ML20062K139
| ML20062K139 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/13/1993 |
| From: | Broughton T GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-93-2171, NUDOCS 9312200220 | |
| Download: ML20062K139 (3) | |
Text
{{#Wiki_filter:.. ) 4 E b GPU Nuclear Corporation i 3 Nuclear
- .o; f r 388 Forked River, New Jersey 08731-0388 609 971-4000 Wnter's Direc Dal Nurnber; (717) 948-8005 December 13, 1993 C311-93-2171 U. S. Nuclear Regulaty ry Concission Attn: Document Control De u Washington, DC 20555
Dear Sir:
Subject:
Three Mile bland Nuclear Station, Unit 1 (TM1-1) Operating License No. DPR-50, Docket No. 50-289 " Reply to a Notice of Violation" - Inspection Report 93-23 Enclosed is the GPU Nutiear reply to the Notice of Violation transmitted as an - enclosure to Inspection Report 93-23. Sincerely, T. G. Broug on Vice President and Director, TMI-l AWM/mkk Attachment cc: Region I Administ ator l 1MI-l Senior Project Manager TMI Senior Resident Inspector !?0031 9312200220 931213 S PDR ADOCK 05000289 m Q PDR D GPU Nuclear Corp rahon rs a subs"1:ary of General Pubhc t libbes Corrorahon .[ O/ Ils
i Attachment ,- C311-93-2171 Page-1 o I NOTICE OF VIOLATION i Technical Specification (TS) 6.12.1.a. states, in part,. that "In lieu of the " control device" or " alarm signal" required by paragraph 20.203(c)(2) of 10 1 CFR 20: Each High Radiation Area as defined by paragraph 20.202(b)(3) shall be barricaded and conspicuously posted as a High Radiation Area,-and personnel desiring entrance shall obtain a Radiation Work Permit (RWP)." Contrary to the above, on October 4 through 8,1993, the inspeci:or found-several examples of high radiation areas where the licensee did not barricade or properly control access to prevent inadvertent entry. The high radiation areas without proper access controls were found in the Auxiliary Building and the Reactor Building. The duration of these conditions was indeterminable. l t The examples listed above in aggregate constitute a Severity Level IV violation. Gjil NUCLEAR RESPONSE TO THE NOTICE OF VIOLATION 1. Reason for the Violation The improperly barricaded High Radiation Area (HRA) in the Auxiliary Building involved a ladder leading to a platform about 10 feet abo' e~ the v floor with a posting indicating dose rates above 100 millirem per hour during fuel transfer operations. The ladder was posted with a HRA sign-hanging from one rung of the ladder. There'was no barricade.at the bottom of the ladder or on the platform at the top of the ladder. The reason for this violation was the Radiological Controls. technician improperly implementing the procedural requirements. The technician's undershnding of what constituted a barricade was insufficient for this ~ situation. In addition, it-is possible that other Radiological Controls personnel failed to notice.this discrepancy during their routine tours and inspections. Several HRA postings and barriers in the reactor building were moved or repo'itioned by workers and not placed back in their original' positions. The areas were marked by a step-off pad on the floor and a swing arm gate-with an HRA posting. Two swing arm gates were propped open against a wall or railing with the postiag facing the other way and not visible to someone entering the HRA. In another instance, the entire swing arm gate was moved about five feet'away and to the side of the step off pad, so .^ that it did'not barricade the entrance to the HRA..The reason for these discrepancies in the reactor building was-that the barricades interfered with the worker's job. Wher, moving large equipment, these barricades impeded the worker's progress. The worker's awareness of the importance of the integrity of these barricades wa.: inadequate. r l =#
3-Attachment .f C311-93-2171 Page 2 II. Corrective Steps That Have Been Taken and the Results Achieved The Manager, Radiological Controls Field Operations, TMI-l' issued a memorandum to his supervisors and tr.cnaicians, which stresses the importance of HRA postings and barricades. This Manager also discussed with the craft supervision and the plant maintenance supervision the importance of HRA postings and barricades. ' Radiological Controls Management tours have specifically looked for problems in HRA postings and barricades since these incidents and no reoccurring problems have been noted. t III. Corrective Steps That Will be Taken to Avoid Further Violations This problem has been documented in a Radiological Awareness Report (RAR). This RAR specifies corrective action steps to prevent further violations. These actions are as follows: 8 1. Place an item on the Radiological Controls Outage preparation punch list to discuss the importance of HRA postings and barricades with contractor and plant supervision. 2. The locations of normally used HRA swing gate barricades will be reviewed to determine whether the location should be changed and how these barricades could be modified to that they are more difficult to move. 3. Review the content of the General Employee Training (GET) Program relative to HRA barricades. Revise GEY if necessary. IV. Date of Full Compliance. The corrective actions described above will be completed by March 31, 1994. i -t s =}}