IR 05000320/1987001

Safety Insp Rept 50-320/87-01 on 870110-0213.No Violations Noted.Major Areas Inspected:Plant Operations,Defueling Operations,Transfers of Spent Filter Canisters,Personnel Injury in Reactor Bldg & LER Followup

ML20207S891
Person / Time
Site:	Three Mile Island
Issue date:	03/12/1987
From:	Bell J, Dan Collins, Cowgill C, Moslak T, Myers L NRC, Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207S882	List: IR 05000320/1987001 ML20207S881
References
50-320-87-01, 50-320-87-1, NUDOCS 8703200374
Download: ML20207S891 (9)

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' U. S. NUCLEAR REGULATORY COMMISSION Report No.

50-320/87-01 Docket No.

50-320 Category C

License No. DPR-73 Priority

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Licensee:

GPU Nuclear Corporation P.O. Box 480 Middletown, Penns>1vania 17057 Facility Name: Three Mile Isled Nuclear Station, Unit 2 Inspection At: Middletown, Penniflvania Inspection C cte-Qkngary(%bh7-February 13, 1987

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d/jQ /577 Inspectors:

T.' Moslak, Re41 den n ns)ector (TMI-2)

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.sbz/97 J._By l, Senior RKUtation Specialist d6te Isigined Radef 0.C A b 3h s1 D. Col-ins, idiation Specialist date sig'ned

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Uffyers,fadiatij5n Specialist d&te tigned d~

f!/L/87 Approved By:

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C.

wgill, Chief, TMI-2 Project Section dite (ign(d Inspection Summary:

Areas Inspected:

Rcutine safety inspection by site inspectors of plano operations, defueling operations, transfers of spent filter canisters, personnel injury in the reactor building, licensee event report followup, radiological and housekeeping conditions within the reactor building, and licensee action on previous inspection findings.

Results:

No violations were identified.

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DETAILS

1.0 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; 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.

Inspections of the control room were performed during regular and backshift hours. The Shift Foreman's Log and selected portions of the Control Room Operator's Log were reviewed for the period January 10, 1987 through February 13, 1987. Other logs reviewed during the inspection period included the Submerged Demineralizer System 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 emergencias was reviewed to verify that they could perform their intended functions. The inspector attended selected licensee planning meetings.

Shift staffing for licensed operators, non-licensed personnel, and fire brigade members was determined to be adequate.

No violations were identified.

2.0 Defueling Operations The licensee continued removing fuel fragments and drilled material from the upper regions of the core. The spade bucket tool was used until it was determined to be no longer effective, then the Airlift Defueling System was utilized.

The rate of defueling using the Airlift System was not as great as originally anticipated. Two canisters were partially filled over a period of about ten days using this system.

However, the system is considered useful in picking up material that might not be lifted using other techniques.

On February 6, 1987, defueling operations were suspended for about two weeks to conduct studies of in-vessel conditions and ex-vessel fuel locations. The data to be acquired includes video inspections of the "B" hot leg, decay heat drop line, all four reactor coolant pumps, core support assembly, and the lower reactor vessel head.

In addition, sampling of material in those areas will be attempted and a hydraulic displacement test of the material in the lower head will be performed to evaluate its consistency. Resumption of defueling is scheduled for February 23, 1987.

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3.0 Licensee Action on Previous Inspection Findings (0 pen) Inspector Follow Item (86-13-01):

Effectiveness and basis of revised procedure 9200-ADM-4212.01, " Air Sample Analysis".

The inspector reviewed licensee progress toward procedure revisions concerning analysis of airborne radioactive particulate samples.

In the interest of procedure consistency, the licensee is coordinating changes to the procedure with TMI Unit 1 and Oyster Creek. Licensee progress appears to be adequate and will be followed by the inspector.

(0 pen) Inspector Follow Item (320/86-15-03): Stability of temporary shields.

Temporary lead blanket shield walls were examined at the temporary reactor vessel filter system at the northwest corner of the defueling work platform, and at the high pressure pump area near the enclosed stairwell on the 347' level of the reactor building during entry 1186 on February 13, 1987. A steel " foot" has been attached at the bottom of each section of shield wall to improve lateral stability. Both shield complexes were resistant to tipping and should adequately resist inadvertent impacts.

However, the accident described in Inspection Report 50-320/86-15 apparently resulted from conscious movement of a shield wall. The licensee is revising its procedure controlling temporary shielding and plans to cover potential hazards associated with attempts to move temporary shield walls in safety meetings. The inspector will continue to follow licensee efforts to control temporary shielding and its potential industrial hazards.

(Closed) Inspector Follow Item (320/86-15-04): Response of non-essential personnel to injured worker event in reactor building.

InDecember1986aworkerwasinjuredinthereactorbuilding(RB)and removed via the Equipment Hatch.

Unnecessary personnel at the site of the event hampered those personnel required to respond to the event and created confusion. However, as noted in paragraph 6.0 of this report, effective control of unnecessary personnel was demonstrated by the licensee on January 19, 1987, when a worker was injured in the RB.

The inspector had no further questions.

4.0 Licensee Event Report (LER) Followup The following LERs were reviewed. The inspector verified that the reporting requirements had been met, causes had been identified, corrective actions appeared appropriate, generic applicability had been considered and the LER forms were complete.

320/86-11 Securin a firewatch without first properly verifying that four(4 fire detectors were returned to service.

320/86-12 Failure to post a roving hourly firewatch when fire suppression equipment was inoperabl.

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5.0 Health Physics and Environmental Review a.

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

the Auxiliary and Fuel Handling Buildings, EPICOR-II, Radiochemistry Laboratories, radioactive waste storage facilities, the Respirator Cleaning and Laundry Facility, the Waste Handling and Packaging 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 rcutinely 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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The inspectors reviewed the application of radiological controls during normal hours, on backshifts, and on weekends.

Log books maintained by Radiological Controls Field Operations and Radiological Engineering to record activities in the reactor building and the balance of the plant were reviewed. All of the log books contained appropriate entries.

No violations were identified, b.

External Exposure Control As reported in 50-320/86-15, the Ifcensee recently initiated the use of increased eye protection against beta radiation. The use of special dosimetry and the processing of thermoluminescent dosimeters worn by individuals is coordinated with the increased eye protection so that the exposure assessments for such individuals are consistent with the exposure conditions.

In order to simplify implementation, the Radiological Controls Field Operations group is specifying the use of augmented eye protection for all individuals entering the reactor building whether or not special set dosimetry is required.

The inspector determined that the coordination of eye protection and personnel dosimetry was effectively implemented with only minor problems.

The inspector will continue to monitor this aspect of the licensee's radiation protection program.

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c.

Radioactive Material Shipments The NRC site Radiation Specialists inspected radioactive materials shipments on January 11 and February 1,1987.

The inspector's review covered:

Compliance with approved packaging and shipping procedures

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Proper preparation of shipping papers, including certification

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that the radioactive materials had been properly classified, described, packaged and marked for transport Warning labels on packages and placarding of vehicles

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Compliance with regulatory limits for radioactive contamination

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and radiation dose rates.

The inspector's review consisted of (1) examinations of shipping papers, procedures,packagesandvehicles,and(2)performanceof radiation and contamination surveys.

No violations were identified.

d.

Reactor Building Work Reactor Building Entries The inspector monitored the licensee's conduct of reactor building (RB) work during the inspection period. The following were reviewed on a sampling basis during the inspection period:

RB entries were 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 area access authorization, specific work instructions, alarming self-reading dosimeters, and breathing zone air samplers.

Individuals making entries into the RB had been properly

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informed, trained, understood emergency procedures, and possessed appropriate communications equipment.

Unique tasks were perfonned using specifically developed

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

The inspector observed radiological and industrial safety conditions in the reactor building on February 13, 1987. A crew was at work on the shielded work platform, maintenance work was in progress on the robot being used to scarify walls in the reactor building basement and progress on the erection of the decontamination facility on the 347' level of the reactor building was observe,

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6 The inspector noted that although the roof of the enclosed stairway is both a transit way (for access to the top of the "B" D-ring) and work area, most of the periphery is not protected by a barrier to prevent falls to the 347' level.

It was also noted that the stretcher staged on top of the "A" D-ring for use in transporting injured workers has been equipped with lifting straps in order to facilitate its movement by means of a crane. However, the stretcher was not bagged to prevent it from becoming contaminated. These concerns, as well as other concerns associated with trip hazards and equipment and waste storage, were brought to the attention of the licensee. The licensee described actions in progress to deal with these concerns including more aggressive safety surveillance procedures that were recently initiated to identify and correct such problems.

No other concerns were identified by the inspector during this entry. The inspector will continue to n'onitor plant safety conditions.

No violations were identified.

6.0 Unusual Event - Personnel Injury in Reactor Building An Unusual Event was declared January 19, 1987 at 11:32 AM when a worker broke his ankle while working in the reactor building (RB). The accident occurred on the top of the "B" D-ring while the individual was building a scaffold. The worker was ) laced in a litter and, using the polar crane, moved from the D-ring to t1e 305' elevation where he was transported out of the RB via the Equipment Hatch. After removal from the RB, the worker's protective clothing and respiratory equipment were removed by a Radiological Controls Technician (RCT) in the presence of a nurse. The worker was found to be free of contamination and was transported to Harrisburg Hospital at 12:50 PM at which time the Unusual Event was terminated.

The inspector observed the worker being removed from the R8 at the Equipment Hatch.

In addition, the inspector reviewed the Incident Event Report, notes of the critique, and notes of the safety meeting attended by the worker.

The licensee's response was very good.

The nurse's response was prompt in making an entry to the RB within minutes of the accident to attend the injured worker. Radiological Controls maintained very good control of the possibly contaminated worker and, after removing the worker's protective clothing and equipment, effectively determined that the worker was not contaminated. The confusion at the Equipment Hatch (noted in Inspection Report 50-320/86-15) associated with the presence of unnecessary personnel was minimized in this case. All unnecessary personnel were removed from the area to allow essential personnel to effectively carry-out their functions.

The critique established that the litter stored in the RB did not have lifting straps.

There was a delay in removing the worker while lifting straps were found. The licensee is addressing this problem by conducting frequent inspections of the litter and by permanently attaching lifting straps to the litte.

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No violations were identified.

7.0 Transfer of Filter Canister from Reactor Building Without Notification of Radiological Controls On January 11, 1987, the Fuel Handling Senior Reactor Operator (FHSRO)

authorized the transfer of a loaded filter canister from the reactor building (RB) via the fuel transfer system to the fuel handling building (FHB) without informing Radiological Controls Field Operations.

The Radiological Controls Technician on duty at the Coordination Center overheard an instruction involving the transfer of the canister.

He immediately investigated the transfer and stopped the activity just as the canister arrived at the FHB via the fuel transfer system. A Radiological Awareness Report was initiated.

The Radiation Work Permit (RWP) for Defueling Operations, No. 15261, includes radiological safety-related requirements related to the movement of fuel and filter canisters from the RB to the FHB. One of these is a requirement that the FHSRO inform the balance-of-plant Group Radiological Controls Supervisor (GRCS) prior to the movement of a canister to FHB.

The RWP requirement is based upon the need to control access to the RB annulus and the shielded fuel transfer canal, and to set up radiological controls in the FHB.

The FHSR0 did not inform the Coordination Center Radiological Controls Coordinator, the balance-of-plant GRCS, or the Radiological Controls Technician on duty in the Coordination Center of his intention to move the filter canister. Further, the FHSR0 failed to brief the coordinator and the Radiological Controls Technician of this planned activity in the morning Defueling Operations briefing.

The FHSR0 explained that although he knew of the RWP requirements he failed to inform Radiological Controls because of other activities requiring his attention.

The Defueling Operations procedure for transferring fuel and filter canisters does not have a hold point for informing Radiological Controls Field Operations (RCF0) prior to a canister transfer. An informal

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checklist in use at the Coordination Center provides for notification of the RCF0 GRCS of the intent to transfer a canister by way of notification of the Coordination Center supervisor.

In January 1986, a fuel canister was transferred without notification of the GRCS.

Corrective actions taken to prevent a recurrerce included the use of the informal checklist.

It is not clear why this requirement pertaining to the transfer of canisters was placed in an RWP instead of in the procedure specifically covering this evolution. However, the Radiation Protection Plan, Procedure 1000-PLN-4010.01, requires in Section 3.1.2 that workers obey written radiological controls instructions and procedures, including instructions on RWPs. The inspector is reviewing the circumstances associated with this event to determine its safety significance in light of its possible relation to similar past events and the timeliness and effectiveness of licensee corrective actions.

This event will be considered as unresolved pending the outcome of the inspector's review.

(320/87-01-01)

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8.0 Respiratory Protection for Defueling Operators The use of respiratory protective equipment by defueling personnel on the shielded work platform (SWP) was studied in the context of its affect on defueling productivity.

The stay time of defueling personnel is limited to four hours by time-of-use limits on the battery packs used with the workers' powered air purifying respirators. Actual productive time is less than four hours since the respirator time in use starts when the device is started in the Personnel Access Facility and ends when the device is turned off after exiting the RB.

Based on the study of defueling personnel activities and airborne radioactivity levels at the SWP, it was determined that defueling personnel could work without respiratory protective equipment if their activities were limited so as to prevent the removal of defueling tools from the reactor vessel and the associated increase in airborne radioactivity levels.

Defueling personnel started defueling operations without respiratory protective equipment during the week of January 5,1987. Additional entry teams equipped with respiratory protective equipment were required to do work that the defueling personnel could not do without respiratory protective equipment.

In the latter part of the week, it was found that breathing zone air sampler (BZA) sample results for the defueling personnel were showing relatively high airborne alpha emitting radioactivity concentrations.

Based upon the CZA sample analysis results, the defueling operators were placed back in respiratory protective equipment on January 12, 1987.

Based on the gross alpha analysis results, several workers were initially assigned maximum permissible concentration-hour (MPC-h) exposures ranging from 20 to 40. A meeting between the licensee and NRC onsite staff was held on January 21, 1987, at which time the licensee explained the intent and the result of removing respiratory protective equipment from defueling personnel and its plan for determining the isotopic composition of the alpha emitting radioactivity. At the present time, the MPC-h assignments are based conservatively on soluble plutonium-239.

Licensee-planned analyses should help define the appropriate MPC, but there is agreement that the analyses will probably result in reduced MPC-h assignments. The inspector will review the results of the analyses and final MPC-h assignments.

(320/87-01-02)

9.0 Inspector Follow Items Inspector follow items are inspector concerns or perceived weaknesses in the licensee's conduct of operations (hardware or programmatic) that could lead to violations if left uncorrected.

Inspector follow items are addressed in paragraphs 3.0 and 8.0.

10.0 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 paragraph.

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11.0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings.

On February 13, 1987, the site inspectors summarized the inspection findings in a meeting with the following personnel:

J. Byrne, Manager, TMI-2 Licensing W. Craft, Manager, RCF0, TMI-2 C. Dell, Licensing Technical Analyst A. Miller, Manager, Plant Operations 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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