IR 05000320/1985019
| ML20198H550 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/23/1986 |
| From: | Bell J, Dan Collins, Cook R, Cowgill C, Moslak T, Myers L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20198H518 | List: |
| References | |
| 50-320-85-19, NUDOCS 8601310052 | |
| Download: ML20198H550 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/85-19 Docket No. 50-320 License No. DPR-73 Priority
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Category C
Licensee:
GPU Nuclear Corporation P.O. Box 480
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Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania Inspection Conducted: November 9, 1985 - December 31, 1985
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3/Mh Inspectors:
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8/ Epok, ior R side Inspector (TMI-2)
ptesigned
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T. MoilaTc, Retibent I7rspectD (TMI-2)
date signed 1 D '\\ h f3 0 '
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dat'esig/st ned J
1, Senio adi'at1on Specialist
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D.Colins, Rad /ationSpecialist date signed
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/k3/06 L'.'Myers,padiation/ Specialist ddte signed Approved By:
MN lh3 ff(,
C.Cowgill,gief,TMI-2ProjectSection date signed Inspection Summary:
Areas Inspected: Routine safety inspection by site inspectors of plant operations (long term shutdown) including assessment of the licensee's implementation of the ALARA concept; defueling operations; evaluation of a defueling platform fire; toxic gas samplirg; observation and/or participation in the licensee's annual emergency exercise; health physics and environmental reviews; radiological shipments; and review of an unplanned airborne contamination incident. The inspection involved 457 inspection hours.
Results:
No violations were identified.
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8601310052 860124 PDR ADOCK 05000320 G
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DETAILS 1.0 Ongoing Recovery Operations f
Routine Plant Operations Inspections of the facility were conducted to assess compliance with the
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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
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i maintenance / modification viewpoint, including plant cleanliness, control l
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 j
keeping practices; radiological controls, and security plan
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implementation.
Random inspections of the control room during regular and backshift hours were routinely conducted. The Shift Foreman's Log and selected portions of the Control Room Operator's Log were reviewed for the period November 9 through December 31, 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
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Sheets.
l Operability of components in systems required to be available for i
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 observed.
No violations were identified.
2.0 Licensee Action on Previously Inspection Findings
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(0 pen) Inspector Follow Item (50-320/84-04-04): The licensee's implementation of the As-Low-As-Is-Reasonably-Achievable (ALARA) concept
was assessed in Inspection Report 50-320/84-04.
One identified weakness concerned training of licensee and contractor personnel at the planning and direction level whose duties may have a significant effect on ALARA implementation. The licensee established two training courses in response to this identified weakness: one for
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j management and one for engineers. The inspector attended one part of the engineers' training course. The instructor was well prepared and the material presented was appropriate. The inspector will review the training course for managers during a future inspection.
I 3.0 Defueling Operations On November 18, 1985, the licensee modified the defueling strategy from that of pick and place to that of removing interferences by cutting tangled fuel rods. Progress has been steady but slow due to debris i
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interfering with tool manipulations and the difficulty in separating fused end fittings.
A problem developed in late November when undissolved boron in the hydraulic system plated out on system filters disabling its operation.
The problem was corrected by flushing the system and replacing the hydraulic fluid with an alternate, approved borated hydraulic fluid.
Following an extensive analyses of airborne sample data and radiation surveys, the licensee determined that the concentration of airborne radioactive particulates at the defueling work platform is less than 0.1 MPC. Based on this analysis, the licensee determined that the wearing of respirators would no longer be necessary for specific defueling tasks.
The removal of respirator requirements is expected to improve worker communication and comfort, thereby increasing worker efficiency.
It is expected that this will result in an overall reduction in occupational exposure.
In mid-December, the filling of fuel canisters, using pick and place methods, resumed. Two canisters were initially filled with end fittings, control rod spiders, and small pieces of partial fuel assemblies.
Filling of the third canister began on December 14. At about 7:30 PM on the 14th, with the canister about half-filled, an end fitting was inserted into the canister and appeared to jam before being fully lowered into the canister. Attempts were made to remove it by grappling it with a J-hook attached to the one ton jib crane. When lifting with the crane, the canister positioning system (CPS) canister sleeve lifted out of the CPS and dropped about 11 feet to the debris pile. On December 15, after special training for the evolution, the canister and sleeve were retrieved using the 5 ton service crane and were successfully reinstalled in the CPS. The licensee's corrective actions to prevent recurrence included procedural changes that require verification of engagement of the sleeve locking mechanism by close video examination.
In addition, the procedures will require use of a load cell during crane operations having the potential to exert an unplanned excessive lifting force. On December 17, the jammed end fitting was freed. A video survey was performed of the canister, sleeve, and CPS; no major damage to these components was identified. Additionally, the licensee stopped any further loading of fuel material into this canister.
On December 19, 1985, operators initially loaded broken fuel rods into a debris bucket. These buckets will be placed inside the fuel canisters.
Use of these buckets should increase canister loading efficiency.
On December 31, 1985, defueling operations using the Vacuum System began.
The system uses an air driven submerged pump to pick up a slurry of fuel debris and water. Debris ranging from about 140 microns up to fuel pellet size are collected in a knockout canister and smaller particles ranging in size down to 0.5 microns are removed from the effluent fluid stream by filter canisters. The knockout and filter canisters also serve as the storage and shipping containers for the debris. The initial fill rate of the knockout canister was approximately 1 - 2 lbs. per minute.
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During filling, canister weight was measured by a hydraulic weight monitoring system. Operators encountered problems obtaining consistent knockout canister weights with this system.
Final determinations of
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weight will be made using a Dillon load cell. No overloading of canisters resulted from this problem.
- To date, the licensee has completely filled two fuel canisters and has
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partially filled two others using pick and place methods. A knockout canister has been partially filled using the Vacuum System.
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The inspector observed these activities and determined that the licensee conducted in-vessel operations in accordance with the provisions of the
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Safety Evaluation Report and procedures approved by the NRC staff. No violations were identified.
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4.0 Defueling Platform Fire:
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A small fire occurred December 5, 1985, on the defueling work platform in
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the Unit 2 Reactor Building when a "Kimwipe" in close proximity to a
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light bulb was ignited shortly after the light was turned "on."
A small amount of flame and smoke resulted and a hole about one foot in diameter was burned in the Herculite under the light before the light was
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de-energized and the fire extinguished. Although the consequences of the fire were minor, examination of the event identified a need for
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evaluation of equipment, procedures and training for work on, and in support of, the defueling work platform. The licensee initiated
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Incident / Event Report No.85-114 and is in the process of evaluating the need for and implementing improvements. The licensee's action on IER
,85-114 will be followed by the inspector.
t (50-320/85-19-01)
5.0 Toxic Gas Sampling During a routine tour of plant areas, the inspector identified an unopened container of a highly toxic substance, methylene bisphenyl isocyanate (MDI) stored atop 55-gallon drums containing chemicals used
for decontamination operations (Freon and phosphoric acid). This material was stored on the North side of the ground level passageway,
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exterior to the Auxiliary Building, near Security Doors No. 8 and No. 9.
The area does not contain structures, systems, or components important-to-safety; however, storage of this chemical near the Security Doors presents a potentially hazardous situation.
Should a fire or chemical reaction occur, airflow could draw toxic fumes into important-to-safety plant areas.
The inspector notified the Unit 2 Fire Protection Engineer of this situation. The engineer stated that this situation was previously identified during a recent housekeeping inspection (4240-85-0412) and that corrective action was being taken. The inspector confirmed that corrective action was taken within one week following the inspection.
i The inspector also notified the site industrial hygienist regarding
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monitoring and controls when personnel use this chemical.
The chemical
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is used as a urethane-foam generating agent (packing material) for
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stabilizing solid radwaste objects in 55-gallon shipping drums.
Small amounts (about 4 cups full) are used, to fill approximately one drum per month.
The industrial hygienist showed the inspector an Industrial Hygiene Sampling Record regarding airborne sampling data when personnel were using the chemical.
From a review of the record, the inspector determined that the sampling data was incorrect and incomplete. The following errors were identified:
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An arithmetic error was made in computing the sampling time. A time of 8 minutes (vice 6 minutes) was determined from Sample-Time-On 1442, Sample-Time-Off 1448.
Correcting this error would increase the final airborne concentration value.
From the data presented, an airborne concentration of 0.024 ppm was
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determined. This value is greater than the Ceiling Threshold Limit Value of 0.020 ppm. The Ceiling Value is the airborne concentration that should not be exceeded as roommended by the American Conference of Governmental and I-dustrial Hygienists. Though this value does not represent a breauhing zone analysis (the sample was taken near the source), no follow-up sampling was taken in the breathing zone to determine actual concentrations personnel may be breathing.
Failure of the licensee to obtain accurate determinations of MDI airborne concentrations is a safety concern of the inspector.
(50-320/85-19-02)
Liuensee progress in obtaining representative samples will be examined in a future NRC inspection.
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6.0 Emergency Drills On November 13, 1985, a practice emergency drill was conducted by the licensee's Emergency Preparedness Department. The emergency drill involved a simulated accident at the Unit I reactor site. The TMIP0 NRC staff responded to the emergency drill and supported Unit 1 NRC staff as delineated in the TMIP0 Emergency Plan. The Emergency Operations Facility (E0F) was manned during this practice drill.
On November 20, 1985, the annual emergency preparedness exercise was conducted by the licensee. Again, the TMIPO staff participated and responded as described in the NRC Emergency Plan.
The simulated event occurred as a Unit 1 accident but during the exercise, Unit 2 was confronted with simulated personnel injuries. NRC Region I implemented the required supplemental emergency response plan for the exercise.
The NRC conducted a routine safety inspection of the annual emergency preparedness exercise. There were no items of noncompliance identified.
The NRC concluded that the licensee's response actions for this exercise were adequate to provide protective measures for the health and safety of the public.
The findings are documented in NRC Inspection Report No.
50-289/85-2 _ _
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i 7.0 Health Physics and Environmental Review a.
Plant Tours
The NRC site radiation specialists performed plant inspection tours
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which included all radiological control points ard selected
radiologically controlled areas. A backshift tour was conducted on December 27, 1985.
I Among the items inspected were:
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Access control to radiologically controlled areas Adherence to Radiation Work Permit (RWP) requirements
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Proper use and storage of resoiratory protection equipment I
Maintenance and inspection of radiological instruments
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Adherence to radiation protection procedures
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Use of survey meters and radiological instruments
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Cleanliness and housekeeping Fire protection.
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The inspector reviewed the application of radiological controls within the plant, the laundry / respirator facility, and the Interim
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Solid Waste Staging Facility. The inspector reviewed the Radiological Controls Field Operations logbook for the period i
November 9 through December 31, 1985.
Notations in the logbooks were appropriate to the conditions, were demonstrative of attention
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to detail and were properly made. Departmental management initials i
indicate frequent management review.
No violations were identified.
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Radiological Shipments
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The inspector (s) examined selected shipments of waste and radioactive materials from the site for some of the following:
External vehicle contamination
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External package contamination
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Radiation levels at vehicle surfaces, two meters and inside cab Radiation levels at package surfaces
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J Verification that recipients possess the appropriate license
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The licensee had applied labels to all packages and had
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placarded vehicles
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The licensee had prepared shipping papers, certifying that the
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materials were properly classified, described, packaged and marked for transport l
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The licensee had controlled the radioactive contamination and j
dose rates below the regulatory limits.
During the period, inspections were performed on November 12 (2 each),18,20,22,27, December 2 (3 each), 5 (3 each), 9 (2 each),
j 10, 11, 13, 18, 19, 20, 1985.
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Measurement Verification
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Measurements were independently made by the inspector using NRC
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radiological equipment. These measurements were made in verifying the quality of licensee performance in radioactive material shipping, radiation and contamination surveys, and onsite environmental air and water analyses, d.
Reactor Building Entries
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The inspector monitored reactor building (RB) entries during the inspection period. The inspection activities included review of
l selected documents and direct observations of RB entries. The l
following items were verified on a sampling basis.
The RB entry was properly planned and coordinated to assure
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j that task implementation included adequate ALARA review, personnel training, and equipment testing
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Radiological precautions were planned and implemented, l
including the use of an RWP, specific work instructions, alarming self-reading dosimeters, breathing zone air samplers, and specific work instructions.
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Special procedures were developed for unique tasks and were l
properly implemented.
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Entries 735 through 781 were conducted during this period.
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No violations were identified, e.
Records Review I
The inspector reviewed selected radiological records during the period to assure the accuracy and completeness of the licensee j'
documentation of occupational exposure. The records reviewed were selected from the following:
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Radiation Work Perm ts (RWPs)
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Dosimetry Investigative Reports
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Incident Evaluation Reports
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Radiological Awareness Reports
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Dosimetry Exceptions Reports
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No violations were identified.
f.
Additional Reviews The inspector reviewed various licensee records and periodic reports concerning the radiological controls program, including current data and trends in such areas as manrem per RWP hour, decentamination
status, skin contaminations, environmental monitoring, radiological
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events, whole body counting, training, dosimetry, shipments, progress toward achievement of goals and objectives, storage tank
radioactivity content, airborne radioactivity, and manrem by work
category; effluent releases, including sump releases and sources of sump contamination; and the cumulative dose (manrem) to all plant personnel.
No violations were identified.
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g.
An unplanned Contamination Incident
On December 19, 1985, some clean areas in the Auxiliary Fuel Handling Building (AFHB) became contaminated durino planned decontamination activities. The contamination resulted from scrubbing and spraying during high pressure wash down of the "A"
Decay Heat Vault (ADHV) walls.
Six workers received some internal contamination during this event. The highest total internal
contamination for one individual was 4.9 MPC-hrs.
Five workers were found contaminated while frisking at the Health Physics Control Point 2.
The area these individuals had been working in was immediately surveyed and found contaminated. The affected areas were isolated and appropriately marked. The licensee determined that the decontamination activities associated with scrubbing and spraying in the ADHV had caused the spread of contamination. Contaminated spray spread by airborne pathways down the corridor of the 281' elevation in the AFHB. The work was
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terminated and a critique was conducted to discuss the event. The
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licensee identified the following corrective actions as a result of this critique:
(1) decontaminate and survey to recover the contaminated areas; (2) enclose the open hatch of the ADHV; (3) use a High Efficiency Particulate Filter Unit (HEPA) to draw air out of the vault from a penetration through an opening in the vault enclosure; (4) promptly perfonn whole body counting on the individuals working in the vicinity. The corrective actions were completed and the work activity resumed af ter installing and testing
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the ventilation and vault enclosure. The inspector determined that i
the corrective actions were appropriate and were completed sufficiently to resume the work activities.
The assignment of i
intakes to the workers' records will be reviewed in a later inspection.
(50-320/85-19-03)
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j The inspectnr reviewed procedures, surveys, Radiation Work Permits
(RWPs), the Incident / Event Report (IER), Unit Work Instructions, and the ALARA review pertaining to the ADHV work. The inspector
d interviewed licensee personnel that were involved with the
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decontamination work activities in the ADHV.
It was noted that a i
special precaution was ambiguously written on the revised RWP
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concerning vault ventilation and that work had proceeded without clarifying the RWP precaution. The inspector expressed concern that j
workers were performing tasks as they interpreted the instruction i
instead of questioning potentially confusing or incorrect
instructions. The inspector noted that these practices could lead to future problems. The licensee acknowledged the inspector's
j concerns. The inspector will review RWP and ALARA review practices in future inspections.
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8.0 Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in
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j the licensee's conduct of operation (hardware or programmatic) that could lead to violations if left uncorrected.
Inspector follow items are addressed in paragraphs 2, 4, 5 and 7.
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9.0 Exit Interview l
The inspectors met periodically with licensee representatives to discuss i
inspection findings. On Jar.uary 7,1986, the inspector summarized the
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inspection findings to the following personn:1 at the exit meeting:
I L. Balint, Industrial Hygienist J. Byrne, Manager, TMI-2 Licensing
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W. Craft III, Manager, Radiological Controls Field Operations i
C. Dell, Licensing Engineer J. Hildebrand, TMI-2 Radiological Controls Director S. Levin, Site Operations Director
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A. Miller, Manager, Plant Operations
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At no time during the inspection was written material provided to the licensee by the TMICPD staff except for procedure reviews pursuant to Technical Specification 6.8.2.
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