ML19345D993
| ML19345D993 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/26/1980 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Arnold R METROPOLITAN EDISON CO. |
| Shared Package | |
| ML19345D994 | List: |
| References | |
| NUDOCS 8012220338 | |
| Download: ML19345D993 (5) | |
See also: IR 05000289/1980022
Text
-
_
_,
UNITED STATES
targ
(
je
NUCLEAR REGULATORY COMMISSION
- Ug*y
g
,
,, s . ,,f
-
eq
g
REoloN 1
'"
,
,'
.l
631 PARK AVENUE
8, ' ,
4
KING OF PWSSI A. PENN5Yt.V ANI A 19404
\\.
..
Navi23 W
Docket No. 50-289
m31EUT10H SERVICES,,
C3M!Cil ' ' ~~
Metropolitan Edison Company
ATTN:
Mr. R. C. Arnold
Senior Vice President
100 Interpace Parkway
Parsippany, New Jersey 07054
Gentlemen:
Subject:
Health Physics Evaluation
The NRC has identified a need for licensees to strengthen the health physics
programs at nuclear power plants and has undertaken a significant effort to
assure that action is taken in this regard.
As a first step in this effort,
the Office of Inspection and Enforcement is conducting special team appraisals
of the health physics programs at all operating power reactor sites, which
include the health physics aspects of radioactive waste management and onsite
The objectives of these appraisals are to evaluate
the overall adequacy and effectiveness of the total health physics program at
each site and to identify areas of weakness that need to be strengthened.
During the period of July 28 - August 8, 1980, the NRC conducted a special
evaluation of the health physics program at Unit 1 of the Three Mile Island
(TMI) Nuclear Station.
The major portion of this evaluation was conducted
using the same appraisal techniques and acceptance criteria for the
same areas as are being used in the conduct of the special team appraisals at
operating power reactors throughout the country.
Two additional areas were
included in the TMI evaluation which are not addressed in the special team
appraisals at operating power reactors.
The two additional areas reviewed
were: 1) your actions to correct itees of noncompliance brought to your attentien
as a result of the investigation into Parch 28, 1979 accident, the findings of
which were documented in NUREG 0600, " Investigation in'.
the March 28, 1979
Three Mile Island Accident By Office of Inspection aad Enforcement"; and 2)
verification of your implementation of recommendations contained in NUREG-0578,
"TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations".
Because of these differences, the term " evaluation" is used to distinguish it
from the special team appraisals conducted at operating reactors.
l
1
Specific areas examined during this special evaluation are described in the
I
enclosed report (50-289/80-22).
Within these areas, the evaluation team
reviewed selected procedures and representative records, observed work practices,
l
l
EU122203 %
f
-
_ _ _ _
___ _ _ _ _ - _ _ _ _ - _ _ _ _ . _ _ _ _ .
-.
__
__ a
r
.
Metropolitan Edison Company
2
NOV 2 5 im
.
and interviewed personnel.
The evaluation findings are discussed in detail in
the enclosed report.
Based on the findings, the Evaluation Team reached the overall conclusion that
the Unit 1 aspects of the health physics program are adequate to support the
present level of activities, but there are a number of significant weaknesses
which must be corrected to provide reasonabir assurance that the program will
be adequate during operation and major outages.
The significant weaknesses
included the following:
'
There was a lack of effective management oversight in assuring that the
1.
radiological controls, training and radioactive waste organizations were
clearly defined, that personnel were properly selected, qualified and
assigned responsibilities for staffing these organizations, and that
assigned responsibilities were being carried out,
i
2.
The exposure control program contained discrepancies between Unit 1 and
Unit 2 indirect bioassay procedures, exhibited inadequacies in several
calibration procedures, lacked action levels for issuance of special
,
monitoring devices, exhibited shortcomings in the maintenance of respiratory
"
protection equipment and had an established quality assurance program
whien failed to include all monitoring devices and contractor-supplied
biosssay services.
3.
The solid radwaste shipping program lacked key elements for ensuring the
proper use of shipping containers and implementat;on of the attendant QA
requirements.
4.
There were incomplete and conflicting actions in reic; ion to resolution
of NUREG-0578 items.
Withi7 the portion of the evaluation related to implementation of the Unit 1
dr: it proposed NUREG 0654 Emergency Plan, the Evaluation Team concluded that
significant weaknesses included the following:
1.
The lack of clear assignment of individuals to the functional areas of
emergency activity;
2.
Failure to have a clearly defined program for training individuals who
may be assigned emergency duties;
3.
Procedures which implemsnt the emergency plan were incomplete, overly
general, and exhibited omissions of key elements; and
l
r
l
t
-
Metropolitan Edison Company
3
NOV 2 61330
4.
There were fac. ity and equipment shortcomings in relation to the Emergency
Operations Facilit;
Environmental Assessment Center, and reactor building
evacuation alarm.
Subsequent to ..w exit interview on August 8, 1980, various meetings were held
with you and members of your staff to discuss the preliminary findings of the
health physics evaluation.
During these meetings, additional information and
preliminary responses were provided by Metropolitan Edison Company in reply to
the preliminary findings identified by the Health Physics Evaluation Team.
The additional information and preliminary responses provided were reviewed
and considered by the Evaluation Team in completing their overall evaluation
of the Three Mile Island Unit 1 health physics program.
We recognize that, as
a result of these discussions, action to resolve the significant weaknesses
has been initiated and, in many cases, may have been completed by this time.
Our verification of your corrective action will await your formal response to
the request in the following paragraph.
After receiving your response, all
information supplied will be reviewed for its implementation during subsequent
inspections.
The significant weaknesses identified must be resolved prior to restart of
Unit 1.
Items identified as significant weaknesses which must be resolved
were selected in a manner consistent with that used in selecting significant
weaknesses which must be corrrected at operating power reactors where special
team appraisals have been conducted.
It is requested that you carefully
review the 57 items identified as necessitating resolution prior to restart
for consideration in effecting improvements in the health physics and emergency
planning programs.
We recognize that an explicit regulatory requirement
pertaining to each significant weakness identified may not currently exist.
However, to determine whether adequate protection will be provided for the
health and safety of workers and the public, you are requested to submit a
written statement within twenty (20) days of your receipt of this letter,
describing your corrective action for each of the items requiring resolution
prior to restart which are identified in the enclosed report including:
(1)
steps which have been taken; (2) steps which will be taken; and (3) a schedule
for completion of action.
This request is made pursuant to Section 50.54(f)
I
of Part 50, Title 10, Code of Federal Regulations.
We note that a number of the significant weaknesses identified are also applicable
to Unit 2 because many of the findings for Unit 1 are based on the direct
support which elements of the Unit 2 radiological controls and radwaste organizations
provide to Unit 1.
This matter will be the subject of separate correspondence
with respect to Unit 2.
l
.
e
Metropolitan Edison Company
4
El 2 6 W
Ouring this evaluation, it was also found that certain of your activities did
not appear to have been conducted in full compliance with NRC requirements, as
set forth in the Notice of Violation enclosed herewith as Appendix A.
The
items of noncompliance in Appendix A have been categorized into the levels of
severity as described in our Criteria for Enforcement Action dated December
31, 1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations,
requires you to submit to *hi: office, within twenty (20) days of your receipt
of this notice, a written sr.<.r. ment or explanation in reply including:
(1)
corrective steps which have been taken by you and the results achieved; (2)
corrective sters which will be taken to avcid further items of noncompliance;
and (3) the date when full compliance will be achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Titia 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 within five (5) days to this
office to withhold such information from public disclosure.
Any such applica-
tion must be accompanied by an affidavit executed.by the owner of the informa-
tion, 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 Commission 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 this regard within the specified period, the report will be placed
in the Public Document Room.
Should you have any questions concerning this evaluation, we will be pleased
to discuss them with you.
Sincerely,
f
Y
.f',30
[lW /
R
,
B
e H. Grier
Director
Enclosures:
1.
Appendix A, Notice of Violation
2.
Office of Inspection and Enforcement Evaluation Report Number
50-289/80-22
.
---w--a
,
- . , .
_ , , _ _ , , _ , .
_
._. -
_
.
.
_
-__.
.
Metropolitan Edison Company
5
NOV 2 6120
!>
cc w/encis:
H. D. Hukill, Director, TMI-1
J. G. Herbein, Director - Nuclear Assurance
R. J. Toole, Manager, Unit 1
J. J. Colitz, Manager, Plant Engineering, Unit 1
L. W. Harding, Supervisor of Licensing
R. F. Wilson, Director - Technical Functions
E. G. Wallace, Licensing Manager
I. R. Finfrock, Jr.
R. W. Conrad
J. B. Lieberman, Esquire
G. F. Trowbridge, Esquire
G. K. Hovey, Director, Unit 2
J. J. Barton, Manager Site Operations, Unit 2
B. Elam, Manager, Plant Engineering, Unit 2
R. W. Heward, Director, Radiclogical and Environmental Controls
W. E. Potts, Manager, Radiological Controls, Unit 1
J. W. Brasher, Manager, Radiological Controls, Unit 2
Ms. Mary V. Southard, Chairperson, Citizens for a Safe Environment
G. Giangi, Emergency Planning Coordinator, TMI
_
.
.
.
--