IR 05000320/1981006
| ML19350F119 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/15/1981 |
| From: | Ronald Bellamy, Conte R, Fasano A, Gage L, Kalman G, Moslak T, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19350F116 | List: |
| References | |
| 50-320-81-06, 50-320-81-6, NUDOCS 8106240233 | |
| Download: ML19350F119 (15) | |
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U.S. NCULEAR REGULATORY COMMISSION O
OertCe Or INSeeCTION AND ENr0RCEMENT Region I Report'No.
50-320/81-06 Cocket No.
50-320 Category c
License No.
OPR-73 Priority
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Licensee:
Metropolitan Edison Company P.O. Box 480 Middletown, Pennsylvania 17057 racility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania
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Inspection conducted: March 29 - May 2,1981 T)'Y V]
Inspector.
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R. C e 'or R st n Inspector, TMI-2 date signed
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T. 'M.oslak, Radi'at' ion SpeciaH st dateh;iighed
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L. ThonusY R diation Specialist,
date signed M/5'k/
Accompanied by:
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L. Gage, Engine NRC TMI Program Office date signed
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G. l(alman,' Engineer, NRC TMI Program Office date signed 0. 0 -
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R. Bellamy, Chief, Teyhnical Support Section datepigned
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TMI Program Office Approved by:
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K7 Fasano, ' Chief, Three Mile Island Resident dats sign 9d Section t
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Inspection Sunnary:
Inspected on March 29,1981 (Inspection Report No. 50-320/81-06 Areas Inspected:. Routine unannounced inspection by resident inspectors of plant operations; reactor building entries; significant event con-cerning apparent elevated tritium airborne concentration levels in the fuel handling building; radioactive material shipments;. routirie health physics and environmental activities. Staff members of the Technical Support Section NRC TMI Program Office reviewed the Reactor Building entries and the Submerged Demineralizer System quality assurance program.
The inspection inn 1_ved 182 inspector-hours by three resident inspectors and 140 staff-hours by two engineers.
Results: No items of noncompliance were identified.
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DETAILS
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1.
Persons Contacted General Public Utilities Nuclear Group
- J Bondik, Supervisor Effluent Dose Assessment TMI-2
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- J. Brasher, Radiological Controls Director, TMI-2 W. Conway, Supervisor Process Operations, TMI-2
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- S. Chaplin, Licensing Engineer, TMI-2
- J. Chwastyk, Manager Plant Operations, TMI-2
- G. Kunder, Supervisor Technical Specification Compliance, TMI-2
- L. King, Plant Operations Director, TMI-2
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- J. Marsden~, Quality Assurance Systems Engineer
- M. Pastor, Recovery Programs Director, TMI-2 l
R. Prabhaker, Manager Site Quality Assurance
- P. Ruhter, Manager Radiological -Technical Support, TMI-2 NRC TMI Program Office
- L. Barre'tt, Acting Deputy Program Director
- J. Wiebe, Engineer-Other members of operations, engineering, quality assurance,.
radiological controls and administrative staffs were also inter-viewed.
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- denotes those present at exit interviews.
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2.
Licensee-Action Previous Inspection Findings
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(Closed) Violation (320/79-10-23):
Failure to put the facility in a cold shutdown mode with Reactor Coolant System unidentified ler.sge greater than one gallon per minute. Details of licensee
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urrective action and NRC verification are in paragraph 6.
3.
?lant Operations
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The inspector, on a periodic basis, obtained information on plant conditions, reviewed selected plant parameters for abnormal trends, ascertained plant status from maintenance / modification viewpoint, and assessed.logkeeping practices in accordance with administrative controls.
The inspector made random visits to the control room during the 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.
Selected key evolutions were reviewed by' the NRC onsite staff as denoted in paragraphs 4 and 5.
No items of noncor5 ance were identified.
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Reactor Building Entries The onsite staff monitored Reactor Building entries conducted during the inspection period to verify the following on a sampling basis:
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The entry was properly planned and coordinated for effective
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task implementation including adequate as low as reasonably
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achievable (ALARA) review, personnel training, and equipment testing.
Proper radiological precautions were planned and implemented
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including the use of a Radiation Work Permit (RWP); and,
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Specific procedures were developed for unique tasks and
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properly implemented.
The following entries were conducted by the licensee:
Entry No. 8 on April 8,1981; Entry No. 9 on April 30, 1981.
Entry No. 8 was a short entry (40 minutes) to survey the area in the vicinity of the open stairwell where a floating sump pump was to be installed to support Submerged Demineralizer System (SDS)
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operations.
. During Entry No. 9, the licensee accomplished the following:
Completion of preparations for a decontamination experiment
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for a subsequent entry; Installation of the floating sump pump referenced above; and,
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Radiological surveys.
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The onsite staff attended Reactor Building entry status meetings, reviewed selected documents, applicable procedures and RWP's, and observed equipment testing prior to entry.
The onsite staff will continue to closely monitor each entry.
5.
. Significant Event - Apparent Elevated Tritium (H-3) Concentration Level in the Fuel Handling Building
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a.
Background At approximately 10:00 p.m. on April 29, 1981, licensee representatives' obtained analytical results for an airborne concentration in the Fuel Handling Building (FHB) of 3.1 x 10-5 uCi/cc (tritium, H-3) for a grab sample taken between
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' 2:00 p.m. to 7:00 p.m.
The sampling process was perfomad
- while EPICOR-II processed water, which contained 0.22 uCi/ml of H-3, was.being transferred to partially fill the "B" Spent.
Fuel Pool. This sample was taken inside the pool. Subsequent airborne samples were imediately taken at the 347' elevation (working area) of the FHB adjacent to the "B", pool.
The results of the second sample bec me available at 4:45 a.m.,
April 30,1981, and showed 2.2 x 10- uCi/cc (H-3). The 347' elevation was subsequently declared an airborne radio-activity area. The transfer process was secured at 2:30 a.m.,
April 30,1981.
At approximately 10:00 a.m.,6on April 30, 1981, a sample analysis indicated 1.2 x 10- uCi/ce, (H-3) and personnel
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entry into the area was resumed since the airborne (H-3)
concentration was reduced 'o below 25 percent of MPC (occu-pational maximum permissible concentration per 10 CFR 20).
Licensee analytical results of a grab sample taken between 5:53 a.m. and 7:40 a.m. on April 30, 1981, from the FHB ventilation exhaust indicated an H-3 concentration of less than the Lower Limit for Detection (LLD-4.5 x 10-9 uCi/cc).
NRC onsite staff reviewed monthly H-3 effluent values and determined that the H-3 airborne releases during April 1980
(2.8 Ci) were essentially the same as March 1981-(2.7 C1).
Based on the monthly effluent data it appears that the slightly elevated and localized H-3 concentration in the FHB during April 29 and 30, 1981, did not contribute to any significant increase in the plant monthly H-3 effluent.
Licensee representatives reported the event to the NRC onsite l
staff at approximately 7:45 a.m. on April 30, 1931. The NRC l
resident inspectors initiated a review as noted below.
b.
Scope of Review
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Licensee activities in_ response to the reported high H-3 airborne concentration levels in sne FHB were reviewed to assess the following:
Event description, including date, time, cause, and
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systems or plant components affected including a sequence of events formulated and reviewed; i
i Safety signi.ficance of the event, and compliance with TS l
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l or other license requirements; Reportability of the event and licensee plans regarding a f
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Necessity to notify state or local government officials;
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and, Amount of radioactivity released.
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c.
Review
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In addition to observations made in and around the "3" Spent Fuel Pool in the FHB and discussions with cognizant licensee representatives, selected portions of the following documents were reviewed:
Control Room Log for the period April 29-30, 1981;
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Shift Foreman Log for the period April 29-30, 1981;
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Health Physics Log for the period April 29-30, 1981 ;
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Procedure 2104-4.54, Revision 2, May 6,1980, Transfer of
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Water from CC-T-1 or CC-T-2 to the Spent Fuel Pool; Analytical results-for H-3 Airborne Samples taken in FHB
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during April 29 - May 1,1981.
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Findings
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By the close of the inspection period (3 ' days after the event)
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the licensee made a press release concerning the event and initiated an investigation into the circumstances surrounding the event. The objective of the licensee's review was: to determine the reason for the higher than expected H-3 levels during the processed water transfer; to determine the adequacy of H-3 sampling and analytical procedures / techniques; and, to l
determine personnel uptake / dose assessment through a bioassay program initiation. At the exit interview the licensee representative reported no positive indication of uptake on bioassay sampling.
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At the time of the exit interview the licensee representatives L
stated that calibration of the sample pump flow indication was suspected as being improperly performed, and that indicated H-3 levels could be lest than reported.
Licensee review of this area was not complete by the close of this inspection period.
This area is unresolved pending completion of licensee and NRC review of this event (320/81-06-01).
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6.
NUREG 0600 - Investigation into the March 28, 1979, Three Mile
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Island Accident by Office of Inspection and Enforcement (IE)
a.
Background During the period March -28 - July 31,1979, IE conducted
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Investigation No. 50-320/79-10, into the TMI-2 Accident on l
March 28,1979, and documented the results of that investigation j
in NUREG 0600, dated August 1979.
In a letter dated October 29, 1979, from V. Stallo, IE, to R. Arnold, General Pubilic Utilities.
the apparent violations of NRC regulations were identified in l
Appendix A of the letter, and a' Notice of Proposed Imposition I
of Civil Penalty (amount $155,000) was issued in Appendix B of'
i that letter.
Based on the licensee's response dated December 5,1980, certain fines were remitted or reduced; however, since the
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cumulative civil penalty amount was still greater than the calculated statutory limit,~ the limit of $155,000 was imposed.
The licensee made payment on the civil penalty by letter dated February 14, 1980, in the amouat of $155,000. Subsequent
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discussions of commitments and corrective actions from initial
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licensee response for all cited items were documented in
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licensee letters dated February 11, May 19, July 10, December 23, 1980, i
and Jar.uary 9,1981; and NRC letters dated January 23, August 27, September 10, November 21, 1980.
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Based on the licensee's initial response of December 5,1980, 26 areas were identified in which commitments and corrective actions were to be taken by the licensee.
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During this inspection period NRC verification of completion l
of the composite licensee commitment / corrective actions for each of the 26 areas was initiated.
Dismsition for one item reviewed during this period is listed below, b.
Licer ;ee Action L
Violation No. 9 (320/79-10-23) was the failure of the licensee to put the facility in a cold shutdown mode with Reactor Coolant System (RCS) leakage greater than one gallon per minute (gpn) during March 22-28, 1979, in violation of Technical Specification (TS) 3/4.4.6. The licensee reported that this was caused by a failure to correct all non RCS tank i
inventory (makeup) values used in the leakage calculation for
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RCS operating temperature conditions. The correction was applicable to Surveillance Procedure 2301-301.
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In August 1979 the licensee revised SP 2301-3D1 for the proper l
temperature compensation for all applicable tank inventory makeup.valu2s. This revision was also reviewed and approved
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by the onsite N'
staff and doenented in IE Inspection Report Nos. 50-320/79-1, and 50-320/79-29 (item 320/79-17-03).
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Currently RCS leakage is calcu!sted using procedure 2102-3.4, Revision 2, January 7,1981, Reactor Coolant System Operation with Core Cooling VIA Natural Losses. Although no TS limit is defined, the licensee's procedures reflect action levels for abnormal RCS leakage trends (re: Emergency Procedure 2202-4.18, RCS Leak /Small Break LOCA).
Tne inspector reviewed selected sections of the above pro-ced;res and reviewed RCS leakage data for 5:00-9:00 a.m. and 9:00-10:00 a.m. on April 28, 1981.
RCS leakage was averaging approximately 0.1 gpm. The inspector had no further comments in this area and considered item 320/79-10-23 closed.
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7.
Submerged Demineralizer System (SDS) - Quality Assuranr.a Program a.
Background
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The SDS is the system that the licensee plans to use to
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process the reactor building sump / basement water that resulted from the March 28, 1979, accident. As a part of the NRC TMI Program Office preoperational review of this systen, the staff
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l members of the Technical Support Section examined the Quality Assura'nce (QA) activities associated with the fabrication and installation of the SDS.
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The QA Program was defi'ned by the "TMI Unit 2 Recovery Quality
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l Assurance Plan".
It was submitted to the NRC TMI Program Office on October 30, 1980, and was gonditionally accepted on March 20, 1981.
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Ancillary procedures that the licensee wrote, which were used in the QA Program for the SDS, included:
TMI-3-01, Revision 1, QA Review of Engineering Change
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Memorandums; TMI-15-03, Revision 0, Important to Safety Material
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Nonconformance Report; GPU 7-3-01, Revision 0, GPUN QA Review of Engineer 4ng
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Specifications and System Design Descriptions; GPU 7-4-01, Revision 2, QA P.eview of Procurement Docu-
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ments; GPU 7-7-03, Revision 4, Supplier Classification List;
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GPU 7-7-04, Revision 3, Evaluation of Suppliers for
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Supplier Quality Classification List; and, 7-10-M0-002, Revision 0, QA Modifications / Operations
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Section--Inspection Program.
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Contract Services Evaluation Pa igraoh 5.1.1 of the QA Plan states, in part: " Procurement of asterial, equipment and services which are considered impoitant to safety shall be perfonned in accordance with writon policies, procedures and instructions. These shall establish methods for preparation, review, approval and control of procurement documents and shall provide measures to l
comply with applicable regulatory requirements. Appropriate measures shall be established to evaluate procurement sources.
l monitor the activities of consultants. vendors and contractors, j
and confirm that purchased item; confonn to procurement j-document requirements. The programs of all participants shall
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be in accordance with the requirements of TMI Quality Assurance Program." The reviewer examined the GPU Survey Report Nc. QA/1190, l
dated October 22, 1979, to determine if the licensee took
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appropriate measures to evaluate the SDS procurement source.
This licensee report was a survey of Chem-Nuclear Services, Inc.,
of Barnwell, South Carolina, performed on September 25-28, 1979.
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The reviewer also reviewed a licensee follow-up Audit Report, l
No. 0-TMI-2-V-80-01, dated March 18, 1980, for an audit l
conducted on February (2-14, 1980.
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The survey and audit * reports identified several unresolved
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items. Chem-Nuclear provided a response on April 23, 1980, to these items via their letter No. 2-CNTM-80/56.
A follow up audit was perfonned by the licensee on June 10-11, 1980,
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and documented in Audit Report No. 0-TMI-V-80-01, dated June 20,1980. Chem-Nuclear provided a response to these audit findi..gs on September.10,1980, via their letter No. LG-TMI-1062.
The close-outs of the licensee's audit findings were confirmed.
l No items of noncompliance were identified.
c.
Procurement Review To determine if the licensee was procuring material and services from Chem-Nuclear in accordance with the requirements
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of the TMI Recovery QA Plan, the reviewer examined the con-ditions imposed by GPU purchase order No. 85939. Change
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Notice No. 3 to the purchase order, dated Febraury 14, 1980, incorporated attachment "A", titled " Met-Ed/GPU Quality Requirements for Radwaste Management Systems and Shipping
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Packages for Radwaste". This attachment imposed quality
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system requirements conforming to 10 CFR 71. These quality l-system requirements were similar to those contained in the TMI l
Recovery QA Plan.
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The reviewer examined the Chem-Nuclear QA Program Manual and the GPU critique of the manual to determine that the attachment "A" quality-systems requirements were being incorporated into the Chem-Nuclear QA Program. The GPU critique of the Chem-Nuclear QA manual was transmitted to Chem-Nuclear on January 29, 1980.
The critique connents could not be incorporated prior to GPU's l
audit of February 12-14, 1980. The comments were subsequently
incorporated in the Chem-Nuclear QA manual revision of i
l April 10,1980; were reviewed during the GPU audit of June 10-11, 1980;
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j and, were accepted per GPU's letter No. QA/3017 to Chem-l Nuclear, dated June 20, 1980.
No items of noncompliance were identified.
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d.
Contractor Procedures l
l Attachment "A" (referenced in paragraph 7.c) also required GPU i
l approval of process procedures (specifications).
Chem-Nuclear provided approximately 30 specifications for the SDS. The l
reviewer selected six or them and reviewed them for con::istency with program requirements. They included
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No. 527-L-5006, Revision P., Stainless Steel Tubes, Grade
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TP304, Seamless; No. 527-L-5013, Revision 0, TFE (Teflon) Metal Braidec,
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Flexible Hose; No. 527-L-5015, Revisio 0, Shop / Field Fabrication and i
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Erection of Piping and Piping Systems; l
No. 527-P-5001, Revision 3, Electrical General Require-
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No. 527-W-5001, Revision 1, Welding, General Specifi-l
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cation; and, No. 527-X-5001, Revision 0, Special Protective Coating
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for Metals.
No items of noncompliance were identified.
e.
Design Review The TMI Recovery QA Plan states in part, "... Materials, parts, and processes selected by design are reviewed to assure that they are suitable for the intended application...." The reviewer examined GPU Technical Data Report No. 201, Revision 0, l
titled "SDS-Connents on Reconnendations of the Draft Design Review by Wachter Associates, Inc.".
This report provides the
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connents of the GPU engineering staff to a design review of the SDS. conducted by a design consultant. The report presents Wachter reconnendations and GPU accept / reject rationale in the following hardware and procedural areas: system function,
. persor.nel safety, and public safety.
i No items of noncompliance were identified.
f.
Audits Attachment "A" (referenced in paragraph 7.c) also provider for licensee audits of Chem-Nuclear. It states in part: "During performance of this order, the seller's quality assurance / control
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or inspection system and manufacturing / operations processes are skject to review, verification and analysis by the purchaser's. quality assurance organization."
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The reviewer examined the following licensee audit reports of Chem-Nuclear and their subcontractor, Applied Engineering Co.
of Orangeburg, South Carolina, to detennine the extent of the licensee's audit program during the fabrication of the SDS:
(1) TMI-2/8/00064, dated February 13, 1981. for an audit of February 5, 1981;
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(2)'TMI-2/7/00054, dated November 19, 1980, for an audit of, L
October 13-17, 1980; i
(3) TMI-2/32, dated August 25, 1980, for an audit on July 21-24,1980; (4) TMI-2/31, dated August 25, 1980, for an audit on July 14-15,1980; and, (5) TMI 2/30, dated July 30, 1980, for an audit on i
June 24-26,1980 Audit report (3) identified five nonconfonnances; audit report (5)
identified four nonconformances.
The reviewer examined licensee disposition of the noncon-fonnances by the subcontractors and the reviewer had no further coments in this area.
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g.
Additional Procurement Services Subsequent to their SDS procurements from Chem-Nuclear, the licensee contracted with the Permutit Company of Lancaster, j
Pennsylvania, for eight additional SDS liners. These liners, i
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-12-of an improved design, will be used in place of the Chem-Nuclear liners in the ion-exchange section of the SDS.
To determine if the licensee took appropriate measures to evaluate this procurement source, 'the inspector reviewed the GPU Survey Report No. QAEL/443, dated April 2,1981. This survey was conducted on March 27, 1981. The report indicated that Permutit had a satisfactory quality assurance program in effect.
The reviewer visited the Permutit facility on April 30, 1981.
He observed final hydro tests in progress on the demineralizer liners, and interviewed the quality assurance manager and supervisor who were responsible for the tests. The reviewer also reviewed the following documents: The Permutit Nuclear Products Quality Assurance Manual (dated August 20,1980); the GPU drawing for the lir.cr fabrication (No. 20-950-29-001, Revision 6); Permutit's manufacturing order process sheets (which include the sequence of fabrication operations and QA inspection points); discrepancy reports and their dispositions;
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and operation and inspection records.
No items of noncompliance were identified.
h.
Installation Procedures The reviewer selected several of the Engineering Change
. Memorandums (ECM's) that were issued to describe the installation
of the SDS at the site. These were reviewed for correct safety classification, quality control (QC) surveillance
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(" hold points"), and over-all clarity of instructions.
The ECM's reviewed included:
748, Revision 0, including the QC inspection reports PIR-
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WE-10231/80 and PIR-WE-40133/81;
752, Revision 0, including the QC inspection reports PIR-
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WE-40151/81 and PIR-WE-40129/81; S793, Revision 0, including inspection report PIR-CS/30280/81;
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S515, Revisions 0 through 4, (This ECM initially did not
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specify QC review, but the later revisions did specify QC review); and, 653, Revision 2, (The inspection report for this ECM,
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PIR-CS/30296/81, incorrectly documented the results of the QC inspection of supports and structural steel.
After the NRC reviewer identified the discrepancy, the licensee corrected it, issuing a revised.'IR-CS/30296A/81).
No items of noncompliance were identified.
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Radioactiv'e Material Shipments The resident inspectors inspected all radioactive material shipments during the inspection period to verify that the:
Licensee had verbatim compliance with approved packaging and
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I shipping procedures; Licensee had prepared shipping papers which certified that the
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radioactive materials were proper'.y classified, described, l
packaged and marked for transport; Licensee had applied warning labels to all packages and
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placarded vehicles; and, Licensee controlled the radioactive contamination and dose
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rates below the regulatory limits.
l During-the inspection period the licensee shipped the following materials:
Four EPICOR-II dewatered resin liners, and one compacted and
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non-compacted waste shipment to Hanford, Washington; Five reactor coolant sample shipments to Lynchburg, Virginia;
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Two laundry shipments to Utica, New York; l
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i One containment sump sample sk.ipment to Oak Ridge, Tennessee;
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Four assorted sample shipments to Westwood, New Jersey, and
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l Rockville, Maryland; Six EPICOR-I dewatered resin liners and one' solidified pre-
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coat liner to Barnwell, South Carolina; and, One shipment of valves to Huntsville, Alabama.
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Resident inspector review in this area consisted of: review of shipping papers and procedures, examination of packages and vehicles, and performance of a survey of the radiation and contamination levels of each shipment.
No items of noncompliance were identified, i
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9.
Routine Health Physics and. Environmental Review a.
Plant Tours Resident inspectors completed a general plant inspection tour
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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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Adherende to Health Physics and Operating procedures;
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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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b.
Measurement Verifications
' Measurements were independently obtained by the resident inspectors to verify the quality of licensee performance in the following selected areas:
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Radiological control, radiation and contamination surveys;
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and, Onsite environmental air samples.
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In addition, a one liter sample of water from the East Dike was sent to Idaho Falls, Idaho, for analysis. Analysis was Tritium concentration was reported at 2.0 x 10 pitters.
requested for Strontium-90, Tritium, and gamna uCi/ml and Cesium-137 was not detectable. Strontium-90 data had not been received as of the close of this inspection period.
No items of noncompliance were identified.
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10. Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is an item of noncompliance, a
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deviation, or acceptable. Unresolved items disclosed during this inspection are discussed in paragraph 5.d.
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11. Exit Interviews On April 21, 1981, and May 7,1981, meetings were held with senior
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facility management to' discuss the inspection scope and findings.
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