ML20028A368
| ML20028A368 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/14/1982 |
| From: | Kanga B GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028A365 | List: |
| References | |
| 4410-82-L-0029, 4410-82-L-29, NUDOCS 8211180497 | |
| Download: ML20028A368 (3) | |
Text
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.w GPU Nuclear Corporation W
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8 Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Writer"s Direct Dial Number:
October 14, 1982 4410-82-L-0029 DESIGNATED ORIGINAL rtified By_ h. I /Jf,MI M Office of Inspection and Enforcement
~~
Attn: Mr. Ronald C. Haynes, Director Region I US Nuclear Regulatory Cmmission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 50-320/82-08 This is in response to Inspection Report 50-320/82-08 issued September 14, 1982. The Inspection Report presented two apparent items of noncompliance.
The Inspection Report citations are restated below in part followed by GPU's response to each.
A.
Statement of Apparent Violation (Severity level V)
"Ihe Order for Modification of License, dated July 20, 1979, as amended by the Order dated February 11, 1980, states, in part,: 'Pending further Amendment of the Facility Operating License, the licensee shall maintain the facility in accordance with requirements set forth in Attachment 1
' (proposed Technical Specification, Appendix A to License No.
DPR-73). Proposed Technical Specifications, Appendix A, Section 6.8.1, requires, in part, that ' written procedures be... impimented...
covering the activities referenced in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978 and the Unit 2 Radiation Protection Plan'.
Specific activities referenced in Regulatory Guide 1.33 include access control to radiation areas including a Radiation Work Permit (RWP) system and personnel monitoring."
" Radiological Controls Procedures (RCP) 4200, Thernoluminescent Dosimeter (TID) Assignment, Issue, and Data Handling, Revision 5, effective June 5, 1982, requires in Paragraph 2.1.1, that TLD's be worn by personnel in site radiation areas which are posted as ' personnel monitoring required' areas, and RCP 4122, Radiation Work Permit, Revision 3, effectiva June 22, 1982, requires in Paragraph 2.2.5 that an RWP is required of all personnel whose work involves entering any area posted 'RWP Required for Entry.'"
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4 Mr. Ronald C. Haynes 4410-82-L-0029
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" Contrary to these requirements, on July 15, 1982, personnel entered the Dosimetry Calibration Building, an area posted as ' Personnel Monitoring Required' and 'RWP Required for Entry', without obtaining personnel monitoring devices and without obtaining an RWP."
Response
GPU concurs with the citation.
In response to the incident (and in accordance with GPU procedures),
the Radiological Controls Director, Unit 2, performed an inmediate and canprehensive investigation to identify the causes and ayyscytiate corrective actions. The investigation, including conclusions and results, is doctmented in Radiological Investigative Report 82-052 dated July 19, 1982.
The apparent causes of the incident were derami=d to be as follows:
1.
Poor cm=mication between the Instrtnent Shop supervision as to duration of the source exposure in the Dosimetry Calibration Facility.
2.
Poor judgement on the part of the Instrunent Shop Supervision in allowing the individuals access to the area witixx2t first inspecting the area and escorting the men.
3.
Violation of a radiological controls barrier by a GET-qualified eroployee.
The corrective actions taken in response to the incident included the following:
1.
Involved personnel were counseled relative to cmnunications, control of the area, and adherence to radiological controls barriers. This was canpleted by July 19, 1962.
2.
Dose assessments were performed on the individuals involved. This was coupleted by July 15, 1982.
3.
A new Radiological Controls procedure was developed which delineates the control and use of radiation sources and control of visitors to the Calibration Facility. The procedure will be issued by Decernber 1, 1982.
B.
Statement of Apparent Violation (Severity Invel V)
"Ihe Order for Modification of License, dated July 20, 1979, as amended by the Order dated February 11, 1980, states, in m rt,:
'Pending further Amendment to the Facility Operating License, tw licensee shall maintain the facility in accordance with requirements set forth in Attachment 1... '
(proposed Technical Specification, Appendix A to License No. DPR-73).
Technical Specifications, Appendix A, Section 6.8.1, requires, in part, that ' written procedures be established... covering the activities referenced in Regulatory Guide 1.33, Appendix A, Revision 2, February 1978.'
Regulatory Guide 1.33 states in Appendix A, Paragraph 8, Procedures for Control of Measuring and Test Equipment and for Surveillance Tests, Procedures and Calibration, that ',.. procedures... be provided to
A
.Mr.. Ronald C. Haynes 4410-82-L-0029 ensure that... measuring devices... are properly controlled, calibrated, and adjusted at specific periods to maintain accuracy. '"
" Contrary to this requirement, Radiological Control Procedure 1772, Dosimeter Calibration and Imak Test, Revision 6, effective January 12, 1982, was inadequate in that it did not establish the frequency of recalibration nor describe the recall system for properly controlling self-reading dosimeters."
Response
GPU Nuclear concurs with the finding.
During one of the revisions to Radiological Controls Procedure 1772, the frequency of recalibration and recall of self-reading dosimeters had been inadvertently rem 3ved from the above procedure.
RCP 1772, Dosimeter Calibration and leak Test, Revision 7, effective August 16, 1982, reestablished the frequency of recalibration of self-reading dosimeters at six months intervals. A calibration sticker with a calibration date and calibration due date will be affixed on each dosimeter to properly control recall of the self-reading dosimeter for recalibration.
If you have any questions, contact Mr. J. J. Byrne of urf staff.
Sincerely,
. K. Kanga Director, M -2 BKK/SDC/jep CC:
L. H. Barrett, Deputy Program Director
'IMI Program Office Dr. B. J. Snyder, Program Director - M Program Office i
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