ML20210A288
| ML20210A288 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/09/1987 |
| From: | Masnik M Office of Nuclear Reactor Regulation |
| To: | Smith H NRC |
| Shared Package | |
| ML20209C045 | List: |
| References | |
| NUDOCS 8705050055 | |
| Download: ML20210A288 (1) | |
Text
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/ 'o UNITED STATES . ** -*
l 8 NUCLEAR REGULATORY COMMISSION n a WASHINGTON, D. C. 20006 i
\ * . . . * ),'t March 9, 1987 wU j' -
NOTE TO: Hazel Smith, PPAS i
FROM: Michael Masnik TMI-2 PD Technical Assistant
SUBJECT:
FOIA 86-83?
In a note ! sent to you on December 23. 1986. I stated that we were unable l
to locate the attachments to the March 74, 1983 mero from Barrett to Snyder.
Several weeks ago, I found all but one of the attachments. A copy of the letter with these attachments is enclosed. After checking with 01, we have determined that the entire docurrent can be released. ,
I 64 Michael T. Masnik. Technical Assistant.
THI-2 Cleanup Proiect Directorate !
l 8705050055 870309 '
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- _. NUCLEAR. REGULATORY COMMLSSION
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March 24, 1983 o c,,..' -
MEMORANDUM FOR: '
' Bernard J. Snyder, Program Director -
TMI Program Office -
FROM: Lake H. Barrett, Deputy Program Director -
+ TMI-Progranr0ffice - -
SUBJECT:
- SU!HARY OF THIPO SITE ACTIONS RELATED TO THE POLAR CRANE /
,, PARKS' ISSUES The purpose of this memorandum is to document historical information and site TMIPO actions on issues involved with 'the polar crane or related to Mr. Parks' concerns. In general Mr. Parks' concerns has its. roots'in GPU's long standing difficulties to establish good connunications, integrate efforts and promote good working relationships between the various internal Departments e.g.,
Operations and Engineering. Although improvenents in this area have been made
.. in the last year, there is still room for con;siderable improvement.
(Additional background on these interface problems can be found in the Unit 2 ,
SALP report Attachment 1.) _.
Our efforts to get GPU to accelerate improv5nents in this area have been a cor.stant challenge since I was assigned;to TMI. For example, on .
February 16,1983,(2 days before Parks approached NRC) I disapproved an Operations procedure (Attachment 2) because it had technical errors. The root cause cf the errors was poor coordination between the Operations and Engineering Departments. In addition to the disapproval note I also verbally -
told Mr. Kanga, on the same day, that I expected good quality final procedures i
from GPU and that my staff was reporting to me that GPU procedure quality was decreasing. I stated that he should take appropriate action to correct the l
I situation. He said he wo01d look into the matter. I On February 18, 1983, Mr. Parks approached the NRC. Joel Wiebe, U-2 SRI, documented his allegation in Attachment TMfPO infortned the Region and O!
and initiated an inquiry into Mr. Parks',3. concerns.
did any TMIPO personnel disclose Mr. Parks' identity to GPU.At As myno stafftime, to my' know interviewed GPU personnel it was not unconnon for GPU to mention Mr. Parks and Mr. Gischel because the issues we were evaluating were the same issues that Mr. Parks and Mr. Gischel had widely discussed. The results of this inquiry is l
documented in the J. Wiebe memorandum of March 10,1983(Attachment 4). This inquiry was carried out while maintaining contact with Regional investigators.
The chronology of the interviews is as follows:
2/18 Informed-Region 2/22 Wiebe interviews King (Operatiens)
. .. o - Z
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i r'- 2/22 NRC requests internal GPU correspondence on Polar Crane 2/23WiebeinterviewsGischel(O i
2/23Poindexter(TMIPO8ethesda)perations)
. performs surprise inspection of Polar !
CranecalculationsinBechtel!sGaithersburgoffjce(Attachment 5) '
2/24WiebeinterviewsHanson(En .
i 2/24 Wiebe interviews Theising (gineering-Licensing)
Engineerin -
2/24 Wiebe interviews Kitler (Engineering)g) -
j 2/24 Gage /Fasano interview with Fenti and Prabhakar (QA Department-).
i On the afternoon of Februa'ry 24, I caucused the staff and sunnarized our '
, findings and infonned..the Region. With their concurrence we set ~"up~a meeting te tell Parks the results of oufinquiry on Feb7uary 25~ ~
~ ~~~
l l
4 Mr. Arnold and Mr. Clark called at 3:00 PM, February 24 and asked why the NRC had been questioning GPU Operations and Engineering personnel about the Polar
- Crane. I said we were gathering infonnation about safety and I was not at liberty to discuss it, further at this time. They demanded to know if it was an IE 1.nspection NRR technical review or OI investigation. I said I interpreted it as an infomation gathering inquiry to detemine if further NRC action was warranted. They said NRC action had to fit one of their three categories. I
, said I didn't think so but if it made them " feel better" they could call it an
- " inspection" activity. Mr. Arnold then told me they were investigating a .
conflict of, interest with Mr. King and Quiltech. I told him I never heard of
- j, Quiltech and what the NRC was looking at was independent of Quiltech.
I At 7:30 PM Larry King called Joel Wiebrat home and told him his badge had been
- kenandhehadbeenescortedoffsite(Ref.'ReportofAllegation," dated March 1,.1983, Attachment 16). King felt *thi's actien had been taken because he -
had talked with the NRC earlier (Joel. Wiebe had intarviewed him when following j up Parks' concerns on the Polar Crane).
At 8:00 AM, February 25, 1983, I called Mr. Arnold and expressed my concern that GPU employees may interpret Kings suspension as a signal that bringing up
. safety concerns were discouraged by management. He said he was aware of the
! problem and would inform employees that the King suspension was a conflict of interest and not because of safety concerns. i As was arranged the previous day, Wiebe and I met with Mr. Parks in my office
, for over an hour. I told Mr. Parks we found nd evidence of threats but we
- could not on the other hand prove that they did not occur. We found no j irregularities in the calculations at Gaitnersburg. We found no safety issues i that were not already being considered by either GPU or the NRC. We also told J
him that we were concerned with the poor relationships between departments and 3 were concerned with the degradation in quality of procedures. I asked if he
- had any sp.acific safety issues concerning the crane or anything else at THI
- that he thought was unsafe. He said no, but that he just had general concerns about acministrative procedures and harassment. I said that if he made a l formal allegation, I could get an outside investigator to come in if he wanted.
! He declined and said he would rather wait to see what GPU QA would do. We also
- generally discussed the King suspension of the previous night. I told 'him we - -
j would continue to look at the Polar Crane closely in our review process. -
i
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V Although Mr. Parks did not pursue the issue of a formal allegation, there was
- continuing NRC action on closely related items. For example, two formal i
i inspection report items did directly result from our inquiry, Open Items 83-02
- (GPU resolution of. internal safety coments) and 83-03 (Administrative ,
- Procedures /4A) which are documented in our monthly Inspection Report
! 50-320/83-03, dated March 14,1983(Attachment 6). This left these items open j
for possible enforcement action as we gained more information .
In the afternoon of February 25. I met with B. Kanga and J. Barton (Director and Depu1;y Director, Unit 2) to discuss the quality of_ Unit 2 performance. I l
- said EPU employees were upset and. perceived that reprisals would be taken if ~
i
! they raised safety concerns. We discussed the general fin' ding's"of our inquiry I (the same things I told Parks). I said I thought he (Kanga) pushed schedule to i hard and GPU was now in the "no time to do it right but time to do it over* '
j mode. I told them I expected them "to get their house in order pmnto" and i that'I was " doubling the watch" on their activities. I told them the old Engineering / Operations and GPU/Bechtel animosities were a big problem. '
1
- . Also during the week of Febnsary 22, my staff was reviewing, procedures that GPU i j had submitted for approval for future Reactor Coolant System depressurization ,
and partial draindown. These were poor quality procedures and I refused to t
approve them for technical reasons noted in Attachment 7. These deficiencies !
were ccanunicated to GPU in a February 24, 1983, meeting with GPU. In '
! addition, we included the sobject of poor l j March 14, 1983, fonnaT fnspection Report (quality procedures in theAttachme!
~
i enforcement action. . .
l On Monday, February 28, late morning, Mr. Arnold told me about the February.25 -
King / Clark meeting and showed me a copy of Clark's notes. This resulted in the :
1-Arnold / King March 4,1983, letter (Attachment 8). !
On the morning of February 28. King called Region I (R. Keimig) requesting an l l investigation. .
4 K. Christopher (RI Investigator) contacted King and interviewed him
] On itarch2 1,(Attachment 9).
i on liarch l On March 4, 7:00 PM, Mr. Arnold called me at home to say he is initiating a i
special General Office Review Board (GORB) revfew by two non-GPU GORS members
! (Griebe and Lowe). ' Griebe met with Gage Poindexter, and myself on March 22 at
! which time I told him of the inter-departmental problems and lower cuality j work. We did not mention Parks. ,
I On March 7, I called Bill Ward of 0! and said I would like 01 to go with Wiebe to interview King and ask King if we had any additional safety. issues that j weren't already being considered. He said that it was OK for THIPO to conduct i
the interview alone, that the Comission was fully briefed, and that in Ol's
! cpinion this was a lower priority than other jobs. I accepted his judgement i
and directed Fasano/Wiebe.to contact --
King. .- - ._
4 I
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v On March 7 Kanga informed me that Bechtel Auditing was to investigate Parks'
" relationship with Quiltech because a secretary had said that Parks was involved in Quiltech, since Parks, asked her to , type several present GPU employee's
- f resumes on Quiltech, stationary. '
On March 8. GPU staff (Kanga included) infonned the NRC staff (Grant et. al.
and myself) of the action the'y were initiating to improve their procedure ,
quality. I said we would judge them by performance, not by intentions or -
promis,es. , ,
On March 9, 5:00 PM, Fasano/Wiebe met with King in the Middletown Office to review site Operations documents to identify any new safety issues. King made broad general allegations which were femarded to 01 and CIA (Attachments 10 and,11). . .
On M' arch 10 Joel Wiebe met with Rick Parks and Carl Hrbac. Rick Parks said GPU was trying to set him up to be fired for coming to the NRC with his concerns. This is documented in the March 11, 1983, Wiebememo(Attach-ment 12).
On March 10 GPU requested NRC approval of the Polar Crane Generic Operating Procedure (NRC approval of this procedure alone would net pemit use of the crane with significant loads because a load specific procecure would also be requi red). I did not approve the procedure because of the technical deficiencies'noted in Attachment 13. M renths of NRC personnel monitoring and~y ccmenting disapproval on GPU's of this preced efforts to develop detailed crane procedures. As a policy,1*have not discouraged GPU from providing internal drafts of GPU documents, e.g. technical plans, safpty '
evaluations, schedules, procedures, and NRC submittals to my s*aff on an informal basis. My staff sees thousands of internal documents to keep abreast '
of the multiple cc= plex technical issues being worked on in the cleanup. !
have instructed them that when they read this, information and they find things that they have safety concerns about, they should infom GPU, at the working level (Engineer-to-Engineer), about their cencerns. This is often done verbally or in hand writing on the GPU document that they are looking at.
These are not considered as formal NRC reviews but do serve to identify safety issues as early as possible so that GPU can promptly address them to avoid unnecessary cleanup delays. This thorough NRC staff technical involvement also results in a more detailed technical knowledge'of alternatives considered and all aspects of safety.
The Polar Crane procedures have had a longer than usual history when compared to similar technical evolutions, e.g. EPICOR prefilter inerting ano waste water processing system;, etc. GPU provided my lead site engineer on the Polar Crane ;
(Les Ga GageandPoindexter(Bethesda i TMIPO) ge) more than the usual number of drafts. reviewed nultiple proced '
cements written in the margins and general hand written cements. An example I I
of this is Attachm. int 14 where Gage and Poindexter identified a lot of c:ments.. This was no surprise because the Polar Crane procecure cevelc; ment has experienced significant problems as was indicated at the January 12,*1993, GPU eeeting (Attachment 15).
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g On March 18, R. Arnold called me and stated he had received a letter from Morris K. Udall regarding an inquiry of the Comittee on Interior and Insular Affairs into the TMI-2 accident and cleanup. A copy of this letter is shown in
' Attachment 17. (Note the names that'Udall requested are all associated with the " Mystery Man" during the accide,nt.)
f The above has been a summa'ry of the NRC onsite.iactivities up.to March 22, 1983. '
I have not approved the use of the Polar Crane for lifting loads (except "no Joad' refurbishment tests and with a marpal 5-ton hoist,'for small loads not
- nearthereactor). Until GPU adequately resolves all open issues with the polar crane, I will not approve its use. , ,
I will contiinue to constantly push GPU towards higher quality work. We will only approve cleanup operations that maintain public health and safety and accelerate the cleanup. As all of the above illustrates it not easy to accomplishthisobjective("pushonarepe"). Our response to the Parks statement is pr'sentlye being fonnulated. -
. Lake H. Barrett Deputy program Director TMI prograin Office P.S. All of the above is nott:ypical at THI-2. We just don't usually get this much attention. .
Attachments: .
As Stated .
cc w/ attachments: '
R. Haynes H. Denton J. Fouchard K. Christopher '
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4 6
.I ' ATTACHMENT 1
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Oceket No. 50-320 9 .eg ,
GPU t'uclear Corporatien l ATT:i: Mr. R. C. Arnold '
l President l P. O. Box 480 Middletown, Pennsylvania 17057 l
Gentlemen:
Subject:
Systematic Assessment of Licensoe Perfemance (SALP)
This letter fonverds the results of our annual SALP for the Three !!11e Island Nuclear Station Unit 2 and includes: a list of attendees who participated in discussions held at Three Mile Island on Decem.ber 10,1902, regarding the assessment (Enclosum 1); the SALP mport (Enclosure 2) which contains our assessment of CPUN perfomance for the period Octcher 1,1981, through Septeator 30,1932 including sup]Iccents to our report which are identified elsewhere in this letter; and, tie December 30,1932, GPUN 1sttor (Enclosure 3 which was provided in response to our request of December 6,1932 (Enclos ,
!n the December 10,1932 meeting, the discussions focused on the SALP Coard Report and your efforts to improve perfomance. We have considered the GPUtl coments regarding our assessn'ont and we acknowledge your comitments for per-femance improvement, your clarification / amplification of certain points con-tained in our report which characterized GPUM intentions, and your perspective
. en certain other matters.
Overall, we find your perfomance or licensed activities indicates a high degree of manage ent attention and involvement and that it is agcressive and oriented toward nuclear safety, with adequate soplication or resources. In the areas of Plant Operations Engineering Design and Modificatien, Radio- ;
logical Controls and Licensing Activities, we note that better ccmunication i aneng departments and better integration of these departnants into the GPUti .
organization would have enhanced your perfomance in these areas. L'o also - !
acknowledge your recognition of those problems which led to the Unit 2 recitani-zation toward the end cf our assessment period'in an effort to correct the situation.
l In response to coment 3.C of your Cecember 30,1080, lotter, we agreo that in a majority of cases, some corrective action is proceeding even uhon the r,utnittal of responses to Notices of Violation is late. He look fonvard to more timely <
responses with the consolidation into one depart:wnt of the previously seoarate Ortups responsible for this effort. De also 40 roe that often the reason for ox.
coeding the time requirement is CPUN's desire to cbtain additional infomstion and asserble a quality response, but point out that effective corrective action st be timely and not dolayed awaiting receipt of the addittenal infomation.
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Af ter obtaining a better understanding of the overall problem in the functional area cf Licensing Activities, as discusseo in cur meeting of Ccccmber 10, 1982, and reviewing c:=ents 1 and 3 in ;> cur December 30, 1982, letter, the SALP Board reconvened to reassess this area. That reassessment .
also took into acccunt your recegniticn of probisms, during the assessment i
period, related to c munication ano organi:aticnal integration which led to the reorgani:ation of T111-2 management tcward the era of the assessment l
period. Based upcn these consideratiens and the fact that cur onsita stcff
' nss also noted improvements in this area, the SALP Scard has concluded the furetional area of Licensing Activities to be Category 2 anc we have supplemented our report acccraingly, f Also, as discussed in our December 10 1982, meeting, we agree that the first l
and second paragraphs in the functional area of Security and Safeguards I (Arca7)neededclarification. Wa, therefore, have revised those paragraphs and supplemented our report accordingly. Further, the point made in cement I cf your December 30, 1982, letter is well understced and has also been reficcted in a supplement to our report (Area 1).
i We censider that our meeting was beneficial and ircreved our mutual under-standing of your activities and our regulatory program. Based on ycur coments during the meeting and your December 30, 1952, letter, we supple-nented the SALP Dcard Report as discussed above. flinor editorial and typographical corrections, that did not affect cur assessment or conclusions, have also been c:Adc.
19 acecrdance with 10 CFR 2.790(a), a copy of this lotter and its enciesures will be plcced in the NRC Public Document Recm. Ito reply to this latter is ,
- r1guired.
! Ycur coeperation with us is appreciateo.
Sincerely, o r stas; f.tse.ea b y s.tw
/.cnaldC.'Haynes h
P
'f/ Regional Administrator
/
l Enclosures I ,
- 1. List of Attendees
- 2. SALP Report t.no supplements
- 3. GPUN Letter of Daccreer 30,1982 4 NRC 1.etter of Occomber 6,1932 l
OFFICIAL RECORD COPY
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s' ,
GPut;uclear Corpcratien cc w/oncl:
B. K. K:nga, Director, Titl-2 J. J. Barton, Deputy Director, T:il-2 L. P. King, Site Operations Director J. E. Larson, Licensing end !!uclear Safety Director ,
i J. J. Byrne, l tanager, Th!-2 Licensing
! J. W. Thicsing,lianagar, Recovery Programs E. G. Wallace, Manager, P',lR Licensing J. 3. Liberman, Esquire G. F. Trowbridge, Esquire Puolic Document Roen (POR)
Lccal Public Occument Rcom (LPOR) fluelear Safety Infomation Center (ftSIC) t'RC Resident Inspector Cetuonwealth of Pennsylvania
!!s. Mary V. Southard, Cc-Chaiman, Citizens for a Safe Envircrr.ent (withoutreport) l l
l I
bec w/ enc 1:
Region 1 Docket Room (with concurrence)
L. Barrett, Deputy Program Director, TMI Prog (am Office J. Goldberg, OELD:HQ Chief, Operational Support Section (w/o encl) fis, Mary V. Southard, Co-Chairman, Citizens'for a Safe Environment l
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o Enclosure 1 LIST OF ATTENDEES GPU Nuclear Corporation R. C. Arnold, President B. K. Kanga, Director of TMI-2 J. J. Barton, Deputy Director, TMI-2 R. L. Long, Vice President, Nuclear Assurance J. E. Larson, Licensing and Nuclear Safety Director J. J. Byrne, Manager, TMI-2 Licensing J. W. Thiesing, Manager, Recovery Programs R. W. Heward, Jr., Vice President, Radiological and Environmental Controls Division U.S. Nuclear Reculatory Commission R. W. Starostecki, Director', Division of Project and Resident Programs L. H. Barrett, Deputy Program Director, TMI Program Office R. R. Keimig, Chief Projects Branch No. 2, DPRP A. N. Fasano, Chief, Three Mile Island-2 Project Section, DPRP l R. R. Bellamy, Chief, Technical 3upport Section. TMIPO l R. J. Conte, Senior Resident Inspector (TMI-1) ;
J. S. Wiebe Senior Resident Inspector (TMI-2)
T. C. Poindexter, Licensing Project Manager 1
. . . . - --. . . . . . _ . ~
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' Enclosure 2 ,
i i
i U. S. NUCLEAR REGULATORY COMMISSION -
REGION I 1
1 1
j SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
GPU NUCLEAR CORPORATION .
THREE MILE ISLAND UNIT 2 f' ,
i November 15, 1982 l-5 i -
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TABLE OF CONTENTS Page I. Introduction .1~
4 II. Summary of Results 6 .
I III.-Criteria '7 IV. Performance Analysis 8 1
- 1. Plant Operations 8
- 2. ~ Radiological Controls 13
- 3. Maintenance. .
17 Preoperational Testing and Surveillance 20
- _4
- 5. Fire Protection and Housekeeping 21
- 6. Emergency Preparedness 23
- 7. Security and Safeguards 25
- l. .
- 8. Engineering Design and Modification.- 26 i
- 9. Licensing Activities 28
- 10. Quality Assurance / Control 30-j V. Supporting Data and Summaries 32 l
l 1. - Licensee Event Report Tabulation and Causal Analysis 32 l 2. Investigation Activities 32
- 3. Escalated Enforcement Actions 33 l
- 4. Management Conferences During the Assessment P.eriod - 33 l l . .
! TABLES Table 1 - Inspection Hours Summary 1-1 Table 2 - Inspection Activities 2-1
- Table 3 -
Enforcement Data 3-1 Table 4 - Tabular Listing of LERs by Funct'f onal Area "
4-l'
- 1 Table 5 - LER Synopsis 5-1 l
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I. INTRODUCTION
- 1. Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations on l
an annual basis and evaluate licensee perfontance based on those -
cbservations. The objectives of the SALP is to improve the NRC Regulatory Program and Licensee performance.
The assessment period is October 1, 1981, through September 30, 1982.
Since this is the first SALP to be performed on Three Mile Island Unit 2 (TMI-2), this assessment contains significant background material and pertinent observations identified prior to the
- assessment period. Significant findings of the assessment are provided in the Performance Analysis Functional Area (Section IV).
Because of the relatively high activity level in the Engineering Design and Modification and in the Quality Assurance functional areas at TMI-2, these areas are reviewed separately. These functional areas more accurately address the significant engineering effort needed to decontaminate various systems, process radioactive water, and develop plans for the removal of the damaged fuel in the reactor -
vessel.
Evaluation criteria used during the assessment are discussed in Section III below. Each criterion was applied using the " Attributes for Assessment of Licensee Performance" contained in NRC Manual Chapter 0516. I
- 2. SALP Attendees ,
i Board Members l
l R. W. Starostecki, Director, Division of Project and Resident i l
Programs (DPRP)
T. T. Martin, Director, Division of Engineering and Technical Programs (DETP)
R. R. Keimig, Chief, Reactor Projectg Branch No. 2. DPRP l R. J. Bores, Chief, Radiological Protection Branch, DETP l A. N. Fasano, Chief, Three Mile Island-2 Project Section, PB No. 2 T. C. Poindexter, Licensing Project Manager, TMIPO J. S. Wiebe, Senior Resident Inspector, TMI-2 Other NRC Attendees l
l M. M. Shanbaky, Chief, Radiation Protection Section, DETP.
R. J. Conte, Senior Resident Inspector, TMI-1 i
l
2
3. Background
(1) Licensee Activities As a result of the March 28, 1979, accident, the plant was in a cold shutdown condition during the entire assessment period.
Pre-Assessment Period (March 29, 1979, through September 30, 1981)
(a) Decentamination of Auxiliary Building and Fuel Handling Builcing Water Following the accident, about 450,000 gallons of centami-nated water were held in various tanks and sumps in the Auxiliary and Fuel Handling Buildings at the plant. To-decontaminate this water, the licensee installed a three-stage demineralization system called EPICOR II. -
Folicwing the NRC Memorandum and Order of October 16, 1979, which directed tha't the EPICOR 11 system be used, the licensee began processing the contaminated water.
l The processed water is being held in storage tanks at the site. The spent resins from this system were_dewatered and .
placed in concrete structures to provide environmental protection and radiation shielding.
The Commission's October 16, 1979, Memorandum included a provision requiring that spent EPICOR II resins not be shipped off site unless solidified. On February 19, 1981, '-
the licensee requested that the requirements for solidification of spent EPICOR II resins be waived and that those spent resin liners which are similar to normal reactor resin wastes be disposed of by shallow land burial at a commercial d.isposal site. The NRC staff reviewed the licensee's request and concluded that 22 of the spent resin liners could be disposed of by burial at a commercial burial site in an unsolidified but dewatered condition.
NRC approval to ship these , liners was issued on March 25, 1981. The last of these 22 liners was shipped from the plant on June 27, 1981.
The remaining EPICOR II spent resin liners (50) from the '
processing of the Auxiliary and Fuel Handling Buildings water are unique ard unlike those routinely generated and disposed of by other nuclear power plants. The requirement to solidify the resins in these liners was also waived so that future options for handling and eventual disposal of these wastes would not be foreclosed. The Department of Energy (DOE) agreed to take possession of these unique liners for research and development. On May 19, 1981, the first of these liners (PF-16) was shipped to a DOE
- contractor laboratory in West Jefferson, Ohio.
. .. 3 ,
(b) Decontamination of High Activity Water Approximately three quarters of a million gallons-of.
high-activity-(greater.than 100 uCi/ml) water were generated as a result of the accident on March 28, 1979. 3 The water was located in the Reactor Building basement and' the Reactor Coolant System (RCS). .To decontaminate this water, the licensee installed the Submerged Demineralizer System (SDS) in one of.the spent fuel pools. The system uses filtration and ion exchange ~ processes with a zeolite medium-to decontaminate the water. The treatment equipment i is submerged-in water for radiation shielding purposes.
The licensee co:m:enced processing the high activity water in September 1981.
After being processed through the SDS, the water was polished by the EPICOR II system and-then transferred to the Processed Water Storage Tanks for onsite storage. The spent resin liners generated by the EPICOR II system are similar to normal reactor resin wastes:and can.be disposed of at a commercial disposal site. Due to the unique
' character and nature of the wastes generated by the SDS, the Department of Energy.will take possession of and retain -
these wastes to conduct a research, development and testing
. program on waste immobilization.
(c) Reactor Building Decontamination Before defueling operations can proceed, airborne radio-4 activity levels, removable radioactive surface- ,
contamination levels, and general area radiation levels in '
the Reactor Building need to be reduced. Purging of the .
Reactor Building atmosphere'to remove Kr-85 began on :
June 28, 1980, and by' July 11,-1980, was essentially .i complete.
Assessment Period (October 1, 1981, through September 30, 1982) 3 (a) Decontamination of Auxiliary Building and Fuel Handling Building Water l l Forty-nine of the spent resin liners generated by the ;
EPICOR II system during the processing of the Auxiliary and '
~
Fuel Handling Buildings water were on site at the beginning l of the assessment period. Because of combustible gas 1 generation in the liners from radiation induced degradation of the resin and disassociation of water, the licensee instituted a. program to monitor and evaluate combustible gas generation. When necessary, the liners- are purged 'and inerted with nitrogen. To ensure no oxygen is introduced into liners during transport, the cask used to transport the liners is also filled with nitrogen. . On .
August 25, 1982, the first of the 49 liners was shipped from the site. l 1
I i
-4 (b) Decontamination of High Activity Water Removal of- the water from the Reactor Building was essentially completed on May 2,1982. Additional water is
~
! continually added to the Reactor Building sump by RCS
!' leakage and decontamination activities-in the Reactor Building. -
On May 17, 1982, processing of.the RCS water commenced. ;A J feed and bleed of the RCS is used to stage. water for the SDS and then the water is processed through the SDS. The processed water is then used as feed for the next feed and bleed cycle. Processing of.the RCS water is ongoing except for interruptions caused by . higher priority operations which interfere with the feed and bleed process.
i (c) Reactor Building Decontaminatioh During March 1982, a decontamination experiment'was- ,
performed to evaluate various decontamination methods in
- the Reactor Building. Using the results of the experiment, the licensee commenced major decontamination activities in the Reactor Building in September 1982. The decontam-ination activities are designed to reduce airborne radioactivity levels in the Reactor Building, reduce surface contamination levels and reduce general area.
radiation levels. This should allow a' reduction in I protective clothing requirements and respiratory protection l
requirements. 1 (d) Evaluation of Core Damage - -
On June 23, 1982, the licensee started an attempt to' insert the eight Axial Power' Shaping Rods (APSRs) which remained:
in the twenty-five percent withdrawn position during and . l following the accident. Because the condition of the APSRs- :
is not fully-known,- it is not known if the APSRs or only 1 their leadscrews were moved. Two of the APSRs (leadscrew')- s were driven in to'the fully inserted position, two of the APSRs (leadscrews) would not move in at all, and the other four APSRs (leadscrews) moved in part way and stuck in a position between 25 percent withdrawn and the full in position. This evolution was completed on June.25, 1982. ,
During the week of July 11, 1982, the licensee depressur-ized, vented, and partially drained the RCS in preparation for inserting a closed circuit television (CCTV) camera into the core. During the' week of July 18, 1982, the; y control rod drive mechanism (CRDM)~ leadscrew was removed
! CCTV camera showed a bed of rubble-approximately five feet below where the top of the core should be. During the week of August 1,1982, CCTV inspecticns of the periphery and halfway between the periphery and the center of.the core i
M
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1 .
,h' '
showed the bed of rubble at the halfway point was still approximately five feet below where the top of the core should be but the CCTV camera could not be lowered below the top of.the core'at the periphery. .
. (2) Inscection Activities .
Two resident inspectors were assigned on site from-November 15, 1981, to September 30,.1982. Prior to this time, one resident inspector was assigned to TMI-2. In addition, a senior radiation specialist and two to three radiation specialists were assigned on site for the entire assessment period. Also located on site were representa-L tives from the Three Mile Island Program Office (NRR).
Total NRC inspector hours: 2294~(resident and regional based). Distribution of inspection' hours is shown in Table 1.
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A tabulation of inspection activities is shown in Table 2,
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and a tabulation of violations is shown in Table 3.
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4
. . . - . .=. . . . . _ _ _ -
6
=
't.
SUMMARY
OF RESULTS FUNC;' NAL AREAS THREE MILE ISLAND U'llT 2-CATEGORY: CATEGORY CATEGORY 1 2 3 I
Plant Operat' ns x
- 1.
Radiological Cont is x f 2.
, _' Radiation Protecti
' Radioactive Waste Man ement
- Transportation
- Effluent Control and Monit ing '
- 3. Maintenance Ns x-
- 4. Surveillance (Including Inservice and Preoperational Testing) x N x I 5. Fire Protection N<
- 6. Emergency Precaredness x\Ns
- 7. Security and Safeguards .x Ns
- 8. Engineering Design and Modification -x *Ns N
- 9. Licensing Activities Nx t
)
\N
- 10. Quality Assurance / Control -x s ss 1
{,
! , l i
l 4
- l 4
i Refer to Supplemental Page 6A Y
)
e i
.. - - _ , , _ - _ , . _ - - .....,,._--..,_,_e - . _ , _ . , _ . ., - - . . ~ , - . . , . . . . , .;__ . . . . _ - . . . . - . _ - . . ,
t
- 6A Sucolement to the TMI-2 SALP II. SUf01ARY OF RESULTS FUNCTIONAL AREAS THREE MILE ISLAND UNIT 2 CATEGORY CATEGORY CATEGORY l 2 3 Plant Operations x 1.
- 2. Radiological Controls x
' Radiation Protection
- Radioactive Waste Management
' Transportation
- Effluent Centrol and Monitoring x
- 3. Maintenance 4 Surveillance (Including Inservice and Preoperational Testing) x Fire Protectios x 5.
- 7. Security and Safeguards x Engineering Design and Modification x 8.
Licensing Activities x , l
- 9. ,
- 10. Quality Assurance / Control x I
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1 f
1
7 III. CRITERIA The following evaluation criteria were applied to each functional area:
- 1. Management involvement in assuring quality.
- 2. Approach to resolution of technical issues from a safety standpoint.
- 3. Responsiveness to NRC initiatives, c 4 Enforcement history.
- 5. Reporting and analysis of reportable events.
- 6. Staffing (including management).
- 7. Training effectiveness and qualifica, tion.
To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics applicable to Categories 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part 11 and Table 1.
The SALP Board conclusions were categorize' d as follows:
Category 1: Reduced NRC attention may be appropriate. Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved. ,
Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not effectivel:e used such that minimally satisfactory performance with respect t3 operational safety and ccnstruction is being achieved.
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1 1
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. . 5 IV. Perfermance Analysis
- 1. Plant Ooerations Analysis NRC site staff reviewed plant operations by frequent in plant .
observations, review of records, verification of procedure implementation and daily attendance at licensee planning meetings.
The licensee's upper management continues to be dedicated to developing and maintaining an effective and efficiently working staff. The technical problems inherent in the TMI-2 recovery program has severely taxed the financial and technical resources of the utility. The utility has compensated by issuing contracts for major recovery operations, by establishing technical advisory committees such as the Technical Assistance Advisory Group (TAAG), and by effectively utilizing available government expertise through the Department of Energy's research activities.
Problems attributed to management control were caused by ineffective communications between departments and also by ineffective inter-department integration. Problems in this area include:
-- ineffective communication and integration of efforts between Operations, Plant Engineering, and Radiological Controls during the January 8,1982, event. During this event bypassing of filters occurred and an effluent monitor detected a small amount of particulate being released from the stack. Good communications between departments would have revealed that the
- air filtration system was not performing as designed. However,'.
the NRC had to initiate communications between the above departments to solve the problem.
-- ineffective communication and integration of efforts between Operations, Recovery Programs, and Radiological Controls in establishing an overall program to reduce Reactor Building general area radiation levels. Considerable effort has been expended by the licensee to improve the radiological conditions inside the Reactor. Building by Qashing surfaces with low and high pressure water flushes. This program to date has not been effective in reducing general area gamma radiation levels.
Little effort has been expended by the licensee to analyze the gamma sources inside the Reactor Building to determine why gamma ,
fields have not been reduced by the draining of the highly 1 centaminated water from the sump and gross washdown of the building. Increased management attention to assure integration of efforts from various GPU departments (e.g., Recovery Programs and Radiological Controls) is necessary to assure that an l effective ALARA program is maintained for major cleanup activity l I
decisions, such as implementing dose reduction activities in addition to other cleanup activities. f l
l
s' 9
--- ineffective cor=unication and integration' of efforts between - -
Operations, Plant Engineering, and Radiological Controls'in.
determining the source of the radioisotopes in the test borings and air intake tunnel. ' Again, the NRC initiated action to solve the problem by initiating communications between the departments. '
The li nsee management has revised the organization of their resourc' , including contractor resources, as changing functions'and changing regress on the TMI recovery program have dictated that changes we needed. The use of many contractors with diverse expertise an several reorganizations has made management difficult, but the licen ee' continues to make progress towards an effective '
organization. ~he most consistent problem noted during the _
assessment perio appeared.to be the inability of upper management to 2
effectively comu icate their philosophies and dedication downward through multiple la ers of contractor and licensee management to the worker. In an attem t to alleviate this problem, the licensee has appointed a contracto manager to.be the Director of TMI-2. These -
individual reports dire tly to the Office of the President, GPU Nuclear Corporation.
i - Operating procedures submit ed by the licensee pursuant to Technical Specification 6.8.2 were rev wed by the TMIPO. Procedure adequacy.
and implementation were a prob em prior to the assessment period and continued to be a problem throu the assessment period. Examples.of
- problems in the area of procedur adequacy include
-- Submerged Demineralizer System SDS) procedures contained incorrect valve lineups and inco sistent sequencing of steps for
~ ~
- similar evolutiens. -
-- Procedures for " Quick look" evolutio s (1) did not require periodic sampling of void s' paces in t Reactor Coolant System (RCS) for combustible gas, (2) did not rovide sufficient '
r technical guidance for obtaining a repre ntative RCS liquid
! sample, and (3) caused three Limiting Con tions for Operation as described in Technical Specifications to be exceeded.
s Problems in the above area were the subject of one iolation during i the assessment period. Since the TMIPO reviews many f these procedures, most problems with procedure inadequacy a corrected prior to the licensee issuing the procedure. -
In the area of operating procedures, some implementation pgoblems were noted, such as: failure to properly implement Submerghd Demineralizer System (SDS) procedures and failure to properl l implement Reactor Building purge procedures. Operating proce re implementation appears to have improved since no violations occ'o(red in this area during the present assessment period. In the 12 mon hs 3 -
prior to the assessment period, 2 violations occurred in this area and in the 12 months preceding that period, 2 violations occurred.
4 Refer to Suppler. ental Page 9A, 4
9A Sucolement to the TMI-2 SALP
-- ineffective communication and integration of efforts between Operations, Plant Engineering, and Radiological Centrols in determining the source'of the radioisotopes in the test borings and air intake tunnel. Again, the NRC initiated action to solve the problem by initiating communications between the departments.
The licensee management has revised the organization of their resources, including contractor resources, as changing functions ano changing progress on the TMI recovery program have dictated that changes were needed. The use of many contractors with diverse expertise and several reorgani:ation; has made management difficult, but the licensee continues to make progress towards an effective organi:ation. The most consistent problem noted during the assessment period appeared to be the inability of upper management to effectively communicate their philosophies and dedication downward through multiple layers of contractor and licensee management to the worker, in an attempt to alleviate this problem, the licensee has appointed a contractor manager to be the Director of TMI-2 and integrated the GPU and contractor staffs. The Director of TMI-2 reports directly to the Office of the President, GPU Nuclear Corporation.
Operating procedures submitted by the licensee pursuant to Technical Specification 6.8.2 were reviewed by the TMIPO. Procedure adequacy and implementation were a problem prior to the assessment period and continued to be a problem through the assessment period.- Examples of problems in the area of procedure adequacy include:
-- Submerged Demineralizer System (SDS) procedures contained incorrect valve lineups and inconsistent sequencing of steps for,-
similar evolutions.
-- Procedures for " Quick Look" evolutions (1) did not require periodic sampling of void spaces in the Reactor Coolant System (RCS) for combustible gas, (2) did not provide sufficient technical guidance for obtaining a representative RCS liquid sample, and (3) caused three Limiting Conditions for Operation
, as described in Technical Specif,1 cations to be exceeded.
Problems in the above area were the subject of one violation during the assessment period. Since the TMIPO reviews many of these procedures, most problems with procedure inadequacy are corrected prior to the licensee issuing the procedure.
In the area of operating procedures, some implementation problems were noted, such as: failure to properly implement Submerged Demineralizer System (505) procedures and failure to properly implement Reactor Building purge procedures. Operating procedure implementation appears to have improved since no violations occurred in this area during the present assessment period. In the 12 months prior to the assessment period, 2 violations occurred in this area and in the 12 months preceding that period, 2 violations occurred.
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10.
t in the area of administrative procedures, some implementation 1
problems were also noted during this assessment period and include
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the following.
-- Failure to properly complete and properly change procedure 50P-2-82-016 .
-- Failure to properly change radiological limit on trash compacting procedure
. -- Failure to properly revise procedures Problems in the above area were the subject of one violation during
?-
the assessment period and the subject of two violations in the twelve 1,
months preceding the assessment period.
To improve the quality of procedures and administrative procedure i implementation, the licensee is preparing a Technical Specification change request which will allow dismantling the Plant Operations Review Committee and the Generation Review Committee (both are part 4 time committees) and replacing them with a full time standing group (Safety Review Group) to parform the safety review function. In -
addition, the change request includes revisions to increase control 4 over temporary changes to procedures.
The resident inspectors and the TMIPO Technical Support Section engineers inspected personnel training associated with specific new systems and special evolutions to ensure such training was adequate.
No significant problems were found. More generally, however, it can ,
be inferred from the problems evident in procedure adequacy and implementation, that training in administrative controls, especially for vendor or contractor personne.1, could be improved. The problem j appears to occur when vendor or contractor personnel (such as
- engineers) are tasked to provide procedures for new systems and special evolutions, and there is no one specifically designated to review the resulting procedure for conformance to TMI-2 administrative controls. As a result, there is no " normal" valve i lineup for plant conditions and no convention as to which valves I should be checked prior to an evolution or what valves should be checked after the evolution This has caused such problems as an ,
improper valve lineup which resulted in a high RCS leak rate. This I was adequately critiqued by the licensee and adequate corrective .
- actions were developed. This type of problem is compounded by turnover of personnel and reorganization.of functions.
A causal analysis of Licensee Event Reports (LERs) submitted during the period was conducted. A tabular listing of LERs by functicnal areas is given in Table 4, and a synepsis of LERs .is given in Table 5. Two LERs involved lightning strikes close enough to the air i intake structure to cause actuation of the Air Intake Tunnel-(AIT) l Halon System, actuation of the AIT Deluge System, and tripping of the j Auxiliary and Fuel Handling Building supply and exhaust fans. The lighting strikes occurred during infrequent severe thunderstorms and i
- r.
- 11 pose no safety concerns. The licensee secured the AIT Deluge System and the AIT Halon System and restarted the fans which tripped. No further action appears to be necessary.
Three LERs involved incperability of the AIT chlorine monitor caused by component failures. The component failures were identified by routine surveillance (in two of the cases) or by a failure alarm (in one of the cases). The failures do not appear to be interrelated and no further failures have occurred. The licensee has replaced the applicable components. No further action appears to be necessary.
Two LERs involved failure of incore thermocouples. The failures are attributable to degradation of the thermocouples following the accident on March 28, 1979. The degraded condition of the core, as evidenced by the " Quick Look" evolution, has caused displacement o'f the thermocouples from the top of the fuel assemblies. These thermocouples are very likely exposed to the water in the Reactor Coolant System. As a result, thermocouple failures are expected and it is not practical to repair the thermocouples. The licensee is planning to insert an additional thermocouple into the reactor coolant above the " core rubble bed" to confirm actual reactor coolant temperature. .
Eleven LERs involve inoperability of the Fuel Handling Building
! and/or Auxiliary Building Ventilation Systems as a result of I personnel error during maintenance, . failure of ccmponents, failure to maintain the system as designed or overly restrictive technical
< specifications. The causal link involved appears to be licensee inattention to the systems. The result is personnel unfamiliarity with the systems, lack of development of a preventive maintenance ,
program on the systems, and overly restrictive technical specifications. To correct the above, the licensee is assigning an engineer to be responsible for these systems, is establishing a preventive maintenance program on these systems, and has requested and received approval to revise the Technical Specifications. The NRC is following these corrective actions.
Three LERs involved inoperability of meteorological instruments caused by icing. The licensee is ins,talling heat tracing to eliminate the problem.
In summary, the licensee is adequately managing a difficult and unique recovery program. Management is frequently involved with site activities. Operations staffing and training are adequate to support l the various special evolutions of TMI-2 recovery, l
Conclusion l l
Category 2 l
. 12 Board Recommendation Review implementation of Technical Specification Section 6 early in 1983 to verify effectiveness of the recent reor5anization for forthcoming evolutions. Routine operation inspections should be continued.
e I
13
- 2. Radiolocical Controls Analysis This analysis is based on one special inspection of all outstanding items rega-ding the Unit 2 Radiological Protection Program (including programmatic areas), two special inspections regarding the Reactor Building Entry Program, one followup inspection regarding entries into the makeup valve room (1979-1980), and one special inspection regarding transportation activities.
Analysis, in this area, does not include an assessment of how effective the Radiological Controls Department is when working and communicating with other departments for advance planning or event analysis. The problems in working and communicating with other departments, to provide an integrated program, is perceived as a management problem and is discussed in the functional area of plant operations.
The areas of radiation protection, radioactive waste management, effluent control and monitoring, and transportation are under continuous ' review by the site radiation specialists, and reported in -
monthly inspection reports.
Radiation Protection The licensee has established a strong health physics organization and program. A staff of more than 65 is engaged in radiological protection for TMI-2.
Three Severity Level IV and two Severity Level V violations were identified. During the unscheduled Reactor Building entry on September 3,1981, an individual violated a Radiation Work Permit (RWP) by nct having an escort, and by removing sludge sampling i equipment from the building. These RWP violations were identified by I the licensee. In a subsequent inspection, the NRC identified a failure to survey the sampling equipment prior to removal of the equipment from the building.
- The licensee authorized an entry into' the Reactor Building on ,
I February 24, 1982, but did not control the entry sufficiently (i.e. ,
was not controlled by the Command Center). Subsequent to this event, ;
the licensee initiated corrective action to prevent recurrence or repetition. The NRC addressed the repetitiveness of the problem via 10 CFR 50, Appendix B, Criterion XVI, after a similar insufficiently controlled entry occurred on March 25, 1982. This second occurrence indicated a failure to institute adequate corrective actions regarding the February 24, 1982, entry.
The licensee and the NRC identified that, on one occasion, individuals had entered a RWP area (a calibration facility) without obtaining personnel monitoring devices and without obtaining a RWP.
14 During July 1982, the NRC identified a procedural inadequacy regarding self-reader dosimeter recalibration and instrument recall frequency.
The licensee developed and tested the following innovations in the area of radiation protection.
-- Instituted a comprehensive man-rem tracking system for TMI-2 activities
-- Successfully developed a new beta / gamma personnel monitoring system (TLD)
-- Mandated use of digital dosimeters during each Reactor Building entry
-- Involved use of radiological engineers in all major radiological work activities Less than 300-man-rem were expended at TMI-2 for the period October 1,1981, - September 30, 1982.
Radioactive Waste Manacement One violation, Severity Level V, was identified (no procedure for testing the integrity of in-place high efficiency particulate absolute (HEPA) filters for vacuum cleaners when used in dry vac mode). In response to the violation, the licensee developed and 4 implemented a procedure to test these filters.
A noticeable improvement was made by the licensee in the radioactive waste management area. During this assessment period the licensee has shown a significant improvement in radioactive waste volume reductien, radioactive waste tem'porary storage / staging facilities, and waste compacting facilities. The construction of an interim solid waste storage facility was completed. The new facility will be ;
used for temporary storage / staging of low level radioactive waste and '
low specific activity (LSA) drums and boxes. l 1
The Submerged Demineralizer System (SDS) generated liners with high curie loading of fission products. These liners are temporarily stored under water in the modified spent fuel pool. The SDS generated liners will be taken by the Department of Energy (DOE) for ,
vitrification. .
The resin liners, generated from the operations of EPICOR II, are temporarily stored in the interim weste modules. Some of these liners will be taken by DOE to be used for research purposes and the rest will be disposed of at a commercial burial facility, i
. 15 The licensee has successfully processed the TMI-2 Reactor Building (RS)sumpwater(approximately 600,000 gallons). Over 200,000 gallons of contaminated RCS water has been pro:essed successfully through the SDS by feed and, bleed.
In summary, the radwaste management problems at TMI-2 are unique and complex. However, the licensee's performance in this area during the -
assessment period was very good.
Effluent Monitorino and Centrol This area was continually reviewed by the onsite NRC staff during the current assessment period to assure that the . conditions on the City of Lancaster Acreement, regarding accident generated water, were
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- followeo.
The licensee has established a program for periodic testing of in-plant, noncontaminated systems. Early in 1980, the licensee established a program to assess Reactor Building integrity by periodic sampling of onsite ground water.
The NRC sta~ff completed review of the following GPU Quarterly Dose Assessment Reports for TMI-2. -
Report for the period October 1,1981, to December 31, 1981 Report for the period January 1, 1982, to March 31, 1982 Report for the period April 1, 1982, to June 30, 1982 The reported effluent releases and corresponding calculated doses in each report were small fractions (less than 1*.) of the TMI-2 ,
Technical Specification limits for annual averaged releases.
No violations in this area were identified during the current assessment period. Licensee perfortnance was very good.
Transportation During the current assessment period, 198 shipments of radioactive material were made (TMI-1 and TMI-2). , The site radiation specialists inspected 100T, of these shipments.
Two Severity Level IV violations were identified: (1) licensee shipping cask gasket inspections aid not have acceptance criteria, and (2) a defective gasket for a cask cover was used for a radio-active material shipment. The NRC conducted a special transportation '
inspection following the temporary revocation of TMI-2's burial permit at the US Ecology site, Hanford, Washington. The licensee has
- shown significant improvements in the area of transportation of I radioactive materials. TMI-2 successfully shipped 22 second and third stage, and 18 polishing resin liners (dewatered) from the EPICOR II System. Initial shipments, in conjunction with DOE, of the first stage EPICOR II liners were also acccmplished.
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. i A 16 Conclusion Category 1 Board Recomendation In view of the continuing unique radiological co.'ditions at TMI-2, the present onsite radiation specialist coverage of TMI-2 evolutions should be continued. Inspection time within this 'unctional area should be reallocated.
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- 3. Maintenance Analvsis .
Resident inspector attention to this area was limited as a result of priority monitoring of TMI-2 recovery activities. Maintenance activities which were reviewed included: (1) followup to a High Radiation Airborne Contamination Unusual Event on January 8,1982; (2) followup to an incident on January 13, 1982, in which a Borated Water Storage Tank (EWST) sample line froze causing cracking and leakage of radioactive BWST water; (3) daily scheduling of maintenance through the licensee planning meetings; (4) and in-plant followup of LERs.
The licensee has a well deve' loped maintenance control program that'is used to consistently prioritize, assign and schedule work activities.
The maintenance department is adequately staffed. Effective coordination and communication exists among sub-groups (i.e.,
electricians, mechanics) within the maintenance department and with other departments such as quality control and radiological control field operations personnel. Planned work is accomplished in an effective m'anner, a relatively low number of tasks require rework and there are few instances where maintenance adversely affected other plant activities.
One violation that was identified was associated with the implementation of a job tickat to correct valve leakage from the Borated Water Storage Tank (BWST) in January 1982. Support activities, associated with the job ticket, enclosed certain BWST
, piping alcng with temperature sensors required for primary heat ..
tracing insice and outside the new enclosure. When a backup heat tracing temperature sensor failed, a portion of e rample line outside this enclosure froze and cracked.resulting in lealage of radioactive BWST water. Licensee analysis of this event indicated maintenance department personnel oversight and a programmatic weakness in the normal development and review process for job tickets. Licensee corrective action included additional department personnel training to be completed by December 1982, and the issuance of a temporary instruction discussing the need to identify and account for all interfaces where a repair support activity could affect the ncrmal function of plant systems. The licensee committed to incorporate these temporary instructions into th'e maintenance control program procedures. Completed corrective actions remain'to be reviewed by the NRC.
Also, two violations indicated that deficiencies existed in mainte-nance department interfacing with plant engineering, and radiological engineering personnel, and with the information management (records) department. The more significant of these two violations also identified the lack of a consolidated system for identifying, tracking and correcting nonconformances or deficiencies.
- 18 Based on the NRC's review of the Unusual Event of January 8,1982, the licensee did not present an aggressive involvement and attention
~
toward resolving the apparent poor HEPA (high efficiency particulate absolute) filter performance in the Auxiliary / Fuel Handling Building ventilation systens durirg the event. Final licensee analysis revealed that bypassing of the filter trains occurred through the -
filter cabinet under-drain system. Further NRC review indicated that tape was used to plug drain openings instead of carbon steel plugs as required by drawings / specifications. This plug deficiency was noted in various maintenance, and associated test and contractor report documents, but was lef t improperly corrected between 1980 and 1932.
The licensee subsequently installed the required carbon steel plugs.
Associated with the above review was the failure of the licensee to retrieve, in a timely manner, records of inspections and tests by contractor personnel for filter testing. The records were subsequently found, but the licensee also identified a programmatic deficiency in their review of the violation addressing this problem.
Formal contractor reports of satisfactory test results on equipment were sometimes not received by site personnel for up to 6 months after completion of the test. The licensee has committed to assure that all contractors submit formal reports of test results to site personnel when testing is used as a basis for restoration of important-to-safety equipment to a normal status.
In response to the above and subsequent to an Enforcement Conference on tnese matters, licensee corrective actions in the area of I organization interface, maintenance control, corrective action systems, and records management control include:
-- a streamlined organization structure which has fewer interfaces, improved comunications, and an enhanced safety review process
-- an improved action item tracking system which is proceduralized
< -- improved communications between the radiological controls and ;
operations organizations
-- improved communications between maintenance and engineering.
including feedback to engineering after maintenance work is completed
-- a special Quality Assurance review and analysis of safety ,
related maintenance (work requests) to look for generic problems or similar probi' ems on systems other than air filtration systems
-- an improved test record system so that when tests are performed by contractors, test records will be sent diiectly to records management personnel
-- consolidation of various departmental "trcuble reports" to assist in integrated review and analysis of events. l l
L., ,
)
19 1 1
Licensee planned corrective actions should be adequate to resolve NRC concerns in this area.
In summary, licensee attention to safety in the maintenance area is normally evident and management involvement shows overall concern.
Staffing is adequate and the achieved safety is satisfactory. .
Conclusion Category 2 i Board Reccmmendation Normal NRC attention should be maintained.
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- . 20 -
4 Preecerational Testino and Surveillance Analysis During this assessment period routine observations of surveillance testing were made by the resident inspectors. The Technical Support staff inspected the preoperational and functional testing of the -
EPICOR II prefilter venting and inerting tool. The preoperational testing was found to be properly implemented and in accordance with the licensee's safety evaluation report and the equipment supplier's (Department of Energy) safety analysis document. flo major deficiencies were identified during the EPICOR II prefilter venting operations. Additionally, specialist inspection of preoperational testing was accomplished in June of 1981.
The licensee has an adequate surveillance and preoperational testing program. The program was properly inclemented during the testing of theSubmergedDemineralizerSystem(SDS). Surveillance testing is generally acccmplished on time and the results of the testing, well documented.
Some isolated problems have occurred in the area of preoperational testing. Prior to the assessment period, in 1980, a Solid Waste Staging Facility Sump was not properly tested and turned over to operations. . In response to this problem, the licensee revised administrative procedures to .ddress the unique aspects of pre-operational testing for recovery systems.
In summary, minor violations are not repetitive in this area and no problems of a programmatic nature are evident. ,
Conclusion .
Category 1 Board Recommendation Inspection of surveillance should be reduced. Normal inspection of preoperational testing should be conti,nued.
9
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. 21 1 .
- 5. Fire Protection and Housekeecino
- Analysis During this assessment period, the TMIP0 ' continued to provide ensite ,
1 review of the fire protecticn program. One specialist inspection was i' conducted.
One deviation was observed for not treeting a commitment to NRR Branch 1 Technical Position 9.5-1, Section D3, which requires penetration i l seals to have the same fire rating as the wall or floor they i 2
penetrate. The licensee's fire penetration seals using Firewall 50 i material did not have the same fire rating as the wall or floor they penetrate. The licensee has instituted a replacement program to
- upgrade the genetration seals which are considered important to maintenance of the plant in a safe configuration.
c
.l At the beginning of the review period the licensee essentially had no l
< structured fire prutection program for containment. Several meetings j and repetitivc regt.ests had to be made by the NRC staff before the i licensee responded with an active program. Management involvement and attention to Reactor Building fire protection was not aggressive and therefore the required attention was not given to fire protection -
I concerns. After the NRC requested that attention be given to fire j protection activities, the licensee lost track of that request and 4 took no action to perform a fire protection analysis, for
! approximately six months. The NRC staff had to strongly suggest that
- an interim program be put in place until an analysis was completed. .
This type or activity should have been a concern of the licensee's f i prior to the NRC's suggestion. Since the program has been ,'
I
- implemented, the licensee has shown signs of being more conscientious
- relative to fire protection.
The licensee has implemented fire survey programs which give >
assurance that adequate attention is being given to minimizing the .
j likelihood and maximizing the detection of a fire. NRC staff l'
- suggestions to improve the fire protection program for specific l
activities, such as redwaste storage, have been incorporated it.to l procedures in a responsive way. The li excellent. There is rarely a prcblem ith w,censee's housekeeping is '
housekeeping and when
~
pr:;blems occur they are corrected in a timely manner.
1 ,
Preparations for defueling which will occur during the next I assessment period will require a modification of the current fire l protection program for the TMI-2 Containment Building. The licensee j i has developed a program to assure ' hat fire hazards are kept at a l minimum, fire detection is kept at a maximum and fire response is i maintained at an acceptable level, i
j Conclusion Category 2 -
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Board Recomendation
- Routine annual inspecticns by specialists should be continued in the area of Fire Protection. Inspection of licensee housekeeping should i*
be accomplished incidental to other inspection activities.
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- 6. Emercency Precaredness i Analysis.
Site staff observations in this area included: (1)participationand 1
witnessing of the December 10, 1981, Annual Exercise; (2) support activities associated with TMI-1 drills; (3) review of department .
preparatory training for major drills especially in the radiological controls area; (4) monitoring of the licensee's TMI-2 Emergency Plan development along with selected implementation reviews outside of the subject evaluation period; and (5) review of emergency plan implementation during actual events.
In accordance with regulations, the licensee submitted to the NRC a revised TMI-2 Emergency Plan on December 31, 1980, and reviseo TMI-2 Emergency Plan Implementing Procedures on February 27, 1981, based on the final guidance of NUREG 0654.
The plan and implementing procedures were effective April 1,1981.
The required annual exercises were conducted December 10, 1981, and August 11, 1982, (combined TMI-1 and TMI-2 drill). The Prompt Notification (Siren) System for TMI was installed, tested, and control was transferred to local responsible county authorities as of December 22, 1981. Ownership 'and maintenance of the siren system remains with the licensee. On May 21, 1982, the licensee reported that the siren system met all design objectives for the system and provides full area coverage of the TMI plume exposure EPZ (Emergency Planning Zone) and that the audible test was fulfilled'per TMI-1 Atomic Safety and Licensing Board Partial Initial Decision of December 27, 1981, on Emergency Planning. ,
'T The siren system has been plagued with numerous inadvertent actuations. Based on discussions with the licensee, the following corrective actions are planned: dual tone activation modification; establishment of a comprehensive preventive maintenance program; establishment of a contingency plan for (on-call) prompt response to correct the problem; and continual routine testing in the various local counties.
The Emergency Planning Department is a corporate function that is independent of site operations and maintenance staffs, and reports to the Vice President of Nuclear Assurance. Ample staffing is available
~
to perform the necessary functions in the emergency preparecness ,
i area.
The December 10, 1981, annual drill was well planned, effectively implemented, and satisfacterily critiqued. Licensee observers identified most of the prcblem areas noted by the NRC. Action items were recorded for followup corrective actions. The August 11, 1982, annual drill was evaluated as satisfactory. The primary event during this drill was simulated at TMI-1. During actual unusual events declared by the licensee on January 8, 1982, February 19, 1982, and l
March 22, 1982, implementation of the applicable portions of the
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emergency plan was adequate.- No significant prcblem areas were. .
identified. However.. an NRC appraisal sof emergency preparedness has not yet been conductet for TMI-2 specific aspects.
) '
l Conclusion Category 1 Board Recommendation Observation of major licensee emergency exercises on an annual basis should be continued. An inspection of TMI-2 specific aspects (implementing documents) of the licensee's em'ergency plan should be
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conducted. ,
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f Security and Safecuards-I Analysis D ing the assessment period,- there was one routine, unannounced phy ical protection inspection perfomed by a region-based inspector and e routine resident _ inspection. No material control and accoun ing inspections were perfomed. Two Severity Level IV s and one unresolved item were identified during the
. violati
- security nspection.. One Severity Level V violation was identified during the RC resident's inspection.
Two violation resulted from lack of coordination between the TMI-1 j and TMI-2 secur'ty supervisors.. The unresolved item pertains .to whether the lice ee should designate the I_ntake Building as a vital -
area. The matter s currently under review by the NRC Division of
- Nuclear Material Sa ty and Safeguards. Regarding the Severity
- Level V violation, th licensee took prompt corrective action.
f The licensee was effect1 e in maintaining the security program.during i the assessment period. M agement resources, both on site and at the corporate level, were adequ te to administer the program. Corporate 4
t management involvement in si activities was evident, as shown by the annual corporate security udit. These audits have consistently been a comprehensive and thorou review of security plan i
comitments. Corrective actions esulting from audit items were j
< timely and effective.
. Key licensee positions were identifie and their duties and '
responsibilities were well defined. Se urity records were complete.g well maintained and available for inspec on. -
j The licensee continues to ensure timely res ution of security issues ,
1 and consistently conducts technically sound a d thorough analyses of ,
j these issues, j During this assessment period, the licensee submi ted nine Security l
Event Reports pursuant to the requirements of 10 C 73.71.
Descriptions of the events were clean and concise.
l, i All security personnel appeared to be knowledgeable in air assigned i duti t:s. The Guard Training and Qualification. Program fo Units 1-and 2 is progressing on schedule with minimal difficulty. The .
. program is well defined and implemented with dedicated pers nel.
Classroom instruction was highly professional.
Conclusion i
Category 1 l
Board Recomendation l Security and safeguards inspections should be reduced.
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! Refer to Supplemental-Page 25A
Sucolement-to the TMI-2 SALP
- 7. Security and Safecuards Analysis 4
During the assessment period, there was one routine, unannounced physical protection inspection performed by a region-based inspector
! and one routine resident inspection. No material control and accounting inspections were performed. ,
Two Severity Level IV violations and one unresolved item were l identified by the regional based inspector. The violations occurred due to a lack of coordination between the TM1-1 and TMI-2 security supervisors when two Unit 2 VA doors were removed from the previously ,
shared Unit 1/ Unit 2 security computer. This resulted in failure to !
perform periodic surveillance on these doors and the loss of CAS alarm capability. The unresolved item pertains to whether the licensee should designate the Intake Building as a vital area. The matter is currently under review by the NRC Division of Nuclear Material Safety and Safeguards. One Severity Level V violation was identified during a resident inspection. The violation involved a :
i 4
vehicle parked within an isolation zone. Corrective action was promptly taken.
1 The licensee was effectSe in maintaining the security program during '
the assessment period. Management resources,.both on site and at the a
corporate level, were adequate to administer the program. Corporate i management involvement ic site activities was evident, as shown by the annual corporate security audit. These audits have consistently been a comprehensive anc' thorough review of security plan commitments. Corrective actions resulting from audit items were timely and effective.
l Key licensee positions were identified and their duties and l
responsibilities were well defined. Security records were complete, well maintained and available for inspection.
The licensee continues to ensure timely resolution of security issues and consistently conducts technically sound and thorough analyses of these issues.
During this assessment period, the licensee submitted nine Security Event Reports pursuant to the requirements of 10 CFR 73.71.
8 Descriptions of the events were clear and concise, 1
All security personnel appeared to be knowledgeable in their assigned duties. The Guard Training and Qualification Program for Units 1 and 2 is progressing on schedule with minimal difficulty. The program is well defined and implemented with dedicated personnel.
t Classroom instruction was highly professional.
Conclusion l Category 1 1 Board Recomendation ,
l Security and safeguards inspections should be reduced.
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.- 26 .
L - 8. Engineering Design and Modification Analysis-During the' assessment period, routine inspections. of engineering .
design.and modifications were conducted. Continuous review.of most-design and_ modification work was provided.by the Technical-Support.
Section of the TMIPO.
Accident recovery activities:at.TMI-2 have necessitated extensive:
modification work to provide for the safe. handling of the wastes and to. provide for the eventual. removal of the damaged fuel. To_ meet this need, the licensee has hired contractors with the.necessary expertise to perform these_ functions. The. licensee and contractors have built many necessary recovery systems including the Standby.
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Pressure Control System. EPICOR-II, Mini Decay. Heat Removal System ,
i and the Submerged Demineralizer System (505). In. addition,-the' licensee has successfully performed special. evolutions such as moving-the axial power shaping rods, the Reactor 1. Building decontamination-experiment, and the " Quick Look" operation.
l Because of _the various contractor groups involved in the engineering l organization, communications between the groups has been a problem.
For example, safety evaluation limits concerning SDS liner pressures-3 did not appear in the SDS procedures until the NRC brought it.to the
' licensee's attention. As another example, a modification was made to-the Long Term "B" Cooling System which made it inoperable in accordance with the applicable operating procedures. The_Long Term "B" Cooling System was designed to recirculate water in the "B" Once Through Steam Generator through a heat exchanger for decay heat ,
removal.
'- On some issues the licensee has failed to establish the proper.
priorities in a timely manner. For example, on August 20, 1982, licensee technical experts predicted that. combustible mixtures of gas were accumulating in the reactor coolant system void spaces. During the week of August 22, 1982, it was determined, by sampling, that
.l combustible mixtures of gas were present in the control rod drive j!
mechanism (CRDM). Corrective action gas taken to. allow.the gas to-escape from the CRDM, and confirmatory measurements were taken to a verify the corrective actions were adequate. The licensee, however, did not sample the loop void spaces or the pressurizor void space until September 29, 1982, after the NRC strongly suggested. sampling. ,
The samples showed that no' combustible gas mixtures were present in the loops nor in the pressurizer. Subsequently, the lic'ensee provided the NRC with additional calculations showing that a combustible gas mixture may never have been present in_the loops.or in the pressurizer.
The licensee took action to modify its-organization and adminis- i trative procedures to correct comunication and prioritization i problems. There is evidence of prior planning and assignment of priorities but frequently there are problems in getting the TMI-2 j organization working with the same list of priorities. Corporate j i
ae-- - - - , _ - . , . - - - - - . .-. - . . . -,m - + . . . - - - - . , . , -
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management is usually involved in'the site activities. Technical reviews are usually viable but sometimes are lacking in thoroughness or depth and must be resolved subsequent to NRC comment.-
Conclusion Category-2 .
Board Recommendation Normal inspection.. effort should be continued.
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. , 28 Licensine Activities Analysis aluation and monitoring of licensing activities during the as ssment period occurred primarily by routine contact between GPU Nuc ar's TMI-2 licensing staff and the NRC TMI Program Office staff -
which includes the resident inspectors and the Technical Support Sectic engineers. Since the TMI Program Office staff is located on site, co tacts with the licensee concerning licensing matters is frequent d often face-to-face. This results in frequent NRC input into licen ing action requests prior to formal submittal to the NRC.
The licensing rocess for TMI-2, since the accident on March 28, 1979, is unique. Technical specifications are in place which relate spe ifically to the condition of the plant and the systems (many of iich are unique) which are important to maintaining the safety of the p ant. Technical Specification administrative controls are similar +o operating plants.
As the condition of the lant has changed during the recovery process, the Technical Se cification and the Recovery Operations Plan has been reviewed to refle t the new condition. This resulted in frequent changes to the Tec nical Specifications (eight changes were made during the assessment pe iod) and the Recovery Operations Plan.
(seven changes were made durin the assessment period). In addition the new systems designed and bu t by the licensee to effect the recovery process must be reviewe and approved by the NRC. Such systems include: the Standby Pres re Control System, the EPICOR II System, the Submerged Demineralizer stem, the Mini Decay Heat ,
System, the Long Term "B" Cooling Sys m, and the Once Through Steam Generator recirculation System.
The licensee's safety evaluations, when s plemented with face-to-face discussions for clarification nd additional data, are generally adequate. The licensee is coopera ive in addressing technical issues brought up by the NRC althou responses are frequently delayed beyond the' scheduled respons date.
The licensee generally provided adequa'te correctiv actions in response to Notices of Violation. However, the lic see frequently refuted violations without providing adequate justif1 ation.
Ccnsiderable licensee and NRC time and effort were req ired for the ,
resolution of many of the identified violations. The 1 ensee also did not generally provide timely responses to Notices of 'iolation.
The licensee generally issued adequate licensee event repo *s although they were not always timely. The NRC recognizes t, t extending the required response dates is sometites necessary o I obtain additional information and provide a quality response, t I such extensions should not become a practice.
l Refer to Supplemental Page 28A l
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. 28A Sucolement to the TMI-2 SALP
- 9. Licensino Activities Analysis Evaluation and monitorinc of licensing activities during tne assessmer.t period occurred primarily by routine contact between GPU Nuclear's TMI-2 licensing staff and the NRC TMI Program Office staff which -
includes the Resident Inspectors and the Technical Support Section engineers. Since the TMI Program Office staff is located on site, contacts with the licensee concerning licensing matters is frequent and often face-to-face. This results in frequent NRC input into licensing action requests prior to formal submittal to the NRC.
The licensing process for TMI-2, since the accident on March 28, 1979, is unique. Technical specifications are in place which relate specifically to the condition of the plant and the systems (many of which are unicue) which are important to maintaining the plant in a safe condition. Technical Specification acministrative controls are similar to those at an operating plant.
As the condition of the plant has changed during the recovery process, the Technical Specification and the Recovery Operations Plan have been reviewed to reflect the new condition. This resulted in frequent.
changes to the Technical Specifications (eight changes were made during the assessment period) and the Recovery Operations Plan (seven changes were made during the assessment period). In addition, the new systems designed and built by the licensee to effect the recovery process are reviewed and approved by the NRC. Such systems include: the Standby Pressure Control System, the EPICOR II System, the Submerged Demineralizer System, the Mini Decay Heat System, the Long Term "B" Cooling System, and the Once Through Steam Generato'r Recirculation System.
The licensee's safety evaluations, when supplemented with face-to-face discussions for clarification and additional data, are generally adecuate. The licensee is cooperative in acdressing technical issues brought up by the NRC although responses are frecuently delayed beyond the scheduled response date.
This is also generally true of r'esponses to Notices of Violation.
F.eQuently the licensee refuted violations without providing adequate justification resulting in considerable discussions among NRC and licensee parsonnel to clarify and resolve the issues. This aeditional effort, in several cases, resulted in the licensee's response to tne Notice of Violation to be late, i.e. response cate extended beyond the normal time period. The NRC recognizes that extending the normal response date is sometime necessary in order to obtain additional information to provide a quality response, but such extensions should not become a practice. In all cases, the licensee's corrective action with regard to the cited violation was prompt and additional
- cerective action, where needed, was generally taken when the issue was clarified.
29
. sumary, licensee reviews are not timely, but are generally found to ba *achnically sound following discussions for clarification. In resclutt f technical issue's,_the licensee often provides viable approaches, ou lacks thoroughness and depth which requires frequent NRC interfacir.g i elarification. The resolutions are often delayed.
Conclusion Category 3 Board Reco=nendation Discuss this area with-licensee representatives at SALP m ng.
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29A -
Sucolement to the TMI-2 SALP .
-Generally, adequate licensee event reports were issued although'they also were not always timely.
Assessment of the. timeliness problem in the licensing area appears to-indicate difficulty in coordinating and integrating the efforts of the various functional. departments which may_be involved in an-issue. GPUN's licensing group functions as a coordinator among the '
. ether technical department's to obtain information and relate _that information to the appropriate NRC office. As previously di_scussed in Functional Area 1, the organization and management structure have at times exhibited that the various departments had problems in communications and coordination in the establishment of priorities.
As a result, the initial quality and timeliness of GPUN's responses to NRC has suffered.
Toward the latter part of this assessment period, the licensee -
reorganized the management ef GPUN and contractor staffs for TMI-2.
One of tiie major reasons for this reorganization was to better integrate the efforts of the many and diverse technical groups participating in the TMI-2 cleanup and to provide for more effective ccmmunications among those groups. Improvements in licensing activities have been observed since the reorganization.
Cenclusion Category 2 .j Eoard Recommendation Discuss this area with licensee representatives at SALP meeting.
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- 10. Cuality Assurance / Control Analysis i
Resident inspector review of this area included followup to previous inspection findings and a review of the applicability to TMI-2 of the generic aspects of an NRC Quality Assurance iaspection at TMI-1. -
The Nuclear Assurance Division Organization manual describes organizational responsibilities and major functions, and provides organization graphs and charts. The licensee.also recently developed a GPU Job Description and Specifications Manual that details individual job responsibilities, position requirements, capabilities, etc. Additionally, the GPU Organization Plan, signed by the President, is the senior management policy description. Management awareness and involvement in the QA Program is demonstrated by the Nuclear Assurance Division goals and task completion dates. The QA Department has developed a computer system to track open items and a User Procedure Manual has been issued.
The QA organization provides for a unique concept of three levels of inspection. Level I activities are essentially inspection or quality control and involve a direct inspection of activities. The implementing QA section onsite is fully staffed with representatives of a variety of specialists (electrical, mechanical, welding, etc).
This section is also supplemented by contractor personnel.
Level II activities involve monitoring or surveillance of numerous functional areas to verify procedure implementation. The QA section responsible for implementing these activities was formed subsequent ,'
to the TMI-2 accident and is adequately staffed. The functions of
< this section have permitted the QA Audit Section more time to concentrate on program establishment in accordance with applicable regulatory requirements.
Level III activities are primarily audit activities. A QA Audit Section is assigned to the TMI site and functionally reports to a Manager at corporate headquarters independent of other site QA l
sections. The entire QA department ig also corporate based. The audit section memoers are qualified and the section is adequately staffed.
The licensee has produced several reports evaluating OA ,
effectiveness. A monthly report titled " Assessment of the Implementation and Effectiveness of the Site Quality Assurance Program," is widely distributed to upper management including the vice presidents of major organizational functions. The reports includes a statistical analysis of Level I and II inspections but more importantly it contains a narrative section which discusses the QA/QC perspective of station activities.
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. 31-1 .
- In July 1982, the QA Department issued a report to;the GpVNC Soard of Directors on the status of the QA Program Implementation. This report was an assessmert of implementation for the new program developed in 1979 and 1980, governing plant activi. ties.
The assess'ent m provided statistical analyses of findings, noted trends, and listed accomplishments and areas needing improvement to .
, provide a balanced review of'the assessment period..
QA effectiveness is further reviewed by licensee participation in audits by a Joint Utility Group.
1 In. summary, QA management attention and involvement are aggressive and oriented toward n'u clear safety. Quality Assurance human' i
s resources are ample and effectively used to produce a high level of -
i performance with respect to operational safety.
Conclusion Category 1
, Board Recommendation Inspections in this area should be continued incidental to l inspections in related areas such as plant operations and engineering design and modification.
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L.. 32 L.. ,
V. SUPPORTING DATA AND SUMMARIES i
- a. Licensee Ever.t Report (LER) Tabulation and Causal Analysis-
-Tabular Listing ;
l Type of Events -
- a. Personnel error 5
.b. Design / Manufacturing / Construction /
Installation Error 5
- c. External Cause 7 ,
- d. Defective Procedures O
- e. Component Failure 14
- f. Other 5 Total llI Licensee Event Reports reviewed:
Report Nos. 81-027/03L-0 through 82-030/03L-0 (Event report Nos. 81-31, 82-02, 82-06, 82-08, 82-26, and 82 werenotused)
Causal Analysis Five sets of common mode event chains were identified:
- 1. LERs 82-18 and 82-23 involved lightning strikes close enough to the air intake structure to cause actuation of the Air Intake
. Tunnel (AIT) Halen System, actuation of the AIT Deluge System, and tripping.of the Auxiliary.and Fuel Handling Buildings supply, and exhaust fans.
- 2. LERs 82-17, 82-21, and 82-22 involved inoperability of the AIT chlorine monitor due to three separate component failures.
- 3. LERs 81-34 and 82-15 involved failure of incore thermocouples. ;
4 LERs 81-28, 81-32, 82-01, 82-04,,82-07, 82-09, 82-10, 82-11, 82-12, 82-24, and 82-29 invol'.ed inoperability of the Fuel Handling Building and/or Auxiliary Building Ventilation Systems as a result of personnel error during maintenance, failure of ;
components, failure to maintain system as designed and overly ,
restrictive technical specifications.
- 5. LERs 81-35, 81-36, and 81-38 involved in' operability of meteorological instruments caused by icing. ,
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- b. Investigation Activities i
There have been no investigations conducted during the assessment i period. j 1
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- c. Escalated Enforcement Actions
- 1. Civil Penalties There have been no civil penalties ~ assessed during the assessment period.
- 2. Orders There have been no orders associated with escalated enforcement actions during the assessment period.
- 3. Confirmatory Action Letters (CALs)
There have been no CALs issued during the assessment period.
- d. Management Meeting Held During the Assessment Period A management meeting was held at the Region 1 Office on July 29, 1982, to discuss NRC findings and concerns involving control of safety related maintenance activities and management of corrective actions (Management Meeting No. 50-320/82-10).
)
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TABLE 1 IMSPECTION HOURS
SUMMARY
'10/1/81 - 9/30/82)
THREE MILE ISLAND UNIT 2 HOURS % OF TIME
- 1. Plant Operations 562 24
- 2. Radiological Controls 1071 47
- 3. Maintenance 122 5 4 Preoperational Testing and Surveillance 140 6
- 5. Fire Protection and Housekeeping 13 1
- 6. Emergency Preparedness 136 6
- 7. Security and Safeguards 77 3
- 8. Engineering Design and Modification 122 5
- 9. Licensing Activities No Data Available
- 10. Quality Assurance 51 2
- Total 2294 100% ,
' Allocations of inspection hours vs. Functional Areas are approximations based upon inspection report data. The sum of the individual functional area percentages are less than 100% because of roundir.g errors, t
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O TABLE 2 It45pECT10ft ACTIVITIES 1
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THREE MILE ISLAfiD UNIT 2 rep 0RT tiUMBER AREAS ItiSpECTED (Inspectors) l 81-17 Routine, Reactor Building'(RB) entries, radio-(Resident / Specialist) active material shipments, health physics, and environmental 81-18 Event followup (exposure of individuals in (Specialist) excess of 10 CFR 20 limits) 81-19 Fire protection / prevention program
- (Specialist) 81-20 Transportation activities and package maintenance
- (Specialist) including management controls .
81-21 Routine, plant operators, radiological and (Resident / Specialist) environmental protection, RB entries, radioactive material shipments, and emergency drills
{
81-22 Event followup (unscheduled RB entry)
(Specialist) 81-23 Routine, plant operations, radiological and (Resident / Specialist) , environmental protection, RB entries, radioactive material shipment, licensee event reports, event l
followup 82-01 Routine, plant operations, surveillance and (Resident / Specialist) maintenance, health physics and environmental, RB entries, radioactive material shipments, licensee event reports, tra'ining, event followup, security 82-02 Routine, plant operations, surveillance and (Resident / Specialist) maintenance, health physics and environmental, RB entries, radioactive material shipments, quality assurance program, records management program, event followup 82-03 Radiological controls training, respiratory (Specialist) protection, procedures, dosimetry, and ALARA program l 6
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6 82-04 Routine, plant operations, surveillance and (Resident / Specialist) maintenance, health physics and environmental, RB entries, radioactive material shipments, and event followup ,
82-05 Routine, plant operations, health physics and (Resident / Specialist) environmental, radioactive material shipments, RB entries, and event followup 82-06 Event followup (open drum of radioactive waste (Specialist) upon arrival at burial site) 82-07 Routine, surveillance, event followup, health
- (Resident / Specialist) physics and environmental, and radioactive material shipments 82-08 Routine, plant operations, health physics and (Resident / Specialist) environmental, RB entries, event followup, radioactive material shipments 82-09 Security (Specialist) 82-10 Management meeting of July 29, 1982, concerning (RImanagement) safety related maintenance activities and management of corrective actions 82-11 Routine, plant operations, health physics, event (Resident / Specialist) followup, and radioactive material shipments 82-12 Routine, plant operations, health physics and *-
(Resident / Specialist) environmental, RB entries, radioactive material shipments, and event followup
+
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TABLE 3 -
ENFORCEMENT DATA ~
THREE MILE ISLAND UNIT 2 ,
A. Number and Severity Level of Violations and Deviations I., Severity Level Deviations 1 Violations S.L. I O -
Violations S.L. II O Violations S.L. III 1 Violations S.L. IV 11 Violations S.L. V 7 Total 20 B. Violations and Deviations vs. Functional Area .
FUNCTIONAL AREAS I II III IV V DEV
- 1. Plant Operations 1 1
- 2. Radiological Controls 1 5 3
- 3. Maintenance 3 1
- 4. Preeperational Testing and
, Surveillance
- 5. Fire Protection and Housekeeping 1
- 7. Security and Safeguards 2 1
- 8. Engineering Design and )
Modification l
- 9. Licensing Activities 1
- 10. Quality Assurance ,
1 11 7 1 I 1
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o TABLE 4 TABULAR LISTING OF LERs BY FUNCTIONAL AREA THREE MILE ISLAND - UNIT 2 Area Number /Cause Code Total
- 1. Plant Operations 3/A 5/C 8/E 5/X 21 Radiological Controls 0 2.
- 3. Maintenance 1/A 1/B 1/X 3 4 Surveillance 1/A 1/B 4/E 6
- 5. Fire Protection anc Housekeeping 1/B 2/C 1/E 4
- 7. Security and Safeguards 0
- 8. Engineering Design and-Modification 2/B 2
- 9. Licensing Activities 0
. 10. Quality Assurance 0 ,
Total 36 Cause Codes:
A- Personnel Error ,
B- Design, Manufa:turing, Construction, or Installation Error C- External Cause D- Defective Procedures i E- Component Failure ,
X- Other I
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's TABLE 5 LER SYNOPSIS
, THREE MILE ISLAND - UNIT 2 October 1, 1981 - September 30, 1982 -
LER Number Su =ary Descriotion 81-27/03L-0 Fire barrier penetration seals failed surveillance j
acceptance criteria 81-28/01L-0 Auxiliary Building Ventilation System inoperable due to -
failed vertex damper control linkage 81-29/01L-0 No N2 relief protection provided in Submerged Demineralizer i
System (505) dewatering station
! 81-30/01L-0 procedures for control of certain containment isolation valves not properly approved by NRC 81-31/ Not used 81-32/03L-0 Auxiliary Building ventilation flow below technical specification limit while moving liquid waste 81-33/01L-0 The 'B' Steam Generator Level indication became inoperable >
l due to power supply failure 81-34/01L-0 Incore Thermocouple No. F-12 inoperable due to personnel error in post-surveillance return to normal operation 81-35/03L-0 Wind direction sensor inoperable due to icy weather ccnditions 81-36/01L-0 Wind director instrument became inoperable due to icy weather conditions and action statement limit exceeded 81-37/03L-0 Motor bearing failed on Nuc' lear Service River Water Pump (NRp1B) 81-38/01L-0 Wind direction on speed instrument inoperable due to icing 82-01/03L-0 'B' Auxiliary Building Supply Fan (AH-E-78) tripped due to '
overload relay trip 82-02/ Not used 82-03/03L-0 Nuclear Services River Water (NSRW) Pump NR-P-1B failed to start due to loose fuse clip 82-04/03L-0 Auxiliary Building ventilation exhaust flow exceeded Technical Specification 3.9.12 limit i,
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82-05/03L-0 Long Term 'B' pump LTB-p-1 failed to start due to stuck limit switch in pump motor breaker 82-06/ Not used I 82-07/03L-0 Auxiliary Building ventilation exhaust flow below Technical Specification 3.9.12 limit .
82-08/ Not used 82-09/03L-0 Auxiliary Building ventilation exhaust flow below Technical Specification 3.9.12 limit 82-10/03L-0 Auxiliary Building ventilation exhaust flow below Technical Specification 3.9.12 limit
'82-11/01L-0 Auxiliary Building and Fuel Handling Building ventilation filter bypass 82-12/03L-0 Fuel Handling Suilding ventilation exhaust flow below Technical Specification 3.9.12 limit 82-13/03L-0 Seven smoke detectors failed to perform trip alarm functions due to failure of high voltage DC power supply 82-14/03L-0 Low Auxiliary Building vent exhaust flow rate violation Technical Specification 82-15/01L-0 Incore thermocouple 14-0 inoperable Deluge / sprinklers inoperable in hydrogen purge and 82-16/03L-0 Auxiliary Building Ventilation System 82-17/03L-0 Air intake tunnel chlorine monitor - potential loss of sensitivity 82-18/03L-0 Air intake Tunnel Halon System actuation, deluge system actuation and ventilation system trip 82-19/03L-0 Wind speed and direction anb air temperature instruments out of service 82-20/01L-0 Auxiliary Building sump flooding due to rainwater influx
- through drain in BWST recirculatien pump enclosure B7-21/03L 0 Control Room chlorine monitor inoperable 82-22/03L-0 Air intake Tunnel chlorine monitor inoperable 82-23/03L-0 Actuation of Air Intake Tunnel Halon System which tripped Auxiliary and Fuel Handling Building ventilation 82-$4/03L-0 Fuel Handling Building ventilation trip 5-2
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82-25/03L-0 Personnel airlock to Reactor Building failed leakage test 82-26/ Not used 82-27/03L-0 Emergency Diesel Generator DF-X-1A inoperable 62-28/03L-0 Auxiliary Building exhaust ficw rate low 82-29/ Not used 82-30/03L-0 tow fuel oil level emergency diesel day tank 1
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Enelesure 3 GPU Nuclear Corporation
[W ] Nuclear t Pc'utsme sStu;n'$o
%ccletown. Pennsylvania 17057 717 944 7621 TELEX 84 2386 Writer"s Direct Dial Number:
December 30, 1982 4410-62-L-0074 Division of Project and Resident Programs Attn: Mr. R. W. Starostecki, Director TMI-2 SALP Board Chairman U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Cear Sir:
l l Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Systematic Assessment of Licensee Performance (SALP) for TMI-2 l
This letter is in response to your letter of December 6,1962, same subject, **
the SALP Ecard Report attached to that letter, and the subsecuent meeting held Cecember 10, 1982 between NRC and GPUNC management to ciscuss the report on I TMI-2. This letter contains GPUNC's written ecmments on the above.
I Firstly, we would like to inoicate GPUNC's appreciation for the cencept of the SALP. GPUNC believes that the SALP Program can be very helpful. It is particularly valuable to have a group of senior NRC Staff persennel, with their unicue perspective on the strengths and weaknesses of several licenses, previce us with their conclusions as to how w' ell TMI-2 is achieving its objectives. We appreciate the objectivity and professional cuality of the assessment and are dedicated to acdressing areas that need incrovement in the j same manner. , j As was incicated by NRC personnel at the SALP meeting, the purpose of the l l SALP, and, in fact, NRC's primary purpose, is to ensure safety. GPU also l shares this cencern fcr and dedication to safety. he believe the efferts mace l
by GPUN to reflect this concern for safety assist us in cenducting TMI-2 cceration with a clear focus en safety aspects. Another step GPUNC has taken toward this cbjective is the estaclishment of the Safety Advisory Ecaro (SAB). This Board consists of cualified experts who provide the GPUNC Office of the Presicent with incependent acpraisal of technical escects of the THI-2 l recovery program as to how it fulfills the responsibility to protect public Eno worker health and safety, n .-.--- ------ O
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a """'" ~ ~ ~%$5 ition is a sutsiciary 6'the General Puche Utilities Corccraticn
i R. W. Starostecki AAID-82-L-0074 6
In accition to the general comments provided abcve, GPUNC would like to provice the following specific ccmments regarding the incicated sections of the SALP EJarc Report:
, 1. Page 9 of the Report indicates that one of the most consistent preolems noted was the " inability of upper management to effectively communicate their philoscphies and dedication downward through multiple layers of contractor and licensee management to the worker. In an attempt to alleviate this problem, the licensee has appointed a contractor manager to be the Director of TMI-2".
We would like to point out that the actual organizational change mace to help improve communications was much more extensive than merely appointing a contractor Director as TMI-2 Director. In accition to the Director, the entire Eechtel and GPUNC l organizations at TMI-2 have been integrated to provide ^
uninterrupted communication paths. This integration is throughout the organization at both the management and the working levels and has alreacy shown improved communication.
I
- 2. In the Emergency Preparedness area (page 23) the TMI-2 SALP report referenced a problem GPUNC had with inadvertent actuations of the emergency siren system. This problem was also referenced in the I TMI-l SALP report provided by your letter of December 3,1982.
l Further information is provided by GPUNC on this item in Section 3 ,
l of the response provided by TMI-l to their SALP report via GPUNC l Letter 5211-82-297, transmitted December 16, 1982.
- 3. It appears that the last paragraph of page 28 of the SALP report ;
' contains the essentials of the section on THI-2 Division Licensing activities. This paragraph indicates "The licensee generally ,
provided adecuate corrective actions in response to Notices of Violation. However, the licensee frecuently refuted violations without providing adecuate justification. Considerable licensee and NRC time and effort were required for the resolution of many of the identified violations. The licensee also did not generally provice timely responses to Notices of Violation. The licensee generally issued adecuate licensee event reports although they were not always timely. The NRC recognizes that extending the recuired response cates is sometimes necessary to obtain additional information and provide a quality response, but such extensions should not become a practice".
l The specific items CPUNC believes are identified in this paragraoh are paraphrased below along with the associated CPUNC response. .
l A. GPUNC generally provides adeouate corrective action to notices of violation. GPUNC concurs.
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R. W. Starcstecki 4410-82-L-C074 B. Violations were frecuently refuted withcut adecuate justification.
GPU Nuclear's intention in responses to NRC letters of violation is to provide facts for further evaluation by NRC management, and to provide our assessment of any apparent
" violations". In future letters we will ensure that data is -
prcperly verified prior to presentation to NRC.
C. Licensee aid not generally provide timely respenses to Notices of Violation.
GPUNC concurs that too large a percentage of responses to Notices of Violation were not as timely as recuired. The recent reorganization integrating GPUNC with its major contractor should improve the information flow and help reduca preparation time.
In addition several other actions have been taken to improve responsiveness in this area, as follows:
- a. Several Action Item tracking systems have been developed which should help prioritize activities
- b. We are studying mechanisms by which timeliness of internal information transmittal can be improved, and
- c. Several of the separate sections responsible for preparation of these reports have been consolidated into one department. ,,
In addition, as ciscussed at the SALP meeting, often the reascn for exceeding the time recuirement is GPUNC's desire to obtain additional information and assemble a cuality response. In these circumstances GPUNC will provice a respense within the time limit providing what information is available at the time and supplement this response at a later date.
Also as noted at the SALP meeting, in the majority of cases, corrective action as appropriate is proceeding even when the submittal is late.
D. The licensee generally issued adecuate LER's although not l always timely.
GPUNC concurs with the observation on LER acecuacy. Regarding timeliness, the response to Item C above also applies to LER's. In acdition, LER's were previously prepared in two stages by groups in two separate departments. The recent reorganization placed both of these groups in the same i department (Licensing and Nuclear Safety Department). GPUNC is also examining the LER preparation process for possible improvements.
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l R. W. Starcstecki 4410-82-L-0074 E. Respense cate extensiens shculd not become a practice.
GPU Nuclear iriter.ds to respond to all NRC requirements in a timely manner. Cerrective action taken or underway is
, icentified in C and D above.
4 Although the SALP indicated that in the area of Radiation -
Protection, " Licensee management attention and involvement are agressive and criented toward nuclear safety; licensee resources are ample and effectively used such that a high level of perfctmance with respect to cperational safety or constructicn is being achieved", we believe two items in this area are worthy of further discussion. These were mentioneo on page 14 of the SALP which indicated that "the licensee developed and tested the following innovations in the area of raciation protection.
Instituted a comprehensive man-rem tracking system for TMI-2 activities.
Successfully develcped a new beta / gamma persennel monitoring system (TLD)."
GPUNC efforts in these areas are summarired below and the details are presented in Attachments 1 and 2. -
The man-rem tracking system employed at TMI brings tecether elements of radiological engineering, health physics field cperations, and radiation exposure management (ALARA). The system utilized at TMI integrates many of the aspects of programs in effect at other progressive utility facilities. The system is designed to allow real time tracking of accumulated personnel coses, in the following categories: individuals, work function, particular job, and nature of work. For additional detail regarding this section see Attachemnt 1.
During the period Detober 1981 to Dctcber 1982, GPU Nuclear took several actions as described in Attachment 2 toward the implementation of a state-of-the-art personnel radiation dosimetry program based on thermoluminescent desimetry (TLD). These acticns included the design of a TLD badge, develcpment of computer technique to process raw TLD data, construction of a dosimetry laboratory and dosimeter calibration facility, improvement of the personnel dosimetry CA program of procecures for desimetry system cperation. These items are discussed in further detail in Attachment 2.
GPUNC believes the above efforts are indicative of an overall philosophy of raciological controls excellence, innovative activities, and management attention tcward radiation protection.
ATTACHNENT 1 Man-rem Trackino Svstem S;mma ry The basic data elements of the man-rem tracking system are captureo at the '
time the radiation work permit (RWP) is generated in real time en tne REM computer system. CRT's are located at each control point to allow direct ircut of exposure cata. The RWP reccrds the pertinent information related to the nature of the jcD, work location, and system prior to start of work.
Throughout tne job, personnel expcsures are accumulated and recorded in real time based en the reading of self-reading pocket ioni:ation chambers by raciological centrol technicians. At any time during an active job or subsequent to its termination, it is possible to interrogate the cata base via CRT at numerous locations througn0ut the plant and administrative offices, t One is able to assess total collective dose for Units 1 or 2 as a whole and I collective dose on a per job basis. By searching the data bcse using ALARA
- ceces, it is possible to identify task, system, and/or component specific cellective exp0:ures.
During the time frame of October 1981 through October 1982, the following l
exp:sure tracking reports were developed, organized ard provided to supervisors resconsible for planning and scheduling radiation work:
Dese Assessment Recort Daily, a Dose Assessment (DA) Report is provided to recuesting departments.
l The DA provides dose summaries fcr period, month, quarter, and year totals by incividuals sorted by exposure gictos.
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Man-rem Job Accountino Report Mcnthly, a Ran-rem by Job Accounting Report is provided to cesig9ated i supersisors. This report provides ccse summaries by jobs associated with specific CDFEC codes. Since unicue company codes exist through the ;
crganization structure, and since they are functionally specific, job specific l cose summaries associated with a specific department or task can be provided.
)
l Functional 3Cb Specific Dose Assessment Report i Monthly, a dose assessment (DA) report by company cede is provided to designated supervisors. This report provides exposure summaries by period, menth, Quarter, and year for all personnel associated with a specific code.
This report allows an individual supervisor to review only those personnel specifically assig,ed to him. In acdition to exposure information, this report provides RWP training dates, medical examinations date, respirator qualification codes, H3C hours accumulated within the last 7 cays, and last whole body count date for each individual. These features aid in verifying the currentness of qualifications for all radiation workers.
+ P R. w. Starcstecki 4.410-82-L-0074 In summary, althougn the NRC TMI-2 SALP report indicated that, in all areas reviewed, GPUNO management or involvement is (at least) acceptable and censicers nuclear safety, CPUNC recognizes that there are some areas where mere attentive management involvement is warranted, and intends to aggressively increase its management involvement in these areas while centinuing to maintain the bign level of management attention in areas already icentifico as having such. .
we trust that this letter provices a positive rescense to your assessments.
we anticipate receiving your findings and planned actions which will integrate the SALP Scard Repert, the SALP meeting, and this response.
Sincerely, ,
O / h l
.J Barton MI-2 Deputy Director JOB:JEL:rlh cc: L. H. Barrett, Deputy Program Director - TMI Program Office Dr. B. J. Snyder, Program Director - TMI Program Office i
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.O The acove reports provic'e task-scecific collective dese assessments based on '
tne results of the self-reading pocket icnization chamcers. As a result of their implementation, departmental supervisors and the Radiological Controls Cepartment are thereby able to track job progress with regard to the l
accumulation of raciation exposure. The effectiveness of the cose reduction tecnniques applied thrcughout the plant can also be assessed by the raciological engineering group.
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l Other features of the GPU REM system which are relevant to the control of
! raciation exposures include the access control routines. These routines employ several cata bases which record each individual's status with regard to currentress of radiation safety training, station acministrative radiation exp0sure limits on weekly, Quarterly, and annual bases, qualification to wear respiratory protection eculement, status of internal dose assessment and accumulated MPC hour exposures to airbcrne radioactivity. Individuals are restricted frem entry into areas controlled for the purpose of raciation protection if any of the applicable plant administrative limits on the above referenced items will be exceeded. The on-line real time portion of the REM system is used to check each workers status before he is allowed access into the restrictec area.
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ATTAChhENT 2 Devel:0 ment Of a State-of-the- Art TLD Badce Cesicn of TLD Bad;e With the assistan:e of Dr. Phillip Plato, of the University of Michigan,
- S:necl of Public H2alth, and the staff of the Natienal Bureau of Standards, TLD bacces proviced by the Panasonic Company were irradiated to various types of radiation sou::es in acecreance with the draf National Stancards Institute ( ArSI) - N13.11,1981.
t standard A computer of was algorithm the /cerican cevelcped to unfold raw TLD tadge data so as to establish the types of raciation incicent on the badge and the resulting c0ses to eye, skin, and ceep tissue. Tc a:: mplish this ambitious task, the standard TLD badge was m dified several times until a ccnstruction Thesuitable to the evaluation badge construction was of the multitude of radiation sources was identified.
testec in a::: cance with the above referenced AtGI Standard and has passed in all tests.
Devel:0m?nt of C:meuter Alcerithm and Data Processing Tasks In conjunction with the studies on TLD badge construction, the University of Michigan werked closely with the TMI Unit 2 Radiological Controle staff to develop a complex ce:ision making alforithm for use in a mini-ccmputer to reselve TLD data and establish radiation types and resulting deses.
Simitaneously, dose rec d computer software develcoment was undertaken and completec. THI's Panas:nic TLD System is now fully integrated with a de:1cated mini-cccuter system which can centrol TLD processing, calibration, cuality perfe:rance testirg, and inventory control.
As tre in-house TLD ccm uter scf tware was ceveleped, a CPU task force worked ,
to integrate tre cecicatec TLD CO*puter with CPU's large personnel In Phase I, data base. '
Pnase I of this multichase task is essentially complete.
c nmunicatien tetween the two c;mputers is possible and automatic dose upcating is possible.
Coastruction of D:siret;v Lateratory A separate lateratcry with environemental centrols for temperature and huricity was constructed to house the TLD system and its associated support computers in the TFI-2 Acministration Building. The facility features see:ial ligntin2 se as to allow visual inspecticn of light sensitive cosimeters and a Kslen fire protecticn system.
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. Desimeter Calibration Facility ,
Ouring the refererced period, work was begun and completed on an 1::adiation facility fer personnel dosimeters and portable survey instruments. The concrete structure houses a panoramic 1.2 curie Cesium-137 gamma irradiator capable of exposing up to 150 TLD bacges or self-reading pocket ionization chambers simultaneously. The facility includes several levels of built-in radiation prctection devices including in-cell radiation monitors, entry way l '
interlock system, and visual warning devices. A variety of radiation sources are available to irradiate badges to test system performance, these include Cesium-137, Strontium /Yitrium-90, and Thallium-204.
Persennel Desimetrv 0;ality Assurance Procram The personnel dosimetry system incorperated several elements as part of an l overall quality assurance program. These include a mic:cprocessor centro 11ed reader capable of checking the presence of sensitive badge elements, proper l cperation of the optical system used to measure the light emitted from the i
dosimeter which is proportienal to absorbed dose, and prcper oceration of the heating devices used to " read" the dosimeter with each badge reading. The dosimeter desi@ed for TH1 itself incorporates features which are designed to prevent tampering. Its unicue construction makes it virtually impessible to insert the cosimeter into the badge holder or reader in any orientation other than intended. This problem has been the source of many errors in older systems in use at other facilities; in particular, misidentification of desimeters and erroneous estimation of shallow (skin) and deep (whole body) deses.
To enharce the acNanced characteristics of the TLD badge and reader, ecually advanced cata processing devices and procedures were developed during 1981 -
1982 by the THI staf f. For example, the four sensitive elements in each TLD
. tacge are individually calibrated using techniques to assure the best possible.,
precision. In addition, each sensitive element is periodically recalibrated l to verify and maintain system performance. The trends of the element
! calibrations are established using the dedicated mini-ccmputer and are l reviewed to ensure preper dosimeter system performance. Computer controlled standard reading cycles are used daily to assure preper reader system performance. Furthe: mere, run control dosimeters irradiated to TBS traceable execsures are used with each reading cycle to ensure preper system calibration. ,
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GPU iiuclear Corporation .
ec w/ enc 1:
R. Arnold, President, GPU Muclear T. Poindexter,llRR, LPM bec w/ enc 1:
L. H. Barrett, Deputy Program Director, TMIPO A. N. Fasano, Chief, Three Mile Island-2 Project Section J. S. Wiebe, SRI L. H. Thenus, RI t
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DEC 0 61982 1-Occket no. 50-320 I .
L GPU Nuclear Corporation ,
ATTH: lir. S. X. . Xanga ,
Director of TI I-2 .
P.O. Bcx 480 fliddletown, Pennsylvania -17057 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) l 15, 1982, and The NRC Region I SALP Scard conducted a review on Novem Unit 2 Ruclear Generating Station. The results of this assessment A meeting are has been scheduled documented in the enclosed SALP Board Report. .This meeting for December 10, 1982, at the site to discuss.this assessment. .
is intended.to provide a forum for candid discussions relating to this ,
perfomance.
At the meeting..you should be prepared to discuss our assessment and your l Any conraents you may have regarding our report '
plans to improve performance. Additionally, you may provide written may be discussed at the meeting.
ccm.ents within 20 days after the meeting.
Fo11cwing our meeting and receipt of your response, the enclosed report, your '
respense, and a sum.ary of our findings and' planned actions will ce placed in * '
the i:RC Public Document Room.
Ycur cooperation is appreciated.
Sincerely.
Oridnal 51gned by m.hard $tsros*1d Richard W. Starcstecki, SALP Scard Chairman Director, Division of Project snd Resident Prcgrams
Enclosure:
As Stated g y gO * * *
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