IR 05000320/1981014
| ML20032D176 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/15/1981 |
| From: | Ronald Bellamy, Conte R, Fasano A, Forgie B, Gage L, Moslak T, Oneill B, Wiebe T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20032D168 | List: |
| References | |
| 50-320-81-14, NUDOCS 8111130466 | |
| Download: ML20032D176 (21) | |
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U.S. NUCLEAR REGUt.ATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT Regien I Report No.
50-320/81-14 Docket No.
50-320 Category c
License No.
DPR-73 Priority
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Licensee:
Metropolitan Edison Company P.O. Box 480
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Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: July 30 - September 26, 1981 Inrpcetors :
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R. Conte, r Res d t I spector (TMI-2)
date signed iniq/R\\
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t date 3sighe3 T. Ho3tak, Radiatilon Specialist As/W La 640 B'
O' pill, /Radi ion Specialist date signed E4
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i,lele; B. Fobfie,
date signed Summer Technical Intern Accompanied by:
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L. Gage /NucleJr Engineer dat6 s'igned NRC TMI Program Off'ce bnt$ b &All loltlF 1 Wiebe, Nuclear Effgineer datd s'igned NRC TMI Program Office La Ka akaL nhh>
M Bellamy, Chief, Technfal Support Section dafe $igned (/ NRC TMI P ogram Office Approved by:
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A! Fasado, Chief, Three Mile Island Resident dati signed Section, PB#2 8111130466 811019 PDR ADOCK 0500032
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-2-Inspection Summary:
Inspection on July 30 - September 26,1981 (Inspection _ Report No. 50-320/81-14)
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Areas Inspected:
Routine safety inspection by resident inspectors of licensee actions on previous inspection findings; plant operations; reactor building (RB)
entries; submerged demineralizer system (SDS); unusual event:aff-normal reactor coolant system (RCS) leak rate; licensee event reports (in-office review); fire door surveillance program; plant status control; radioactive material shipments; health physics and environmental areas; and radiological environmental monitoring program. NRC TMI Program Office Technical Support staff members reviewed RB entries, SDS, and RB penetration No. 401 modification.
The inspection involved 213 inspector-hours by three resident inspectors and one summer technical intern.
Resul ts : Of the 11 areas inspected, one apparent item of noncompliance was identified in one area (failure to properly document status of components on blue tagged applications for maintenance, paragraph 10.c).
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DETAILS 1.
Persons Contacted General Public-Utilities Nuclear Group
- S Chaplin, Nuclear Licensing Engineer
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J. Chwastyk, Manager Plant Operations -
G. Derk, Engineer Assistant Senior II - Quality Assurance (QA)
- J. Larson, Supervisor TMI-2 Licensing.
C. Kimball, Engineer Assistant Senior II - QA
- L. King, Plant Operations' Director C. Mell, Shi ft ; Foreman.
A. Miller, Technical Analyst Senior I
' R. Parks, Senior Startup Engineer L. Zehner, Radioactive Materal Coordinator NRC TMI Program Office
- L. Barrett, Deputy Program Director
- J.. Wiebe, Nuclear Engineer
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Other members of the operations, engineering, radiological controls, quality assurance and administrative staffs were also interviewed.
- denotes those present at the exit interview.
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2.
Licensee Action on Previous Inspection Findings (Closed) Inspection Finding (Report 50-320/81-07):. Licensee to determine safety classification 'for a modification.
Engineering.
Change Memorandum (ECM) 714, Revision 6, Narch 12,1981, SDS (Submerged Demineralizer System) Feed and Monitor Tank System was properly classified "important to safety".
3.
Plant Operations The resident inspector, on a periodic basis, obtained information on plant conditions, reviewed selected plant parameters for abnormal-
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trends, ascertained plant status from a maintenance / modification
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viewpoint, and assessed logkeeping practices in accordance with l
l administrative controls.
j The resident inspector made random visits to the control room
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during the regular and back-shift hours, discussed operations with control room personnel, reviewed selected control room logs and i
records, and observed selected licensee plan-of-the-day meetings, i
A plant tour was conducted to assess housekeeping and fire protection measures.
Selected key evolutions / events were reviewed by the NRC onsite staff as denoted in paragraphs 4, 5, 6 and 7.
No items of noncompliance were identified.
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-4-4.
Reactor Building Entries '
a.
The onsite -staff monitored reactor building (RB) entries conducted during the inspection period to verify the following on a sampling basis..
.The entry was properly planned and coordinated'for effective
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task implementation including adequate as low as reasonably 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).
Specific procedures were developed for unique' tasks and
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properly implemented.
b.
The. following entries were conducted by the licensee: Entry No.15 on August 27,1981; a one' man, unscheduled entry,'made during the early morning hours on September 3,1981; and Entry No. 16 on September 24, 1981.
During Entry No.15,the licensee accomplished the below listed-items.
Measurements using a portable gamma spectrometer
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Closed circuit television maintenance
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Air cooler inspection and survey-
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RB t!ool' removal, ~ clean-up, and inspection
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During Entry.No.16,the licensee accomplished the below listed items.
Inventory of defueling tools
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Photographs to support future operations
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Radiological surveys to characterize the RB Sump sample under reactor' coolant system (RCS) drain tank
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rupture disk RB air cooler bearing temperature readings
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Sump water transfer hose survey (following transfer of
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15,000 gallons from the sump)
The onsite staff attended RB entry status meetings, reviewed selected documents, applicable procedures and RWP's concerning these entrie e
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-5-c.
At 4:29 R1 on Thursday, September 3,1981, a 10 minute unscheduled entry was made into the TMI-2 RB.
The entry was made to visually ascertain the RB sump / basement water level in the RB after the instrument, which is normally used to measure the elevation of the water, began giving erratic indications.
One man entered the RB and visually verified, through the open stairwell, that there was'no noticeable change in the RB water l evel.
0ne closed circuit television camera was moved into position to continually view the water level through the open stai rwell.
It was subsequently determined that air leaks into the instrument-(a manometer) were causing the incorrect level indications.
The instrument was repaired and indicated that the water surface was at elevation 290.96 feet.
By letter, dated September 8,1981, the licensee submitted a report to 'the NRC on this entrance concerning actions taken.
No items of noncompliance were identified.
5.
Submerged Demineralizer-System Onsite staff review of the submerged demineralizer system (SDS)
preoperational testing, and operation phases continued in specific areas addressed below, a.
SDS Operations During the ' period September 8-11, 1981, the onsite staff monitored the continued use of the SDS for the transfer and processing of reactor coolant bleed tank water (radioactive concentration of approximately 1 uCi/ml).
This evolution was-in preparation for the processing of RB sump / basement water (approximately 150 uCi/ml).
During the period September 2E-25,1981, the onsite staff (with assistance from NRC personnel, TMI Program Office, Bethesda) monitored the transfer of RB sump /
basement water to the SDS feed tanks using a surface suction pump in the RB.
This was the first time PB sump water (other than water saraples) was transferred outside the RB since the March 28,1979 accident. Subsequent processing of 15,000 gallons of sump water through the SDS zeolite beds occurred.
For the sump water transfer and processing, NRC personnel worked shift work to verify the below listed items.
Licensee proper implementation of SDS operating procedures
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Licensee adherence to administrative controls for procedure
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revision / changes
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Assess the performance of the SDS to adequately process radioactive water
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-6-Observations were made concerning operator actions and imple-mentation of various procedures associated with SDS operations.
On September 12, 1981, the licensee ~ implemented Operating Procedure (0P) 2104-8.1, SDS Submerged Ion Exchanger System Operation.
During the flushing of an SDS vessel prior to exchange of vessels, demineralized water (DW) system pressure (approximately 100 psig) was inadvertently' applied to the vessel s.
The vessel was designed and hydrostatically tested to a pressure in excess of the DW system pressure. However, the licensee identified that the inadvertent pressurization was due to an effective TCN (Temporary Change Notice) not being incorporated into the procedure used at the job location.
The TCN corrected an improper lineup contained in the original procedure. The improper lineup caused the problem.
During this period, other document control problems were identified by the licensee.
The licensee reported the initiation of action to assure personnel having access to control room procedures, read and understand facility document control administrative procedures.
Further, the licensee is preparing a response to an apparent item of noncompliance ir, the area of SDS document control (320/81-12-04).
This area will continue to be reviewed by NRC with' respect to that item, b.
SDS Vessel Hydrostatic Test On September 21,1981,an engineer from the NRC TMI Program Office travelle<' to the Buffalo Tank Company (Baltimore, Maryland) to observe hydrostatic testing of the first SDS vessel fabricated by this subcontractor.
The vessel was filled with water and pressurized to 530 psig (1.5 times the design pressure and 5.3 times the maximum operating pressure).
The pressure was maintained for 10 minutes; during this time, no water leakage was observed at any of the welded seams.
Licensee quality control and engineering personnel witnessing the test accepted the test results.
A total of 22 vessels will be fabricated for the SDS by this subcontractor.
No items of noncompliance were identified.
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c.
SDS Performance Radiation levels in the fuel handling building increased only slightly, as expected,during the transfer of RB sump water to the SDS feed tanks and the processing of RB sump water through the SDS zeolite beds. General area radiation levels in the fuel pool areas continued to be less than 1 mR/hr.
Technical problem areas identified during these evolutions are addressed belo r
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(1)
Radioactive Particle Buildup on SDS Air Off-gas Roughing Filter The radioactive particle ' buildup o'n the SDS air off-gas roughing filter was noted initially when processing
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reactor coolant bleed tank water through the-SDS.
Using radiation surveys and reviewing system configuration, the licensee determined that most of the radioactive particles : appeared to be caused by the SDS feed pump recirculation line which allowed water to fall from the end of the recirculation line down to the surface of the water in the feed pump standpipe.
The distance through which this water fell was determined by the level of water in the feed tanks.
The airborne particulates generated by this process were transported to the air off-gas roughing filter by the ventilation system airflow.
To intercept the air particulates prior to reaching the
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roughing filter, the licensee installed a HEPA filter in the ventilation ducting from the feed pump standpipe.
The radiation levels at the roughing filter continued to rise after the beginning of the processing of RB sump water.
In fact, this level rose at a faster rate than prior to the installation of the.new HEPA filter.
This indicated other sources of radioactive particulates and reflected the higher activity of the water being processed.
The increase in radiation levels at the roughing filter appeared to coincide with sampling operations, indicating.
that the sample glove boxes could be the source of airborne radioactivi ty.
The licensee installed HEPA filters in the ventilation ducting for a number of the sample glove
boxes to further identify the source.
The onsite staff is continuing to routinely follow this area.
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Zeolite Fines Generation During processing of reactor coolant bleed tank water the licensee determined that small pieces of zeolite (fines)
were carried out of the zeolite beds contained in the SDS vessels.
The fines carry Cs-137 and Sr-90 that is adsorbed in the zeolite structure.
The fines were apparently generated during the processing of water and this limited i
the quality of water in the effluent.
The fines have not restricted operation of the SD5 apparently due to the low radioactivity loadings (less than 10,000 C1)
encountered to date in the vessel,
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-8-The trial-runs of processing RB sump water did not reveal any major operational problems resulting from fine generation and transport.
The licensee is evaluating methods of retaining the fines in the SDS vessels in the event future operations indicate this is necessary.
The onsite staff is continuing to routinely follow this-area.
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Low Leakage Containment Flow The leakage containment system collects possible leakage from the quick disconnects connecting the zeolite beds to the system piping and directs it along with fuel pool water to two vessels containing ion exchange medium (resin)
located in the fuel pool.
The effluents from these vessels are ther discharged back into the fuel pool.
A minimum leakage containment flow is specified by procedure in order to ensure acceptable quality for fuel pool water.
Problems with containment system flow developed early in the startup and test phase of the SDS.
Pressure drops across the Hanson quick disconnects of the leakage containment ion exchangers and across the SDS ion exchanger were higher than anticipated.
The system flow has been marginally -
acceptable throughout SDS processing and has resulted in frequent system ion exchanger vessel changeouts, resulting in delays in SDS operation.
The licensee obtained a larger capacity pump and intends to install it at a convenient outage time period.
The onsite staff is continuing to routinely follow this area.
6.
Modification to Reactor Building (RB) Penetration No. 401 RB penetration No. 401 is located at the 292 foot elevation in the RB.
(This penetration is approximately 8 feet above the RB basement floor. ) The penetration is 1 foot in diameter.
It was modified after the March 28, 1979 accident to allow the licensee to obtain samples of the contaminated water in the RB basement.
It was later modified again, to allow the licensee to take water level measure-ments.
A tube was passed through the penetration; one end was dropped into the RB basement water, and the other end was connected to a manometer.
The RB basement water level has been gradually rising at a rate of approximately 0.1 foot per month. As of September 15,1981, the level was approximately 0.5 foot below the bottom of the 401 penetration.
Although the water level is expected to recede as water is removed for the SDS processing, additional water can be expected near this penetration during the RB decontamination, when the wall and equipment inside the RB will be washed down.
Considering the above,and in light of future defueling plans, the licensee provided a permanent type closure for the penetration.
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_9-The new modification removed a 12-inch gate valve-and cover assembly and replaced them with a 12-inch circular. closure "sembly that was welded in place.
During the modification, the manometer was -dis-connected, and water level surveillance during this time was by closed-circuit TV camera, in which a reference point was established during~the September 24, 1981 RB entry.
The licensee completed the modification on a 24-hour basis during September 25-27, 1981.
NRC onsite staff witnessing of the work associated with this modification occurred on a sampling basis.
No items of noncompliance were identified.
7.
- Unusual Event - Off-Normal Reactor Coolant System (RCS) Leak Rate a.
Background At 5:00 PM, September 11,1981, the licensee measured RCS leak rate at approximately 0.7 gpm.
Subsequent half-hour measurement periods confirmed the leak between 0.6 and 0.9 gpm. Normal leak rate readings were 0.1 gpm.
At 6:43 PM the same day the licensee declared an unusual event based on plant conditions warranting increased awareness in accordance with the licensee's Emergency Plan Implementing Procedures.
Licensee investigation later that evening confirmed the abnormal leak'in the RCS (downstream of SPC-V71, Standby Pressure Control System) and inside the RB.
Based on a review of previous day's evolutions with shift operators, the licensee determined the excessive leak was due to the-cycling of RC-V122, Pressurizer Liquid Sample Isolation Valve,at approximately 2:30 PM, September 11, 1981.
At 4:22 AM, September 12, 1981, RC-V122 was closed and subsequent leak rate measurements returned to normal.
The exact nature of the leak was not determined since RC-V122 was located in the RB.
No area or process radiological monitors indicated a release of radioactivity to the plant or the environment during the event.
The NRC onsite staff received notification of this event by telephone from the Shift Foreman at approximately 6:00 PM on September 11, 1981.
The staff responded to the event by providing 24-hour coverage until approximately 6:00 AM, September 12, 1981, and by responding to public and media inquiries throughout that weekend September 11-14, 1981.
The circumstances on the cycling of RC-V122 and licensee l
response to the unusual event were reviewed as noted below.
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b.
Scope of Review.
Licensee activities in response to the reported increased RCS leak rate were reviewed to assess the below listed items.
Event description, including date, time, cause and systems
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or plant components affected including a sequence of-events formulated ~ and reviewed
- Safety significance of the event, and compliance with TS.
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or other license requirements Reportability of the event and licensee plans regarding a
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press relaase Necessity to notify state or local. government officials
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Amount of radioactivity released,-if applicable
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Further. licensee activities related to' the functional check of RC-V122 were reviewed to assess the below' items.
Nature of work necessitating functional test of the valve
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Work and subsequent testing controlled by procedures
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Test results in accordance with test acceptance criteria
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Adequate records to support work and test. activities
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c.
Review In addition to observations made in the. control room and at
the radioactive waste panel.at the 305 foot elevation in the l
auxiliary building, and-discussions-with cognizant licensee representatives, selected portions of the following documents l
were reviewed.
t Control Room (Operators) Log for-the period September 11-15, 1981
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on September 15, 1981 Shift Foreman's Log for the period September ll-15,1981
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on September 15, 1981 (
Danger Tag Applications No. 8266, dated August 31, 1981
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l and No. 8317, dated September 12,1981 (RC-V122)
Switching and. Tag Order No.1112, dated September 11, 1981
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Drawing No. 2024, Revision 25, dated January 22, 1979,
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-Reactor Coolant System Makeup and Purification f
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e e-11-Engineering Change Memorandum (ECM) 862, Revision 0,
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dated May 4,1981, Mechanical - Removal of Nuclear
. Sampling Lines ECM 862,- Revision 1, dated June 5,1981, Electrical
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Relocation of Valve (Nuclear Sampling) Control and
' Indication ECM 862, Revision 2, dated July.15,1981 Unit 1-Unit 2
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Separation Shift' Turnover Sheets for the day, swing'and mid shifts,
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September 11-12,'1981 for the following shift positions; Shift Foreman; CR0 (Control Room Operator); Primary A0 (Auxiliary Operator); Secondary A0;- 0utbuilding A0 Turnover Package for ECM 862, Revision 1 for period
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August - September 1981, including associated Turnover Routing Sheet, Work Permit, Tie-In Authorization
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Quality Control (QC) Plant Inspection Report (PIR)
No. 30815, dated August 21, 1981 September 11, 1981, _ Licensee Event Critique Documentation,
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dated September 21, 1981
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Maintenance Procedure 1420-EL-2, Revision 1. March 6,'1981, Preoperational Startup Testing of Electrical Equipment and associated test data for the period September-4-11,'1981 Administrative Procedure (AP).1043, Revision 0, January 15, 1981,
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Work Authorization Procedure
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AP 1047, Revision 0, January 26, 1981, Startup and Test Manual
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Emergency Plan Implementing Procedure 1054.1, Revision 0, April 1,1981 Emergency Operating Procedure 2202-4.18, Revision 1,
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April 15,1981, Reactor Coolant System Leakage d.
Findings _
The cycling of.RC-V122 was due to a required functional test following a modification to' the control circuitry per ECM 862, Revision 1.
The specific test was Test No. 26 of Maintenance Procedure 1420-EL-2.
The modification was performed to shift controls for this valve (and other RCS/ waste disposal system valves) from TMI-l to TMI-2 as part of the separation of units criteria for the restart of TMI-1. A new control panel for
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-12-these valves was installed to the west of the radioactive waste panel, 305 foot elevation of the TMI-2 Auxiliary Building.
Indications for the valves are by limit switch activation of operator position and is also indicated in the control oom.
In the critique of this event, the licensee identified a number of action items to correct certain problems.
One of these was the adequacy of the shift-to-shift turnover to identify tests completed during the shift for increased operator awareness to anticipated off-normal events.
For the RC-V122 event no operator log entries were made concerning the test and the applicable shift turnover sheets did not identify the functional test of RC-V122.
Specific corrective action was under consideration by the licensee at the close of the inspection period.
Accordingly, this is unresolved and the NRC will continue to review this area (320/81-14-03).
8.
In-Office Review of Licensee Event Reports (LER's)
The resident inspector reviewed LER's submitted to NRC: Region I to verify that the details of the event were clearly reported, including the accuracy of the description of cause, and adequacy of corrective action. The inspector determined whether further information.was required from the licensee, whether generic implications were indicated, and whether the event warranted onsite followup.
LER 81-13/0ll-0, dated May 8,1981, Incore thermocouple L-il
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failed.
LER 81-14/03L-0, dated May 7,1981, The surveillance procedure
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3301-Rl' for TMI-2 fire pump battery was not rescheduled or performed since September 1977.
LER 81-15/0ll-0, dated June 13, 1981, Control room ventilation
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monitor alarmed and the control room ventilation system failed to automatically switch to the recirculation mode.
Fire Door Surveillance During the inspection period, the onsite staff reviewed the imple-mentation of administrative controls for fire door supervision.
On August 6,1981 the primary auxiliary operator (AO) check sheets; secondary A0 logs; outbuilding A0 logs; and the operations surveillance OPS-S-177 (weekly check), locked fire doors, dated June 12, 1981, were reviewed for the period July 16 - August 6,1981.
On August 7,1981, 10 fire doors (locked and unlocked) were randomly chosen to verify log sheet status.
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-13-The controls were issued to meet commitments made in a letter dated May 5,1980 to the NRC to comply with License Condition 2.c(3)e.7.
No items of noncompliance were identified.
10.
Plant Status Controls a.
Caution /Do Not Operate Tags During the inspection period, the inspector reviewed the implementation of caution tags and Do Not Operate (DNO) tag controls per Administrative Procedure (AP) 1037, Revision 2, July 31,1979, Control of Caution and DN0 Tags. The logbook containing the caution tag logs and the DN0 tag logs was reviewed for proper completion of the -log sheets.
Twelve different tags were randomly picked to insure proper completion and to check the consistency between the tags and log sheets.
' Tag installations were observed to insure that the tags did not obscure component status lights or switch positions.
No items of noncompliance were identified.
b.
During the inspection period, the inspector reviewed the implementation of controls for temporary modification per AP 1013, Revision 7, February 21, 1978, Bypass of Safety Function and Jumper Control.
The AP addresses the controls on-lifted lead, jumper and temporary mechnical modifications.
Specifically the below listed items were verified.
Jumper tags (red in color) were placed at each end of the
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jumper.
The Shift Foreman's approval was obtained prior to the
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installation of-any temporary electrical jumpers, lifted leads, or mechanical modifications.
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Tags and log sheets were properly-completed.
For lifted leads, jumpers, or' temporary mechanical
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modifications in effect greater than 12 months, an evaluation by the cognizant engineer of the effected system was completed to assure the modification was to remain in effect with a supporting evaluation documented.
A 10 CFR 50.59 review was conducted for temporary
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modifications to systems as described in the Final Safety Analysis Report (FSAR).
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During the period August 17-19,1981,the inspector reviewed f
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the log books containing all of the jumper log sheets, lifted lead log sheets, and temporary mechanical modification log
sheets.
Several installed jumper, lifted lead, and mechanicti modification tags were checked for consistency with respective log sheets.
The review identified one unresolved item.
The inspector determined that improvement was needed in the control of temporary modifications to systems as described in the FSAR (10 CFR 50.b9).
If a temporary modification was installed by a properly reviewed and approved facility procedure a 10 CFR 50.59 review would be conducted using the licensee's procedure control system. However, this type of review would not necessarily be conducted for a temporary modification not-under the purview of a specific operating procedure.
The licensee identified this discrepancy by an internal audit prior to inspector review of this area and on August 19, 1981, the licensee completed the preparation of a change (PCR -
Procedure Change Request) to AP 1013 to address 10 CFR 59.59 review for temporary modifications. The licensee representative
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reported that-this PCR should be issued by mid January 1982.
g This area is unresolved pending completion of action by the y
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licensee,as stated above and subsequent NRC review (320/81-14-01).,
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Equipment and Personnel Protection During the inspection period, the inspector reviewed the
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implementation of controls for equipment and personnel protection per AP 1002, Revision 18, February 11,'1981, Rules for the Protection of Employees Working on Electrical and Mechanical Equipment.
Specifically, the below listed items were verified.
The application for apparatus.to be taken out of service
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was initiated by a person on the approved switching and tagging list and properly reviewed and approved including Shi ft Foreman's, approval.
Tag applications, switchin'g order and tags were properly
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completed.
When equipment was ready to be returned to service, the
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operator was to prepare the switching order for restoratio'nt of the equipment to a normal configuration.
A weekly audit of the tagout log 'was to be perforced by
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the operations department to verify accuracy.
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-15-When an employee' reported '" clear of the apparatus" with -
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' the tags :to remain, the control room operator (CRO) was.
to note theLtime,.date, along with the component' status -
(red and blue' tagged components) and positions (for blue.
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tagged equipment) along'with a statement as to the operability.
Insure. tags were not obscuring component status lights,or
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switch positions.
On August 4 and 5,'1981, the inspector reviewed the tagout logbooks containing all of the. active, old active (greater-than 2 months old), and cleared applications.
Ten tags were also randomly chosen: and each was checked.to see if:it was consistent with the application in the tagout logbook.
Al so,
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the conduct of weekly audits'of plant tagging applications was
verified for' the period July 16 August 7.1981.
The review identified one apparent. item of noncompliance.
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Several instances were noted on the clearance sections of the tag applications involving blue tags where the status column-did not giv& the specific valve / breaker positions of blue-p
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tagged components. - Per AP 1002, a blue tagged component may be-
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operated duririg maintenance-in distinction to red (danger)
tagged components which are not.to be operated unless the tag is cleared.
The blue tag system. facilitates. troubleshooting :
type maintenance to prevent excessive administrative effort in alternating clearance and installation of tags. ' Examples of the failure to give-specific valve / breaker positions upon clearance were noted in the following tag applications.
-Tag Applicat on No. (TAN) 8139, dated July 31 - August-_5,1981,.
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Breaker Controls-and Associated Valves: for Standby Pressure
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Control Pump (SPC-P-3) - No status documented in clearance section
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TAN 8067, dated July 10, 1981, Feeder. Breaker / Control s j
for Substation Electrical Bus.2-72 - No. breaker position.
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f was documented along with status 'of "DN0" (Do Not Operate)
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TAN 8030, dated Jurie 20, 1981, Nitrogen Manifold Valves l
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Unit I-II Corridor - No valve position given along with
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status of "needs leak test" i
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TAN 8028, dated June 23 - July 6,1981, Auxiliary Building g
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Exhaust Fan Breaker / Control (AH-E-10A) - No breaker
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position documented along with status and no status was
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given on certain clearance dates
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In general, the documented component status gave an indication f
of actual plant conditions but since the position of a blue i
p tagged valve or breaker was not specifically stated it would
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-16-only be assumed by the operator from a documentation viewpoint that the position was as originally tagged which was specified on the original tagout application.
The licensee representative stated that the latest positions upon clearance are usually the originally tagged positions.
The inspector concluded that the failure to document valve / breaker positions on " clearance of work" represents apparent noncompliance with TS 6.8.1, AP 1002, paragraph D.3 (320/81-14-02).
The Operations Manager issued a department action item assignment and tracing form, dated September 23, 1981, for control room operators to become more aware of documentation requirements in this area.
By October 16, 1981, all sh Ft foreman (CR0's)
are to re-review AP 1002 paying particular attention to this area of clearance of work under blue tags and they are to sign for completion of this action.
NRC will review the effectiveness of these measures.
At the close of the inspection period,the inspector noted improvements in CR0 documentation states on cleared work for more recent tag applications.
d.
Document Control During the above review (paragraph 10.a through c) it was observed that the various notebooks used to file tag log sheets and application forms contained certain loose-leaf pages that were in rather poor condition.
The inspector raised the question on what measures exist to assure the accuracy of plant status knowledge in that there were no missing pages due to inadvertent los; of the loose-leaf pages from frequent notebook use.
The licensee representative t
l indicated that several operation surveillancas were initiated
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to assure that all notebook binder type recards were accurate.
The inspector reviewed the following documents.
Operations Surveillance (0PS-S)-7, dated March 11, 1981,
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l Audit of Plant Tagging Applications l
OPS-S-13, dated March li,1981, Control Room Logbook l
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Weekly Audit (Saturday)
OPS-S-14, dated March 11, 1981, Control Room Logbook
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Weekly Audit (Sunday)
OPS-S-179, dated August 1,1981, Annual Field Verification
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j of Jumpers, Lifted Leads, Temporary Mechanical Modifications The inspector had no further questions in this area.
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-17-11, Radioactive Material Shipments The resident inspector inspected all radioactive material shipments during the inspection period to verify the below items.
Licensee has verbatim compliance with approved packaging and
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shipping proce. & es.
Licensee had prepared shipping papers which certified that the
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radioactive materials were properly classified, described, packaged and marked for transport.
Licensee had applied warning labels to all packages and placarded
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vehicles.
Licensee controlled the radioactive contaminstion and dose
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rates below the regulatory limits.
The following shipments were reviewed.
Nine TMI-2 reactor coolant sample shipments to the Babcock and
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Wilcox (B&W) Lynchburg Research Center, Lynchburg, Virginia One TMI-2 reactor coolant sample shipment to EG&G Idaho, Inc.,
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Idaho Falb, Idaho Six TMI-2 laundry shipments to Tri-State Industrial Laundries,
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Inc., Utica, New York One burnt out clothes dryer to Tri-State Industrial Laundries,
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Inc., Utica, New York Five SDS monitoring tank samples to Science Applications,
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Inc., Rockville, Maryland One shipment containing assorted scrapings from the inside
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floor and walls of the TMI-2 containment building One shipment containing compacted, solidifled, and noncompacted
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TMI-2 waste to U.S. Ecology, Richland, Washington
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One shipment containing TMI-l decay heat system liquid samples
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and smears to Tel' dyne Isotopes, Westwood, New Jersey Ten EPICOR I dewatered resin liners to Chem-Nuclear Systems,
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Inc., (CNSI), Barnwell, South Carolina Two waste evaporator condensate storage tank monthly composite
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samples to Teledyne Isotopes, Westwood, New Jersey
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-18-One shipment containing TMI-l compacted and noncompacted waste
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to CNSI, Barnwell, South Carolina Three shipments of solidified evaporator bottoms to U.S. Ecology,
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Richland, Washington One shipment containing smears from the TMI-l containment
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building Resident inspector review in this area consisted of: :eview 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.
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Routine Health _ Physi _cs and Environmental Review _
a.
Plant Tours The resident inspector completed a general plant inspection tour daily.
These inspections included all control points and selected radiologically controlled areas.
Observations included the below areas.
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 radiation protection procedures
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Use of survey meters including personnel frisking techniques Cleanliness and housekeeping conditions
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Firra protection measures
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b.
Measurnient Verifications
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Measurements were independently obtained by the resident inspector to verify the quality of licensee performance in the following selected dreas.
R3dioactive material st 2nping
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Radiological control, radiation and contamination surveys
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Onsite environm ntal air and water samples
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No items of noncompliance were identi fle.
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R-19-13.
Radiological Environmental Monitoring Program - Gaseous Effluents During this reporting period, the measures being ' implemented by the licensee to comply with Amendment No.16,-dated June 26,1981.- to
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the Environmental Technical Specifications (ETS) were reviewed.
Amendment No.16 limits the radioactive effluent releases to the environment to the requirements set forth in. Appendix R of. the Final Programmatic Environmental Impact Statement (NUREG-0683).
The review consisted of examining the licensee's measures to control gaseous releases and to evaluate the subsequent doses to the environment.
In reviewing the licensee's control of gaseous effluent releases the following was conducted.
Evaluation of the conservatism of the radiation monitor
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setpoint calculations as per Regulatory Guide 1.109 Examination of the Offsite. Dose Calculation Manual
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Verification that the curie release limits specified in the
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ETS.are incorporated in operating procedures Examinations of the monthly and semi-annual effluent release
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reports and correlate this data with specific release points Compilation of release data _for reactor building purges
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conducted in January through August 1981 In reviewing the Environmental Surveillance Program the following aspects were examined:
Measurement and communication of meteorological data
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Types and frequency of environmental sampling and licensee
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response to abnormal results Bases for animal, general and re::reational population census
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measurements Selected sections of the following documents were reviewed.
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TMI-2 Operating Procedure 2105-1.12, Radiation Monitoring System.Setpoints, Revision 13, June 27,1981 Amendment ha.16 to NRC License No. DPR-73
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Offsite Dose Calculation Manual Three Mile Island Nuclear
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Generating Station
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-20-Regulatory Guide 1.109, Calculation of Annual Doses to Man
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from Routine Releases from Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I, October 1977 NUREG-0133, Preparation of Radiological Effluent Technical
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Specifications for Nuclear Power Plants, October 1978 General Public Utilities (GPU) Inter-0ffice Memorandum from
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Supervisor Effluent Assessment to Engineer Technical Specification Compliance, Subject: PCR 2-81-724 July 14,1981 NUREG-0683, Final Programmatic Environmental Impact Statement,
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Volume 2, Appendices J. R and W, March 1981 Environmental Control Procedures (ECP) 1502, Radiological-
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Environmental Monitoring Program (REMP), Revision 3, September 1,1981 ECP 1503, Sample Collection: General, Revision 3, September 1,1981
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ECP 1503.1, Sample Collection Procedure - Milk, Revision 3,
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September 1,1981
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ECP 1503.2, Sample Collection Procedure, Thermoluminescent Dosimeters, Revision 5, September 1,1981 ECP 1503.4, Sample Collection Procedure, Green Leafy Vegetables
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and Fruit, Revision 3, September 1,1981 ECP 1503.5, Sample Collection Procedure, Air. Iodine and -
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Particulates, Revision 3, September 1,1981
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ECP 1503.7, Sample Collection Pro:edure Precipitation, Revision 5, September 1,1981 ECP 1503.8, Sampic Collection Procedure, Soil, Revision 0,
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September 1,1981 ECP 1503.9, Surveillance Procedure, Air Iodine / Air Particulate,
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Revision 0, September 1,1981 ECP 1504, REMP Surveillance Procedure, Revision 3, September 3,1981
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ECP 1507, Determination of REMP Investigative Levels and
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Subsequent Actions, Revision 1, September 1,1981 ECP 1601, Operating Procedure for the Tektronix 4054 Terminal,
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Revision 2, August 5,1981 ECP 1602, Determination of Off-Site Dose, Revision 1, May 26,1981
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-21-TMI-1 Emergency Plan Implementing Procedure 1004.7, Offsit'e
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Dose Projections, Revision 2,_ June 23,1981 Monthly Effluent. Release Reports from TMI-2 for January
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through July 1981 Semi-annual Effluent Release Report for TMI-2 for January
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through July 1981'
No items of noncompliance were identified.
This area will be routinely monitored by NRC.
14. Unresolved Items Unresolved items are findings about which nore information is needed to ascertain whether it is an item of noncompliance, a deviation, or acceptabl e.
Unresolved items disclosed during this inspection are discussed in paragraphs 7 and 10.b.
15. Exit Interview On September 29. 1981 a meeting was held with 1,rensee representatives (denoted in paragraph 1) to discuss the inspection. scope and findings.
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