ML20207E661
| ML20207E661 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/15/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 5211-86-2122, NUDOCS 8607220395 | |
| Download: ML20207E661 (5) | |
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GPU Nuclear Corporation NggIgf Post Office Eox 480 Route 441 South Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
July 15, 1986 5211-86-2122 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Notice of Violation from Inspection Report 86-05 Enclosed is GPUN's response to the Notice of Violation in Appendix A to Inspection Report No. 50-289/86-05 ( Attachment 1). A discussion on the pace of activities and lessons learned from the event of March 24, 1986 are found in Attachment 2.
This response is being submitted late as discussed with NRC Sr. Resident Inspector R. Conte.
S ncerely,
/A D. Huki V ce President & Director, TMI-1 i
l HDH/SM0/spb:0626A cc:
R. Conte Attachments 93 e6%Q 89 e6072jjoCW 00 P R Sworn and subscribe { to POR j
l before me this 151 day 0
of Qal11
, 1986.
i g f, SEARON P. ERCWN, NOT*RY PUSLIC FIDDLETNil 8020. CAUPh!N COU1;iY
/
Notary Pupi1C MY COMt.flSSION EXPggr$ Juhl 12.1933 l
Member, Pennsylvania Associstion of Nourls:
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation t
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.e ATTACHMENT 1 As a result of an inspection conducted on March 7 to April 11,1986; and, in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the following violations were identified:
Violation A:
10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with all sections of Part 20. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Requirements of 10 CFR 20.103(a)(3) in part are that "... the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity... as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals...."
Contrary to the above, on March 24, 1986, the licensee failed to perform a timely evaluation of airborne radiofodine in the Reactor Building (RB). Work on the once-through steam generators (OTSGs), initiated at approximately 9:00 a.m., generated airborne radiof odine in the RB which was not detected until approximately 11:00 p.m.
The nearly 14-hour delay resulted in the unplanned exposure of 77 personnel, with intakes of radioactive iodine as high as 120 nCf.
Response A:
On March 24, 1986, work was scheduled to begin in the TMI-l once-through steam generators (OTSG). The presence of iodine was anticipated therefore two breathing zone air (BZA) samples with iodine sampling capability were taken adjacent to the exhaust from the OTSG heads.
The samples indicated that the iodine was at an acceptable level but it was not recognized at the time that the samples were unrepresentative.
The sample results, combined with RM-A2 readings which did not indicate a substantial rapid increase in activity and the belief that Reactor Building purge had decreased the iodine concentration led Radiological Controls supervision to believe there was not an iodine problem.
The error went unrecognized for a number of reasons.
There was a delay in analyzing the other iodine air samples taken that would have indicated an iodine problem.
This delay was due to the failure to prioritize counting of samples which were representative of building atmosphere. Also, there was a large number of samples that needed to be analyzed due to the amount of work being performed.
In addition to the delay, there was poor communication between Radiological Controls personnel on shif t turnover.
Once the samples had been analyzed that truly indicated an iodine problem, the information was not adequately communicated to the oncoming shif t.
Therefore, the event continued for an additional period of time.
Response A (Cont'd.):
As a result of this event, the following corrective actions were taken:
- 1) The air sample isotopic analysis equipment sof tware has been modified such that Radiological Controls personnel can appropriately reduce sample analysis times.
This will allow for more rapid assessment of radiological conditions during periods of intense plant activity while maintaining appropriate LLD's.
This was completed for iodine sample analysis on April 2,1986 and for the remaining sample analyses on July 1,1986.
- 2) Charcoal absorbers have been procured and are currently available for use with existing portable ventilation equipment when appropriate.
Replacement parts for these absorbers have been established in the spare parts system to assure availability for future use. The units arrived March 27, 1986 and were installed immediately.
- 3) The Radiological Controls personnel involved in the shif t turnover were counselled on the need for better communication.
Additional lessons learned from the event are discussed in Attachment 2.
Violation B:
10 CFR 20.203(b) requires that each radiation area shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words, " Caution - Radiation Area."
10 CFR 20.202(b)(2) defines a Radiation Area as "any area accessible to personnel in which there exists radiation... at such levels that a major portion of the body could receive in any one hour a dose in excess of 5 mi ll i rem... "
Contrary to the above, on April 1,1986 at approximately 3:00 p.m.,
the radiation area in the hot machine shop on the 305-foot elevation of the i
Auxiliary Building was not conspicuously posted as required.
Survey measurements inside the hot machine shop indicated general area dose rates up to 20 millirem / hour.
Response B:
l On April 1,1986, equipment was being moved out of the hot machine shop. The door of the machine shop with the radio:ogical posting was open. A i
l Radiological Controls technician was assigned to the job. His duties were to control access to the shop as well as conduct a survey of the item being l
moved. The technician lef t his post temporarily without ensuring the area was adequately posted to warn personnel of the radiological conditions in the i
area.
Upon identification, the area was reposted.
This is considered a l
personnel error.
Response B (Cont'd.):
The incident was reviewed with the technician and the Radiological Controls supervisor. Appropriate disciplinary action was taken.
A memo was issued April 14,1986 to all Radiological Controls personnel involved in posting of radiation areas. The memo reviewed the incident and emphasized the need to follow procedures. A Radiological Awareness Report on the incident was closed April 17,1986.
Inspection Report 86-05, Section 6.2.2 requests GPUN address the implications of the two recent posting incidents documented in Inspection Report 85-30 and Violation B.
One of the previous incidents involved an area in which radiation levels has unexpectedly changed since the last routine survey causing the High Radiation area boundary to extend beyond the posted area.
The second incident (GPUN identified item) involved an unidentified plant worker who failed to replace a High Radiation area barrier / posting when exiting the area.
Subsequently, another worker inadvertently entered the area. Violation B, as discussed, is considered a personnel error.
Each incident was an implementation problem, not a programmatic problem.
Appropriate corrective action is being taken for each incident to prevent recurrence.
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ATTACHMENT 2 A.
Pace of Activities As requested in the cover letter of Inspection Report 86-05, the following discusses the pace of activities as a contributing factor in the radiological event of March 24-25, 1986.
We feel the pace of activities was acceptable and safe. The pace of activities only contributed to the event in the number of people in the' '
Reactor Building and the amount of iodine in the Reactor Building. The pace did not delay recognition of the iodine which led to the worker exposure.
Adequate Radiological Controls manpower and equipment were available to' perform sample analysis in support of the work being performed.
1 B.
Lessons Learned As a result of the event, the value of purging to the extent allowed by Tech.
Specs, and longer, more effective RCS degas was highlighted.
The following procedure changes are planned:
1.
Revise OP 1102-10 and 11 to recommend commencing degassing at l day in advance of a plant shutdown and continuing until the ma\\ east one '
e up system is shutdown.
2.
Revise AP 1030 " Control of Access to Primary System Openings" to provide better guidance on how to control and contain any releases which may result from opening the RCS.
3.
Revise OP 1102-14 " Reactor Building Purging and Venting" to add a caution to explain how opening the personnel door to the Reactor Building can i
affect the ability to control the purge and dilution flow rates when a ',
purge is in progress.
The procedure will also be revised to recommend initiating a purge the full 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of a shutdown as allowed by Tech. Specs and to fully open each of the purge valves when containment integrity is not required.
In addition, personnel have been made aware of the incident through an Operations memorandum and a Radiological Investigative Report.