IR 05000320/1987009

Insp Rept 50-320/87-09 on 870801-28.Violations Noted.Major Areas Inspected:Plant Operations,Defueling Operations, Housekeeping Conditions within Reactor Bldg,Shipments of Radioactive Matls & Radioactive Sludge Processing

ML20235F480
Person / Time
Site:	Three Mile Island
Issue date:	09/18/1987
From:	Bell J, Dan Collins, Moslak T, Travers W NRC, Office of Nuclear Reactor Regulation
To:
Shared Package
ML20235F459	List: IR 05000320/1987009 ML20235F456 ML20235F469
References
50-320-87-09, 50-320-87-9, NUDOCS 8709290144
Download: ML20235F480 (7)

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'U. S. NUCLEAR REGULATORY COMMISSION l

Report No. 50-320/87-09 l Docket N license No. DPR-73 Priority --

Category C licensee: GPU Nuclear Corporation 4 P.O. Box 480 l

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Middletown, Pennsylvania 17057

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Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania InspectionCpcted: Aggust 1,m1 9 A - August 28, 1987 Inspectors: ,

Q / l7/987 T.'Moslak,' Retident Inspector (TMI-2) da'th signed J

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ell, S n W Radis ion Specialist 9QW dpte's'ig s3

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9 // 7 f7 D. Collins R diation Specialist date ' sign'ed Approved By: h)j/m )M_- _ ,.

W.' Travers, Di re or, TMI-2 Cleanup Project O

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ats si'gned Directorate Inspection Summary:

Areas Inspected: Routine safety inspection by site inspectors of plant operations, deTueling operations, housekeeping conditions within the reactor building, shipments of radioactive materials, radioactive sludge processing, systems decontamination, radioactive resin spill, the implementation of radiological controls, and licensee action on previous inspection finding Results: Two violations were identified. One violation resulted when the licensee failed to perform an adequate radiation survey resulting in the

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contamination of a worker and equipment. The second. violation resulted from the failure of the licensee to implement a procedure during the hydrostatic testing of sludge transfer hoses causing a spill of radioactive material in the auxiliary buildin hDR ADOCK 0500o320 PDR

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DETAILS 1.0 Routine Plant! Operations

)1 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;ilicensee control of routine and special' evolutions, including )

control' room personnel awareness of these evolutions; control of l documents.. including log keeping practices; radiological controls; and

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security plan implementatio 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. August 1, 1987 through' August 28, 1987. Other logs reviewed during the inspection

- period included the Submerged Demineralized System Operations Log,

. Radiological _ Controls Foreman's Log, and Auxiliary Operator's Daily Log' i

. Sheet .i 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 inspector attended selected licensee plannin.g meetings. Shift staffing for licensed and non-licensed personnel was determined to be adequat No violations were identifie .0 Licensee Action on Previous Inspection Findings I

-- (Closed) Inspector Follow Item (320/86-09-01): Trend Industrial Safety Practices Based on an examination of the' corrective actions.taken during the past twelve months by the licensee to improve industrial safety for operations conducted in the reactor building and through discussions with licensee representatives, the inspector concluded that no increase in the frequency of significant injuries occurred subsequent to those documented in inspection' report 50-320/86-0 The inspector had no further questions regarding this matte (Closed) Inspector Follow Item (320/85-01-01):

Training / Qualification of Fuel Handling Limited-SR0s  ;

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senior reactor operators to perform fuel handling activities documented in Inspection Report 50-320/85-13, the inspector had no further questions regarding this ite i

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(Closed) Violation (320/86-15-07): Failure to Perform Survey The inspector reviewed the licensee's corrective actions which included:

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specifying decision criteria in ALARA reviews and Radiation 1

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Work Permits

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counseling the involved radiological controls personnel and ;

incorporating the lessons learned from the event into a seminar l for cyclic technician training in order to help ensure that i adequate evaluations of radiation hazards are performed )

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performing a ventilation study of the MU-P-1C cubicle that resulted in sealing cubicle penetrations and providing an additional exhaust pathway from the cubicl From this review, the inspector concluded the actions were appropriate and had no further questions on this ite .0 Licensee Event Report (LER) Review and Onsite Followup i

The inspector reviewed LER 87-006 to verify that the details of the event were clearly reported, including the accuracy of the description cf the causes and the adequacy of corrective actions. The inspector determined whether further information was required from the licensee, whether the event should be classified as an Abnormal Occurrence, whether generic implications were indicated, and whether the event warranted onsite followu LER 87-006, dated August 27, 1987, addresses a licensee identified radioactive contamination event. A routine survey of a vehicle that had previously carried radioactive material identified radioactive contamination on a chain in excess of ten times the limits established by the licensee's Radiation Protection Plan. Such an event is reportable under 10 CFR 20.405 and is treated further in this report under'" Health Physics and Environmental Review."

4.0 Defueling Operations j Pick and place defueling of partial (stub) length fuel assemblies !

continue For this reporting period 33 stub assemblies were remove As of the end of the repcrting period, a total of 93 fuel assemblies out of a total'of 177 in the core had been loaded into canisters. This material equates to approximately 140,000 pounds of debris, out of a 1 total of approximately 293,000 pounds, that has been loaded into defueling canisters. The work was primarily performed using the fuel assembly puller tool and the fuel assembly handling too During the week of August lith, a video inspection was performed of the in-vessel conditions after stub assembly D-12 was removed. In this j location the flow holes in the lower grid, distributor plate, grid i forging, and elliptical flow distributor are aligned providing a clear j path to the lower head. The video showed a variety of materials in the {

core support assembly including loose sandy fines and once molten j resolidified material. No significant damage to the core supporc )

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1 assembly was discernible. The core debris in the lower head appeared to be'12 to 18 inches deep. These results are consistent with information 4 previously obtained from core boring and video inspections, f 5.0 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 i sampling basis: 1

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planning and coordination of the various aspects of the work, including ALARA reviews and equipment preparatio i

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planning and implementation of radiological safety measures, including locked high radiation area authorizations, specific work )

instructions, Radiation Work Permits (RWPs), alarming self-reading dosimetry, and breathing zone air samplin j ;

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personnel training in emergency procedures and the use of specially l developed procedures and mockups for unique task ;

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On August 20, and ~ August 27, the inspector entered the Reactor Building l (RB) to evaluate the radiological and housekeeping condition f On August 20, 1987, the Radiological Controls Director for TMI-2 accompanied the inspector. Housekeeping conditions were evaluated for the radwaste storage areas, general work areas, and equipment staging / repair areas, on the 305' elevation and 347' elevation. On August 27, 1987, the inspector expressed a concern to licensee

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representatives regarding the following condition:

Bags containing radioactive trash were inappropriately staged between the a rope barrier and shielding in the High Rad Storage Area, in lieu of

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placement behind the storage area shielding. Such a practice can j increase.the radiation level in the general area with a subsequent increase in worker transient dos Licensee representatives agreed with the inspector and initiated actions i to correct the situation and preclude a recurrenc !

No violations were identifie .0 Monthly Surveillance Containment Integrity Verification i i

On August 18, 1987, the inspector witnessed the performance of a portion [

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of the containment integrity verification (4210-SUR-3244.01). The verification is performed monthly, pursuant to the TMI-2 Recovery

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Operations Plan Section 4.6.1.1.a which requires that primary containment l integrity be demonstrated by verifying that all accessible penetrations not required to be open per approved procedures during the recovery mode l

are closed by valves, blind flanges, or deactivated automatic valves l secured in their positions. The inspector accompanied a Control Room l

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l 0)erator and entered the Reactor Building annulus area (338' elevction of 1 tie Fuel Handling Building) during the performance of the surveillanc The inspector verified that the most current revision of the controlled procedure was used, and that the following valves were in their required positions: DW-V-28, DW-V-556, CF-V-145, CF-V-114B, CF-V-1298, CF-V-146, CF-V-129A, DH-V-187, DH-V-205, and DH-V-20 No. violations were identifie Fire System Valve line-up Verification-On August 20, 1987, the inspector witnessed the performance of a portion of the fire system valve lir:e-up verification. The verification is performed monthly pursuant to TMI-2 Recovery Operations Plan paragraph 4.7.10.1.1.c which requires that at least once per 31 days each valve in the flow path for the fire protection system is to be verified that it is in the correct positio The inspector accompanied an Auxiliary Operator and verified the positions of'53 valves (out of a total of 116 valves)

that are located in the Fuel Handling Building, Auxiliary Building, Turbine Building, and the Control and Service Buildin The inspector verified that the most current revision of the controlled procedure, Station Surveillance Procedure 3301-MI, was use No exceptions or deficiencies were identified during the performance of the surveillance. However, the inspector observed that four valves (FS-V-632, FS-V-639, FS-V-615, FS-V-630) did not have brass identifying tags attached to their hand wheels. The auxiliary operator did inform the shift supervisor of this finding and actions were taken to have new tags on these valve No violations were identifie .0 Monthly Maintenance Corrective Maintenance Upon evaluating the results of the daily RCS leak rate tests on August 13, 1987, control room personnel determined that an off-normal leak rate existed. Previous leak rates ranged from -0.2 gpm to 0.2 gpm and that day's result indicated a slight increase to 0.6 gpm. Though this condition did not represent an emergency situation, control room personnel initiated troubleshooting to identify pathways that could be potentially leaking. A walkdown of accessible hoses, valves, and manifold in the Defueling Water Cleanup System (DWCS) was completed without identifying any apparent leakag Plans were formulated to first secure DWCS then sequentially run the separate DWCS "A" and "B" trains to determine if the leak could be attributed to a hidden leakage path that j- existed when the system was operating. However, before this evaluation i

commenced, an electrician, who was performing an unrelated task in the

) reactor building, discovered a small puddle of water in the vicinity of the tygon tubing that serves as the RCS level standpipe (manometer). The electrician reported this to the control room. Operations personnel

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identified the source of the drippage as a leak in a section of the i-inch tygon tubing that is a part of the RCS level standpipe. The leak

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wastisol'ated by clamping the tubing with visegrip pliers. Subsequent leak rate determinations-indicated that the off-normal leakage condition-was correcte The exact location of.the leak ~was determined to be in the sample lin portion'of the. standpipe between RC-FV2 and the tee connection to the vertical riser of the standpip A Unit Work Instruction (UWI 4220-3641-87-H571) was prepared to replace

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the ruptured section of tubing and will soon be implemente The inspector followed licensee actions .in evaluating the leakage b reviewing. relevant documents and interviewing cognizant individuals. The ihspector concluded that the off-normal situation was evaluated by site-organizations including the Safety Review-Group, Quality' Assurance, Radiological Controls,-and Maintenance and.that the' diagnostic and corrective actions.were appropriat .. No> violations were identifie .0 Health Physics-and Environmental Review Plant Tours The NRC site' Radiation Specialists performed inspection tours of the-plant, including all radiological control points and selected  !

radiologically centro 11ed areas. Among the areas inspected were the reactor building, the Auxiliary and: Fuel Handling-Building EPICOR-II, the Radiochemistry Laboratories, the laundry and'

Respirator Maintenance Facility, the Waste Handling and Packaging Facility, the Interim Solid Waste Storage Facility, and the Radiological Controls Instrument Facilit ,

Among the items inspected were:

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-- Access control to radiologically controlled areas

-- Adherence to Radiation. Work Permit (RWP) requirements ,

-- Proper use, storage, cleaning, maintenance, and repair of respiratory protection devices and associated equipment

-- Maintenance and storage of emergency respiratory equipment

-- Use of radiological instrumentatio Use of survey meters and other radiological instrument The inspectors reviewed the implementation of radiological controls during day shifts, on backshifts, and on weekends. Log books maintained by Radiological Controls Field Operations to record activities in the reactor building and the balance of the plant were reviewed for completeness and accuracy. All of the log books contained appropriate entrie _ _ _ _ _ _ - - _ _ - _ _ _ _ _ -

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During this-inspection period, the inspectors conducted backshift and weekend inspections on the following days:

i 8/9/87 7:30 PM to 9:30 PM 8/12/87 8:00 PM to 11:00 PM 8/14/87 5:00 PM to 6:30 PM 8/16/87 5:00 PM to 6:00 PM 8/18/87 3:30 AM to 7:30 AM 8/20/87 8:00 PM to' 11:00 PM 8/26/87 4:15 PM to 5:45 PM 8/27/87 4:15 PM to 5:45 PM No violations were identifie b. Radioactive Material Shipments The inspectors reviewed preparations and conduct of radioactive materials shipments on August 3, 18, and 28, 198 The inspector's reviews of shipments covered:

-- Verification that the recipient is properly licensed ,

-- Verification of compliance with 10 CFR Part 61 radioactive waste disposal regulations

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Verification of compliance with approved packaging and shipping procedures

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Proper preparation of shipping papers

-- Package labeling and vehicle placarding

-- Instructions to vehicle operators

-- Verification of compliance with regulatory limits for radioactive contamination and radiation dose rate The inspector's review consisted of observations of shipping canister loading, performance of radiation and contamination surveys, and examination of shipping papers, procedures, and vehicle No violations were identifie c. Records Review The inspector reviewed selected licensee records related to occupatior:al radiation exposure with respect to their accuracy and completeness, including Radiation Work Permits (RWPs), Dosimetry Investigative Reports, Incident / Event Reports, Radiological Awareness Reports, Dosimetry Exception Reports, Bioassay Reports, Respiratory Protection Device Fit Tests, and medical examination _ _ _ _ _ _ _ _ _ _ - _ _ -

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r The inspector also reviewed other licensee records and periodic reports concerning the radiological controls program, including current data and trends in such areas as person-rem ptr RWP hour, decontamination. status, skin contaminations, environmental

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monitoring, progress toward achieving goals and objectives, storage tank radioactivity content, airborne radioactivity, effluent releases (including sump releases and sources of sump contamination), and the cumulative dose to plant personne No violations were identifie d. Control' of Radioactive Material Radioactive Material in Unrestricted Areas As a result of earlier events involving the loss of control of radioactive material, the licensee has intensified its efforts to improve radiation surveys and identify radioactive contaminatio On July 26, portions of the bed of a truck were found by licensee survey to exceed the release limits stated in the licensee's Radiation Protection Plan (Procedure 1000-PLN-4010.01). Also, on July 28, one link of a twenty foot length of chain stored in a bag in the bed of a truck was found by licensee survey to exceed the release limits of Procedure 1000-PLN-4010.01. In both cases the contaminated material had been untended in unrestricted areas in apparent violation of Section 20.207 of 10 CFR 20. However, the health and safety significance of these occurrences is considered t be minor, the problems were identified and reported by the licensee, and appropriate corrective action has been taken by the license j Therefore, in accordance with Appendix C of 10 CFR Part 2, a notice of violation will not be issue i Personnel and Equipment Contamination On August 19, the assessment of a personnel contamination by the I licensee resulted in a determination that radioactive contamination j from a waste package had spread to an individual loading a truck, the truck, and other waste containers on the truc Upon determining that the individual was contaminated, the licensee took j appropriate action to decontaminate the individual, determine the -

source of the contamination, and survey the truck, the packages on the truck, the route that the truck had followed, and appropriate areas within plant buildings. Subsequent actions included decontamination of the truck, and appropriate processing of the waste package The waste materials, consisting of steel "LSA boxes" and plastic-wrapped bundles of pipe, sample tubing, and a door; were staged near an outside roll-up door of the auxiliary building for j

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packages were loaded on a truc'k, the truck was posted as a

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l radioactive materials area and was escorted to the WH&PF on the l t plant site, in accordance with the licensee's procedure The j contamination was discovered when one of the workers who had loaded

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the truck set off an~ alarm at a frisking station in the auxiliary building. An alert Radiological Controls (Rad Con) technician realized the connection between the worker and the truck and a call to.the WH&PF triggered actions by Rad Con personnel at the WH&PF that prevented a further spread of contaminatio Subsequent analyses of the contamination established that its source was the radioactive materials contained in the packaged sample lines. This result indicated that the containment of the radioactive materials coupled with the handling of the packages were not adequate to prevent the spread of the radioactive material Further, it appears that the licensee did not perform an adequate survey of the packages. Section 20.201, " Surveys", of 10 CFR Part 20 defines " survey" as an evaluation of the radiation hazards incident to the...use....or presence of radioactive materials...

This section of the regulation also requires that each licensee make such surveys as may be necessary for the licensee to comply with the regulations and that are reasonable to evaluate the extent of radiation hazards that may be present. An adequate survey would have detected the contamination allowing those involved to take the J.teps necessary to prevent the personnel and equipment contaminations and the potential for the uncontrolled release of radioactive materials to unrestricted areas. Because of the failure of the licensee to perform an adequate survey and the apparent violation of Section 20.201 of 10 CFR Part 20, a notice of violation will be issue (320/87-09-01)

It appears that there were several contributing causes for this even The individual pieces of tubing containing internal contaminationwerenotpluggedorcapped(otherthanwithtape)to contain the radioactive material. As evidenced by a penetration in the outer wrapping of one package, the packaging (plastic wrapping)

was not adequate to withstand the handling during the multiple j relocations experienced by the packages during storage and staging !

prior to reaching the WH&PF. Radiological Controls (Rad Con) was provided only brief advance notification of the need for coverage of the package loading and movement evolution which contributed to the performance of an inadequate survey. The Rad Con technician covering the movement of the materials from the auxiliary building i did not recognize his full responsibility with respect to conducting i an adequate survey. Finally, the procedure applicable to the movement (9200-ADM-4430.01, " Radioactive Material Transfer") lacks clarity with respect to the performance of surveys and the time sequence of the various actions required by the procedur In addition to the immediate corrective actions described above, the licensee has or plans to:

l Discipline and counsel the Rad Con technician, j 1 Review the incident in Rad Con technician cyclic training and J in a radiological awareness meetin ]

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l Review the incident and clarify the requirements of the

" Radioactive Material Transfer Procedure" with all Group Radiological Controls Supervisors who will, in turn, cover these items with all Rad Con technician . Review the' adequacy of the " Radioactive Materials Transfer" procedure and make necessary clarifying / corrective change . Establish improved coordination between Waste Management and Rad Con with respect to radioactive material transfer The inspector will review implementation of these corrective actions. The inspector also expressed his concern to the licensee with respect to the desirability of prompt processing and disposal of waste materials and, where this is not practical, the adequate surveillance of stored waste packages. This concern will be reviewed during future inspections, e. Waste Gas Vent Header Decontamination The waste gas vent header (WGVH) was contaminated during a resin transfer evolution on July 24, 1987 (covered in Report 50-320/87-05). Radiation levels in certain work areas were greatly increased as a result of the presence of the radioactive contamination. Consequently, a plan was devised for flushing of the WGVH with processed water to reduce the contamination and radiation level The inspector observed preparations for the flush and its successful implementation between 2000 and 2200 hours0.0255 days <br />0.611 hours <br />0.00364 weeks <br />8.371e-4 months <br /> on August 12, 1987. The inspector did not observe any departures from the requirements of applicable procedures, including the radiation work permit covering the job. The flush resulted in general area radiation levels being reduced by as much as a factor of ten and specific system component radiation levels being reduced by as much as a factor of 50 No violations were observed and the inspector had no further question Solidification Unit Spill  ! The solidification for burial of radioactive sludge from the auxiliary and reactor buildings is being done by *1 licensee contractor using a cement solidification process. The contractor's assembly and operating procedures for the contractor's transportable system have been incorporated into licensee procedures.

l- Prior to August 1987, the contractor had solidified a quantity of radioactive sludge material removed from the auxiliary (Aux)

building sum This Aux sump sludge was pumped to the solidification unit valve assembly, then to the solidification liner. At the end of the evolution the contractor personnel departed the site. Licensee personnel and personnel f rom a second

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contractor partially disassembled the feed line from the Aux sump to the solidification unit and left the hose end in a plastic ba In preparation for solidifying contaminated sludge which had been removed from the reactor building, another line was connected to the vendor's valve assembly. On August 13, 1987 while preparing to transfer reactor building sludge to the vendor's unit, processed (previously contaminated) water was supplied to the unit to demonstrate hydrostatic integrity. When water was not found to be pressurizing the line'or flowing into the solidification liner, a spill of processed water was noted. Before securing the spill, about 200 gallons of water and Aux sump sludge (left in the hose from earlier transfers) were deposited around and under the vandor's unit and the enclosure housing it. The spill pathway was through a broken sight glass near the hose end in the plastic bag. The 1 radiation levels from the sludge / water mixture were as high as 1 R/hr genma and 20 Rad /hr beta at near contact with the floor. The area was decontaminated and the sludge solidified without further inciden Attachment A to licensee Procedure 4231-0PS-3233.02 " Operation of the Chem-Nuclear Cement Solidification Unit 125", Revision 0-00, dated January 20. 1987, includes the Chem-Nuclear Procedure

" Operation of the Cement Solidification Unit No 125."

Section 4.0, "Preoperational Testing" of this procedure i contains the note:

" Unit is assembled, all cables and hoses are connected in a accordance with the Assembly and Disassembly Procedure...

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"4.1 Perform the Preoperational Checklist... Form A" Form A, Step 2 states:

" Hose Inspection Completed SAT UNSAT" 1 The procedure continues in Section 4.3:

"4.3 Fillhead Placement  ;

4.3.7 Check for proper connection of all hoses and cables to i the fillhead."

The spill demonstrated that proper connection of hoses did not precede the hydrostatic test. Failure to follow Procedure 4231-0PS-3233.02 in performing preoperational testing of the unit is

! an apparent violation of Technical Specification 6.8.1 requiring

) implementation of procedures for handling and solidifying l- radioactive waste sludges. (320/87-09-02) j l

The licensee held a critique and established corrective actions to preclude a recurrence of this type event. Among the short term

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actions taken were temporary procedure changes to require plant personnel: (vice contractor personnel) .to make all valve movements,

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and to. require aiwalkdown of all. hoses used. One of the contributing causes was the placement of lead shielding which

. impeded-visual inspection of the entire hose-lengt Long term corrective actions include appropriate permanent procedure changes and the incorporation of-lessons learned into the procedures

'for solidifying the resins-from the cleanup demineralizers and the-makeup and purification demineralizer The inspe~ctor will review implementation of-these plan ' 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 paragraph i 10.0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On August 28, 1987, the site inspectors summarized the inspection findings in a meeting with the following personnel:

. J. Byrne, Manager, TMI-2. licensing i C. Dell Technical Analyst, Licensing i T. Demmitt, Deputy Director, TMI-2 C. Incorvati, TMI- QA Audit Manager-S.-levin, Defueling Director l W. Potts, Site 0perations ' Director i R. Rogan, Director, Licensing & Nuclear Safety D. Turner, Director, Radiological Controls, TMI-2  ;

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

licensee'by the inspector i

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