ML20050L447
| ML20050L447 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/15/1982 |
| From: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20050L260 | List: |
| References | |
| 4400-82-L-0025, 4400-82-L-25, NUDOCS 8204140284 | |
| Download: ML20050L447 (3) | |
Text
.
GPU Nuclear U
g{
P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Writer's Direct Dial Number:
March 15,1982 4400-82-L-0025 Office of Inspection and Enforcement Attn:
Mr. Ronald C. Ilaynes, Director Region I U. S. Nuclear Regulatory Commission 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 50-320/81-22 This is in response to the subject Inspection Report issued January 11, 1982, and is being submitted in accordance with provisions of the report, and a discussion between Mr. S. D. Chaplin of our Licensing staff with Mr. R. J. Conte. Senior Resident Inspector (TMI-2), U. S. Nucicar Regul-atory Commission on February 11, 1982.
In the report the Licensee was cited with one apparent noncompliance. The following is a reiteration of the citation and our response to same.
Apparent Violation (Severity Level IV)
Contrary to the requirements of 00CFR20.201(b), on September 3, 1981, surveys adequate to assure compliance with 10CFR20.101(a) were not performed.
Specifically, an individual entered the reactor building
(!!igh Radiation Area) and removed a contaminated sludge sample tool from the area without performing a radiation survey, or otherwise assessing the potential radiation exposure that personnel could receive from handling that piece of equipment.
Subsequent survey of the equipment indicated 10 mR/hr gamma, and 160 mrad /hr beta at contact.
Response
At the time of the event, 10CFR20.201(b) required that "each licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part".
10CFR20.201(a) defines " survey" as "... an evaluation of the radiation hazards incident to the
. presence of radioactive materials.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment and measurements of levels of radiation.
8204140284 820407 PDR ADOCK 05000320 s a part of the General Pubhc Utikties System G
i Mr. Ronald C. Haynes 4400-82-L-0025 l
The sludge sample tool was located in a radiologically controlled area in the containment where the general area radiation levels were known to be in the range of 300-400 mrem /hr. The tool was known to be contaminated (as a result of its usage) and was appropriately treated as a contaminated item. The tool was not expected to contribute significantly to personnel exposure during its transport out of the containment, i.e., 10 mr/hr vis-a-vis 300/400 mr/hr general area. This " expectation" was the pro-fessional opinion of radiological controls personnel based on (his) knowledge of the working history of the tool and of the general area radiation levels. A meaningful radiation survey prior to removal was not practicable considering the general area radiation levels. This judgement was confirmed by the radiation survey data taken subsequent to its removal from the high radiation area as noted in your citation, and by the radiation exposure received by the individual (130 mrem to the head, 100 mrem to the chest, and 90 mrem to the right knee). Note the radiation doses are higher at the head than at the knee level (where the tool was handled) and do not reflect a significant exposure from the sludge sample tool.
Consequently, in our judgement, the " survey" as performed was sufficient and adequate for compliance with 10CFR20.201(b). Therefore, the Licensee believes that no item of noncompliance existed.
Spccrely,g_ _ ____ _ __
6#
Q);
J.
on l Ac inA Director, TMI-2 JJB:SDC:djb cc:
Dr. B. J. Snyder, Program Director, TMI Program Office Mr. L. H. Barrett, Deputy Program Director, TMI Program Office
l METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT II Operating License No. DPR-73 Docket No. 50-320 This letter is submitted in support of the Nuclear Regulatory Commission request concerning the January ll, 1982 letter transmitting Inspection Report 50-320/81-22.
The response to the subject Inspection is attached.
Further, all statements contained in these responses have been reviewed and all such statements made and matters set forth therein are true and correct to the best of my knowledge, information and belief.
i
\\
/? '
i.
By
/
'[.
Acting di'tector, TMI-2 i
Sworn and subscribed to me this day of
, 1982.
By Notary Public
-