IR 05000320/1979013

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IE Insp Rept 50-320/79-13 on 790515-0612.No Noncompliance Noted.Significant Findings Identified:Failure to Post, Barricade or Control Access to High Radiation Areas
ML19290A174
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Site: Crane Constellation icon.png
Issue date: 07/09/1979
From: Haverkamp D, Mccabe E, Neely D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
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ML19290A173 List:
References
50-320-79-13, NUDOCS 7910170505
Download: ML19290A174 (15)


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U.S. NUCLEAR REGULATORY-COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

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Region I

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Report No. 50-320/79/13 Docket No. 50-320 C

License No. DPR-73 Priority Category

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Licensee:

Metropolitan Edison Company P.O. Box 542 Reading, Pennsylvania 19640 Facility NamE:

Three Mile Island Nuclear Station, Unit 2 Inspection at:

Middletown, Pennsylvania Inspection conducted:

May 15 - June 12, 1979 Inspectors:

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~2/d!7i v

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Favernamp, Leadgeactor Operations date signed D.

R.

Inspector N A. &rr&

'7ll=lM D. R. Neely,/Leac Raciation Specialist date signed date signed Approved by:

C. C. b 0.4, h L.

7 /9119 E.

G. McGaoe, chiar, tr Resident date signed Office-TMI 2 Inspection Summary:

Insoection on May 15 - June 12, 1979 (Rcport No. 50-320 79-13)

._ Areas Insoected:

Special inspection by IE Resident Office staff and shift inspectors of: new and revised procedures; plant operations including logs, records, issued procedures, performance of tests, measurement verifications,

,stgnificant evolutions witnessing, and general plant tours; in-plant health physics including documentation, posting and labeling reviews, vitnessing of activities, and area tours. The inspection included continuous shi ft coverage by both reactor operations and radiation specialist inspectors.

Results:

Si gificant findings were brought to the attention of licensee management wnen identified. Acceptable corrective actions were initiated without additional enforcement action being undertaken.

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2224 021 Region I Form 12 (Rev. April 77)

7910170 Gof

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DETAILS

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1.

_ Persons Contacted Licensee and contractor personnel contacted during this inspection are identified in the appropriate report sections.

2.

IE Inspection Participants The following tabulation identifies the TMI-2 IE Resident Office professional personnel participating in this inspection.

a.

Resident Office Staff Mr. R. Conte, Reactor Operations Inspector, EE:RI, May 28-June 12, 1979 Mr. D. Haverkamp, Lead Reactor Operations Inspector, IE:RI, Mey 15-June 12, 1979 Mr. R. Keinig, Chief, IE Resident Office, IE:RI, May 22-June 4,1979 Mr. E. McCabe, Chief, IE Resident Office, EE:RI, June 5-June 12, 1979 Mr. R. McGaughy, Chief, IE Resident Office, EE:RI, May 15-May 21,1979 Mr. D. Neely, Lead Radiation Specialist, ZE:RI. May 15-June 12, 1979

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Mr. W. Raymond, Reactor Operations Inspector, IE:RI, May 29-June 8,1979 Mr. W. Rekito, Reactor Operations Inspector, IE:RI, June ll-June 12, 1979 Mr. J. White, Radiation Specialist, IE :RI, May 29-June 12,1979 b.

Shift Reactor Ooerations Insoectors Mr. M. Ashenden, EE:RII, May 15-May 23 and June 12, 1979 Mr. K. Baker, EE:RIII, May 22-June 4, 1979 Mr. C. Brown, IE:RIII, May 15-May 20,1979 Mr. T. Donat, IE :RII, June 7-June 12, 1979 Nb. E. Johnson, IE:RIV, June 4-June 8 and June ll-June 12, 1979 Mr. B. Jorgensen, EE:RIII, May 19-May 23, 1979 Mr. L. MacGregor, IE:RIII, May 21-June 3,1979 Mr. L. Miller, EE:RIV, May 15-May 31, 1979 Mr. P. Morrill, IE :RV, June 1-June 11,1979 Mr. J. Smith, IE:RIII, June 4-June 12,1979 Mr. A. Wagner, IE:RII, May 24-June 6,1979 c.

Shift Radiation Soecialists Mr. B. Baird, IE:RV, May 25-June 12, 1979 Mr. C. Cchen, IE:HQ, May 15-May 21,1979

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Mr. J. Curtis, IE:RV, June 4-June 6,1979 Mr. 3. Dubry, IE:RIII, June 1-June 12, 1979 Mr. J. Everett, IE:RIV, May 15-May 28,1979 Mr. R. Greger, IE:RIII May 15-May 17, 1979 Mr. L. Hueter, EE:RIII, May 18-May 31,1979 Mr. C. Hosey, IE:RII.

May 21-May 31, 1979 Mr. D. Miller, IE:RIII, June 1-June 3, 1979 Mr. W. Millsap, IE:RII, June 12, 1979 2224 022

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-3-Mr. B. Murray, IE:RIV, May 29-June 11,1979 Mr. M. Schumaker, IE:RIII, May 15 and June ll-June 12, 1979 Mr. R. Thomas, EE:RV, May 15-May 24, 1979 Mr. L. Thonus, EE:RI, June 4-June 12, 1979 Mr. J. Wray, IE:RIII, May 15-May 21,1979 3.

Review of New and Rcvised Procedures Special Operating, Operating, Emergency and "Z" procedures were reviewed by the Resident Office during this inspection.

"Z" procedures are system operating procedures written for the TMI-2 Recovery Program, and govern special evolutions and/or use of off-ncrmal plant systems.

Procedure review included both Health Physics and Operations aspects, and included consideration that:

(1) the procedure, when implemented, vould not degrade the containment vf radioactive material, jeopardize core cooling, or result in excessive personnel exposure; (2) the procedure technical content was adequate to perform the intended evolution; and (3) the procedure conformed with the general criteria of ANSI N18.7-1972.

Procedures reviewed during this report period are listed below, together with the dates on which IE comments vere ccmpleted.

-- Z-33, R2 - Water Sump Discharge W-IWTS & IUFS (June 5,1979)

-- SOP, RO - Standby RC Pressure Control System (June 1, 1979)

-- OP-2107-1.6, RO - Task TS 10/11 Balance of Plant (BOP) DG-A (GRAY) Diesels and Auxiliaries (June 6, 1979)

-- OP-2107-1.5, R0 - Task TS 10/11 Balance of Plant (BOP) DG-B (WHITE)

Diesels and Auxiliaries (June 6, 1979)

-- EP-9, RO - Loss of Make Up (June 8, 1979)

-- SOP, RO - Test of Condensate Polisher System (June 6, 1979)

-- Z93. R3 - RB Su=p Level Measurement (June 4, 1979)

-- Z93, R4 - RB Sump Level Measurement (June 5, 1979)

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-- Z58, RO - RCS Pressure Control - CFT Float (June 8, 1979)

-- SOP, RO - Leak Check Penetration - R-605 (June 8,1979)

-- Z39, R1 - Fill BAMT With BA & Caustic (June 8,1979)

-- Test Procedure for Standby RCPCS Valve SPC-V-71 (June 13,1979)

-- U-2, RB, Atmosphere Gas Sampling Using HPR-227 (June 13,1979)

Composite NRC cm=ments on procedures were forwarded to the licensee by

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NRR. No instances of failure to resolve NRC comments were identified.

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Review of Plant Operations a.

Shift Logs, Operating Records and Ooerating Procedures The following logs, racords and operating procedures were roviewed.

-- Shift Foreman's Log for the period April 28 to May 5, 1979.

Control Room Log Book for the period April 2F to May 5, 1979.

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-- Lis:ed Lead and Jumper Log as of June 4,1979.

-- Do Not Operate and Caution Tag Log as of May 23, 1979; June 4, 1979 and June 6, 1979.

-- Alarm Response Procedures (sampling review) as of June 8,1979.

b.

Surveillance Tests The following surveillance tests were witnessed.

-- SP 2303-M16D, Operational Test of Emergency Diesel (B) on May 24, 1979.

-- SP 2303-M16D, Operational Test of Emergency Diesel (A) on June 3, 1979.

c.

Measurement Verifications The #911owing measurements were independently calculated by the inspector.

Reactor Building Su=p Level on May 15, 16, 23, June 8, 9, 11

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and 12, 1979.

-- Reactor Coolant System Leakage on June 11, 12 and 13, 1979.

d.

Preocerational Tests Tha following tests were witnessed for new systems associated with the TMI 2 Recovery Progra=.

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"B" Decay Heat Removal Loop Hydrostatic Test on May 15, 1979.

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"A" Train Decay Heat Removal Loop, Hydrosta* '. Test sn May 18, 1979.

-- Gray Diesel Loading Test by "C" Condensate Pump on May 21, 1979.

-- Z-114, Operational Test of Long Term OTSG B Pump on May 23, 1979.

-- Hydrostatic Test of Feedwater Heaters in OTSG B System on May 22,

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1979.

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-- EPICOR II Transfer Pump Operability Check oa May 31, 1979.

-- SOR R-2-79-21, Waste Gas System Integrity Test Phase II on June 1, 1979.

-- Auto Mode of Operation of EPICOR II on June 5,1979.

e.

Plant Tours During the period May 15, 1979 through June 13, 1979, tours of the following areas were conducted (number of tours are indicated in parenthesis).

Cleanliness / Housekeeping conditions were observed along with Radiological and Fire Protection Measures.

In addition, for the specific areas listed, construction status and testing progress were noted.

-- General Plant Area including the outside sections within the Protected Area.

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"B" OTSG Long Term Cooling System Area of the Turbine Building.

(13)

-- Fuel Handling Building including Standby Pressure Control System and Fuel Pool Waste Storage System.

(17)

-- Chemical Cleaning Building including the Auxiliary Building Emergency Liquid Cleanup System (EPICOR II).

(21)

-- Control Room including panel observations.

(7)

-- Auxiliary Building.

(3)

-- Various sections of Control Building and Servit.2 Building.

(12)

-- Vent Stack and Roof Area of Auxiliary Building.

(2)

f.

Sienificant Evolutions *

The following operations were witnessed.

-- The Pressurizer Steam Bubble Formation en May 16 and 24, 1979.

-- Reactor Coolant System Solid Operation achieved on May 22 and 29, 1979.

g.

Findings During a review of the Lifted Leads and Jumpers Log it was

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observed that several leads had been lifted in various panels in the Control Room without documentation in the appropriate section

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-6-of the log.

These leads had been lifted to support certain temporary modifications associated with the TMI-2 Recovery Program. Upon notification by the inspector, the licensee representative entered these leads in the appropriate section of the log book for those leads considered temporary modifications.

Licene'e commitments' for additional correctiv'e action are descri ed in Detail Paragraph 6.

With the exception of the above, no una_cceptable conditions or significant discrepancies were identified in the review of plant operations.

5.

In-Plant Health Physics a.

Qualification of Personnel Technical Specification 6.3, Unit Staff Qualifications, requires each member of the unit staff to meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions.

The qualifications and backgrounds of the contractor supplied health physics (H.P.) supervisors and technicians, hired to supplement the licensee's H.P. s,taff during the incident recovery

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effort, were reviewed.

Several personnel were found to be functioning outside the position limits established by education and experience as delineated in accordance with ANSI N18.1-1971,

" Selection and Training of Nuclear' Power Plant Personnel", Section 4.3.2 " Supervisors" and Section 4.5'.2 " Technicians."

The individual qualifications and backgrounds were discussed with the licensee and the contractor.

The personnel involved were placed in positions comparable to their qualifications and background.

Licensee action is being taken to ensure that only qualified personnel are assigned to health physics positions in the future.

Effectiveness of licensee actions will be subsequently inspected.

(320/79-13-01)

b.

Posting and Area Control Tours of the controlled areas and independent radiation intensity measurements were made to verify licensee compliance with 10 CFR 20.203, " Caution signs, labels, signals and controls",

and Tech.nical Specification Section 6.12, 'Migh Radiation Area".

One significant inspection finding concerning high radiation area centrols.was identified during the period May 15 thru June 13, 1979. That-finding (320/79-13 -02) is appended to this inspection report as APPENDIX A.

Licensee action such as locking of doors and fabrication of additional lockable doors is being undertaken to improve access control to all High Radiation Areas with dose rates greater than

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1000 mrem /hr. Additionally, a licensee "High-Radiatio geg Control Check" sheet has been implemented to assure t 4L 026

-7-appropriate action is taken to post, barricade and control all such High Radiation Areas.

The effectiveness of licensee ce_:ective action will be subsequently inspected, c.

Exoosure Control (1) Personnel Dosimetry The licensee's personnel dosimetry program was reviewed against:

10 CFR 20.202, " Personnel Monitoring",10 CFR 20.101,

" Exposure of individuals to radiation in Restricted Areas" and Station Health Physics Procedure 1643, " Quality Assurance Tests for TLD Dosimetry System".

It was found that the licensee had not performed the annual TLD quality assurance (QA) test required by Procedure 1643, Section 5.3.

Record review indicated that the last complete annual test was begun on October 1977 and completed in December 1977.

Quality Assurance for the dosimetry system was discussed with licensee health physics representatives, who indicated that themsoluminescent dosimeter (TLD) cards will be prepared and sent for irradiation.

The QA testing is to be completed by June 12, 1979.

This item (320/79-13 03) will be subsequently reexamined.

(2) Respiratory Protection Review of respiratory protective equipment utilized pursuant to 10 CFR 20.103 (b) (2) was conducted.

Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection",

referenced in 10 CFR 20.103 (c) was used as the inspection standard.

Special Operating Procedure, SOP No. R-2-79-20 dated May 30, 1979, "Use of Charcoal Canister Respirator in Radiciodine Atmospheres" was included in this review. During review of MPC-hour records on May 23, 1979, several mathematical errors were identified.

These errors were brought to the attention of licensee health physics staff and correction was accomplished.

The inspector had no further questions on this item.

(3) Air -Sasoling General area air samples of airborne radioactivity concentrations have been used for job specific airborne activity. Breathing zone air samples provide more valid results, and the need for taking breathing zone air samples was discussed wir.h licensee representatives.

This item (320/79-13 -04) is unr_ solved and will be reexamined.

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-8-(d) Padioactive and Contaminated Material Control Radioactive and contaminated material control was reviswed fer the period May 15 thru June 12, 1979 for compliance with 10 CFR 20.203 (f) and Procedure 1682 " Control of Contaminated Tools, Equipment and Material". No unacceptable conditions or significant discrepancies were identified.

.(e) _ Solid Radioactive Waste Solid radioactive waste shipping and handling was reviewed for compliance with 10 CFR 20, " Standards for Protection Against Radiation" and 10 CFR 71," Packaging of Radioactive Material for Transport and Transportation of Radioactive Material under Certain Conditions".

(1) Shiements The following shipments were reviewed:

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Shiement No.

Date Item Total mci 79-49 5/16/79 laundry 21.93 79-50 5/19/79 RCS letdown sample 240.56 79-51 5/19/79 RCS letdown sample 66.10 79-52 5/24/79 Various liquid samples 341.81 79-54 5/31/79 laundry 10.3 79-55 6/11/79 RCS letdown sample 264.4 Ne unecceptable conditions were sidentified in the above shipments. However, tne licensee had not filed,as of June 15,1979, a-description of the Quality Assurance program for shipment of greater than Type "A" quantities of radioactive material in accordance with 10 CFR 71.51(a).

Until licensee submission and NRC approval of the required QA plan is effected, shipments of greater than Type "A" quantities of radioactive material is prohibited.

(2) Storage of Solid Radioactive Waste On-site storage of solid radioactive waste was reviewed

against Special Operating Procedure, SOP No. R-2-79-6,

"On-site Solid Waste Storage for TFE-2" dated 5/8/79.

The licensee is currently utilizing in-plant storage and storage in the area south and east of the Unit 2 cooling towers (old paint shop), with long term planning consisting of ctorage in:

existing metal buildings; semi-trailer storage; and storage in concrete structures for high level waste. No unacceptable conditions or significant discrepancies were identified.

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-9-(3) Sewage Disposal Special Operating Procedure, S0P No. Z-46, " Sewage Disposal," dated 5/1/79, provi~ des guidance for sewage removal from the site.

Procedure paragraph A, Limitations and Precautions, requires NRC notification prior to any shipment of sewage containing greener than background activity. NRC periodic review of the sample isotopic analysis for any indication of activity build up was conducted.

The disposal was found to be consistent with the requirements of 10 CFR 20.303 " Disposal by release into sanitary sewage systems" No unacceptable conditions or significant discrepancies were identified in this area.

(f) Procedures The following special operating procedures were reviewed against Technical Specification Section 6.8, " Procedures",

Section 6.11, " Radiation Protection Program" and the criteria presented in ANSI N18.7-1972," Administrative Controls for Nuclear Power Plants "

SOP NO.

Title Rev.

Date Z-29 Fill BAMT with NA0H Solution

6/9/79 Z-33 Sump Discharges to IWTS and

5/18/79 IVFS Z-93 Reactor Building Sump Level

6/8/79 Measurement R-2-79-04 operations of supplemental

5/9/79 Fans and Filters R-2-79-14 Balance of Plant Diesels

5/30/79 DG-A (Gray)

R-2-79-15 Balance of Plant Diesels DG-B

5/30/79 (White)

R-2-79-20 Use of Charcoal Canister in

5/30/79 Radio-Iodine Atmospheres R-2-79-25 U-2 Reactor Building

6/15/79 Atmosphere Gas Sampling using HPR-227 No unseceptable conditions or significant discrecan'.ies were identified.

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(g) Radioactive Effluent Releases (1) Liquid Effluent Releases All radioactive liquid effluent releases from the site during the reporting period were reviewed.

The licensee currently utilizes special operating procedure, SOP No.

Z-33, Rev 2. " Water Sump Discharges to IWTS and IWFS

" dated 5/18/79 and SOP No.

-51, " Liquid Releases from TMI", dated 5/2/79, for this purpose. All liquid radio-active releases were found to conform to the requirement:

of Z-33 and Z-51.

Additionally, procedures Z-33 and Z-51 were found to be consistent with the requirements of 10 CFR 20.106, " Radioactivity in effluents to unrestricted areas."

No unacceptable condi~. ons or significant discrepancies were identified.

(2) Gaseous Ef fluent Release The installation, calibration and operational characteristics of the Unit 2 Supplemental Vent Radiation Monitoring System was reviewed, including the following special operating procedures for system response determination and follow-up on system alarms:

SOP NO.

TITLE REV.

DATE R-2-79-1 Effluent Monitoring Data

5/20/79 Sheet Calculations fot Aux Bldg. Roof i

R-2-79-2 Response to Alarms for

5/1/79 Supplemental Unit 2 Vent Radiation Monitor System R-2-79-3 Supplemental Unit Radiation 0 5/1/79 Monitor Set Points No unacceptable conditions or significant discrepancies were identified.

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(h) Portable Radiation Survev Instrumentation The following portable radiation monitoring instrumentation calibraticn procedures were reviewed:

PROCEDURE NO.

TITLE REV.

DATE 1748 Operation and Calibration

2/14/77

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of the Eberline PIC-6A 1749 Portable / Lab Instrument

12/1/77 Calibration Schedule 22:24 OL30

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1756 Operation and Calibration

6/23/76 of Eberline 6112 Teletector Dose Rate Meter 1762 Operation and Calibration of

12/18/75 the R0-2 The following portable radiation survey instruments were reviewed with respect to the above:

MODEL SERIAL NO.

STATUS R0-2 393 No calibration data available R0-2A 222 No problems identified R0-2A 285 No calibration data available R0-2A 287 No calibration data available R0-2A 499 No problems identified PIC-6A 1750 No problems identified PIC-6A 1301 No problems identified 6116 14418 No problems identified 6112 14419 No problems identified The licensee indicated that high range instrumentation is transferred to the contractors' off site calibration facility and the calibration records are maintained there.

Tours performed on May 4 and 7, 1979 identified two personnel monitors, a RM-14 and a Portal Monitor, respectively, which appeared to be past due' calibration by approximately one month.

Adequacy of equipment calibration and records is in question (320/79-L3-05) and will be reexamined.

(il Plant Tours

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Tours were made to examine:

access control; personnel frisking; use of survey meters; adherence to Radiation Work Permit (RWP) requirements and proper use of respiratory prstection equipment.

The following was identified during routine tours:

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DATE ITEM 5/27/79 Individual performing decontamination of respiratory protective equipment was not wearing protective apparel as required by KRP No. 33335.

5/31/79 Same as above, RWP No. 33462.

6/2/79 Personnel observed working on the 281' elevation of the Auxiliary Building in supplied air, respiratory protection equipment as required by RWP No. 26318 without an air supply.

Personnel were breathing airborne radioactivity through disconnected hoses.

These items represent a failure to adhere to radiation protection procedures. Licensee corrective measures will be examined during a subsequent inspection.

(320/79-13-06)

6.

Exit Interviews Meetings were held with licensee management to discuss inspection findings and concerns as discussed in the following'.

a.

Exit Meetinz on May 25, 1979 The TMI-2 IE Resident Office Chief; EE:RI Fuel Facility and Materials safety Branch Chief;.TMI-2 IE Resident Office Lead Radiation Specialist and Lead Reactor Operations Inspector met with the following licensee representatives on May 25, 1979.

Mr. D. Hatrick, GPUSC Supervisor of Health Physics Mr. G. Kunder, Unit 2 Superintendent - Technical Support Mr. J. Logan, Unit 2 Superintendent Mr. T. Mulleavy, Station Supervisor of Health Physics Items discussed during this meeting were as follows:

(1) Containment Integrity (2) Technical Specifications

(3) Facility Procedures (4) Health Physics Discrepancies Inspector concerns associated with these areas were discussed along with the status of licensee actions for each item. Licensee corrective actions for each item were in progress at the conclusion

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of the inspection. These areas will be followed by NRC personnel on site.

(paragraph 6.b.(2) of this report also refers to these

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concerns).

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b.

Exit Meeting on June 15. 1(79 The TMI-2 IE Resident Office Chidf, Lead Reactor Operations Inspector and Lead Radiation Specialist met with the following licensee representatives after the conclusion of the inspection period on June 15, 1979 Mr. R. Bensel, Unit 2 Lead Electrical Engineer Mr. M. Bezilla, Unit 2 PORC Secretary Mr. J. Floyd, Unit 2 Supervisor of Operations Mr. D. Hetrick, GPUSC Supervisor of Health Physics Mr. G, kunder, Unit 2 Superintendent - Technical Support Mr. D. Limroth, Superintendent, Administrative / Technical Support Mr. J. Logan, Unit 2 Superintendent Mr. T. Mulleavy, Station Supervisor of Health Physics Mr. E. Murri, NUS Supervisor of Health Physics The significant findings of the inspection and licensee corrective actions were discussed as described below.

(1) Health Physics Findings (a) High Radiation Area Controls High Radiation Area Controls were not in compliance with Technical Specification 6.12.

The licensee has committed to developing a procedure for control of keys to High Radiation Areas, specifically the Auxiliary Building, and to upgrading High Radiation Area posting and surveillance to maintain positive control.

(320/79-13-02)

(b) Dosimetrv and Training Personnel dosimetry and ladiation protection qualification /

training of personnel has been deficient in several areas.

The licensee must assure that health physics administrative control requirements are met.

Quality assurance for personnel dosimetry must be reestablished, including checks of individuals nearing limits and ILD/ dosimeter checks.

Action due dates for corrective action of health

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physics problems are to be established.

(320/79<l3-03, 320/79-l'3-06)

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(c)

Instructions t) Workers

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Adequate instrucedons to workers on radiation hazards have not been proviCad pursuant to 10 CFR 19.

Plant

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and contractor personnel must be fully informed about radiation health hazards associated with their work at

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the facility.

The licensee stated that Health Physics personnel are developing an instruction list, in the form

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of a check-off, which will be posted at appropriate radiological work locations.

(320/79-13-07)

(d) Contractor Qualifications Contractor HP personnel qualifications were deficient, in that two individuals were found to be not pr.operly qualified.

The licensee has removed those individuals from HP responsibilities.

The licensee has co=sitted to develop procedural controls specifying qualification requirements for contractor HP personnel.

(320/79-L3 -01)

(2) Recoverv Operations Findings (a) Containment Inte grity Containment integrity is bel g treated in a piecemeal fashion. There is a need fv. a comprehensive, overall control document. A procedure for maintaining containment integrity has been partially drafted.

The licensee expects the procedure to be implemented by late June.

(320/79-13 -08)

(b) Technical Specifications Draft Technical Specifications for Recovery Operations have been submitted to the NRC by the licensee.

The revised format and content of these Technical Specifications is being reviewed' by NRR and OELD.

Af ter interim NRC concurrence with the draft specifications, a final licensee

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review will be conducted for adequacy and consistency with current plant conditions.

(c) Facility Procedures Facility procedure, require comprehensive review for major revision consistent with current plant recovery operations equipment operability.

A licensee schedule for procedure revision has been prepared.

The licensee's procedure review and revision program will be routinely monitored by NRC personnel on site.

(320/79-13-09)

(d) Wirine Changes

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Numerous wiring changes have been effected since the March 28 accident, some of which do not appear to have been documented and approved by either permanent design change controls or temporary lifted lead / jumper controls.

The licensee has committed to a review of applicable control cabinets and consoles to assure proper documentation of wiring changes.

(320/79-13-10)

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(e) Auxiliary Building Fire Protection and Emergency Lighting Fire protection and emergency lighting concerns were noted during recent tours of the auxiliary building.

For example, access to a fire hose was impeded by a block shield wall installed for radiation protection, and emergency lighting equipment was found with insufficient electrolyte in the wet cells.

Adequacy of the installed emergency lights is in question. The licensee stated that a fire protection survey will be made of the auxiliary building to assure that fire protection fire fighting equipment and emergency lighting is adequate.

(320/79-13-11)

(f) Recovery Ooerations Organizati>n The licensee's organization for recovery operations has undergone several structural and functional changes.

The licensee co=mitted that, pending issuance of the proposed Technical Specifications for Recovery Operations, he will identify the current organi=ation by position title, specific personnel assignments, and job description, and that subsequent changes to the organization will be promptly identified to on site NRC representatives.

(320/79-13-12)

c.

Concerns Relcred Lirectly to Licensee Management In addition to the exit meetings, substantive concerns were relayed directly to licensee management throughout the inspection period.

Significant concerns identified in this fashion on or ah'out June 8,1979 included the following:

(1) High Radiation Area posting in the Auxiliary Building (320/79-13-02)

(2) Detailed surveys defining High Radiat; ion Area (100=r) boundaries in the Auxiliary Building and marking of those boundaries.

(320/79-13-02)

(3) Worker instruction on activity restriction and radiological pr'ecautions in the Auxiliary Building.

(320/79-13-07)

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(4) Lack of specificity of maximum and general area dose rates documented on Radiation Work Permits.

(320/79-13-02)

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(5) Realth Physics personnel coverage of work areas in the Auxiliary Building.

(320/79-13-02)

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