IR 05000289/1980002
| ML19352A014 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/01/1980 |
| From: | Conte R, Fasano A, Haverkamp D, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19351G574 | List: |
| References | |
| 50-289-80-02, 50-289-80-2, 50-320-80-02, 50-320-80-2, NUDOCS 8102250416 | |
| Download: ML19352A014 (16) | |
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O U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I 50-289/80-02 Report No.
50-320/80-02 50-289 Docket No.
50-320 DPR-50 c
License No. DPR-73 Priority Category c
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Licensee:
Metropolitan Edison Company 100 Interpace Parkway Parsippany, New Jersey 07054 Facility Name: Three Mile Island Nuclear Station Units 1 and 2 Inspection at: Middletown, Pennsylvania Inspection conducted:
February 1 - March 16, 1980 Inspectors:
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4/d/ro 2:
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D.Haverkamp,MeniofResidentInspector date signed GM;::L n Ag
&&ro R. Con % Senior Resident Inspector da'te signed M-AIO
'l 7o/$Y6 M. ShanbaRy, Seni r Ra#ation Specialist d6te s'igned -
Approved by: Mdf f///#o ta A. Fasano( Ctfief, Site Operations Section
'date signed TMI Program Office Inspection Summary:
Inspection on February 1 - March 16,1980 (Combined Report Nos. 50-289/80-02; 50-320/80-02
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Areas Inspected: Special inspection by NRC TMI Program Office Staff of:
licensee action on previous inspection findings (Unit 2); selected new and revised procedures (Unit 2); daily and selected shift activities (Units 1 and ~2); water leak from makeup pump instrumentation on February li, 1980; reactor building atmosphere sample on February 12-13, 1980; and contruction/ plans for processed water storage tanks. The inspection included daily (Monday-Friday) NRC TMI staff coverage and day shift coverage, with selected backshifts included, by NRC shift radiation specialists.
Results: Of the six areas inspected five items of noncompliance were found in two areas (Infractions:
failure to properly train vendor personnel, paragraph 5.d(2);
failure of operators to properly implement a facility procedure, paragraph 5.d(1);
failure to obtain an adequate airborne survey, paragraph 4.e(l); failure to properly post radiation area, paragraph 6.c; failure to adequately survey for airborne tritium activity, paragraph 6.d.)
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DETAILS
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Persons Contacted Licensee Representatives Principal licensee and contractor personnel contacted during this inspection are identified in paragraph 10.
NRC Inspection Participants The following personnel participated in this inspection.
J. Bland, IE:HQ, February 1 - February 6, 1980 P. Clemons, IE:RI, February 6 - February 20, 1980 L. Cohen, IE:HQ, February 13 - February 27, 1980 R. Conte, IE:RI, February 1 - March 16,1980 J. Davis, IE:RII, March 5 - March 12,1980 A. Fasano, IE:RI, February 1 - March 16, 1980 E. Ford, IE:RII, February 1 - February 13, 1980 L. Friedman, IE:RI, February 13 - February 27, 1980 D. Haverkamp, IE:RI, February 1 - March 16,1980 L. Jackson, IE:RII, February 6 - February 13, 1980 W. Kinney, IE:RI, March 12 - March 16,1980 W. Millsap, IE:RII, February 1 - February 6,1980 R. Nimitz, IE:RI, February 1 - February 13, 1980 K. Plumlee, IE:RI, February 27 - March 16,1980 C. Rowe, IE:RI, February 27 - March 12, 1980 J. Serabian, IE:RI, February 27 - March 5, 1980 M. Shanbaky, IE:RI, February 1 - March 16, 1980 N. Terc, IE:RI, March 5 - March 16, 1980
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L. Thonus, March 12 - March 16,1980 G. Troup, IE:RII, February 20. - February 27, 1980 A. Varela, IE:RI, February 28 - February 29, 1980 and March 3 - March 6, 1980 2.
Licensee Action on Previous Inspection Findings i
(0 pen) Unresolved (320/79-13-09):
Upgrading of Facility Procedures with respect to recovery mode.
Contingency plans for emergencies /
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abnormal events were reviewed with respect to the makeup pump i
instrument water leak.
Findings are addressed in paragraph 4.d(2).
3.
Facility Procedures Submitted for Approval (Unit 2)
Facility procedures and subsequent revisions, required to be sub-i mitted for approval to the NRC as required by Technical Specification j
(TS) 6.8.2, were reviewed by the NRC TMI Program Office Staff.
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These procedures address the Recovery Operations Plan Implementation (Surveillance Procedures) and Recovery Mode Implementation (Operating Procedures).
Detailed review of selected procedures included both health physics and operations aspects with consideration of the l
following:
(1)
the procedure, when implemented, would not degrade the containment of radioactive material, jeopardize core cooling,
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the technical j
content of the procedure is adequate to perform the intended evolution.
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Composite staff comments on procedures were forwarded to the licensee.
Licensee resolution of comments was acceptable.
4.
Water Leak From Makeup Pump Instrumentation
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a.
Background On February 11,1980, at 12:20 p.m., an operability test of the makeup pump (No. lA) was initiated. After starting the pump, a low discharge pressure alarm was received for the makeup pump No.1B followed by confimation of a 9 gpm leak based upon decreasing makeup tank level and local air monitor alams. An evacuation of the auxiliary building was ordered at 12:50 p.m., and a local emergency was declared at 12:58 p.m.
Upon announcement of the local emergency onsite NRC staff members were immediately dispatched to the Unit 2 control room and to the Unit 2 health physics control point.
Personnel entries to the auxiliary building and control room operations were observed by the NRC staff members.
The leak was later determined to be due to the blow out of a compression fitting which connects an instrument root stop valve to makeup pump discharge pressure instrument sensing lines.
This event caused a total leakage of approximately 1,000 gallons of primary system water (total sh 116 uCi/ gram) to the auxiliary building sump via the floor drain system. As a result of this leak, airborne activity (1.95 x 10-7 uCi/ml, highest reading) increased near the makeup pump room and the other general areas in the lower levels of the auxiliary buidling.
Dosimetry data for all personnel originally present in the auxiliary building and those who participated in the survey and repair teams, showed exposure well below the regulatory limits. All releases to the unrestricted at a were calculated by the licensee and verified by the onsite NRC staff. A total of about 300 mci of Kr-85 was released.
Offsite dose estimates were made by the licensee and independently verified by the NRC staff. Offsite dose calculations indicated that the dose to a tLeoretical individual at the site fence throughout the release period was minimal (reference paragraph 4.3.(3)).
b.
Purpose of Review An evaluation of the licensee's performance during this event, on February ll,1980, was conducted.
The following items were detemined based on record review, direct observation, and discussions with licensee personnel:
Event Discovery and Notification Method of discovery of off-nomal radioactivity release;
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Sequence of licensee actions which led to confimation of
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release point; Nature and extent of radioactivity release;
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Initial and subsequent notifications made by licensee
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personnel to licensee management, NRC, state and local agencies, off-site support facilities and press; and, Acceptability of the above actions used on regulatory
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requirements and procedural ccntrols.
Corrective Action - Technical Immediate corrective actions taken to teminate the off-
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normal radioactivity release were appropriate to correct the cause of the release and were taken satisfactorily; Responsibility was assigned for assuring completion of
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specific and generic measures planned to prevent recurrence, including equipment / component modifications, procedural changes, and training; and, The above actions were adequate to assure prompt termination
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of the release and to prevent recurrence.
Safety of Operations - Technical
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Whether or not the event involved continued operations in
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violation of regulatory requirements or license conditions.
c.
Documents Reviewed The following documents were reviewed:
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Licensee Sequence of Events for the occurrence;
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Station Administrative Procedure 1001, Revision 21,
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September 21, 1979, TMI Document Control; Three Mile Island Emergency Plan, Administrat'ive Procedure 1004,
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Section 2.0, Revision 2, " Emergency Conditions,"
February 15, 1978;
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Station Radiation Emergency Procedure 1670.1, Revision 3, February 13, 1978, Local Emergency Procedure; Station Radiation Emergency Procedure 1670.2, Revision 9,
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November 22, 1978, Site Emergency Procedure; Station Health Physics Procedure 1670.8, Revision 0,
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" Emergency Re-Entry for Repair or Pescue," January 16, 1978; Station Health Physics Procedure 1670.15, Revision 0,
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" Post-Accident Re-Entry and Recovery Plan," January 16, 1978;
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Unit 2 Operating Procedure 2104-1.14, Revision 0,
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December 25, 1979, Standby Reactor Coolant Pressure Control System (SPC);
Unit 2 Emergency Procedure 2202-1.3, Revision 11,
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October 6, 1978, Loss of Reactor Coolant / Reactor Coolant System Pressure; Unit 2 Emergency Procedure 2202-1.7, Revision 3,
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December 12, 1979, Excessive Radiation Level; Unit 2 Emergency Procedure 2203.-l.5, Revision 2,
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September 7, 1978, Loss of RC Makeup; Radiation Work Permit 80B-0862, " Health Physics and
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Surveillance," and Sign-In Sheets dated February 11, 1980; Metropolitan Edison Company Inter-0ffice Memorandum
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(J. J. Barton to R. F. Wilson), TMI-II-R-6350, dated February 15, 1980, " Makeup System Instrument Tie-Line Leak on February 11, 1980;"
Metropolitan Edison Company Inter-0ffice Memorandum
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(J. J. Barton to J. J. Chwastyk), TMI-II-R-6367, dated February 22,1980, " Lessons Learned-Auxiliary Building Local Emergency of February 11, 1980;"
Unit 2 Air Sample Log Sheets dated February 11, 1980;
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Unit 2. Personnel Contamination Reports, dated February 11, 1980;
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Summary of Internal and External Exposures of Individuals
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. in the Unit 2 Auxiliary Building during the Local Emergency
.on February 11, 1980; and, Radiological Survey of Unit 2 Makeup Pump, Revision 18,
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dated February 11, 1980.
d.
Operational Assessment (1)
In order to minimize a recurrence of this type of event, several precautions received an engineering evaluation by the licensee. These actions included operating only one makeup pump at a time and isolating all instrumentation that was not required for pump operation or system
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operation in the plant configuration at that time.
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The isolation of all superfluous instrumentation would
. reduce the number of compression type fittings which may become a source of leakage.. These actions will be described in the licensee's thirty day written report of
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the event and reviewed by the NRC staff. This is unresolved (320/80-02-01) pending final NRC staff review.
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(2) During this review the adequacy of contingency plans for emergencies was questioned in light of this specific mechanical malfunction.
No emergency or abnormal procedure deal specifically with leak isolation of the makeup system. However, the operating procedure for the SPC system did give direction on isolating the makeup pumps and this operating procedure was used during the event to isolate the makeup pumps.
The LOCA Procedure (OP 2202-1.3) considers the makeup system part of the RCS, but it is a preaccident procedure, and it is somewhat outdated with respect to present plant conditions.
The issue of up3rading preaccident procedures (especially emergency / abnormal procedures) was addressed in a previous inspection by the NRC staff (320/79-13-09). This included the incorporation of temporary emergency procedures into the formal facility procedure system.
Progress in this area has been noted with respect to operating procedures. However, in the area of emergency procedures, progress has been relatively slow. The NRC staff has placed increased emphasis on upgrading of emergency / abnormal procedures.
This remains unresolved (320/79-03-09).
Contingency plans continue to be reviewed by the licensee and will be fo.llowed by the NRC staff.
e.
padiological Assessment
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(1) Air sample results taken during and after the local emergency were reviewed by the NRC staff.
The licensee representative was asked whether an air sample was taken in makeup pump room No. 1B.
The licensee representative stated that there were two air samples taken in the
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corridor outside the makeup pump room but no samples were l
taken inside the makeup pump room.
It was noted that i
makeup pump room No.1B, where the contaminated water leak took place, was under a negative air pressure such
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l that the air flow was from the corridor into the room.
Air sample results from the corridor were of the order of 10-7 uCi/ml. Therefore, the actual room air concentrations could be higher than the airborne concentration detected in the corridor.
l 10 CFR 20.103, " Exposures of Individuals to Concen-trations of Radioactive Materials in Air in Restricted
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l Areas," requires, in part, that suitable measurements of l
concentrations of radioactive materials shall be used.
i It was determined (through review of the Sign-In Sheets l
for RWP 808-0862 and the air sample log sheets for l
February ll,.1980), that a suitable air sample to represent l
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the air concentrations in makeup pump room No.1B was not taken either at the time of room entry or at the location of the entry insi(e the room.
Subsequent discussion with the licensee representatives, confirmed that no air sample was taken within makeup pump room No. 1B on February 11, 1960. The inspector stated that failure to use suitable measurements of concentrations of radioactive materials in the air was an item of noncompliance with 10CFR20.103(a)(3)(320/80-02-02).
The licensee perfonned whole body counts for individuals who were either in the Unit 2 auxiliary building at the initiation of the local emergency or who made entries during the local emergency. All of the results were below the licensee's screening limit, of 3% of the maximum permissible organ burcen for cesium-137, which was the principal isotope comprising the airborne radio-activity increase.
(2) A review ofithe licensee's personnel contamination record indicated that three individuals were contaminated during the course of the local emergency. Two individuals received skin contamination on the forearm and hand ranging from 2,000 dpm to 3,500 dpm.
Both were decontaminated
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to less than 1,000 dpm.
The contamination occurred when
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the two individuals were at the rad / chem control point and changing out contaminated air bottles for personnel who had entered the auxiliary building.
The third individual received contamination to his left hand, wrist and hair ranging from 5,000 dpm to 8,000 dpm.
Records indicate that the wrist and hair were decontaminated to less than 1,000 dpm but that the hand remained contaminated at 8,000 dpm. This individual had been a Rad / Chem technician in the Unit 2 auxiliary building during the local emergency. The licensee's contamination record did not indicate specifically how the contamination occurred and the individual has since tenninated his employment.
Subsequent discussion with the licensee indicated that all contaminated individuals were decantaminated prior to leaving the site.
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The NRC staff has no further connents in thi5 area, i
(3) The radiological monitors for iodine, particulate and noble gases in effluents were examined and estimates of total releases were calculated. On February 11, 1980, about 300 mci of Kr-85 was released to the environment as a result of the instrument line leak in the auxiliary building. This calculated release was based on an instrument sensitivity factor for the AM monitors, which was provided by the licensee.
Neither particulate nor iodine showed any increase on the AM monitors (AM-2 through AM-5). - Auxiliary building exhaust monitor
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AM-1 was out of service at the time of the release. This releare was well below the regulatory limits of 10 CFR 20 and the TMI-2 Environmental Technical Specification
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(ETS).
Preliminary offsite dose calculations were perfonned by the NRC staff. The total skin beta and whole body doses at t'he highest X/Q location were approximately 0.0013 mrem
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and 0.000015 mrem, respectively.
5.
Reactor Building Atmosphere Samples
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a.
Background
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On February 12,1980, at 6:50 p.m., a sample line recirculation purge was initiated in preparation for obtaining a sample of the reactor building atmosphere. The purge was continued for uore than 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> prior to getting the sample and isolating the line at 12:30 p.m. on February 13, 1980. During the recirculation period an increase in auxiliary building radiogas monitor (AM-5) activity was noted by the NRC shift radiation specialist. The observation was reported to both the licensee and NRC site staff supervisory personnel.
Initial reaction by both the licensee and the NRC staff personnel was that the increase was only slightly above the normal activity levels and well within the allowable release limits. No action was taken to stop the gas sample evolution which was attributed as being the cause of the release since this was the only evolution occurring in the plant during this period. However, extensive review of the release was subseque;itly performed by both the licensee and the NRC staff. The preliminary evaluation results of the gas sampling evolution has identified several areas of concern as described below.
b.
Purpose of Review An evaluation of the licensee's performance during this event on February 12, 1960, was conducted.
The following items were verified based on record review, direct observation, and by l
discussion with licensee personnel:
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Event Discovery and Notification Method of discovery of off-normal radioactivity release; l
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Sequence of licensee actions which led to confirmation of
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release point; Nature and extent of radioactivity release;
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Initial and subsequent notifications made by licensee
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personnel to licensee management, NRC, state and local agencies, off-site support facilities, press; and, l
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Whether or not the above actions are acceptable based on
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regulatory requirements, and procedural controls.
Corrective Action - Technical That immediate corrective actions were taken to tenninate
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the off-normal radioactivity release were appropriate to correct the cause of the release and were taken satisfactorily;
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Responsibility was assigned for assuring completion of
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specific and generic measures planned to prevent recurrence, including equipment / component modifications, procedural changes, and training; and, The above actions were adequate to assure prompt termination
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of the release and to prevent recurrence.
Safety of Operations - Technical Whether or not the event involved continued operations in
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violation of regulatory requirements or licensee conditions.
c.
Documents Reviewed The following documents were reviewed:
Licensee Sequence of Even'ts for the event;
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Station Administrative Procedure 1001, Revision 4,
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September 21, 1979, "TMI Document Control;"
Health Physics Procedure 1631.2, Revision 5, October 30, 1979,
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" Sampling of Reactor Building" (Unit 2 only);
Station Radiation Emergency Procedure 1670.1, Revision 6,
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l February 13, 1978, " Local Emergency Procedures;"
Metropolitan Edison Company Inter-Office Memorandum
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l (K. Frederick to B. D. Elam), TMI-II-R-4015, dated i
January 7, 1980, " Reactor Building Atmosphere Sampling Using HPR-227;"
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Metropolitan Edison Company Inter-0ffice Memorandum
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(J. J. Barton to Distribution), TMI-II-R-6351, dated February 15, 1980, " Procedures-Approval and Control;"
Supervisor of Operations, Memo No. 2-80-3, dated
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February 20, 1980, "Use of Procedures;"
Personal Memorandum #572 (J. G. Herbein to G. P. Miller),
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dated February 21,1980, " Procedure Team;" and, Sample Request Tag Sheets for Unit No. 2 HPR 227, Reactor
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Building Particulate Samples, Nos. 29867, 29868, 30403, 30404, 31210, 31211, 31825, 31826, 32452, and 32453.
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Op$rationalAssassment (1) The licensee (vendor) shift engineer who implemented the reactor building air sample procedure did not use the correct effective procedure (Revision 5) at the time of the event. This resulted because the individual did not obtain a controlled copy of the correct procedure as established by AP 1001. The procedure used by the shift engineer was a draft version of a proposed revision to 1631.2. This draft was properly approved both by the licensee and NRC staff, but it was in the typing stage, and was not yet effective (final copy not in the control room).
The control room operators were aware of the reactor building air sample evolution in progress since the evolution was discussed at a preshift briefing and the control room operators n:aipulated valves as part of the initial Tineup required by the procedure. However, one shift foreman on duty at that time indicated that no one in the control room referred to the actual procedure (Revision 5) from the control room files during the sampling evolution.
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The correct effective procedure (Revision 5), contained criteria for terminating the sampling (if an excessive increase in air activity is observed three times the reading prior to sampling). NRC critical review of the strip charts following this event shows that the criteria was exceeded during February 12-13, 1980, as well as during previous occasions.
In addition the one hour recirculation time limit was exceeded for 12-15 hours without properly changing the procedure.
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The failure of the control room operators to properly implement HP 1631.2 is contrary to the NRC Order for
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Modification of License dated July 20, 1979, and Tech-nical Specifications (Appendix A) TS 6.8.1 dated February 11, 1980 l
(320/80-02-03).
(2). Based on a discussion with the responsible shift engineer's supervisor of the air sample event, the shift engineer implementing the sample procedure was never formally
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indoctrinated in the established administrative controls of the licensee. The shift engineer is a member of one of the contractor service groups provided for the recovery staff.
Licensee management indicated that the shift engineer's -
supervisor was responsible for conducting training of these administrative controls. The supervisor indicated that ~ this responsibility was not clearly delineated.
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supervisor did possess a generai familiarity with AP 1001 l
but he stated that the specifics of how to get a control
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procedure was not discussed with the shift engineer who implemented the air sample procedure.
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The failure of the licensee to properly train the individual who implemented HP 1631.2 is contrary. to the 10 CFR 50, Appendix B, the approved FSAR Quality Assurance Plan, ANSI 18.1, 1971, paragraph 5.4(320/80-02-04).
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Radiological Assessment
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(1) The auxiliary building exhaust monitors calibration
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procedures and calitration records for Kr-85 were discussed
'with the licensee. The licensee stated that the auxiliary building exhaust monitors AM-1 through 4 were calibrated for Kr-85. The NRC staff reviewed the auxiliary building
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monitors calibration data and noted that Kr-85 was used to calibrata AM-1 through 4 monitors. The calibration data and plots were reviewed by the NRC staff and found to be acceptable for the four downstream monitors (AM-1
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through 4). AM-5, upstream of AM-1 through 4, and in series, was designated by the licensee to be their
" Official" radiogas release monitor rather than AM-1 through 4.
Monitor AM-5 is used to monitor the entire flow of the plant exhaust prior to its branching into four exhaust ducts (1, 2, 3, and 4) which are monitored by AM-1 through 4, respectively.
Initial review of AM-5 calibration records showed that AM-5 was not calibrated
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for Kr-85.
Subsequent review and evaluation of this area indicated that the licensee used AM-1-4 monitoring results to evaluate gaseous and particulate releases.
The NRC staff has no further questions in this area.
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(2) During the period of February 12, 1980, at 1951 hours0.0226 days <br />0.542 hours <br />0.00323 weeks <br />7.423555e-4 months <br /> through February 13,1980, at 1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br />, the total release activity, during the reactor building gas sampling,
was calculated by the NRC staff to be 4.1 curies of Kr-85. The Kr-85 release was based on integration of the rise on the Unit 2 vent radiogas monitor chart (AM-5).
The NRC staff reviewed the Unit 2 radiogas releases during.the months of January and February 1980.
Approx-imately 80 curies of Kr-85 were released from Unit 2 during the month of January 1980.
This release was partially. contributed tg identified leaks in the hydrogen purge line.
For the month of January and through February 13, 1980, 18.1 curies of Kr-85 were released during the hydrogen purge line recirculation operation.
These releases were as shown below.
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HPR-227 Recirculation Times Kr-85 Curies Released 1/2 at 1445 to 1512 0.07 1/3 at 0510 to 0605 0.16 1/9 at 1110 to 1300 0.30 1/15 at 1815 to 1/16 at 1425 3.10 1/23 at 1015 to 1115 0.30 1/30 at 0108 to 1433 4.60 2/6 at 0250 to 1700 5.50 2/12 at 1915 to 2/13 at 1245 4.10 These releases are well below the regulatory limits of 10 CFR 20 and TMI-2 Environmental Technical Specifications (ETS).
Preliminary offsite dose calculations for the February 12-13 release were performed by the NRC staff.
The total skin
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beta and whole body gamma dose at the highest X/Q location were approximately 0.017 mrem and 0.00021 mrem, respectively.
The NRC staff reviewed the licensee's gaseous effluent monitors strip chart for eight releases during January and February and noted values as indicated by the AM-5 (gas) monitor. These values indicate that six of the eight_ releases resulted in AM-5 monitor readings at greater than (or equal to) three times the monitor reading prior to the release which 's in violation of the effective procedure (Revision 5) for this sampling evolution. This is addressed in paragraph 5.d(l) and (2).
6.
Health Physics and Environmental Inspection and Review a.
Plant Tours
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On a daily basis three shift inspectors completed a general i
plant tour including all control points and selected radio-
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logically controlled areas. Observations included:
l Access control to radiologically controlled areas;
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Adherence to Radiation Work Pennit (RWP) requirements;
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Proper use of respiratory protection equipment;
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Adherence to Health Physics and Operating Procedures;
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I Use of survey meters including personnel frisking techniques;
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Various logs / records to ascertain current licensee
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actions / evaluations / problem areas; l'
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~ Cleanliness and. housekeeping conditions;
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Fire ~ protection measures; and,
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Construction status and startup testing progress.
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Findings were acceptable, exepct as described in Paragraph 6.c.
and 6.d.
b.
Measurement Verifications The below listed measurements were independently obtained to verify the quality of licensee performance in these selected areas:
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Radioactive material shipping;
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Radiological control radiation and contamination surveys;
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and,
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Onsite environmental air sample.
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Findings were acceptable, except as described in Paragraph 6.d.
c.
Posting of Radiation Areas
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On February 2,1980, an NRC staff member was performing independent radiation surveys for verification of licensee's posting and labeling of radiation / radioactive materials areas.
While performing surveys outside the EPICOR I. processing-bui-hitng, the staff member discovered the 7-10 millirem /hr unposted area.
These dose rates were verifiec by licensee surveys, utilizing licensee survey meters.
The radiation levels were caused by a bag of contaminated materials reading 90 millirem /hr on contact, which was stored inside the EPICOR I processing building, directly adjacent to the inner building wall.
This bag of
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contamir.ated material was subsequently shielded and later removed fran the building. This unposted radiation area was accessible for unrestricted access.
This was an item of noncompliance with 10 CFR 20.203.
(50-320/80-02-05).
d.
Airborne Samoling for Tritium On February 16, 1980, water was transferred from the auxiliary
building emergency liquid cleanup system into tha. Unit 2 spent fuel pool "B".
The concentration of tritium in the water was I
8.35 x 10-2 uCi/ml. An air sample collected during the transfer showed a tritium concentration of 2.08 x 10-7 uCi/ml,
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which was 4.16% of maximum permissible concentration in air (MPCa) for occupational exposures specified in 10 CFR 20, Appendix B, Table I, Column I.
At the request of the NRC staff member air samples were collected on February 21, 1980 and analyzed for tritium and sample results were from 3.23 x 10-7 uCi/ml l
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to 3.92 x 10-7 uCi/ml.
The NRC staff reviewed the airborne radioactivity survey results for t.he period February 16-26, 1980, and detennined that the only samples analyzed for tritium were those on February 16 and 21, 1980.
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The licensee stated that there is no need to sample the air
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for tritium since the concentration of trivium in water was less than MPCa. The airborne critium was raleased frcm the
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pool by evaporation of the water; the amount of airborne is not only dependent on the concentration in the water but also
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on other factors such as relative humidity, ventilation flow and volume charges and temperature of the air and water.
Therefore, the fact that the concentration in the water was less than MPCa does not assure, by itself, that the airborne concentration would be less than MPCa or that no radiological problems existed.
10 CFR 20.201(b) requires that the licensee make such surveys as may be necessary for him to comply with the regulations.
10 CFR 20.201(a) defines " survey" as an evaluation of the radiation hazard, such as the measurement of concentrations of radioactive material present.
10 CFR 20.103.a.(3) requires for purposes of detennining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, shall use measurements of radio-activity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intake of radioactivity by exposed individuals.
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Although tritium was identified in the sample collected and analyzed on February 16, 1980, no further surveys were performed until requested by the NRC staff on February 21, 1980, and during the water transfer on February 26, 1980.
Neither measurements of airborne tritium nor measurements of radioactivity excreted from the body were made. This is an item of noncompliance with 10 CFR 20.201(b) in that the licensee did not make adequate surveys to evaluate the radiation hazards present in the fuel handling building around the spent fuel pool.
(50-320/80-02-06)
7.
Radioactive Material Shipments On February 6, 1980, the licensee shipped a reactor coolant sample l
(approximately 100 uCf/ml) to Babcock and Wilcox, Lync'hburg, Virginia.
I The 30 ml coolant sample was packaged in a metal sample bomb which l
was placed in absorbent material and dunnage inside a Department of Transportation (DOT) specification 7A container.
When the consignee opened the package it was detennined that the inner containment
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vessel (sample bomb) had. leaked.
On March 6,1980, the licensee shipped a 55 gallon DOT specifi-
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cation 7A drum to Oak Ridge National Laboratory (ORNL), Oak Ridge, Tennessee. The drum contained 10 polyethylene sample bottles containing liquid activity. Wh'en the consignee opened the shipment it was determined that four of the sample bottles leaked during shipment. One of the leaking bottles contair.::d a reactor coolant
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bleed tank sample (approximately 100 uCi/ml), the others contained j
orders of magnitude of less activity.
This area is receiving additional evaluation by the NRC staff.
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8.
Unit 2 Processed Water Storage Tanks (PWST)
a.
On February 28-29, 1980, and March 3-6, 1980, a review of aspects (as noted below) of the construction of PWST (two 500,000 gallon radwaste liquid storage tanks) was conducted.
ECMs #545 and 571 and specifications / drawings for control
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criteria.
Interview with cognizant personnel GPU engineering and QC
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and Bechtel engineering and construction.
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Inspection of completed work on earth excavation for
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foundations, b.
No items of noncompliance were identified, however, one concern resulted from this inspection.
During this review it appeared that analysis for soil suit-ability was not going to be performed prior to construction of the tanks. The NRC staff expressed concern that if density of compacted soil was not known the long term structural integrity of the tanks would not be known.
As a result of this review the licensee revised ECM 571 to incorporate soil testing as specified in Bechtel Specification No. 234.
The NRC staff has no further comments in this area.
9.
Unresolved Items
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Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items disclosed /
reviewed d';r'ng this inspection are discussed in Paragraphs 2 and 4. d(1 )'.
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10.
Exit In'terviews Meetings were held with licensee management to discuss inspection findings and concerns as noted below.
Unit 1 Meeting on March 21, 1980
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Licensee Representatives G. Miller, Manager-Unit 1 Restart G. Troffer, Deputy Manager-Unit 1 Restart
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e NRC Representative A. Fasano, Chief, TML Site Operations Section Findings in the operations and health physics areas for the inspection period were discussed.
Unit 2 Meeting on March 19, 1980 Licensee Representatives J. Barton, Manager Sita Operations, TMI-2 J. Chwastyk, Operations Supervisor, TMI-2 R. Heward, Radiological Control Manager, TMI-2 G. Kunder, Supervisor of Compliance, TMI-2 P. Ruhter, Manager, Radiation Technical Support NRC Representatives J. Collins, Deputy Program Director, TMI Program Office R. Conte, TMI-2 Senior Resident Inspector A. Fasano, Chief, Site Operations Section D. Haverkamp, TMI-l Senior Resident Inspector M. Shanbaky, Senior Radiation Specialist Findings in the operations and health physics areas for the
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inspection period were discussed.
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