ML20010D041
| ML20010D041 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/06/1981 |
| From: | Barley W, Neely D, Shanbaky M, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20010D012 | List: |
| References | |
| 50-289-81-07, 50-289-81-7, NUDOCS 8108210397 | |
| Download: ML20010D041 (40) | |
See also: IR 05000289/1981007
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-289/81-07
1
Docket No.
50-289
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License No.
Priority
Category
C
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Licensee :
Metropolitan Edison Company
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P. O. Box 480
Middletown, Pennsylvania 17057
Facility Name:
Three Mile Island Nuclear Station, Unit 1
Inspection At:
Middl.etown, Pennsylvania
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Inspectiois Conduc ed: April .la
May 2,1981
6h/
Ins pectors.;
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D. R. Neefy, Inspection Specialist (Team Le ider)
/ date
N" ll0n
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M. M! Shanbaky, Senpr Radiation Specialis',
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W,.]. Barl ey,' Rad tiop$pecialist
date
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Approved by:
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Eme gency/h, Di' rector, Division of
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Preparedness & Operational Support
Inspection Summary:
Inspection on April 13 - May 2,1981
(Inspection Report No 50-289/81-07)
Areas Inspected: Special, announced inspection of the Unit I radiation protection
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and radwaste programs and those elements of the Unit 2 radiologica'. controls and
radwaste program which provide direct support to Unit 1.
This inspection was
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limited to the verification of the licensee's implementation of corrective actions
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taken as a result of the signifit. ant. weaknesses and items of noncompliance identi-
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fied in Health Physics Evaluation (HPE) Report No. 50-289/80-22 (also discussed in
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NUREG 0680 Supplement 1); items of noncomoiiance identified in NUREG 0600,
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Investigation into the March 28, 1979 Three Mile Island Accident by Office of
Inspection and Enforcement; certain IE Circulars and Bulletins and other pre-
4
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viously identified items of noncompliance, unresolved items or inspector follow-up
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items.
The inspection involved 456 inspection hours by two NRC FMI resident
inspectors and one regionally based (Performance Appraisal Section) NRC inspector.
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Results: Twenty seven significant program weaknesses identified in HPE Report
3
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No. 50-289/80-22 were reviewed by the inspection team, of which 25 items were found
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to be satisfactorily corrected; seven items of noncomplianc, previously identi-
fled as a result of the March 28, 1979 accident at Unit 2 (NUREG 0600), for which
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corrective actions were also requimd of Unit 1 to address the generic problems
associated with these items, were examined ahi found to be adequately corrected
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as to the routine radiological operations; and, licensee actions on one IE Circular
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and one IE Bulletin were examined and found adequate.
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DETAILS
1.
Persons Contacted
E. Fuhrer, Radwaste Operations Manager, TMI-1
J. Barton, Director, Site Operations, TMI-2
C. De' tete, Manager, Radwaste Process Support
S Presgrove, Edpervisor Process Support (NUS Corp.)
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J. Hess, Radioactive Material Coordinator (NSS)
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R. Knief, Manager, Pic.nt Training
N. Brown, Supervisor, Licensed Operator Training
R. Zechman, Supervisor, Tachnician Training
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- W. Potts, Manager, Radiological Controls, TMI-1
J. Kuehn, Deputy Manager, Radiological Controls, TMI-1
R. Jubiel, Radiological Engineering Manager, TMI-1
- J. Brasher, Radiological Controls Director, TMI-2
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J. Hildebrand, Manager, Radiological Health, TMI-2
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R. Perry, Dosimetry, Bioassay and Whole Body Count, Manager
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T. Mulleavy, Radiological Training Manager, TMI-2
F. Grice, Senior Project Coordinator, TMI-2
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D. Reppert, Radiological Engineer (Corporate)
.
H. Hukill, Jr. , Vice President and Director, TMI-1
)'
W. Zewe, Shift Supervisor, TMI-1
R. rieward, Jr., Vice President - Radiological and Environmental
Controls
- L. Harding, Supervisor TMI-l Licensing
NRC Personnel at Exit Interview (Other Than Inspection Team Members)
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R. Cor te, Senior Resident Inspector, TMI-2
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- denotes those present at the exit interview at the Three Mile
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Island Section on May 12, 1981.
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The inspectors also held discussions with and interviewed other
licensee and contractor employees.
They included engineering,
operations, training and radiological controls personnel.
2.
Significant Program Weaknesses and Items of Noncompliance
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During the Health Physics Evaluat'on conducted July 28 through
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August 8,1980 at Three Mile Island Unit 1, the following significant
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findings were identified for resolution prior to resumption of
facility operation.
In addition, five items of noncompliance were
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identified as a result of this special evaluation.
These items
were reported in the HP Evaluation Report No. 50-289/80-22 and
4
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reiterated in NUREG 0680 (a detailed discussion of each item is
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provided in the previously mentioned documents).
The inspection
team examined the licensee's corrective actions as suomitted to the
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NRC in letters dated December 16, 1980, December 30, 1980, February 1981,
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and February 27, 1981.
In addition, the status of implementation
of these corrective actions was also inspected.
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Significant Finding No. 50-289/80-22 01
of the interfaces of the Unit 1 Radiological Controls
P~
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t and radwaste cperations functions with those elements
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,...t 2 which support Unit 1.
Statement in Reply to Significant Evaluation Finding
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The following GPU/ Met-Ed management documents will be developed
in response to this item:
GPU Nuclear Group Organization Plan
Personnel Charts
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Department Organization Plans (Radiological Controls)
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Program Organization Responsibility Document for Radwaste
Position Specifications
P)sition Descriptions
Baseo on examination of the licensee's stated corrective
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actions, discussions with licensee representatives, and
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examination of selective radiological operations and procedures,
+he inspection team determined that adequate corrective actions
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were completed for this item. This item is considered closed.
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b.
Significant Finding No. 50-289/80-22-02
Definition of the Unit 1 Training Department organizational
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structure down to and including the instructor level.
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Statement in Reply to Significant Evaluation Finding
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The following GPU/Med-Ed management documents will be developed
in response to this item:
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GPU Nuclear Group Organization Plan
Department Organization Plans (Radiological Controls)
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Personnel Chart
Training Department Administrative Manual
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Based on examinatica of the licensee's stated corrective
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actions, discussions with sicensee representatives, and
axamination of sele .ive radiological operations and procedures,
the inspection team determined that adequate corrective actions
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were completed for this ' tem.
This item is considered closed.
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c.
Significant Finding No. 50-289/80-22-04
Definition of the Unit 2 Radiological Controls Department
organizational structure down to and including the non-supervisory
level and reflecting organizational interfaces with che Unit 1
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radiological controls program.
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Statement in Reply to Significant Evaluation Finding -
- The following GPU/ Met-Ed management documents will be developed
in response to this item:
GPU Nuclear Group Organization Plan
i
Department Organization Plans (Radiological Controls)
Personnel Charts
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
'
inspection team determined that adequate corrective actions
j.
were completed for this item. This item is considered closed.
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Significant Finding No. 50-289/80-22-05
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Definition of the Unit 2 radioactive waste organizational
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structure down to and including the non-supervisory level and
reflecting org?pizational interfaces with the Unit 1 program.
Statement in Reply to Significant Evaluation Finding
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The following GPU/ Met-Ed management documents will be developed
in response to this item
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GPU Nuclear Group Organization Plan
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Personnel Charts
Program Organization Responsibility Document for Radwaste
by February 28, 1981
Department Organization Plans (Radiological Controls)
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Based on examination of the licensee's stated corrective
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actions, discussions with licensee representatives, and examination
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of selective radiological operations and procedures, the
inspection team determinad that adequate corrective actions
were completed for this item. This item is con.3idered closed.
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e.
Significant Finding No. 50-289/80-22-06
Develop.;.ent of job descriptions for positions in the TMI-1
Radiological Controls Department.
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Statement in Reply to Significant Evaluation Finding
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The following GPU/ Met-Ed management documents will be developed
in response to this item:
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GPU Nuclear Group Organization Plan
Personnel Charts
Program Organization Responsibility Document for Radwaste
Position Descriptions
Position Spacifications
In addition, revised job descriptions are being negotiated for
technicci positions.
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Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspecticn team determined that a fequate corrective actions
were completed for this item.
This item is considered closed.
f.
Significant Finding No. 50-289/80-22-08
Definition of the respor.siblities and functions to be performed
by the corporate element of the Radiological fontrols Department.
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Statement in Reply to Significant Evaluation Finding
The following GPU/ Met-Ed management documents will be developed
in response to this item:
GPU Nuclear Group Organization Plan
Department Organization Plan (Corporate Radiological
Controls)
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and p.aocedures, the
inspection team determined that adequate corrective actions
were completed for this item. This item is considered closed.
g.
Significant Finding No. 50-289/80-22-10
Development and implementation of staffing plans to ensure
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that the responsibilities cad functions assigned to the corporate
element of the Radiological Controls Department can be performed.
Statement in Reply to_Significant Evaluation Finding
The following GPU/ Met-Ed managemen' documents will be developed
in response to this item-
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GPU Nuclear Group Organization Plan
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Personnel Charts
Department Organization Plan (Corporata Radiological
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Controls)
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Based on examination nf the licensee's stated corrective
actions, discussion; with licensee representatives, and
examination of selective radiological operations and procedures,
the inspection teain determined that adequate corrective actions
were completed for this item.
This item is considered closed.
h.
Significant Finding No. 50-289/80-22-11_
Review of the adequacy of the implementation of the management
and managerial functions in relation to the raoiological
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controls program at the TMI site by an indepm dent review
group, outside the GPU system, having expertise in the review
and analysis of management principles and practices.
Statement in Reply to Significant Evaluation Finding
The Three Mile Island Nuclear Station Unit 1 Radiation Protection
Plan commits, in Article 3, to:
" Periodically, the services of an outside consultant will
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be retained to provide esaluation and guidance on ways to
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improve the TMI-1 Radiological Controls Program." The
evaluation and guidance on ways to improve the program
will include review and analysis of management principles
and practices as they apply to the Radiological Controls
Program.
The evaluation is being conducted by Basic Energy Technology
Associates, Inc. as part of a general review and analysis
of the application of management prir.ciples and practices
throughout the GPU Nuclear Group. The results of this
evaluation will be available by February 28, 1931."
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adeqt. ate corrective actions
were completed for this item.
This item is considered closed.
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Significant Finding No. 50-289/80_-22
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Development of selection criteria for all positions in the
Unit I radwaste organization which include formal education,
experience and training factors.
Statement in Reply to Significant Evaluation Finding
Position Specifications will be developed in response to this
item.
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Based on examination of the licensee's st'ated corrective
actions, discussions with licensee representatives, and exaraination
of selective radiological operations and procedures, the
-inspection team determined that adequate corrective actions
were completed for this item. This item is considered closed.
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Significant Finding No. 50-289/80-22-14
Development of selection criteria for all positions i- the
Unit 2 radwaste organization which include formal ecuescion,
experience and training factors.
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Statement in Reply to Significant Evaluation Finding
Position Specifications will be developed in response to this
item.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
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inspection team determined that adequate Larrective actions
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were completed for this item. This item is considered closed.
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Significant Finding No. 50-289/80-22-15
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Development and implementation of selection criteria for staff
positions in the corporate element of the Radiological Controls
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Department.
Statement in Reply to Significant Evaluation Finding
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Position Specifications will be developed in response 4.0 this
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item.
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Based on examination of the licensee's stated corrective
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actions, discussions with licent;e representatives, and examination
of selective radiological operations and procedures, the
inspection team determired that adequate corrective actions
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were completed for th's item.
This item is considered closed.
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Significant Finding No. 50-289/80-22-16
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Developaent and toplementation of approvea training and replacement
training programs for Unit 1 general employees, radiological
controls, radwaste and training personnel.
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First Statement in Reply to Significant Evaluation Finding
The Training Department's Administrative Manual will be developed
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in response to this item.
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Initial Evaluation _ of Licensee Respons_e_
The response did not address when actual implc.antation of the
training programs would be initiated.
Additional Statement in Reply to Significant Evaluation Finding
In a letter to the NRC dated February 27, 1981, the licensee
stated that the Training Department Administrative Manual
describes programs already in place 'n the areas of Radiological
Controls, General Employee, Rad thste Training and the Instructor
Development Program.
Therefore, formal implementation in
those areas is the date of issue.
1
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item. This item is considered closed.
m.
Significant Finding No. 50-289/80-22-17
Development and imple:nentation of retraining and replacement
training programs for Unit 2 radiological controls and radwaste
rarsonnel.
Statemer.t in Reply to Significant Evaluation Finding
The Trainino Department's Administrative Manual will be
developed i- response to this item.
The Unit 2 Radiologial Controls Training Procedures will be
issued by February 28, 1981.
Additional Statement in Reply to significant Evaluation Findings
The TMI-2 Radiological Controls Section of the Corporate
Radiological Cont.ols Training Manual was approved on February 27, 1981.
This section of the manual is effective on issue.
An early
response refers to this manual section as a procedure.
Training for Unit 2 Rad Waste personnel is covered by the
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Training Department's Administrative fianual.
The inspector reviewed the 1MI Unit 2 Training Manual (prepared
by the Radiological Training Department) and the Training
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Department's (Unit 1) Administrative I.anual.
Minimum requirements
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for job entry and training required prior to job assignment
have been established for all Unit 1 support positions within
the Unit 2 Radiological Controls and the Unit 2 Radwaste
organizations.
In addition, training required during assignment,
and required retraining /requalification are also specified.
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Through discussions with licensee representatives, the inspector
indicatea that, in general, the requirements listed were vague
and confusing.
For example, the inspector could not determine
if training required for job assignment is a minimum requirement
for job entry (the only criteria for replacement training).
Also, it could not be detennined if training required during
assignment is a part of retraining and, if so, at what frequency.
The licensee indicated that a review of the various requiremcots
would be performed to clarify the replacement and retraining
,
requirements as' well as provide more guidance as to details of
minimum job entry experience requirements.
Significant
Finding No. 50-289/80-22-17 will remain open pending licensee
review and upgrading of specific retraining and replacement
training requirements.
n.
Item of Nonccmpliancg No. 50-289/80-22-18_
Contrary to 10 CFR 20.201(b),10 CFR 20.201(a), and 10 CFR 20.202(a), as of July 28, 1980, the licensee had not determined
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if appropriate extremity monitoring devices were being provided
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to individuals.
Statement in Reply of Violation
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10 CFR 20.201 " Surveys" requires evaluations of radiation
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hazards; such evaluations are conducted using portable radiation
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monitoring equipment.
10 CFR 20.202 " Personnel Monitoring" requires each licensee to
supply appropriate personnel monitoring equipment.
The vendor,
Harshaw, Inc., is a nationally utilized supplier of this same
TLD personnel monitoring device for reactor work.
The appropriateness
of the single chip TLD and processing capability were verified
by GPU/ Met-Ed subsequent to the NRC Evaluation.
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Evaluation of Licensee Response
Metropolitan Edison denied this as an item of noncompliance.
However, licensee representatives stated during telephone
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discussions on February 26. 1981 between staff members of
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Metropolitan Edison Company and NRC Region I that, while they
did not agree this was an item of noncompliance, they had
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instituted procedures on their own initiative which would
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provide quality control measures over procurement and processing
of personnel monitoring devices received from contracted
suppliers in the future.
The iiRC staff position was that the item cited was an item of
noncompliance.
Therefore, notwithstanding the licensee's
denial of the item of nor. compliance, which remains as cited,
and subject to reinspection, the NRC staff finds that acceptable
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resolution of the issue has occurred.
Satisfactory implementation
of these corrective measures will oe verified by the Office of
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Inspection and Enforcement prior to TMI-1 restart.
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Based on discussic1s with licensee representatives, and examination
of selective radiological operttions and procedures, the
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inspection team detern.ined that adequate corrective actions
were completed for this item.
This item is considered closed.
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Significant Finding No. 50-289/80-22-19
Resolution of the effect of high energy (approximately 2.2 MeV
endpoint) beta radiation on the TLD gamma exposure results.
First Statement in Reply to Significant Evaluation Finding
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The effect of high caergy (i.e. , 2.2 MeV endpcint) beta radiation
on the TLD gamma exposure results is limited to the effect of
strontium activity in Unit 2 and is not a factor on TLD exposures
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in Unit 1 under normal operating ccr.ditions.
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T* effect of high energy radiation on the TLD gamma results
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is a consideration in some areas of Unit 2.
During the past
15 months the company has expended extensive research resources
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to obtain an approvM 'Ca monitoring capability.
Since there
was no commercial sys.
readily available which was considered
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acceptable for use without some modification, three systems, a
Harshaw system, a Panasonic system and an INEL system have
been researched.
None of these systems, as presented by the
manufacturer, are acceptable, as is, for TMI use.
Two of the
systems are not on the market (readily available for short
term order) and one of the systems is still in the developmental
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s tage.
GPU/ Met-Ed has been working closely with one of these
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companies in particular and has had, on site, representatives
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of the other two companies. Any of the three systems will
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ultimately require additional technical and management efforts
by GPU/ Met-Ed to ensure that the system procured for use is
adequate for our purpose.
TN recommendation to improve the
TMI beta monitoring system could be achieved only with further
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extensive research and investigative effort on the part of the
company and with the cooperation of the vendors.
Due to our
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efforts and the efforts of the cognizant vendors, a final
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decision on one of the three systems which will improve the
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beta monitoring capabilities at TMI has been made.
It is
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expected that the procurement and installation, calibration,
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computer software, preparation and computer tie-in will require
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several months. Since the high energy beta radiation is not a
factor in TLD exposures in Unit 1 under. normal operating
conditions, the implementation of this new system is not
considered a prerequisite to startup of Unit 1.
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Initial Evaluation of Licensee Response
The response did not state how the licensee prepared to control
individual exposures to the high energy beta radiation (i.e.,
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Unit 1 personnel entering Unit 2 controlled areas) and what
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method would be established and implemented to identify and
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assess the doses received by these individuals as a result. of
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their entries into the areas.
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Additional Statement in Reply to Significant Appraisal Finding
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In a letter to the NRC dated February 27, 1981, the licensee
stated that, with noted exceptions, the beta correction factors
used for TMI Stations are based on a natural uranium correction
factor.
Compared with a Strontium-90 beta correction factor,
this is a ' conservative" or higher factor; therefore, if used
in a beta radiation field composed of mixed isotopes, some of
which were Strontium-90, use of this factor would yield a
slightly higher exposure indication.
This correction factor
is determined by technical personnel and then programmed into
the computer for automatic beta interpretation and requires no
manipulations or calculations on the part of the TLD equipment
operator.
Likewise, some Strontium-90 activity in a beta
field will yield slightly higher exposure indications on the
gamma component. Since, in most areas this is a small percentage
and the exposure :ndications are higher than actual (conservative),
normally no correction is made.
In some arecs of Unit 2,
where significant quantities of Strontium-90 are found, dose
assessments by technical personnel are made on a case basis
where the indicated exposure warrants.
Entry to these areas
is rigidly controlled and remrres completion cf detailed data
sheets and approval by Director, Radiological Controls Unit 2.
Based on examination of the licensee's ' stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item. This item is considered closed.
.p.
Significant Finding No. 50-289/80-22-20
t
Decision as to what neutron monitoring equipment will be used
at TMI for monitoring neutron exposure and implementation of
that program.
If a badge device is selected, the device
should be capable of responding to neutrons of energies from
thermal to at least 1 MeV and should have a lower limit of
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detection of not greater than 30 millirems.
Special consideration
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of neutron threshold energies for the detector (140 kev) when
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major portions of neutron exposures are from energies less
than 140 kev should be applied.
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Statement in Reply to Significant Evaluation Finding
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In t'ae current shutdown condition, neutron monitoring is being
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performed by a dosimetry contractor, R. S. Landauer.
Landauer is a supplier of beta, gamma and neutron monitoring
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devices on a nationwide basis.
Under shutdown conditions,
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the vendor neutron dosimetry device is considered adequate.
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The company has made extensive contacts with vendors and with
other professionals in neutron dosimetry mon'itoring and has
been unable to locate a stpplier of neutron monitoring equipment
which is considered capable of meeting the criteria specified
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by the NRC.
Therefore, when Unit 1 becomes operational, the
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neutron dosimetry monitoring procedures in effect for Unit 1
prior to March 28, 1979 will be used with additional confirmation
!
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of correction factors for specific plant areas should the
additional correcti;n fa'ctors be warranted.
The additional
correction would, of course, be determined after startup of
Unit I when dose rates can be taken.
Although the technique
.
will require the use of dose rate instrument determined
j
correction factors to be applied to the neutron monitoring
'
badge, it has the advantage of full time personnel monitoring
while in the neutron field.
GPU/Med-Ed will continue to pursue investigations of neutron
monitoring devices from commercial or research resources and
will consider the use of any advances in neutron monitoring as
new devices are available on the market and as they are considered
to meet the NRC response criteria.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed.
The implementation of the licensee's proposed personnel neutron
dosimetry method and its accuracy will be assessed during
power ascension '.50-289/81-07-01).
q.
Signi ficant Find'.ng No. 50-289/80-22-22
Establishment of action levels for the issuance and use of
special case personnel monitoring devices under conditions
where exposures to the extremities, skin of the whole body or
lens of the eye may be limiting.
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First Statement in Reply to Significant Evaluation Finding
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Revision 11, RCP 1613 ' Radiation Work Permits', dated June 13, 1980,
speci fies criteria for issuance of extremity dosimetry.
Revision 13 of RCP 1613, dated January 5,1981, requires
issuance of extremity monitoring when performing primary
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sampling, 0TSG entries, manipulating high intensity radiation
sources, and any time the extremity exposure rate is likely to
exceed specified criteria.
{
All TLD's now in use at TMI-1 are analyzed for beta exposure.
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Initial Evaluation of Licensee Response
The response only addresses the use of extremity monitoring
and does not reflect action levels or use of special case
monitoring for situations such as exposure to the lens of the
<
eyes or head.
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Additional Statement in Reply to Significant Appraisal Finding
a
In a letter to the NRC dated February 27, 1981, the licensee
stated tt t Radiological Control Procedure 4200, "TLD Assignment,
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Issue and Data Handling" provides procedures for the issuance
of extremity monitoring devices and special monitoring devices;
however, it lacks the specificity to ensure that the specific
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items noted in the Evaluation Report will be accomlished.
t
RCP 4200 will be revised to add the needed specificity as to
perfonnance standards which must be considered in making
individual dosimetry decisions. This revision will bc ccmpleted
by May 30, 1981.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
,
of selective radiological operations and procedures, the
!
inspection team determined that adequate corrective actions
were completed for this item. This item is considered closed.
.
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Significant Finding No. 50-289/80-22-23
Development and implementation of a QA program for vendor
supplied and processed extremity monitoring devices.
Licensee Planned Action
The licensee has established and implemented a 0A program for
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extremity monitoring devices.
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Statement in Reply to Significant Evaluation Finding
The QA Program for extremity monitoring was implemented in
October, 1980. The program includes a " spike" test for finger
rings which are processed by the vendor.
The program requires
a semi-annual test with acceptance criteria, as defined in
NUREG/CR-1063, modified by HPSSC WG-4.
A procedure change
request ~ (PCR) to RCP 4200 has been submitted to incorporate
the finger ring test requiremen+.s and is expected to be issued
May 30, 1981.
Based on examination of the licensee's stated corrective
actiont, discussions with licensee representatives, and examination
of selective radiological operati.as and procedures, the
inspection team de tennined that adequate corrective actions
were completed for this item.
This item is consid2 red closed.
s.
Significant Finding No. 50-289/80-22-24
Within the existing QA program, development and implementation
of provisions for determining correction factors to be applied
in the determination of gamma doses received in mixed radiation
fields.
Licensee Planned Action
This will be addressed in conjunction with Item No. 80-22-19.
Statement in Reply to Significant Evaluation Finding
Gamma calibration factors are not applied to Unit 1 TLD data
as implied in the finding.
The exposure received on the deep
chip is taken as the penetrating dose. The beta emitters
expected to be encountered during normal Unit 1 operations
have energies too low to penetrate the deep chip. Thus,
no gamma correction factors are required in determining the
gamma dose.
Gamma calibration factors are dose evaluation
factors in Unit 2 in selected areas with significant high
energy beta isotopes.
It is expected that this factor will be
adequately corrected by the implementation of the new TLD
monitoring system.
(See response to Item 22-19.)
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team detennined that adequate corrective actions
..ere completed for this item.
This item is considered closed.
t.
Significant Finding No. 50-289/80-22-26
Development and implementation of a bioassay procedure, common
to both Units 1 and 2, which details criteria, collection
methods and handling techniques for each type of indirect
bioassay performed at the site in order to insure unifnrm
coordination and implementation of the bioassay proar i.
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Statement in Reply to Significant Evaluation Finding
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RCP 1628 (Unit 1 implemented November 19,1980) and RCP 4238
(Unit 2 implemented July 25,1980) document the indirect
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bioassay requirements for Unit 1 and Unit 2.
The requirements
contained in these procedures are consistent and common to
,
both units.
Tt ese procedures currently invoke ANSI N343-1978
1
which providet iluidelines on collection, handling and performance
criteria for incirect bioassay.
To ensure clarity and specificity,
the applicable guidelines from ANSI N343-1978 will be incorporated
into the aforementioned procedures by May 30, 1981.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed.
u.
Item of Noncompliance No. 50-289/80-22-27
Contrary to 10 CFR 20.103(c) and Regulatory Guide 8.15:
Certain Respiratory Protection Procedures Were Not Maintained
and Implemented
First Statement in Reply to Notice of Violation
Prior to the evaluation, GPU/ Met-Ed had identified inadequacies
in the existing respiratory protection procedures and had pro-
cedure revisions in process. These procedures were revised to
,
include periodic main +enance on self-contained breathing appa-
'
ratus units and air line respirator regulators and were issued
as follows:
8-12-80
Inspection, Maintenance and Repair of Respiratory
Equipment - RCP 4053, Revision 0
8-28-80
Respiratory Protection Program - RCP 4051, Revision 1
9-08-80
Selection, Prescription and Use of Respiratory Pro-
tection Equipment - RCP 4052, Revision -1
The results of the GPU/ Met-Ed bioassay program, both whole
body counting and specimen bioassays, have demonstrated that
the Respiratory Protection Program has been operationally
ef fecti ve.
Full compliance has been achieved.
!
Operating Procedures for the Eagle and Mako breathing air
!
compressor for filling SCBA bottles are currently in prepara-
l
tion and will be approved for implementation by January 31, 1981.
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Preventative Maintenance procedures for both compressors
existed prior to the Health Physics Evaluation (PM-M-121 4/80
for Mako and PM-M-111 through 114 4/79 for the Eagle compressor).
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Manufacturer's operating instructions for the Eagle compressor
and Instructions for Recharging Breathing Air Systems are both
in use for filling SCBA bottles, however, they have not been
formally approved.
This is a correction to the Met-Ed letter
responding to informal items to Region I dated October 31, 1980
file number TLL 566.
Full compliance will be achieved
(
January 31, 1981.
Initial Evaluation of Licensee Response
The respanse states that certain actions are being taken which
could correct this problem such as revisions to certain procedures;
however, corrective steps which have been taken to prevent
further items of noncompliance were not addressed.
Additional Statement in Reply to Notice of Violation
In a letter to the NRC dated February 27, 1981, the licensee
stated, in addition to the procedure revisions noted in our
earlier response to the items , increased emphasis on procedure
complianice, other improved piacedures, additional assigned
personnel resources and personnel reinstruction in the corporate
policy of verbatii.; compliance function as a system to prevent
recurrence of this item.
Licensee will ensure that the management
policy on use of and verbatim compliance with procedures is
included as part of the General Employee Training (GET) and
annual retraining programs.
Based on examination of the licensee's stated corrective
actions, discussions with licenree representatives, and examination
of selective radiological operations and procedures, the
inspection team detennined that adequate corrective actions
were completed for this item.
This item is considered closed.
v.
Item of Noncompliance No. 50-289/80-22-28
Contrary to Technical Specification 6.11,10 CFR 20 require-
ments, and Radiological Controls Procedure No.1616.2, the
respiratory protection program was not being audited.
First Statement in Reply to Notice of Violation
As stated to the NRC inspector during the evaluation, this
deficiency in conducting the audits required by the TMI Unit 1
procedure had been identified by the licensee prior to the
inspection.
The required audits are now being conducted
ironthly.
F'ill compliance has been achieved.
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Initial Evaluation of Licensee Response
The response states that full compliance has been achieved and
that required audits are being performed; however, corrective
steps which have been taken to prevent further items of noncomoliance
were not addressed.
Additional Statement in Peply to Notice of Violation
In a letter to the NRC dated February 27, 1981, the licensee
stated that, in addit'.cn, increased emphasis on procedure
compliance, other improved prc:edures, additional assigned
personnel resources and personnel reinstruction in the corporate
policy of verbatim compliance function as a system to prevent
recurrence of this iten..
Licensee will ensure that the
management policy
0,, use of and verbatim compliance with
procedures is included as part of the GET and annual retraining
programs.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for chis item.
This item is considered closed.
w.
Significant Finding No. 50-80-22-29
Establish Respiratory Protection Instructor selection criteria
and provisions for qualifying these instructors prior to their
assumption of instructor duties.
.
Statement in Reply to Significant Evaluation Findings
The selection criteria and qualification standards for Respiratory
Protection Instructors were provided to the NRC in August,1980.
These criteria are to be formalized in the pacition specifications
for this job by August 21, 1981.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed.
x.
Item of Noncompliance No. 50-289/80-22-32
Contrary to Technical Spr
Mcation 6.8.1 and Appendix "A" of
aer 1972, as of July 28, 1980,
no Unit Superintendent appoved cr PORC reviewed procedures
were being used for operation, celibration and Quality Assurance
of the whole body counter, a device used for personnel monitoring,
or for the Unit 2 contractor laboratory counting equipment.
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First Statement in Reply to Notice of Violation
GPU/ Met-Ed disagrees with the NRC evaluation team's interpretation
'
that contractor procedures must be reviewed and approved by
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the PORC and Unit Superintendent, respectively.
GPU/ Met-Ed maintain that in the case of contractor services
the contractor should be required by contract to have a contractor-
u; proved quality assurance program satisfactory to the licensee
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for the type of services covered by the contract. When such
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an approve d orogram requires written procedures for the work,
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licensee auditing of the program is the verification that the
contractor procedures are being followed and that they are in
accordance with the contractor's quality assurance program.
The whole body counting contractor, Radiation Management .
Corporation and the two chemistry contractors, B&W and SAI,
have such contracts and quality assurance prograns satis-
factory to the owner. Audits of the onsite radiochemistry
work by SAI and B&W were completed in April 1980 and September 1980.
i
Audit of RMC is in progress.
1
B&W and SAI have worked to their own procedures.
These procedures
are being approved by GPU/ Met-Ed since GPU/ Met-Ed intends to
accomplish this work in the future. A spiked sample program
has existed with the two contractors and GPU/ Met-Ed sicce
after the TMI-2 accident.
Results have bee documented; but
the program wasn't documented until GPU/ Met-Ed prepared a
formal Quality Control Program for Radiochemistry Instrumentation
(Procedure 1982).
This procedure provides for daily background
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counting and calibration also.
l
The 'SAI and B&W procedures will be transformed to GPU/ Met-Ed
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procedures, which require PORC re.iew and Superintendent
.
approval, by January 31, 1981.
,
Initial Evaluation of Licensee Respc..se
The licensee's response did not adequately address corrective
actions with regard to operation, calibration or quality
assurance of the whole body counter.
The licensee's response
did not provide any new information that wasn't already documented
in the details of Evaluation Report 80-22, therefore, the
licensee's response is unsatisfactory.
Additional Statement in Reply to Notice of Violation
In a letter to the NRC dated February 27, 1981, the licensee
!
stated that the Whole Body Counting cauipnent must be operated
by a certified individuai.
This requirement is specified in
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the Whole Body Counter operating specification.
Individuals
are certified by RMC upon completion of the Whole Body Counter
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Tiaining Program which is established by a Training Outline.
The Whole Body 'ounting equipment is operated in accordance
with RMC written Irocedures.
These items (0perating Specifications,
Training Outline and Proceduras) are a part of the Whole Body.
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Counting Manual which has been approved by GPU Radiological
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Controls.
The QA Program which verifies the adequacy of the
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WhoM Body Counter service is specified in RCP 4239.
Included
in these requiremeni.s, among other items, are daily source
checks and quarterly calibration checks with a phantom containing
radioactive sm rces.
These checks are reviewed by trained and
experienced personnel in the Radiological Controls Organization.
.
The RCP will be revised by May 30, 1981 to specify performance
standards and raview requirement by the Radiological Health
organization.
The Manager, Radiological Health, with assistance from the
Manager, Radiological Technical Support, is responsible for
verifying compliance with the above procedures and for ensuring
that the Whole Body Counting Program is maintained consistent
with applicable Regulatory Guides and Standards.
The Qualit,
Assurance Department also monitors and audits performance in
this area as a part of their regular audit program.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed fcr this item. This item is considered closed.
y.
Significant Finding No. 50-289/8C-22-30
Upgrade the existing Unit I respiratory protection training
program to include the elements contained in NUREG 0041,
Section 8.3.
Statement in Reply to Signi ficant Evaluation Finding
Subsequent to the evaluation, the lesson plcn for the Respiratory
Protection Training Program was reviewed and revised to comply
I
with applicable portions of Section 8.3 in NUREG 0041.
This
!
program, which has been reviewed and approved by the Re.,piratory
)
Protection Supervisor, includes all items required by the
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MJREG.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
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were completed for this item.
This item 's considered closed.
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Significant Finding No. 50-289/80-22-33
Development and implementation of a contractor-indepeident QA
program for the bioassay program which' includes: fixed audit
schedules; use of NBS traceable sources; acceptance / rejection
criteria; accuracy and precision requirements; MDAs; and use
and ac'equacy of . licensee procedures.
Statement in Reply to Significant Evaluation Finding
RCP 4239 provides the QA Program for the bioassay program and
invokes the requirements of ANSI N343-1978. As part of the QA
Program, an annual audit a .d calibration check is performed.
The procedure will be expanded by May 30, 1981 to incorporate
the applicable specifications of the ANSI standard.
Basad on examinution of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and proceduras, .the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed.
aa.
Significant Finding No. 50-289/80-22-34
Establishment of portal and hand and foot monitor calibration
programs which include the use of NBS traceable radiation
sources and instrument acceptance criteria.
First Statement in Reply to Significant Evaluation Finding
Use of hand and foot monitor in Unit I was discontinued prior
to the evaluation.
All personnel must perfonn a contamination
survey using a "frisker" when leaving potentially contaminated
areas.
The portal monitors are precautionary monitoring
devices used only as secondary or tertiary contamination
control monitors when leaving the Security Protected Areas.
The calibration procedure (RCP 1745) requires that the monitors
be calibrated electronically and source checked.
This is an
industry practice and has been considered acceptable.
Neverthe-
1 css, as an additional improvement to ou. calibration program,
the procedure will be revised by May 30, 1981 to provide
source calibration of the portal monitors with NBS traceable
sources.
Initial Evaluation of Licensee Response
The response did not address the establishment of calibration
programs for hand and foot monitors in use at Unit 2.
It was
discussed and agreed to in a December.17, 1980 management
!
meeting in Region I that items relating to the Unit 2 would be
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acted upon prior to restart of Unit 1.
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' Additional State.aent in Reply to Significant Evaluation Finoing
In a letter to the NRC dated February 27,1981, the licensee
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' stated that the hand and foot counters are currently being
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electronically calibrated and source checked. A procedure
change is undergoing review and approval which will formalize
this calibration / source check.
The revision will be issued by
May 30, 1981.
Based on examination of the licensae's stated corrective
r
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed,
bb. Significant Finding No. 50-289/80-22-36
Provisions for resolving time corrections in Geiger Muller
(GM) detector counting procedures and determination of the
gross beta efficiency using appropriate. backscatter corrections
for the medium being counted.
Statement in Reply to Significant Evaluation Finding
Resolving time corrections are needed only for counting high
level samples with GM detectors.
A provision will be added to
the applicable procedures by May 30, 1981, to either correct
fo;' resolving times at high count rates, or to use proportional
counters for. samples where precise activity levels are required.
The sources used at TMI for beta efficiencies are standard
I
sources' used throughout the industry and are considered adequate.
liowever, in an effort to continue improving ' comparisons between
the sources used in determining beta efficiencies and the
samples taken in the field, Met-Ed/GPU is attempting to locate
a supplier of National Bureau of Standards (NBS) traceable
sources prepared on air sample filter paper.
An earlier
verbal report to the NRC indicated that the National Bureau of
Standards would supply these sources. Subsequent to that, the
NBS had stated that they cannot supply the sources' as requested.
Af jitional Statement in Reply to Signifir. ant Evaluation Finding
Licensee has confirmed the appropriateness of continued use of
the present detector counting ufficiency factor.
Thi: is
based on a report of calibration dated July 12, 1979, supplied
by the source v;.. dor and a report from the National Bureau of
Standards dated August 22, 1979, both of which indicate a
finding of essentially the same calibration source surface
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emission rate.
Nevertheless, we are pursuing the question of
source medium and have placed an order for filter media sources
with a firm in California. Af ter receipt of these sources,
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checks including autoradiographs will be conducted by the
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licensee. Additionally, it is intended that the sources be
sent to NBS for their certification. After the sources are
returned from NBS, efficiency studies will be conducted by the
licensee.
The NRC will be advised within 60 days of our
progress on procurement, checking and certification of the
filter medium source, and after completion of the efficiency
studies, the NRC will be informed of the findings.
The ir.spector discussed with licensee representatives the
status of filter medium sources.
The licensee representativer
indicated the sources had been received from the manufacturer
i
and have been forwarded to the NBS for certification.
This
'
item (50-289/80-22-36) is open pending analysis of beta counting
efficiencies of filter medium sources following the certification
by NBS.
cc.
Significant Finding No. 50-289/80-22-50
Provisions for weight loading limitations for 17H drums in the
applicable procedures.
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Statement in Reply to Significant Evaluation Finding
Procedures which allow the use of 17H drums as DOT Specification 7A
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packages, will be revised to include the specific weight
limitation, as defined in Safety Evaluation for the package.
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This action will be completed by April 1,1981.
Based on examination of the licensee's stated corrective
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actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
'
inspection team determined that adequate corrective actions
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were completed for this item.
This item is considered closed.
dd.
Significant Finding No. 50-289/80-22-51
Revision of procedures to eliminate references to entire
!
collections of regulatory requirements and incarporate specific
Certificate of Compliance requirements.
Statement in Reply to Significant Evaluation Finding
Procedures involved with radioactive waste handling are currently
being reviewed and revisec as necessary to eliminate reference
to generic regulatory documents.
Included in this effort will
be the incorporation of specific Certificate of Compliance
requirements. This effort is scheduled for completion by
April 1,1981.
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Based on examination of th' licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
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inspection team determined that adequate corrective actions
l
were completed for this item.
This item is considered closed.
ee. Significant Finding No. 50_-289/80-22-52
Development and implementation of provisions for performing
and documenting radiation surveys of shipping casks prior to
intrasite transfer.
Statement in Reply to Significant Evaluation Finding
Procedures governing the intresite movement of shipping casks
are being reviewed and revised as necessary to require HP
,
surveys of the vehicle and shipping cask, and to document such
surveys, prior to the liner being moved.
This action will be
complete by April 1,1981.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this itu. This item is considereu' closed.
ff.
I vem of Noncompliance No. 50-289/30-22-54
Contrary to 10 CFR 71.51 and 10 CFR 71, Appendix E, Criteria
10 and 12:
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Quality assurance criteria for shipping packages for radioactive
'
material requirements were not met.
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Statement in Reply to Notice of Violation
A review of all Type B shipment records since late 1979 was
!
conducted by Quality Assurance personnel.
Administrative
!
errors were found including the deviation from the requirements
to sign off the Rad Waste procedure.
The witnessing and hold-
point verification of shipments 80-49 and 80-56 were performed
by QA surveillance persont~1.
This is documented in QA Sur-
veillance Reports 80-77 and 80-95. To improve administrative
controls and provide better documentation the Radioactive
Waste procedure will be revised by January 31, 1981 to include
a requirement for hold point signature by QA personnel. QA
4
and Radioactive Waste personnel will be re-indoctrinated by
February 1,1981 in these requirements.
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Full compliance has been achieved and further improvements
will be complete February 1,1981.
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The governing procedure in effect at the time of the evaluation
L
to control torque wrenches was TMI Station Administrative
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Procedure AP 1022 ":.ontrol of Measuring and Test Equipment",
dated November 13, 1978.
l
Operating Procedure 2104-4.13, with attachments for the closure
of shipping cask lid bolts, requires the torquing of bolts to
'
specified values.
The QA Surveillance checklist requires verification that the
cask lid closure is correct. A review of past QA Surveillance
!
checklists indicated that all cask lid closures were witnessed
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by QA in 3ccordance with their checklist and in some specific
!
instances the surveillance personnel indicated the torque
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wrench number.
Since specific shipment numbers or dates were not cited by the
!
NRC in their description of the apparent infraction further
verification could not be performed.
To imprwe administrative
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l
control and provide better documentation the operating procedure
OP 2104-4.13 will be revised to require listing the torque
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wrench number and calibration due date.
1
Full compliance has been achieved and further improvements
will be complete by issuing a revised procedure ~ by January 31, 1981.
!
!
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and
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examination of selective radiological operations and procedures,
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the inspection team determined that adequate corrective actions
]
were completed for this item. This item is considered closed.
3.
Follow-up on Noncompliances Identified in the " Investigation into
.
the March 28, 1979, Three Mile Island Accident by the Office of
I_nspection and Enforcement," NUREG-0600.
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Investigation Report No.
50-320/79-10 sets forth in detail the
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events leading to and the facts resulti io from the subject inves-
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tigation. - The findings of the IE inve/igation subsequently became
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the subject of escalated enforcement action, as described in
Appendix A, " Notice of Violation" and Appendix-B, " Notice of Proposed
,
Imposition of Civil Penalties," enclosed with a letter from the Director,
Office of Inspeu. ion and Enforcement, NRC to Metropolitan Edison
Company, dated October 25, 1979. That letter stated, in part:
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"This refers to the investigation...of your activities preceding,
during and imedintely following the nuclear accident that
occurred at the Three Mile Island Nuclear Power Station, Unit
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Number 2, on March 28, 1979.
Because of the similarity of
Units 1 and 2 and commonality of management of the two units,
i
corrective actions taken in resoonso to this letter aad its
}
enclosures aust be equally appilcable to Units 1 and 2."
The inspection team examined the licensee's stated corrective actions
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for Unit 1 as subndtted to the NRC in letters dated DecemLer 5,1979,
May 19, 1980, and July 21, 1980 and NRC letters dated October 25, 1979,
5
January 23, 1980, and November 20, 1980 and implementation of the
licensee's corrective actions, as follows:
d.
Item 79-IR-02
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Contrary to Technical Specification 6.12, positive control
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over entering high radiation areas was not exercised.
!
Statement in. Reply to Notice of Violation
Although Metropolitan Edison acknowledged that failure to
i
maintain positive control in any particular instance constituted
a noncompliance with 10 CFR 20, the license; considered that
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the overall p;ogram as implemented during the March 28 - March 30
2
period was in conformance with 10 CFR 20.
The licensee described
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the measures taken during that period to assure " positive
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control" of entries to the auxiliary building, although. the
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entrance itself was not secured by lacked doors.
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The licensee described, in general, various actions which
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would be implemented to strengthen the health physics program.
.
With respect to this noncompliance, the health physics program
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would be revised to firmly establish the positive control
concept, and required training of all appropriate personnel
would be undertaken to assure that full compliance with a
'
positive control program is achieved, even under accident
circumstances.
The Technical Specifications 6.12.2 should be
modified to permit the imposition of a positive control entry
system during periods when locked doors are impracticable,
impossible or inconsistent with good health physics practices.
'
Evaluation of Licensee Response
The response to this item admitted nonconpliance but argued
that the overall access control program was reasonable under
'
the circumstances and was in conformance with 10 CFR 20.
10 CFR 20,203(c)(2) (iii) required positive control over each
,
j
individual entry. NUREG 0600 (pages 11-3-34, 35, 54, 57, 70
)
and 71) established that such control was not exer:ised.
The
NRC continued to believe that, with the resources available,
6
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-26-
,
i
i
additional measures could and should have been taken to better
!
control access to high radiation areas. The commitment for
corrective a>, tion did not state specific changes to be made to
,
!
the health physics program to improve access control nor did
'
it state the date when full compliar.ce would be achieved.
'
j
Additional Statement in Reply to Notice of Viola,th
The revised TMI-1 Radiation Protection Plan is included in
4
Section 7 of the TMI-1 Restart Report. Met-Ed was in the
process of thoroughly reviewing and appropriately revising the
!
I
approximately 60 Health Physics procedures, and projected all
,
procedures to be finalized, approved ano in effect by
t
3
4
September 1, 1980.
The TPI-1 Restart Report, Sections 4, 6,
!
and 7, discusses Onsite Radiation Protection Equipment, Training
i
and Radiation Protection, respectively.
Additional Evaluation of . Corrective Action
i
During various conversations and meetings with NRC personnel
j
in September and October 1980, the licensee provided additional
1
specificity and/or commitments regarding corrective actions
l
for this noncompliance as described below.
l
Article 5 of the TMI-1 Radiation Protection Plan and implementing
i
j
procedure RCP 1610.1, Access Control for High Radiation Areas,
describes access control for normal conditions.
Emergency
j
Plan Implementing Procedures 1004.9 and 1004.18 describe means
!
of access control as well as personnel exposures during
i
accident conditions.
The deficient conditions identified by
i
this item will be corrected by the above actions.
Full
l
compliance will be achieved by January 1, 1981.
$
Based on examination of the licensee's stated corrective
l
actions, discussions with licensee representatives, and examination
l
of selective radiological operatiens and procedures, the
!
inspection team determined that adequate correctim actions
were completed for this item. This item is considered closed
j
with respect to ac. cess control to high radiation areas during
,
j
normal conditiens.
This item (50-289/79-IR-02) remains open
.
with respect to access control during accident conditiSns, which
!
will be reviewed during a subsequent NRC en:ergency preparedness
inspection.
b.
Item 79-IR-03
'
'
Contrary to Technical Specification 6.12, entries into the
Auxiliary Building were made by individuals who were not
equipped with a radiation monitoring device which continuously
l
indicated-the dose rate.
,
,
'
i
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-27-
Statement in Reply to Notice of Violation
Metropolitan Edison agreed that a violation occurred in that
the individuals specified in NUREG 0600 Section 11-3.2.4.6 and
11-3.2.4.8 did rot have radiation monitoring devices which at
all times indicated the dose rate.
In each case, individuals
were making entries into the Auxiliary Building with some
awareness of information on dose rates and anticipated exposures,
and attempts were made to provide monitoring equipment from
the available equipment.
The licensee described, in general, the various actions which
would be implemented to strengthen the health physics program.
Evaluation of Licensee Response _
The response to this item admitted noncompliance but requested
remission or mitigation of the proposed penalty since the
number of instru:nents available was insufficient to meet
demand.
The response also stated that each individual entering
the Auxiliary Building had "some awareness of information on
dose rates" based on previous surveys and the number of
individuals overexposed was low and exposures were not significantly
above limits.
The fact that an insufficient number of instruments
was available did not relieve the licensee of responsibility
for providing such instruments to individuals entering high
radiation areas as required by Technical Specifications.
The
fact that more than half of the licensee's survey instruments
were out of service for maintenance or calibration undoubtedly
contributed to this problem.
Informing individuals of previous
,
survey results did not provide protection equivalent to equipping
them with a monitoring device as required by Technical Specifications
and did not provide adequate protection when radiation levels
were as high and variable as they were dur.ing the period in
i
question.
The NRC did not believe that any of the overexposures
l
which occurred at TMI were justified; and did not accept the
statement that there were "few overexposures" as justification
i
l
for not providing monitoring devices to individuals entering
l
high radiation areas. The response stated that " site monitoring
i.
devices will be re-evaluated and enhanced as necessary" but
i
did not describe specific steps to be taken nor the 66te when
full compliance will be achieved.
A supplemental response was
requested which specifies in greater detail:
(1) the corrective
steps which have been taken and results achieved; (2) corrective
steps which will be taken to avoid further items of noncompliance;
and, (3) the date when full compliance will be achieved.
Additional Statement in Reply to Notice of Violation
i
The licensee responded in general to this item, as described
for item 79-IR-02.
.
!
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- - - _ - . .-
--
. - _
-
- - - - . . . - ,
--
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-28-
f
Additional Evaluation of Corrective Action
During various conversations and meetings with NRC personnel
in September and October 1980, the licensee provided additional
specificity and/or coninitments regarding corrective actions
for this noncompliance as described below.
Emergency monitoring equipment, dedicated for use in emergency
situations, has been placed at strategic locations, such as:
Security Processing Center, Control Room and Health Physics
Lab.
This equipment will be maintained and inspected in
l
accordance with Administrative Procedure 1053, " Emergency
Equipment Readiness Checklist",
Administrative Procedure 1053
will address the specific type and quantities of equipment,
which will be maintained for emergency use, and will be
implemented by January 1,1981.
During normal operations, the requirement for dose-rate
monitoring instrumentation in High Radiation Areas is imple-
mented through Proceaure RCP 1613, " Radiation Work Permits".
RCP 1613 requires that tha block entitled " Dose Rate Inst." be
checked for any entry into a High Radiation Area. Each
individual entering an RWF controlled area must initial the
RWP to "...sicnify that they have read these documents and
understand them." RCP 1613 is issued and in use.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
ir.spection team determined that adequate corrective actions
were completed for this item.
This item it, considered closed
with respect to use of continuously indicating radiation
monitoring devices during normal operations.
This item
'
(50-289/79-IR-03) remains open with respect to use of proper
monitoring devices during accident conditions, which will be
reviewed during a subsequent NRC emergency preparedness
inspection.
c.
Item 79-IR-05
_
Contrary to 10 CFR 20.201,10 CFR 20.202 and 10 CFR 20.101,
Auxiliary Operator's Whole Body Dose Exceeded Quarterly Limits.
Statement in Reply to Notice of Violation
>
Metropolitan Edison felt that cppropriate instrunrntation to
define radiation levels was provided as well as adeqeate
',
dosimetry in the form of thermoluminescent dosimeters (TLDs).
Following the seand entry by the individual and upon determination
by his supervisor of the off-scale reading on the self-reading
dosimeter, the individual was removed from radiation areas and
his TLD processed.
_
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The events showed the intent to follow sound health physics
practices and provide adequate monitoring Nring the accident
condi tions. The licensee descriW. in gr.neral, the various
actions which would be implemented to strengthen the health
physics program.
Evaluation of Lizensee Response
The response to this item admitted noncompliance but requested
remission or mitigation of the proposed penalty based on the
licensee's intent to follow sound health physics practices.
The circumstances related to the overexposure cited in this item
exemplified lack of sound health physics practices.
For
example, the overexposed individual was not briefed on radiological
conditions prior to entering the building, he did not carry a
high-range dosi.neter, access controls were ineffective for
preventing hu re-entry, even though he was contaminated, and
he made a re-eatry even though his low-range self-reading
dosimeter was offsca M.
Other examples were described in
Section 3.2.4.7 of the Investigation Report.
Although the
licensee suggested otherwise, appropriate instrumentation was
not provided since the individual did not have a high-ange
,
dosimeter and made a re-entry even though his low-cange pocket
'
dosimeter was offscale. Although there was no doubt of the
intent on the part of the individual and manvjement to follow
sound health physics principles, the individual had not been
provided an understanding of health physics principles and
management ccntrols were not sufficien;;ly effectf we to protect
him.
The response stated that certain actions were being
taken which could correct this problem such as revisions to
Emergency Plan implementing procedures and changes in retraining
programs, but the specific steps which have been taken and
results achieved, the steps to be ta' Ken, and the date when
full compliance will be achieved were not stated.
Additional Statement in Reply to Notice of Violation
The licensee responded in general to this item, as described
for item 79-IR-02.
Additional Evaluation of Corrective Action
During various conversations and meetings with URC personnel
in September and October 1980, the licensee stated that corrective
actions desc"ibed in a, b, and d are considered to be applic-
able to this item and adequate to prevent its recurrence.
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed
.=
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with respect to whole body dose limits during normal operations.
This item (50-289/79-IR-05) remains open with respect to controls
l
over whole body doses during accident conditions, which will be
l
reviewed during a subsequent NRC emergency preparedness inspection,
j
d.
Item 19-IR-06
,
,
i
Contrary to 10 CFR 20.201 and 10 CFR 20.101, Nuclear Engineer's
'
Whole Body Dose Exceeded Quarterly Limit.
Statement in Reply to Notice of Violation
!
Metropolitan Edison concurred that this item was a noncompliance.
!
The exposure was confirmed and the engineer was restricted
i
from further activities in controlled areas for the remainder
i
of the quarter Lince his exposure exceeded the 3 rem / quarter
i
limit of 10 CFR 20.
Separate reports and evaluations have
been submitted to the NRC regarding this matter.
'
%e licensee described, in general, the various actions which
would be implemented to strengthen the health physics program.
Evaluation of Licensee Response
The response to this item admitted noncompliance but requested
remission or mitigation of the proposed penalty based on the
licensee's belief that the entry was . vital to public safety
and that proper radiological practices were followed to the
I
degree possible.
The NRC agreed that the entry was justified
but did not agree that proper radiological practices were
followed to the degree possible.
The two engineers she ld
have promptly exited the Auxiliary Buidling when their only
high-range survey instrument failed.
Instead, they continued
on even though their low-range instrument was frequently
" pegged" (radiation levels exceeded the instruments' capabilities).
Although identifying the sourca of leakage was important, the
I
problems had been recognized for at least 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> preceding
i
the entry and th additional delay which would have resulted
from exit to replace the failed instrument would not have
affected public health or safety. More effective training of
radiation workers and radiation chemistry technicians was
l
essential to preventing recurrence of this problem, but the
'
response did not describa specific steps to be taken in this
regard nor did it specify the date when full compliance is to
be achieved.
Additional Statement in Reply to Notice of Violation
,
The licensee respo1ded in general to this item, as described
'
for item 79-IR-02.
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Additional Evaluation of Corrective Actions
During various conversations and meetings with NRC personnel
in September and October 1980, the licensee provided additional
specificity and/or commitments regarding corrective ac.tions
taken for this noncompliance as described below.
The actions stated in a, b, and f are considered applicable to
this item and will aid in preventing its recurrence.
The
Emergency Plan has been modified to include exposure guidelines
,
in emergency situations.
Thase criteria will apply the guidelines
i
of the National Council for Radiation Protection (NCRP) and 10
t
CFR 20 to the specific phases and situations that may be
encountered in an emergency.
The Radiological Safety Training Program for all personnel
employed at TMI-1 has been revised and is currently in progress.
In addition to classroom instruc', ions, emergency response and
practical factor training provides operational training in the
!
radiclogical considerations applicable to the individual's
l
craft lines / functions.
RCP 1690, the implementing procedure
defining this program, has been developed and is currently
awaiting final approval.
Retraining will be conducted on an
l
annual basis.
Full compliance will be achieved by
'
December 1, 1980.
Based on examination of the licensee's stated corrective actions,
discussions with licensee representatives, and examination of
selective radiological operations and procedures, the inspection
team determined that adequate corrective actions were completed
for this item.
This item is considered closed with respect to
l
whole body dose limits during abnormal operations.
This item
l
(50-289/79-IR-06) remains open with respect to controls over
'
whole body doses during accident conditions, which will be
reviewed during a subsequent NRC emergency preparedness inspection.
l
l
e.
Items 79-IR-07 and 79-IR-08
Contrary to 10 CFR 20.201,10 CFR 20.202 and 10 CFR 20.101, a
l
whole body dose limit was exceeded.
In addition, the quarterly
l
.m
limit for the extremities was exceeded for two individuals.
!
l
Statement in Reply to Notice of Violation _
Metropolitan Edison Company agreed that adequate extremity
,
monitoring was not used by the individuals, however, all
evaluations of extremity esosure have been completed and
documented.
Metropolitan Edison felt that the circumstances
surrounding the drawing of the sample indicated that serious
attention was given to radiological practices and that the
sample was obtained in a way that minimized exposure using
available equipment considering the urgency of the sample
requirements.
.
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The licensee described, in general, the .various actions which
would be implemented to strengthen the health physics program.
1
Evaluation of Licensee Response
,
The response to these items admitted noncompliance i.ut requested
migitation or remission based on the licensee's belief that
,
measures taken to minimize exposure were reasonable under the
<
!
circumstances.
Although some planning was done and protective
measures were taken which reduced exposure, the planning was
not sufficient to anticipate the high dose rates encountered
nor to identify the need for extremity monitoring.
In addition,
the dose received by the chemistry foreman during a previous
'
sampling operation was not taken into account when planning
the sample in question. The NRC believed that the overexposures
resulting from this sampling were unjustified and could have
4
been prevented by more effective preplanning.
The response
stated that special handling, tools, shielding, and training
,
of chemistry personnel would be provided; however, this
,
i
comitment lacked specificity and failed to address the more
general area of preplanning for all radiological work.
No
'
date was specified for full compliance.
Additional Statement in Reply to Notice of Violation
,
The licensee responded in general to this item, as described
for item 79-IR-02.
Addit.ional Evaluation of Corrective Action
During various conversations and meetings with NRC personnel
in September and Octcher 1980, the licensee provided additional
j
specificity and/or commitments regarding corrective actions
!
taken for this noncompliance as described below,
j
Radiological (ALARA) Engineers review work requests meeting
the criteria established by the Radiological Control Department
i
for tasks in areas or on systems having radiological implications.
ALARA engineers are on call on a twenty-four hour basis to
'
.
perform these reviews.
The purpose of these reviews is to
l
assess the radiological conditions and determine the most
effective manner to perform the task while maintaining personnel
exposures as low as reasonably achievable.
Techniques considered
i
in reducing exposures are flushing operations, shielding,
special tooling, and the use of containment systems.
In
addition to operational techniques, the need for mock-up
training and/or working briefings prior to the performance of
i
the task are considered.
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Mock-up training, wu.ker briefings and operational techniques
were utilized on major evolutions already conducted at TMI-1.
RCP 1651, Rev.1, "ALARA" and RCP 1651.1 "ALARA Preplanning"
were issued July 28, 1980.
RCP 1651.2 " Facility Planning and
Maintenance ALARA" will be issued by January 1,1980.
The
.
specific method for post-accident sampling is described in
Emergency Plan Implementnci Procedure 1004.15 which was presently
drafted awaiting final approval.
Full compliance will be
achieved by January 1,1980.
Based on examination of the licensee's sttted corrective
actions, discr.ssions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for these items.
These items are considered
closed with respect to dose limits to extremities during normal
operations. These items (50-289/79-IR-07 and 50-289/IR-08)
remain open with respect to controls over extremity doses
during accident conditions, which will be reviewed during a
subsequent NRC emergency preparedness inspection.
f.
Action Item 79-IR-22
Contrary to Technical Specificution 6.4, as of Ma
?8, 1979,
a retraining program meeting or exceeding ANSI N1
_971
recommendations had not been maintained f.'r me
the
radiation protection an't chemistry staff 1
tha . ..ly 2 of the
10 topics recommended were included 'in the prtarim.
Statement in Reply to Notice of Violation
Metropolitan Edison believed that the retraining program
established for the radiation protection and chemistry staff
met the requirements of Technical Specification 6.4 and
Section 5.5 of ANSI N18.1-1971.
The bases for Metropolitan
Edison's disagreement that this was a noncompliance was
described in detail.
'
Although Metropolitan Edison did not believe that its retraining
program for radiation protection and chemistry staff was in
noncompliance with Section 5.5 of ANSI " 18.1-1971, Metropolitan
Edison recognized the need for more -
oetter training of
these and other components of the operating organization.
The
upgraded training and retraining program was especially necessary
in light of the particular le,el of challenge associated with
TMI-2. An improved and expanded training program to address
these concerns was under develonment and would be in place
prior to the restart of TMI-1.
._
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.
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Evaluation of Licensee Response
,
The response denied this item of noncompliance based on the
licensee's belief that only two of the ten training areas
specified in Section 5.5 of ANSI N18.1-1971 applied to n. embers
,
of the radiation protection and chemistry staff and that
applying all ten areas to all members of the " operating
,
organization" was contrary to the intent of the ANSI.
The NRC
'
!
agreed that applicability of some of the ten training areas is
somewhat limited for some members of the operating organi-
zation but believed that the radiation protection and chemistry
staff should receive some training in each of the ten areas.
For example: Area #1 specifies training in " Plant startup and
shutdown procecures; such procedures may require technicians
to take radiation measurements and coolant samples during
startup, but no such training was provided to the technicians.
The commitments for corrective action in this area lacked
sufficient specificity. A supplemental response was needed
which described in detail the scope and extent of training to
,
'
be provided.
]
Additional Statement in_ Reply to Notice of Violation
!
The response to this item in the TMI-2 May 19,1980 letter was
declared to apply to TMI-1.
Q
The ten items in Section 5.5 of ANSI N18.1-1971 referenced in
.
this item are specific to Operator Replacement and Requalification
Training.
This is further amplified in the 1978 edition of
the standard.
The Radiological Control Technicians qualification program,
,
is an annual recurring program.
Training on the ten items
!
listed in Section 5.5 of ANSI N18.1-1971 will be presented as
'
applicable to conditions present at TMI-2 and only in tha
,
detail necessary to the performance of the Radiological
Control Technician's duties and responsibilities as an integral
l
part of this training.
A Chemistry Technician Training Program for TMI-1 and TMI-2
was being developed that was job related.
It would contain a
program for newly-hired technicians and incumbent Technicians /
Foremen similar to the HP Programs.
-
This program would contain lectures in basic theory, systems
and procedures including instrumentation necessary to prepare
and maintain chemistry personnel proficient in their arsigned
job.
_
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The ten items in Section 5.5 ANSI N18.1-1971 would be addressed
to give the Techncians a general understanding of the plant
operations with specific emphasis on his role in the overall
plant evolution.
'
This program would be available to commence on or before
-
June 1, 1980.
Addition.1 Commitments in Reply to NRC Qu_estions
During various conversations and meetings with NRC personnel
in September and October 1980, the licensee provided additional
specificity and/or commitaients regarding corrective actions
'
taken for this non :ompliance as described below.
The Radiologica; Control Technician Training Program at TMI-1
)
consists of initial and requalification training.
Radiological
Control Procedures describe the content, frequency. and acceptable
performance criteria for the various levels of personnel
-
within the Radiological Controls Department.
-
The progra.a consists of classroom training, written examination,
1
practical factors, oral boards, and periodic drills.
Training
'
is scheduled for each Radiological Control Technician / Foreman.
The training providad is intended to enhance each individual's
I
ability to respond to nonnal, unusual, and emergency situations.
Training on the ten items listed in Section 5.5 of ANSI N18.1-1971
will be presented as applicable and only in the detail necessary
for the proper performance of the Radiological Control Technicians'
duties and responsibilities.
l
The Radiological Control Training Program began in February 1980
based on proposed procedures and has been on-going since that
'
da te.
Final, approved procedures will be issued by January 1,1981,
i
at which time full implementation will be achieved.
!
Based on examination of the licensee's stated corrective actions,
,
discussions with incensee representatives, and examination of
i
selective radiological operations and procedures, the inspection
team determined that adequate corrective actions were completed
<
1
for this item. This item is considerrd closed with respect to
a retraining prJgram for radiation protection and chemistry
staff for nonnal operations.
This item (50-289/79-IR-22)
'
remains open with respect to retraining for radiation protection
1
and chemistry staff for accident conditions, which will be
reviewed during a subsequent NRC er.:ergency preparedness
{
i ns pection.
.
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4.
Follow-up on Inspection and Enforcement Bulletins and Circulars
a.
IE Bulletin No. 79-BU-19
Packaging Low-Level Radioactive Waste For Transport and Burial
Based upon combined inspection 50-289/80-08; 50-320/80-05,
Health Physics Evaluation 50-289/80-22, and this inspection,
this item is considered closed,
b.
IE Circular No. 78-CI-03
Packaging Greater Than Type "A" Quantities of Low Specific
Activity Radioactive Material for Transport
Based upon combined. inspection 50-289/80-08; 50-320/80-05,
Health Physics Evaluation 50-289/89-22, and this inspection,
this item is considered closed.
5.
Follow-up on Previously Identified Items of Ncqcompliance, Unresolved
ltems, and Inspector Follow-Up Items
a.
Inspector Follow-Up Item No. 50-289/30-22-03
This item was identified by the special Health Physics Evaluation
Team during the evaluatica of Unit 1 and was subsequently
determined to be applicabie on'y to the Unit 2 f acility. This
resulted in an item of noncompliance being issued to Unit 2.
The details pertaining to this item of noncompliance are
reiterated in Inspection Report No. 50-320/80-05.
The responsibility
for corrective action has been assigned to Unit 2 and will be
reviewed during routine inspections of the Unit 2 facility.
Thi7, item is considered closed.
b.
Inspector Follow-Up Item No. 50-289/80-22-07
Determine Whether Unit 2 Job Descriptions Provided (During HP
Evaluatien) Adequately Addres. d Responsibilities For All
Positions
Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considr. red closed.
c.
Inspector Follow-Up Item No. 50-289/80-22-09
Review Adequacy of Unit 2 Staffing in Relation to Support of
the Unit 1 Radiological Controls Program
.
.
,
.
,
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Besed on examination of the licensee's actions, staffing
plans, discussions with licensee representatives, and examination
i
of selective radiological operations and procedures, the
inspection team determined that the Unit 2 Radiological
Contro;s Department appears to be adequately staffed to
support the Unit 1 Radiological Controls program for routine
j
.
operation.
This item is considered closed.
t
l
d.
Inspector Follow-Up Item No. 50-289/80-22-12
l
Evaluate Qualifications of the Incurabent Radiological Controls
Manager
During IE Inspection No. 50-289/80-22, it was determined that
j
the Manager, Radiological Controls, Unit 1, did not meet the
qualification criteria of Regulatory Guide 1.8, Revision 1-R,
'
1977 and ANSI N18.1.
Section 5.2.2.d of the TMI Restart
Report specified that the Manager, Radiological Controls or
the Radiological Controls Manager (Deputy) shall meet the
requirements of Regulatory Guide 1.8, Revision 1-R,1977.
The
,
l
concept of a Radiological Control Manager. (Deputy) as the
!
qualified Radiation Protection Manager was concurred in by the
!
Nuclear Regulatory Commission staff as specified in the TMI-l
Radiological Protection Plan, Revision 4, dated August 27, 1980,
to provide for assurance that the technical aspects of a
Radiological- Control Program would be adequately managed when
the Manager, Radiological Controls qualifications did not meet
all of the criteria required by Regulatory Guide 1.8 and
During this current inspection, the Radiological Controls
Department organization was examined and it was determined
that the Manager, Radiological Controls did not meet all of
the criteria of Regulatory Guide 1.8 and ANSI 18.1; however,
the " Deputy" Manager Radiological Controls qualifications did
meet these criteria. The inspector examined the TMI-1 Radio-
logical Controls Organization as provided in Revision 4 of the
TMI-1 Radiation Protection Plan and discussed with licensee
representatives the assignment of program responsibilities.
The Radiation Protection Plan organization chart was consistent
with the licensee's Technical Specifications.
,
l
This chart indicated that the implementation of the Radiologiu:1
Controls Program was executed by the " Deputy" Manager Radiologict1
Controls who reports to the Manager, Radiological Controls.
During review of the licensee Radiological Control organization,
the inspector noted that the licensee's Radiological Controls
Procedure 1600, Department Organization Plan, Revision 1,
,
l
dated March 4,1981, was inconsistent with the licensee's
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Radiation Protection Plan and the Technical Specifications.
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' Prior to conclusion of this inspection, Procedure 1600 was
revised by the licensee and the revised procedure was examined
by the inspector.
The inspector determined that corrections
to Procedure 1600 were made and provided for consistency
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between the liccnsee's Radiation Protection Plan and Procedure 1600.
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The inspector discussed the Radiological Controls Department
organization with licensee's management.
The licensee indicated
that the responsibility for the Radiological Controls Program
administration and development was assigned to Manager, Radio-
logical Control. The program implementati.on and day-to-day
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program operation responsibilities, however, were assigned to
the " Deputy" Radiological Controls Manager.
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The inspector determined through examination of licensee
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procedures, organization charts and discussion with licensee
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representatives, that the niection of the Radiological Controls
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Department personnel and its organization structure, were in
accordance with the Technical Specifications and met the
intent of Regulatory Guide 1.8 and ANSI 18.1.
This item is
considered closed.
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e.
Inspector Follow-Up Item No. 50-289/80-22-21
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Evaluate Adequacy of the Implementation of the Exposure Review
2
Program
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Based on examination of the licensee's corrective actions,
discussions with licensee representatives, and examination of
selective radiological operations and procedures, the inspection
team determined that the implementation of the exposure review
program is adequate.
This item is considered closed.
f.
Inspector Follow-Up Item No. 50-289/80-22-25
Review Implemerdation of the Exposure. Review Segment of the
4
Internal Dosimetry Program
Based on examination of the ' licensee's corrective actions,
discussions with licensee representatives, and examination of
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selective radiological operations and procedurer, the inspection
team determined that the implementation of the exposure review
segment of the internal dosimetry program is adequate.
This
item is considered closed.
4
g.
_ Inspector Follow-Up Item No. 50-289/80-22-31
~Storage Provisions for Respirators to Prevent Deformation and
Possible Damage
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Based upon a review of the licensee's procedures and the
licensee's respiratory protection equipment storage facilities,
the inspection team determined that adequate storage facilities
exist in Unit 1 and that this item is considered closed.
h.
Inspector Follow-Up Item 50-289/P0-22-35
Evaluation and Establishment of Portable Instrument Requirements
for Unit 1 to Assure That an Adequate Supply of Instrunents
will be Available During Normal and Off-Normal Conditions
Based on a review of licensee records, it appears that a
sufficient number of portable instruments are assigned for use
in Unit 1 for normal operating conditions.
This item is
considered closed.
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i.
Inspector Follow-Up Item No. 50-289/80-22-37
Review the Ability of the Evaporators to Operate at 75% Capability
to Permit Removal of the EPICOR-I System
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Subsequent to the special Health Physics Appraisal, the licensee
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had dismantled and renoved the EPICOR-I system f rom service.
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The licensee presently uses the Unit 1 evaporators in place of
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The licensee has determined the evaporators perform
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at sufficient capacity to meet current processing demands.
This item is considered closed,
j.
Inspector Follow-Up Item No. 50-289/76-26-05
Replace Temporary Locks and Doors to High Radiation Areas
The inspection team toured controlled areas of Unit 3 and
verified by direct observation that all doors installed for
purposes of high radiation entry control were adequately
installed with permanent doors and locks. This item is considered
closed.
k.
Unresolved Item No. 50-289/79-21-02
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Revise Procedure to Include Requirements of 10 CFR 20.102
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" Determination of Prior Dose"
Inspection Report No. 50-289/79-21 identified that the licensee
had not f ully implemented a new regulation,10 CFR 20.102,
" Determination of prior dose," in that station procedures did
not require a signed statement of the indi"idual's previous
accumulated radiation exposure.
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Based on examination of the licensee's stated corrective
actions, discussions with licensee representatives, and examination
of selective radiological operations and procedures, the
inspection team determined that adequate corrective actions
were completed for this item.
This item is considered closed.
6.
Exit Interview
The inspectors met with the licensee representatives (denoted in
paragraph 1) at the conclusion of the inspection on May 12, 1981.
The inspectors summarized the purpose and scope of the inspection
and the inspection and the findings.
The licensee acknowledged the
findings.
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