IR 05000289/1975006
| ML19256D621 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/04/1975 |
| From: | Meyer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D617 | List: |
| References | |
| 50-289-75-06, 50-289-75-6, NUDOCS 7910190579 | |
| Download: ML19256D621 (12) | |
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IE:I Forn 12
(Jan 75) (Rev)
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCDiENT
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REGION I
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IE Inspection Report No:
50-289/75-06 Docket No:
50-289
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Licensee:
' Metropolitan Edison Company License No:
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P. O. Box 542 Priority:
Reading, Pennsylvania Category:
C Safeguards Group:
Location:
Three Mile Island 1, Middletown, Pa.
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Type of Licensee:
y of Inspection:
Health Physics
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Da* 9 of Inspection:
March 12-14, 1975
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De__.s of Previous Inspection:
February 24-27, 1975 s
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Reporting Inspector:
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W
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R. J. F er,RadipionSpecialist DATE
Accompanying Inspectors:
DATE DATE DATE Other Accom _nying_ Personnel:
None DATE a
k M-d-75 Reviewed By:
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P. 3. Knapp, Chief, Facilitihs Radiological DATE Protection Section 1452 157
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SUMMARY OF FINDINGS Enforcement Action
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Items of Noncompliance 1.
Violations
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None
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2.
Infractions None.
3.
Deficiencies
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a.
' Failure to post radiation areas in accordance with 10 CFR 20.203(b).
(Details, Paragraph 8.b &, c)
b.
Failure to follow written procedures as required by Technical Specification 6.2.3.
(Details, Paragraphs 8.d.1-3)
B.
Deviations
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None
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Licensee Action on Previously Identified Enforcemer.: Action Not applicable
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Design Changes Not applicable Unusual Occurrerces A.
Unplanned _ Releases of Radioactive Material, No Limits Exceeded 1.
Release of radioactive material from the plant vent on October 6, 8 and 9, 1974 resulting from waste evaporator problems.
This was reported by the licensee's Non-routine Reports 74-02, 03 and 04, dated October 17, and 24, and November 14, 1974.
Cir-cumstances of the release were previously reviewed.* During this inspection corrective actions as described in the above
- RO: Inspection Report 50-289/73-31
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referenced letters were verified as having been acco=plished.
There are no further questions on this matter at this time.
2.
Release of radioactive macerials from the plant vent on November 29 ar.d December 2,1974 which resultad from the lif ting of a relief valve in the gas sampling system.
Circumstances,
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licensee evaluations and corrective actions were reviewed and appeared consistent with those described in licensee's report dated December 12, 1974.
There are no further questions on this matter at this time.
3.
Release of radioactive materials from the plant vent on February 24, 1975, resulting from the loss of the ventilation system in the auxiliary building.
(See unresolved item A.3.a.
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below)
(Details, Paragraph 9.u-c)
B.
Unplanaed Releases of Radioactive Materials: T/S Limit Exceeded 1.
Release of radioactive material from the plant vent on J'
January 23, 1975 resulting from loss of the loop seal on the reclaimed boric acid tank.
(Details, Paragraphs -10.a-c)
Other Significant Findings
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Current Findings
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a.
A review of the radiation protection program showed that implementation is continuing.
Procedure review and changes continue with implementation experience.
A minor organ-Tzation realignment has occurred and an additional super-visory position has been added.
Exposure use remains low to date.
Study and evaluation of vent header system problems continues.
2.
Acceptable Areas (No items of noncompliance noted)
a.
Organization (Details, Paragraph 2.a-b)
b.
Licensee Audits (Details, Paragraph 3.a)
c.
Discussions With Management (Details, Paragraph 4.a)
d.
Training (Details, Paragraph 5.a)
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Records - Radiation Safety (Details, Paragraph 6.a-b)
f.
Radiation Protection Procedures (Details, Paragraph 7.a)
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3.
Unresolved Items Licensee's final evaluation of unplanned release after
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loss of auxiliary building ventilation system.
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Paragraph 9.a-c)
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Licensee's evalustion of radiation monitor annunciator delays.
(Details, Paragraph ll.a-b)
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4.
Infractions and Deficiencies Identified by Licensee L
Infraction Release of radioactive material from the plant vent in a.
' excess of technical specification limit.
Licensee reported as A0 50-289/75-04 and in accordance with 10 CFR 20.403(b)
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and 405(a)(2) in letter dated February 3,1975.
Corrective actions by the licensee are continuing.
(Details,
Paragraph 10.a-c)
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Deficiency
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b.
Failure of an individual to follow requirements of RWP-660 with respect to protective clothing requirements.
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failure to follow procedure was identified by the' licensee's
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internal audit program.
It was noted that corrective actions
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were taken by the licensee.
B.
Status of Previously Unresolved Items Not applicable
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Management Interview E
The following individuals attended the management interview at the conclusion of the inspection.
J. Herbein, Station Superintendent J. Colitz, Unit 1 Superintendent J. Romanski, Engineer Nuclear (Supervisor Health Physics and Chemistry)
The following subjects were discussed:
A.
The inspector described the items of noncompliance identified in the
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Enforcement Action, Su= mary of Findings section, this report. With respect to those items concerning the posting of radiation areas, the inspector.noted that posting had been corrected and review with and instructions to personnel had been initiated prior to completion of the inspection and that no written response to those items would be required.
(Details, Paragraph 8.a-d)
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B.
The inspector discussed the scope of the inspection and stated that
.the areas noted below had been reviewed and no items of noncompliance had been observed.
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1.
Organization (Details, Paragraph 2.a-b)
2.
Licensee Auiits (Details, Paragraph 3.a)
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3.
Discussions With Managenent (Details, Paragraph 4.a)
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4.
Training (Details, Paragraph 5.a)
5.
Records - Radiation Safety (Details, Paragraph 6.a-b)
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Radiation Protection Procedures (Details, Paragraph 7.a)
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C The inspector stated that he lad verified that corrective actions had been accomplished as described in the licensee's Nonroutine Reports 74-02, 03 and 04 and that there were no further questions
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at this time.
D.
The inspector stated that he had reviewed the circumstances, evaluations and corrective actions as described in Nonroutine Reports 74-10 and 11 and that there were no further questions at this time.
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E.
An inspector identified annenciator problem was discussed.
The licensee stated that this matter would be reviewed.
This matter was left as unresolved.
(Details, Paragraph 11.a-b)
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F.
With respect to A0 50-289/75-04 (unplanned release) the licensee
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stated that a consulting firm is currently studying vent header system problems.
(Details, Paragraph 'O.a-c)
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G.
The inspector discussed the licensee's findings to date with respect to the release resulting from loss of the ventilation system.
This matter remains unresolved pending the licensee's final evaluation.
(Details, Paragraph 9.a-c)
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DETAILS 1.
Persons Contacted
J. Herbein, Station Superintendent J. Colitz, Unit 1 Superintendent J. Romanski, Engineer Nuclear, Supervisor Health Physics and Chemistry
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K. Beal, Health Physics Supervisor R. McCann, Radiation Protection Foreman
,u T. Mulleavy, Radiation Protection Foreman B. Smith, Shift Supervisor, Operations V. Orlandi, Lead I&C Engineer
J. Seelinger, Supervisor Training J. Deman, RadChem Technician G. Kunder,' Engineer, Nuclear W. Potts, Supervisor, Quality Control 2.
Organization
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The inspector's review of the existing organization showed that a.
alignment, responsibilities and staff qualifications were con-sistent with that described in the FSAR, Technical Specifi. cations and Regulatory Guide 8.10.
The following areas were reviewed with respect to the aforementioned criteria.
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(1) Changes in management
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(2) Changes at staff level (3) Qualifications of new personnel b.
With respect to item a.(2) above, it was noted that recent changes in staff alignment and responsibility has o'ecurred.
This involved the integration of the health physics and chemistry function.
Both groups maintain supervisors specific to each function but reporting to a new supervisor position.
This new position is responsibile to the Unit Superintendent.
3.
Licensee Audits The program was reviewed for consistency with that required by a.
Procedure HP1685, Technical Specifications and the Radiation Protection Manual.
The below listed areas were included in the review.
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(1)
Internal audits s
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QA sudits (3)
Records of audits (4)
Follow-up actions 4.
General Discussion (Radiation Protection Supervisors)
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A discussion was conducted during which implementation of the a.
radiation protection program was reviewed.
This included a review of how the management system functions with respect to action, follow-up and attention to the various needs of the program. The below listed areas were reviewed with respect to management review, evaluation and reporting as required by procedure, technical specifications and 10 CFR Part 20.
The management system appears to be consistent with the above requirements.
(1) Unresolved items
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(2) Unusual occurrences (3)
Personnel exposures (4)
Radioactive releases (unplanned)
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Training a.
The inspector's review showed that training programs and sub-
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ject material are defined by procedure.
A review of training t
records showed that training is continuing as described by
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procedure.
Training is consistent with that described in the FSAR, ANSI 18.1 and Regulatory Guide 8.10.
Retraining is in progress.
Specific areas reviewed are noted below:
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(1)
Changes in training (2)
Initial training (3) Retraining (4)
Records (5)
Tests (6)
10 CFR Part 19 (7) ALAP philosophy 6.
Records - Radiation Safety Evaluation a.
Records pertine'.t to control of radiation and contamination with respect c; personnel exposures were reviewed.
These records were reviewed for consistency with the requirements 1452 163
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of 10 CFR Part 20 Technical Specifications, HP Procedures and Regulatory Guide 8.10.
Records covering the period from
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September 1974 through February 1975 were reviewed.
The review covered specific areas as noted below:
(1)
In-plant air samples
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(2) Unusual occurrences
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(3)
Personnel exposures (see para, b below)
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Bioassay and whole body counting (5)
Radiation & contamination surveys (6)
Radiation Work Permits (see para. 8.d.1. below)
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b.
Personnel exposures for 1975, by exposure range, is shown below:
Individuals Exposure Range (mrer'
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< 100
100 - 250
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250 - 500
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500 - 750
750 - 1000
1000 - 2000 (max. 1660)
f The maxivim expos':re t'; rough January 31, 1975 was 210 mrem.
7.
Radiation Protection Procedures
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a.
A review of radiation protection procedures showed that they are reviewed on a continuing basis and changes effected as needed when deficiencies are noted or demanded by plant status
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changes.
Procedures were reviewed for consistency.with the i
below noted areas.
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(1)
FSAR (2)
Technical Specifications (3)
NRC requirements (4)
Change approvals
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8.
Facilities and Equipment a.
The inspector reviewed facility and equipment status with respect to implementation of the radiation protectivn plan.
The review included visual observations and radiation measure-ments during a tour of the auxiliary building.
It was noted 1452 164
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that facilities and systems appear to be consistent with those described in the FSAR and compatible with Regulatory Guide 8.8.
It was noted that, in general, control of access to radiation
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areas was consistent w1*h the need.
Identification of areas with increasing radiati n levels appear to be continuing.
It was noted that componen's not shielded by original design are being shielded.
Specific arecs as noted below were reviewed.
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(1)
Health Physics facilities (2) Access control points (3)
Availability of personnel survey equipment (4)
Radiation and high radiation area controls
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(5)
Posting (see para. 8.b. & c. below)
(6). Solid waste storage (7)
Standing and special RWP's (see para. 8.d. below)
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Procedural adherence (see para. 8.d. below)
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m b.
With respect to posting of radiation areas, the inspector ob-
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served on March 12, 1975 that three radiation areas in the auxiliary building were not posted with radiation area signs in accordance w.i h the requirements of 10 CFR Part 20.203(b).
t Existing radiation levels were measured by the inspector and verified by a licensee representative.
The areas are ider.tified below:
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(1) Seal Injection Filter Area, 305' elevation - Radiation -
levels to 15 milliren per hour.
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Intermediate Cooling Water Filter Area, 305' elevation -
Radiation levels to 10 millfrem per hour.
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(3)
Concentrated Waste Pump Room, 281' elevation - Radiation levels of 5 millirem per hour at entrance.
c.
With respect to the above areas, the inspector noted that they were properly posted prior to the conclusion of the inspection.
It was further noted that review v1.th, and instructions to employees, had been initiated by the licensee to correct and prevent recorrence.
d.
The inspector, by observations and by records review, deter-mined that certain health physics procedures had not been followed. Technical Specification 6.2.3 requires that written procedures be strictly adhered to.
Specific instances of failure to follow written procedures are noted below.
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(1)
Health Physic; Procedure 1613, Section 5.4 requires that upon completion of the work the Radiation Work Permit will
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be signed off by the job foreman.
The inspector noted that this was not always done, as determined from a review of completed RWP's.
Specifically RWP's 1541, 42, 43, 44, 29, 23 and 18 were not signed off by the job foreman.
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(2)
Health Physics Procedure 1612, Section 2.0.a. requires that individuals monitor themselves for contamination upon leaving a contaminated area.
On March 12, 1975 the inspector observed three individuals who removed protective clothing and left the Solid Radwaste Room, a contaminated area, without monitoring themselves for contamination.
Radiation survey instruments were available.
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(3). Health Physics Procedure 1682, Section 5.4 requires that contaminated equipment be stored in designated areas.
On March 12, 1975 the inspector observed that a stepladder, tagged as contaminated equipment, was stored in clean area near the elevator on the 281' elevation.
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9.
Unplanned Radioactive Release, No Limits Exceeded l
An unplanned release occurring on February 24, 1975 following a.
loss of the auxiliary buiding ventilation flow was reviewed with the licensee. This event was reported by the licensee by telephone and telegram. An Interim Nonroutine 30 Day Report,
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dated March 7, 1975 was also submitted.
The licensee reported that there appears to be radioactive noble gas leakage.to the auxiliary building, the probable cause being a design inadequacy in the gas handling systems.
The loss af ventilation allowed a buildup of radioactive gases in the building.
Subsequent startup of the ventilation system resulted in a discharge of radioactivity concentrations greater ' han normal but less than any applicable license limits.
The release was limited to noble gas (95% Xenon-133) and no applicable limits were exceeded.
b.
The licensee is continuing their investigation with respect to this matter.
Preliminary results have indicated that low level concentrations of radioactive gases are leaking to the auxiliary building.
The licensee is currently trying to identify the source of leakage, and is reviewing monitet strip charts and other historical survey data as part of their evaluation.
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It w-s further noted that the gas handling systems are under c.
review with respect to design deficiencies (see para.10 below).
In that the licensee's evaluation was not complete the inspector stated that this matter ould remain unresolved and would be reviewed during a subsequent inspection.
10.
Unplanned Radioact,1ve Release, Technical Specification Limit Exceeded
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An unplanned release occurring on January 23, 1975 which a.
resulted from an overpressure in the vent header system and subsequent loss of a loop seal in the Reclaimed Boric Acid Tank was reviewed during the inspection.
This release was reported by the licensee by telephone and telegram on January 24, 1975 followed by a written report designated A0 50-289/75-04 dated February 3, 1975.
b.
Themaximug/sec. release rate (during approximately 10 minutes) was 1.26X105 M The technical specification limit is
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5 M /sec.
The release occurred over a period of 3 houta 1.2X10 and37 ming /sec. The average release rate for tbat period was tes.
1.65X104 M Radior.tivity concentration in.the boric acid room, averaged over 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, was 1.23X10-3 uCi/ml.
This concentration was in excess of 500 times the Appendix B, Table II, 10 CPR Part 20 limit.
This was so reported by the lice'nsee in
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accordance with 10 CFR Part 20.403(b)(2) and 10 CFR Part 20.405
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No personnel exposures to excessive concentrations
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a result of the event.
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Specific to the above release, the licensee detensined that c.
valve stem leakoff caused the buildup of pressure,in the cover gas system with a subsequent loss of the loop seal on the Reclaimed Boric Acid Tank.
This occurred during maintenance work on the Pressurizer Spray Valve.
Corrective actions were taken to terminate the release.
Subsequent changes in pro-cedures tc cope with system problems have been made pending completion of system studies and modification.
Other preventive
and corrective measures such as plugging certain loop seals, valve repair, vent header pressure monitoring and more restrictive administrative controls have been instituted.
d.
The licensee's continuing evaluation of the event showed that the design of the nitrogen cover gas system and/or related systems may be inadequate to handle pressure surges.
A con-sultant to the licensee is currently evaluating system problems.
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A preliminary report from the consultant, according to the
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licensee, suggested certain modifications to the systems.
These included; (1) redesign the loop seals to handle greater
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pressure surges; (2) plug the loop seals and add relief valves and vacuum breakers; (3) increase system operating pressure; and (4) redesign valve stem leak off to vent to the exhaust system. The licensee stated that evaluations for best fix
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is continuing and that modification time frames will be estab-lished,when that fix is determined.
The Division of Reactor Licensing, by letter dated March 19, e.
- 1975 requested the licensee to provide their plans and schedule to modify the plant vent hsader system and to propose a change F
to the Technical Specifications that would prevent unplanned radioactive releases from this system until completion and testing of the m6dified system.
The inspector has no further questions on this matter at this time. Additional inspection
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effort will be based on resolution of this problem between the
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licensee and the Division of Reactor Licensing.
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Radiation Monitor Annunciator During a tour of the control room the inspector noted that a.
RM-L8, the liquid radiation monitor on the Miscellaneous Su=p I.
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Discharge was in high alarm and no apparent. action was being
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taken. During discussions with control ro'om personnel the inspector determined that no discharge was occurring in that the discharge line was valved to the Miscellaneous Waste Storage Tank (MWST).
This mode had been established because of back-ground buildup in the instrument approaching the normally established trip point.
The discharge had been valved to the MWST pending review of trip point setting and/or decontamination of the instrument.
b.
The inspector noted that the trip was coming in en an inter-mittent basis on the raeliation monitor panel, however, no main
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annunciator signal was received.
Upon further questioning the
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inspector determined that there was a recovery time in the circuit between 'cips during which time no signal would get to the main annuncistor.
This time delay is on the order of eighty seconds.
In the event of intermittent trips, the system needs that amcunt of time to recover from one trip to the next.
The inspector raised the, question with respect to this pro'blem being inherent in other monitors.
Tha licensee representatives stated that they would investigate the problem.
This ites remains unresolved and will be reviewed during a subsequent inspection.
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