IR 05000320/1979023
| ML19308C252 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/07/1979 |
| From: | Haverkamp D, Keimig R, Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19308C251 | List: |
| References | |
| 50-320-79-23, NUDOCS 8001220272 | |
| Download: ML19308C252 (27) | |
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O-u.S. NuCteAa aecutAT0av COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
50-320/79-23 Docket No.
50-320 License lio. DPR-73 Priority Category C
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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: fiiddletown, Pennsylvania Inspection conducted:
August 15 - September 18, 1979 Inspectors:
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/Muf/M
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D.R.Haverkamp,LeadfReactorOperations ddte signed Inspector AA % sbr lobrolrn
'O.
R~. Neelyf/ Lead Radiation Specialist dite si'ghed
>
date signed
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Approved by:
he#~
//- 7-79
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. R.' Kei '
ECnief c. Resident date' signed Office - Ti
Inspection Summary:
Inspection on August 15 - September 181979 (Report No. 50-320/79-23)
Areas Inspected:
Special inspection by NRC TMI Recovery Operations Inspection staff of:
licensee action on previous inspection findings; new and revised procedures; plant operations including records, performance of tests, and general plant tours; in-plant health physics including documentation, posting and labeling reviews, witnessing of activities, and area tours; and R0RC responsibilities. The inspection included continuous shift coverage by reactor operations and radiation specialist inspectors.
Results:
Significant findings were brought to the attention of the licensee management when identified.
Region I Form 12 (Rev. April 77)
8001220 b
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DETAILS 1.
Persons Contacted Principal licensee and contractor personnel contacted during this inspection are identified in the exit interview section of this report.
2.
IE Inspection Participants The following tabulation identifies the TMI-2 Resident Office professional i
personnel participating in this inspection.
a.
Resident Office Staff R. Conte, Reactor Operations Inspector, IE:RI, August 15 -
September 18, 1979 H. Crocker, Chief, IE Resident Office, IE:RI, August 15 -
August 28, 1979 D. Haverkamp, Leac Reactor Operations Inspector, IE:RI, August 22 -
September 16, 1979
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R. Keimig, Chief, IE Resident Office, IE:RI, August 28 -
l September 18, 1979 D. Neely, Lead Radiation Specialist, IE:RI, August 15 -
September 18, 1979 W. Raymond, Reactor Operations Inspector, IE:RI, August 15 -
September 18, 1979 J. White, Radiation Specialist, IE:RI, August 29-31, September 5, 6,13, and 14, 1979 b.
Shift Reactor Operations Inspectors
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J. Ashenden, IE:RII, August 15 - August 21, 1979 G. Constable, IE:RIV, August 21 - August 28, 1979 S. Elrod, IE:RII, August 21 - August 26, 1979 C. Feiraband, IE:RIII, August 28 - September 11, 1979 A. Johnson, IE:RII, September 11 - September 18, 1979 R. Masse, IE:RIII, August 15 - August 23, 1979 D. Price, IE:RII, August 15 - August 21, 1979 R. Smith, IE:RIV, August 15 - August 21, 1979 E. Webster, IE:RII, August 21 - September 5,1979 G. Zwetzig, IE:RV, September 5 - September 18, 1979 c.
Shift Radiation Specialists J. Baird, IE:RV, August 28 - September 11, 1979 N. Dubry, IE:RIII, September 6 - September 18, 1979 R. Fish, IE:RV, September 11 - September 18, 1979 H. Harrison, IE:RIV, October 21 - September 6, 1979 l
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J. Hiatt, IE:RIII, August 15 - August 21, 1979 C. Hosey, IE:RII, August 16 - August 28, 1979 W. Millsap, IE:RII, August 15 - August 16, 1979 L. Wilborn, IE:RIV, August 15 - August 20, 1979 3.
Licensee Action on Previous Inspection Findings (0 pen) Inspection Finding (320/79-13-09):
Review of Facility Procedures
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for consistency with current recovery operations.
NRC monitoring of licensee progress in this area continued with the review of Emergency
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Procedures (EP's).
Results are addressed in paragraph 4.
A similar (but not as extensive) review was conducted on Special Operating Procedures designated "Z".
Specific discrepancies (as of August 17, 1979) are noted below:
Z-2, Discharge of WDG-T-1A(B) to Reactor Building, Revision 2, April
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6, 1979, references Z-32 and 35 which are no longer in use; Z-39, Natural Circulation Operation, Revision 1, June 18, 1979, I
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references Z-58 which has not been issued; and, Z-63, Solid Plant Operations, Revision 4, June 22, 1979, references i
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EP-9 which has not been issued.
(0 pen) Significant Inspection Finding (320/79-17-04):
Concerns Regarding TMI Personnel Dosimetry.
The respiratory protection program has deficiencies in the areas of timely physicals, whole body counts and related records.
Personnel may enter controlled areas wearing respiratory protective equipment when records available to HP personnel indicate whole body counts and/or physicals may be out of date.
Also, records do not contain the most recent information. The Unit 2 HP control point has established supplemental records system.
NRC:
TMI Recovery Operations Inspection staff monitoring of this area continues (Details Paragraph 8.f.(2)).
(0 pen) Inspection Finding (320/79-22-01):
Administrative Controls for Recovery Special Operating Procedures.
On August 25, 1979 during the conduct of R-SOP-2-79-63, Test of Oxygen (0 ) in SPC-T4 (Changing Water Storage Tank), Revision 0, August 25, 1979,2a temporary change to the procedure was not properly implemented.
The procedure did not address venting the Storage Tank during refill operations.
The operator did obtain verbal permission from the shift supervisor to operate the appro-priate valve for venting the tank during the fill procedure.
However, a Temporary Change Notice (required by established Administrative Controls, AP 1001) was not completed until some time after implementation of this change (TCN No. 2-79-110, dated August 25,1979).
The establishment and implementation of Procedural Administrative Controls for Recovery Technical Specification continue. to be under review by the Licensee and monitored by NRC:
TMI Recovery Operations Inspection staff.
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i (0 pen) Inspection Finding (320/79-22-09):
Calibration and Operation
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Deficiencies of Air Sample and Proportional Counters.
NBS has returned i
licensee calibration contractor Cs-137 and Sr-90 calibration sources i
after standardization of same.
The licensee has administrative 1y set conservative counting efficiencies on above counting equipment.
Pending establishment, approval and implementation of calibration and operational procedures for the counters, this item will remain open.
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(0 pen) Inspection Finding (320/79-22-08):
Failure to utilize breathing l
air system properly.
The licensee established procedures for use of
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respiratory protective equipment.
Pending review of field implementation,
this item will remain open (Details Paragraph 8.g.).
(0 pen) Inspection Finding (320/79-13-04):
Failure to perform job specific airborne radioactivity determinations.
Procedures remain to be implemented (Details Paragraph 8.g.).
4.
Facility Procedure Review Operating Procedures (0P), Emergency Procedures (EP), Surveillance Procedures J
and Special Operating Procedures (SOP), including subsequent revisions, were reviewed by the Resident Office during this inspection. The SOP's
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are temporary procedures written for the TMI-2 Recovery Program which govern special evolutions and/or use of off-normal plant systems and these are designated "Z" or "R" procedures depending on date of generation.
Procedure review included both Health Physics and Operations aspects with
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consideration of the following:
(1) the procedure, when implemented, would not degrade the containment of radioactive material, jeopardize core cooling, or result in excessive personnel exposure; (2) the procedure conforms to the general criteria of TS 6.8, " Procedures", TS 6.11, " Radiation Protection Program", ANSI N18.7, 1976; (3) the technical content of the procedure is adequate to perform the intended evolution.
Procedures reviewed during this report period are listed below together with dates (in parenthesis) on which IE comments were completed.
Fire in the EPICOR II Ventilation System, Revision 0, August 13,
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1979 (August 16,1979)
i Fire in the EPICOR II Control Room, Revision 0, August 13, 1979
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(August 16,1979)
Fire in the Chemical Cleaning Building, Revision 0, August 13, 1979
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(August 16,1979)
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NSI/VIKEM DC-3, Support Procedure for Solidification of RADIAC Wash
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Waste Water Stored in U-2 Auxiliary Building, Revision 0, August 14, 1979 (August 15,1979)
Temporary Sampling System, Revision 0, August 15,1979 (August 15,
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1979)
Containment Surveillance Hole Cutting Procedure - Penetration 626,
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Revision 0, August 13, i979 (August 17,1979)
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Z-46 Sewage Disposal, Revision 3, August 16, 1979 (August 20,1979)
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2104-5.16 Operation of CCB Ventilation System, August 16, 1979
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(August 21,1979)
R-2-79-52, TCN 2-79-99 to Depressurizing and Draining of DH System,
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August 10, 1979 (August 20,1979)
1618A Shipment of Radioactive Material, Revision 0, August 15, 1979
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(August 17,1979)
2204-8 Coolant System Monitoring Panel, Revision 0, August 16, 1979
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(August 20,1979)
2202-4.1 Loss of~ Fluid System Integrity for EPICOR II, Revision 0,
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August 16, 1979 (August 20,1979)
2202-4.3 High Radiation /High Airborne Activity in the CCB, Revision
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0, August 16, 1979 (August 20,1979)
2104-4.8 Transfer of Water from Auxiliary Building Sump to WDL-T-2
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Without Pumping Through WDL-T-5, Revision 0, August 1,1979 (August 20,1979)
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16188 Receipt of Radioactive Materials, Revision 0, August 8, 1979
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(August 17,1979)
i TCN 2-79-104 TCN to Depressurization and Draining of DH System, j
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Revision 0 (August 21,1979)
TCN 2-79-103 to Operating Procedure for White Diesel, Revision 0,
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August 17, 1979 (August 21,1979)
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TCN 2-79-105 TCN to 80P Diesel - Gray, Revision 0, August 17, 1979
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(August 21,1979)
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Fire in the Chemical Cleaning Building, Revision 0, August 13, 1979
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(August 28,1979)
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- Discharge of WDG-T-1A(E) to Reactor Building, Revision 0, August 8,
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1979 (August 21, 1979)
- Design Criteria Document for TMI-2 Evaporator / Solidification Facility,
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August 16, 1979 (September 6, 1979)
- Preliminary Operating Procedure for Task WG#16 Fuel Pool Waste
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Storage System, Revision 2, July 26, 1979 (September 6, 1979)
3104-4.3 Transfer of Unit 1 WDL-T-11A/B to CAPGUN II CC-T-1, Revision
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0, August 2, 1979 (September 4, 1979)
2104-4.8 Transfer Auxiliary Building Sump to MWHT Bypassing Auxiliary
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Building Sump Tank (TCN 2-79-162), Revision 0, August 21, 1979 (August 21, 1979)
- TMI Unit 2 Permanent Sampling System Draft Criteria (Revised)
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August 17, 1979 (September 4, 1979)
Fire in EPICOR II Ventilation System, Revision 0, August 18, 1979
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(August 27,1979)
- Criteria Document and Scope Document for the Mini Decay Heat Removal
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System, August 17, 1979 (August 31,1979)
- TMI-2 Penetration R-626 Experiment, August 21, 1979 (August 29,
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1979)
2202-4.4 Fire in EPICOR II Control Room, August 13, 1979 (August 28,
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1979)
TMI-2 Containment Evaluation Report - Penetration R-626 Experiment,
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Revision 0, August 21, 1979 (August 31,1979)
2104-5.16 Operation of CCB Ventilation System, Revision 0, August
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16, 1979 (August 27,1979)
- TMI-2 Submerged Demineralizer System Design Criteria, August 21,
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1979 (September 6, 1979)
Operation of Supplemental Fans and Filters, Revision 0, August 1,
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1979 (August 29,1979)
Z-39, Natural Circulation Operation, Revision 2, August 13, 1979
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(August 20,1979)
2107-1.5 DG White Operations (PCR No. 2-79-132) (August 27,1979)
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2106-1.6 OP Procedure Gray Diesel (PCR No. 2-79-130) (August
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i 27,1979)
2301-301 PCR No. 2-79-131 to RCS Inventory, Revision 3, August
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20, 1979 (September 6, 1979)
2104-4.11 Change Out of Crud Filter (ALC-F-5) Cartridge,
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Revision 0, (August 27, 1979)
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2104-4.61 EPICOR I or EPICOR II Transporter Vehicle Accident
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During Prefilter/Demineralizer Transfer, Revision 0, August 8, 1979 (August 28,1979)
- Preliminary Design Criteria for Additional Processed Water
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Storage Tanks, Revision 0, August 23, 1979 (September 6, 1979)
2204-8 Coolant System Monitor Panel, Revision 0, August 16,
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1979 (August 28,1979)
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R-2-79-53 TCN (No. 2-79-109) to DHR System Fill, Vent and Hydro, Revision 2, August 24, 1979 (August 28,1979)
EP-34 Loss of Natural Circulation, Revision 1, August 30, 1979
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(August 31,1979)
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Z-63 Solid Plant Operations, Revision 5, August 30, 1979
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(September 6, 1979)
EP-9 Loss of Makeup, Revision 0, August 30, 1979 (September 7,
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1979)
2202-4.3 High Radiation /High Airborne Activity in the CCB
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(EPICOR II), Revision 0, August 16, 1979 (September 4, 1979)
- Portable Auxiliary Boiler - Design Criteria, August 27, 1979
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(September 6, 1979)
1631.2 Sampling of Reactor Building, Revision 4, September 4,
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1979 (September 5, 1979)
R-2-79-63 TCN 2-79-110, Test of Oxygen in SPC Tank SPC-T-4
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August 31, 1979 (September 5, 1979)
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2203-1.9 Standby RC Pressure Control System Isolation on
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Rising RCS Pressure, Revision 0, August 31, 1979 (September 5, 1979)
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EP-33 Core Cooling with No RCPs or Natural Circulation, l
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Revision 1, September 4, 1979 (September 6, 1979)
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AP 1050 TCN No.79-136 to Control of High Radiation Area,
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Revision 0, August 28, 1979 (September 7, 1979)
Proposed TCN to 2104-5.1, RB Normal and Emergency Cooling
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(September 6, 1979)
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Drilling Procedure R-626, Revision 0, August 29, 1979 (September
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10,1979)
2203-1.9 Standby RC Pressure Control System Isolation on
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Rising RCS Pressure, Revision 0, August 31, 1979 (September 12,1979)
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Z-63 Solid Plant Operations, Revision 5, August 30, 1979
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(September 10,1979)
Special Radiation Survey of Southeast Corner of Fuel Handling
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Building (281 ft. Elevation), Revision 0, September 11, 1979 (September 12,1979)
Special Survey of 305 ft. Elevation Fuel Handling Building,
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Revision 0, September 7, 1979 (September 12,1979)
Special Radiation Survey of Fuel Handling Building 281 ft.
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Elevation, Revision 0 (September 12,1979)
As Low as Reasonably Achievable Interim (ALARA) Program, i
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Revision 0, September 11, 1979 (September 12, 1979)
R-2-79-35 (TCN No. 2-79-112) to SPC System Operation, Revir, ion
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0, September 11, 1979 (September 11,1979)
R-626 Containment Surveillance Pressure Boundary Installation,
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Revision 0, September 6, 1979 (September 18,1979)
Reactor Building Remote Access - R-626 Drilling Procedure,
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Revision 0, September 12, 1979 (September 18,1979)
RCS and PZR Sampling for Total Gas (Manual), Revision 0,
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September 14, 1979 (September 14,1979)
MU Valve Room TLD Analysis, Revision 0, September 12, 1979
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(September 14,1979)
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Operating Procedure Standby Pressure Control System - Phase I,
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Revision 0, September 14, 1979 (September 18,1979)
EP-9 Loss of Make-up, Revision 0 (September 17,1979)
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3303-Q1 Fire Pump Diesel Fuel, Revision 4, March 22, 1979
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(August 28,1979)
3301-R1 Fire Service Diesel Engine Inspection, Revision 0,
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February 2, 1978 (September 5, 1979)
3301-Q2 Specific Gravity Check - Diesel Fire Pumps, Revision
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1, March 7, 1978 (August 28,1979)
4311-10 Control Room Ventilation - Charcoal Analysis, Revision
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0, August 8, 1979 (September 5, 1979)
4303-sal Seismic Instrumentation Functional Test, Revision 0,
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August 8, 1979 (September 4, 1979)
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4301-Q1 Station Storage Batteries, Revision 0 (September 5, 1979)
4302-R15.5 BWST Temperature and Level, Revision 0, August 8,
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1979 (September 18,1979)
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4303-R25 Control Room Emergency Ventilation Performance Analysis, Revision 0, August 8, 1979 (September 5, 1979)
3301-W2 Fire System Diesel Battery Check, Revision 3, March 6,
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1979 (August 28,1979)
- These are design criteria also submitted by the licensee and reviewed for technical adequacy.
Composite NRC comments on procedures were forwarded to the licensee by Office of Nuclear Reactor Regulation (NRR).
No instances of failure to resolve NRC comments were identified.
5.
Review of Emergency Procedures a.
Emergency Procedures (designated "EP" for post accident procedures) were reviewed to verify the following:
Effective procedures are applicable for present plant
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status;
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Format and content are in accordance with ANSI N18.7-1976,
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paragraph 5.3.8; Selected EP's are compatible with existing plant pro-
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cedures and temporary procedures associated with Recovery Operations;
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b.
The following documents were reviewed:
ANSI N18.7-1976, paragraph 5.3.8; i
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AP 1001, TMI Document Control, Revision 20, July 30,
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1979;
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EP-5, Loss of Letdown, Revision 1, May 16,1979;
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EP-6, Reactor Coolant Pump Seal Failure, Revision 1, May
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11, 1979; EP-7, Loss of Off-Site Power, Revision 2, May 8,1979;
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EP 9, Loss of MU Pump and HPI;
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EP 12, Loss of RCS Pressure Indication, Revision 1, June
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27, 1979;
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EP-13, Loss of RCS Temperature Indication, Revision 0,
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April 25, 1979; EP-15, Loss of OTSG Level Indication, Revision 0, May 9,
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1979;
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EP-16, Loss of Source Range Instrumentation, Revision 0,
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May 8, 1979; EP-17, RC-V 137 Stuck Open, Revision 0, May 14,1979; i
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EP-18, RC-V2 Stuck Open, Revision 0, May 14, 1979;
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EP-19, RC-V2 Stuck Shut, Revision 1, May 5, 1979;
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EP-20, RC-V137 Stuck Shut, Revision 1, May 5, 1979;
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EP-21, Loss of Pressurizer Level Indication, Revision 6,
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May 9, 1979;
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EP-22, Loss of Pressurizer Temperature Indication,
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Revision 1, May 6, 1979; EP-24, Responses for H Recombiner Alarm Indication,
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April 3, 1979;
EP-26, Actions to be Taken if R.B. Pressure Less Than -2
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PSI, Revision 0, April 8, 1979; EP-27, Site Evacuation;
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EP-28, TMI Unit 2 Control Room Evacuation, Revision 0,
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May 11, 1979; EP-29, Loss of Condenser Vacuum, Revision 1, May 11,
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1979; EP-33, Core Cooling With No RCP's or Natural Circulation,
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Revision 0, May 26, 1979; and, EP-35, Loss of Instrument Air and Service Air, Revision
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0, May 19, 1979.
c.
Specific results of this review (as of September 13, 1979) are listed below.
In general, these discrepancies indicate that a good number of EP's need to be updated for present operational status.
The review and updating of Temporary (termed by the licensee "Special") Operating Procedures is being followed under Inspection Finding 320/79-13-09.
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Pen and ink changes were noted with an initial but it was
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not noted whether they are a part of last Revision (Revision 1) or not.
Figure A is a revised Brittle Fracture Curve for the
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Reactor Vessel.
A note on the curve indicates instrument error is not included, but the procedure gives no guidance to the operator on what error is to be applied and how it is to be applied (definition of the operating window stated in paragraph 2.2.2.d).
The procedure directs actions for maintaining a Steam
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Bubble (Pressurizer Level) in the Pressurizer but doesn't recognize present solid plant operations.
Further, the l
procedure will have to be revised to address the Standby Pressure Control System which is soon to be operationa _
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EP-6 Paragraph 2.2.1 and 2.2.2 refer to EP-32 which has been
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cancelled.
The enclosed curve is a plot of Makeup Tank Pressure
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versus Level.
The procedure is vague in terms of which side of the enclosed curve should be the operating section.
EP-7 Balance of Plant Diesels or 13 KV Line for Circulating
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Water Pumps are not addressed.
These are recovery modifications that became operational after the issuance of the latest revision.
It appears this was never issued.
The index does not
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reflect a revision and a copy is not on file.
An evalu-ation should be made to determine current applicability.
EP-9 It appears this was never issued.
The index does not
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reflect a revision and a copy is not on file.
An evalu-ation should be made to determine current applicability.
EP-12 Referenced procedures (2104-1.14 and Z-58) do not exist.
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EP-15 Paragraph 2.2.6 contains outdated Loss of Natural Cir-
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culation Criteria.
EP-16 The procedure will have to be revised to reflect new
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minimum limits for RCS boron concentration (3500 ppm).
EP-17 Paragraph 2.2.2.6 contains outdated Loss of Natural
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Circulation Criteria which is not consistent with that stated in EP-15.
Follow up actions are oriented to maintain a bubble in
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the Pressurizer.
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I EP-18 Paragraph 2.2.2.6 contains outdated Loss of Natural
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Circulation criteria which is not consistent with that stated in EP-15.
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Figure 1 has same comment for Figure A of EP-5.
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EP-26 Actions address use of Reactor Building Emergency cooling
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System (safety mode) only with no recognition of the
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Reactor Building Evaporator Cooling System (normal mode)
which is presently being used.
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EP-27 l
It appears this was never issued.
The index does not
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reflect a revision and a copy is not on file.
An evalu-ation should be made to determine current applicability.
r EP-28 l
In paragraph 3.2.2.A and in light of solid plant oper-
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ations, it appears questionable to place pressurizer heaters in automatic on a Control Room evacuation.
Use
of SPC system (local operations) should also be addressed.
EP-29 Paragraph 3.2.3 addresses outdated Loss of Natural
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Circulation criteria.
6.
Review of Plant Operations a.
Test Performance / Procedure Implementation The following tests / procedure implementations were witnessed:
R-2-79-56, Reactor Building Remote Access, Revision 0,
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July 31, 1979, on August 14 through August 25, 1979.
R-2-79-44, SPC-P-3 in Recirculation Mode, Revision 0,
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July 20, 1979 on August 14 through August 17, 1979.
2107-1.6, Balance of Plant Diesel (Gray) and Auxiliaries
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Operating Procedure, Revision 0, August 15, 1979 on August 17, 1979.
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2303-M16C, Emergency Diesel Generator and Cooling Water
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Valve Operability Test (A Diesel), Revision 9,. March 26, 1979 on August 20, 1979.
R-2-79-63, Test Oxygen (0 ) in SPC Changing Water Storage
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Tank (T-4), Revision 0, August 14, 1979, on August 25, 1979 (Steps 4.9, 4.10 and 4.11).
Z-63, Solid Operations, Revision 4, May 27, 1979, on
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August 28, 1979 (Step 6.1.6.1, RCS Leak Rate Determi-nation).
R-2-79-53, DHR System Fill Vent and Hydro, Revision 2,
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August 5, 1979 on August 14 through August 28, 1979.
b.
Plant Tours During the period August 15, 1979 through September 18, 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 outside and inside of the
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protected area (10)
Fuel Handling Building accessible areas on elevation 331
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(1)
Chemical Cleaning Building including the Auxiliary Build-
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ing Emergency Liquid Cleanup System (EPICOR II) (10)
Turbine Building, accessible areas on elevation 280'
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(20), elevation 305' (20), and elevation 331' (22)
j Diesel Generator Building accessible areas on elevation
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305' and elevation 280' (4)
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Balance-of-Plant Diesel Generators Trailers & Fuel
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Storage Area (13)
Control Building accessible areas on elevation 280* (13)
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elevation 305' (13) and elevation 331' (13), including the Control Room (17)
Auxiliary Building control point on elevation 280' (2)
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Service Building accessible areas on elevation 280' (11)
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elevation 305' (11) and elevation 331' (11)
c.
Status Meetings NRC personnel attended the following licensee meetings to observe and ascertain additional plant status information.
The meetings attended included discussions of:
plant status; specific system operation; pending or planned construction activities; raciocctive waste management and plant radio-logical status:
Morning Plant Status Meeting (0730), Monday through
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Friday, Each Week; Standby Pressure Control Meeting on August 24, 30, l
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September 6, 13, 18, 1979;
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Sample Sink Tie-in/ Mini-Decay Heat Removal Meeting on
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August 23, 28, September 5, 7, 12, 1979; and, Radioactive Waste Management Meeting (0900), Monday
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through Friday, Each Week.
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No discrepancies or unacceptable conditions were identified.
7.
Radwaste Operations Review Committee (RORC)
l The licensee received a change (NRC letter, Vollmer to Herbein, dated July 16,1979) to Unit 2 Technical Specifications establish-
ing the RORC and immediately implemented RORC review of procedures.
The inspector reviewed the licensee memorandum that established the committee and reviewed RORC minutes for all meetings conducted
during July and August 1979.
Although Technical Specification requirements are that the RORC meet at least once a month, the RORC has met four or five times a week because of the large number of procedures requiring review.
All RORC activity to date has been the review of procedures.
Review of RORC minutes for meetings to date verified that quorum requirements were met.
The minutes identified all procedures reviewed and recommended for approval.
Discussions of the content of the minutes with the committee chairman and secretary included advisability of documenting reviews of procedures not recommended for approval to provide a more accurate record of committee actions.
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The licensee intends to formalize provisions for assuring that all RORC responsibilities are fulfilled to facilitate implementation of the revi:ed Technical Specifications when they are issued by NRC. This will be followed by NRC:
TMI Recovery Operations Inspection staff (320/79-23-02).
8.
In-Plant Health Physics a.
Solid Radioactive Waste Shipping, handling, storage and analysis of solid radioactive waste was reviewed for compliance with the following:
10 CFR 20, " Standards for Protection Against Radiation";
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10 CFR 71, " Packaging of Radioactive Material for Trans-port and Transportation of Radioactive Material Under Certain Conditions";
Station Health Physics Procedure 1620, Revision 4,
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" Radiological Controls for Processing Radioactive Solid Waste" dated February 9, 1979; and Special Operating Procedure, S0P No. R-2-79-6, Revision
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1, "On-site Solid Waste Storage for TMI-2" dated May 8, 1979.
The review included documentation, truck placarding and the performance of independent radiation intensity measurements were necessary.
(1)
Shipments The following shipments of radioactive material were i
reviewed during the reporting period:
Shipment #
Date Item Total mci 79-44 August 16. 1979 Laundry 8.4 i
compacted 79-95 August 20, 1979 trash 1430.
79-96 August 22, 1979 Liquid sample 9.
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79-97 August 23, 1979 Laundry 19.2 79-98 August 24, 1979 Compacted trash 331 __
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79-99 August 27, 1979 Liquid samples 51.037 79-100 August 27, 1979 Charcoal filter
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79-101 August 27, 1979 Compacted trash 2220.79-102 August 28, 1979 Liquid sample 26.79-103 August 28, 1979 Compacted trash 10370.79-104 September 10, 1979 Empty tanker
.039 79-105 September 6, 1979 Empty tanker 29.75 79-106 September 5, 1979 Empty tanker
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79-107 August 30, 1979 Misc. samples 9.49 79-108 August 30, 1979 Non-compacted trash 148.5 i
j 79-109 August 31, 1979 Liquid sample
.00014 79-110 August 30, 1979 Laundry 12.11 79-111 August 31, 1979 Non-compacted trash 183.6 79-112 September 4, 1979 Non-compacted trash 574.92 79-114 September 6, 1979 Laundry 499.8
'79-115 September 6, 1979 Misc. liquid samples 19.0 l
l 79-117 September 17, 1979 Non-compacted trash 282.96 79-118 September 10, 1979 Misc. liquid samples 9.57
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During inspector review of Shipment No. 79-96 on August 22, 1979, it was noted that the package, containing a radioactive sample for offsite analysis, was improperly labeled as Radioactive Yellow - II.
Based on package external surface exposure dose rates at three feet, the package was required to be labeled Radioactive Yellow - III as delineated in 49 CFR 172.403(d)(1).
This discrepancy with Department of Transportation regulations was brought to the attention of licensee representatives who corrected same prior to delivery to the carrier for transport.
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The licensee is currently revising Station Health Physics Procedure 1618, Revision 6, " Shipment of Radioactive Material, DOT Regulations," which addresses package labeling.
The labeling of pack-ages for shipment will be included in review of procedure 1618 (320/79-23-03).
(2) Storage of Solid Radioactive Waste Tours of solid radioactive waste storage areas were made to review storage, access control, posting and barricading of storage areas.
No unacceptable conditions or significant discrepancies were identified.
b.
Radioactive and Contaminated Material Control Radioactive and contaminated material control was reviewed for compliance with 10 CFR 20.203, " Caution signs, labels, signals and controls," and Health Physics Procedure 1682, Revision 2,
" Control of Contaminated Tools, Equipment and Material," dated April 28, 1977.
No unacceptable conditions or significant discrepancies were identified.
c.
Posting and Area Control Tours of areas (both controlled and uncontrolled) were made to verify licensee compliance with 10 CFR 20.203, " Caution signs, labels, signals and controls," Technical Specification Section 6.12, "High Radiation Area" and Station Health Physics procedure 1610, Revision 7, " Establishing and Posting Areas," dated September 30, 1977.
The area tours and the performance of independent radiation intensity measurements identified one Significant Inspection Finding.
The finding, Failure to Post a Radiation Area, as required by 10 CFR 20.203(b), is attached to this report as Significant Inspection Finding No. 320/79-23-01.
d.
Radioactive Effluent Releases (1)
Liquid Effluent Releases Radioactive liquid effluent releases from the plant were reviewed against the following:
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10 CFR 20.106, " Radioactivity in Effluents to l
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Unrestricted Area" Station Health Physics Procedure 1621.2, Revision 4,
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" Release Radioactive Liquid Waste from Unit 2,"
dated January 5, 1979
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Special Operating Procedure, 50P No. Z-33, Revision
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2, " Water Sump Discharges to IWTS and IWFS," dated May 18, 1979 Special Operating Procedure, 50P No. Z-51, Revision
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3, " Liquid Releases from TMI," dated May 2, 1979 During review of liquid effluent monitor RML-7 composite samples, the following wa i noted:
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(a) An inspector revicw, on September 9, 1979 of samples collected, prepared and counted since the previous day, identified one sample, No. 18657, which indicated 29 times the allowable unrestricted radioactive concentration limits as delineated in 10 CFR 20, Appendix 8.
(b) An inspector review, on September 10, 1979 identified a second RML-7 sample indicating concentration greater than the limits specified in (a) above.
The sample, No. 18758, dated 0400 September 9, 1979, indicated approximately 8 times the allowable limits.
Licensee representatives were notified immediately upon identification of the above.
Preliminary licensee review indicated the activity was due to contamination of prepared samples.
Licensee recounts of re prepared composite samples indicated no detectable activity greater than the lower limit of detection of the counters utilized.
The above item, including licensee response to high effluent sample results will continue to be reviewed (320/79-23-04).
(2) Gaseous and Particulate Effluent Releases The licensee maintains a Supplemental Vent Radiation Monitoring System to monitor gaseous and particulate releases from the Unit 2 augmented exhaust ventilation system.
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A review of system operation on August 27, 1979 indicated an inconsistency between filter exposure dose rates.
One train indicated a dose rate of approximately 10 times the remaining three trains.
The dose rates, obtained via fixed area radiation monitors located on each train, provide an indication of filter train radioactivity build-up.
Upon identification, the inconsistency was brought to the attention of licensee representatives who indicated a review of the matter would be undertaken (320/79-23-05).
e.
Exposure Control The following instances of personnel contamination and possible personnel exposure in excess of regulatory limits were reviewed.
(1) Personnel Contamination
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(a) On August 13, 1979, one individual sustained con-tamination of the fingers of both hands as a result of handling a torn bag of used respiratory pro-tection equipment.
Initial surveys of finger contamination indicated a maximum of approximately 100,000 dpm.
The individual underwent decontamination and whole body counting.
Preliminary review of the individuals whole body counting data indicated less than one percent of the established body burdens for the isotopes involved.
This value is conservative since any residual low level skin contamination was assumed to have been internally deposited (320/79-23-06).
(b) On August 27, 1979 a second individual sustained radioactive contamination.
The contamination was of the arm and right thigh with measurements indicating a maximum contamination of 35,000 dpm.
During decontamination, it was noted that the individual
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was found to have a blister on the left arm near a
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contaminated skin area.
As a result, the licensee restricted the individual from further work in contaminated areas pending licensee review of instance.
Licensee whole body counts of the individual will be reviewed (320/79-23-07).
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(c) On August 30, 1979, three licensee contractor employees sustained skin contamination while kneeling near pipe supports on the 281'el. of the Fuel Handling Building.
One individual was noted to have a maximum contamination level of 200,000 dpm of the right knee.
The individuals underwent decontamination, whole body counting and samples were collected for bioassay analyses.
The whole body counts of one individual indicated a possible intake of less than one percent of the maximum permissible body burden for Cs-137.
As above, any residual skin contam-ination was conservatively assumed to be internally deposited (320/79-23-08).
The above instances of personnel contamination will remain open pending review of licensee dose evalu-ations and licensee actions taken to prevent similar instances.
(2) Personnel Exposure On August 28, 1979, six individuals, repairing leaking valves located in the Fuel Handling Building, may have sustained exposure to the extremities and skin of the whole body in excess of regulatory limits.
The individuals'
preliminary thermoluminescent dosimeter (TLD) results, evaluated on site August 29, 1979, indicated beta radiation exposure to the extremities of between 40 and 150 rads and exposure to the skin of the whole body approaching 50 rads.
!0 CFR 20.101, " Radiation dose standards for individuals in restricted areas" limits quarterij occupe'
tional doses to the extremities and skin of whale body to 18.75 and 7.5 rems, respectively.
The licensee has, as a resA t of the above inrtance, issued a letter dated September 1,1979, detailing specific actions to be taken when beta radiat'on greater than 100 millirad per hour is suspect.
Additionally, the letter, directed to all Unit 2 Radiation Protaction personnel, specifically restricts access to t1ose areas previously identified as high beta radiation areas without express plant management permission.
The licensee has informed the workers of preliminary dosimetry results, as required by 10 CFR 20.509,
" Notifications and reports to individuals" and is con-ducting an investigation of the incident.
Ponding review of licensee investigation, this item will roain open (320/79-23-09).
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Personnel Monitorina
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l As a result of significant deficiencies identified in the l
licensee's thermoluminescent dosimetry (TLD) program, which
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are described in previous inspection reports (320/79-13 and i
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320/79-17), an extensive review of the program was conducted.
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The review encompassed personnel qualifications, TLD response i
capabilities (including response to known source radiations),
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administrative control, record review and retention and
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licensee action on previous inspection findings.
(1) TLD Fxposure Test
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Twenty TLD badges, provided by the licensee, were used to
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perform a blind test of the TLD dosimetry system's
response to gamma and beta radiation.
One badge was
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maintained at the NRC Resident Inspector's office as an
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onsite control.
The remaining nineteen badges were sent
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INL exposed seventeen of the l
badges to preplanned doses of radiation from cesium-137 l
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and/or a uranium slab.
Two badges were maintained as in-
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transit controls.
The badges were read out by the
licensee and the raw data were provided to the inspector.
Table I gives the doses calculated by the inspector from l
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the raw data using the licensee's procedures and the
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actual exposure given by INL.
The results of the test
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were considered acceptable.
The fact that badges 16 and
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17 failed to detect a small beta dose in the presence of
a large gamma dose is reasonable for this type of dosimeter
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and the beta / gamma ratio used.
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TABLE I TLD 00SIMETERS EXPOSED BY INDEPENDENT LABORATORY Gamma Beta Given2 Reported Given2 Reported Badge
[ mrem)
(mrem)
(mrem)
(mrem)
270 250
0
270 255
0
270 255
0
2700 2400
0
2700 2280
0
2700 2410
0
2903 275 2700 2310
2903 315 2700 2370
2903 275 2700 2510
303
270 220
303
270 260
303
270 255
5604 535 2700 2210
5604 490 2700 2600
5604 500 2700 2140
2730s 2530 270
17 27305 2500 270
1 Cesium exposure by INL 2 Uranium slab exposure by INL 3This is an estimation of the "hard" component from the uranium slab taking into account the badge configuration and filter thickness.
4This reflects 270 mrem Cs exposure plus $290 mrem "hard" component from the uranium slab.
5This reflects 2700 mrem Cs187 exposure plus $30 mrem "hard" component from the uranium sla.
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(2) Licensee Action on Previous TLD Inspection: Findings Items identified in Significant Inspection Finding 50-320/79-17-04 were reviewed and licensee corrective action for the following were verified (Item numbers are the same as those indicated in Report 50-320/79-17-04):
Item No.
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The present Dosimetry Supervisor meets the criteria in ANSI N18.1 (1971) as required by Technical Specification 6.3
Individuals operating the TLD reader have received training in appropriate procedures.
However, the pro-
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cedures are in the process of being modified.
The new
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procedures and the training of the operators will be reviewed upon implementation.
Administrative controls are now in place and account for data outputs and computer changes.
Review will continue.
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A computer program has been written to compare TLD and pocket dosimeter data.
A review to determine program adequacy will be conducted by NRC resident staff.
The termination of individuals as " active" with respect j
to dosimetry records, upon site termination, has improved.
Periodic review for consistency will continue.
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A licensee contractor report, concerning TLD system accuracy and consistency was received.
The report, dated July 12, 1979, discusses among other items, TLD system difficulties prior to March 28, 1979.
The report will be reviewed by NRC resident staff (320/79-23-10).
g.
Respiratory Protection The licensee utilizes respiratory protective equipment to limit the inhalation of airborne radioactive material.
As specified in 10 CFR 20.103(c), the licensee may make allowance for the use of such equipment provided that the respiratory protective equipment is used as stipulated in Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection".
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As a result of significant deficiencies identified in the licensee's respiratory protection program, particularly with respect to implementation of the requirements of Regulatory Guide 8.15, meetings were held with the licensee on August 17 and August 28, 1979, to discuss the deficiencies.
The dis-
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cussions included:
(1) upgrading of respiratory protection
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procedures (2) review of supplied air systems, and (3) improving
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sampling of airborne radioactive material.
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The following established procedures were extensively reviewed.
The review primarily focused on Regulatory Guide 8.15 require-ments, however, T.S. 6.8, 6.11 and ANSI N18.7-1972 were also used as inspection standards:
HPP-1616, Respiratory Protection Program
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HPP-1616.1, Selection and Use of Respiratory Protection
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Devices HPP-1616.2, Respiratory Protection Program Effectiveness
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HPP-1616.3, Operation of Facemask Cleaning Facility
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HPP-1717, Operation of Respiratory Test Booth
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Additionally, the following procedures concerning airborne radioactivity, sampling, activity determination and MPC hour calculations were reviewed:
HPP-1616.4, Implementation of Air Sampling, Counting
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Handling and Actions HPP-1616.5, Calculation of MPC Hours and Stay Time
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HPP-1605, Air Sampling for Radioactive Particulates
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HPP-1608, Portable Air Sampling for Tritium
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Pending licensee approval and field observation of procedure implementation, this item will remain open (320/79-23-11).
h.
Plant Tours Tours were made of both controlled and uncontrolled areas to examine:
access control; personnel frisking; use of survey meters; adherence to Radiation Work Permit requirements and proper use of respiratory protection equipment.
Additionally, the following operations were reviewed:
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Collection, packaging and shipment of reactor coolant
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samples on August 15, 1979.
Decontamination of 347' Annulus area of the Fuel Handling
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Building on August 18, 1979.
Dose Mapping of Personnel Airlock door on August 21,
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1979.
(Procedure R2-79-61 utilized by licensee for guidance.)
No unacceptable conditions or significant discrepancies were identified.
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9.
Exit Interview A meeting was held on September 21, 1979, with licensee management to discuss inspection findings and concerns as noted below:
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Licensee Representatives D. Limroth, Superintendent, Administrative / Technical Support J. Logan, Unit 2 Superintendent NRC Representatives R. Conte, Reactor Inspector R. Keimig, Chief TMI Resident Office D. Neely, Lead Radiation Specialist The following items were discussed.
Significant Inspection Finding No. 320/79-23-01.
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RORC Review Responsibilities.
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Licensee Action of Previous Inspection Findings (paragraph 3).
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ENCLOSURE 2 SIGNIFICANT INSPECTION FINDINGS Metropolitan Edison Company Docket No. 50-320 Unposted Radiation Area: (Significant Inspection Finding No. 79-23-01):
During the 1600-2400 shift on August 16, 1979,several wooden boxes in front of the " Doghouse" were surveyed with a Digi / Master survey meter, serial No. 417.
The boxes were inside a roped area.
The survey showed a level of 6 mR/hr in the southeast corner where the rope was stretched around one of the boxes.
An NSS (contractor) HP technician, using an E 520 survey meter confirmed the above result and found an additional "hotspot" that measured 35 mR/hr at the rope boundary.
The rope barrier was posted with signs reading
" Caution Radiation Area" and " Radioactive Material".
Contrary to 10 CFR 20.203.(b),
an area outside the rope barrier where radiation levels greater than 5 mR/hr existed was not posted as required. (Report Details, Paragraph 8.c)
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