IR 05000320/1986008

Safety Insp Rept 50-320/86-08 on 860612-0718.Violation Noted:Inservice Insp Program Not Established to Demonstrate Operational Readiness of Category B & C Valves

ML20203K405
Person / Time
Site:	Three Mile Island
Issue date:	08/06/1986
From:	Bell J, Dan Collins, Cowgill C, Moslak T, Myers L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203K398	List: IR 05000320/1986008 ML20203K394 ML20203K402
References
50-320-86-08, 50-320-86-8, NUDOCS 8608200285
Download: ML20203K405 (9)

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U. S. NUCLEAR REGULATORY COMMISSION Report No. 50-320/86-08 Docket No. 50-320 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 C n u ed: Jun L2,1986Nguly 18,1986 Inspectors: \ n T. Moslak, Retident Inspect 3r (TMI-2)

T/1/ E date s/lgned

'Mm + %29-Byll,SeniorRadiationSpecialist

.elilB s

'date 'si gned

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• 9 i N Ridiation Specialist date . signed D.nw Collins,N wa > e/Ilab

/ ijers,fRadiatyn Specialist dite' signed Approved By: fxJdE KfG[f6 C.CoWgilQhief,TMI-2ProjectSection date signed Inspection Summary:

Areas Inspected: Routine safety inspection by site inspectors of plant operations (long term shutdown) including core stratification sampling, implementation of an In-Service Inspection Program for Type B and C valves, radiological shipments, control of contaminated tools, radiation worker training, and licensee actions on previous inspection finding Results: One violation was identified in that an in-service inspection program was not implemented as required (paragraph 2.0).

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8608200285 860914 PDR G

ADOCK 05000320 '

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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 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 r security plan implementatio ,

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 June 12 through July 18, 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 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 determined to be adequat No violations were identified.

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2.0 Licensee Action on Previous Inspection Findings (Closed) Unresolved 50-320/86-06-04 In-Service Inspection Program, Subsequent to a meeting on May 6, 1986, between the NRC and licensee representatives, the licensee established a formalized In-Service Inspection Program to determine the operational readiness of Category B and C valves in safety related systems. This program was to be initially .

established in response to an NRC letter dated April 27, 1981, from the Director, TMI Program Office, which stated, in part, that,

" Category B and C valves in safety related systems, in service, should be exercised at least once per 92 days where practical to determine their operational readiness. Relief from the test requirements for Category B and C valves in safety related systems specified above will have to be submitted on an individual valve basis."

l The delay of approximately five years to implement the testing i requirement represents a weakness within the licensee's organization to

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. incorporate regulatory requirements into its operations. As such, this inaction is contrary to the requirements of 10 CFR 50 Appendix B, Section XI, Test Control, which states, in part, l

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"A test-program shall be established to assure that all-testing required to demonstrate that... components will perform satisfactorily in service is identified and performed in accordance

with written test procedures which incorporate the requirements and acceptance limits..."

This failure to establish the ISI program as required is a violation.

Althcugh there was not a formalized ISI program, operability has been demonstrated for most valves _on a less frequent basis by confonning with requirements listed in the Technical Specifications / Recovery Operations

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Plan or as part of periodic operational / maintenance checks of plant systems. 'Following implementation of the ISI program, operability was

, confirmed for all valves per the requirements of the ASME' Boiler and 3 Pressure Vessel Code,Section XI. - As such, the failure to formally test the operational readiness of Category B and C valves during the period April 27,1981 through May 6,1986, is considered to have minor safety significanc However, the failure to incorporate regulatory requirements into plant operations in a timely manner represents a breakdown of administrative controls; specifically, inter-departmental communications. The actions

taken by the licensee to improve administrative controls, to assure that t

regulatory requirements are implemented, will be examined in future NRC

inspections. (320/86-08-01)

(Closed) Inspector Follow Item 50-320/86-06-05 Review AMS-3 training for technicians and replacement and maintenance of AMS-3 filter holder 0-ring The inspector reviewed the licensee's recently developed cyclic training segment covering change-out of Eberline AMS-3 airborne radioactivity monitors, including inspection of 0-rings and actions to be taken'should 0-rings be missing, damaged, or otherwise unsuitable for use in the instrument. The training scope and depth were appropriate. The effectiveness of the training was enhanced by the use of a functional AMS-3 detector-shield assembly and RAP-1 air pump, the hands-op use of this equipment by each trainee, and a well prepared presentation. The inspector had no further questions concerning the training of Radiological Controls Field Operations technicians in change-out of AMS-3

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The inspector also observed 0-rings in place in the filter assemblies of six operating AMS-3 units in the auxiliary and fuel handling building Further inspections of filter assemblies will be made; however, .this sample of six.AMS-3 units indicates that the licensee has taken appropriate action to assure that AMS-3 units are properly equipped with i 0-ring (Closed) Inspector Follow Item (50-320/85-19-03) Review of assignment of intakes to workers involved in airborne contamination incident in "A" Decay Heat Vault in December 198 The inspector reviewed the methods used to assign intakes to the workers which was based upon Breathing Zones Samples, whole body counts, and

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urine bioassays. The inspector reviewed the records maintained for the dose evaluation and assignment record. The assumptions used to estimate the intakes (MPC-hrs) and committed doses were reasonable and conservativ The inspector had no further question (0 pen) Inspector Follow Item (50-320/85-21-04) Evaluate unmonitored release pathway Evaluation of potential unmonitored pathways is ongoing. The pathways identified by Plant Engineering are being evaluated by Radiological Engineering to determine release bounds and dose assessments. The completion date of the evaluations is projected to be October 1986. The

- modification work on the Contaminated Drain Tanks to prever.'. a release

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pathway when the tanks are used to contain waste from the chemical laboratory is to be completed when the parts are received. These tanks will not be used until modified. The inspector will continue to follow licensee progress in this are .0 Defueling Operations Defueling efforts during this reporting period were directed at implementing the core stratification sampling (core bore) program. The program started on June 21, 1986; however, the actual drilling of the core region began on July 3 following completion of equipment installation and resolution of operational problems. The intent of the program is to obtain information on the properties, configuration, and quantities of material found in various regions within the reactor vessel in order to facilitate defueling' strategie To date, core boring occurred at the following locations: N-5, N-12, G-8, G-12, K-9, and D-8. The stratified samples were placed in fuel canisters and will be eventually shipped to the Idaho National Engineering Laboratory for detailed analysi On July 16, 1986, an extended drilling operation was performed in the K-9 position to characterize core debris found on the reactor vessel lower head. K-9 was the selected position for extended drilling because flow holes exist in the lower support grid and flow distributor to permit access to co e debris that had relocated to the lower head. The inspector observed the performance of this operation. Through attendance of pre-job briefings in the Control Room and Command Center; review of the opecating procedure (4210-0PS-3250.01), safety _ evaluation report (SER), and supporting documents; and observation of the activity; the inspector determined that job prerequisites were completed and that the aparation was performed within the limitations prescribed in the SE No violations were identifie During the extended drilling operation, the inspector noted that no monitoring of the job was done by Quality Assurance (QA) personnel. The *

inspector will determine the degree of QA Department involvement in monitoring core boring /defueling operations in a future NRC inspectio (320/86-08-02)

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f 4.0 Health Physics and Environmental Review Plant Tours The NRC site Radiation Specialists performed plant inspection tours i 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 Facilit Among the items inspected were:

-- Access control to radiologically controlled areas

-- Adherence to Radiation Work Permit (RWP) requirements i

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Proper use and storage of routinely used respirators and associated equipment

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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 I --

Fire protectio The inspectors reviewed the application of radiological controls during normal hours, on backshifts, and on weekends. Log books maintained by Radiological Controls Field Dperations to record activities in the Reactor Building and the balance of the plant were reviewed. All notebooks contained appropriate entries and showed evidence of frequent management revie . .

c) i No violations were identifie : Radiological Shipments 1 The inspectors examined shipments from the site on July 9 and 16, 1986, for the following:

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External vehicle contamination

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External package contamination

-- External radiation levels at vehicle surfaces, two meters away,

and inside the tractor cab

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Radiation levels at package surfaces

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-- Verification that the recipient holds an appropriate license

-- The proper preparation of shipping documents certifying the materials had been properly classified, described, packaged, and marked; and

-- Appropriate package markings, placards placed on vehicle No violations were identifie 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. Additionally, the inspector reviewed the licensee's measurements of radioactivity in water discharges ani compared them to results obtained from EPA sample .

No violations were identifie d. Reactor Building Work The inspectors monitored the licensee's conduct of reactor building (RB) work during the inspection period. The following were reviewed by sampling basis during the inspection period:

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The RB entry was planned and coordinated so as to ensure that ALARA review, personnel training, and equipment testing had been conducte Radiological precautions were planned and implemented including: use of an RWP, locked high radiation access authorization, specific work instructions, alanning self-reading dosimeters, and breathing zone air sampler Individuals making entries into the RB had been properly informed, trained, and understood emergency procedure Unique tasks were performed using specifically developed procedures, and mock-up training had been conductea where warrante Entries 943 through 978 were conducted during the reporting perio 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 shift Installation of the core boring equipment was completed. Samples taken will be loaded into modified fuel debris canisters for shipment to the Idaho National Engineering Laborator No violations were identifie ;

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e. 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 Exception Report Additionally, 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, 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 personne No violations were identifie Semi-Annual Radiological Effluent Report The Semi-Annual Radiological Effluent Report (SRER), dated June 13, 1986, for the second half of 1985, and the Quarterly Dose Assessment Report, dated May 30, 1986, for the first quarter of 1986, were reviewed. The SRER amends the previous reports from 1984 to 1985 to include specific release figures for Sr-90 in liquid effluents in response to concerns by this office. The method of estimating the Sr-90 activity as the gross beta activity has been determined to be conservative and leads to the most conservative dose assessmen No violations were identifie Radiological Environmental Monitoring Program The inspector reviewed the licensee's Radiological Environmental Monitoring Program annual report for 1985. This report summarizes

. the results of the sampling and analyses of environmental media to determine the radiological impact of station operations. These environmental media include air, water, vegetation, and aquatic plants and animals. In addition, direct radiation is monitored by placement of thermoluminescent dusimeters at various locations around the statio As a result of this review, the inspector determined that the licensee has generally complied with its Technical Specification requirements for sampling frequencies, types of measurements, analytical sensitivities, and reporting schedules. Exceptions to the sampling and analysis program were adequately explained. The report included summaries of the laboratory quality assurance program and of the land use surve . - __

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The analyses of environmental samples indicated that doses to humans i

from radionuclides of station origin were negligibl Contaminated Tool Found in an Uncontrolled Onsite Area ,

On July 15, 1986, a radioactively contaminated camera tripod was found in a scrap bin in the owner controlled area near the sand-blasting / paint shop. The tripod had fixed contamination and also removable contamination. 'The fixed contamination tool release limit is given as 100 counts per minute (cpm) above background with a survey meter. The tripod had in excess of the equivalent of 42,000 cpm. The loose / removable beta / gamma contamination limit is 1000 disintegrations per minute per 100 square centimeters (dpm/100 cm2). The tripod had removable contamination of up to 20,000 -

dpm/100 cm r . The scrap bin was surveyed, then decontaminated when it was found to have some fixed contamination on its sides. The other materials in the scrap bin, the surrounding grounds and nearby '

buildings were surveyed. No other contamination was identifie Licensee Investigation Incident Event Report 50-320/86-56 was initiated on July 17, 198 The licensee's investigation determined that the tripod was purchased in 1983, but has not determined how or when the tripod was contaminated, the method by which the tripod was put in the scrap bin, or how the tripod was removed from a radiologically controlled area. Gamma spectroscopy of the components indicate the contamination to be from TMI- Corrective Actions The licensee immediately isolated the scrap bin, surveyed the bin and its contents, surveyed the surrounding area, and decontaminated the tripod. The licensee has increased the frequency of surveys of uncontrolled areas.

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This item will remain unresolved pending completion of licensee's investigation and subsequent NRC revie (320/86-08-03) Training On June 14, 1986, the inspector attended training course GET 202,

"RWT (Radiation Worker Training) Retraining Program", an annual course required of workers who work in radiologically controlled

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areas. Revision 12 of the course handout dated March 27, 1986, was given to all students prior to attending the course. The handout did not reflect the surface contamination limits as specified in the

! Corporate Radiation Protection Plan revised on May 1, 1986. The .

instructor did prompt the class to change the definition on the I handout during the course. The inspector expressed concern in that students may use the handout as a reference for a year and may not

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make the correction. Also, the revision system needs to be more l responsive to student and instructor needs. The supervisor of GET .

training acknowledged the inspector's concerns and demonstrated that

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revision 13, dated June 11, 1986, had been prepared and would be issued in the future for GET 202 and GET 102, " Radiation Worker Initial Training", reflecting the correct definitio The inspector had no further questions regarding this matte Reduction of Contaminated Areas The inspector reviewed the status of contaminated areas in the auxiliary and fuel handling buildings (AFHB). Due to the nature and scheduling of work in the AFHB, the location and extent of contaminated areas are highly variable. Also, there are some areas that are inaccessible, entered quite infrequently, or are scheduled for work activities such that decontaminating them would be impractical or inconsistent with the As-Low-As-Is-Reasonably-Achievable (ALARA) concept. Based on the inspector's review, it appears that the licensee is taking appropriate action to control the extent and effect of contaminated areas on radiation protectio The inspector will continue to monitor actions by the licensee to control contaminated area .0 Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operation (hardware or pr,ogrammatic) that could lead to violations if left uncorrected. Inspector follow items are addressed in paragraphs 2.0 and .0 Unresolved Items Unresolved items are findings about which more information is needed to ascertain whether they are violations, deviations, or acceptable. An unresolved item is addressed in paragraphs 2.0 and 4 .0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On July 21, 1986, the site inspectors summarized the inspection findings to the following personnel:

J. Byrne, Manager, TMI-2 Licensing W. County, QA Lead Auditor W. Craft, Manager, Radiological Controls Field Operations C. Dell, Licensing Technical Analyst T. Demmitt, Deputy Director, TMI-2 i J. Jandovitz, QA Monitor S. Levin, Site Operations Director M. Pastor, Defueling Operations Director J. Renshaw, Manager, Waste Management R. Rogan, Director, Licensing and Nuclear Safety Director l l

At no time during the inspection was written material provided to the

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licensee by the TMICPD staff except for procedure reviews pursuant to Technical Specification 6. l