ML19352A012
| ML19352A012 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/01/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19351G574 | List: |
| References | |
| 50-289-80-02, 50-289-80-2, 50-320-80-02, 50-320-80-2, NUDOCS 8102250410 | |
| Download: ML19352A012 (3) | |
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APPENDIX A NOTICE OF VIOLATION Metropolitan Edison Company Docket No. 50-320 Based on the results of an NRC inspection conducted on February 1 - March 16,1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Facility License No. DPR-73 as indicated below.
These items are infactions.
A.
10 CFR 50, Appendix B, Criterion V states in part:
" Activities affecting quality shall be prescribed by documented instruction procedures...." The Three Mile Island FSAR (the approved Quality Assurance Plan) Section 17.2.7 states in part:
" Met-Ed will comply with... Regulatory Guide 1.8 (March 1971)...." Regulatory Guide 1.8 references ANSI 18.1, 1971, and ANSI 18.1, 1971, paragraph 5.4 states in part:
"All persons regularly employed in the nuclear power plant shall be trained in... appropriate plans and procedures Temporary maintenance and service personnel shall also be trained in the above area... to the extent necessary to assure safe execution of their duties."
Contrary to the above as of February 13, 1980, a vendor individual whose duty it was to implement various licensee procedures was not formally and adequately trained in the administrative controls for procedural implementation. This lack of training resulted in the incorrect implementation on February 12-13, 1980, of Station Health Physics Procedure 1631.2, Sampling of Reactor Building (Unit #2 only),
Revision 5, October 30, 1979. The following was noted:
The vendor individual operated the reactor building air sampling system with a draft version of a proposed revision (Revision 6) to 1631.2 in lieu of Revision 5 to 1631.2 which was the correct revision in effect at that time.
The standardized recirculation time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the reactor l
containment gas sample (paragraph 5.4 of 1631.2) was exceeded from 1 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> without a change to the procedure being j
properly documented, reviewed, and approved.
1 The effluent noble gas monitor for the auxiliary building i
supplemental fan system indicated effluent activity 3 times the reading prior to sampling with no termination of sampling as required by paragraph 5.4.8.1 of 1631.2.
B.
The Order for_ Modification of License dated July 20, 1979, states in part:
... pending further amendment of the Facility Operating License, the licensee shall maintain the facility in a shutdown i
condition in accordance with.the approved operating and contingency procedures for the facility...." The order was extended by the
" Notice of Delay in Issuance of Order for Modification of License for Three Mile Island, Unit 2" on August 20, 1979, and September 20, 1979.
B10 2250[
2 TechnicalSpecifications[,datedFebruary 11,1980, TS 6.8.1 states in part:
" Written procedures shall... be implemented... covering
... recovery mode implementation... procedures... which... alter the distribution or processing of significant quantities of stored radioactivity or radioactivity being released through known flow paths."
Contrary to the above, on various dates noted below, the control room operators failed to properly implement virious aspects of Station Health Physics Procedure 1631.2, Sampiing of Reactor Building (Unit #2 only), Revision 5, October 30, 1979, as follows:
On January 15-16, 30, February 6 and 12-13, 1980, the standardized recirculation time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (paragraph 5.4 of 1631.2) was exceeded from 1 to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />.
On January 30 and February 6, 1980, the effluent noble gas monitor for the auxiliary building supplemental fan system indicated effluent activity 3 times the reading prior to sampling with no termination of sampling as required by paragraph 5.4.8.1 of 1631.2.
C.
10 CFR 20.103, " Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas," states, in part in Section (a)(3), "For Purposes of determining compliance with the
. requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas...."
Contrary to the above, on FebrJary 11, 1980, suitable measurements of concentrations of radioactive materials in air were not made when members of an Emergency Repair Team entered into an airborne radioactive material area inside Make-up Pump Room 18 at Unit 2.
No air sample was taken from inside the room (which was under a negative pressure at the time). An air sample taken in the labyrinth outside_the room indicated an airborne radioactivity concentration on the order of 10-7 uCi/ml.
D.
10 CFR 20.203, " Caution si specifies in paragraph (b)gns, labels, signals and controls" that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words:
CAUTION RADIATION AREA 10 CFR 20.202 defines a radiation area as, "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, or in any 5 consecutive days a dose in excess of 100 millirem.
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3 Contrary to the above, on February 2,1980, a radiation area located at the outside north end of the EPICOR I processing building was accessible to personnel and emanated whole body gamma dose rates of 7 to 10 millirem /hr and was not posted.
These radiation levels were caused by licensed radioactive material reading 90 millirem /hr on contact, which was stored inside the EpICOR I processing building, directly adjacent to the inner building wall.
E.
10 CFR 20.201(b) requires that each licensee shall make or cause to be made such surveys as may be necessary for him to canply with the regulations in this part.
10 CFR 20.201(a) defines " survey" as an evaluation of radiation hazards including a physical survey and measurements of level of radiation or concentrations of radioactive material present. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentration of radioactive material present.
10 CFR 20.103.a.(3) requires for purposes of determining compliance with the requirements of this section the licensee shall use suitable measure-ments of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
Contrary to the above, the licensee did not make adequate surveys of airborne radioactive materials in the Unit 2 fuel handling building at the spent fuel pool during the period February 17-20, 1980, and February 22-26, 1980, in that neither measurements of airborne tritium nor measurements of radioactivity excreted from the body were made.
Airborne tritium was identified in surveys on February 16 and February 21.
During this period individuals were present periodically in the area and exposed to unknown concentrations of airborne tritium.
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