IR 05000320/1985014

Safety Insp Rept 50-320/85-14 on 850702-0805.No Violation Noted.Major Areas Inspected:Plant Operations (long-term Shutdown),Operator Training,Preoperational Boronometer Testing,Entry Into Locked High Radiation Area & Security

ML20137F698
Person / Time
Site:	Three Mile Island
Issue date:	08/19/1985
From:	Bell J, Dan Collins, Cook R, Coolins D, Cowgill C, Moslak T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137F672	List: IR 05000320/1985014 ML20137F666
References
50-320-85-14, NUDOCS 8508270054
Download: ML20137F698 (8)

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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/85-14 Docket N License No. DPR-73 Priority --

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: July 2, 1985 - August 5, 1985 Inspectors: N//~&~ d I 4!I date signed

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R. G60k, gior ResitDdnt Inspector (THI-2)

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T. fj6slakOResidentUInspector (THI-2)

F)h/tr date signed AluE // w fk4/W date signed J. Beyl,' S g r Radi& tion Specialist Ale)eVw - F 4 J~

D. @ lli g Radiatif4n Specialist date signed '

Approved By: NdX//

C. Cow)flT, E

ef', TMI-2 Project Section P 9/C date signed Inspection Summary:

Area Inspected: Routine safety inspection by site inspectors of plant operations (long term shutdown), operator training at the Penn State Reactor, pre-operational testing of a boronometer, action on previously identified items, an unauthorized entry into a locked high radiation area and radioactive material shipments including improperly classified and packaged material shipped to the burial site. The inspection involved 235 inspector hour Results: No violations were identified. The improperly classified and packaged material is the subject of a separate inspectio .

8508270054 850822 PDR ADOCK 05000320 0 PDR

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DETAILS 1.0 Ongoing Recovery Operations Routine Plant Operations Inspections of the facility were conducted to assess compliance with the requirements of the Proposed Technical Specifications and Recovery Operations Plan in the following areas: licensee review of selected plant parameters for abnormal trends; plant status from a maintenance / modification viewpoint, including plant cleanliness, control of switching and tagging, and fire protection; licensee control of routine and special evolutions, including control room personnel awareness of these evolutions; control of documents, including log keeping practices; radiological controls; and security plan implementatio Random inspections of the control room during regular and back shift hours were routinely conducted. The Shift Foreman's Log and selected portions of the Control Room Operator's Log were reviewed for the period July 2 through August 5, 1985. Other logs reviewed during the inspection period included the Submerged Demineralizer System (SDS) Operations Log, Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log Sheet Operability of components in systems required to be available for response to emergencies was reviewed to verify that they could perform their intended functions. The inspectors attended selected licensee planning meetings. Shift staffing for licensed operators, non-licensed personnel, and fire brigade members was observe No violations were identifie .0 Licensee Action on Previous Inspection Findings (Closed) Inspector Follow Item (320/84-19-02): Upgrade the Calibration

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Data Sheets for Pressure Gauge The inspector verified that the licensee generated a Site Operations Action Item (SOAI 4240-84-4241-0523) to correct the tolerances specified on Calibration Data Sheets and the Emergency Diesel Instrument List. In addition to the lube oil filter pressure indicator (DF-PI-2026), that was identified in a past inspection to have an improper tolerance, the licensee is correcting the tolerances for DF-PI-2023, 2024, and 202 The inspector had no further questions on this ite . - . -_ . _ __. -- - _

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(Closed) Inspector Follow Item (320/84-19-04): Weakness in training presentation The inspector attended training sessions for the requalification of licensed and non-licensed personnel on the operation of the reactor defueling system and various support systems. The inspector evaluated lesson plans, audio-visual aids, and handouts. The inspector determined that the licensee has committed significant resources to upgrading the training program. This has resulted in well organized, detailed, and effective training session The inspector had no further questions on this ite (Closed) Inspector Follow Item (320/85-10-03): Step-off pad presents fall ris The fall risk associated with the location of the step-off pad at the inner edge of the top of the "A" D-ring near the top of the ladder providing access to the inside of the D-ring was noted during an entry to the reactor building on April 19, 1985. During entry 664 on July 31, 1985, an inspector noted that the fall risk had been substantially mitigated as a result of the licensee relocating the step-off pad away from the inner edge of the D-ring. Those exiting from the D-ring now have a substantial area in which they can stand while removing foot coverings prior to stepping on the step-off pa The inspector had no further questions on this ite (Closed) Violation (320/85-01-04): Failure to tag an inoperable electrical breaker on DH-V-5 As corrective action, the licensee performed a review of all major plant electrical buses, Unit Substations, and Motor Control Centers to determine if conditions similar to the cited condition existed elsewhere in the plant. As a result of this review no similar condition, i.e., an open, untagged breaker which would represent a personnel hazard if operated, was identifie The inspector had no further questions on this ite (Closed) Violation (84-21-01): Licensee did not provide cyclic training for Radiation Support Technician as required by procedur As described in a licensee letter to NRC: Region I on January 11, 1985, Radiological Controls Procedure (RCP) 9000-ADM-2622.05 has been changed so as to reflect actual conditions within the department. These changes include a self-study program and on-going training for currently assigned personnel, to ensure that new methods and materials used within the department are disseminated. Personnel are precluded from performing work for which competency has not been demonstrate In addition, the program requires periodic requalifications.

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The inspector had no further questions on this item.

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(Closed) Violation (50-320/80-09-01): Failure to follow open flame welding procedure. Maintenance Procedure 1410-Y-26, Revision 5, January 15, 1981, " Welding, Cutting, Grinding and Open Flamework Procedure for Fire Safety," clearly states that the job foreman is responsible for implementation of the procedure at the jobsite. Through interviews and observations of jobsites and employee training classes, the inspector has determined that craftspersons, their foremen, site operations, maintenance and radiological controls personnel are sufficiently familiar with the requirements of the procedure so that routine implementation is assure The inspector had no further questions on this ite .0 Operator Training at Penn State Reactor On July 2,1985, the inspector reviewed training provided to GPU Nuclear Senior Reactor Operators (SR0)/ Fuel Handling Limited SR0's (FHSRO)

candidates at the Penn State Breazeale Reactor (PSBR) in University Park, Pennsylvani The PSBR is being used to perform a series of experiments which simulate potential configurations of the fuel in the TMI-2 reactor vessel that could occur during defueling operations. These experiments include simulating a collapse of fuel, reconfiguring fuel in a highly borated .

environment, deboration, fuel loading into a submerged canister, and the draindown of the reactor vesse To accomplish these experiments, the PSBR (a TRIGA, swimming pool, core)

was modified to simulate conditions found in the TMI-2 reactor vesse Due to the inherent differences between the PSBR and the present TMI-2 core, these modifications impose limitations on the degree of simulatio Two examples of these limitations are:

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To simulate a highly borated condition (5000 ppm), borated polyethene rods were positioned in the PSBR core. Because they are rods, they exhibited a localized reactivity effect rather than a uniform effect that would be caused by a homogeneous borated solutio Since the PSBR cannot be drained of water to simulate a draindown of the TMI-2 reactor coolant system, special elements with voids were placed in the core to show the effects of creating voids adjacent to the core. Use of void rods does not account for the effects that decay heat (e.g. reflux boiling) may have on reactivit The inspector determined that these constraints did not detract from achieving the training objectives of providing the operator first hand

' observations of neutron population changes and changes to the margin to criticality during various core configuration The inspector witnessed the conducting of three simulations: removing fuel from various regions of the core (defueling), deboration, and the loading of fuel fragments into a canister by loading fuel rods into a specific region of the core. The inspector reviewed the procedures for

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conducting these experiments, observed the Penn State Reactor Operators manipulating fuel for various core configurations. The inspector also observed GPU Nuclear SR0's/FHSR0's take count rate measures, perform Keff calculations, and plot 1/m (reciprocal count rate ratios) versus core configuration changes. The inspector performed independent calculations of 1/m and K eff to confirm operator calculation Based on observations of training provided by Penn State personnel, review of training materials, and discussions with trainees, the inspector detennined that the operators were provided experience in identifying the effects of sub-critical multiplication and changes to safety margins for various core configuration The inspector had no further questions on this ite .0 Pre-Operational Testing of Boronometer On July 31, 1985, the inspector witnessed pre-operational testing of a recently installed boronometer. The boronometer is designed to provide a digital readout of reactor coolant system (RCS) boron concentration over short time periods (e.g. every 10 secs.) so as to provide a more rapid indication of a boron dilution even The testing performed under Unit Work Instruction (UWI)

4370-3558-84-P265, was to verify RCS flowpath through the boronometer, provide an in-service leak test of the installed components, and compare boronometer results with the most current RCS chemistry result Prior to the test, the inspector reviewed the Test Procedure and determined that the procedure had received the appropriate reviews including those by the NRC, the licensee's Quality Assurance Department, and the approval to commence work was authorized by a Senior Reactor Operator. The inspector determined that the Quality Control Hold and

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Witness Points were appropriate to ensure the test criteria were met, and

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that the pre-requisites, limits and precautions were met to ensure that there were no conflicts with other plant operations. The inspector examined the boronometer, p essure gauges, and flow indicator; SNS-AY-203, SNS-Pl-203/Cf 30-005, SNS-FlS-203, respectively, to determine i if they had the appropriate ranges for the measured parameters, and if i they had been recently calibrated. The inspector checked instrument calibration stickers against calibration data sheets.

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The inspector also discussed the conduct of test with the Supervisor, Start-Up and Test. In conjunction with this discussion, the inspector

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examined the Test Engineer's daily log and examined the training and qualification records of site Test Engineers. The inspector verified ( that the test engineer responsible for pre-op testing the boronometer met the education / experience requirements of ANSI N18.1-1971 and of licensee procedure 4000-ADM-3055.0 During the test the inspector observed that the test engineer performed the test in accordance with the procedure and quality control personnel verified valve line-up, performed an in-service (visual) leak test of i fittings, and verified that the test package was in order. The inspector '

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made independent calculations verifying that the average of five boron concentration readouts were 'sithin 1% of boron chemistry results of the most recent RCS sampl No violations were identifie .0 Routine Health Physics and Environmental Review Plant Tours The NRC site radiation specialists performed routine plant inspection tours. These inspections included all radiological control points and selected radiologically controlled areas. Items inspected included:

4 -- Access control to radiologically controlled areas

-- Adherence to Radiation Work Permit (RWP) requirements

-- Proper use of respiratory protection equipment

-- Adherence to radiation protection procedures

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-- Use of survey meters, including personnel frisking techniques f

-- Cleanliness and housekeeping conditions i

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-- Fire protection measure '

Measurement Verification

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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 environmental air and water sampling analyses. Licensee data was consistent with the NRC measurement The inspector reviewed the radiological controls applied within the plant. Appropriate postings, surveys, and controls were observed during inspector tours during day-shift and off-shift hour No violations were identifie Reactor Building Entries The inspectors monitored RB entries conducted during the inspection period. The inspection activities included review of selected documents and direct observations of RB entries. The following items were verified on a sampling basi The RB entry was properly planned and coordinated to assure that task implementation including adequate As Low As Is Reasonably Achievable (ALARA) review, personnel training, and equipment testin ,

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-- Radiological precautions were planned and implemented including the use of a RWP and specific work instruction . Specific procedures were developed for unique tasks and were properly implemente Entries 645 through 667 were conducted during this inspection perio No violations were identified, d.- Reactor Building Entry A radiation specialist toured the reactor building on July 31, 1985'

(Entry 664) t1 observe radiological conditions and inspect the west rail of the ~nd service crane. Conditions were observed on the 305 foot and 347 foot levels and at the upper surface of the "A" D-rin No unacceptable conditions were observe The inspector noted that the metal protrusion referenced in NRC Inspection Report. 50-320/85-12 and located on the west rail of the RB service crane had been removed by grinding, Locked High Radiation Area On July ll, 1985, GPUN verbally notified the NRC that an improper entry was inade to a locked high radiation area (LHRA) at the licensee's Interim Solid Waste Storage Facility (ISSWF). It was reported that a health physics technician had entered the LHRA by scaling-the locked gate at the entrance to the area rather than properly obtaining and using the key to the locked gat Radiological Awareness Report 85-069 was issued by the licensee and corrective action, including a critique, counseling, and

~ disciplinary action, was accomplished. A notice of violation will not be issued because the event (1) was licensee identified, (2)

fits Severity Level IV or V, (3) was reported, (4) was corrected, and (5) could not have been prevented by corrective actions for a previous violation. The inspector had no further questions on this rette Radioactive Material Shipments (1) The NRC site radiation specialists inspected selected TMI-2 radioactive material shipments during the inspection period to verify the items listed belo The licensee had complied with approved packaging and shipping procedure The licensee had prepared shipping papers, which certified that the radioactive materials were properly classified, described, packaged, and marked for transpor .

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-- The licensee had applied warning labels to all packages and had placarded vehicle The licensee had controlled the radioactive contamination and

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dose rates below the regulatory limit Inspector review of this area consisted of (1) examination of shipping papers, procedures, packages, and vehicles, and (2)

performance of radiation an'i contamination surveys of shipments on July 18, July 24, and July 26, 198 No violations were identified with respect to the items inspecte (2) The licensee and NRC were n(tified by the burial site operator on July 23, 1985 that an incoming inspection shipment of 104 barrels of radioactive waste had shown that three barrels were apparently misclassified. This shipment is the subject of a separate inspection (50-320/85-15) and will be reported accordingl Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operation (hardware or programatic) that could lead to violations if left uncorrected. Inspector follow items are addressed in paragraph Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On August 7,1985, the inspector sumarized the inspection findings to the following personnel at the exit meeting:

J. C. Auger, Licensing Engineer J. A. Renshaw, Manager, Special Projects W. C. Craft, III, Manager, Field Operations J. J. Byrne, Manager, Licensing, TMI-2 R. E. Rogan, Director, Licensing and Nuclear Safety J. F. Flowers, Lt., Site Security Force J. Hildebrand, Radiological Controls Director, TMI-2 S. Levin, Site Operations Director At no time during the inspection was written material provided to the licensee by the TMIP0 staff except for procedure reviews pursuant to Technical Specification 6.8.2.