IR 05000320/1987012

Safety Insp Rept 50-320/87-12 on 870829-0930.No Violations Noted.Major Areas Inspected:Plant Operations,Defueling Operations,Housekeeping Conditions,Radioactive Matl Shipment,Radioactive Resin Movement & Radiological Controls

ML20236B855
Person / Time
Site:	Three Mile Island
Issue date:	10/22/1987
From:	Bell J, Dan Collins, Cowgill C, Moslak T Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236B816	List: IR 05000320/1987012 ML20236B814
References
50-320-87-12, NUDOCS 8710260380
Download: ML20236B855 (11)

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.U. S.. NUCLEAR REGULATORY COMMISSION-Report N /87-12 i

. Docket N Category C'

License No. DPR-73 Priority --

] 1 Licensee: GPU Nuclear Corporation {

. . l P.O. Box'480~ J l

Middletown, Pennsylvania 17057 j Facility Name: Three Mile'Islan'd Nuclear Station, Uni Inspection At: Middletown, Pennsylvania Inspection Conducted:- August 29, 1987 - September 30, 1987' -

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Inspectors: h /A n yi h T. MotlaR, Resident Ins

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/ector(TMI-2)

// 7 da'te signsd J B

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1, Senior Radiatioh Specialist

/D k87 date fignb .i

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0AR D. Collins, R iation Specialist

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date signe~d Approved By: M M C. Cowgil1,/ Chief, Project 7/Section 1A

- /d /dA 62 date-signed i

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Inspection ~ Summary: q Areas Inspected: Routine safety inspection by site inspectors of plant 1 operations, defueling. operations, preparation of defueling canisters fo j shipment, plant' housekeeping conditions, shipment'of radioactive' materials, j radioactive resin movements, the dose reduction and decontar:ination program, . 1 the implementation of~ radiological controls, licensee event report review and j followup, the control of radioactive materials, licensee conduct of an oral j qualification board, and licensee action on previous. inspection finding ;

Results: No violations were identifie q l

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DETAILS j 1.0 Routine Plant Operations l

Inspections of the facility were conducted to assess compliance with the q requirements of the Technical Specifications and Recovery Operations Plan 4 in the following areas: licensee review of selected plant parameters for l abnormal trends; plant status from a maintenance / modification viewpoint, l 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 implementatio Inspections of the control room were performed during regular and j backshift hours. The Shift Foreman's Log and selected portions of the i Control Room Operator's Log were reviewed for the. period August 29, 1987 1 through September 30, 1987. Other logs reviewed during the inspection ;

period included the Submerged Demineralized System Operations Log, j Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log l

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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 inspector attended selected licensee )

planning meetings. Shift staffing for licensed and non-licensed !

personnel was determined to be adequat i

No violations were identifie .0 Licensee Action on Previous Inspection Findings

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(Closed) Violation (320/87-04-01): Inadvertent Operation of DWC-P-10 Based on an examination of revisions to procedures 4000-ADM-3020.04,

" Switching and Tagging Safety", and 4000-ADM-3020.06, " Status Tagging", and discussions with licensee personnel, the inspector determined that corrective actions being implemented to provide additional clarification-for the use of safety and status tags were l appropriate to preclude similar circumstances that previously l resulted in the inadvertent operation of DWC-P-10 The inspector had no further questions regarding this matte !

-- (Closed)' Inspector Follow Item (320/86-15-09): Guard Appeared to be Inattentive to Dut The inspector discussed his observation with the Security Manager,.

TMI-2, and determined that a program is in place to frequently rotate security personnel from their watch stations during their work shift. This action and other management oversight programs (e.g. unannounced backshif t inspections by .nanagers and quality

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" assurance personnel)'are designed to assure and monitor the ; d attentiveness of: security personnel during off normal work hour l The inspector had no further questions'regarding this matte .

-- .'(Closed)InspectorFollow-Item'(320/84-23-01): Non-representative j

.RCS Samples - LER 84-2 ;

The inspector reviewed modifications made to the. nuclear samplin i-system to assure'that a; representative RCS sample is;obtaine Presently, RCS' samples can be obtained using the vent line from the !

'boronometer, providing that the boronometer has been operating for: i-at.least.four.houce prior to'taking the sample.- This. time period of l operation allows-for a sufficient volume through-put for aLthree i line: volume. exchange of'RCS sampl Through witnessing RCS '

sampling', discussions with licensee. personnel, and review of the-j sampling procedure (4212-0PS-3551.02), the inspector concluded that measures have been implemented to assure representative samples are being obtaine '

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The inspector had no further questions on this matte j 3.0 Licensee Event Report (LER) Review and Onsite Followup The' inspector reviewed LER 87-07.to verify that the details of the event ,

were clearly reported, including-the accuracy of the description. of the, causes and the adequacy of corrective actions. The inspector determined whether furthe'r information was required from the licensee, whether the' ;

event should .be classified as an Abncrmal Occurrence, whether generic - 1 implications were indicated, and whether the' event warranted onsite followu LER 87-07, dated September 17, 1987, addresses the inoperability of the Cable-Room and Transformer Room halon syste i During the 2300-0700 shift commencing on August 7, 1987, a Quality Assurance (QA)monitorobservedanapparentabnormal'pressureindication i onone(1)of19haloncylindersfortheCableRoomandTransformerRoom

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Halon Syste Specifically, halon bottle FH-165-002164. indicated ,

approximately 340 psig. .It was later determined that this indication was l 200 psig less than the minimum limit, i.e., 90% of full pressure, required by the Limiting Condition'of 0peration (LCO) Technical'

Specification (Tech. Spec.)3.7.10.3. However, the QA monitor did.not a realize that the observed condition constituted noncompliance with the  ;

referenced LCO until August 18,:1987, when the event was: discussed with the TMI-2: Fire Protection Engineer. Accordingly, at 1408; hours on August 18, 1987, the action. statement of Tech. Spec. 3.7.10.3 wasi.ntered. The required hourly firewatch and backup-fire suppression equipnent were established within one'(1)' hour-and restoration'of the system to operable j status was accomplished within 14 days. A replacement halon bottle;was: !

installed and the system was. initially restored to operable status at 0740' hours on7 August.20, 1987. ~Although compliance with the 14-day 1 timeclock was achieved, the failure to. establish.the hourly firewatch'on August 7,.1987, resulted in a' condition prohibited by the. Tech. Specs and

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1 is reportable pursuant.to: 10CFR50.73(a)(2)(1)(B). . 0n September 6, 1987,,-the' pressure'of.the. replacement halon bottle was observed to-b l ,

less'than~-the minimum Tech. Spec. limit. An investigation determined  ;

that the root cause-was a deficient: solenoid pilot valve. 'The valve was'

replaced and the system was. returned.to' operable status on September 12, 1987..A procedure-change will be initiated to require leak testing.of the cylinder valve and solenoid pilot valve fittings uponl replacement of

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On.Septembar 21,.19'87,- the. inspector examined the. pressure. indications on- 1 the halon bottles'and= determined that the halon gas pressure met:the 1 requirements of Tech.' Spec. 3.7.10.3. Through discussions with licensee

. personnel and examination of procedure' change request'No._'87-0724_for procedure 4224-SUR--3812.03. ." Fire System Halon' System Check", that is:

presently in the licensee's review 'and approval cycle, the inspector concluded that the licensee is taking appropriate. actions to preclude a L similar occurrenc '4.0 Defueling Operations During-this reporting period, pick and place.defueling'of.. partial'. length:

(stub) fuel assemblies continued. Defueling operators had exceeded their-monthly goal of 28 stub assemblies by removing 39 stub assemblies'from the core region and placing them into defueling canisters. This brings i the total assemblies removed to 132 of 177. Individual: fuel' pins that-are loose or.' splayed within a- fuelLbundle have been cut, using hydraulic ,

shears, and used to " top-off" partially loaded canisters. .Some l agglomerated, once' molten material, in the core region, called " rocks",

has also been loaded. Currently, approximately 160,000 lbs. out of  ;

approximately 300,000 lbs. of core debris' and other materials has been

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l loade Completion of removal of stub assemblies is expected in December q of this yea This will complete defueling.of the core region. The next l

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two areas to be defueled are the lower' internals and-the lower head. The j lower internals is the region between the lower grid top' rib'section and- 1 the elliptical flow distributor. This area contains a mixture of: loose  !

material'and solidified, once molten material in the spaces between the 4 L horizontal structural components and in the flow holes >of the structural !

l components. The lower head is the hemispherical bottom of the reactor j vessel and contains a mixture of loose, sand-like, material and resolidified agglomerate Defueling of the areas' between the baffle plates and the core barrel is ~

scheduled subsequent to defueling the lower head. -Additionally, the  ;

decay' heat drop line has a significant quantity of fuel'and will be ~?

defueled-concurrently with the remainder of the reactor coolant system piping'in early 1988.;

During September, ex-vessel.defueling has concentrated on fuel. removal- I from the upper tube sheets of the steam. generators. The "A" steam  !

generator' upper tube sheet was cleared.of debris by pick and place and- i vacuuming. Pick and _ place yielded about 5 lbs. of' rock / gravel like

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I debrisLwhile vacuuming produced about 5 lbs. of finer debri Preparations are being made to begin defueling the "B" steam generator.in early Octobe )

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l 5.0 Defueling Canister Preparation for Shipment ]

On September-18 and 28, 1987, the inspector witnessed various steps performed in the preparation for shipment of filled defueling canister ,

Prior to shipment, canisters containing core debris are initially weighed .i I

.upon transfer to the "A" Spent Fuel Pool, disinfected by adding H 0 2 to thecanister,dewateredandconcurrentlyblanketedwithArgoncov$rgas, stored for a 1 to 2 week period, gas samples obtained to determine the concentrations of Hydrogen and Oxygen, and final dewatering is performe On September 18, 1987, the inspector observed the addition'of H 20 to canisters and the subsequent sampling and analysis of liquid grkb samples l taken'from the canisters. Grab samples are taken to assure that the concentration of Hp70 does not decrease to less than 200 ppm during the ninety minute recirculation period in.which core materials are disinfected. The inspector determined that the addition and recirculation of the disinfectant (H 0 ) were performed in accordance j

with the operating procedure, 4215-0PS-3255.01, and that the liquid grab l samples were analyzed per chemistry procedure, 4212-CHM-3013.2 The !

inspector observed that the H 0 concentration decreased from 1000 ppm J upon addition to the canister27 to 300 ppm after recirculatio l The inspector also verified that radiological controls as specified on the radiation work permits were implemented by operators and chemistry technician No violations were identifie >

6.0 Monthly Surveillance Reactor Coolant System (RCS) Sampling and Analysis On September 28, 1987, the inspector witnessed the obtaining of an RCS sample and its subsequent analysis. The sampling and analysis are 3

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required in accordance with Technical Specifications 4.1.1.2.A.2 and 4.4.9.1.4/5, to determine the pH and concentrations'of baron and i chlorides in the RCS.

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j During the sample acquisition, the inspector determined that the l chemistry technician followed the latest revision to the sampling i procedure (4212-0PS-3551.02 Revision 3-01) and implemented the t radiological controls to limit the spread of any contamination,that may i

result while sampling. The inspector verified that a radiological- l

controls technician measured the dose rates of the sample and properly i

! bagged and labelled the sample prior to its transfer to the laborator i

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For the determination of the boron concentration, the inspector observed

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the standardization of the sodium hydroxide, the analysis of.a 1000 ppm ,

l Baron standard, and the sample analysis. The inspector determined that j

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the analysis was generally performed in accordance with the approved <

. procedure (4212-CHM-3013.12), but noted that sections 6.1.3.5 and 6.1. i were not strictly adhered t These sections stipulate that the !

technician is to record the volume of titrant at the endpoint which is j achieved when the pH remains constant at 8.5 for 15 seconds. The .

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inspector observed'that the. technician' relied on judgement when the 1 l endpoint was reached and did not actually time the period during which- ,

the pH was. constant. .The inspector discussed this with the Chemistry Laboratory Foreman and was assured that these procedural steps would.b appropriately' clarifie t From'a review of the results of the laboratory analysis, the inspecto q determined that the concentrations for boron and. chlorides., and the pH of -

RCS water met the Technical Specification criteri .0. Health Physics and Environmental Review j

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7.1 Plant Tours 1 The NRC site Radiation Specialists. performed inspection tours of the j i plant, including all radiological control points and selected' j radiologically controlled areas. Among the areas inspected were the J l

reactor building, the Auxiliary'and Fuel Handling Buildings,.

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 j Radiological Controls Instrument Facility, l

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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 protection equipment l

-- Adherence to radiation protection procedures 1

-- Use of survey meters and other radiological instrument The inspectors reviewed the implementation of radiological controls i during day shifts, on backshif ts, and on weekends. Log books  ;

maintained by Radiological Controls Field Operations to record activities in-the reactor building'ard the balance of the plant were reviewed for completeness and accuracy. All of the log-books .i '

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

9/12/87 7:00 PM to 9:00 PM 9/13/87 8:30 AM to 10:00 AM 9/15/87 4:30 PM to 6:30:PM 9/15/87 8:30 PM to 11:00 PM 9/16/87 4:45 PM to 5:45 PM i

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~9/17/87 4:45 PM to 5:15 PM 9/20/87 8:00 PM to 10:00 PM 9/21/87 4:45 PM to 5:30 PM 9/24/87 10:30 PM to 12:30 AM 9/27/87 -10:30 PM to 12:30 AM 9/28/87 4:45 PM to 5:15 PM 9/29/87- 11:30 PM 'to 1:30 AM ,

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'No violations were identifie .2 Reactor Building Entrie The inspector monitored the licensee's conduct of. reactor building l (RB) work during the inspection period. The following were reviewed .l on a sampling basis during the inspection period:

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The planning and coordinating of RB entries, including ALARA' ]

reviews, personnel training, and equipment preparatio ]

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-- The planning and implementation of radiological safety measures, including the use of RWPs, locked high radiation area access authorizations, specific work instructions, alarming 1 1 l self-reading dosimeters, and breathing zone air sampler .

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Reactor building entry perscnnel training in emergency . )

procedures and with mock-ups, where warranted; and the use by entry personnel of specifically developed procedures for unique task The use of appropriate communications equipmen .3 Radioactive Material Shipments l 'The inspectors reviewed the preparation and conduct of radioactive materials shipments on Septemoer 3, 11, 17, 24, 25. The inspectors also observed preparations and execution of a railcar-mounted cask shipment of TMI-2 core debris from TMI to the US Department of Energy on September 13, 198 The inspector's reviews covered:

-- Verification that the recipient is properly licensed ,

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

-- Verification of compliance with approved packaging and shipping procedures

-- Completed shipping papers

-- Package labeling and vehicle placarding

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Instructions.to vehicle operators

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-~ Verification of compliance with' regulatory 'l'imits for-radioactive contaminat'on and radiation dose rate l The inspector's review consisted of observations of shipping ,,

canister loading, performance of radiation and contamination j surveys, and examination of shipping papers, procedures,- sind i i

vehicle No violations were identifie ,

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7.4 Records Review Theinspectorreviewedselected,IRdseerecordsrelatedto occupational radiation exposure With respect to their accuracy and completeness, including Radiation ~ Work Permits (RWPs), Dosimetry '

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Investigative Reports, Incident / Event Reports, Radiological .

Awareness Reports, Dosimetry E.xception Reports, Bioassay Reports, Respiratory Protection Device Fit Tests, and medical examination i The inspector also reviewed'other licenset records and periodic 1 reports concerning the' radiological controls program, including f current data and trends in such areas as person-rem per RWP hour, '

decontamination status, skin contaminations, environmental monitoring, progress toward acMeving goals and objectives, storage tank radioactivity content > airborne radioactivity, effluent -

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releases (including sump releases and sources of sump , .

W contamination), and the cumulative dose to plant pyrsonnei !

No violations were identifie J 7.5 Control of Radioactive Material 4

As described in Report 50-320/87-09, the licensee has intensified its efforts to improve radiation surveys a i identify radioactive contaminatio Two events were reviewed during the inspection period as part of the inspector's followup of licensee efforts. 'The first resulted in licensee Incident / Event Report (IER 87-077).and involved two surveys of the same truck by two Health Physics Technicians (HPTs), one at Unit 1 and one at Unit 2, with significantly different results. It appears that a major contributing cause for the differing results was different survey technique In an effort to establish greater consistency in survey results, the licensee is meeting with' appropriate personnel at Oyster Creek and TMI Unit 1. The inspector was informed that survey guidance.and procedures, and HPT survey practices are being evaluated as part of I

this effort. The licensee is also evaluating a-large area radiation survey probe in an effort to improve survey efficiency in terms of both time and area covere The second event involved five surveys of the same truck, at

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different times, over a period of one week, with significantly different results. In addition to concern over HPT survey l

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i-effectiveness, the licensee is concerned about the possibility of

'- recontamination of vehicles and the migration of contamination from one location to.another on the same vehicle. As a result, the licensee is developing a program to better control vehicle l contamination and define the sources of vehicle contaminatio No violations were. identified, licensee efforts in this area will l be followed by the inspector as part of.open item 320/87-09-0 .6 Steam Generator Tube Sheet Debris j i

The inspector reviewed the licensee's removal of core debris from l-the upper tube sheet inside the "A" once-through-steam-generator 'l (OTSG) on September 14 - 19, 1987. During the 1979 accident, core !

L debris of various. sizes was carried into the piping leaving the J

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reactor vessel and entering the~0TSG. Debris-too large to pass j'

through the individual steam generator tubes (about 1/2 inch diameter) was captured on the tube sheet. About 15 pounds of material were removed by using long-handled tools and vacuuming ]

device l The work location was inside the "A" D-ring, accessed from the 367'

elevation._ Because of the high radiation fields, permission to !

enter the area was granted only by the Radiological Controls Director following the completion and review of all radiological

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protection related measures. Radiation dose rates around the man-way access to the upper tube sheet required shielding of the work area and dry-run training of work crews in order to maintain worker doses at ALARA levels. A mockup of the OTSG and work area i were constructed in the Unit 2 turbine hal Time and motion studies were made, and movements into and out of the work areas were rehearsed. The equipment was then moved into the reactor buildin The ALARA review (87-0085) included an estimate of 15 - 20 man-rem for the jo Because of thorough planning, training, efficient operations, and the smaller-than-expected amount of debris, only man-rem were use No violations were identified. Further work with the "B" 0TSG will be followed as part of the routine inspection progra .7 Movement of Solidified Spent Resin j Because of the relatively high radiation levels involved, the l-inspector reviewed preparations for, and the transfer of, a 5 x 6 ,

liner from the basement of the auxiliary building to the waste j storage modules. The liner containing olidified reactor coolant j cleanup demineralized resin was transferred on September 22, 1987 at i

.about 11:00 A The inspector reviewed the "ALARA Review" l (Procedure 9200-ADM-4010.02, Rev. 3) covering the transfer, !

applicable Radiation Work Permits (Numbers 16440 and 16379), and l worker exposure records. The inspector also interviewed involved l workers and observed the performance of radiation surveys and the 1 posting of affected areas inside the~ Unit 2 auxiliary building as '

well as in handling areas outside the auxiliary buildin i l

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'The: preparation and movement of the liner from the:hoxiliar ~

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building, its placement in,a shie'1d on the transporting truck and its movement to the waste modules was-accomplished smoothly an ~

expeditiously. . Although: the' liner external . radiation level of about-40 R/hr significantly exceeded the calculated values (probably' ;

because of r'esin sampling difficulties), the increaseo radiation 1 levels did not result in any violations, and personnel doses did notl

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greatly exceed pre-job es.timate :1 DThe inspector expressed' concern-to the-licensee with respect to planning for the transfer in the areas of radiation level .

' determinations., posting, notification'of.those2in: adjacent work

areas (e.g.;to prevent concern over.the triggering of sensitive radiation level alarms), worker uncertainty over which RWP(s) to i sign.onto, the completeness'of RWPs-at control, points, and the-revision.of pre-job' assessments ("ALARA reviews):in a more complete

.and detailed manner when work' scope changes.are mad Additional; r'esin transfers are anticipated .in the 'near future and the inspector will follow preparations for, and the . execution .of;

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these transfer .8 -licensee Dose Reduction and Decontamination Program ,

On September 8, 1987, the inspector and other TMICPD staff members l were briefed by licensee staff. members on the status of.the  !

licensee's decontamination'and radiation level reduction. program for d both the reactor building and the balance of the plant and the .i licensee's plans for further activities in this. area'.

Further progress has been made in all' major areas of decontamination. The auxiliary building sump andLreactor building sludge removal has'been completed and the reactor building gross flush is in-progress. Seventy-five : percent of the previously contaminated areas (462,708 sq.ft.).of,the' auxiliary and fuel ,

handling buildings have been decontaminated, 11. systems flushes out !

of 22 planned.have been accomplished, 2 of 10 tanks'desludged and 7 I of 9 demineralizers cleaned. Of 143 contaminated: cubicles,.107 have been decontaminated, leaving 36 to be. decontaminated. Twenty-three I of the remaining 36 are scheduled-for decontamination in 198 Projected cumulative worker dose for 1987(1027 person-rem) is below ]

the licensee's goal of 1175 person-rem and justl120 person-rem (13%)

obove the 907 person-rem total -for 1986. .The major contributor to

,the aversion of doses during'1987.is the reduced' dose. rates' on the

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shielded defueling' work platfor The results of a licensee study of the variousioptions for _

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decontaminating'the reactor.' building basement are expected. shortl '

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Such options. span the range from' leaving the basement virtually as-is to utilizing: mechanical and chemical means to' physically remove the contaminated material. Leach tests are still in' progress as~a I bdsis for determining the feasibility of removing radioactivity from~ -

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the. reactor building basement by flooding part or all: of it,followed

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by processing of the water to remove the radioactivity. The results ,

of these tests will-be considered in an upcoming licensee repor l l

7.9 Licensee Oral Board j The inspector observed an oral board examination of a candidate for I the position of Group Radiological Controls. Supervisor. (GRCS) on- -

September 17, 198 .

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The composition of the board, the conduct of the examination and !

evaluation of the candidate's performance were all consistent with ta licensee's procedure 9100-ADM-2622.02, Rev. O, " Oral Board '

Exansinations for Radiological Controls Technicians and Group-Radiciogical Controls Supervisors". The questions presented to the l candidate were of a practical, realistic nature and emphasized the supervisory role of the candidate in each situatio Th candidate's responses indicated an adequate level'of knowledge and competency resulting in her assignment to the position of GRC l The inspector had no further question .0 Open Item Matters that require further review and evaluation by the inspector Open items are used to document, track, and ensure adequate followup on matters of concern to the inspecto Open items are add essed in paragraph .0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On October 1, 1987, the site inspectors summarized the inspection findings in a-meeting with the following personnel:

J. Byrne, Manager, TMI-2 Licensing W. County, QA Auditor C. Dell, Technical Analyst, Licensing S. Levin, Defueling Director W. Potts, Site Operations Director D. Turner, Director, Radiological Controls, TMI-2 At no time during the inspection was written material provided to the -

licensee by the inspectors.