IR 05000320/1981001

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IE Insp Rept 50-320/81-01 on 810201-0328.Noncompliance Noted:Failure to Properly Make Temporary Change to Operating Procedure
ML20005B373
Person / Time
Site: Crane 
Issue date: 04/30/1981
From: Ronald Bellamy, Conte R, Fasano A, Kalman G, Martin T, Oniell B, Sassani A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20005B370 List:
References
50-320-81-01, 50-320-81-1, NUDOCS 8107080038
Download: ML20005B373 (9)


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U.S. NUCLEAR REGULATORY CGMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Rtgion I Report No. 50-320/31-01 Docket No.

50-320 Category c

License No. DPR-73 Priority

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Licensee:

Metropolitan Edison Company P. O. Box 480 M_iddletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Midoietown, Pennsylvania Inspection conducted: February 1 - March 28, 1981 Inspectors:

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R. ConteklSenior Resi ent Inspector, TMI-2 date si'gned dwl ' Y Vf27///

B.O'Npll,RadiapionSpecialist date signed fh w h S// / Vl A. Safsani, pactor Ir.3pector da~te signed Accompanied by:

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G. Calmanv Engirieer, NRC'TMI P70tpam Office date signed V.Ls M k L~

vinin P[.,NRCBellamy, Chief, TRhnical Support Section, ddte digned U

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frector, Division of

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Engineering and Technical Inspection a

Approved by:

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A. Fasano, CXief, Ahree Mile Island Resident date signed Se,: tion i

8107080038 810506 -

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-2-Inspection Summary:

Inspection on February s - March 28,1981 (Inspection Report No. 50-320/81-01)

Areas Inspected:

Routine, unannounced inspection by resident and regional based inspectors of plant operations; reactor building entries; submergad demineralizer system - instrument and electrical construction activities; procedure tamporary change controls; and, health physics / environmental routine activities. The inspection involved 98 inspector-hours by 2 resident inspectors and 1 regional based inspector.

Resul ts: Of the five areas inspected, one apparent item of noncanpliarce was identified in one area (Violation - failure to properly make a temporary change to an operating procedure, paragraph 6).

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DETAILS 1.

Persons Contacted General Public Utilities (GPU) Nuclear Group

  • J. Barton, Director Site Operations, TMI-2 J. Brummer, Instrument and Control (I&C) Engineer
  • S. Chaplin, Licensing Engineer J. Chwastyk, Plant Operations Manager D. Collins, Radiological Controls (RADCON) Foreman, TMI-2 W. Conway, Senior Reactor Operator, TMI-2
  • J. DeVine, Manager, Recovery Engineering B. Elam, Manager Plant Engineering
  • R. Fenti, Supertisor Quality Assurance (QA) Audit
  • G. Hovey, Director TMI-2
  • L. King, Manager Plant Operations
  • G. Kunder, Supervisor Technical Specification Compliance
  • S. Lehman, Licensing Engineer C. Mell, Senior Reactor Operator, TMI-2 D. Merchant, RADCON Foreman, TMI-2
  • T. Osternaudt, Recovery Engineer H. Phillips, Recovery Engineer
  • J. Renshaw, Manager Radiological Controls Field Operation
  • P. Ruhter, Manager Radiological Technical Support
  • R. Skillman, Recovery Engineer
  • J. Wright, QA Manufacturing Assurance Manager Burns and Roe

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W. Richards, Recovery Engineer Bechtel Power Generation M. Corbie, Recovery Engineer (telephone conversation only)

NRC TMI Projram Office

  • L. Barrett, Acting Deputy Program Director
  • L. Gage, Engineer
  • J. Wiebe, Engineer Other members of operations, engineering, quality assurance, radiological controls and administrative staffs were also inter-viewed.
  • denotes those present at exit interviews.

2.

Plant Operations a.

The inspector, on a periodic basis, obtained information on plant conditions, reviewed selected plant pa.ra.eters for abnormal trends, ascertained plant status from maintenance /

modification viewpoint, and assessed logkeeping practices in accordance with administrative controls.

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-4-The inspector made random visits to the control room during regular and back shift hours, discussed operations with control room personnel, reviewed selected control room logs and records and observed selected licensee plan-of-the-day meetings. A plant tour was conducted to assess housekeeping and fire protection measures.

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Selected key evolutions were reviewed by the NRC onsite staff as denoted in paragraph 3.

b.

At approximately 8:10 a.m., on February 5,1981, during a purge of the Reactor Building atmosphere, the inspector monitored licensee actions related to an electrical fire in bus 2-47, located on the 328' elevation of the Auxiliary Building. The bus was electrically isolated upon discovering smoke eminating from the associated switchboard.

This was the bus that supplied power to the Reactor Building heating-ventilation-air conditioning substation (HVAC) which supplied power to the Reactor Building system exhaust fans used in' the building purge evolution.

The purge, which was in progress, was secured and the system put in a temporary shutdown condition.

The planned Reactor Building entry was put on hold pending further investigation into the cause of the smoking in the electrical bus. Personnel did not enter the Reactor Building.

The industrial cooling system for the Reactor Building was put on service to maintain vacuum. conditions in the building in accordance with Technical Specifications.

The licensee's investigation revealed the existenc a

burned-out controller for one of eight heaters in.. Reactor Building ventilation supply system.

The controller was isolated and power restored to bus 2-47.

The Reactor Building purge was reinitiated at 11:01 a.m.

The licensee proceeded to enter the Reactor Building that day.

The inspector had no further comments in this area.

3.

Reactor Building Entries The onsite staff monitored Reactor Building entries conducted during the inspection period to verify the following on a sampling ba sis.

The entry was properly planned and coordinated for effective

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task implementation including an adequate as low as reasonably achievable (ALARA) review.

Proper radiological precautions were planned and implemented

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including the use of a radiation work permit (RWP).

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Specific precedures were developed for unioue tasks and

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properly impiemerte.i.

The following entries were conducted by the licensee:

Entry No. 6 on February 3 and 5,1981 and Entry No. 7 c arch 17, 18 and 20, 1981.

During Entry No. 6 the licensee accomplisheo.ae following:

Installation of a closed circuit television system;

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Conduct of decuntamination experiments utilizing various

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solution and stripable coatings;

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Troubleshooting the inoperable source range monitor; and, l

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Radiological surveys.

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During Entry No. 7 the licensee accomplished the following:

Collection of various volumetric samples of Reactor Building

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sump water; Repair of a lighting circuit;

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Pumping of Reactor Building sump water through the zeolite

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test column for data in support of the Submerged Demineralizer System (SDS) operation; and, Radiological surveys.

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Onsite staff review in this area consisted of: Reactor Building entry status meeting monitoring; review of selected documents indicating plans / tasks to be accomplished; review of applicable procedures and RWP's.

The onsite staff had no further comr.ents in this area.

4.

Submerged Demineralizer System (SDS) - Instrument and Electrical Construction Activities a.

The SDS is the system that the licensee plans to use to process the Reactor Building sump / basement water that resulted from the March 28, 1979 accident.

The inspector reviewed documentation relative to construction aspects of instrumentation and electrical portions of the SDS to ascertain whether applicable requirements were met.

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Documentation reviewed for this determination included:

Technical Data Report No. 201, Revision 0;

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Technical Evaluation Report, SDS, April 1980;

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-6-Technical Evaluation Report, SDS, Appendix I, May 23, 1980;

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System Design Description of the SDS Feed and Monitor

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Tank, Bechtel Drawing No. 2-M74-SDS01; SDS System Description, October 30, 1980;

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Supply Manifold Submerged Ion Exchanger, Pipe and Instrument

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Diagram (P&ID), 527 D-A-5001, Revision 5; Containinated Feed Water System, P&ID, 5270-A-5002, Revision 4;

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Off Gas and Liquid Separation System, P&ID, 527D-A-5004,

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Revision 6; Ion Exchange Flow Sheet, 5270-A-5005, Revision 2;

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Intermediate Sampling System, P&ID, 527D-A-5006, Revision 4;

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General Layout Plan, Ion Excnange Equipment, 527D-A-5007,

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Revision 1;

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Beta Monitoring Manifold, P&ID, 527D-A-5009, Revision 3;

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RCS Clean Up Manifold, P&ID, 5270-A-5013, Revision 2;

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Filter Manifold Piping Plan and Elevation, 5270-L-5001,

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Revision 1; Feed Manifold Piping Plan and Elevation, 527D-L-5006,

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Revision 2; SDS Feed and Monitor Tank, P&ID, 2-M74-5001, Revision 2;

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Processed Water Storage and Recycle System, P&ID, 2-M74-PW01,

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Revision 1; and,

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SDS Instrumentation, Plan View, SK171-2, Revision 0.

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During this review, the inspector observed that system design did not include instrumentation in the following areas:

System ' flow and tank level recording;

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Fuel pool level analog indication in the control room;

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and, System high flow alarms.

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-7-The rationale for the system design and the omission of the above instrumentation was discussed with the licensee repre-sentatives.

The licensee representative indicated that this design was intentional to induce increased operator attention to system operation.

Further it was stated by the licensee representative that the instrumentation design was more than adequate to support the purpose of the SDS.

c.

During walkdowns of the system, the inspector observed system installations and made the following observations:

The waste tank level systen, which util..es the bubbler

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principle, did not have t!ie flexible, non-metallic instrument tubing secured properly to the U-tube man '

ometer.

(The licensee representative indicated that this wouldbecorrected.)

The containment box leak detection flow manometers

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utilizes polyethelyne instrument tubing rather than a rigid instrument tubing. Although the polyethelyne tubing is not in contact with the highly radioactive fluid, it is submerged in the fuel pool water and is more prone to degradation and breakage than rigid instrument tubing.

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System design requires that operators monitor several

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locations, i.e., there is no central control panel for operating the system locally or remotely.

The inspector indicated that in light of the above observations increased attention to detail is warranted in the preparation of system procedure and operator training from a human factors point of view. The licensee representative acknowledged the above and indicated that such emphasis was being placed on operator training.

The system procedures and operator training program will be reviewed by the onsite NRC staff. This area will continue to be reviewed by the NRC (320/80-01-01).

5.

TMI-2 Radiation Protection Program During this inspection period the resident inspectors reviewed the completion status of licensee commitments made as a result of the NRC Special Panel that reviewed the TMI-2 Radiation Protection Program in October - November 1979. The Office of Inspection and Enforcement Inspection Report No. 50-320/80-16 was the first NRC followup to this Special Panel review. The results of this latest review were documented in Inspection Report No. 50-320/81-03.

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Procedure Temporary Change Controls On March 6,1981, a TMI-2 Temporary Change Notice (TCN) No. 2-81-48 to Station Operating Procedure 2104-4.39, Solid Radwaste Disposal System Compacting Radioactive Wast':, was approved by a licensed senior reactor operator and a member of the plant management staff.

The TCN deleted from the radwaste compacting procedure the restriction for compacting trash exhibiting greater than 500 mR/hr f'alds, and therefore allowed the compaction of higher level radioactive solid waste materials.

This task was accomplished on March 6,1981, under Radiation Work Permit (RWP) No. 605.

A resident inspector reviewed the circumstances of this work, and reviewed the necessity for a TCN.

During March 1981 the inspector interviewed the involved operations and radiological controls (RADCON) personnel.

The following observations concerning the compacting of radioactive waste on March 6,1981, were identified:

Upper radiation limit of 500 mR/hr was removed from Pro-

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cedure 2104-4.39, and no new limit was introduced; High level radiation work was performed using a standing

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RWP (this RWP did not specify special radiation precautions, or special ALARA review); and,

The TCN was initiated and then validated by the same two

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members of the operations staff.

Although this is a standard and acceptable procedure for immediate or emergency tasks, the compaction of high level radioactive waste, which did not require immediate action, needed Plant Operations Review Committee (PORC) review and Director, Site Operations, TMI-2 approval prior to implementation as noted below.

The inspector reviewed Station Administrative Procedure AP 1001 and TCN No. 2-81 -48.

AP 1001 defines the requirement for issuing a TCN.

Paragraph 3.6.4.2.a of this procedure specifies the method for generating a TCN, and requires in part that a TCN must receive PORC review and Unit Superintendent approval prior to implementation, if the intent of the Station Procedure is changed.

From the review of this task, the inspector detennined that admin-istrative controls were imaroperly implemented in that the intent of Procedure 2104-4.39 was changed by removal of the radiation restriction from the procedure, and therefore the TCN required PORC review before implementatio.

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-g-The finding represents apparent noncompliance with TS J.8.1, 6.8.3.1, and AP 1001, paragraph 3.6.4.2.a, line 7 (320/81-2 -02).

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Routine Health Physics and Environmental Review a.

Plant Tours Resident inspectors completed a general plant inspection tour daily. These inspections included all control points and selected-radiologically controlled areas.

Observations included:

Access control to radiologically controlled areas;

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Adherence to RWP requirements;

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Proper use of respiratory protection equipment;

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Adherence to Health Physics and Operating procedure;

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Use of survey meters including personnel frisking techniques;

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Cleanliness and housekeeping conditions; and,

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Fire protection measures.

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Measurement Verifications Measurements were independently obtained by the resident inspectors to verify the quality of licensee performance in the following selected areas:

Radioactive material shipping;

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i Radiological control, radiation and contamination surveys;

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and, Onsite environmental air samples.

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No items of noncompl'..ce were identified.

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_E;it Interviews

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On March 26, 1981, a meeting was held with senior facility manage-

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ment to discuss the inspection scope and' findings on the SDS review.

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On April 2,1981, a meeting was held with licensee representatives to discuss the inspection scope and findings of the remaining areas noted in this report.

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