IR 05000320/1983007

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IE Insp Rept 50-320/83-07 on 830502-30.No Noncompliance Noted.Major Areas Inspected:Licensee Action on Previous Insp Findings,Routine Plant Operations,Lers,Routine Maint,Health Physics & Environ Review & Reactor Bldg Entries
ML20024B805
Person / Time
Site: Crane Constellation icon.png
Issue date: 06/22/1983
From: Barr K, Bell J, Fasano A, Kalman G, Moslak T, Oneill B, Thonus L, Joel Wiebe
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20024B800 List:
References
50-320-83-07, 50-320-83-7, NUDOCS 8307110396
Download: ML20024B805 (9)


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U. S. NUCLEAR REGULATORY COMMISSION 50320-830325 50320-830329 Region I 50320-830418 Report No.

50-320/83-07 Docket No.

50-320 License No. DPR-73 Priority

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Category C

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: May 2 - 30, 1983 Inspectors:

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'iebe, Senior Resident Inspector (TMI-2)

date Isigned

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K. SRr, Rafiation Specialist date ' signed Cod R eid L.

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. Moslal, Radiatior[ Specialist da'te'si gned

/Sm l 6//NW2 B. O'N(i)l,4 tad % ion Specialist date signed

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L. Thonus, Resident Inspector (TMI-2)

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b oh0 gBell,SeniorRadiatf6nS'pecialist ddte' signed

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G. Kalmfi, Nuclear E ineer date s'igned l

Approved by:

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l A. Arsano, Chi

, Thre le Island-2 Projects date signed

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Section, Pro ects B h No. 2 Inspection Summary:

I Inspection conducted on May 2 - 30, 1983 (Inspection Report Number t

l 50-320/83-07)

Areas Inspected:

Routine safety inspection conducted by site inspectors of

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licensee action on previous inspection findings; routine plant operations;

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licensee event reports; routine ~ maintenance; health physics and environmental review; reactor building entries; radioactive material shipments; procedure review, and NRC bulletin review. The inspection involved 239 inspector-hours.

Results: No violations or deviations were identified.

r307110396 830623 DR ADOCK 05000 2

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DETAILS 1.

Persons Contacted

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General Public Utilities (GPU) Nuclear Corporation J. Barton, Deputy Director, TMI-2

  • S. Chaplin, Licensing Engineer.

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  • W. Conaway, Radwaste Support Manager i
  • W. Craft, Radiological Assessor
  • J. Flanigan, Radiological Engineering Manager

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R. Freemerman, Deputy Manager, Recovery Programs

  • K'. Harner, Chemistry Lab Manager
  • J. Hildebrand,' Radiological Controls Director, TMI-2
  • G. Kunder, Manager, Safety Review Group

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  • J. Larson, Director, Licensing and Nuclear Safety, TMI-2 F. Linsenbach, Radiological Controls Foreman
  • J. Mayer, Lead Rad-Con Monitor, Operations QA H. McGovern, Shift Supervisor B. McMullen, Command Center Coordinator

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  • R. Neidig, Communications J. Quinette, Plant Engineer
  • J. Renshaw, Manager, Radiological Field Operations i

R. Ritthamel, Safety and Health

  • J. Schork, Supervisor, Safety and Health E. Short, Safety and Health

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  • M. Slobodien, Manager, Radiological Health i
  • B. Smith, Radwaste Supervisor
  • J. Thiesing, Manager, Recovery Programs
  • G. Tomb, Media Representative l

Other licensee and contractor personnel were also interviewed.

  • denotes those present at the exit interview,

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2.

Licensee Action on Previous Inspection Findings *

(0 pen) Unresolved item (320/82-02-03): Review and tracking of open items

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i in Licensee Event Reports (LERs). The licensee established a tracking system and provided updates to 1980 and 1981 LERs. Action on 1979 LER open item tracking remain; incomplete.

3.

Routine Plant Operations-Inspections of the facility were conducted to assess compliance with~

general operating. requirements of Technical Specification (TS) 6.8.1 in the following areas:

licensee review of selected plant parameters for

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abnormal trends; plant status from a maintenance / modification viewpoint

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including plant cleanliness and fire protection; licensee control of

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ongoing and special evolutions including control room personnel awareness of these evolutions; control of documents including log keeping practices; area radiological controls; and security plan' implementation.

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Random inspections of the control room during regular and back shift hours were conducted at least three times per week.

The shift foreman's log and selected portions of the control room operator's log were reviewed for the period May 2 - 30, 1983.

Other logs reviewed during the inspection period included the procedure-in-use log and auxiliary operators daily log sheets.

Operability of components in systems required by TS or plant procedures to be available for response to emergencies was reviewed to verify that they could perform their intended functions.

Shift staffing for licensed operators and fire brigade members and selected licensee planning meetings were observed.

The above areas were acceptable except as noted below. During a tour of the Control Room, the inspector noted that the startup rate rod withdrawal inhibit alarm is hidden behind the incore thermocouple readout board (this board was installed after the March 28, 1979 accident to allow continuous incore thermocouple readout in the control room). The hidden alarm could be useful in detecting a boron dilution event where criticality and a positive startup rate occurs.

In addition, the alarm response procedure for this alarm has not been updated and as a result does not give sufficient guidance to the operator and does not reference the emergency procedure for boron dilution. The inspector also questions the advisability of installing the incore thermocouple readout in front of the visual alarm module which prevents the operators from easily identifying the cause for the audible alarm should this alarm sound.

This item will remain open pending further NRC review.

(83-07-01)

On May 27, 1983, the inspector was informed by the licensee that a portion of the Air Intake Tunnel (AIT) Halon system had been taken out of service (in accordance with internal memoranda) to prevent inadvertent actuation by lightning during an imminent thunderstorm. Taking the AIT halon system out of service places the plant in the Action Statement of the Technical Specifications section 3.7.10.3 which requires restoration of the system to operable status within 14 days. The inspector informed the licensee that it is generally inappropriate to intentionally place the plant in an Action Statement unless it can be shown that this action

justifiably increases safety. The licensee determined that the action increased safety because if the halon system was actuated, the system would be out of service for 10-14 ' days for recharging, whereas to prevent inadvertant actuation, the system would only be cut of service for several hours at a time during thunderstorms and could be actuated manually if necessary. This. item is considered unresolved until the NRC completes its review of the problem of inadvertent actuation, the I

licensee's action to permanently correct the problem, and the licensee's method of issuing instructions to take a Technical Specification required system out of service.

(83-07-02)

4.

Licensee Event Reports I

The inspector reviewed three Licensee Event Reports (LERs) required to be submitted in accordance with Technical Specifications (TS) 6.9.1.8 and 6.9.1.9 (and NUREG 0161) to verify the following:

Event and cause

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description clearly reported event information; the required LER form was properly completed; and adequate corrective action was specified.

LERs 83-ll/0ll-0 and 83-12/03L-0 and 83-13/03L-0 were reviewed.

Initial screening of these events was completed to determine generic applicability, need for additional site verification, and the necessity for additional NRC management review. Additional onsite followup was

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performed in the case of LER 83-12/03L-0. The inspector verified that

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personnel error rather than a delay due to lengthy calculations caused the temporary inoperability of the air intake halon system. The time involved (less than 10 minutes) in performing the calculations regarding the required pressure in the bottles did not affect the operability of the system. This completes the review of LER 83-12/03L-0; no additional review was required for the other LERs.

5.

Routine Maintenance

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The inspector observed portions of replacement of fire barrier penetrations. The licensee is permanently replacing firewall 50 fire barrier penetrations with a silicone foam.

Problems associated with the firewall 50 were identified with unresolved item 79-26-05.

The inspector examined the work area including scaffolding and lighting and observed a portion of the foaming operation including quality control sampling. All areas observed were acceptable, however, unresolved item 79-26-05 remains open pending further review of licensee progress in this area.

6.

Routine Health Physics and Environmental Review a.

Plant Tours The NRC site radiation specialists completed routine plant i

inspection tours. These inspections included all radiation protection control points and selected radiologically controlled areas.

Items inspected included:

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Access control to radiologically controlled areas j

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Adherence to Radiation Work Permit (RWP) requirements l

Proper use of respiratory protection equipment

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Adherence to radiation protection procedures 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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Licensee performance was satisfactory.

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Measurement Verification Measurements were independently made by the inspector to verify the quality of licensee performance in the areas of radioactive material shipping, radiation and contamination surveys, and onsite environ-mental air and water sampling and analyses.

Licensee data were consistent with the NRC measurements.

c.

Gate 7 Sewage Holding Tank and Lancaster Sewage Samples The Gate 7 Sewage Holding Tank is located just outside the west entrance of the TMI-2 Turbine Building. The tank has a 1500 gallon capacity and receives waste from the Personnel Access Facility (PAF). This includes waste from toilets, showers, and washing machines.

In December 1982, low levels of Cesium-137 (Cs-137) and tritium Since tgat time, the levels have averaged 5 x 10 gom the tank.

(H-3) began to show up in routine samples taken f uCi/cc Cs-137 and 7 x 10- uCi/cc H-3.

These concentrations represent 0.0025 of the Maximum Permissible Concentration (MPC) for unrestricted areas of Cs-137 and 0.0022 of the MPC for unrestricted areas of H-3.

The levels are consistent with the activities of the PAF and are within the discharge limits of 10 CFR 20.303 and the licensee's Technical Specifications.

TMI sewage is transported to two sewage treatment plants; Conewago Industrial Park Plant and the City of Lancaster Sewage Treatment Facility. On May 13, 1983, nine liquid sewage samples and three dried filter cake samples were delivered to the TMI Program Office by the Lancaster Sewage Treatment Plant for radiochemical analyses at the request of the City of Lancaster. The samples were taken to the Environmental Protection Agency's Middletown Counting Laboratory for determination of the concentration of gamma emitting radioisotopes. Results indicated that no gamma emitting activity was detectable. Tritium analyses were performed by the Pennsylvania Department of Environmental Resources.

No tritium was detected.

The lower limit of detectability (LLD) was 1 y 10-5 uCi/ sample (Cs-137) for the gamma analysis and 2.8 x 10- uCi/cc on the. tritium analyses.

7.

Reactor Building Entries a.

The site staff monitored reactor building (RB) entries conducted during the inspection period. The inspection activities included review of selected documents and direct observations of reactor building entries. The following items were verified on a sampling basis.

The RB entry was properly planned and coordinated to assure

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

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Radiological precautions were planned and implemented including

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the use of a Radiation Work Permit (RWP).

i Specific procedures were developed for unique tasks and were

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properly implemented.

Entries 212 through 230 were conducted during this inspection period.

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All the areas observed were acceptable.

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Two personnel from the NRC TMIPO conducted a special inspection inside the reactor building on Thursday, May 5, 1983. The inspection scope included:

Effectiveness of dose reduction measures

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Industrial safety / fire protection

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Evaluation of potential hazards during polar crane operations

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Vulnerability of incore instrumentation pressure boundaries to

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damage during recovery operations

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Inspection of components and systems needed for reactor

disassembly.

f Several areas requiring followup action were identified and were pursued with cognizant licensee personnel (these were addressed in a letter to the licensee dated May 16, 1983, NRC/TMI-83-031). Details-of the reactor building inspection will be documented in report

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50-320/83-06.

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Reactor Building Entry Work Package J004 (Neutron Detectors, NI-l and NI-2, Source Calibration

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During reactor building entry number 220 on May 13,1983, an

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Americium-Beryllium neutron source was used to verify that the-source range nuclear instruments were operating correctly.

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Subsequent to the entry, the inspector was notified that problems I

had occurred when attempting to remove a source tube cover plate l

from the lower canal work area. Team members had attempted to use a l

nylon rope to hoist the cover plate from the canal. Apparently, the rope broke twice and on both incidents the plate fell and struck-the

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j stainless steel liner of the canal and possibly other components.

NRC review of the incident is continuing; this item is unresolved pending completion of the NRC review (320/83-07-03).

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Radioactive Material Shipments The NRC site radiaticn specialists inspected TMI-2 radioactive material shipments during the inspection period to verify the items listed below.

The licensee had complied with approved packaging and shipping

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procedures.

The licensee had prepared shipping papers, which certified that the

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

The licensee had applied warning labels to all packages and had

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placarded vehicles.

The licensee had controlled the radioactive contamination and dose

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rates below the regulatory limits.

Inspector review of this area consisted of (1) examination of shipping papers, procedures, packages, and vehicles, and (2) performance of radiation and contamination surveys of the shipments which were inspected. All of the items examined were acceptable 9.

procedure Review On May 2, 1983, the inspector reviewed Unit Work Instruction (UWI)

  1. 4220-3623/83/0298 "NI-l and NI-2 Source Check", which was submitted to the NRC in accordance with TMI-2 proposed Technical Specifications Section 6.8.2.

The UWI was reviewed for technical adequacy, human factors considerations, and for compliance with Administrative Procedure 4000-ADM-3000.01 "TMI-2 Unit Work Instructions". Since certain licensee procedures require NRC approval, this review was conducted prior to procedure issuance and implementation. The items listed below were noted.

Significant steps such as torque requirements on cover plate bolts

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and de-energizing NI-l and NI-2 high voltage for personnel safety did not have sign off spaces as required by 4000-ADM-3000.01.

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Af ter the spare detector was reconnected, there was no check required to ensure the instrument was reconnected and operating properly.

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The instructions were not clear in several instances.

The procedure for handling the neutron source was contained in an

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attachment to the UWI. The prerequisites to the UWI required this procedure to be attached to the UWI, but the body of the UWI did not contain instructions as to when to use this attached procedure.

The inspector discussed the above with the cognizant engineer who agreed to make changes to the UWI to correct the problems.

On May 3, 1983, the UWI was again submitted to the NRC.

The inspector noted that the UWI was changed to include installation and removal of Solid State Track W

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Recorders (SSTR's) in the source tubes but the UWI did not receive additional review following the change in scope.

Further inspection revealed that after the Plant Operation Review Committee (PORC) review of the UWI occurred, the following changes to the UWI were made.

An unapproved source handling procedure was added as an attachment.

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Measurement of gamma radiation near the nuclear instrument detectors

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was added.

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Installation and removal of SSTR's was added.

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A check to ensure that the source range nuclear instruments were operating properly was added.

The above was discussed with the PORC chairman and he agreed that the above items included those which should be reviewed by PORC. The above was also discussed with the manager of Management Services who indicated that although the administrative procedure 4000-ADM-3000.01 only requires that changes of scope to the UWI be performed by the cognizant engineer, the procedure should be interpreted as requiring complete review and approval following the change. The UWI was returned to the licensee to obtain the required review and approval. This item will remain unresolved pending further NRC review of the licensee's UWI administrative procedures (83-07-04).

10. Review of NRC Bulletins The licensee determined that many bulletins were not applicable to TMI-2 in the recovery (long-term shutdown) mode though they would be applicable to an operating plant. The licensee indicated that he would postpone actions required by these bulletins until a decision whether or not to restart TMI-2 was reached. Subsequent review by the inspector also concluded that the below list of bulletins were not applicable to TMI-2 in the recovery mode. The items have been added to the licensing project managers restart items list.

Bulletins 79-01,79-01B, 79-02,79-03A, 79-04, 79-05, 79-07, 79-09, 79-13, 79-14, 79-17, 79-21, 79-27, 80-03, 80-04, 80-06, 80-08, 80-11, 80-12, 80-16, 80-18, and 81-01 are closed.

Review of bulletin 79-11 indicated that the equipment (breakers)

described in the bulletin is not used at TMI-2. This bulletin is closed.

12.

Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operation (hardware or programmatic) that could lead to violations if lef t uncorrected. An inspector follow item is addressed in paragraph 3.

13. Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether it is a violation, a deviation, or acceptable.

Unresolved items are addressed in paragraphs 2, 3, 5, 7, and 9.

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Exit Interview On May 31, 1983, a meeting was held with licensee representatives (denoted in paragraph 1) to discuss the inspection scope ard findings.

On June 7, 1983, a telephone conversation was held with S. Chaplin, Licensing Engineer, to discuss the open items in paragraph 3.

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