ML20215J675

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Responds to NRC Re Violation Noted in Insp Rept 50-320/86-15.Corrective Action:Radiological Controls Technician Temporarily Disqualified from Working in Radiological Areas Until Counseled on Performance
ML20215J675
Person / Time
Site: Crane Constellation icon.png
Issue date: 03/18/1987
From: Standerfer F
GENERAL PUBLIC UTILITIES CORP.
To: Murley T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
4410-87-L-0038, 4410-87-L-38, NUDOCS 8705080196
Download: ML20215J675 (3)


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GPU Nuclear Corporation Nuclear

,omar8o Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

(717) 948-8461 4410-87-L-0038 Document ID 0170P March 18, 1987 Dr. T. E. Murley - Regional Administrator Region 1 US Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Inspection Report 86-15 Inspection Report 50-320/86-15 dated February 17, 1987, identified one (1) item of non-compliance. Attached is the GPU Nuclear response to that item.

Sincerely, F. R. Standerfer Director, TMI-2 FRS/CJD/eml Attachment cc: Director - TMI-2 Cleanup Project Directorate, Dr. W. D. Travers 8705080196 870318 PDR ADOCK 05000320 G

PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation M -O I

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ATTACHMENT

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4410-87-L-0038 NRC NOTICE OF VIOLATION 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys, as defined in Section 20.201(a), as (1) may be necessary for the licensee to comply with the regulations in 10 CFR Part 20, and (2) are reasonable under the circumstances to evaluate the extent of the radiation hazards that may be present. 10 CFR 20.103(a)(3) required, in part, that the licensee use suitable measurements of the concentrations of the radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.

Contrary to the above, on January 2, 1987, the licensee did not adequately evaluate or suitably measure the radiation hazards incidant to the presence of radioactive material in the 281' elevation of the Auxiliary Building prior to and during an entry by a Radiological Controls Technician resulting in an unplanned exposure to airborne radioactivity of about 80 MPC-hours.

This is a Severity level IV violation (Supplement IV).

GPU NUCLEAR RESPONSE As documented in the NRC Inspection Feport 50-320/86-15 dated February 17, 1987, a Radiological Controls Technician (RCT) received an unplanned exposure to airborne radioactivity as a result of an entry into 4akeup Pump Room 1-C (MU-1-C) on the 281' elevation of the Auxiliary Building on January 2, 1987.

The RCT was assigned to provide coverage for a work activity in MU-1-C.

Prior to the work party entering the room, the RCT decided to perform a radiological survey of MU-1-C to verify the routine radiological survey. To perform tne survey, the RCT used a routine Health Physics / Operations ( W/0PS) surveillance and job coverage Radiation Work Permit (RWP) as opposed to the RWP for the specific work activity. The RWP for the work entry included specific requirements for respiratory protection equipment and breathing zone air samples. The P/0PS RWP only indicatec respiratory-protective equipment "per Group Radiolcgical Controls Supervisor (GRCS)" discretion. The RCT did not consult the GRCS about respiratory protection and entered MU-1-C without respiratory protection as he believed the short entry did not warrant it.

After completing the survey, the RCT exited MU-1-C and while briefing the work party, a local AMS-3 air monitor alarme.d. The RCT exited the area, undressed, and, upon frisking himself, discovered facial contamination.

The cause of the high airborne radioactivity cannot be conclusively determined; however it is believed that it was the result of stagnant air in MU-1-C, the RCT's activities in the room and a short-term positive air pressure inside the room due to door openings and/or other activities in the Auxiliary Building. The resulting airborne exposure to the RCT was a result of the RCT not performing his duties in accordance with his documented training, qualifications, and experience.

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T ATTACHENT 4410-87-L-0038 As a result of this event, the following immediate corrective actions were taken.

o The RCT was temporarily disqualified fro.n working in Radiological Controlled Areas until he received counseling by the Manager, Radiological Controls Field Operations regarding his performance.

Remedial training and testing were determined to be inappropriate for this event.

o A Radiological Controls Field Operations log entry directed all GRCSs and RCTs to stop using the iF/0PS RWP for entries into highly contaminated areas. Job coverage survey entries must be made under the job specific RWP.

o The event was reviewed with RCTs and GRCSs with an emphasis on the.

necessity for clear, concise communication between the two (2) parties.

To prevent further violations of this type, the following preventive actions have been taken, o

Radiological Engineering and Radiological Controls Field Operations have been directed to specify decision criteria in ALARA reviews and RWPs whenever practical rather than using "per GRCS". ALARA reviews and RWPs will be evaluated and revised, if appropriate on an "as needed" basis, to minimize the phrase "per GRCS."

o The " lessons-learned" from this event have been incorporated into a seminar for cyclic RCT training.

o A ventilation study of the cubicle was performed. Cubicle penetrations were sealed and an additional exhaust pathway from the cubicle was added to improve negative air flow of the cubicle.

All of the above corrective and preventive actions, with the exception of evaluating ALARA reviews and RWPs, which will be an ongoing activity, have been completed. GPU Nuclear believes that these actions will preclude a similar event from occurring and that full compliance has been achieved.