ML20010A173
| ML20010A173 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/16/1981 |
| From: | Hovey G METROPOLITAN EDISON CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20010A172 | List: |
| References | |
| LL2-81-0165, LL2-81-165, NUDOCS 8108110140 | |
| Download: ML20010A173 (4) | |
Text
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Metropolitan Edison Company a
Post Office Box 480 Middletown, Pennsylvania 17057 Wnter's Direct Dial Number June 14 1981 LL2-81-0165 Office of Inspection and Er.forcement Attn:
Mr. B. H. Grier, Director Region I U. S. Nuclear Regulatory Commission
- 231 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Niiclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 80-18 This is in response to the subject Inspection Report issued May 6, 1981, and is being submitted in accordance with our letter of May 29, 1981 (LL2-81-0153).
Item A Apparent Infraction Contrary to 10 CFR 19.12 " Instructions to Workers" on October 6, 1980, personnel entering the Three Mile Island Unit 2 fuel handling building north make-up valve room were not informed of high beta radiation fields associated with leaking valves of the make-up system. Also, personnel were not instructed on which areas in the make-up valve room should be avoided due to existing high beta and gamma radiation fields.
Response
A critique of the personnel entry into the Make-Up Valve Room was conducted on October 7, 1980. The Senior Vice President of Metropolitan Edison Compamy requested the Radiological Control Director to conduct inquiry into l
the matter and issue a report indicating what happened and what should have happened. This report was issued i
on November 3, 1980. He also requested that a memo discussing the special beta radiation situation in Unit II
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be prepared and issued for review with Unit II radiological workers. This memo was issued on October 20, 1980 and personnel briefings commenced following issuance of the memo.
8108110140 910731 PDR ADOCK 05000320 0
PDR Metropohtan Ed: son Company is a Memner of the General Pubhc Utint es System t
LL2-81-0165 Mr. B. H. Grier The Radiological Controls Director also issued instructions to the Radiological Training Section to review the special beta situation in Unit II with all Radiological Controls technicians and to include this training in all new techni-These actions were completed on December 1, cian training.
1980.
In regard to the adequacy of personnels' knowledge of the job via briefings, with che issuance of the entry critique, on November 3, 1980, the problems associated with this entry were given wide distribution within the Operating and Rad.
This distribution presented the oppor-Con. organizations.
tunity to reinforce the concept of ensuring that personnel In January 1981, the understand the job to be performed.
issuance of RCP4045, " Radiological Review of Work Instructions,"
with its extensive preplanning requirements added additional opportunity to impart an adequate briefing of personnel.
Briefing of personnel prior to work evaluation is presently required by Administrative Procedure 1060.
It requires review of both the applicable work package in addition to radiological conditions.
Item B Apparent Infraction Contrary to 10 CFR 20.201(b), on October 6, 1980, beta radia-tion surveys, adequate to assure compliance with the regulatory limits of 10 CFR 20.101, were not performed by personnel enter-ing the Three Mile Island Unit 2 fuel handling building north make-up valve room.
l l
Response
is correct that beta surveys were not performed in the It north Make-Up Valve Room; hcwever, this was contrary toThe instructions on the RWP which required beta surveys.Radiation technician failed to carry out this instruction.
surveys were also required by existing procedures as well.
The technicians was counselled on the need for RWP compliance.
i i
j Item C foparent Infracticn f
" Contrary to the above requirement, on October 6, 1980, personnel l
entered the north Make-Up Valve Room under RWP 80B-5194 and entered areas with significantly higher radiation levels than l
One of the individuals entered the south valve stated on the RWP.
room which was not authorized by the RWP.
Changes to the RWP were not made and approved as required, prior to personnel entry into the south Make-Up Valve Room, or prior to personnel j'
entry into higher radiation levels than those specified on the RWP for entry into the north Make-Up Valve Room.
a
1 f.
Mr. B. H. Grier LL2-81-0165
Response
It is clear that the exposure rates established on the Radiation Work Permit (RWP) did not cover entry into the higher radiation level areas that were entered. The exposure rates established on the entry RWP were set for entry to the portion of the room originally intended for entry. It was well known that exposure rates in the areas subsequently entered inadvertently were much higher than those established on the RWP.
Three Mile Island has written procedures covering " access control to radiation areas including a Radiation Work Permit system." This procedure ucs utilized for entry into the Make-Up Valve Room. As previously noted, the RWP conditions were established for entry into a pre-
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selected area of the Make-Up Valve Room from which it was intended by engineering personnel that pictures be taken.
Immediately upon reviewing the results of the survey data and the pictures obtained on the entry, it was obvious to engineering personnel that the entry personnel had entered an unauthorized area of the Make-Up Valve Room. Therefore, the RWP in use at the time was expired.
The actions noted above for items A and B have been adequate to prevent problems of this nature from recurring since that time and are considered adequate to prevent further iteas of noncompliance.
Item D Apparent Infraction
" Contrary to the above, as of October 6, 1980, certain of the Radiological Controls Department's requirements for entry to a certain group of high radiation areas were not prescribed by documented instructions or procedures. These requirements included obtaining the radiological controls manager's approval for entry and performing an As Low As Reasonably Achievable (ALARA) review prior to entry. The areas to which the entry requirements applied were also not prescribed in documented instructiens or procedures."
?,
o Mr. B. H. Grier 'LL2-81-0165
Response
10CFR 50 Appendix B requires the establishment of.a Quality Assurance (QA) Plan including documented procedures.. The Recovery QA Plan, approved by t'Te NRC, includes identification of radiological control procedures. These procedures have been adequately documented, therefore, the 10CFR 50 Appendix B requirements have been satisfied. In addition, verbal request -
may be issued which supplement these procedures, but they need not be reduced to written form when the procedures are felt to be adequate. These verbal instructions are intended to give additional emphasis to the procedures. This was the case regarding the additional requirements for entries. For the above reasons,-we do not believe that this is an item of noncompliance.
For your information, the verbal direction existing prior to October 1, 1980 was supplemented by memos of October 1 and October 8, 1980 delineating additional information required in order to obtain entry. approval of the Manager, Radiological.
Controls, to certain high radiation areas.
On April 22, 1981, the above referrenced requirements were replaced by a standing Order.
Sincerely, jG'
<a G. K. Hovey Vice-President and Director, TMI-2 GKH:SDC:djb i
cc:
L. H. Barrett, Deputy Program Director Dr. B. J. Snyder, Program Director, TMI Program Office t
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