ML20011A156
| ML20011A156 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/22/1981 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Bradford P NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8110070482 | |
| Download: ML20011A156 (3) | |
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MEMORANDUM FOR: Commissioner Bradford
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FROM:
William J. Dircks, Executive Director for Operations
SUBJECT:
THREE MILE ISLAND UNIT 2 OCCUPATIONAL RADIATION PROTECTION PROGRAM In your memorandum of January 3,1980, you requested notification when the staff determined that the Health Physics Program at TMI Unit 2 was adequate to support major radiological recovery operations.
In March 1981, we forwarded a status report on the licensee's progress which concluded that although the licensee had made significant improvements to his program, we could not at that time conclude that it was adequate to support major recovery activities and that the onsite staff would perform detailed case-by-case radiation protection reviews of each licensee proposed activity (e.g. the Submerged Demineralizer System, (NUREG 0796)). The TMI Program Office on-site staff has recently completed inspection report 50-320/81-13 (attachment 1).
This report, in addition to previous inspection reports and the staff's Radiation Protection Plan Safety Evaluation Report (attachment 2), focused on corrective actions taken by the licensee to upgrade his Radiation Protection Program to support cleanup at TMI Unit 2.
Based upon the above ins uctions and evaluation, we have concluded that the licensee has taken the necessary corrective actions to upgrade his Radiation Protection Program to implement the recommendations of the NRC's Special Panel (NUREG 0640) such that it is now sufficient to support major cleanup activities.
This conclusion is contingent upon the licensee continuing to emphasize commitments to program implementation, expanding the radiological control and training staffs as the pace of the cleanup accelerates and upgrading the personnel dosimetry program to eliminate the conservative assessment of Beta exposures.
I The on-site staff will continue to audit progress on items reflected in the inspection reports and continually assess the licensee's performance towards further improvements to the program.
pgned)V5mam J.lEich William J. Dircks 8110070482 810d2 Executive Director PDR ADOCK 05000320 for Operations PDR p
Enclosures :
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I UNITED STATES t
t NUCLEAR REGULATORY COMMisslON f
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639 PARK AVENUE F
KING OF PRU$$1 A, PENNSYLVANI A 19406 AUG 0 01981 Docket No. 50,320 Metropolitan Edison Company ATTN:~ Mr.-G. K. Hovey ~
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Vice President and Director of TMI-2 P.O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:
Subject:
Inspection Report 50-320/81 13 This refers to the special safety inspection conducted by Dr. M. Shanbaky of this office on June 18 - July '20,1981, of activities ' authorized by NRC License DPR-73 and to the discussions of our findings held by Dr. Shanbaky with members of your staff at the conclusion of the inspection.
Arcas' examined during this inspection are described in the Office of
. Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were observed.
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In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and t:.e enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any informatinn that you '(or your contractors) bt teve to be exempt from disclosure i
under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file'a request for withholding; and (b) submit within 25 days from the date of this letter a written application to this office to withhold such information.
Consistent with section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part sought to be withheld, and which -
contains a full statement of the reasons on the basis which it is claimed that the information should be withheld from pt ilic disclosure.
This section further requires the statement to address with specificity the
~ considerations listed in 10 CFR 2.790(b)(4).
The inru ination sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If'we do not hear from you in this regard within Owoe6Lp9030997
Metropolitan Edison Company AUG 2 01981
.the -specified periods noted above, the report will be placed in the Public Document Room. The telephone notification of your intent to request withholding, or any request for an extension of the 10 day
. period which you believe necessary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.
No reply to this letter is required; however, should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, A-p,==y R. R. Keimig, Chief Projects Branch #2,. Division of Resident and Project Inspection
Enclosure:
Office of Inspection and Enforcement Report Number 50-320/81-13 cc-w/ enc 1:
J. J. Barton, Director, Site Operations E..D. Fuller, TMI-2 Licensing Supervisor E. G. Wallace, PWR Licensing Manager J. B. Libeman, Esquire G.- F. Trowbridge, Esquire Public Document Room (FDR)
Local Public Document Room (LPDR) (NSIC)
Nuclear. Safety Infomation Center NRC Resident Inspector Connonwealth of Pennsylvania bec w/ encl:
Region I Docket Room (with concurrence)
L. Barrett, ' Deputy Program Director, iMI Program Office Chief, Operational Support Sectior. iw/o encl)
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-320/81-13 Docket No.
50-320 Category c
License No. DPR-73 Priority Licensee :
Metropolitan Edison Company P.O. Box 480
.Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania
_J_upe 18' - July 20,1981 Inspection conducted:
u Inspectors:
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M. Shanbaky, Seni r Radiation Specialist date signed 3
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1 T. MosT21t,7a&iation Specialist date~ Mgne~d Approved by:
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A."Fasan6, Chief, Three Mile Island Resident Sc.ction d(te sign'ed
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Projects Braaph #2 Inspection Summary:
Ic20ection on June 18 - July 20,1961
' Mas inspected: Special, announce;i inspection by NRC resident inspectors of licensee action on previous inspection findings in the areas of radiological instrument calibration, radiation nonitoring, respiratory protection, radioactive waste processing and transportation, procedures, personnel dosimetry, ar ; exposure c::ntrol.
The inspection involved 225 inspector-hours by 3 radiation specialist (resident) inspectors.
Results: Of sixty-one items reviewed, fifty-nine are considered closed and two remain open. No items of noncompliance were identified.
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Persons Contacted General Public Utilities Nuclear Group D. Benzel, Supervisor, System Support Engineering K. Bucher, Foreman, Respirator Decontamination S. Chaplin, Nuclear Licensing Engineer W. Clark, Sample Coordinator D. Collins, Foreman, Radiological Controls
~ E. Gee, Supervisor, Respiratory Protection E. Gischel,. Director, Plant Engineering, Unit 2 F. Grice, Senior Project Coordinator, Radiological Controls J. Hildebrande, Manager, Radiological Health K. 9ofstetter, Supervisor, Radiochemistry G Juteau, Supervisor, Decontamination Laundry G. Lodde, Special-Project Coordinator D.- Merchant, Foreman, Radiological Controls P. Newkirk, Foreman, Radiological Controls H. Peterson, Engineer, Radiological Technical Support
- P. Ruhter, Manager. Radiological Technical Support D. Shriner, Manager,-Instrument Calibration and Repair Shop
- R. Swartzwelder, Nuclear Licensing Engineer R. Warren, Plant Mechanical Engineer
- denotes those present at exit interview.
2.
Licensee Action On Previous Inspection Findings a.
Radiological Instrumentation and Calibration (0 pen) Unresolved (320/79-29-04), Licensee to evaluate Counting Equipment Calibration and Efficiency Determination.
The inspecter noted. progress in an on-going licensee radiation instrument calibration audit.
To date, the licensee has evaluated 70% of its radiation counting instruments to identify and correct deficiencies in procedures and calibration practices.
Completion of the evaluation is scheduled for September 1981.
The inspector determined that the adequacy of the licensee's instrument calibration is considered unresolved pending completion of the evaluation.
(Closed) Significant Inspection Finding (320/79-26-02),
Air Sampler Not Calibrated.
On September 21, 1979, an inspector toured the Unit 2 auxiliary building and discovered an air sampler that was overdue for calibration.
Upon being notified of this finding, the licensee removed the sampler and had it calibrated.
n t During this inspection, Unit 2 Health Physics Procedure 1758,
" Operation, Calibration, Maintenance and Repcir of Portable
' Air Samplers," effective July.22,1980, was reviewed.
Air samplers were randomly selected by the inspector and verified to be calibrated.
Calibration records were examiner' to verify that an ongoing calibration program was in effect.
(Closed) Significant Inspection Finding (320/79-17-12),
= Failure to Use Approved Procedures and Certified Calibration Equipment for Calibration of Portable Air Samplers.
During a previous inspection, a review of the instrument calibration program indicated that no approved calibration procedures were being used for calibration of portable and breathing zone samplers.
Additionally, the flow calibration was in question due to the lack of certification of flow calibration instrumentation.
A review of contractor calibration records, procedures, calibration frequencies and certification of calibration instrumentation had indicated the following discrepancies.
No certificates of traceability to the National Bureau of Standards (NBS) were on-site for certain instruments.
Instrumentation was not being removed from the Unit 2 auxiliary building for calibration at the required frequencies.
Examples included Eberline R0-2A lon Chambers, Serial Numbers 285 and 287.
These particular instruments were utilized for beta and gamma radiation field measurements.
During this inspection the following approved procedures were reviewed.
Health Physics Procedure (HPP) 1758, " Operation, Calibration, Maintenance, and _ Repair of Portable Air Samplers," Revision 2, July 22,1980 HPP 1762, " Calibration, Maintenance, and Repair of the Eberline Instrument Company (EIC) R0-2A,"
Revision 4, April 21,1981 Also, R0-2A' instruments were randomly selected by the.
. inspector and verified to be calibrated within the required frequency.
Certificates of traceability to NBS were examined for the following calibration instruments.
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, Radeco'Model 828 (High Flow Calibrator) Serial
-No. 1128
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.Radeco'Model 812 (Low Flow Calibrator) Serial No. 1147 s
The Fisher-porter Flowrator Kit has not been calibrated;
.however, the licensee is processing the requisition (No. 9211-1016) to purchase a calibrated Fisher-Porter kit.-
Based on this examination of the licensee *s corrective-Actions, this item is considered closed, b '.-
Surveys and. Monitoring (Closed) Unresolved Item (320/00-19-05).
Cork Seam Contam'ination.
The inspector reviewed the licensee's actions to monitor and control the spread of contamination discovered in the cork seam of the auxiliary building floor.
The inspector determined that adequate measures had been initiated.
To date, a strippable coating has been applied to the scam and the water and contamination levels are being periodically monitored to detect any spreading of the contamination.
An engineering review of the causes cnd aggravating conditions has been completed.
The' review indicated a need to repair the roof flashing between the reactor building and adjacent. buildings to prevent rainwater from reaching the cork seam and potentially spreading the contamination further.
A contract for repair is being processed.
The inspector stated that the roof repair would be examined to verify completion during a future inspection (320/81-13-01).
(Closed) Infraction (320/80-02-02), Fail.ure to Use Suitable Measurements of Concentrations ~of Radioactive Materials in. Air for Entry into Hake-up Pump Room IB.
On February 11, 1980 suitable measurements of concentrations of radioactive materials in air-were not made when members of an One'rgency Repair Team entered into an airborne radioactive material area inside the Make-up Pump Room.
No air sample was taken from inside the room during the emergency.
During this inspectiJn. the following procedures were reviewed.
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Unit 2 Emergency Plan Implementing Procedure No.1054.9, "In-Plant Radiological Controls During Emergencies,"
dated April 1,1981 Unit 2 Radiological Controls Procedure (RCP) 4045,
" Radiological Review of Work Instructions," dated January, 5,1981 Unit 2 RCP 4052, " Selection, Prescription, and Use of Respiratory Protective Equipment," dated December 11, 1980 Unit 2 RCP 4100, " Radiological Surveys," dated March 6,1981 Airborne sampling requirements dictated by these procedures
'are considered adequate to address emergency action responses.
(Closed) Unresolved Item (320/79-29-03), Verify Licensee is Submitting Samples for Sr-90 Analysis in Accordance with HP Procedure 1616.4.
During a previous inspection, an inspector reviewed the licensee's air sampling program against the requirement of Health Physics Procedure 1616.4, " Implementation of Air Sample Counting, Handling and Actions."
Procedural steps 3.8 through 3.11 require the licensee to submit selected samples for Sr-89 and Sr-90 activity analysis on a weekly basis.
Though the procedure was first implemented on October 9,1979, the licensee had failed to submit air samples for the strontium evaluation.
The inspector had determined that this failure did not constitute; a health and safety problem but did require monitoring by the NRC onsite staff to assure that the licensee adheres to procedural specifications.
During this inspection, air sampling practices and records were reviewed against the following procedures which superseded Health Physics Procedure 1616.4, (cancelled by Procedure Change Request 2-80-657, dated January 26, 1981).
Unit 2 RCP 4100, " Radiological Surveys," dated March 6,1981 Unit 2 RCP 4101, " Air Sample Counting, Handling, and Actions," dated December 28, 1980 Unit 2 RCP 4104, " Air Sampling Procedure," dated May 4, 1981
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BasedLonlthis procedural and record review, and discussions with licensee representatives, adherence to procedural i
specifications is_ being maintained.
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-(Ciosed) ' Inspector Follow Item (320/19 23-05), Review 3
Inconsistency:in Unit 2 Auxiliary Buildt 7 Vent Monitor Dose Rates.
lation the' Unit:2' augmented (supplemental) exhaust v6 sy6t'em was taken out of service in June 1980.
liary building' vent 11ation exhaust is now being monito, by t',iW vent stack monitor, HPR-219A.
Since the supplemental o
?ient radiation monitoring system has not been in use
~ since-that date this item is no longer pertinent.
,(Closed) Significant Inspection Finding (320/79-17-11),
Non-representative Sampling of EPICOR-II Building Ventilation.
' On June 29, 1979 an inspector identified deficiencies in the EPICOR-II exhaust duct monitoring system which ' prevented the licensee ~from obtaining a representative air-sample.
.During'this inspection effort, an examinatten was made of Lthe licensee's Engineering Change Memorandum (ECM No. 3475-134),'that was initiated to corre:t the-identified deficiencies, and an inspection was made of the EPICOR-II exhaust monitoring system to verify completion of the ' corrective actions.
(Closed) Inspector Follow Item (320/79-23-04), High L-Composite Offsite Samples (Liquid).
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During 'a ~ previous review of liquid effluent monitor RML-7 composite samples, analysis results indicated concentrations' greater than 10 CFR 20, Appendix B limits due 'to ~ sample cross contamination.
? Licensee recounts lof re-prepared ' composite samples l
indicated no detectable activity greater than the lower limit of detection of the counters used.
- During: this inspection, a ' review-of RML-7 sample -collection,
preparation 'and ' counting was -conducted.10bservations of-licensee " practices 'in these ' areas,' discussions -with licensee representatives, _ and review of the below listed
. procedures indicate 'that effluents are -being adequately monitored.
RCP 1621.2,'" Releasing Radioactive LiquidiWaste from Unit 2,": Revision 5. July 17,1980 4
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~ RCP 1699A, " Liquid Release from Three Mile Island, Administrative Controls." Revision 4, November 4,1980 (Closed) Significant Inspection Findings (320/79-22-12 and 320/79-22-13) and Inspector Follow Item (320/79-17-21),
Failure to Perform Gross Beta Analysis on Liquid Effluents.
During a previous inspection of licensee liquid effluent release practices, the inspector discovered that Gross Beta Analyses were not being performed on liquid waste prior to release from the site.
During this inspection the following procedures were reviewed.
RCP 1621.2, " Releasing Radioactive Liquid Waste from Unit 2." Revision 5. July 17,1980.
RCP 1699A, " Liquid Release from Three Mile Island,
Administrative Contr01s," Revision 4, November 4,1980 b
Station Chemistry Procedure 1800.5, " Sampling Procedure," Revision 0, September 30, 1980 Station Chemistry Procedure 1950, " Determination of Gross Beta-Gamma," Revisfon 4, February 5,1981 Review was made of sample collection, preparation, counting, and liquid release records per RCP 1699A.
Based on this review, monitoring of effluents by the licensee appeared to be adequate.
(Closed) Signi ficant. Inspection Finding (320/79-22-07),
Improper Posting of Radioactive Material Storage Area.
During a previous inspection,an inspector identified a failure of th,e licensee to label a radioactive materials storage area.
During this inspection, tours were made of controlled and noncontrolled areas to verify compliance with the require-r;nts of 10 CFR 20.203, " Caution signs, labels, signals and controls."
In addition, the following approved procedures were reviewed.
Health Physics Procedure (HPP) 1682, " Control of Contaminated Tools, Equipment, and Material,"
Revision 4, June 13,1980 RCP 4100, " Radiological Surveys," Revision 1, March 6,1981.
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December.23,1980 The results of area tours conducted during this inspection and the results of those conducted daily by the NRC onsite staff indicate that the licensee is adequately
. posting controlled areas.
(Closed) Significant Inspection Finding (320/79-17-14),
- Failure of Personnel to Frisk.
The inspector reviewed Radiological Controls Procedure
-(RCP) 4105, " Monitoring for Personnel Contamination" and RCP 4120, " Operation of a Control Point".
Further discussions with licensee's representatives occurred and observations of frisking at control points.were made.
(Closed) Significant Inspection Finding (320/79-17-13),
Failure to Label Drums and Samples for Analysis.
On July 5,1979, an inspector observed licensee failure to -label radioactive air samples removed from a restricted area for analysis and failure to label drums of radioactive samples being returned from the counting facility.
During this inspection the following procedures were reviewed.
RCP 4100, %aiological Surveys," Revision 1, March 6,1981 RCP 4150, " Radioactive Material Transfer Account-ability " Revision 0, June 1,1980 RCP 4101, " Air Sample Counting, Handiing and Actions,"
Revision 0, December 28, 1980 Based upon this review,the procedures provide adequate instruction for labeling.
The daily tours conducted by the inspector confirmed that the licensee is maintaining an adequate surveillance program to label and account for the transfer of radioactive materials.
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(Closed) Significant Inspection Findings (320/79-13-04 and 320-79-17-10), Inadequate Airborne Survey of Work Area.
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During an inspection 'in June 1979, the inspector determined
.that' general' area air samples of airborne radioactivity concentrations had been used for job specific airborne-activity'. Breathing zone air samples;were not routinely collected. A technical meeting was held with the licensee on taking breathing zone samples and the licensee committed-I
- to the review and revision 'of the airborne radioactivity sampling program.
The licensee's air sampling' program was reviewed in
' February 1981,i(Office cf Inspection and Enforcement-ins pection. 50-320/81 -0s' ).
Based upon the results of that inspection these items are considered closed.
(Closed) Significant-Inspection Finding (320/79-17-15),
Unit 2. Air Sampling Program. Deficiencies.
'A previous inspection of Unit 2 revealed air sampling not being performed at a frequency adequate to demonstrate-compliance with 10 CFR 20.103, " Exposure ~ of individuals to concentrations of radioactive materials in air in u'nrestricted areas."
During this inspection the following procedures of the
, revised air' sampling program were reviewed.
RCP'4100, " Radiological Surveys," Revision 1
- Ma rch - 6, 1981 RCP 4101, " Air Sample Counting, Handling and Actions,"
Revision ~0, December 28, 1980 RCP 4104, " Air Sampling Procedure," Revision 1, July 4,1981 RCP 4051, " Respiratory Protection Program," Revision 3, June 1,1981 RCP 4052, '.' Selection, Prescription, and Use of Respiratory Protective Equipment," Revision 2, December 11, 1980
.RCP 4054, " Calculation of MPC Hours and Stay Times,"
Revision 0, September 5,1980 On the basis of the procedural review, discussions with licensee's' rQresentative, and an examination of air
. sampling s ecords, this item is considered closed.
- .(Closed) Significant _ Inspection Finding (320/79-17-01),
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. Unmonitored -Release Path to the Environment.
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.In, June;1979,canEinspector identified that the 'Tri-State.
- Laundry-mobile' unit used for decontamination of protective
. clothing had a filtered ventilation exhaust which was not
' monitored.
The. filtered air was discharged directly to
- the environment.
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The: current status-of the laundry exhaust system was
' inspected and associated procedures-reviewed. ~hi AMS-3
.tair sampler has been installed 'to monitor air :that is
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tdischarged directly to the environment.~ This: modification rand. associated approved monitoring procedures;provides
. adequate. ventilation monitoring for: airborne : radioactive icantaminants.
-. l(Closed) Violation :(320/79-10-06), Overexposure iDue to
- Failure' to Survey.
0n March 29, ~1979,.a ' Nuclear Engineer entered an area-of
-the auxiliary building where -the radiation' level.was
. greater _ than that which could be measured (2 R/hr) by -his
. portable survey instrument.
Failure.to perform.a survey of the exposure rate in this area contributed;to the
-individual receiving a whole body dose of 3.14 rems for
-this entry. When this dose was added to.the engineer's previous dose-for the quarter, the engineer's-quarterly whole' body dose was 4.175 rems as measured by' personnel dosimetry devices.
The. licensee stated that the Emertency Plan would be modified to include exposure-guidelines in emergency situations, improved training and retraining would be developed -for -radiological centrols personnel, and radiological safety training for all. site personnel would be expanded.
During this. inspection, the actions 'that the licensee -
. stated would te 'taken were reviewed. ' The inspector verified implementation -through discussions' with licensee representatives, observation of licensee activities, and review of the following -procedures.
Emergency Plan Implementing Procedure (EPIP) 1054.3,
" Site -Emergency," : Revision 0, April 1,1981 EPIP 1054.9, "In-Plant Radiological Controls During Emergencies," Revision 0, April 1,1981 EPIP 1054.16. " Contaminated Injuries / Radiation Overexposure," Revision 0, April 1, ~1981 Administrative Procedure (AP) 1055, "Energency
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.. AP 1056, " Emergency Planning Training," Revision 0, April 1,1981 AP 1057, " Emergency Equipment Readiness," Revision 0, April 1,1981
. RCP 4015 " Administrative and Emergency Exposure and Contamination Limits," Revision 0, July 28,1980 RCP 4041, "ALARA Program," Revision 0, December 23,1980 RCP 4045, " Radiological Review of Work Instructions,"
Revision 0, January 5,1981 RCP 4000, " Radiation Protection Plan," Revison 1, January 14, 1980
'(Closed) Violation (320/79-10-04), No Airborne Measurements were made for Auxiliary Building and/or Primary Sample Room.
No measurements were made of the concentrations of airborne radioactive materials in the Unit 2 auxiliary building for periods during which individuals were exposed from 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979 through midnight March 30,1979, nor in the primary sample roca and primary chemistry laboratory for periods during which individuals were exposed from 0400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> on March 28 through 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on March 30, 1979.
During this inspection, it was confirmed that since the accident continuous monitoring instruments capable of measuring particulate, iodine, and gases were installed.
The licensee also has 27 continuous monitors for particulate activity and 30 portable particulate sampling devices in use within Unit'2.
Training in the use of this equipment was 'found to be included in the qualification program for all radiological control technicians and foremen.
These corrective actions are considered to be satisfactory.
(Closed) Violation (320/79-10-03), Auxiliery Building Entries Without Continuous Radiation Monitors.
Certain individuals did not have radiation monitoring devices which at all times indicated the dose rate when these in.ividuals entered high radiation areas of the Unit 2 Auxiliary Building on the evening of March 28, 1979.
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- To correctithis violation, the licensee committed to ple'cin'g
- emergency. monitoring equipment dedicated to bec used only for emergency' situations at strategic locations.._
This equipment isl to be maintained in-a state of readiness.
- at-all times;-
During this ' inspection the emergency equipment wasI
- examined 'and verifled to be maintained in accordance with-
' Unit 2 ' AP:1057,' " Emergency Equipment : Readiness," J Revision 0,
- April 1,.1981. -
-t (Closed): Inspector-Follow' Item (320/78-31-04), Review Radiation' Levels! on Containment Dome to~ Verify that Surveys are made < before ~ Personnel ' Perform 1endon : Surveillance on' Dome'During; Reactor' Operation.
t During an inspection conducted prior to the'Three Mile
~
DIsland: Unit 2: accident, thelinspector noted that no
' confinnat'ory gama3 surveys-were performed on; thet containment.
- building of Unit' 2 to determine' that the. design -objectives given in the FSAR' are met.
The licensee committed to.
making. radiation measurements at 75". andi1000 power of:
Unit:2~ thac ~would be reviewed 'by the NRC during a subsequent routine ' inspection.
L Based upon, surveys:conductedLo'n the containment. dome on-
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. March 31,-1979f it' was~ concluded that the design: objectives of the FSAR'have' been met, i;
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'Respi ratory ' Protection
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(Closed) Inspactor; Follow Item (320/79-23-11), Review L
Field Implementation ~of New Respiratorf Protection and Sampiing Pro'cedures.-
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The licensee utilizes respiratory protective equipment to limit the inhalation ~ of airborne radioactive material.
l-r As specified in 10 CFR 20.103(c), the licensee may make.
'allowancet for'the use of such equipment provided that.the respiratory protective equipment is used as stipulated in Regulatory Guide 8.15,1" Acceptable Programs for< Respiratory Protectien"'.
As a:resultf of significant deficiencies identified in the-licensee's' respiratory protection program, particularly -
with respect lto. implementation of the' requirements of i
- Regulatory Guide 8.15', meetings were held with the licenseeton: August 17 and August '28,-1979, to discuss the n
deficiencies.
The discussions included: ;(1) upgrading of; respiratory. protectionLprocedures' (2) review of suppliediair systems, and (3) improving sampling of
_ airborne: radioactive material.
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F During this inspection, the below lis'ted Unit 2 procedures
!were reviewed.
The review focused on the compliance of the licensee's respiratory protection program with Regulatory Guide 8.15. " Acceptable Programs for Respiratory Protection,".and NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials.",
RCP 4051, " Respiratory Protection Program,"-Revision 3 June 1,1981-RCP 4052, " Selection, Prescription and Use of Respiratory Protective Equipment," Revision 2, December 11, 1980 RCP 4053, " Inspection, Mainter.ince and Repair of
- Res'piratory Protective Equipment," Revision 1, December 5,1980 RCP 4054, " Calculation of MPC Hours and Stay-Times,"
Revision 0. September-5,1980 RCP 4100, " Radiological Survejs," Revision 0,
-Janaury 22, 1 981 RCP 4101, Air Sample Counting, Handling, and Actions,"
Revision 0, December 28, 1980 RCP 4104, " Air Sampling Procedure," Revision 1 July 4,1981.
RCP 4238, " Bioassay Program," Revision 3, April 8,1981 RCP 4239, " Implementation and Quality Assurance of the Three Mile Island Nuclear Station Bioassay Program," Revision 1, April 8,1981 Health Physics Procedure 1758, " Operation, Calibration, Maintenance and Repair of Portable Air Samplers,"
Revision 2, July 22,1980 RCP 1758.2, " Low Volume Tritium Sampling," Revision 0, August 22, 1980
'RCP 1616.3, " Respirator Cleaning and Testing Facility,"
Revision 6, February 26, 1981 RCP 1616.3A, "Q-127 00P Respiratory Filter Tester,"
Revision 2, April 28,1981 RCP 1616.38, " Operating TDA-2D DOP Respiratory Leak Tester," Revision 0, February 26, 1981
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Based upon this. procedural review, observation of activities and examination of. records at the respiratory fitting booth, Radiation Work Permit Training. Health Physics i Control Point Unit 2, Respiratory. Decontamination Facility
.and the whole body counte. the Respiratory Protection Program meets -the criteria of Regulatory Guide 8.15,and
< NUREG-0041.
5 d.
Radioactive Waste Processing and Transportation
-(Closed) Inspector Follow Item (320/79-17-19), Proper
. Numbering of-Radioactive Material. Shipments.
During a-previous inspection,the inspector identified the use of the same radioactive material shipping number for two different shipments in June-July 1979. The licensee revised Health Physics Procedure 1618 to: prevent recurrence.
The review of RCP 1618A, ". Radioactive Material Shipping;"
Revision 5, Attachment 3, indicated that adequate direct!on is provided -for proper numbering of radioactive material shipments.
In addition, records of past shipments during a preceeding six month period were reviewed with no observed problems of 'hipment numbering.
(Closed) Violation (32010-14I01), Packages at Burial Ground not Properly F.:aled (Loose or Broken Locking Rings).
On June 10, 1980, an inspection of trailer 440571 loaded with radioactive waste packages from Three Mile Island.
arrived at the burial site with at least 15 drums with loose locking rings (could be rotated by-hand) on the lids.
One of. these rings was physically broken at the l
wel d.
The licensee responded that procedures had been implemented which provided for verification of tightness for each -drum ring.
In addition, the licensee ' initiated the use of elect.-ical impact wrenches.to' achieve tightness and to dStect faulty welds associated with the locking ring.
. Based on examination of the licensee's corrective actions, discussions with licensee representatives, and review of RCP 1618A and RCP 16180, " Radioactive Material Packaging,"
the inspectar determined that adequate corrective actions were taken s.il completed in this area.
.(Closed) Inspector Follow Item (320/79-23-03), Incl usion.
of Requirements for Labeling of Packages.for Shipment in Revised Procedure.
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. During a previous inspection,it was noted that a package of radioactive material was not labeled,in accordance
~
with 49 CFR 172.403(d)(1).
Based on discussions with licensee represnntatives and examination of RCP 1618A and RCP 16180, the inspector determined that adequate direction for labeling of packages of radioactive material for shipping is contained in current shipping procedures.
(Closed) Inspector Follow Item (320/79-17-20), Curie Content Estimations of Radioactive Waste Shipping Containers.
A review of determination of the curie contents of radio-active waste shipping containers indicated that the curie
-content was only valid for gamma emitting isotopes.
Based on a review of RCP 1620, " Radiological Controls for Processing Radioactive Solid Waste," and RCP 1655, " Curie Estimates for Radioactive Material Shipments," and discussions with licensee representatives, the inspector determined that current methods of estimating curie content of packages includes fac. tors based upon measured beta to gamma. emitter ratios.
(Closed) Inspector Follow Item (320/79-13-01), Qualification of Licensee Contractor Health Physics Personnel.
A review of qualifications and backgri unds of contractor supplied health physics (HP) supervisors and technicians performed during inspection 50-320/79-13 identified that no procedural controls specifying qualification require-ments for contractor HP personnel existed.
The licensee connitted to develop procedural controls for HP personnel qualification.
The inspector reviewed applicable procedures, training records, the radiation protection plan, and had dis-cussions with licensee representatives.
The inspector determined that adequate procedural control for health physics contractor personnel qualifications and back-grounds exists.
(Closed) Open Item (320/81-03-03), Incorporation of NRC Comments into Radi.ition Protection Plan.
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- The licensee submitted a proposed radiation protection plan to the.NRC staff for approval.
The proposed plan -
~
was approved with several minor comments which were to be incorporated in the plan.
. The inspector reviewed the present controlled copies of
'the licensee's radiation protection plan and veriffed
- that the NRC comments.had been incorporated.
<(Closed) Noncompliance (320/80-19-04). Failure -to Follow
' Procedures Associated with Coolant Sampling and Analysis.
A-review of reactor coolant sampling and onsite analysis
, performed during inspection 50-320/80-19 -identi fied two
, instances of failure to follow applicable procedures.
Based on discussions with licensee representatives, observation of sampling operations and review of selective procedures, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Inspector ' Follow Item (320/79-22-14), Radiological Concerns Identified During EPICOR-II Preoperational Review.'
Inspection 50-320/79-22 listed six discrepancies to be followed by the NRC onsite staff concerning EPICOR-II operations.
These items were identified during a pre-operational eeview of the EPICOR-II system and procedures.
During startup and operation of the EPICOR-II system, the items were satisfactorily resolved by the licensee.
'(Closed) Violation (320/80-10-01), Failure to Use Leak-l resistant Containers.
During March 1980, the licensee shipped water samples in which the inner. containers of three of the ten samples had leaked contrary to the requirements of 49 'CFR 173.393(g) and 20 CFR 71.5.
Based oa examination of the licensee's submitted corrective actions, discussions with licensee representatives, and review of RCP 1618D, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Violation (320/80-10-02), Failure to use Authorized Packaging for Shipment of Type "A" Liquid Radioactive
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Prior to March 23, 1980, on at le st two occasions type i
"A" quantities of liquid radioactive material were shipped f
in 17H drums.
At the time of the shipments,17H drums I
were not authorized for radioactive liquid shipments in that
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the licensee's safety analysis. failed to demonstrate that the
- a packaging would meet the requirements of paragraph 49 CFR 173.393(g)(1).
The licensee modified his packaging requirements for type "A" liquid radioactive material shipments and completed a safety analysis for the same.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, examinations of several subsequent shipments, and review of RCP 16180, " Packaging of Radioactive Material," the inspector determined that adequate corrective actions were completed in this area.
(Closed) Significant Inspection Finding (320/79-17-08),
ALARA (As Low As Is Reasonably Achievable) Review of Facility Procedures During inspection 50-320/79-17, the inspector identified that certain recovery procedures and associated operating procedures were receiving little or no review to assure that adequate ALARA and Health P,hysics consideration were incorporated.
The licensee issued RCP 4041, "ALARA Program," Revision 0, December 23, 1980 and RCP 4045,
" Radiological Review of Work Instructions," Revision 1, February 12, 1981, to identify criteria for ALARA review, designate personnel to perform reviews, and to include ALARA sign-off on applicable facility procedures.
Based on examination of the licensee's corrective actions, discussion with licensee representatives, and examination of selective radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area, f.
Dosimetry (Closed) Significant Inspection Finding (320/79-17-04),
Identified Concerns with TMI Personnel Dosimetry System.
Inspection 50-320/79-17 included an. in-depth review of the TMI personnel dosimetry system.
During this review, ten significant findings were identified and brought to the attention of licensee representatives on June 15, 1979 l
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16-I Based on review of licensee d' osimetry. procedures, docu-mentation, and interviews'_with licensee representative',,
all of the:above identified concerns with the TMI personnel
~
dosimetry system have been corrected.
Presently the only open item 1concerning personnel dosimetry is proper response
- to beta and mixed beta-gamma fields and is being' carried y'-
as open item'(??0/80-16-16).
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c(Closed)- Unresolved Item (320/79-29-05),~ Incorporation of
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.10;CFR 20.102, " Determination of Prior Dose" Requirements L
Into Dosimetry Procedures;.
During combined inspections 50-289/79-22.and 50-320/79-29 the inspector determined that the licensee -had not fully Limplemented dosimetry program changes to comply with a new -
, regulation,'10 CFR 20.102, " Determination of Prior -
Dose".- The licensee initiated a procedural change to
- comply with the new regulation ~.
The change was to be monitored by.the NRC staf'-
' The: status of the ~1 ice.. e s current procedure to determine prior dose was inspected during inspection 50-289/81-07 and item 289/79-21-02 was closed. Based upon this inspection and common dosimetry processing for both units, item l
'(320/79-29-05) is considered closed.
(Closed) Inspector Follow Item (320/79-23-10), Review of
~
- Contractor Report Concerning Thermoluminescent Dosimeter.
-(TLD)l System Accuracy and Consistency.
In connection with significant inspection finding l
320/73-17-04, an audit conducted by a contractor prior l
to the March 28, 1979 accident was submitted to the NRC for: review.
The report was reviewed and in light of significant modifications in-the-dosimetry procedures, staffing, documentation, calibration and training 'as, documented in the health physics TMI Unit 1 evaluation, the section on
- personnel dosimetry is no longer applicable.
(Closed) Unresolved Item (320/79-29-07), Review Revised Procedure 'and Training of Dosimetry. Personnel.
On October 29, 1979, a dosimetry technician preparing TLD extremity devices for issuance failed to realize no TLD elements were in the devices.
Upon-discovering the mistake,the licensee removed the extremity ~ devices from (service. Also, a revision to the applicable procedure was-initiated along with instruction to personnel in the
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, Based on discussions with licensee. representatives and
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examination of dosimetry procedures and training records, the dosimetry procedures and instructions for dosimetry personnel were determined to be adequate.
(Closed) Inspector Follow Item (320/79-13-03), Performance
During review of the personnel dosimetry performed as a portion of inspection 50-320/79'-13, the inspector identified that the licensee had not performed the annual QA test as required by procedure 1643, " Quality Assurance Tests for TLD Dosimetry System".
Subsequent to inspection 50-320/79-13,the licensee issued a new QA procedure which required monthly, quarterly and annual QA tests.
Through review of records and discussions with licensee representatives, the inspector verified performance of these required tests.
(Closed)' Open Item (320/81-03-11), Performance of Annual (QA) Test for TLD's as Required by RCP 4220, "TLD System Quality Assurance".
The status of the licensee's (QA) program for personnel dosimetry was reviewed during inspection 50-320/81-03.
RCP 4220 required monthly, quarterly, and annual irradiations of TLD's.
During inspection 50-320/81-03 the inspector verified performance of the monthly and quarterly tests.
Based on discussions with licensee representatives and review of-selective records, the inspector verified performance of the required annual QA test for TLD's.
g.
Exposure Control (Closed) Infraction (320/80-02-05), Failure to Properly Post a Radiation Area.
r On February 2,1980, an inspector was performing independent radiation surveys for verification of licens'ee's posting and labeling of radiation / radioactive material areas.
While performing surveys outside the EPICOR-I processing building, the inspector discovered the 7-10 millirem /hr unposted area.. These dose rates were verified by licensee surveys, using licensee survey meters.
The radiation levels were caused by a bag of contaminated material, reading 90 milliran/hr on contact, which was stored inside the EPICOR-I processing building, directly adjacent to the inner building wall.
This bag of contaminated material was subsequently shielded and later removed from the
. Luil ding. 'This unposted radiation area was accessible for unrestricted access.
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actions, discussions with licensee representatives, and current-examination of selective radiological operations and' applicable procedures, the inspector determined that adequate corrective' actions were completed in this area.
7
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(Closed) Significant Inspection Findings (320/79-26.and 320/79-26-04), Failure to Follow Radiation Work
-Permit (RWP) - Procedure 1613.
On October.15 and 17,1979,the inspector examined the implementation of. certain RWP's including RWP Nos. 28777 and 28741..The inspector noted that the licensee's failure to, comply with protective clothing required by RWP No. 28777 resulted ia one individual receiving contamination ~ below the left knee.
The. RWP called for coveralls and wet suit.
Paper coveralis were substituted for the: wet suit by the shift ilP foreman for-the Unit-2 control post.
Only dry decontamination was to be performed;
. wet. suits were not thought to be necessary.
During the decontamination, the individual accidentally knelt,in a wet / oily spot, feeling slight wetness through the coveralls.
The RWP substitution was in violation with the procedure 1613, Section 5.0(d) which required changes to RWP's be approved and reflected on all topies by the Radiation Protection Supervisor / Foreman or-the Shift Superviscr or their designees (320/79-26-03).
The inspector also noted that standing RWP's (SRWP) required workers to have a dose rate instrument for entry to an area controlled by a SRWP.
On October 17, 1979
. orkers in the Cap Gun 1 area, controlled by SRWP 28741, w
did not have a dose rate instrument during moving and wipe down of resin liners.
Failure to have a dose rate instrument for an operation where high radiation levels are likely resulted in the inability for a proper evaluation of the radiation hazards to be performed as required by 10 CFR.20.201(b).- Radiation levels were later measured by licensee personnel to be up to 0.8 R/hr on contact (320/79-26-04).
Based on examination of the licensee's corrective actions, discussions with licensee represeatatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that
- adequate. corrective actions were completed in this area.
l (Closed) Significant Inspection Finding (320/79-26-01),
Failure to Adhere to Adminstrative Procedures for High
-Radiation Areas.
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s On September 26, 1979, the inspector reviewed the imple-
' mentation of procedure 1050 which establishes administrative
., controls for. high radiation areas. As a result of the inspector review, at that time, several inadequacies were noted, including ft.11' re to perform the required audits u
of the high radiation areas key locker, failure to provide y^
.a' unique lock to each high radiation area as required, failure tc prepare and maintain a current list of high radiation area keys, and failure to document the status a
of high radiation area barricades.
Based on examination of the licensee's corrective actions.
. discussions with licensee representatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Inspector Follow Items (320/79-23-06, 320/79-23-07, and 320/79-23-08), Contamination of Individuals.
On August 13,1979,one individual sustained contamination of the fingers of both hands as a result of handling a torn bag of used respiratory protection equipment.
Initial surveys of finger contamination indicated a maximum of approximately 100,000 dpm.
The individual underwent decontamination and 'whole body counting (320/79-23-06).
On August 27,1979,a second individual sustained radio-active contamination.
The contamination was of the ann and. right thigh wit.h measurements indicating a maximum contamination of 35,000 dpm (320/79-23-07).
'On August 30,1979,three licensee contractor employees sustained skin contamination while kneeling near pipe supports on the 281' elevation of the fuel handling building.
One individual was noted to have a maximum contamination level of 200,000 dpm of the right knee (320/79-23-08).
Based on examination of these contamination incidents and review of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed in this area.
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-(Closed) Significant Inspection Findings (320/79-22-04,
'320/79-22-05, and 320/79-23-01) Failure to Control High s
Radiation and Radiation Areas Through Posting and Barricading.
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i 1 During July and August 1979, tours of controlled and noncontrolled areas were made to verify licensee compliance 4
with the reqdirements of 10 CFR 20.203, "Cautionligns,
~1abels, signals and controls" Technical Specification Section 5.12 "High Radiation Area" and Station Health Physics Procedure 1610. " Establishing and Posting Areas".
During area tours and the performance of independent radiation intensity measurements the inspector identified
. licensee failure to post, barric,de and control access to a
radiation areas and high radiation areas.
The= licensee,
in a letter dated August 6,1979, connitted to the review and revision of those procedures dealing with the cor. trol of High Radiation. Areas.
The revised proceduretwere to include: 1) specific-steps for Me control of High Radiation Area access 2) a surveillance program for identification of new High Radiation Areas
. and 3) a surveillance program to ensure all High Radia-tion Areas are properly controlled.
q Based on examination of the licensee' 3 stated corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and applicable precedures, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Significant' Inspection Findings (320/79-13-02, 32n/79-17-05, 320/79-17-06 and 320/79-17-18), Failure to Post and Control High Radiaticn Areas.
During June and July 1979, tours of areas (both controlled and uncontrolled) were made to verify licensee compliance with 10 CFR 20.~20h " Caution Signs, Labels,' Signals 'and Controls," Technical Specification Section 6.12. "High Radiation Area" and Station Health Physics Procedure 1610
" Establishing and Posting Areas," dated September 30, 1977.
During area tours and the performance of independent radiation intensity measurements,the inspector identified failure to control and post access to high radiation areas.
AS;d on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radioloS cal operations and
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procedures, the inspector determined that adequate corrective actions have been completed.
(Closed) Significant Inspection Findings (320/79-17-13 and 320/79-17-16), Inadequate Radioactive Material Control.
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paring an -inspection in July 1979, radioactive and
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contaminated material controls were reviewed for compliance with 10 CFR 20.203, " Caution Signs, Labels, Signals and Controls," and HPP 1682, " Control of Contaminated Tools, Equipment and Material," Revision 2, dat.ed April 28, 1 977.
r Several instances of failure to comply with the above requirements were noted.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed.
(Closed) Significant Inspection Finding (320/79-17-09),
Improper Container Posting.
During a rolew of radioactive waste storage on June 26, 1979, it was noted that posting and labeling of radioactive waste at the south-east storage area was not consistent with the requirements of 10 CFR 20.203(f), " Containers,"
and Station HP Procedure 1620, Section 5.4, " Identification of Shipping Containers."
Based on examination of the licensee's corrective actions, discussions with lic.ensee representatives, and current examination of selective radiological operations and applicable procedures, the inspector determined that adequate corrective actions were completed.
(Closed) Inspector Follow Item (320/79-13-06), Failure to follow Radiation Work Permit (RWP).
During May and June 1979,the inspector examined a sample of RWP's to verify adherence to RWP requirements. Several instances of failures to follow RWP requirements were identified.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed.
(0 pen) Violation (320/79-10-09), No Evaluation of Skin Contamination Exposure.
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, On March 28, 1979 and March 29, 1979, several individuals received skin contamination of the hand and other parts of the body sufficient to cause exposure rates in the range of 20-100 mR/hr when measured with a hand-held survey instrument and no evaluation of the dose to the, skin of these individuals was made.
Licensee's corrective actions and the submitted licensee's dose evaluation report are still undergoing NRC review.
This item remains open pending completion of NRC assessment.
(Closed) Violation -(320/79-10-08), Chemistry and Radiation
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Protection (HP) Foremen Extremity Over-Exposure.
On Maren 29, 1979, a chemistry foreman and a radiation protection fo-eman were permitted to handle a highly radioactive actor coolant sample without adequate personnel mon toring and without first performing a survey of hand and forearm exposure rates.
Handling of this sample 'resulted in a calculated dose to the hands and forearms of the chemistry foreman of about 147 rem and a calculated dose to the hands and forearms of the radiation protection foreman in the range of 44 to 54 rem..
Based on examination of the licensee's corrective actions in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area.
(Closed) Inspector follow Item (320/79-13-07), Adequate Instructions to Workers on Radiation Hazards Hao Not 9een Provided Pursuant to 10 CFR 19.
Adequate instructions to workers on radiation hazards had not been provided pursuant to 10 CFR 19.
Plant and contractor personnel must be fully informed about radiation health hazards associated with their work at the facility.
The licensee developed an instruction list, in the form of a check-off, which was posted at appropriate radiological work locations.
Based on examination of the licensee's corrective actions, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed.
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.- (Closed) Violation (320/79-10-05), Overexposure in Excess of the Quarterly Limit.
29,1979,an auxiliary operator was permitted to On March enter areas of the auxiliary building where exposure rates of up to 100 R/hr existed.
Radiation survey information and appropriate personnel monitoring were'not provided to the operator for this entry. This contributed to the operator receiving a whole body dose of 3.170 rem for that calendar quarter.
Based on examination of the licensee's corrective actions in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed in this area.
j (Closed) Violation (320/79-10-02), Auxiliary Building High Radiation Area Not Locked.
From 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on March 28, 1979 until the afternoon.of March 30,1979, the doors to the auxiliary building were not locked and access was not otherwise controlled even though the building was known to be a high radiation area with radiation levels much greater than 1000 mrem /hr during this period.
9 Based on examination of the licensee's corrective actions as stated in letters dated December 5,1979 and May 19, 1980, discussions with licensee representatives, and current examination of selected radiological operations and procedures, the inspector determined that adequate corrective actions were completed.
(Closed) Inspector Follow Item (320/79-04-01), Low Water Level in Neutron Shield Tanks.
On March 9,1979, following a reactor trip, the neutron shield tanks were checked.
The inspector found that several of the tanks were dry and the remainder had low water level.
The licensee stated that this area would be examined.
A licensee representative stated that no level indication and no provision to refill these tanks at power was included in the design.
During this inspection, the inspector examined this item and determined that,after the March 1979 accident at TMI and under the current plant condition,this concern is not applicable.
~
' ~3,z Inspector Follow Items
. Inspector follow items are; inspector concerns or perceived weaknesses Lin the licensee's conduct of operation (hardware or programmatic)
- that could lead to; noncompliance if.left uncorrected.
Inspector follow items are addressed in-paragraph 2.
4 L0 pen Itmas-
'Opein items are findings in which further action is warranted by the licensee to fulfill the intent of commitments to the NRC or further review by NRC is warranted to assure licensee is meeting the intent
- of, committed. action.
This classification of findings was used primarily for licensee commitments made as a result of the Special Panel that reviewed the TMI-2 : Radiation Protection Program in October-Noverbar 1979.
Open Litemscare addressed in paragraph 2.
15.-
LSignificant Inspection Findings
-From March -1979 to October 1979, inspectors closely monitored licensee
. daily'; activities during post accident efforts. At that time normal NRC enforcement actions were deemed inappropriate for the situation at TMI-2. Accordingly inspector findings were termed "Significant Inspection Findings" (SIF's) and these dealt with concerns in the
'following areas: containment of radioactive material; maintainance of core cooling; and reduction of radiation dose to personnel.
A SIF _could be a noncompliance,. deviation or unresolved item.
It could;also be acceptable from a strict rc3ulatory viewpoint but represented a weakness warranting improvement in light of the accident situation. ' SIF's are addressed in paragraph 2.
- 6. -
Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is an item of noncompliance, a 1-
. deviation', or acceptable. Unresolved items are addressed in paragraph 2.
7.
' Exit Interview
-(M July 20,1981 the resident inspectors met with licensee repre-sentatives (denoted in paragraph 1) to discuss the inspection scope and. findings -
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hisi. m TION:
TETJ 'Tldi~
iaC POR Local PDR TERA MAR 5 1981 J.".L.Erscram Office HQ
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liRC/Till-81-218
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L. L.arrett A. Fasano a
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-~2 Docket fio.' 50-320 Attorney, ELO "
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Metropolitan Edison Company M. Duncan fir. Gale llovey, Vice President and Director of Tail-2 ACRS (16)
B. J. Snyder P.O. Cox 480 niddletown,PA 17057 R. Weller J. Ufebe R. Bellamy
Dear Hr. Hovey:
THI Unit 2 Radiation Protection Plad
Subject:
He have reviewed your Radiation Protection Plan, Revision 2, dated..
25, 1930.
Jana 16,19J0, and suboitted to us by letter TLt.-355 dated July We conclude tnat minor clarification is required prior to our approval.
These Our comrsents have been discs : sed and resolved with your staff.
cocr. ants and tnair resolutit,ns are cresented below.
Articles 2, 4, 5, 6, 7, and 9 of the plan are acceptable as subaitted.
i Article 1 Regulatory Guidos 8.2, 8.4 and 8.9 should be referenced.
Carment:
Your staff has agreed to make reference to these
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regulatory guides as additional regulatory guidance.
[
Resolution:
Article 3 The proposed review and audit procedures should incorporate..
Comnent:
criteria for tirely and gyropriate action....
Your staff has agreed to include criteria for timely.
Resolution:
and appropriate action in implementing procedures.
for those functions specified in the plan.
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Article S A means'for str agthening assurance that re:novable Co:zaent:
contanination limits are not being exceeded should be instituted. Assurance should be given to ensure contaainated natorial is not released from the site above the stated liaits.
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!!.AR a p-g g Resolution:
Your s;tff has agreed to provida for periodic swipe surveys in imple:enttr) procedures.
7-your staff, is enclosed. lith the incorporstica of the above resolutions, Our 'evalstioni based'on incorporation of.our consents as agreed.to by m..
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U w concluda that your Radiation Protection Plan is acceptable.
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Lake H. Barrett
. Acting Deputy Program Director ~
.T.II Progrzs Offica
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Enclosure:
As stated t
cc: See Service Distribution List?
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i THREE MILE ISLAND, UNIT 2 U-V EVALUATION OF RADIATION PROTECTION PLAN RADIATION PROTECTION
. Met Ed's. submittal with regard to the Three Mile Island, Unit 2, " Radiation Protection Plan", describes -the proposed radiation protection program.
The staff has reviewed the Radiation Protection Plan, and has used the acceptance criteria of Section'12 of NUREG-75/087, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" to judge the acceptability ~ of the appi. cant's radiation protection program.
Where other or additional criteria were used, those criteria are presented in our evaluation.
Article 1 Foundation for the TMI-2 Radioloaical Controls Program Article 1 sets forth the Met Ed.
philosophies and basic policies concerning radiological controls program.
We conclude that these policy considerations are consistent with the guidance of Regulatarj Guide 8.8, "Information Relevant to Insuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" and the acceptance criteria of Sections 12.1 and 12.5 of NUREG-75/087.
Regulatory Guides 8.2, 8.4, and 8.9, are referenced for additional regulatory guidance.
Therefore,
- we conclude.that the policy considerations ure acceptable.
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b.
, Article 2 Responsibilities of Workers p
Art.icle 2. identifies specific rules to be followed by individuals working in, restricted areas, in order to minimize radiological problems.
We conclude that these provisions of the Plan are consistent with Regulatory Guide 8.8 and the acceptance criteria of NUREG-75/087.
Therefore, we conclude that the responsibilities described in Article 2 are acceptable.
Article 3 Audits, Reviews and Reports on the TMI-2 Radiological Control Program Article 3 ' identifies nine levels of audits, reviews and reports to assure that individuals a'nd supervisors responsible for maintaining occupational radiation exposures as low as is reasonably achievable are meeting that requirement, and
(+
assisting others in understanding and complying with that requirement.
Since the proposed review and audit procedures incorporate criteria for timely and appropriate action for those functions specified in the, plan,.we conclude that this ~ article provides methods capable of verifying that this requirement 'will.
be met, and are therefore acceptabic.
Article 4 Radiological Control Training Article 4 describes Met-Ed's radiological control training program, to assure that each person understands radiation risks, radiological conditions to be encountered, personal responsibility to maintain exposure as low as is reasonably achievable and to comply with radiological control procedures.
We conclude
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3 il that the training program described is consistent with the requirements of 10 CFR Part 19.12 and the ' draft guidance in the NRC draft Regulatory Guide,
" Radiation Protection Training for Light-Water Cooled Nuclear Power Plant Personnel". Therefore, the training program described in Article 4 is -
acceptable.
Article 5 Control of External Exposure Article 5 reaffirms Met-Ed's commitment to mainiain occupational radiation exposures as low as is reasonably achievable, and describes exposure control policies and requirements addressed to that goal.
We conclude that these policies and requirements are consistent with the guidance of R% s'iatory Guide 8.8 and the requirements of 10 CFR Part 20, " Standards for Protection
('
Against Radiation".
Therefore, the exposure control program described in Article 5 is acceptable.
\\
Article 6 Control of Internal Exposure Article 6 describes an internal exposure control program intended to prevent any significant internal exposure to personnel by limiting internal exposure to one tenth of the exposure to airborne radioactive materials that 10 CFR Part 20 would allow.
We conclude that the internal exposure control program described is consistent with the requirements of 10 CFR Part 20.103, Regulatory Guide 8.15,
" Acceptable Programs for Respiratory Protection", and Standard Review Plan, Section 12.5.
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4
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Artic'le 7 Control of Radioactive Contamination Article 7 states an intent to minimize possible inhalation or, ingestion of radioactivity and buildup of radioactivity in the environment, in order to minimize personnel radiation exposure, to simplify subsequent decontamination, and to minimize the need to rely on anticontamination clothing, and emphasizes the importance of training in assuring success of this aspect of the program.
We conclude that the licensee's plan for control of radioactive contamination is acceptable.
Article 8 Control of Radioactive Materials Article 8 describes a program for a radiocative material control system to assure that such material is not lost or misplaced so as to cause inadvertent occupational exposures, and to prevent uncontrolled spread of such material.s to areas where the public might be affected.
Surveys for contamination will be provided for sampling of items to assure th t contamination limits are not exceeded.
We have concluded that the program for control of radioactive materials described in Article 8 is consistent with-the guidance in Regulatory Guide 8.8 and the provisions of 10 CFR Part 20.
Therefore, we conclude that the radioactive materials control program is acceptable.
Article 9 Organization for Radiological Controls 1
Article 9 describes the organization for Radiological Controls Department.
,[;':'
We have concluded that the organization described is consistent with the 1
i V
guidance in Regulatory Guides 8.8 and 1.8, " Personnel Selection and Training".
Therefore,' the organization of the Radiological Controls Department is acceptable.
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