IR 05000320/1981017

IE Insp Rept 50-320/81-17 on 810927-1114.Noncompliance Noted:Failure to Follow Radiation Work Permit

ML20039C437
Person / Time
Site:	Three Mile Island
Issue date:	12/09/1981
From:	Bellamy R, Conte R, Fasano A, Oneill B, Joel Wiebe NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20039C431	List: IR 05000320/1981017 ML20039C430 ML20039C435
References
50-320-81-17, NUDOCS 8112290349
Download: ML20039C437 (11)

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U.S. WUCLEAR REGULATORY COMMISSION 50320-810903 0FFICE OF INSPECTION AND ENFORCEMENT 50320-811004 Region I Report No.

50-320/81-17 Docket No.

50-320 Category c

License No.

D P R-7_3_

Priurity

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Licensee :

Metropolitan Edison Company P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear _ Station, Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: September 27 - November __14,1981

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Inspectors:

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R. Conte, Senior Resident Inspector (TMI-2)

date ' signed huJ $4 N/ 9/

B. O' Neill,/Radiption Specialist date signed l.2 f 9 f?"/

Accompanied by:

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dats signed

. jWiebe, Nuclear Engineer i

TMI Program Office

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)date signed R. Bellamy, Chief, Technic'aTSupport Section NRC TMI Program Office

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Approved by:

i gw A.~ Fa'sano, Chief, Three Mile Island Resident date ' signed Section, PB No. 2 Inspection Summary:

Inspection on September 27 - November 14,1981 (Inspection Report No. 50-320/81-17)

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Areas l_nspected : Routine safety inspection by onsite inspectors of reactor building (RB) entries; radioactive material shipments; and health physics and environmental areas.

NRC TMI Program Office Technical Support staff members reviewed RB entries and submerged demineralizer system operations.

The inspection involved 160 inspector-hours.

R_es ul ts : Of the four areas reviewed, one apparent item of noncompliance was identified in one area (failure to follow a radiation work permit, paragraph 2.d).

8112290349 811211 PDR ADOCK 05000

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Detail s 1.

Persons Contacted General Public Utilities Nuclear Group

• S. Chaplin, Licensing Engineer

• W. Conaway, Shift Supervisor

• W. Heysek, Quality Assurance (QA) Audit

• P. Hollenbeck, Radiological Engineer

• L. King, Plant Operations Director

• D. Lequia, QA Audit Monitor P. Newkirk, Assistant Manager Radiological Control M. Pastor, Recovery Programs, Operations and Construction Director P. Ruhter, Manager Radiological Technical Support Bechtel Corporation J. Gilbert, Assistant Entry Supervisor D. Machiela, Entry Coordinator T. Morris, Entry Supervisor Other licensee personnel were aisc interviewed.

• denotes those present at the exit interview.

2.

Reac_t_or Building Entries During this instection period the licensee announced that a schedule of reactor building (RB) entries was planned in preparation for large scale decontamination experiments; which would be conducted during December 1981.

In accordance with the licensee's plan, approximately 17 RB entries were scheduled to commence during the last week of October and continue through November and December.

A synopsis of the plan (from Three Mile Island Program Office weekly status report, dated October 26, 1981) follows : "The objective of the 17 entries is to acquire generic research and development information on accident related contamination problems.

The initial entries are planned to thoroughly characterize the RB contamination and the contamination induced radiation levels on the polar crane and on the two accessible floors of the RB.

Following the characterization, the areas will be decontaminated in an attempt to remove loose surface contamination using water with various combinations of temperature and pressure.

Following the decontamination experiments, the RB will be resurveyed to determine the effectiveness of the decontamination techniques.

The contamination characterization surveys will include sample removal for laboratory analysis, in situ spectroscopic measurements, and air, water, and area radiation surveys.

The predecontamination surveys will be performed in October and November.

In parallel with the characterization surveys, decontamination hardware will be installed in the RB.

The installation will include

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R3 penetration modifications to insert high pressure water hoses into the RB.

A power lift will be attached to the polar crane for use in transporting personnel and equipment from the 305' elevation to the 347' elevation and to the polar crane.

A 10,000 PSI, 25 GPM water pump and water heaters will be installed outside the R3.

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The actual decontamination inside the RB is scheduled to commence on the 305' elevation in early December.

The decontamination

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techniques will be limited to high pressure water sprays and low

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pressure water washes. Water temperatures up to approximately 140 degrees fahrenheit will be used.

It is estimated that the decontamination experiment may add approximately 55,000 gallons of previously processed water to the RB sump.

The Submerged Demineralizer System (SDS) will reprocess this water from the RB sump."

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a.

The onsite NPC staff monitored the RB entries conducted during this inspection period to verify the following on a sampling basis.

The entry was properly planned and cocrdinated for effective

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task implementation including adequate as low as reasonable achievable (ALARA) review, personnel training, and equipment testing.

Proper radiological precautions were planned and implemented

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

Specific procedures were developed for unique tasks and

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properly implemented, b.

Several discussions were conducted between NRC onsite staff and the licensee regarding the following documents in support of RB entries / decontamination experiments.

Three Mile Island Unit 2 Containment Building Experiment

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Purpose and Scope of Work, dated October 30, 1981 Draft, Unit 2 Containment Access Procedure, dated November 13, 1981

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Radiological and Safety Evaluation of the Containment

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Building Decontamination Experiment for TMI-2 Recovery, dated November 18, 1981 Technical Plan for Reactor Building Gross Decontamination,

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and Technical Data Book, Volume 2, Decontamination Technology, dated May 1981 Unit 2 Operating Procedure 2104-4.55, Reactor Building

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Entry and Pre-Decon, Revision 5, dated September 29, 1981 (also Revisions 0-4)

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-4-Three Mile Island Nuclear Station Unit 2 Radiation Protection

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Plan, dated January 23, 1981 c.

The following RB entries were conducted by the licensee:

Entry No.17 on Tuesday, October 27, 1981; Entry No.18 on Thursday, October 29, 1981; Entry No.19 on Thursday, November 5,1981; and Entry No. 20 on Friday, November 13, 1981.

During Entries No.17, No.18 and No.19, the licensee performed the following tasks:

Sump water transfer hose survey following transfer to SDS

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of 165,000 gallons of water as of October 29,1981 and 2C5,000 gallons of water as of October 31, 1981 Measurements using a gamma multichannel analy:er on the

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305' elevation Radiation survey and sample gathering

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Trash removal cleanup, and staging of trash and equipment

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on elevations 305' and 347'

During Entry No. 20, the licensee perfonned the following tasks:

Sump water transfer hose survey following transfer to SDS

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of 255,000 gallons of water as of November 12, 1981 Reactor building air and water samples for biological

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analysis Removal of HPR-212 (area radiation monitor) and solenoid

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valve Continuation of the area housekeeping on elevations 305'

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and 347'

Still photography documentation

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The onsite staff attended RB entry status meetings, reviewed selected documents, applicable procedures, RWP's concerning these entries and monitored entry activities from the RB entry command center.

d.

During this inspection period the inspector reviewed the circumstances and the documentation of the unscheduled RB entry which was made at 4:29 N4 on Thursday, September 3,1981.

The one rr.an entry was made to visually ascertain the RB sump / basement

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water level in the RB after an instrument, a manometer which is normally used to measure the elevation of the water, began giving erratic indications.

The inspector interviewed the licensee's entry personnel and personnel that supported the entry.

The inspector reviewed i

RWP No.1866, dated September 3,1981 which described the scope of the task to be performed during the entry.

The inspector noted that the RWP was specific as to the work to be performed in that item 5 stated " visual inspection of water level and positioning of CCTV camera".

Item 13 of the RWP required an HP (health physics technician) escort for the individual making the entry.

l The inspector also reviewed the following documents concerning the unscheduled entry:

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Letter to Mr. M. K. Pastor, GPU Service Corporation, dated September 8,1981, from Mr. R. Rider, Project

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Engineer, Bechtel Northern Corporation Radiation Work Permit No.1867, " Ante Room and Airlock,"

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dated September 3,1981 Radiological Survey Form, dated September 4,1931, Ante

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Room (Sludge Sample Tool)

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TMI Unit-2 Radiological Deficiency Report No. 81-0061,

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dated September 3,1981 Unit 2 Radiological Control Log

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From discussions with involved personnel and the documentation review, the inspector determined that during the unscheduled

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RB entry on September 3,1981, two failures to follow RWP

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requirements occurred.

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Removal of the sludge sample tool from RB staging area, 305' elevation, to the ante room

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No HP escort during the entry i

The inspector noted that failure to properly follow RWP requirements was identified by licensee personnel, in that at 6:30 AM on September 3,1981 a Radiological Deficiency Report (RDR) (No. 81-0061) describing the deficiency had been filed by the duty Radiological Controls Foreman and approved by the Radiological Controls Department Manager.

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-6-The inspector reviewed the corrective actions documented on the RDR, dated September 17, 1981, and discussed the seriousness of failure to follow RWP requirements during a special meeting with licensee staff concerning RB entries on October 2,1981.

Corrective actions included involved personnel counseling on following RWP requirements, HP Foreman review of future PS

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entry scenarios for an understanding of specific tasks, and one final discussion on expected actions prior to entry will be made.

The inspector stated that failure to follow RWP requirements constituted an apparent item of noncompliance (320/81-17-01).

However, NRC review of the unscheduled entry and other related licensee's action were not completed at the close of this inspection period and therefore, this area is unresolved pending completion of that review (320/81-17-02).

3.

Radioactiv_e__ Material Shipments The onsite NRC radiation specialists inspected all radioactha material shipments during the inspection period to verify the below items.

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Licensee had complied with approved packaging and shipping procedures.

Licensee had prepared shipping papers which certified that the

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radioactive materials were properly classified, described, packaged and marked for transport.

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Licensee had applied warning labels to all packages and placarded

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vehicles.

Licensee controlled the radioactive contamination and dose

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rates below the regulatory limits.

The following shipments were reviewed.

Five TMI-2 reactor coolant sample shipments to the Babcock and

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Wilcox (B&W) Lynchburg Research Center, Lynchburg, Virginia

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One TMI-2 RB sump water sample shipment to EG&G Idaho, Inc.,

Idaho Falls, Idaho Three TMI-1 shipments of metal boxes containing noncompacted

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trash to U.S. Ecology, Richland, Washington Fourteen EPICOR II dewatered resin liners to U.S. Ecology,

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i Richland, Washington

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i-7-Two shipments containing compacted and noncompacted TMI-l LSA

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(Low Specific Activity) waste to Chem-Nuclear Systems, Inc.,

Barnwell, South Carolina Two TMI-1/TMI-2 laundry shipments to Tri-State Industrial

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Laundries, Inc., Utica, New York Threc shipments of liquid samples from TMI-l to Teledyne

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Isotopes, Westwood, New Jersey One shipment of THI-l solidified evaporator bottoms to U.S.

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Ecology, Richland, Washington One shipment of TMI-l solidified evaporator bottoms to Chem-

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Nuclear Systems, Inc., Barnwell, South Carolina Two shipments of samples and equipment from inside the TMI-2

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Reactor Building to EG&G Idaho, Inc., Idaho Falls, Idaho One shipment of EPIC 0R II liquid samples to the State of

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Maryland Laboratory and Research A6ninistration, Baltimore,.

Ma ryland One shipment of TMI-2 compacted and noncompacted LSA waste,

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to U.S. Ecology, Richland, Washington One shipment of six samples from inside the TMI-2 Reactor

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Building to Massachusetts Institute of Technology, Cambridge, Massachusetts 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.

Routine Health Physics _ and Environmental Review a.

Plant Tours The onsite NRC radiation specialists completed routine general plant inspections and tours.

These inspections included all control points and selected radiologically cantrolled 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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r-8-Adherence to radiation protection procedures

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Use of survey meters including personnel frisking techniques

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Cleanliness and housekeeping conditions

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Fire protection measures

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Measurement Verifications Measurements were independently obtained by the inspector to verify the quality of licensee performance in the following selected areas.

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Radioactive material shipping Radiological control, radiation and contamination surveys

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Onsite environmental air and water samples

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No items of noncompliance were identified.

c.

Status Report on TMI-2 Radiological Protection Program Evaluation (from the TMIPO weekly status report, dated October 9,1981)

" Radiological Protectio _n Program Evaluation.

In November 1979 the NRC appointed a special technical group to examine and determine the effectiveness of the TMI-2 Radiological Protection Program.

As a result of the special technical group (Blue Ribbon Panel) examination, several inadequacies were identified in the TMI-2 Radiolojical Protection Program.

The findings of the Blue Ribbon Panel were published in NUREG-0640 which recommended that certain improvements in the licensee's Radiological Protection Program should be implemented prior to commencing major recovery activities.

The TMI Program Office radiation specialist staff conducted several inspections and evaluations of the licensee's Radiological Protection Program during 1980-1981.

Based on these inspections and evaluations, the TMI Program Office concluded that the licensee has taken the necessary corrective actions to upgrade the Radiological Protection Program by implementing the recommendations of the NRC's Blue Ribbon Panel (NUREG-0640) to the extent that the program is now adequate to support major cleanup activities.

This conclusion is contingent upon the licensee continuing to emphasize commitments to program implementation and expanding the radiological control and training staffs as the pace of the cleanup accelerates.

An upgrading of the personnel dosimetry program is also required.

The onsite TMI Program Office Radiation Specialist staff will continue to examine progress on these items and will continually assess the licensee's performance relative to the Radiological Protection Program."

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Submerged Demineralizer System Onsite staff review of SDS operations continued in the specific areas addressed below, a.

Leak on Surface Suction Pumps Flush Connection (1) Background On October 4,1981, while transferring water from the RB sump to the SDS feed tank, a health physics (HP) technician i

became contaminated during a routine surface contamination

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survey at approximately 2:30 PM.

The HP technician had contamination on both hands and the side of the right

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s hoe.

The flush connection being surveyed was noted to have two drops of water on its threaded connection and the area directly beneath it was fuund to be contaminted.

The transfer of water from the RB was secured and the

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area around the flush connection surveyed.

No additional areas were found to be contaminated.

The HP technician's

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hands were slightly contaminated and were subsequently cleaned up.

The individual was whole body counted and indicated no uptake of contaminants.

The onsite NRC staff was notified of this occurrence at 3:10 PM.

The licensees response to the leak and to the contaminated individual were reviewed as noted below.

(2) Scope of Review.

The scope of the review was the following:

Review of the occurrence circumstance, description and

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sequence of events,

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Reportability of the event; and, Amount of radioactivity released, if applicable.

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(3) Review i

In addition to discussions with cognizant licensee representatives, selected portions of the following documents were reviewed.

Process Operations log for the period October 4-5, 1981,

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on October 5,1981 SDS Operators log for the period October 4-5, 1981,

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on October 5,1981 SDS Readings log for the period October 4-5, 1981,

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Health Physics log for the period October 4-5, 1981, on October 5,1981 Shift Foremans log for the period October 4-5, 1 981,

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on October 5,1981 Superintendents Event Report Number 81-229, dated

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October 4,1981

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Onergency Procedure 2202-8.1, Revision 1, June 22,1981,

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Leakage in the SDS Feed Filtration System Health Physics Procedure 4170, Revision 1, December 23, 1981,

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Decontamination of Personnel (4)

Findings No items of noncompliance were noted.

In the critique of this event, the licensee identified as a corrective action to evaluate generic problems of leaking flush connectors in the SDS.

There were no detectable releases to the environment.

The NRC will continue to routinely monitor licensee action as stated above.

b.

Reactor Coolant Bleed Tank Protection During NRC review of a procedural Temporary Change Notice (TCN),

it was noted that the reactor coolant bleed tank transfer pump low suction trip was jumpered out since October 25, 1980, making the trip ineffective.

The licensee verified that the reason the trip was jumpered was to allow one of the reactor coolant bleed tank transfer pumps to be operated after its associated trip sensor had failed and caused the pump to trip.

The trip sensor repair is still outstanding.

Jumping this trip appeared to be contrary to the intent of the licensee's response (TLL 381 from G. K. Hovey to B. H. Grier, dated August 22, 1980) to NRC Bulletin No. 80-05.

In this response the licensee stated that the low suction pressure signal was used to adequately protect the reactor coolant bleed tanks from buckling due to vacuum conditions developed during transfer of water out of the tank.

In view of the activity of the water stored in these tanks as a result of the TMI-2 accident and the needed storage capacity for this water at TMI-2, it is especially important for these tanks to be protected.

The licensee stated that use of the low suction pressure trip as a means for protecting the tank from buckling may not be correct with respect to the original design function of the subject trip, i.e., pump protection, not tank protectio _ - _ _ _ _ _ _ _ _ _ _ _ _

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-11-Since the licensee's response indicated seven tanks are in this category, the licensee stated that further review in this area is warranted and an additional response to Bulletin No. 80-05 may, also, be warranted.

The licensee also stated that adequate procedural controls exist to prevent an underpressure situation inside the tank.

This area is unresolved pending completion of licensee action as stated above and subsequent NRC review (320/81-17-03).

6.

Exit Interview On November 18, 1981, a meeting was held with licensee representatives (denoted in paragraph 1) to discuss the inspection scope and findings.

In addition to the reporting inspectors, other NRC personnel in attendance are noted below.

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R. Bellamy, Chief, Technical Support Section, NRC TMI Program Of fice A. Fasano, Chief, Three Mile Island Resident Section, Projects

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Branch No. 2 M. Shanbaky, Senior Radiation Specialist, Three Mile Island

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Resident Section l

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