IR 05000289/1981034
| ML20040D779 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/15/1982 |
| From: | Fasano A, Moslak T, Shanbaky M, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20040D773 | List: |
| References | |
| 50-289-81-34, NUDOCS 8202020244 | |
| Download: ML20040D779 (7) | |
Text
{{#Wiki_filter:- . U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
50-289/81-34 Docket No. 50-289 ) License No. DPR-50 Priority -- Category C Licensee: GPU Nuclear Corporation
P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection at: Middle _ town, Pennsylvania Ins pectio "c'onducted :,Decemberr15-29, 1981 \\ / W /93 Inspectors : _ date signed' T. Moslak, Radiation Specialist tK L i/is/et L. Thonus, Resident Inspector (TMI-2) date signed Reviewed by: M.
M /[/v[[Z M. ShanbaEy, Senior Radi1ition Specialist date signed Approved by: h. #/ se o _//[S'/f(& 'K. Fasano, Chief, Three Mile Island Section, da te' signed Projects Branch No. 2 Inspection Summary: Inspection on December 15-29,1981 (Inspection Report No. 50-289/81-34) Areas Inspected: Routine unannounced safety inspection by resident inspectors of radioactive waste systems including tests of air cleaning systems, the Hittman solidification system, effluent control instrumentation, radioactive liquid waste sampling and analysis, procedures, records, and reports of effluents.
Th : inspection involved 75 inspector-hours by 2. resident inspectors.
_R_esul ts : Of the five areas inspected, five items of noncompliance were l identified in two areas (failure to monitor gaseous effluent release i paths, paragraph 3.a; failure to make suitable measurements of concentrations ' of airborne radioactive materials in restricted areas, paragraph 3.b; failure to document surveys, paragraph 3.c; failure to have adequate procedures, paragraph 3.d; and, failure to adhere to Radiological Controls Procedures, paragraph 4).
8202020244 820118 PDR ADOCK 05000289 G PDR .
- . Detail s 1.
Perso_ns Contar.ted
- B. Ballard, Quality Assurance Modifications / Operations Manager J. Boyer, Radwaste Engineer
- J. Fornicola, Quality Assurance Manager
- E. Fuhrer, Radwaste Operations Manager
- W. Heysek, Site Audits Supervisor
- G. Kuehn, Deputy Radiological Controls Manager
- W. Miller, Licensing Engineer J. Reed, Chemistry Supervisor C. Smyth, Licensing Supervisor M. Snyder, Preventive Maintenance Manager
- C. Stephenson, Licensing Engineer
- D. Tuttle, Radiological Engineering Manager (Acting)
P. Velez, Radiological Controls Field Operations Manager The inspector contacted other licensee and contractor employees including members of the engineering, radiological controls, chemistry, and operations staff.
- denotes those individuals present at the exit interview on December 29, 1981.
2.
Effluent Controls Systems a.
Op_erability Tests of Air Cleaning Systems The licensee is required to roeet operability requirements and perform surveillance activities of air treatment systems.
These include: Emergency Control Room Air Treatment System -- Reactor Building Purge Air Treatnent System -- Auxiliary and Fuel Handling Exhaust Air Treatment System -- The inspector performed a visual inspecticn of the Emergency Control Room Air Treatment System and associatcd instrumentation.
. The results of surveillance tests were reviewed to verify that the licensee met the operability and surveillance requirements of Technical Spect fication (TS) Sections 3.15 and 4.12.
One set of auxiliary and fuel handling building exhaust fans had been tagged out since September 16, 1981, and was inoperable.
The other train was operable and,thus,the licensee met the TS operability requirements and was not in an action statement.
The licensee was not required to conduct halogenated hydro-carbon or dioctyl phthalate (DOP) tests on the filter systems at the time of the inspection due to plant shutdown.
Such tests will be required prior to Unit 1 restart and will be reviewed in a subsequent NRC inspection, k
. . -3-The inspector reviewed the following Surveillance Procedures (SP) to verify that operability tests of air treatment systems were conducted properly and within the required frequency.
SP 1303-5.5, " Control Room Emergenc.) Filtering System -- Operability Tests" SP 1303-5.8, " Auxiliary and Fuel Handling Exhaust Air -- Treatment Fan Operational Test and Filter D/P" The inspector examined shift and daily operational checks per SP 1301-1 for the months of August, September, and October 1981, approximately 90 records, to verify completion of routine surveillance requirements. Based upon this review, the inspector determined that the stated SP's were completed as requi red.
No items of noncompliance were identified.
b.
Calibration and Functional Tests of the Radiation Monitoring System (RMS)_ Technical Specification, Appendix A, Table 4.1.1, Item 28 and Sections 4.21.1 and 4.21.2 requires,in part,that area gamma monitors, atmospheric monitors, and liquid monitors be calibrated every calendar quarter.
The inspector reviewed SP 1302-3.1, "RMS Quarterly Calibration" completed during calendar year 1981 and verified the procedure was completed as required.
No items of noncompliance were identified.
Technical Specification, Appendix A. Sections 4.1.1, item 28; 4.21.1, Table 4.21-1.1.a, 2a, 2b, 3a; 4.21.2, Table 4.21-2.la, lb, 3a, 4a Sa, 5d, Se and 4.12.1.3, requires that functional tests be performed monthly to verify operability of the RMS and effluent instrument control channels.
The inspector reviewed SP 1303-4.15, " Radiation Monitoring Systems," completed January 1981 through November 1981.
No items of noncompliance were identified.
3.
Hittman Waste Solidification System This system is an in-container cement solidification system provided by the Hittman Nuclear and Development Corporation.
The originally installed solid radwaste system using urea formaldehyde (UF) as the solidifying agent,was replaced by this interim system because the UF system did not provide a complete solidification of waste.
The interim system is to be used until a permanent solidification system is installed and demonstrated operational at TMI-1.
._ .
. -4-The interim system is installed and operated in a shed outside the TMI-l Auxiliary Building. Waste is transferred from the auxiliary building via hose to a solidification container housed in the shed.
Two radioactive waste (radwaste) types are being solidified. Spent resins are transferred from the spent resin tark (SRT) and/or the used precoat tank (UPT) via flexible firehoses to the solidification container; or evaporator bottoms from the concentrated waste storage tank (CWST) are transferred using a hose line, from the original UF system, to the solidification container.
a.
Monitoring of Release Pathways Upon filling the solidification container with liquid radwaste, pre-determined amounts of cement and chemical additives are batch loaded into the container by means of a screw conveyor from a bulk solids transport device located adjacent to the Hittman solidification shed.
Dusting is minimized by the use of a dust collector, which draws air from the container head space and exhausts it through flat fabric filters to the interior of the shed.
The shed does not have a controlled ventilation system nor is the exhaust from the dust collector monitored for airborne radioactivity.
This dust collector exhaust is a potential unmonitored pathway for release of airborne radioactivity to the environment.
A second potential unmonitored release pathway exists in that during filling of the solidification container with evaporator bottoms, the inspection port (an 8" x 8" penetration located on top of the container) is maintained opened to permit a visual check of the liquid level.
Failure to provide the means to monitor these effluent discharge paths is in noncompliance with 10 CFR 50, Appendix B, Criterion III.
Design Control, which requires that applicable regulatory requirements be translated into specifications, drawings, ! procedures, and instructions.
Regulatory requirements of 10 CFR 50, Appendix A, General Design Criteria, Criterion 64 states in part that "...means shall be provided for monitoring... effluent discharge paths...for radioactivity that may be released from normal operations including anticipated operational occurrences and from postulated accidents.
The licensee's approved Operational Quality Assurance Program, FSAR, Revision 9, May 28,1981, Article 4.2.1.2 requires that all design regulations be reviewed and adhered to unless specific Technical Specifications or FSAR changes are requested.
This failure to incorporate , Criterion 64 into the design of the radwaste solidification system represents a lack of effectiveness of the licensee's Quality Assurance Program.
This is an apparent item of noncompliance (50-289/81-34-01).
__ _
.. - . -5-b.
Evaluat_fon of Airborne Activity in Restricted Areas When filling the solidification container with evaporator bottoms, the operator must periodically visually check the liquid volume in the container by directing a flashlight through the inspection port and observing the liquid level.
During performing this check, the operator could be exposed to gases and vapors being discharged from the container head space. Monitoring of gases and vapors being released from the inspection port was not performed as required by 10 CFR 20.103(a)(3) in that the licensee has not made suitable measurements of concentrations of radioactive materials in air for detecting , and evaluating airborne radioactivity in restricted areas.
This represents an apparent item of noncompliance (50-289/81-34-02).
c.
Documenting Surveys TMI-l Operating Procedure 1104-28A, " Radioactive Waste Solidi-fication - Hittman," Revision 2, effective September 4,1981, requires in Section 2.3 that a radiation survey shall be made of the waste transfer hose during each use and a followup survey shall be made following each flush.- The inspector determined through examination of records and discussions with various members of the licensee's Radwaste and Radiological Controls Departments, that such surveys were performed.
However, these surveys have not been documented.
This is an apparent item of noncompliance with 10 CFR 20.401(b) (50-289/81-34-03).
d.
Procedures for the Control of Radioactivity Prior to filling the solidification liner with radwaste, the radwaste operator is to connect a flexible vent line to the , liner's fill head and run this line from the Hittman shed into the auxiliary building, place the exhaust end of the line in a 55-gallon drum and re-position a portable airborne radioactivity monitor (AMS-3) near the drum.
The Radwaste and Radiological Controls Department personnel are aware that these preparations are a routine practice during liner filling. However, failure to document these instructions in Operating Procedure 1104-28A is contrary to Technical Specificiations, Appendix A, Section 6.8.1 that requires written procedures be established, implemented and maintained that meet or exceed the requirements and recommendations of Section 5.1 and 5.3 of ANSI N18.7-1972, and Appendix "A" of < USNRC Regulatory Guide 1.33, November 1972 Sections of ANSI 18.7-1972 which specifically apply to the licensee's failure to incorporate venting instructions into procedures are Section 5.3 which states in part ... procedures shall " provide an approved preplanned method of conducting operations
, . , _ -. _ ._
- , -6-to minimize reliance on memory" and Section 5.3.3 which states in part ... Instructions for energizing, filling, venting, " draining, starting up, shutting down, changing modes of operation and other instructions appropriate for operations of systems related to the sa'fety of the plant shall be delineated in' system procedures".
This is an apparent item of noncompliance (50-289/81-34-04).
4.
Controlled Vacuum Cleaners During this inspection the licensee's program for using vacuum cleaners in controlled areas was reviewed.
Two Radiological Control Procedures (RCP) are being used to regulate the use, cleaning, and maintenance of the controlled vacuum cleaners.
Failure to adher to the requirements of these procedures pursuant to Technical Specification, Appendix A Section 6.11, was identified in two occurrences.
RCP 1796, "D0P Testing Controlled Vacuums," Revision 0, effective -- March 3,1981, requires, in paragraph 5.1.3, that the D0P generator and detector be calibrated within the past six months.
Contrary to this procedure, controlled vacuum cleaners,whose High Ffficiency Particulate Air (HEPA) filters were tested in July and August of 1981, were tested with equipment that was calibrated in April 1980.
RCP 1683, " Controlled Vacuum Clear,ers," Rcvision 3, effective -- July 17,1981, re',aires, in paragraph 5.2.4, that the location of all vacuum cleaners be determined weekly.
Contrary to this procedure, locations of controlled vacuum cleaners have not been determined since November 1981.
This is an apparent item of noncompliance (50-289/81-34-05).
, 5.
Concentrated Waste Storage Tank Analyses The inspector reviewed the results of radioisotopic analyses of samples of evaporator bottoms and discussed with the licensee representative the reported presence of Sb-122 in analyses performed on December 2,1981 for solidification liner numbers 32 and 33.
Sb-122 has a two day half-life anf should not be present after three years of cold shutdown.
The licensee representative acknowledge the questionable presence of this isotopa and agreed to review this area.
This is unresolved pending completion of licensee action and subsequent NPC review (50-289/81-34-06).
. .. -7-6.
Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is an item of noncompliance, a deviation, or acceptable.
Unresolved items disclosed during this inspection are discussed in paragraph 5, 7.
Exit Interview At periodic intervals during the course of this inspection, meetings were held with senior facility management to discuss inspection scope and findings.
On January 5,1982, a meeting was held with Messrs. C. Smyth and W. Miller of the GPU Nuclear staff. At this meeting, the licensee representatives stated that the Hittman Solidification System was ' currently shutdown and not scheduled for operation until April 1982.
In addition, an evaluation of the structure and oper system was being initiated. (ref. Detail paragraph 3)ation of this . !
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