IR 05000289/1992021
| ML20127F278 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/12/1993 |
| From: | Chawaga D, Joseph Nick, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20127F225 | List: |
| References | |
| 50-289-92-21, 50-320-92-15, NUDOCS 9301200187 | |
| Download: ML20127F278 (6) | |
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U.S. NUC1. EAR REGULATORY COMMISSION REGION 1 (
Report Nos.
50-289/92-21 50-320/92-15
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Docket Nos.
50-289 10-320 License Nos.
DPR-50 Category.C.
DPlL-23 Licensee:
.QPU Nuclear Corocrat{pa P.O.110x 480 Middletown. PA 17057 Facility Name:
Three Mile Island. Units 1 and 2 Inspection At:
hilddletown. Pennsylvania inspection Period:
December 7 - 11. 1992 h
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Inspector:
D. Chawfl/, Sc6ior Radiation Specialist Date Facilities Radiation Protection Section
\\b I - "- 93 Inspector:
J. Nic/, Radiafion Specialist Date Facil ties Radia}lon Protection Section
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-t 1 (f N t - i 2-9 3 Approved by:
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Walt Pasciak,' Chief Date Facilities Radiation Protection Section
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Arras Inspected; Postings and other controls observed during facility tours, reactor building entry during power operation, ALARA, organization and staf0ng, survey of materials leaving the RCA,'
radiological information availabic to workers, radiological incidence and personnel contamination reports and access control to lower elevations in the Unit 11 Reactor 13uilding.
Renths Good performance was noted in many areas throughout the inspection, One non-cited violation of NRC requirements was identined for failure to barricade the entrance to a High Radiation Area (see Section 3.0).
9301200107 930112
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PDR ADOCK 0D000209
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DETAILS 1.0 Persons Contacks 1.1 GPU Nuclear Personnel
- R. Shaw, Radiological Controls Director
- E. Scheyder, Site Operations Director
- R. Rogan, TMI Licensing Director
- W. County, QA Audit Manager
- D. Ethridge, Manager Radiological Engineering
- A. Paynter, Radiological Controls Field Operations Manager, TMI 2
- A. Miller, Licensing Engineer J. Harworth, Group Supervisor Dosimetry and Rad I&C D. lawyer, Radiological Engineer B. Parfitt, Radiological Engineer D. Tuttle, Manager Special Projects Radiological Control P. Velez, Radiological Controls Field Operations Manager, TMI-l 1.2 NRC Personnel F. Young, Senior Resident inspector D. Beaulieu, Resident inspector
- Denotes those present during the exit meeting 2.0 Purpose The purpose of this unannounced inspection was to assess the licensee's implementation of the radiological controls program during normal operation. Program elements reviewed included postings and other controls observed during facility tours, reactor building entry during power
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operation, ALARA, organization and staffing, survey of materials leaving the RCA, radiological information available to workers, radiological incidence and personnel contamination reports and access control to lower elevations in the Unit II Reactor Building.
3.0 Facility Tours 3.1 Unit 2 The inspector toured many areas of the facility for both Unit I and Unit 2. The areas toured in Unit 2 included the auxiliary building, fuel handling building (FHB), waste evaporator work area, turbine building, and the radiological control point. Minor inconsistencies in auxiliary building and FHB postings were noted and brought to the attention of licensee supervision. One instance of a contaminated High Radiation Area (HRA) without a barricade was also identified by the inspector.
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3 The area had a step-off pad, but this did not qualify as a barrier as per NUREG/CR-5569 (Health
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Physics Position Data llase, llPPOS 234, page 48). The licensee took prompt corrective action by
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immediately placing a barrier at the entrance to the high radiation area and posting a standing order
to all technicians concerning the need for barriers at the entrances to all high radiation areas.
t Additionally, a memorandum was written to all radiological control supervisors and technicians that clari6cd the posting and barrier requirement for high radiation areas. The memorandum stressed the need for a barrier such as a rope hung below chest level. The absence of a barrier at the
entrance to a HRA is a violation of 10 CFR 20.203 and contmry to requirements of technical speciGeation 6.12. Ilecause this was an isolated NRC Severity level V violation for which the i
licensec took prompt corrective action, this violation will not be subject to enforcement action because the licensee's efforts met the criteria specified in Section V.A. of the Enforcement Policy.
The spent fuel pool area had been recently occupied and the workers had left nails and sawdust extending out from a posted contamination area. Protective clothing and trash were found on the Door in other areas of the auxiliary building. These areas were brought to the attention of licensee supervision and improvements were noted the next day.
3.2 Utlill The inspector toured most of the Unit 1 RCA. Areas visited included the auxiliary building, fuel
handling building, reactor building and portions of the turbine building and outdoor areas. The tour included an entry to the Unit I reactor containment building while the reactor was operating at full power (power entry). All areas observed were posted, barricaded, and/or locked in accordance with NRC requirements. Postings clearly indicated the extent of radiological hazards present in all areas observed during inspection of the Unit 1 RCA Radiological Controls Technicians (RCTs) were knowledgeable of plant conditions and aware of work in progress within the RCA. No weaknesses were noted in instructions given to workers for radiation protection purposes.
3.3 Common Areal
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The whole body count equipment was moved from a trailer to a permanent building and is now
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located closer to the dosimetry office. Although the move was completed, the new facilities were not yet operational at the end of the inspection period. The new facility will provide more work space for whole body counting operations and required extensive planning and preparation prior to the relocation. Licensee personnel anticipate improvements in personnel processing and utilization of manpower resources between the dosimetry ofnce and the whole body counting facility.
4.0 Unit 1 Reactor fluilding Entries During Power Operation (Power Entries)
The inspectors accompanied a RCT during a power entry to the Unit I reactor building. The briefing conducted by licensec personnel contained pertinent information concerning dose rates, _
protective clothing requirements, ALARA practices and required personnel dosimeters. The inspectors measured radiation levels and observed readings that closely approximated the licensee's j
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documented survey results. No weaknesses were noted in housekeeping and the maintenance of radiological postings and boundaries within the reactor building. Radiation Work Permit (RWP)
controls were adequately implemented and observed to be commensurate with the anticipated radiological hazards.
During a previous inspection in February of 1992 (50-289/92-02; 50-320/92-02), licensee personnel committed to evaluate personnel monitoring practices for individuals making power entries and provide additional training to radiological controls personnel making such entries. The licensee's radiological engineering staff wrote a memo, dated September 25,1992, concerning beta radiation monitoring for power entries. The memo stated that the thermoluminescence dosimeters (TLDs)
used for power entries had a neutron monitoring capability, but did not have the capability for beta monitoring. The emphasis was intentionally placed on the neutron monitoring capability due to the
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greater sign 10cance of neutron dose relative to beta particle dose. In recognition of the need to estimate beta doses, licensee personnel committed to perform surveys to assess and assign beta dose from airborne noble gases and surface contamination, liased on the licensee's evaluation, beta doses from both noble gases and surface contamination were calculated using dose rates from survey results and personnel occupancy times. Noble gas exposure rates were determined using air sample results. Surface contamination dose rates were determined using ion chamber survey instruments. Since noble gases often infiltrate the detector volume of ambient pressure ion chamber instruments, these instruments were covered with a plastic bag which
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slowed the migration of noble gas into the detector. Licensee personnel committed to perform general area beta surveys on a quarterly schedule. When work was scheduled on components with the potential for beta emitting contamination, job specine beta surveys would be performed. The inspector reviewed the procedure changes proposed for these items. No weaknesses were noted in
the licensce's efforts in the area of beta radiation dose assignment for power entries.
5.0 ALARA In February of 1992, the licensee established personnel radiation exposure goals of 45 person-rem for Unit I and 200 person rem for Unit 11. Licensee management had not revised these goals at the time of this inspection. Unit I personnel had accumulated approximately 30 person-rem as of November 1,1992. Unit 11 personnel had accumulated approximately 156 person-rem as of December 6,1992. No major radiological work was planned for either unit and licensee personnel anticipated that the 1992 exposure goals would not be exceeded. The inspector reviewed the licensee dose reports for annual and quarterly personnel dose accumulation. As of December 10, 1992, the individual with the highest quarterly dose had accumulated 556 mrem. The highest annual dose for any individual was 2506 mrem.
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6.0 Organization and StafGng There have been no signincant changes in the licensee's radiation protection organization or staff
since the last inspection. The organization was well staffed with qualified personnel.
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7.0 Survey of Materials leaving the RCA NRC Combined Inspection Report Nos. 50-289/92-02 and 50-320/92-02 documented a concern involving the release of " clean" trash from the Unit 11 RCA. The licensec's procedure did not require the use of a sensitive gamma detecting instrument. This was inconsistent with the procedure used for Unit I where such surveys were required prior to releasing " clean" trash from the RCA.
Licensee personnel had stated that the procedure would be changed to ensure consistency between Unit I and 11 and require low-level gamma readings for release of trash. Licensec personnel informed the inspector that the procedure change was completed. A review of this procedure change will be performed as part of the NRC core inspection program in the future,
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8.0 Radjnlegical Information Available to Plant Worken The inspector reviewed the radiological information provided to plant workers including newsletters, memos, briefings, surveys, postings, and RWP requirements. All of the information reviewed during the inspection was found to be clear, comprehensive and technically accurate.
No weaknesses were noted in the quality of radiological control information provided to workers.
Several workers were questioned on their knowledge of radiological conditions and methods available to minimire their exposure to radiation. Those workers interviewed were well informed on radiation levels in their work areas.
9.0 Radiolocical incident and Personnel Contamination Recorts The facility had two Radiological incidence Reports (RIRs) for the year 1992. The first incident
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involved a misplaced source. The source contained 0.057 uCi of Sr/Y-90 that had been removed from a radiation detector for decontamination before re-calibration. A check was immediately performed on all radioactive sources contained on the inventory list as part of the licensee's investigation. During that inventory check, another source containing 0.05 uCi of Sr/Y-90 was determined to be missing. The first source was never recovered and was assumed to have been disposed of as radioactive waste. All other sources were eventually accounted for through a physical accountability. The corrective actions for this event included clarification of inventory requirements, an audit of the source accountability program, and implementation of improvements in source tracking program. The inspector concluded that the licensee's corrective actions were adequate to prevent recurrence of a similar incident.
The second RIR involved a routine gan.ma scan of a filter from the Industrial Waste Filter System (IWFS), a non-radioactive system. The filter was smveyed for radioactive contamination as required by station procedures to determine ifit could be disposed as non-radioactive waste. Low level contamination was found on the filter Radiological Engineering personnel determined that contaminated mop water was introduced to the IWFS through a clean sump resulting in contamination of the system. The radiological engineering staffisolated the sump to prevent further transfer to the IWFS. Licensee personnel planned to treat the contaminated contents of the sump as radioactive waste and dispose of the material in accordance with station procedures._
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comprehensive review of the handling of this event will be performed as part of the NRC's radiological inspection of RIRs during a future inspection after licensee personnel have completed their analysis and have fully implemented corrective actions.
10.0 Access to 1 ower Elevations of the Unit 11 Reactor Building The inspector viewed some areas of the Unit 2 Reactor llullding through the use of video surveillance equipment. Access control to the "D" ring areas was identified as an area of concern in NRC Combined Inspection Report Nos. 50-289/92-02 and 50-320/92-02. Licensee personnel stated that they would install physical barriers, such as construction fencing, over access points to the lower elevations of the reactor building. The lower elevations contain areas with radiation levels in excess of 1000 rem per hour. These areas will be classified as Very High Radiation Areas (VIIRAs) with the implementation of the revision to 10 CFR 20 scheduled for January 1,1994. The access points were through the "D" ring areas and a stairway. Licensee personnel assured the inspector that the barriers were in place; however, due to poor lighting, the inspector was unable to verify the presence of the personnel barriers using a remote camera. The barriers are not required by NRC regulations because the reactor building is locked and access is strictly controlled by station management and Radiological Control personnel, 11.0 Exit Meeting i
i A meeting was held with licensee representatives at the end of the inspection period on December 11,1992. The purpose and scope of the inspection were reviewed and the findings of the inspection were discussed.
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