IR 05000289/1996006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-289/96-06

ML20137P017
Person / Time
Site:	Three Mile Island
Issue date:	04/02/1997
From:	Eselgroth P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9704090112
Download: ML20137P017 (2)

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April 2, 1997 Mr.' James W. Langenbach Vice President and Director,.TMI GPU Nuclear Corporation Three Mile Island Nuclear Station P. O. Box 480 Middletown, PA 17057-0191 SUBJECT: INSPECTION REPORT NO. 50-289/96-06

Dear Mr. Knubel:

This letter refers to your December 11,1996 correspondence, in response to our November 11,1996 letter.

Thank you for informing us of the cc,rrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

Your cooperation with us is appreciated.

Sincerely, Original Signed By:

Peter W. Eselgroth, Chief Projects Branch 7 Division of Reactor Projects Docket No. 50-289 cc: w/o cy of Licensee's Response Letter J. C. Fornicola, Director, Licensing and Regulatory Affairs M. J. Ross, Director, Operations and Maintenance J. S. Wetmore, Manager, TMl Licensing Department cc: w/cy of Licensee's Response Letter -

- TMI-Alert (TMIA)

E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)

Commonwealth of Pennsylvania

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9704090112 970402 /,

PDR ADOCK 05000289

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. t e t Distribution w/cv of Licensee Response Letter  ;

Region i Docket Room (with concurrences) .

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Nuclear Safety Information Center (NSIC)  ;

PUBLIC ,

NRC Resident inspector i

i- . D. Screnci, PAO -

' P. Eselgroth, DRP  ;

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! -- D.' Haverkamp, DRP.

J. Nick, DRP ,

C. O'Daniell, DRP ['

W. Dean, OEDO B. Buckley, PD l-2, NRR ,

J. Stolz, PD l-2 NRR ,

R. Correia, NRR ,

D. Taylor., NRR  ;

Inspection Program Branch, NRR (IPAS)

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GPU Nuclear,inc.

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NUCLEAR / Post Office Box 480 -

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December 11, 1996 4 6710-96-2410

U.S; Nuclear Regulatory Commission Attn: Document Control Desk ,

Washington, DC 20555 .

Subject: Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 '

Reply to a Notice of Violation

Dear Sirs:

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Attached is the GPU Nuclear reply to the Notice of Violation,96-06-01, transmitted as Enclosure I to NRC Integrated Inspection Report Nos. 50-289/96-06.

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Sincerely,

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Vice President and Director, TMI cc: TMI-l Senior Resident inspector

TNI-l Senior Project Manager; ,

1NRC Regional Administrator, Region ! l

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ATTACHMENT 1 6710-96-2410 Page 1 of 4 NOTICE OF VIOLATION - 96-02-0_t During an NP.C inspection, conducted August 4,1996 - September 28,1996, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (60 FR 34381; June 30,1995), the violation is listed below:

Technical Specification (TS) 6.12.la states, in part, that "Each high radiation area in which the intensity of radiation at 30 cm (11.8 in.) is greater than 100 mrem / hour deep dose but less than 1000 mrem / hour shall be barricaded and conspicuously posted as a High Radiation Area."

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Contrary to the above, on August 7,1996, a posted high radiation area located on the 281 foot elevation of the Auxiliary Building in the 'B' emergency safeguards vault area, with dose rates up to 300 to 500 mrem / hour on contact and 90 mrem at 30 cm, was not barricaded as a High ,

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Radiation Area for a period of three hours.

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

GPU NUCLEAR RESPONSE TO NOTICE OF VIOLATION 96-06-01 Background  !

At approximately 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> on August 7,1996, a swing gate barrier at the entrance to a posted Hi t,h Radiation Area on the 281' elevation Auxiliary Building 'B' Shielded Area was found open. The

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radiological posting for the 'B' Shielded Area had been changed on dayshift to extend the High Radiation Area boundary in order to better accommodate work activities in the area. The area was inspected by a Radiological Controls Supenisor at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />, who found the area to be appropriately posted. After a shift change, and during a routine tour of the Auxiliary Building, an Operator identified the newly installed liigh Radiation Area swing gate at the B Shielded Area as propped in full open position at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />. The swing gate in that position did not provide a barrier to the area, as required by Three Mile Island Unit 1

, Technical Specification 6.12.1.a. An Operations Foreman and Radiological Controls Supervisor were subsequently notified, and the swing gate was retumed to it's proper position. Notifications were made to TMI management, a radiation survey of the area was performed, and a TMI Event Capture Form was f

initiated.

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A'ITACHMENT I 6710-96-2410 l

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Page 2 of 4 i Reason for the Viola,tio_n Investigation of this event concluded that propping open this High Radiation Area barrier was not an accident or error, it was a deliberate act. Probable reasons for the propped open swing gate barrier include

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case of moving material in or out of the area, or ease of protective clothing removal by personnel exiting the area.

Cprrective Stens Taken and Results Achieved

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A full-scale investigation of the incident was initiated by TMI management the following day. The investigative team consisted of members from Operations & Maintenance, Radiological Controls, ~ Nuclear Safety Assessment, and Corporate Security. A determination was made that the swing gate was propped open between 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> and 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> on August 7,1996. In addition, a reenactment of the 'as found'

swing gate by the Operations Foreman and the investigative team indicated that the gate had to be deliberately propped open; that it could not have been accidentally or inadvertently left in the open position.

A list was obtained by Security of all personnel that would have had access to the area in the time frame.

The investigative team immediately commenced an aggressive inteniew process of those personnel, resulting in the inteniew of 32 personnel over the next 9 days in order to gather information on the incident. None of the personnel inteniewed indicated that they opened the High Radiation Area gate, nor heard of anyone who had left open the gate, during the time frame in question.

As a result of the incident, several short-term corrective actions were taken:

l A walkdown of all High Radiation Area barriers was performed by Radiological Controls Supenision after the incident. Several of the High Radiation Area swing gates were moved in order to provide an easier and i more convenient access point for personnel requiring entry and exit from those areas.

Previous TMI High Radiation Area barrier violation corrective actions were reviewed, which included posting equipment improvements such as attaching ' Tech Spec Required Barrier' signs to the stanchions and the upgrading of the boundary rope supporting material. Also, several memoranda to site personnel from TMI management had been previously issued concerning personal accountability, self-checking, and adherence to safety and radiological rules. These memos were followed up by numerous site management / employee meetings held to reinforce management's expectations ofimproved performance in this area. These previously initiated corrective actions are still appropriate.

Corrective Steps to be Taken to Avoid Further Violations Radiological Controls has instituted a program of physically verifying proper positioning of the High Radiation Area barriers and posting on a shiftly basis, documented in the Rad Con Shift Log. 'Ihis action not only emphasizes management's desire for proper High Radiation Area postings, but prosides a Radiological Controls Department presence ard reinforces to all plant workers the need to comply with the posting requirements.

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. 6710- % -2410 Page 3 of 4 i

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As part of the interview process, the investigative team asked the personnel for suggestions and ,

recommendations to improve the Radiological Controls program with respect to High Radiation Area

- posting and control. A summary is provided below;

- !The majority ofrecommendations were to reduce to a minimum the number ofconservative High Radiation Area postings at TMI. ' Dere is an ongoing effort at TMI to reduce the number of High

! Radiation Area postings by means ofimproved radiation surveys to identify the contributors to plant dose rates, partial system flushes of hot spots in piping, and judicious use of hot spot shielding to lower dose j

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rates. The TMI Operations ALARA Working Group has been tasked with identifying opportunities for plant dose rate reduction, in part, to optimize the placement of High Radiation Area postings. With respect l

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to the plant location of this violation, subsequent to the work activities in the B Shielded Area a thorough l 4 ' radiation survey was performed and the area was completely deposted as a High Radiation Area. ]

- Use ofturnstiles, instead ofswing gates, to ensure that a physical barricade is in place at all timesfor

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High Radiation Area access points. ' Radiological Controls reviewed this receiisadation, and detemuned that a more effective means of ensuring an immovable physical barrier at area access points is

to permanently anchor the swing gates, and other barriers, to plant structures. Anchoring of High Radiation

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Area postings in the TMI-l Reactor Building was accomplished during the September 1995 11R outage,

, with favorable results. Those successes will be built on by installing permanent anchors at selected

locations outside the Reactor Building. Job Orders have been processed and the work has been scheduled ,

for December 1996 to install anchors at two locations in the Auxiliary Building, with additional anchor (

? installation under consideration for 1997.  ;

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- Installation ofbu::ers or lights on the swing gates that will energi:e whenever a gate is open. '  ;

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Radiological Controls evaluated these suggestions, along with ' talking signs'. Based on mixed results at other power stations, and the maintenance / operational difficulties of these devices, it was determined not to  !

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- Placement ofvideo cameras at High Radiation Area access points. ' The use of video cameras at High

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- Radiation Area access points was evaluated by Radiological Controls and determined not to be a ,

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reasonable method of ensuring compliance with the posting requirements.

- Increase worker sensitivity ofthe issue. * The department directors for Operations, Maintenance, and

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l Radiological Controls initiated meetings with all TMI supervision to raise the level of performance to  ;

t conform with management's expectations at TMI. A key area stressed in the meetings was that all

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supervision and employees, not just Radiological Controls, are responsible and will be held accountable for 4 ' adhering to radiological controls rules and requirements. A specific example discussed at the meetings was the TMI workforce's problems with High Radiation Area boundary controls. Management also discussed

! this Notice of Violation and the ramifications of future problems of this nature. In addition to the above ,

meetings, the weekly GPU Nuclear newsletter will have an article during December 1996 discussing this

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s Notice of Violation, and a description of the High Radiation Area posting violation will be included in i General Employee Traimng in early 1997. f

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6710-96-2410:

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Date when Full Comoliance will be Achieved i i t

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GPU Nuclear considers that full compliance has been achieved. Improvements to the Radiological Controls program concerning High Radiation Area postings, and increased worker sensitivity to these l

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issues, will be an ongoing process at TMI.

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