IR 05000320/1982002
| ML20052D303 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/20/1982 |
| From: | Dan Collins, Conte R, Fasano A, Oneill, Oneill B, Thonus L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20052D281 | List: |
| References | |
| 50-320-82-02, 50-320-82-2, NUDOCS 8205060448 | |
| Download: ML20052D303 (32) | |
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U.S. NUCLEAR REGULATORY COMMISSION 50320-811228 50320-790328 50320-820104 50320-791205 Region I 50320-820108 50320-800126 50320-820110 50320-800131 50320-820111 50320-800707 50320-820118 50320-800717 50320-820120 50320-801112 50320-820201 50320-801127 50320-790219 50320-801226 50320-790217 50320-810119 50320-790218 50320-810805 Report No.
50-320/82-02 Docket No.
50-320 License No.
DPR-73 Priority Category C
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Licensee :
GPU Nuclear Corporation P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection at: Middletown, Pennsylvania Inspection conducted: February 16 - March 20,1982 Inspectors :
b fN R. Conte Senior Resident Inspector (TMI 2)
date signed hW hi E Ffo?J B. O' eill JRaation Specialist date 'si gned 7L-1No-L. Thonus, Resident Inspector (TMI-2)
date' signed Accompanied by: OmCollins, Radiation Specialist Approved by:
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,% x>, D
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A.~ Jasano, Chief, Three Mile Island Section 4fatvsigned Projects Branch No. 2
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Inspection Summary:
Inspection conducted on February 16 - March 20,1982 (Inspection Report Number 50-320/82-02)
Areas Inspected:
Routine safety inspection conducted by site inspectors of licensee action on previous inspection findings; routine plant operations; routine surveillance and maintenance; routine health physics and environmental areas; reactor building entries; radiological material shipments; licensee event reports; operator plant analysis; management plant analysis; quality assurance program; records management program; unusual event of February 19, 1982; and procedures implementation.
The inspection involved 270 inspector-hours.
Resul ts : No Violations were identified.
8205060448 820422 I
gDRADOCK 05000320 PDR
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DETAILS 1.
Persons Contacted General Public Utilities (GPU) Nuclear _ Corporation
- C, Adams, Quality Assurance (QA) Auditor B. Ballard, Manager TMI QA Modifications / Operations D. Carl Technical Analyst
- S. Chaplin, Licensing Engineer
- J. Chwastyk, Manager Plant Operations R. Fenti, Quality Control Manager J. Flanegan, Radiological Enginee_ ring Manager
- J. Fornicola, Operations QA Manager E. Gee, Supervisor Respiratory Protection
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- G. Giangi, Emergency Preparedness Manager
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- R. Hahn, Supervisor Waste Disposal R. Hanson, Reactor Building (RB) Entry Radiological Controls Technician j
W. Heysek, Supervisor Site QA Audit J. Hildebrand, Manager Radiological Controls
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- L. King, Plants Operations Director G. Kunder, Supervisor Technical Specification Compliance J. Larson, TMI-2 Licensing Manager J. Lawton, Lead Electrical Engineer H. McGovern, Shift Foreman P. Newkirk, Deputy Manager Radiological Field Operation B. Rittle, Lead Electrical Foreman
- R.
Rogan, Manager Emergency Prepardeness-TMI
- P. Ruhter, Manager Radiological Technical Support
- J. Schork, Site Supervisor Safety and Health A. Stowe, Project Coordinator Senior-Nuclear J. Weiser, Manager TMI Information Center Bechtel Corporation
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V. Gilbert, Assistant RB Entry Supervisor D. Machiela, RB Entry Coordinator T. Morris, RB Entry Supervisor Other licensee personnel were also interviewed.
- denotes those present at the exit interview.
2, Licensee Action on Previous Inspection Findings
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(Closed) Unresolved Item (320/78-10-03): Licensee to request extension on the implementation of Records Storage Requirement ( ANSI 45.2.9-1974).
The licensee has revised the Quality Assurance Plan in that record storage requirements are to be implemented by commitment to ANSI /ASME NQA-1-1979 (17S-1 and 17A-1).
This area is addressed in paragraph 13.
This particular item is no longer appl icabl e.
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-3-(Closed) Violation (320/79-10-11):
Failure to Close Block Valve
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for Power Operated Relief Valve (PORV) on the Pressurizer with Discharge Temperature Greater than 130 F.
Commitment for procedure upgrading is under NRC review (320/79-13-09).
Commitments for training improvements is also under NRC review (320/79-10-22).
Details of other specific licensee corrective actions and NRC verification / findings are in paragraphs 9 and 10.
(Cicsed) Violation (320/79-10-12):
Failure to Maintain High Pressure Injection Flow in Accordance with Emergency Procedures.
Speci fic corrective actions that remained to be verified are addressed in paragraph 11.
(Closed) Violation (320/79-10-14):
Licensee to evaluate changing Operating Procedure (0P) 2104-6.2 to allow operators to put the emergency diesel generators in the maintenance exercise control position to prevent spurious starts by multiple Engineered Safeguards Feature (ESF) signals.
The ESF electrical leads have been lifted obviating this corrective action.
The licensee placed this item in a separate file, pending a decision to operate TMI-2 when _ the item
would again become applicable to TMI-2.
Corrective actions in the training area for this item are being followed separately (320/79-10-22).
(0 pen) Violation (320/79-10-22): Failure to maintain retraining program for radiation protection and chemistry staff.
Commitments from other accident investigation findings including items addressed in this report, are grouped under this area.
This is to support a thorough training program review and to permit the closure of these other findings based on completion of corrective action that addresses respective major issues (paragraph 10).
The licensee committed to include steps in the training program to assure appropriate procedure revision / change / upgrading are initiated when inadequacies were observed by operating personnel and to improve operating organization analysis capabilities of off normal condition (320/79-10-11, Licensee response letter of December 5,1979, pages 37 and 39).
(Closed) Inspector Follow Item (320/79-10-26): NRC to Review Quality Assurance Department Improvements.
Details of licensee corrective action and NRC verification / findings are in paragraph 12.
(0 pen) Inspector Follow Item (320/79-13-09): Review of Facility Procedures.
Licensee commitments as a result of various accident investigation findings, including those addressed in this report in the area of procedure upgrading, are grouped under this item.
Paragraph 13.c.(1) addresses need for revision of records management control procedure Administrative Procedure (AP) 1007 and 1024
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-4-Specifically, the licensee committed to address Technical Assessment Comments of the Technical Staff Analysis Group (President's Commission Investigation, March 28, 1979, Accident) on Operating, Abnormal, Emergency Procedure (pp 14-17).
The licensee inicated that upgraded procedures and training would improve the operating crganizations ability to diagnose conditions.
(0 pen) Unresolved Items (320/81-23-02 and 03): Licensee to Review Auxiliary and Fuel Handling Buildings Filter Performance and Discrep-ancies Associated with Plant Effluent Monitors during the January 8,1982, Unusual Event.
A meeting was held onsite with licensee representa-tives on March 2,1982.
The licensee is still investigating the disparity between the stack monitors, HPR-219 and HPR-219A.
The licensee is tracing the piping for the monitors looking for a potential loop seal and is awaiting the results of samples sent off-site for Sr-90 analysis.
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Subsequent to the meeting, a Licensee Event Report (LER No. 82-ll/IP)
(prompt notification) dated March 4,1982, was submitted with respect to potential filter bypassing during the January 8,1982, event.
The 30-day report was due April 5,1982 NRC review of this event continues.
(Closed) Unresolved Item (320/82-01-03): NRC to Review the Licensee's Records Management Program.
Details of this review are addressed in paragraph 13.
3.
Routine Plant ___0perations Inspections of the facility, which included specific and more frequent reviews in the control room, were conducted to assess compliance with general operating requirements of Technical Speci-fication 6.8.1 in the following areas: licensee review of selected plant parameters for abnormal trends; plant status from' a maintenance /
modi'ication viewpoint including plant cleanliness; licensee control of or, oing and special evolutions including control room personnel awareness of these evolutions; control of documents including logkeeping practices; and, area radiological controls.
Random inspections of the control room during regular and back shift hours were conducted at least three times per week.
Selected sections of the shift foreman's log and control room operator's log were reviewed for the period February 16 - March 19,1982 Sel ected sections of other control room daily logs were reviewed for the period from midnight to the time of review.
Inspections of areas outside the control room occurred on March 3,18, and 20,1982 Selected licensee planning meetings were also observed.
Review of a special evolution and unusual event occurred; details are described in paragraphs 14 and 15.
No violations were identifie.
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_ Routine Surveil _ lance _ and Maintenance Licensee implementation of Surveillance Procedure (SP) 4303-M28A/B, Revision 2 July 31,1981, NSRW [ Nuclear Service River Water]
Operability Test and Valve Operability Test, which test NSRW pumps, and associated valves, was observed on March 20, 1982.
The procedure was reviewed and approved as required by Technical Specification (TS) 6.8.1.c.
The inspector observed the testing of NR-P-1B, one of the three currently installed pumps, its associated valves and i
instrumentation, and the restoration to normal service of this
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equipment.
The test instrument used to obtain vibration readings had a current calibration sticker.
No limiting conditions for operation were exceeded.
Completed work packages for four tasks performed on the emergency
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diesel generators (EDG) were reviewed in conjunction with the
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review of Licensee Event Reports (paragraph 8) on this system.
The job ticket numbers for these tasks were 3332, 3862, 5244, and 5982.
The inspector reviewed the job tickets and routing control forms associated with the tasks.
Quality control (QC) accepted parts were used for the tasks, in one instance the part was not a
" replacement in kind" and an engineering evaluation was performed to substitute an equivalent part.
The engineering evaluation and equivalent part were QC accepted.
The inspector traced the part numbers through the licensee's warehouse system as additional verification that the proper parts had been used.
The tasks were performed using procedure 1420-Y-12 " Troubleshoot and Repair of Control or Indication Circuits."
One of the tasks had been selected by the licensee for QC monitoring;
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hold points were established; and QC witnessing, indicated by signature, was noted.
The EDG's were tested with satisfactory results after each task was compl eted.
No violations were identified.
Routine Health Physics and Environmental Review a.
Plant Tours
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The site radiation specialists completed routine plant inspection tours. 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 Radiation Work Permit (RWP) requirements
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Proper use of respiratory protection equipment
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-6-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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I b.
Measurement Verification Measurements were independently made by the inspector to verify the quality of licensee performance in the following selected areas:
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Radioactive material shipping
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Radiological control, radiation and contamination surveys
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Onsite environmental air and water sampling and analyses
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During the period March 15, 1982 to March 19, 1982, environmental samples were obtained from the following locations.
Offsite soil and liquid samples (airport and upstream
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river)
Liquid samples from the TMI-2 Air Intake Tunnel and
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Borated Water Storage Tank (BWST) pipe chase Soil samples in vicinity of the' Borated Water Storage
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Tank (BWST)
Soil samples in vicinity of Processed Water Storage Tank
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(PWST)
These samples will be analyzed at the Radiological and Environ-mental Sciences Laboratory in Idaho.
c.
Findings On March 8,1982, a gate to a high radiation area, Intermediate
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Closed Cooling area, 305' elevation of the auxiliary building, was discovered unlocked and unguarded by a TMI-2 Radiological Control Technician.
Corrective action was immediately initiated.
. A Radiological Investigative Report (RIR No.82-023, dated March 9, 1982) was issued.
The inspector reviewed licensee actions and corrective measures regarding this identified violation of Radiological Control Procedure (RCP) 4161, Control of High Radiation Areas Revision.1, dated March 3,1981, Section 6.21.
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-7-The licensee conducted an investigation as required by the RIR procedure.
Corrective actions included: reinstruction of all
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Radiological Control Technicians on RCP 4161; a Temporary Change Notice (TCN) to Procedure 4161 was implemented to improve high radiation area key control.
Although this item was identified by the licensee and measures were initiated to prevent recurrence, this item remains unresolved pending NRC completion of a review to assess the effectiveness of licensee corrective actions (320/82-02-01).
Reactor Building Entries a.
The site staff monitored reactor building (RB) entries conducted during the inspection period to verify the following on a sampling basis:
The RB entry was properly planned and coordinated for
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effective task implementation including adequate as low as is 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 RWP.
Specific procedures were developed for unique tasks and
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properly implemented, b.
The site staff attended RB entry status meetings; reviewed selected documents, applicable procedures, and RWP's concerning these entries.
Entries 34 through 52 were conducted during this inspection period.
A synopsis of the entry tasks follows.
Entry 34 (February 16, 1982) - Preparations for decon-
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tamination experiment (gamma spectrometry 347' elevation, radiation survey, and fire hose installation)
Entry 35 (February 19,1982 (two entries)) - Unusual
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Event (Portable instruments indicated deficient 02 and presence of combustible gases.
A radiological control technician had a problem with R0-2A (meter reading off scale) and was in constant radio communication with command center (details, paragraph 15).
Entry 36 (February 20, 1982, 12:30 AM) - Investigation of
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reactor building air quality (radio frequency problem noted) (details, paragraph 15).
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Entry 37 (February 20, 1982, 6:45 PM) - Investigation of
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reactor building air quality and radio frequency problem l
(details, paragraph 15).
Entry 38 (February 24,1982)- Verification of reactor
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l building air quality prior to resumption of decontamination equipment activities (details, paragraph 15).
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Entries 39 and 40 (February 25, 1982 and February 26, 1982) -
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Installation of systems to support gross decontamination
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l experiment.
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Entries 41 through 44 (March 2-5,1982) - Gross Decon-
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tamination Experiment Begins (low pressure flush of
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l 305' elevation and polar crane).
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l Entries 45 through 48 (March 8-12,1982) - Gross Decon-
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tamination Experiment: low pressure flush of the polar crane; low pressure flush of the refueling pool; and, low and high pressure flush of the 347' elevation surfaces.
Entries 49 through 51 (March 15-18,1982) - Gross Decon-
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tamination Experiment: high pressure flush of the 347'
and 305' elevation surfaces; mechanical Floor Scrubber Test Staging at the 347' elevation; and, commencement of post test data gathering acquisition.
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Entry 52 (March 19,1982) - Problem with personnel hatch door interlock mechanism (Entry terminated and interlock repaired).
Once preparations were completed, the gross decontamination experiment was accomplished at accelerated pace, as can be inferred from the number of reactor building entries accomplished during this period.
Approximately 10,000 gallons of processed water were added to the reactor building sump during the fl ushing.
Preliminary area radiation surveys following the flushes on the 305' elevation and the 347' elevation indicate an apparent decrease in radiation levels. By the close of the inspection period, it was difficult to quantify the magnitude of the decrease due to significant variations in the radiation levels in various areas of the reactor building, apparent variations in the effectiveness of the decontamination, and the preliminary status of the data.
This area will be routinely reviewed by NR _ _ __
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-9-c.
The following problems / deficiencies were noted during reactor building entries 34 through 52.
(1)
During the second entry conducted on February 19, 1982 (Entry 35), an individual failed to use a Self-Contained Breathing Apparatus (SCBA) in the pressure-demand mode, as required by Radiation Control Procedure (RCP) 4052.
This problem was identified by the individual involved during the reactor building debriefing conducted on February 20, 1982.
The incident was reviewed by a site NRC radiation specialist with the Supervisor Respiratory Protection (TMI), on February 23, 1982.
The licensee acknowledged that this item was a violation of RCP 4052, which requires that SCBA be operated in the pressure-demand mode to provide for the equipment design protection factor.
The Supervisor Respiratory Protection outlined a new comprehensive training and SCBA qualification program for all individuals expected to use such equipment.
This training program was scheduled to be in effect by April 1,1982.
(2)
During reactor building entry No. 38 on February 4,1982, an individual entered the reactor building without the Reactor Building Command Center being manned.
Since the individual had signed onto a Radiation Work Permit (RWP),
licensee representatives stated that no radiological control procedures were violated.
The unauthorized entry of the individual was identified by the Entry Coordinator (a contractor individual) on February 24, 1982, and was subsequently documented in a letter to the Recovery Programs Operations and Construction Director, GPU Nuclear Corporation, dated February 26, 1982, which addressed appropriate corrective actions.
Although items (1) and (2) above were identified by the licensee and corrective measures were initiated, the items
remain unresolved pending NRC review and assessment of the
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effectiveness of the corrective action taken (320/82-02-02).
d.
In accordance with NRC's previous letter (in reference to NRC Region I Inspection Report 'No. 50-320/82-01), results of NRC independent measurements and sample analyses, associated with reactor building entry No. 33 and conducted by the regional based office laboratory, are included in Attachment 1 to this
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repo rt.
The basic purpose of these independent measurements is to verify licensee capability for analyzing radioactive samples, and to achieve and maintain comparable methods of analyses between the licensee's facility and the NRC'. _ _ _.
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Radioactive Material Shipments a.
The site radiation specialists inspected all radioactive material shipments during the inspection period to verify the items listed below:
Licensee had complied with approved packaging and shipping
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procedures.
Licensee had prepared shipping papers, which certified
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that the radioactive materials were properly classified, described, packaged, and marked for transport.
Licensee had applied warning labels to all packages and
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placarded vehicles.
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Licensee controlled the radioactive contamination and
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dose rates below the regulatory limits.
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Inspector review in this area consisted of: examination of shipping papers, procedures, packages, and vehicles; and performance of radiation and contamination surveys for each shipment.
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During this period,16 radioactive material shipments were made by the licensee.
8.
Licensee Event Reports
a.
The inspector reviewed Licensee Event Reports (LER's) required to be submitted in accordance with Technical Specification (TS) 6.9.1.8 and.9 (and NUREG-0161) to verify the following:
Event and cause description clearly reported event information; the required LER form was properly completed; and adequate corrective action was speci fied.
Initial screening of these events was completed to determine generic applicability, need for additional site verification, and the necessity for additional NRC management review.
The below listed LER's were reviewed.
LER 81-38/0ll-0, dated December 28, 1981, Wind direction
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and speed instrument inoperable due to icing LER 82-01/03L-0, dated January 4,-1982,
"B" Auxiliary
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Building Supply Fan ( AH-E-7B) tripped due to overload relay trip LER 82-03/03L-0, dated January 11, 1982, Nuclear Services.
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River Water (NSRW) Pump NR-P-1B failed to start due to loose fuse clip
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-11-LER 82-04/03L-0, dated January 10, 1982, Auxiliary
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Building ventilation exhaust flow exceeded TS 3.9.12 limit LER 82-05/03L-0, dated January 18, 1982, Long Term "B"
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pump, LTB-P-1, failed to start due to stuck limit switch in pump motor breaker LER 82-07/03L-0, dated January 20, 1982, Auxiliary
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Building ventilation exhaust flow below TS 3.9.12 limit LER 82-09/03L-0, dated February 1,1982, Auxiliary
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Building ventilation exhaust flow below TS 3.9.12 limit b.
LER's were reviewed, in plant, to verify the following:
specified corrective actions including generic implications were completed, or scheduled and assigned to cognizant licensee personnel; the event did not involve an unreviewed safety question or continued operation in violation of regulatory requirements or license conditions; and, report satisfied TS reporting requirements.
The below listed LER's were reviewed.
LER 79-11/03L, Diesel Generator Trip.
On February 17
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and 19,1979, Emergency Diesel Generator (EDG) DF-X-1B tripped shortly after starting.
The licensee's initial investigation failed to identify a definite cause.
Suspected loose wiring connections to the governor
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actuator were tightened.
This malfunction has not recurred in the intervening 36 months.
The licensee took action to add checking and tightening these connections to the EDG annual maintenance program.
The inspector performed a inspection of the EDG's, no loose wires were observed on the governor.
LER 79-21/03L, Dietei Generator Trip.
On December 5,1979,
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EDG DF-X-1B tripped apparently due to low lube oil level.
The licensee restored the lube oil level and satisfactorily tested the diesel.
Procedure OP 2104-6.2 was revised to
require checking oil level prior to manually starting the diesel and once for every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of ' continuous operation.
LER 80-001/99X, Circuit breaker for diesel generator
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auxiliaries tripped.
On January '26,1980, a 60 amp circuit for EDG DF-X-1B was found tripped.
Licensee test results indicated a defective internal connection.
The breaker was replaced.
The licensee returned the defective part to the manufacturer to evaluate possible generic corrective
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action.
The inspector reviewed the licensee's engineering evaluation.
No generic problems were identifled.
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-12-LER 80-003/99X, Diesel Generator Trip.
On January 31, 1980,
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EDG DF-X-1B started and tripped within 15 seconds.
A pneumatic timer on a delay relay timed out in 7 seconds instead of 20 seconds.
This did not allow enough time for lube oil pressure to exceed the low pressure trip on startup.
The timing unit was replaced.
The licensee returned the timing unit to the manufacturer to determine if a generic problem existed.
Further NRC inspection followup is addressed under LER 80-33 below.
LER 80-028/03L, Diesel Generator Trip.
On July 7, 1980,
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EDG DF-X-1B tripped due to high crankcase pressure.
A hose connecting the upper and lower ejector pipes vibrated off the upper pipe due to a loose hose clamp, causing a loss of vacuum.
The piping connects an eductor (the source of the vacuum) to the crankcase.
The licensee reconnected the hose and tightened the clamp.
The inspector reviewed section 6.2.2.24.2 of SP 2305-R3 which was revised to require that clamps be checked for tightness.
The inspector obscrved that the hose was connected and that the clamps were tight.
LER 80-033/0ll, Manufacturers Report on Diesel Generator
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Tri p.
On July 17, 1980, when a control room operator attempted to shutdown EDG DF-X-1B from the control room, the EDG did not shutdown.
The problem was determined to be due to a failed pneumatic timer for the relay in the diesel shutdown circuit.
The timer exhibited short cycling and could not be recalibrated to give repeated in-speci fication timing.
This relay is of the same type discussed in LER 80-003 above.
The licensee received a report from the manufacturer on July 29,1980, which verified erratic timing and recommended a different type of timer for EDG type application.
The licensee's evaluation concurred that environmental conditions of the EDG could contribute to the unreliability of the pneumatic timers and recommended that they be replaced with electronic timing units.
The licensee is following the implementation of the timer replacement via Plant Operations Review Committ e (PORC) action item (PAI) 2-81-008.
LER 80-054/03L, Diesel Generator Failed to Start on
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November 12, 1980 The jacket coolant heater for EDG DF-X-1B failed.
The heaters purpose is to maintain the diesel's ambient temperature at a level sufficient to enable proper starting of the diesel.
As a result of the heater inoperability, an alternate method of maintaining the diesels' ambient temperature was initiated which included increasing the EDG room's ambient temperature and by ocassionally running the diesel.
On November 17, 1980, the EDG failed to start at 4:15 AM, on the third attempt at 4:30 AM the EDG was successfully started.
This is further discussed under LER 80-055/03L belo.
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-13-LER 80-055/03L, Diesel Generator Failed to Start.
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November 27, 1980, EDG DF-X-1B failed to start, it was successfully started on the fifth attempt.
The licensee's initial investigation determined that the cause was low ambient coolant temperature due to a failed jacket coolant heater.
A subsequent licensee investigation determined that an internal mounting screw on a contactor vibrated loose jamming the internal mechanism.
The licensee's evaluation recommended that a tightness check of all diesel electrical contractor screws be added to the annual maintenance procedure and that "Locktite" be applied to the screws.
The inspector verified that Surveillance Procedure (SP) 2304-R3 had been revised to check tightness of terminal screws on the contactor panel and reviewed the licensee's documentation that "Locktite" had been applied to the screws.
LER 80-059/03L, Diesel Generator Trip.
On December 26, 1980,
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EDG DF-X-1 A started and tripped after apprcximately 9 seconds.
The cause was determined to be a coil failure in the time delay relay.
This is part of the pneumatic time delay / relay system in LER's80-003 and 80-033 and the licensee is tracking them as a group.
The inspector reviewed the work package which replaced the relay and coil.
LER 81-02/0ll, Diesel Generator Inoperable.
On January 19, 1981,
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EDG DF-X-1B was inoperable from 9:00 AM to 5:30 PM due to a lack of a cooling water source.
At 9:00 AM the "B" Nuclear Service River Water (NSRW) header was removed from service.
The "B" NRSW header normally supplies cooling water to EDG "B" cooling water jacket.
The switching order which removed NRSW "B" header from service also instructed the garator to open NR-V-31B, a cross connect valve, to allow EDG "B" to be cooled by NRSW "A" header.
The operator failed to properly complete the switching order.
The operator was suspended for 10 days and counselled on the importance of properly completing switching orders.
The inspector reviewed the current status of the EDG's, NRSW headers and cross connect valve positions to verify proper lineup.
LER 81-17/Oll, Diesel Generator Unavailable.
On August 5,1981,
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while EDG DF-X-1 A was removed from service for maintenance EDG DF-X-1B was tested as required by Technical Specification ( TS ) 3.8.1.1.
At the end of the test, EDG EF-X-1B was left in the maintenance exercise mode rather than the emergency standby as required by Operating Procedure (0P) 2104-6.2.
The control room operator was counselled in the need for procedure adherence and the procedure was -
revised to clarify the requ'.rement for the emergency standby mod.
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-14-The inspector reviewed the revised OP 2104-6.2; it contains a separate signoff step for returning the mode switch to emergency standby and a step to check for panel alarm lights.
The mode switch not in emergency standby generates a panel alarm light.
c.
The inspector also reviewed the licensees administrative control and tracking system for LER's79-012, 80-002,80-003, 81-004, and 81-006.
The inspector determined that 1979 LER's were not currently being tracked and that 1980 and,1981 LER's
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were not being updated in a timely manner, i.e., revisions when engineering evaluations of cause were completed.
Licensee representatives stated that the 1979 LER's would be reviewed to determi'ne if there were any untracked open items and that 1980 and 1981 LER's would be updated as required.
This is unresolved pending completion of action as stated by the licensee and subsequent NRC review (320/82-02-03).
9.
NUREG 0600 - Investigation into the March 28, 1979, Three Mile Island Accident by Office of Inspection and Enforcement (IET--
During the period March 28 - July 31,1979, IE conducted Investi-gation No. 50-320/79-10, into the March 28, 1979, TMI-2 Accident, and documented the results of that investigation in NUREG 0600, dated August 1979.
In a letter dated October 29,1979, from V. Stello, IE, to R. Arnold, General Public Utilities, the apparent violations of NRC regulations were identified in Appendix A of the letter, and a Notice of Proposed Imposition of Civil Penalty was issued in Appendix B of that letter.
Based on the licensee's response dated December 5,1979, certain fines were remitted or reduced; however, since the cumulative civil penalty amount was still greater than the calculated statutory limit, the limit of
$155,000 was imposed.
Subsequent discussions of commitments and corrective actions from initial licensee response for all cited items were documented in licensee letters dated February ll, May 19, July 10, December 23, 1980, and January 9,1981; and NRC letters dated January 23, August 27, September 10, and November 21, 1980 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.
During this inspection period NRC verification of completion of the composite licensee commitment / corrective actions for each of the 26 areas continued.
Disposition for the items reviewed during this period are addressed in paragraphs 2 and 10 through 13.
Of the 26 items,19 were closed in previous inspection reports and in this report with 8 items that are still open in the following functional areas: Training (2); Radiological Controls (2); and Emergency Planning (4).
These areas will be reviewed in subsequent inspections,
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.
.
-15-10. Operator Plant Analysis a.
Background
'
Violation No. 4. A (320/79-10-11) was the failure to close the block (isolation) valve for the Power Operated Relief Valve (PORV) when valve discharge temperature was greater than 130 F.
The major issues discussed in licensee and NRC correspondence were the role and meaning of " symptoms" of problems along with corrective actions, by the operator and operator initiation of action to update procedures for long duration plant condition changes. Also discussed was positive valve position indication for the PORV.
Presently the PORV block valve is shut since the date of the accident and the physical condition of the PORV is unknown due to its inaccessibility in the reactor building.
b.
Review l
Selected sections of the following documents were reviewed.
Administrative Procedure (AP) 1029, Revision 1, March 10,1982,
--
Conduct of Operations AP 1033, Revision 2, February 12, 1981, Operating Memos
--
and Standing Orders AP 1060, Revision 0, March 23,1981, Procedure Usage and
--
Implementation c.
Findings (1)
Licensee commitments in the area of training program improvements (320/79-10-22) and procedure upgrading (320/79-13-09) are being reviewed by NRC separately.
Positive valve position indication modification commitment for the PORV is not applicable to TMI-2 in its present plant condition.
The positive valve position indication
,
issue for TMI-2 as a' power operating plant will be reviewed by NRC with respect to TMI lessons learned pending licensee decision and subsequent NRC approval (if so decided) to operate TMI-2.
Based on selected NRC reviews of recovery system design and installation, positive ~ valve positioi indications are being used by the licensee.
The inspector had no further
comments in this area.
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_.
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-16-(2) The licensee's policy with respect to the major issues addressed above are embodied in AP's 1029,1033, and 1060.
In summary, this policy does reflect commitments made by the licensee to NRC., Operators are directed to
>
pursue symptoms of any plant problem to a satisfactory resolution, that is, emergency, abnormal, or alarm procedure response or initiation of corrective actions such as procedure upgrading or corrective maintenance. Verbatim compliance with procedures is mandated. Stop work is to be initiated if procedures can not be properly implemented.
The inspector had no further comments in this area.
,
.
Based on the above review, this area (320/79-10-11) is closed.
11. Management Pla'nt Analysis a.
Backgroun_d Violation No. 4.B.1 (320/79-10-12) of the accident. investigation was the failure to maintain high pressure injection (HPI) flow during the emergency contrary to plant procedures.
One of the
'
major issues discussed in licensee and NRC correspondence was the failure of operator and emergency response management to consider and believe all indications / symptoms of plant problems, e.g., pressurizer level increased due to HPI flow versus saturatier conditions.
Along with this issue was routine plant operations not in compliance with facility procedures.
Licensee corrective actions on the role and use of symptoms of plant problems and procedure upgrading was reviewed in the i
previous section (paragraph 10).
Another major issue discussed was the use of diverse management tools consisting of internal and external examination of
operations, independent safety reviews, and an expanded quality
,
assurance review.
b.
Review Selected sections of the following documents were reviewed.
Metropolitan Edison Company (Met-Ed) Memorandum No. LM-2-81-0411,
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J. Larson to J. Barton, TMI-2 Performance of Review and Evaluation, dated December 21, 1981 Met-Ed Memorandum No. LM-2-81-0322, J. Larson to J. Barton,
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TMI-2 Safety Reviews, dated November 18, 1981 General Office Review Board (G0RB) Responsibility, Authority
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Organization and Resources, dated April 1981 Charter. for the Safety Advisory Board, Three Mile Island
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Unit 2 Program, dated April 21,1981
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-17-The inspector attended a Technology Assessment and Advisory Group (TAAG) meeting on March 18, 1981.
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c.
Findings _
(1) Licensee commitments in the area of training program improvements (320/79-10-22) and procedure upgrading (320/79-13-09) are being reviewed by NRC separately.
Expansion and improvements in quality assurance reviews are addressed in paragraph 12 (320/79-10-26).
Organization changes were previously reviewed by NRC (320/79-10-21).
(2) The Plant Operation Review Committee (PORC) and Generation Review Committee (GRC) are functional as required by Technical Specifications (Section 6).
To address the unique situation at TMI-2 and in addition to regulatory requirements,the licensee established a Risk Assessment Task Force (RATF) and Safety Advirory Board (SAB).
The purpose of the RATF is to review present plant conditions using a fault tree analysis methodology to identify unsafe or overlooked conditions / plant problems that warrant corrective actions.
An initial report of this group is under licensee review.
The purpose of SAB is to provide a high level broad appraisal of technical aspects of TMI-2 cleanup, waste disposal, decommissioning or recovery through the review of plans and technical basis with a goal to protect public health and safety.
The SAB membership is composed of industrial expert personnel from outside the licensee's organization.
Further, the licensee continues to use the General Office Review Board (60RB), mostly GPU personnel outside of the TMI-2 Division and including outside GPU personnel.
The purpose of GORB is to independently consider potentially significant nuclear and radiation safety matters including related management aspects.
The GORS is responsible to the Office of the President, GPUNC.
In addition, the licensee will use the efforts of the Technology Assessment and Advisory Group (TAAG) which is composed of members outside GPUNC and is responsible to NRC, Department of Energy and GPUNC.
The purpose of TAAG is to analyze, review and evaluate alternatives to assure safety and public health is adequately protected during decontamination and defueling.
Based on NRC's initial meeting with this group during the inspection period, it appears TAAG will be useful in accomplishing its purpose.
With respect to improving operator guidelines for power operations (more applicable to TMI-1) the licensee is
)
participating in an industry program on Anticipated Transient Operator Guidelines (AT0G).
Based on the above review, this area (320/79-10-12) is closed.
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_ _ ______________
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.
-18-12. Quality Assurance Program
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a.
Background An apparent violation No. 11 (320/79-10-26) from the accident investigation, was cited and later withdrawn by the NRC with t
respect to the apparent failure to conduct surveillance inspections of plant operation.
The licensee provided additional information to the NRC that substantiated appropriate quality assurance surveillance review. However, the licensee committed to an expanded and improved quality assurance program.
This review was to verify that commitment.
Other findings (320/79-10-18 and 320/79-10-12) resulted in similar licensee commitments that were verified by this review.
b.
Review Selected sections of the following documents were reviewed.
Quality Assurance Audit Schedule, TMI Nuclear Station for
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1982-83 TMI Generation Audit Listing 1981, 1980, 1979
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Met-Ed Audit List 1979, 1978
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Audit No. 78-03, dated April 25,1979 (GQM-1694) Security Program GPUN Audit Report No. S-TMI-81-07, dated October 28, 1981
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(6163-81-5295) Security Program Audit No. 78-15, dated July 14,1978 (GEM 2934) Special
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Nuclear Material (SNM)
GPUN Audit Report No. S-TMI-81-21, dated January 13, 1982
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(6161-82-0002), Audit of TMI-l and 2 Special Nuclear Material Control Audit No. 78-11, dated August 14, 1978, Station Maintenance -
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Including Modifications (Nuclear) (GCM 3546)
GPUN Audit Report No. S-TMI-81-ll, dated October 29, 1981,
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THI-2 Plant Maintenance, (6163-81-5299)
Inter-Of fice Memorandum, dated February 17,1982 (not
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serialized) from J. Fornicola to 0QA Monitoring Staff, 0QA Monitoring Plant Quality Checklist for Document Review Notebook,
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QAM/0-0, dated July 16, 1980, Revision 0 l
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GPU Quality Assurance [ Department Manual] Procedures
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Quality Assurance (QA) Procedure 7-2-06, Revision 0,
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July 1980, QA Department Annual Program Assessment QA 6100- ADM-1218.01 (7-5-01 ), Revision 5, August 14, 1981,
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Preparation and Control of QA Plans, Procedures, Standards and Forms QA 7-18-01, Revision 7, November 1981, Quality Assurance
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Audits Quality Assurance Section Procedures Manual
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QA 7-1-M0-001, Revision 1, May 26,1981, QA Mod /0ps Section Procedure Organization and Responsibilities QA 7-1-M0-002, Revision 1, November 10, 1980, Operations
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Quality Assurance Organization and Responsibilities QA 7-2-M0-001, Revision 1, July 1,1981, Vice-President's/
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Director's Repor t QA 7-2-M0-002, Revision 2, June 24,1981, Quality Assurance
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Audit / Monitor / Inspection System (QAMIS) Data Acquisition Procedure
,
QA 7-18-M0- A-001, Revision 0, November 1980, QA Audit
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Plan Surveillance Report Index 1978, 1979, 1980
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Quality Assurance Monitor Report Index 1981-82
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QA Inspection Report Status (M00-M-40) 1979-80
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Inspection Report Status (I&C) 1979
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Inspection Report Status (Electrical) 1979
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Inspection Report Status (Welding) 1979
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Inspection Report Status (Structural) 1979
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Piant Inspection Report Logs 1980, 1981
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Q(, Surveillance Report (QCSR). No. 80-67, on June 24, 1980,
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Storage of Documents at Met-Ed Office in Reading QCSR No. 80-06, on May 12-14, 1980, Compliance of New
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Records Storage Vault to Committed Requirements QCSR No.80-199, on August 14, 1980, Duty Tour
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-20-I QCSR No.80-211, on August 12-13, 1980, Document Storage
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Crawford Station Quality Assurance Modifications / Operations Monitoring
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Report No. DPL-0175-81 on February 5,1981, Records Retention Interviews with selected Quality Assurance (QA) Deparment personnel were also conducted.
c.
Findings i
Between August 17 and September 2,1981, NRC review of the licensee's QC department for TMI-1 was conducted. Major areas
,
I reviewed are documented in NRC Region I Inspection Report No. 50-289/81-22.
The following functional areas addressed in that report are common to TMI-l and THI-2: QA Organization /
Administration; QA Personnel Qualifications; QA/ Maintenance Interface (Level I, II, III Inspection); QA Effectiveness Reports; and Records Storage.
The acceptable disposition of these areas for IMI-l are considered applicable and acceptable for TMI-2.
Additional and specific findings to support the review in this area for TMI-2 are addressed below.
Separate QA Plans for TMI-l and TMI-2 were established and subsequently approved by NRC to address the unique aspects of each unit.
For TMI-2 the Recovery Quality Assurance Plan was approved by NRC on March 20, 1980.
Prior to the accident, the site QA organization reported to a corporate position and it was primarily composed of quality control inspection personnel in the basic engineering areas such as Civil / Structural, Welding, liechanical, or Electrical work.
Surveillance inspections and audit participation were also conducted by these personnel.
Since the accident, new QA sections were formed: Operations QA Monitoring (0QA), QA Engineering (site representatives), QA System Engineering (QASE) and an Audit Section.
Surveillance or monitoring is now conducted by the 0QA group.
The audit section on site conducts audits on a 2 year schedule and they report offsite within the QA Department, which overall remains a corporate based (independent) organization, The QASE group is reviewing / evaluating methodologies (processes / systems) on how QA department personnel perform their functions.
Section procedures were formalized for these sections in addition to QA department procedures.
Preaccident and post-accident audit reports in the areas of security, special nuclear material, and maintenance were reviewed; and overall improvements in quality were noted.
Specifically the licensee QA auditors (level III inspectors)
are now concentrating on program compliance with Standards, regulations, etc., in addition to program implementation complianc.
.
-21-The 0QA group (level II inspectors) is directly verifying program implementation compliance for TMI-l and TMI-2.
Sel f-evaluation within the 0QA group lead to department management questioning why NRC findings in certain areas were different than or' apparently missed by QA monitors.
The introduction of team inspection concept for monitors (in distinction to auditors) is an attempt to give a broader review of program /
procedure implementation, similar to NRC review, to identify problem areas and take corrective actions independent of NRC.
Based on a review of selected audit report indices, monitor reports / indices, plant inspection report indices it is apparent that appropriate levels of QA staff-hours are being given to both TMI-l and, TMI-2 without neglecting one for the other.
Based on the above review, this area (320/79-10-26) is closed.
13.
Information Records Management Program a.
Background Violation No. 4.G (320/79-10-18) of the accident investigation was the failure to timely retrieve maintenance and testing records associated with Emergency Feedwater Valves.
Details of the close-out review of this item were documented in NRC Inspection Report No. 50-320/82-01.
However, since that inspection report period did not afford the opportunity to conduct a detailed review of the licensee's records management program, co"mitments in this area were left unresolved (320/82-01-03)
pending further NRC review. ~ NRC's review was completed during this inspection period.
Review of this area also supports closure of a previous finding (320/78-10-03) in reference to compliance with records storage requirements of ANSI 45.2.9-1974.
b.
Review Selected sections of the following documents were reviewed.
Licensee Inter-0ffice Memorandum No. 7132-82-024, dated
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January 15,1981, " Revision 5, Administrative Procedure 1007 and Revision 2, Administrative Procedure 1024" Unit No.1 Administrative Procedure ( AP) 1007, Revision 5,
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January 8,1982, Identification of THI-1 Records Unit No.1 AP 1024, Revision 2, December 23, 1981,
--
Receipt Storage Retrieval and Disposition of TMI No.1 Records GPUN Audit Report No. S-TMI-81-06 (6163-81-5231) dated
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July 27,1981, Audit of Site Radioactive Materials Packaging and Shipping i
.
.
-22-Audit No. 79-07, Quality Assurance Records (Nuclear),
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September 25,1979 (GQfi 3163)
Unit No. 2 AP 1007, Revision 4, July 14,1978, Control of
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Tlil Records Unit No. 2 AP 1024, Revision 1, December 16, 1977, Control
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of Tlil QC Records Tlil-2 Recovery Quality Assurance Plan, Section 3.3 and
--
Appendix C Information Management Department (IliD) Instructions
--
Manual as of March 17,1982 (Various dated department procedures)
ANSI /ASME NQA-1-1979, Quality Program Requirements for
--
Nuclear Power Plants (Supplement 17S-1 and Appendix 17A-1)
Interviews were conducted with selected QA and Records Manage-ment Personnel.
Observations were made in and around the records vault in the TMI-2 Administration Building.
The new computer retrieval system (CARIRS) was used by the inspector to obtain selected records.
c.
Findings (1 )
Records Storage personnel were reorganized into a new department, Information Management Department, which not only is responsible for records storage; but, also is responsible for drawing and document control including reprographics and micrographics.
In numbers, personnel dealing primarily with records storage went from one licensee individual with six to eight contractors prior to the accident, to apprnximately twenty to twenty-five individuals employed by the licensee presently.
Detailed department instructions were established except in the area of drawing and document control which is being reviewed separately by NRC and the licensee's QA department.
TMI-2 did not, as yet, issue a revised (updated) AP 1007 and 1024 for records control.
Further it appears that certain individual departments have records storage responsibilities, i.e., maintenance, plant engineering without department procedures to control records until they reach the Information Management Department.
It is intended that these procedures be developed.
This area of procedure upgrading and development is being reviewed separately (320/79-13-09) by NRC and the licensee's QA department ( Audit No. 79-09).
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_ _ _ _
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-23-A new computer retrieval system (CARIRS - Computer Assisted Records and Information Retrieval System) was initiated for correspondence QA department records, procedures and drawings.
This program is continuing to be expanded to
"
other department records.
Based on the above review, this area (320/82-01-03) is closed.
(2)
During the review of the records vault area, the inspector noted that the NQA-1 standard being implemented by the licensee for records storage requirements was not clear on what vault penetrations were permitted.
The Recovery QA Plans commits to ANSI /ASME NQA-1-1979, Supplement 17S-1 and Appendix 17A-1.
One requirement for single facility
,
storage is no pipes other than those providing fire protection are to be located within the facility; but in the same list forced air circulation (with filter) system is required (for humidity and temperature control).
The vault area (two levels) was built with no penetrations using an internally supplied fire protection system.
Lighting is provided by an electrical cable that is manually plugged into a receptacle outside the vault thereby necessitating that vault door to be kept open during working hours.
The licensee's safety department and an NRC inspector on a TMI-l inspection (NRC Inspection No. 50-289/81-22) questioned this condition from a personnel safety viewpoint and fire protection effectiveness viewpoint, in light of the need for personnel te manually close the vault door in case of fire and/or actuation of the fire protection (cardox) system.
The inspector identified that 1980 and 1981 addendum to NQA-1 clarify this situation in that penetrations for fire protection systems, communications, lighting, forced air circulation are permitted as long as the penetration /
dampers have a two hour fire rating.
The licensee intends to put a forced air system into the vault this-year and has budgeted electrical penetrations along with this modi fication.
The licensee's representatives, subsequent to questioning the inspector on the acceptability of electrical penetration for the vault, agreed to review this area for clarification of QA Plan records storage requirements.
This area is unresolved pending further licensee and NRC review (320/82-02-04).
,
.
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-24-14. Procedure Implementation The inspector monitored the system realignment of the standby pressure control (SPC) system from the reactor coolant system (RCS)
"B" loop to the "A" loop.
This evolution was carried out using operating procedure (0P) 2104-1.14, Revision 9, February 1,1982, Standby Reactor Coolant Pressure Control System.
The pre-job briefing and the initial attempt to perform the task were observed on March 3,1982 The evolution was secured due to a missing handwheel on valve
'
MU-V-144 B.
A temporary valve handle was obtained and on March 8,1982, the inspector observed the successful completion of the job.
No violations were identi fied.
15. Unusual Event of February 19, 1982 a.
Background At the start of a routine reactor building (RB) entry on February 19,1982, low 02 readings were observed by a health physics technician, Subsequent iacasurements, analyses and events led the licensee to declare an Unusual Event at 5:26 PM.
The licensee secured from the Unusual Event at 2:04 AM on February 20, 1982.
A brief chronology of key events and information development is in Attachment 2.
Onsite NRC personnel became aware of the developing situation on the morning of
'
February 19, 1982, and followed the events until after the Unusual Event was terminated.
Licensee actions, analyses, evaluations, and data were subsequently reviewed.
b.
Evaluation of Instrument Giving Abnormal Indications (1)
Rad _iation Monitor R0-2A The R0-2A readings were not given much credibility from the start.
They were inconsistent with previous surveys; exibited a step change in radiation field rather than a smooth transition (500 mR/hr to > 50 R/hr vs. a gradient);
and were contradicted by two sets of digital dosimeters and sel f-reading dosimeters.
Subsequent investigation by instrument technicians revealed a faulty instrument switch.
This caused the detector electronics and pointer to'be working on a 500 mR/hr scale while the meter indicated a 50 R/hr scale (i.e., a true 500 mR/hr field would cause full scale deflection and an observer would read 50 R/hr).
.
.
-25-(2) Gas Chromatograph The gas chromatograph (GC) in warehouse No. 3 had been recently acquired for EPICOR II prefilter venting ~ gas analysis and the individual who performed the initial RB gas analysis had little time to gain experience in the use of the GC prior to the event. -This GC was not in a radiologically controlled area (did not require a radiation work permit or protective clothing) and was used because it was more accessible than the gas partitioner in the auxiliary building.
The initial reading of H2 in the RB was apparently due to use of hydrogen-helium carrier gas in the GC separator column.
After the initial erroneous analyses, adjustments were made and the GC produced consistent reliable analyses.
Most personnel observed and interviewed by the NRC inspector tended not to place much trust in the GC results after the initial error.
This situation was not the intended use of the GC; a subsequent licensee evaluation concluded that to better use the GC for response to such events, a second separator column which uses N2 carrier gas should be purchased.
(3) Portable Gas Analyzers Just prior to the entry made at 12:30 AM on February 20, 1982, radio frequency interference with the portable gas analyzers (PGA) were confirmed subsequent to NRC inspector questioning
in this area.
Radio frequency interference with an NRC voice activated tape recorder was observed during preparations for an NRC inspector's recent entry into the RB.
Subsequent licensee investigations and evaluation disclosed several other shortcomings of the PGA's.
They included, battery depletion / defects and depleted sensor cells which caused sensitivity to temperature, pressure, and humidity.
As the sensor cells age and are depleted, they can be calibrated and adjusted for 02 and CH4 (methane) measurements using manufacturers instructions; but they will give unreliable 02 and CH4 readings when subjected to changes in temperature, pressure, or humidity.
A post-event licensee engineering evaluation recommended test procedure upgrading, c.
Findings In retrospect it was clear that indications of elevated radiation levels, depletion of 0, presence of H, and presence
2 of combustible gases in the RB on February 19,1982, were erroneous.
The licensee appropriately responded to these indications and took action to mitigate, correct and gather additional data about the perceived situation.
The basis for
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-26-the declaration of the Unusual Event, "Whenever plant conditions warrant' increased plant awareness", was discretionary and at the judgement of the shift foreman / emergency director.
This judgement could have been made at any time after the initial reading of depleted 02 at 9:30 AM.
Licensee evaluation did not specifically justify the 5:26 AM declaration; however, it was apparent that this occurred after high level NRC management attention.
The licensee's internal reports / evaluations recommended corrective actions and actions to prevent recurrence, in particular, the upgrading of portable gas analyzer maintenance and calibration procedures.
This is unresolved pending completion of action by the licensee as noted above and subsequent NRC review (320/82-02-05).
Inspector Follow Items r
Inspector follow items are inspector concerns or preceived weaknesses in the licensee's conduct of operation (hardware or programmatic)
that could lead to noncompliance if left uncorrected.
Inspector follow items are addressed in paragraph 2.
17. Unresolved Items Unresolved items are findings about which more information is
,
'
needed to ascertain whether it is an item of noncompliance, a deviation, or acceptable.
Unresolved items are addressed in paragraphs 2 and 5.c, 6.c, 8.c 13.c(2) and 15.c.
18.
Exit Interview On March 25, 1982, 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.
L. Barrett, Deputy Program Director, NRC TMI Program Office
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R. Bellamy, Chief, Technical Support Section, NRC TMI Program
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Office A. Fasano, Chief, Three Mile Island Section, Projects Branch
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No. 2 M. Shanbaky, Senior Radiation Specialist, Three Mile Island
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Section
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ATTACHMEtiT 1 Report of Findings and Sample Results for Reactor Building Entry tio. 33, February 4,1982 Discussion It was reported in NRC Inspection Report 50-320/82-01 that on February 4,1982, an NRC inspector entered the reactor building (RB).
The inspector attended training sessions, a full mock-up, and post entry debriefings.
During the entry, the inspector performed an independent radiation survey of the top of the "D" ring, elevation 305' and 347' areas.
The inspector successfully tested a modifled tape recorder to demonstrate reduction of stay time and expediency of radiation survey documentation in High Radiation Areas."
The following tasks were completed by the inspector as scheduled:
Audit of entry process, use of equipment, and contamination controls, training, RB anteroom procedures, etc.
2.
Independent radiation survey (fixed point and other locations)
using NRC R02A, (survey locations were located on 305' and 347' elevations).
3.
Photography of RB sump level, " bathtub ring," miscellaneous RB equipment and areas (although scheduled; not completed).
Walkdown of the Sabmerged Demineralizer System (SDS) hose and survey.
5.
Assessment of licensee's sample testing program:
Breathing Zone Analysis (BZA) sample will be counted by
-
licensee and NRC
,
Urine sample - to include "3H-spiked" sample will be
--
counted by licensee and NRC Comparison of the results given by Film Badges, and TLD's
--
which will be worn during the entry 6.
Test and use of voice activated tape recorder developed by the NRC.
The entry lasted 79 minutes.
The task man-rem estimate was 0.6 with an actual dose of 0.23 man-rem.
The results of survey and NRC Region I analysis of samples (identified by ** in confirmatory measurements section) were in agreement or possible agreement with licensee result.. -
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ATTACHMENT 1-2-Confirmatory Measurements
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.l.
Radiation -survey (R0-2A) of reactor building (a)
Fixed point survey (elevation 305') gamma readings in mR/hr NRC Licensee Survey Point 1 250 (general area) 200
250 300
700 700
400 500
t
500 500
1,000 1,000
"
2,200 3,000 l
(b) Personnel Dosimetry Results in mrem Licensee Licensee i
Body.
Licensee NRC High Pencil Low Licensee Licensee Location TLD Film Dosimeter Dosimeter Digital Modified TLD Right Thigh 280 300 364
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Back 230
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--
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Chest 230 260 200 200 185
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Head 300
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(c)** Breathing-Zone Analysis (BZA) microcurie /cc of air I
Radionuclide NRC Licensee Cesium-134 5.87 E-9 5.4 E-9
,
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1 o ~(12.42 E-10)
Ces ium-137 6.57 E-8 6.2 E-8 1 o (16.70 E-10)
(d)** Bioassay Results (urine sample) microcurie per milliliter i
l Radionuclide NRC Licensee
.
l (Tritium) H-3 1.55 E-5 3.2 E-5
1 o (1 1.29 E-6)
l'
j (e)** Unknown " spiked" H-3 sample (prepared by inspector) uCi/mi NRC Licensee 1.78 E-5 2.0 E-5 1 o (1 2.07 E-7)
l l
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ATTACHMENT 1-3-
- Criteria for Comparing Analytical Measurements
The following is the criteria for comparing results of capability
'
. tests and veri fication measurements.
The criteria are based.on an
empirical relationship which combines prior experience and the l
accuracy needs of this program.
.
!
i
In these criteria, the judgement limits are v&riable in relation to
i the comparison.of the NRC Reference Laboratory's value to its
'
i-associated uncertainty. As that ratio increases, referred to in
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this program as " Resolution", acceptability of a licensee's_ measurement should be more selective.
Conversely, poorer agreement must be
considered acceptable as the resolution decreases.
.
.
LICENSEE VALUE
<
l RATIO = NRC REFERENCE VALUE Possible Possible l-Resolution Agreement Agreement A Agreement B i
<3 0. 4 - 2. 5 0.3 - 3.0 No Comparison
4-7 0.5 - 2.0 0.4 - 2.5 0.3 - 3.0 8 - 15 0.6 - 1.66 0.5 - 2.0 0.4 - 2.5
'
16 - 50 0.75 - 1.33 0.6 - 1.66 0.5 - 2.0
51 - 200 0.80 - 1.25 0.75 - 1.33 0.6 - 1.66-j
>200 0.85 - 1.18 0.80 - 1.25 0.75 - 1.33
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" A" criteria are applied to the following analyses:
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Gamma Spectrometry where principal gamma energy used for identification is greater than 250 Key Tritium analyses of liquid samples f
,
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"B" criteria are applied to the following analyses:
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Gamma Spectrometry where princtpal gamma energy used for identification is less than 250 Kev
>
Gross Beta where samples are counted on the same date using
+
the same reference nuclide
i I
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ATTACHMENT 1-4 Example of Criteria for Comparing Measurements (Using Bioassay Resul ts Reported Above)
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NRC (uCi/cc) + 1 o Licensee uCi/cc + 1 o 15.5 E-6 + 1.29 E-6 3.2 E-5 microcuries per milliliter Step 1 NRC Results 15.5, 12.0 resolution
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1o 1.29 Step 2 Licensee Resul t, 3.2 NRC Result IIllI = 2.0 ratio Step 3 (Using Table) The determined resolution (12.0) is between 8-15, reading across to " A" criteria (H-3 analyses of liquid samples) the ratio is 0.5 - 2.0.
Therefore, the results are in possible agreement.
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ATTACHMENT 2 Sequence of Events for February 19, 1982, Unusual Event February 19,
9.07 AM -
A health physics (HP) technician made entries 9:35 AM into the RB to verify air quality prior to entry by work teams.
Information transmitted to the control. room and NRC inspectors was that two different instruments from different manufacturers (Gastech and Edmont) both indicated normal levels of 02 in the anteroom but 17% 02 in the RB.
9:45 AM -
Licensee personnel evaluated available infor-1 :00 PM mation to determine what had happened.
(In addition to the low 02 readings the temperature detectors on the outlets of two (of six) fan cooler units in the RB showed a temperature rise of approximately 10 F on February 18, 1982.)
Other RB instrumentation indicated no change in temperature or pressure for the previous 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as veri fied by NRC personnel.
A portable gas
analyzer indicated 20.5% 02 in the RB purge duct and 21% 02 in the room surrounding the duct at approximately noon.
Among the areas being evaluated were changes to the RB since the last entry (approximately six inches lower water level and energization of certain electric circuits) and the possibility of a N2 leak (diluting 0 ).
A second entry team, consisting
of the HP technician and a health and safety (HS) supervisor, prepared for a second entry to gather more in formation.
These individuals were to sample for combustible gas and 0, to
take a grab sample of air in a marinelli beaker,
to take radiological samples, and to look for signs of fire / combustion particularly in the l
area of the air coolers.
1:45 PM -
HP technician and HS supervisor entered RB and 2:05 PM took the marinelli sample.
As they approached the core flood tank (CFT) one portable gas -
analyzer (Edmont) read 12% 02 and the other (Gastech) read 19% 0, and a radiation survey
instrument (Eberline R0-2A) pegged on the 5 R/hr, then the 50 R/hr scale.
Digital dosimeters worn by the individuals contradicted the R0-2A
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and were consistent with expected dose rates, so the individuals continued their entry.
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ATTACHMENT 2-2-Later in the entry as they climbed the open stairwell, the HP technician thought he saw a mist above the "D" rings.
He wasn't sure if this was due to facepiece fogging on his self contained breathing apparatus.
Shortly thereafter, both portable gas monitors indicated full scale for combustible gases; for the Edmont this is 100% (i.e. > 5% methane equivalent) of lower explosive limit (LEL); for the Gashtech this is 50% of LEL.
The Gastech was switched to a times 2 scale and still indicated full scale (i.e.100% LEL or > 5% methane).
This was erroneously reported as 2 x 100% rather than 2 x 50% (i.e.10% methane equivalent vs. 5%
methane equivalent).
The individuals promptly exited the RB.
2:05 PM -
(Time approximate) Licensee management personnel
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2:30 PM contemplated declaring an Unusual Event but decided to wait until the entry team was debriefed.
At this time no specific conditions defined as Emergency Action Levels (EAL) in the licensee's emergency plan existed.
Step 3.21 of the Emergency Plan Implementing Procedure (EPIP) 1054.1, allows for declaration of an Unusual Event,
"Whenever plant conditions warrant increased plant awareness"; this is done at the " Shift Foreman's/ Emergency Director's judgement".
2:30 PM -
(Time approximate) The entry team debriefed.
3:30 PM Readings obtained from the portable radiation meters and portable gas analyzers were given.
Neither individual reported seeing any clear evidence of fire (i.e. charring, smoke); the.HP technician reported that he may have seen a slight mist above the
"D" ring.
The HS supervisor did not see any mist but was unable to rule it out.
The possibility of mask lens fogging was discussed.
4 :00 PM -
Licensee operations and technical support 4:30 PM personnel began preparing contingency plans (i.e. augmenting the fire brigade, reflooding six inches of RB sump and deenergization of all or selected electrical supplies to the RB).
The results (from a gas chromatograph (GC) in warehouse No. 3) of the gas sample from the entry were called in to the control room; they were H2 - 1 to 1.5%, Methane - none detected, CO - none detected, and 02 - 19% + 2%.
(The H2 result later proved to be erroneous.)
Contingency
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ATTACHMENT 2-3-plans for an additional entry were discussed.
Licensee management personnel decided to continue purging (to dilute any gases in the containment)
and to sample the purge exhaust and the RB air (via the RB dome sample point - HPR-227) to monitor the effectiveness of purging.
4:30 PM -
Several discussions and telephone conversations 5:26 PM took place among onsite licensee management, offsite licensee management, and NRC management; the principal topics were plant status, evaluation of data, and emergency response status.
At 5:26 PM, the licensee declared an Unusual Event.
6:00 PM -
Information reached the control room that there 9:00 PM was a problem with the gas chromatograph; chemistry personnel began warming up a gas partitioner (GP) in the auxiliary building.
Gas samples were sent offsite to the licensee's Reading laboratory for analysis.
The licensee confirmed that the high radiation reading on the R0-2A were erroneous and identified the cause as a faulty switch. Samples from HPR-227, the RB dome and HPR-226, the purge duct, indicated no H2 and normal 0, analyzed by the GP.
9:00 PM -
The licensee continued to sample and analyze 2 :04 AM HPR-226 and HPR-227; results indicated no.
combustible gases and normal levels of 02 Plans were made for an additional RB entry.
While preparing for the entry it was noted that radio transmissions caused erratic readings and alarms on the portable gas analyzers.
Resul ts of grab samples taken during this entry indicated no combustible gases and normal 02 levels.
The licensee secured from the Unusual Event at
. 2 :04 AM, February 20, 1982.
February 20-24,1982 -
The licensee continued to sample the RB atmosphere via HPR-227.
The purge was shutdown on the morning of February 20 to allow gases (if any were being produced) to build up.
On February 24, 1982, grab samples were taken during an RB entry.
All results indicated normal 02 levels and no detectable combustible gases.
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