IR 05000320/1986005

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Safety Insp Rept 50-320/86-05 on 860401-0509.No Violation Noted.Major Areas Inspected:Plant Operations (long-term Shutdown),Including Defueling Operations & Licensee Action on Previous Insp Findings
ML20195C207
Person / Time
Site: Crane Constellation icon.png
Issue date: 05/20/1986
From: Bell J, Dan Collins, Cook R, Cowgill C, Moslak T, Myers L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20195C197 List:
References
50-320-86-05, 50-320-86-5, NUDOCS 8605300169
Download: ML20195C207 (10)


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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/86-05 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: April 1, 1986 - May 9, 1986 Inspector.

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Rf C Senior ei t Inspector (TMI-2)

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T? Moslak, Resident Inspector (TMI-2)

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ll,' Jenior Radiati6n Specialist date Mgned 4 /f!8[

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D. Collins, Rad tion Specialist date signed

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yers, Radiation Specialist dite ligned Approved By:

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.N !86 C. Cowgill, (hjef, TMI-2 Project Section date signed Inspection Suninary:

Areas Inspected:

Routine safety inspection by site inspectors of plant operations (long term shutdown) including defueling operations; review of of reactor vessel water cleanup program; a dropped (empty)gs; implementation licensee action on previously identified inspection findin knockout canister incident; 1985 occupational exposure report; environmental surveys; shipments of radioactive materials; operations in the reactor building; and records associated with the radiological control program.

Results: No violations were identified.

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l DETAll.S 1.0 Ongoing Recovery Operations Routine Plant Operations

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Inspections of the facility were conducted to assess compliance with the requirements of the 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 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 April 1 i

through May 9, 1986. 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 Sheets.

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

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planning meetings. Shif t staffing for licensed operators, non-licensed

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personnel, and fire brigade members was observed.

No violations were identified.

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2.0 Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-320/85-21-03): Misadjustment of reactor building defueling platform area monitor.

Inspector review of requirements applicable to the area monitor, including licensee procedures, and inspector interviews of Radiological Controls Fields Operations and Instrumentation and Control technicians and supervisors did not identify any violations. The actions taken by the licensee, including counseling of technicians and modification of the surveillance program, should prevent future occurrences of instrument misadjustment.

The inspector had no further questions on this matter.

3.0 Defueling Operations The licensee continued defueling operations during the reporting period.

By the end of the period, a total of 42 defueling canisters had been

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transferred from the reactor vessel to the spent fuel pool storage racks.

The total weight of the fuel debris and structural material transferred out of the reactor vessel is about 50,170 pounds. The bulk of the

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material which has been placed in the fuel canisters has been done using the hydraulically operated spade bucket discharging directly into the fuel canister.

In mid-April, the licensee suspended defueling operations. Most of the small loose rubble amenable to defueling using the spade bucket tool was substantially depleted. The remaining accessible fuel is either in the form of fines or pieces which would require some sizing such as cutting or shredding before they could be placed into the defueling canisters. Vacuum defueling and sizing operations require good underwater visibility which has not been available since the first of the year because of the biological growth.

Therefore, the licensee embarked on a program to destroy and control biological growth, including filtration to improve visibility. The program to control the biological growth consists of manually brushing and hydrolazing to remove the growths adhering to surfaces in the reacMr vessel and then batch treating the reactor coolant with hydrogen perox. S to kill the organism. The reactor coolant system will then be filtereu through diatomaceous earth filters to remove the dead organisms and enhance visibility.

During the reporting period, defueling operations were periodically observed by the Resident Inspector via closed circuit T.V. from the Defueling Coordination Center. On April 29, 1986, the licensee was engaged in hydrolazing and brushing the accessible surfaces inside the reactor vetsel to loosen adherent biological growth. The crew that was sent onto the work platform were not trained and/or experienced in the use of either the brush (with counter balance) or the hydrolazing tool.

The Fuel Handling Senior Reactor Operator (FHSRO), after consultation with the Group Radiological Control Supervisor, removed part of the crew to conserve exposure.

The FHSR0 was not aware that the crew was not trained in the use of the hydrolance or brush prior to the crew making an entry. Ultimately, at the direction of the FHSRO, attempts to hydrolaze were aborted using this crew and the hydrolazing tool was placed in storage.

The NRC has expressed concerns pertaining to the licensee assuring that an operator is trained and qualified on a specific task before being assigned to perform that task.

Therefore operator training being commensurate with assigned work evolutions is an item which will be followed during subsequent inspections.

(50-320/86-05-01)

4.0 Reactor Vessel Water Cleanup Lack of visibility due to microorganisms growing in the reactor vessel has hampered the defueling process. During the reporting period, the licensee stopped defueling operations to implement a program to remove the biological growth in the reactor coolant system (RCS) to improve water clarity. The program included the injection into the RCS of borated water treated with hydrogen peroxide to act as a biocide, recirculation of vessel water through a high pressure pump to kill microorganisms by a rapid pressurization /depressurization technique, and filtration to remove them from the reactor vessel. Growths on the internal walls of the vessel are being removed by water sprays and long

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handled brushes. The inspector witnessed various aspects of these operations.

On May 8,1986, the inspector witnessed the addition of a second batch of hydrogen peroxide to the RCS. Prior to the addition, the inspector reviewed the special operating procedure (4215-3525-86-143), safety analysis (4240-3525-86-0080), and supporting documentation, including switching and tagging order (9616), chemistry results, and the process instruction and data sheet (PID).

From this review, the inspector determined that the operation was being performed in compliance with applicable limits and precautions for primary plant operations and Technical Specification requirements. The inspector performed independent calculations to predict final RCS peroxide concentrations based on initial peroxide concentrations in the feed tank (SPC-T-4) and RCS, and determined that the estimated concentration (114 ppm) would not exceed the limiting concentration (200 ppm) as stated in the PID. The inspector determined that the feed tank was recirculated through three (3) volume changes to insure the representativeness of samples, and that the final chemistry of the feed met applicable criteria. Through reviews of controlled drawings, the switching / tagging order and the primary plant operating procedure (4210-0PS-3200.02), the inspector determined that the valve line-up was as required for the injection flowpath.

The inspector witnessed the startup of SPC-P-1B (initiating the addition), vessel water level increases as indicated by RC-LI-100 and RC-LI-102, and termination of the operation. Approximately 2300 gallons of 3000 ppm peroxide was added to the RCS.

Approximately three hours following the addition, the inspector observed an aberration in thermocouple (T/C) readings. The average of 31 T/C's indicated a drop in RCS temperature of about 5* F (81* F vice 86 F).

However, the inspector noted no change in temperature indication of the three Resistance Temperature Detectors (RTDs). The T/C stabilized at normal readings approximately six hours later. The cause of the change in T/C temperature is attributed to a transient chemical effect of the hydrogen peroxide on T/C materials.

Through review of radiochemistry data of samples taken subsequent to the peroxide additions, the inspector determined that no increase (crud burst) in radionuclide concentrations occurred in the RCS.

No violations were identified during the conduct of these operations.

The measures taken to control and remove the microorganisms from the RCS have been successful. Turbidit (nephelometric turbidity units)y has decreased from over 100 NTUs to approximately 30 NTUs, with a resultant increase in water clarity.

The next step in the treatment program will involve bleeding four 15,000 gallon batches of vessel water and replacing it with peroxide treated water.

In parallel with the bleeding and feeding, vessel water will be recirculated through diatomaceous earth filter ~

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5.0 Dropped Empty Knockout Filter Canister At 10:00 PM on April 30, 1986, an empty knockout filter canister (F-421)

became disengaged from its handling tool and fell approximately six (6)

feet coming to rest in its desired location in the Dewatering Station.

The canister was being transferred witnin the "A" Spent Fuel Pool from a decontamination bath to the Dewatering Station using a long handled tool

attached to the Fuel Handling Building Crane.

Initial inspection identified no damage to the canister or storage rack. The center point grapple of the handling tool is being evaluated by the licensee to determine the cause of the premature disengagement. The inspector is following licensee actions that are being taken to prevent a recurrence.

(50-320/86-05-02)

6.0 Health Physics and Environmental Review a.

Plant Tours The NRC site Radiation Specialists performed plant inspection tours which included all radiological control points and selected radiologically controlled areas. Among the areas inspected were:

the Auxiliary and Fuel Handling Buildings; EPICOR-II; Radiochemistry Laboratories; South East Acres radioactive waste storage facility; Solid Waste Storage Facility; Interim Waste Storage Facility; Respirator Cleaning and Laundry Facility; and, the Radiological Controls Instrument Facility.

Among the items inspected were:

Access control to radiologically controlled areas

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Adherence to Radiation Work Permit (RWP) requirements

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Proper use and storage of routinely used respirators and

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associated equipment Maintenance and storage of emergency respiratory equipment

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Adherence to radiation protection procedures

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Use of survey meters and other radiological instruments

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Cleanliness and housekeeping; and

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Fire protection.

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The inspectors reviewed the application of radiological controls during normal hours, on backshifts, and on weekends. Backshift inspections were performed on April 4, 5, 14, 17, 19, and 27, 1966.

Log books maintained by Radiological Controls Field Operations to record activities in the Reactor Building and the balance of plant were reviewed. All notebooks contained appropriate entries and showed evidence of frequent management review.

No violations were identified.

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Radiological Shipments

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.The inspectors examined shipments from the site on April 2 and 4, 1986 for the following:

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External vehicle contamination

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External package contamination

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External radiation levels at vehicle surfaces, two meters away

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.and inside the tractor cab Radiation levels at package surfaces

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Verification that the recipient holds an appropriate license

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The proper preparation of shipping documents certifying the

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materials had been properly classified, described, packaged and marked; and Appropriate package markings, placards placed on vehicles.

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No violations were identified, c.

Measurement Verifications Measurements were made by the inspector using NRC-calibrated radiological equipment. These measurements were made in verifying the quality of licensee performance in radioactive material shipping, radiation and contamination. Additionally, the inspectors reviewed the licensee's measurements of water discharges by comparison to results obtained from EPA samples.

No violations were identified.

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Reactor Building Work The inspectors monitored the licensee's conduct of reactor building (RB) work during the inspection-period. The RB remains a locked high radiation area, requiring an RWP for entry. The entry into the RB also requires the use of specific work instructions.

The following were reviewed by sample during the month:

The RB entry was planned and' coordinated so as to ensure that

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ALARA review, personnel training, and equipment testing had been conducted.

Radiological precautions were planned and implemented;

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including: use of an RWP; locked high radiation access authorization; specific work instructions; alarming self-reading dosimeters; breathing zone air samplers.

Individuals making entries into the RB had been properly

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informed, trained and understood emergency procedure.

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Unique tasks were performed using specifically developed

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procedures, and mock-up training had been conducted where warranted.

Entries 871 through 909 were conducted during the reporting period.

The Reactor Building entries have been conducted around the clock for the most part. Defueling activities (e.g. pick and place, canister transfer to the Fuel Handling Building) have been routinely performed by 4 - 5 person teams working four-hour shifts. Two to three person teams have worked on the defueling platform when adding chemicals to the reactor vessel or when operating the filter and pressurizing pump.

No violations were identified.

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Records Review The inspector reviewed selected radiological records during the period to assure the accuracy and completeness of the licensee's documentation of occupational exposure.

The records reviewed included Radiation Work Permits (RWPs), Dosimetry Investigative Reports Incident Evaluation Reports, Radiological Awareness Reports, and Dosimetry Exceptions Reports.

No violations were identified.

The inspector also 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, decontamination status, skin contaminations, environmental monitoring, radiological 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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Review of Reports Required by Technical Specifications The licensee submitted its calendar year 1985 report of occupational radiation exposures and the airport traffic report to NRC Region I on February 25, 1986.

These reports are required by Technical Specification 6.9.1.5.

Following is a tabulation of exposure incurred during 198 n-

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TOTAL OCCUPATIONAL EXPOSURE 1985 492 Station Personnel 210.896 manrem 19 Utility Personnel

.440 manrem 677 Contractor Personnel 594.741 manrem 1,188 Personnel 806.077 manrem Special Maintenance 305 Station Personnel 63.484 manrem 6 Utility Personnel

.165 manrem 569 Contractor Personnel 522.288 manrem 880 Personnel 585.937 manrem It is noted that the data given in this report has been taken from self-reading dosimeter records representing data for work in radiation work permit areas. Special Maintenance comprised 73% of the total exposures. Special Maintenance at TMI-2 included these activities:

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Reactor Building Decontamination 2.

Reactor Building Dose Reduction 3.

Reactor Systems Disassembly 4.

Reactor Defueling 5.

Primary Coolant Decontamination 6.

Auxiliary and Fuel Handling Building Decontamination The airport traffic report is a breakdown of aircraft movements at the Harrisburg International Airport. Accounting of the overflights of large aircraft is a requirement for information collection with respect to the potential for impact on containment structures. The report tabulates 22 aircraft weighing more -than 200,000 pounds of the total of 162,713 aircraf t which used Harrisburg in 1985.

The inspector determined the reports to be acceptable and had no further questions.

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Radiological Instruments

.1 Calibration Program Radiological Controls Procedure 9000-QAP-4220.01, " Quality Assurance Program for Radiological Instruments," Revision 2 states that Radiological Controls Field Operations is responsible for submission of instruments to the calibration facility.

Procedure 9000-ADM-4220.01, " Portable Instrument Accountability and Recall System," Revision 1-02 states that each individual allowed to assume responsibility for an instrument shall remove an instrument from service and tag it for return to the instrument shop on or before its calibration due dat.

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During tours of the facilities, the inspector noted on April 24, 1985 that an instrument system used to measure radiation levels in the annulus area between the Reactor and Fuel Handling Buildings had passed its calibration due date. Licensee representatives stated that the instrument had not been used after the expiration of the calibration. The responsible radiological engineer had not instructed Field Operations personnel to remove the instrument for calibration. The instrument was removed on April 29 and returned to the instrument shop.

On April 28, 1986, the inspector noted that a tritium air sampler was in use in the fuel storage pool area and its flow calibration had expired on April 25, 1986.

The licensee removed the instrument from service and replaced it with a calibrated instrument.

The instruments in the above cases were properly mentioned in the recall listing sent to Field Operations and to Radiological Engineering. The three month calibration period listed for the use of instruments is within the one year recommendation of ANSI N323-1978, " Radiation Protection Instrumentation Test and Calibration."

Because of the above instances, the conduct of recall of instruments will be followed by the inspector.

(50-320/86-05-03)

.2 Noble Gas Monitor Calibration A radiation specialist observed the calibration of a continuous air monitor to be used at the defueling work platform in the reactor building (RB) to monitor for radioactive gases that may be released as a result of core characterization (e.g. " core boring")

evolutions. Two Instrumentation and Control technicians performed the calibration ir, accordance with the written calibration procedure. The calibration was accomplished at the RB purge duct area on the 328' level of the auxiliary building utilizing a flask of krypton-85 and four Marinelli flasks, each filled from the flask so as to contain different concentrations of krypton-85. A satisfactory calibration curve was constructed from the four calibration points.

No violations were identified.

.3 High Reading Thermoluminescent Dosimeter (TLD)

As described in Inspection Report 50-320/84-17 (October 1984), the licensee investigated a TLD reading indicative of a 28.8 rem low energy beta dose.

Based on the results of the investigation, the licensee determined that the worker who had used the TLD did not receive the 28.8 rem dose. The licensee has continued its investigation in an attempt to understand the cause of the high reading and determine any steps that may be appropriate to prevent or mitigate the effects of similar events in the futur _

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Studies, including both destructive and non-destructive tests on the TLD, were performed by the licensee and the TLD supplier. Based on the results of these studies, the licensee has taken various actions

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of the studies and licensee actions confirm the licensee's

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conclusions and indicate that appropriate steps are being taken by the licensee to maintain the high quality of its personnel monitoring program.

The inspector had not further questions on this matter.

7.0 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 left uncorrected.

Inspector follow items are addressed in paragraphs 3.0, 5.0 and 6.0.

l 8.0 Unresolv_ed Items Unresolved items are findings about which more information is needed to ascertain whether they are violations, deviations, or acceptable.

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Unresolved items are addressed in paragraph 2.

i 9.0 Ex_it Interview l

The inspectors met periodically with licensee representatives to discuss

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inspection findings. On May 14, 1986, the inspector summarized the

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inspection findings to the following personnel at the exit meeting:

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J. Byrne, Manager, TMI-2 Licensing D. Cowser Defueling Operations Planner W. Craft, Manager, Radiological Controls Field Operations

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C. Dell, Licensing, Technical Analyst l

S. Levin, Director, Site Operations R. Rogan, Director, TMI-2 Licensing and Nuclear Safety i

l M. Slobodien, Manager, Radiological Engineering At no time during the inspection was written material provided to the l

licensee by the THICPD staff except for procedure reviews pursuant to l

Technical Specification 6.8.2.

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