encls:
T. Broughton, Safety and Licensing Manager J. J. Barton, Project Manager R. C. Arnold, Vice President - Generation L. L. Lawyer, Manager - Generation Operations - Nuclear G. P. Miller, Superintendent J. P. O'Hanlon, Unit 1 Superintendent J. L. Seelinger, Unit 2 Superintendent - Technical Support I. R. Finfrock, Jr.
Mr. R. Conrad G. F. Trowbridge, Esquire Miss Mary V. Southard, Chairman, Citizens for a Safe Environment (WithoutReport) i i
1 l
APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket Nos: 50-289 50-320 Based on the results of an NRC inspection conducted on October 6,10-12, and 17-19, 1978, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your license as indicated below.
Items A and B are infractions and item C is a deficiency.
A.
Technical Specifications Section 6.13.1 requires that each high radiation area (100 mrem /hr or greater) be barricaded and conspic-uously posted as a high radiation area.
Contrary to this requirement, at 3:00 p.m., on October 6, 1978, there was neither a barricade nor a conspicuously posted high radiation area sign at an unattended high radiation area located in the Unit 2 reactor coolant drain tank room wherein the radiation level was measured at up to 180 mr/hr at 12 inches from some 55 gallon drums of reactor orifice rods stored in this room.
B.
10 CFR 20.201(b), " Surveys," requires each licensee to make or 4
cause to be made such surveys as may be necessary for him to comply with the regulations in this part.
Contrary to this requirement, a timely survey was not conducted as was necessary to identify and post a radiation area in the Unit 2 makeup pump room 1-C to comply with the requirements of 10 CFR 20.303(b), " Caution signs, labels, signals, and controls." The radiation dose rate was measured at 10 mr/hr at 12 inches from decay heat removal system piping in this unattended non-posted area at 3:20 p.m., on October 6, 1978.
l C.
Environmental Technical Specifications Section 2.C requires that sampling and analyses of radioactive effluent releases through the auxiliary and fuel handling building exhaust vent and the reactor i
building purge vent release points be recorded and the errors associated with each sample analysis be retained.
C@
7 p z Z7 005^{
Appendix A 2
Contrary to the above requirements, the sample flow rate readings and the sampling times used in calculat ng the Unit 1 vent sample volumes prior to September 1978, had been discarded and any errors in calculating the sample volumes could not be evaluated. As a consequence potential errors of the orde. of 10% of the monthly gaseous releases could not be evaluated.
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+
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/78-18 Report No.
50-320/78-31 50-289 Docket No.
50-320 DPR-50 C
License No. OPR Priority Category B-2 Licensee:
Metropolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19603 Facility Name:
Three Mile Island Nuclear Station, Units 1 & 2 Inspection at: Middletown, Pennsylvania Inspection conducted: October 6,10-12 and 17-19,1978 Inspectors:
ue.
1i
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/./E. Plu,mlee, Radiation Specialist date signed K
- 0. i M
lI/I 3 [7 (
E S.A.Serabian,RadiationSpecialist date signed Approved by g I
- drMh,
/
P. J. KhaMhiet, Radiat1wr wp date signed ~
Section, FF&MS Branch Inspection Summary:
Inspection en October 6,10.12 and 17-19,1978 (Combined Report Nos. 50-289/78-18 and 50-320/78 3,l_)_
Areas Inspectet:
Routine, urannounced inspection by regional based inspectors of radioactive effluent management and personnel exposures in Units 1 and 2, and of the radiation protection pregrOm and the biological shielding surveys in Unit 2 during power ascension.
U p o arrival, areas where work was being con-j ducted were examined to review radiation safety procedures and practices. This inspection involved 84 inspector hours on site by two regional based NRC inspectors.
Results: Of the four areas inspected no items of noncompliance were identified in two areas.
Three items of noncompliance were identified in two areas (Infrac-tion - failure to post and barricade a high radiation area in Unit 2 - Paragraph 4.a; Infraction - failure to conduct a timely survey during decay heat removal in Unit 2 - Paragraph 4.b; and, Deficiency - failure to maintain complete records of effluent sampling in Unit 1 - Paragraph 5).
Region i Form 12 gZ Z 7Cd
)
(Rev. April 77)
DETAILS 1.
Persons Contacted Metropolitan Edison Company (Met-Ed)
M. Bezilla, PORC Secretary, Unit 2 J. Brummer, Lead Instruments and Controls Engineer, Unit 2 J. DeMan, Radiation Protection Foreman, Unit 2
- R. Dubiel, Supervisor of Radiation Proteciian & Chemistry
- J. Floyd, Superintendent of Operations, Un t 2 i
K. Fredericks, Staff Chemist J. Hilbish, Senior Reactor Engineer (PORC Chali. - O F. Huwe, Radiation Protection Foreman, Unit 2
- L. Landry, Radiation Protection Engineer
- J. Logan, Superintendent, Unit 2 R. McCann, Radiation Protection Foreman, Unit 1
- T. Mulleavy, Radiation Protection Supervisor G. Reed, Chemistry Foreman, Unit 2 M. Ross, Supervisor, Station Operations - Nuclear
- J. Seelinger, Superintendent, Technical Support, Unit 2 E. Showalter, Engineer II - Nuclear J. Smith, Radiation Protection Foreman, Radwaste R. Warren, Lead Mechanical Engineer, Unit 2 W. Zewe, Shift Supervisor - Nuclear P. Velez, Radiation Protection Foreman, Unit 1 General Public Utilities Services Corporation (GPUSC)
T. Hawkins, Assistant Test Superintendent W. Pitka, Chemonuclear Engineer (Consultant to GPUSC)
R. Toole, Test Superintendent
- denotes those present during the exit interview at 4:00 p.m.,
October 19, 1978.
2.
Licensee Action on Previous Inspect on Items i
(0 pen) Infraction (289/78-16-01): Inadequate surveys of steam generators resul ting in the failure to provide extremity dosimeters to workers on this job. A;though a licensee reprchentative stated by telephone on June 14, 1578 that further evaluation could be pro-vided to show that extremity dosimeters warc not necescary, the eval-uation was not available for review on this inspection.
3 (Closed) Infraction (289/78-03-02): Failure to self-monitor and to survey a waste container for contamination on removing it from a radioactive contamination area.
Review did not identify any similar items of noncompliance on this inspection.
(0 pen) Inspector follow item (289/78-03-03): Review the computerized record system for personnel dosimetry. The official records are being maintained on forms NRC-4 and NRC-5. A licensee representative stated that the computer records are being used for day-to-day purposes but the program requires corrections. This program processes Unit 1 and Unit 2 personnel exposure records, (0 pen) Inspector follow item (289/76-26-05): Temporary locks and doors.
Review indicated that the replacement of these locks and doors is not completed.
J (0 pen) Inspector follow items (320/78-04-05 and 320/78-19-01):
Review of gaseous waste system preoperational tests and of the evaluation of isokinetic sampling systems.
" Radiation monitoring system (RMS) test atmospheric monitors" has not been accepted by the licensee (TP 360/lA) pending a consultant's report.
No other problems were identified.
(0 pen) Inspector follow item (320/78-19-01): Review gas and liquid monitor preoperational tests.
TP 360/1A, above, remains open. TP 360/1B, liquid monitors, is closed.
Review of records of the one radioactive liquid release tr: Ate did not identify any problems.
(0 pen) Inspector follow item (320/78-19-02): Review the completion of functional tests of the reactor coolant waste evaporator (TP 230/3) and heat tracing (TP 370/1). These tests were incomplete.
(0 pen) Inspector follow item (320/78-19-03): Review of tests to be continued at higher power levels:
TP 500/3 Initial radiochemistry test TP 800/3 Biological shield survey (paragraph 7)
TP 800/35 Effluent systems and effluent monitoring These tests have been performed after reaching 40% reactor power.
Review of these items on this inspection did not identify any items of noncompliance.
Further reviews will be performed after reaching higher power levels.
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4 (0 pen) Inspector follow item (320/78-19-04): Review of the completion of maintenance on the secondary chemistry fume hood system, decontam-ination room floor opening, decontamination room shower, other shower facilities, and a multipoint recorder.
Review indicated that the designated Unit 2 decontamination room hos not been made ready for use.
No other problems were identified.
(Closed) Inspector follow item (320/78-19-05): Review the operability of the Unit 2 liquid waste system.
Review of the records of the single radioactive liquid release made up to the date of the inspection did not identify any uncorrected problems.
3.
Licensee Action on Bulletins a.
Bulletin 78-07, Airline Respirators and Supplied Air Hoods By replies dated August 11 and September 19, 1978, the licensee indicated that replacement regulators for the airline respirators have been ordered.
The licensee representative stated that the delivery of the replacement regulators is expected during January 1979.
The licensee uses administrative controls requiring the present regulators to be used only in the continuous flow mode, pending replacement.
No airline respirator use was observed during this inspection.
Respirator use will be reviewed aoain on a su'osequent routine inspection.
(289/78-BU-07,320-78-BU-07) b.
Bulletin 78-08, Radiation Levels from Fuel Element Transfer Tubes By a reply dated August 15, 1978, the licensee indicated that in Unit 1 the areas around the fuel elenent transfer tube were sealed with concrete block walls prior to commercial operations, and that surveys were performed subsequently to verify the edequacy of the shielding.
Examination of these areas in Unit 1 during full power operation did not identify any problem.
The posting and survey information will be routinely reviewed as feasible during a refueling.
(289/
78-BU-08)
5 Examination of the corresponding areas in Unit 2 showed that wood and metal mesh barricades, some including gates, have been pro-vided rather than concrete block walls. Although key control was in effect it appeared that these barricades could be easily re-moved from the entrances without obtaining a key.
The licensee control of this area will be again reviewed before the first transfer of irradiated fuel.
(320/78-BU-08) 4.
Facility Tour Part of the inspection effort was to tour the facility to examine the posting and control of radiation areas, high radiation areas and con-tamination areas.
a.
High Radiation Areas Technical Specification (TS) section 6.13.1 requires each high radiation area (100 mrem /hr or greater) to be barricaded and conspicuously posted as a high radiation area.
The inspector observed at 3:00 p.m. on Octcoer 6,1978 that although a wood and metal mesh barricade r.nd a high radiation area sign were available there was none controlling access to the Unit 2 reactor coolant drain tank room, elevt. tion 280 ft. The sign was face down on the floor.
Examination stowed that the sign indicated the presence of a high radiation area with up to 350 mrem /hr at contact in this room. The inspector iubsequentl that confirmed there was a high radia: ion area (y made a survey greater than 100 mrem /hr) in the general vicinity of some 55 gallon drums containing orifice rods that were stored in this room. The inspector measured 180 mr/hr at 12 inches from a drum. The area was unattended and neither barricaded nor posted.
The inspector identified this as noncompliance with the require-ments of TS 6.13.1.
(320/78-31-01)
The licensee promptly placed the barricade in the entrance and inserted wooden wedges to secure it in an upright position in the opening. The barricade, which included a padlocked door, was later bolted to the walls. A high radiation area sign was posted on the barricade.
b.
Radiation Areas 10 CFR 20.201(b) " Surveys" requires each licensee to make or cause to be made such surveys as may be necessary for him to comply with
6 i
the regulations in this part.
10 CFR 20.203(b) " Caution signs, labels, signals and controls" requires that each radiation area shall be conspicuously posted, and 10 CFR 20.202(b)(2) states that " Radiation Area" means any area accessible to personnel in which there exists radiation originating in whole or in part within licensed material at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 millirem.
At about 3:20 p.m. on October 6,1978 the inspector identified an unposted radiation area in a corner of the Unit 2 makeup pump room 1C. No posting was evident in the vicinity.
The inspector measured up to 40 mr/hr on contact with a vertical run of pipe, and 10 mr/hr at 12 inches from the pipe. The licensee repre-sentative stated that the pipe was part of the decay heat removal system.
The licensee representative stated that the room had been surveyed earlier in the week and no radiation area was present at that time.
The inspector loted that after a reactor shutdown from 40% power the operation of the decay heat removal system for several hours on October 6, had changed the radiation levels of the system but no survey had bean performed to determine the change in radiation levels and postin] requirements.
The inspector identified this as noncompliance with the require-ments of 10 CFR 20.201(b).
(320/78-31-02)
The licensee promptly initiated survey of the system and also posted the above radiation area.
5.
Process and Effluent Systems and Monitors Part of the inspection effort was to observe the status and the operation of the process and effluent systems and monitors and to review the records of tests and calibrations, and the releases of radioactive effluents.
a.
Release Records Environmental Technical Specification (ETS) section 2.C requires (in part) that gaseous effluents released via the auxiliary and fuel handling building (AFHB) exhaust vent and the reactor building (RB) purge vent be sampled and analyzed.
ETS section 2.C l
7 also requires that records of the results of the sampling and analyses be kept with the sample errors associated with each sample analysis and that the results be reported to the NRC.
The inspector reviewed the licensee's records of the accumulated station vent releases for the month of January 1978 and identified an error in which one day was added in calculating the total ventilation flow for the month through the Unit 1 AFHB exhaust vent. This increased the reported release by about 3%.
The licensee records were sufficient that this error could be evaluated by the inspector.
j Review of records and also a discussion of the vent sampling and analyses performed during January 1978 showed that the licensee had no provision to retain and had, in fact, discarded the sample flow rate readings and the sampling times used to calculate the vent sample volumes through September 1978.
The records were insufficient for an accurate evaluation of any errors in calcu-lating the sample volumes. Reviews by the inspector, and subse-quently by the licensee, showed that if the recorded sample volumes were correct some of the sample flow rates had been unusual (example -
about 1.4 cfm for the RMA8 weekly vent particulate sample counted on January 17, 1978 - sample volume recorded as 3.47 E8 ml.)
Review of recent sample flow rates showed that with a fresh particulate filter the flow rate was typically one cfm and the flow rate typically decreased as time passed.
The inspector did not identify anyone who recalled any readings of as high as 1.4 cfm sample flow rate.
The inspector identified the failure to retain records as noncom-pliance with the requirements of ETS section 2.C.
(289/78-18-01)
The inspector noted that the reported gaseous releases were far j
below the quarterly and annual release limits and the substitution of typical sample flow rates and sample volumes for the identified unusual values (above) would not have increased the reported total releases by greater than 10% for the month of January 1978, and l
l no item of noncompliance with release limits was indicated.
l b.
Licensee Reports The inspector reviewed selected information contained in the licensee semiannual reports of effluents for the periods July 1 through December 31, 1977, and January 1 through June 30, 1978 and contained in the licensee environmental monitoring report for the period l
January 1 through December 31, 1977.
8 A comparison of samples of the reported information with the licensee worksheets that were used to compile the reports and with on site records of releases, sampling and analyses did not identify any problems with reported liquid releases and did not identify any potentially large errors with gaseous releases as described abcve.
i The inspector had no further questions in this area at this time.
c.
Status of Equipment The inspector observed the status and operation of equipment and interviewed several individuals involved in servicing, operating, testing, evaluating, or other responsibilities for equipment. The inspector reviewed test and surveillance records.
The Unit 2 reactor coolant evaporator was not yet in service. No problem was reported in processing Unit 2 reactor coolant through the Unit 1 evaporator.
Licensee representatives stated that the following modifications are scheduled in Unit 2 equipment which neither involve require-ments of the Technical Specifications nor the unreviewed safety items.
(1) Charcoal filter replacement (to upgrade to currently available material).
(2) Dampers (3) replacement in Auxiliary Building and Fuel Handling Buildinq Ventilation (to achieve rero leakage).
(3)
Installation of additional test and injection ports at ventilation filters.
(4)
Replacement of the water pretreatment chemical additive pump WTP-1.
(5) Replacement of the hotwell sample pumps.
Instrument surveillance and calibration information is reviewed in paragraph 6.
The inspector had no further questions in this area of the inspection at this time.
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9 6.
Instrument Source Checks, Surveillance and Calibrations Part of the inspection effort was to review the licensee's performance of the instrument source checks, surveillance and calibrations re-quired by the Technical Specifications and to verify that the instru-ments described in the FSAR were operable.
No overdue or omitted calibrations were identified, however, the inspector noted there were maintenance problems.
Review of the records of 20 of the quarterly calibrations performed during July 1978 on Unit 1 instruments showed that 14 (i.e. 70% of those reviewed) were out of calibration in some respect, as found.
The following eight instruments, as found, had given indications that failed the + 15% calibration requirement of the licensee calibration procedures at one or more of the calibration points: RMG-1, -2,
-3,
-4, -11, -13, and -14, and RMA-2.
The following six instruments, as found, had failed the alert or the alarm trip level requirement (one or both) even though the instrument indications were within the l
calibration requirements: RMA-4, -5G, -6 and -7, and RML-2 and -3.
The inspector noted on October 10, 1978 that control room console audible annunication was bypassed with respect to the following 12 Unit 2 instruments, apparently to avoid constantly recurring annuncia-tion.
Those instruments denoted by an asterisk (*) were also suppressed on October 19, 1978: HPR-209*, -210*, -215*, -219*, -220*, -221*,
-222*, -225*, -226*, -227, -228, and -229.
The following five instru-ments were tagged out of service on October 10, 1978: HPR-220, -229, and -3238, and WDGR-1485 and -1486.
The inspector noted that instrument servicing was evident during the inspection.
This item will be followed up on a subsequent routine inspection.
(289/78-18-02) (320/78-31-03) l i
Review did not indicate any items of noncompliance with requirements of the Technical Specifications.
(seeExitInterview, paragraph 11) l 7.
Shield Surveys l
Part of the inspection effort was to review, observe, and perform confirmatory shield surveys in Unit 2 to detennine that the design ob-jectives given in the FSAR are met.
One of these objectives is that the dose rate at the exposed outer surface of containment is less than 0.5 mrem /hr.
1 10 The inspector noted that no measurements had bsan made on top of or high on the Unit 2 containment structure and no record was found during the inspection of any corresponding measurements at Unit 1.
The licensee representative stated, at the exit interview, that such measurements will be made prior to allowing personnel access on the dome for tendon surveillance during reactor operation.
(289/78-18-04) (320/78-31-04)
The inspector noted that some of the radiation measurements inside i
the Unit 2 containment at 40% power were about as great as the corres-ponding measurements in Unit 1 at 100% power.
The licensee representative stated that the points selected at Unit 2 might not exactly duplicate those used for the shield survey in Unit 1, and any substantial differences at 100% power would be evaluated.
Confirmatory surveys inside containment did not identify any discrep-ancies in the survey records.
The inspector noted that reasonable i
correlation with reactor power level was found in the highest measure-ments made in each reactor. This was on the operating floor at the edge of the reactor cavity. At 40% power in Unit 2 the total of the neutron and gamma radiation dose rate was about 2 rem /hr, as compared l
to 6 rem /hr in Unit 1 at 100% power.
No items of noncompliance were identified and the inspector had no further questions in this area at this time. Scheduled measurements at 75% and 100% power in Unit 2 will be reviewed on a subsequent routine inspection.
8.
Dosimetry practices The inspector reviewed the licensee's personnel dosimetry practices to determine compliance with the requirements of 10 CFR 20.202
" Personnel Monitoring" and with the licensee's Radiation Protection Manual, Section 2 " Monitoring Practices." The inspector noted that weekly or more frequent entries are made into containment for such purposes as snubber surveillance and inspection of valves. Wherever the licensee neutron rem-meter detected a neutron dose rate (i.e. greater than twice the background of the instrument) inside containment the dose i
rate due to neutrons was about twice that due to gamma radiation. The inspector made confirmatory surveys inside containment.
i The licensee issues neutron film badges to each individual entering i
containment during reactor operation or handling any neutron sources.
During 1977 this ranged from 41 to 190 neutron badges during a single l
1 1
11 badge period. There were 38 or more neutron badges issued each badge period during the period January to September 1978. Review of records showed that none of these badges were reported to exceed the minimum detectible exposure. Badge service documentation indicated that 10 mrem thernal neutron or 20 mrem fast neutron exposure was the minimum detectible level.
l The licensee representative stated that neutron film badges will be exposed to the neutrons in containment to determine their response.
Any work that might lead to significant exposures of personnel to neutrons will be evaluated on the basis of stay-time and any signifi-cant doses will be entered in the individual's records.
The licensee representative stated that this has not been necessary to date.
1 The inspector had no further questions on this item at this time.
Licensee badge performance will be followed up on subsequent routine inspections.
(289/78-18-03)
No items of' noncompliance were identified.
9.
Review of Plant Procedures, Policies, and Staffing for Radiation Protection Review of the Unit 2 radiation protection program did not identify any changes from or discrepancies with the description in the FSAR or with the practices and policies previously ~ established at Unit 1.
Review of the instrument calibration records, routine surveillance records, survey records, and test procedures did not identify any failures to carry out scheduled requirements.
One senior radiation protection technician had been promoted to the foreman level and there are now two foremen at each unit.
No items of noncompliance were identified.
10.
Radioactive Waste Management Review of the Unit 2 radioactive waste system tests and operations did not identify any required tests for which the licensee had not provided.
The licensee reviews and evaluations of these tests appeared to be carried out in compliance with the requirements of the Technical Specifications and the FSAR description.
1
)
l r-12 Review of Unit I radioactive waste system operations during the period November 1,1977, to October 12, 1978, did not identify any failures to make the required reports or any releases exceeding regulatory limits.
No items of noncompliance involving radioactive waste system operations were identified.
11.
Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection.
The inspector reviewed the scope and findings of the inspection.
The inspector reviewed the maintenance history of several instruments.
The inspector stated that the number of instruments bypassed to suppress the audible annunciation in the Unit 2 control room, and the frequency that instruments were found out of calibration in Unit 1, appeared to indicate a need for a licensee review of instrument servicing requirements.
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