IR 05000320/1987014
| ML20148R516 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/12/1988 |
| From: | Bell J, Dan Collins, Cowgill C, Krasopoulos A, Moslak T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20148R491 | List: |
| References | |
| 50-320-87-14, GL-82-21, NUDOCS 8802020212 | |
| Download: ML20148R516 (22) | |
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U. S. NUCLEAR REGULATORY COMMISSION Report N /87-14 Docket N 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 ucted: October 1x 1SR7 - November 25, 1987 Inspectors: 1 / m /qX7 T.' Moslak', Rbs idenf Inspector (TMI-2) date sYgne~d
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Lk /f/Lf88 Senior adia ion ~ Specialist d6te/ signed A & .n
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, I Ra i Specialist date signed A R \ / f t/R ~
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A. Krasopoulo), Reactor Engineer d&te (>igned Approved By: Mb h C. Cowg4'll, Chief, Projects Section 1A
[c /dh 3 ate signed Inspection Summary:
Areas Inspected: Routine safety inspection by site and regional inspectors of plant operations, defueling operations, fire protection program, plant housekeeping conditions, shipment of radioactive materials, radioactive resin movements, the implementation of radiological controls, licensee event report review and followup, the control of radioactive materials, and licensee action on previous inspection finding Results: No violations were identifie PDR ADOCK 05000320 G PDR
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DETAILS 1.0 Rcutine 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 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 October 1, 1987 through November 25, 1987. Other logs reviewed during the inspection period included the Defueling Water Cleanup System Operations Log, Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Loa 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 fer licensed and non-licensed personnel was determined to be adequat No violations were identifie During this inspection period, the inspectors conducted backshift, weekend, and holiday inspections on the following days:
10/12/87 8:00 AM to 4:30 PM (Holiday) 11/12/87 5:45 PM to 6:30 PM 10/18/87 6:15 PM to 8:15 PM 11/15/87 8:00 AM to 9:45 AM 10/25/87 9:00 AM to 11:00 AM 11/16/87 4:30 PM to 5:30 PM 11/3/87 11:00 PM to 12:00 Midnight 11/22/87 8:40 PM to 11:40 PM 11/4/87 12:00 Mid to 2:30 AM 11/23/87 4:30 PM to 5:30 PM 11/11/87 3:00 PM to 4:00 PM (Holiday) 11/24/87 7:50 PM to 10:50 PM 2.0 Licensee Action on Previous Inspection Findings
-- (0 pen) Non-Compliance (320/87-09-01): Failure to perform adequate surve This item was generated as a result of a radiological technician failing to perform a radiological survey prior to the intra-site transport of packaged radioactive material Personnel, vehicle and
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material contamination resulte The inspector found the licensee's corrective actions acceptable and appropriate to preclude similar events. However, the licensee's
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' corrective action in the form of a change to its radioactive inaterial transfer procedure (9200-ADM-4430.01) had not been implemented and will be reviewed in a later inspectio (Closed)InspectorFollowItem(320/87-02-01): Licensee to issue procedure revision for fuel canister transfers The inspector determined that revision 4 to procedure 4211-0PS-3252.01, "Canister Transfer System," addressed the notifications needed to assure a safe transfer of loaded fuel debris canisters through the fuel transfer system tubes between the reactor building and the "A" spent fuel pool in the fuel handling buildin The inspector detennined by frequent observations of canister transfers that the procedure requirements were being met and had no further questions regarding this matte (Closed) Inspector Follow Item (320/87-01-02): Licensee review of alpha airborne on platform resulting from respiratory protection discontinuatio The inspector expressed concern to the licensee in February 1987 with respect to the level of MPC-hour (Maximum Permissible Concentration Hours) exposures being assigned to workers on the shielded defueling work pistform (SDWP). The licensee subsequently determined that the airt ene exposure limit in use at that time was overly conservative. Although the licensee has established a higher limit, consistent with regulatory requirements, it was determined i that respiratory protective devices would continue to be worn by SDWP workers and are being worn at this tim The inspector reviewed licensee studies and determinations, including personnel airborne exposure records, related to personnel use of respiratory protective devices on the shielded defueling work platform. MPC-hour assignments continue to be far below regulatory limits and are consistent with the type of work and airborne radioactivity levels on the SDW The inspector had no further questions regarding this matte (Closed) Inspector Follow Item (320/86-15-08): Calculation of airborne activity improperly performe The inspector has observed the calculation of air volume through air samplers and subsequent Group Radiological Control Supervisor review of the air sampling methods and logs. No discrepancies were identified between January and September 198 The inspector had no further questions regarding this matter.
! -- (Closed) Inspector Follow Item (320/86-15-06): Use of routine radiation work pernit (RWP) for work in highly contaminated areas.
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' The inspector determined that Radiological Controls Field Operations (RCF0) management has implemented a policy dictating the use of j job-specific RWPS by technicians providing job coverage, i.e., the RCF0 technician will work under the same job-specific RWP as the other workers involved in the jo l
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The inspector had no further question (Closed) Inspector Follow Item (320/86-15-05): NRC review of assignment of intake to technicia The inspector reviewed an assignment of intake MPC-hours for the technician involved in the January 2, 1987, incident. The licensee's calculations were based on a urine sample collected January 7-8, 1987, shipped to a vendor laboratory and results reported on March 2, 1987. The calculation, based on ICRP 10 methodology, was acceptabl The inspector had no further questions regarding this matter.
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-- (Closed) Inspector Follow Item (320/86-15-01): Implementation of canister preparation procedure Through discussions with Rad Waste Operations and Quality Assurance (QA) personnel and review of relavant documents, the inspector
' determined that there have been no recurrences of the under-torquing of canister closure head bolts following tho' implementation of corrective actions that resulted from the initial incident in l
December 1986. The licensee has assured that the bolts are properly l torqued by requiring the operators to comply verbatim, with sign-off, with a series of procedures that tracks the filled l
canister from its initial closure in the reactor vessel through its final preparation for shipment in the "A" spent fuel poo The inspector had no further questions regarding this matte (Closed) Inspector Follow Item (320/86-10-02): Operational problems
! with defueling activitie On October 21, 1987 the inspector entered the reactor building to evaluate defueling activities and general working conditions. The inspector observed that improvenents have been made in overall housekeeping, i.e., walkways were clear, tools stored in designated areas, and fire protection equipment readily accessible. The inspector noted that changes have been made on the defueling platform to improve the conduct of defueling operations. These include improving the lighting, modifying the controls to the video monitors to facilitate operation when wearing protective clothing, and re-routing hydraulic hoses and electrical cords to eliminate tripping hazard Based on these observations and upon discussions with licensee representatives, the inspector concluded that improvements have been
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made on the work platform to increase the safety and efficiency of defueling operation The inspector had no further questions on this matte (Closed) Inspector Follow Item (320/86-10-01): Evaluate effectiveness and completeness of the biennial review of procedure The inspector discussed the Procedure Periodic Review Program (PPRP)
with cognizant licensee personnel responsible for implementing the program. Through these discussions and through review of relevant documents, the inspector determined that the PPRP is a formalized program maintained in a data processing format and coordinated by the Man &ger - TMI QA Modifications / Operations. The program is set up to produce a quarterly report that indicates procedures which are due for their biennial review and provide a periodic review report on those procedures that have passed their review due dat Quarterly reports of all procedures overdue for review are issued to the Director, TMI-2 and the Manager - TMI QA Modifications /
Operations. Within the TMI - QA Modification /0perations Department, a person has been assigned as an expeditor to contact department heads to assure reviews are performed in a timely manner. The inspector reviewed procedure 4000-ADM-1218.08, Revision 1, and determined that a two page checklist is provided to the responsible office for each procedure being reviewed that identified the specific technical and administrative criteria against which must be met to complete the revie The inspector had no further questions on this matte (Closed)Non-Compliance,(320/86-09-03): Contaminated tripod in unrestricted area onsit The inspector noted that despite the corrective actions taken in response to this item, additional contaminated equipment has been found in uncontrolled areas. The most recent example occurred June 7, 1987, and resulted in the issuance of a notice of violation (Inspection Report 50-320/87-04). This item will be further reviewed as part of open item 320/87-04-0 (Closed) Inspector Follow Item (320/86-05-01): Operator training for specialized tasks in reactor building (RB).
The inspector determined that operators are trained for specified tasks in the RB. Each defueling crew is assigned for one week and Monday's activities normally consist of refresher training and training on new tools prior +o work in the reactor buildin The inspector had no further questions on this matte (0 pen) Inspector Follow Item (320/84-24-04): Submerged demineralizer system (SDS) liner inleakage determination . _ ___
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This item was generated out of a concern with respect to the water content of SDS liners as prepared for offsite shipment. The determination of water content is related to the establishment of-compliance with shipping requirements and limitations pertaining to hazardous gas generation. In this case, the gas would be hydrogen gas resulting _from the radiolytic decomposition of the water contained within the radioactive spent resin in the SDS line The current hiatus in SDS liner shipments will end early in 1988 when a campaign will be initiated to ship approximately 36 liners now in the SDS system or in underwater storag During recent discussions with the licensee, the inspector expressed concern that appropriate steps be taken, including documentation, to ensure that appropriate, effective, and accurate determinations are made as a basis for establishing compliance with transport requirements. Licensee _ representatives assured the inspector that appropriate written procedures would be implemented prior to further shipments. This item will be reconsidered at such time as the procedures become available for revie (Closed) Inspector Follow Item (320/84-12-03): Applying quality controls to the purchase of off-the-shelf shielding material As a result of identifying manufacturing defects in commercially supplied shield components, i.e. lead blanket hangers and water filled fiberglass columns, the licensee no longer purchases these components from the original vendor Instead, the licensee has fabricated lead blanket hangers on-site to meet specific shielding requirements. No fractures of hangers have occurred since the initial _ incident in July 198 The inspector has no further questions on this matte (Closed) Unresolved (320/84-09-04): Administrative procedure compliance in review of temporary procedure chang This item resulted from the inspector questioning whether a licensee modification to a Unit Work Instruction (UWI) exceeded the licensee authority for making minor changes. The authority to change UWIs as specified in step 4.5.4.1 of procedure 4000-ADM-3000.01, "Unit Work Instruction" limits changes to those not intended to change the scope or direction of a UWI. For work within the protected area the change must be approved by the system's cognizant engineer and the plant shift supervisor (a licensed senior reactor operator). The present guidance appears to be adequate to prevent changes exceeding the licensee's authorit The inspector had no further questions on this matte (Closed) Unresolved (320/83-16-01): NRC to review TMI-2 support to TMI-1 and the Project Organization and Responsibilities Document (PORD) delineation of responsibilities.
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This item was generated as a result of apparent Unit 1/ Unit 2 coordination problems within the licensee's program for processing, handling, and shipping radioactive materials. Several inspections have ~been made of all aspects of the licensee's programs at both Unit 1 and Unit 2 in the ensuing four years and have established that Unit 1 and Unit 2 coordination in these areas is acceptabl The inspector had no further questions regarding this matte (Closed) Inspector Follow Item (320/83-02-03): Lift mechanism (spider) has switch which stick As noted in the update of this item in Inspection Report 50-320/84-25 (February 21,1985), the refurbished spider mechanism was used to provide emergency access capability for the plenum lif The inspector reviewed the operation of the spider as part of the plenum lift, and had no further question (Closed) Unresolved (320/81-15-05): Evaluation of total stack flow vice summing of individual input The inspector has determined that a new flow totalizer has been procured, installed and calibrated in accordance with the manufacturer's direction and plant procedures. The installation and calibration was completed November 15, 1986, under Unit Work Instruction (UWI) 4200-3661-83-130 The inspector had no further questions on this matte .0 Licensee Event Report (LER) Review and Onsite Followup The inspector reviewed the following LERs to verify that the details of the events were clearly reported, including the accuracy of the description of 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 87-08, dated October 28, 1987 addresses a "Hot Particle" of radioactive material being found in an unrestricted area.
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At approximately 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> on September 29, 1987, the portal monitor (PM-6) at the Unit 2 Personnel Search Center alarmed as an individual passed through it. A direct frisk of the individual located a single hot particle reading 12,000 cpm (approximately 120,000 dpm) located on his pants. Isotopic results of the hot particle indicated Sr/Y-90 activity only. The individual, a Radiological Controls Technician, had perfonned various radiological duties during the course of his shif Several times during the shift, the individual passed through the PCM-1 at the Health Physics
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Control point -(HP-2) and transited non-radiological controlled areas (i.e., an unrestricted area).
The contamination levels of the hot particle were in excess of ten (10) times the limit set forth in the GPU Nuclear Corporation-Radiation Protection Plan, which is a Licensing Basis Documen Therefore, this event is reportable pursuant to 10 CFR 20.405(a)(1)(v).
The root cause of this event is considered to be the detection capabilities of the PCM-1. Upon discovery, the hot particle was removed. As a long-term corrective action, a posting has been erected at the PCM-1 that provides guidance on the proper posture to be taken while being monitored. In addition, Radiological Engineering will perform a study to assess the effectiveness of the PCM-1 in detecting hot particles. A dose assessment of the individual's skin was performed. The calculated skin exposure of 1230 mrem was within the regulatory limits of 10 CFR 2 This event is similar in nature to LER 86-06, 87-02, 87-05, and 87-06 in that radioactive material was discovered in an unrestricted are LER 87-09, dated November 2, 1987, addressed a contaminated banding tool found in an unrestricted are On Tuesday, October 6, 1987, a millwright transporting a banding machine out of the protected area alarmed a Personnel Contamination Monitor (PCM-6). Radiological Ccntrols Technicians detemined that the banding machine was internally contaminated. The highest level of contamination was found to be 350,000 dpa direct reading and .
200,000 dpm/ smear of loose surface contamination inside an air supply coupling. The levels of contamination present in the coupling are in excess of ten (10) times the limits established in the GPU Nuclear Corporation Radiation Plan, which is a Licensing Basis Document. Therefore, this event is reportable pursuant to 10 CFR 20.405(a)(1)(v). The root cause of this event was a less than adequate survey of the air supply coupling prior to its release from a controlled area to an unrestricted area. Since the banding machine had been in service for about one year, it is known that the fitting was released from a controlled area at least a year ag However, the time of release, the contamination source, the coupling's previous use locations, and previous survey data could not be determined. The couplings on the service air supply where the banding machine had been connected were renoved and handled as radioactive material. The banding machine was transported to a radiologically controlled area, and the work areas where the banding machine had been located were surveyed and found clean. The service air system was sampled upstream of the banding machine and was found to be clean. The storage bin in which the contaminated coupling was at one time stored was surveyed and two other items were discovered which did not meet present release criteri .
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This event is similar in nature to LERs 86-06, 87-02, 87-05, and 87-0 .LER 87-10, dated November 4, 1987, addressed the inoperability of the EDICOR II Ventilation Radiation Monito ,
On July 15, 1987, EPICOR II Ventilation System Radiation Monitor (ALC-RMI-18) was replaced with an Eberline PING 2A. type monito This modification resulted in the sample flowrate monitor being changed from a photohelic type monitor to a rotameter and pressure gauge combination. Table 2.1-3b of the Appendix B Technical Specifications (TS) requires the sample flowrate monitor to be calibrated semi-annually. These surveillances had been performed previously in accordance with Surveillance Procedure 4221-SUR-3526.01. However, the engineering change and implementing documentation did not specify the performance of this procedure as part of the criteria for placing the replacement monitor in scryic The failure to do so resulted in ALC-RMI-18 being in an inoperable condition, per the TS and should have required compliance with Action Statement 36 of Table 2.1-3a. On October 6, 1987, during the preparation of a procedure change to 4221-SUR-3526.01, the Safety Review Group (SRG) was consulted and identified the above conditio Compliance with the above referenced Action Statement was achieve On October 7,1987, this event was determined to be reportable due to the failure to recognize and comply with the action statement upon the installation of the replacement monitor. This event is reportable per 10 CFR 50.73(a)(2)(1)(B) due to a condition prohibited by the plant's TS. The sample flowrate monitor was surveilled, determined to be within calibrated limits, and restored to operable status on October 9,1987. The Cognizant Engineer and Responsible Technical Reviewer (RTR) for this event have been counseled. This event also will be discussed with all the Cognizant Engineers, RTRs, and SRG. The surveillance procedures for the EPICOR II monitor will be reviewed ~and revised, as necessary, to ensure compliance with the TS. This LER is similar in nature to LER 86-0 The inspector has determined these corrective actions to be acceptabl .0 Fire Protection and Prevention Program Purpose and Scope This inspection was conducted to verify the adequacy of the licensee's fire prevention and protection program. The major emphasis was in the
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plant housekeeping and construction work practices since these activities would increase the plant's fire hazard The inspector also reviewed the fire brigade training. the condition and maintenance of fire fighting and fire protection hardware and also the QA involvement in fire protectio .
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Housekeeping and Work Practices The inspector toured accessible plant areas and observed work in process to verify that housekeeping conditions do not create fire hazards, that procedures exist to remove combustible debris on a regular basis, all wood used inside the plant is treated with fire retardant, and an effort is made to minimize fire hazards during the cleanup effor '
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The inspector observed the following: In the control room, the licensee is running 115 VAC extension cords from one electrical equipment cabinet to another with the doors of fire cabinets open. An accidental closing of fire doors could shear the electrical cord and short the cabinet. Besides being a potential electrical hazard to control room personnel, this situation could disable electrical equipment. In addition, the cabinet doors should be maintained closed as a good operating practice, The inspector also observed a few isolated incidents in which a hose station and some portable fire extinguishers were partially blocked by the placement of construction-related material or equipment. The licensee acted on the inspector's observations and stated that improvements in this area will be made, c The inspector also observed that construction debris created from cleanup activities is temporarily stored in non-safety related areas and is routinely carted away. This minimizes fire potential. This is acceptabl The licensee has erected temporary wooden structures for offices or tool and equipment storage areas throughout the plant. The wood used is treated with a fire retardan In addition, these structures, located in areas where sprinkler systems have been installed, are constructed with a type of ceiling that would allow the spinkler system to be effective if a fire originated within the
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temporary enclosure Except as noted in items a and b the housekeeping inspection did not identify any unacceptable condition Fire Brigade Training The licensee is required to maintain a trained fire brigade onsite at all time The licensee has received NRC approval to use the fire brigade of Unit 1 to fight potential fires in Unit This is done with the provision that the Unit 1 brigade receive, in addition to the standard brigade training, a Unit 2 site specific fire protection training and each member participates in at least two drills per year conducted at Unit The inspector reviewed the Unit 1 brigade training and training record The inspector noted that all members of the fire brigade had received a familiarization tour of Unit 2, had participated in all required training I
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including classroom and practical, and there was a plan to include all members of the fire brigade in Unit 2 drills by July 198 The inspector noted that less than half of the fire brigade members had participated to date and expressed concern that the licensee might not meet their July 1988 goal. The licensee acknowledged the inspector's concern. The inspector also noted that the licensee has a designated individual to escort fire brigade members in Unit 2. The inspector will continue to evaluate the readiness of the fire brigade in future inspection The inspector identified no unacceptable condition Fire Protection Equipment and Maintenance The inspector ieviewed fire fighting and fire protection equipment to ascertain the adequacy of the equipment readiness and operability. The inspector verified that the equipment used by the fire brigade is adequate, operable and well maintained. The conditions of fire hose houses and the contents of the fire brigade locker were examined. Random maintenance /surveillarce procedures were reviewed to verify that the required surveillances were performed. The procedures reviewed were as follows: Fire Detection Circuits Operational Check Procedure N SUR-3680.01 and 4210-SUR-3680.02; Fire System Hose Station Visual Inspection Procedure No. 4210-SUR-3811.01 and 4210-SUR-3811.02~
The inspector also observed that because of construction / cleanup activities the location of fire extinguishers may be inappropriate and a reevaluation of the fire extinguisher locations may be required. The locations of some fire extinguishers throughout the site may need reevaluation so as to place the extinguishers either nearer to the hazard or nearer the persons who would ostensibly use the The inspector also identified one instance where extinguishers in an area were not readily visible and others were missing from their stations. The inspector informed the licensee representative of this observation and the fire protection engineer took expeditious corrective actio QA Audit The licensee is required to perform 12 month, 24 month and 36 month audits of the fire protection program. Guidance for the performance of the audits was given to all licensee's in Generic Letter 82-2 The inspector reviewed audits 86-08 (12 month)and 86-03 (24 month) and 87-02 (36 month). This review did not identify any unacceptable condition .0 Maintenance During the 2300-0700 shift on October 9, 1987 subsequent to restoring the
"A" Decay Heat Removal Loop to service, a control room operator observed that the valve position indicators for DH-V-4A indicated that the valve was cycling open and close Control room personnel took action to close the valve, open the valve actuator's electrical breaker, manually close
. DH-V-159A to ensure containment integrity, and place hand caution tags on the affected components in the "A" loop. Upon isolating the "A" loop, a redundant: boration flow path, the "B" decay heat removal loop, was availabl J
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Because DH-V-4A appeared to be open without operations personnel being aware or in control of the valve, _the licensee initiated an investigation (IER 87-092) to detemine the cause of the malfunction and take cocrective action to preclude a recurrenc DH-V-4A is a motor operated, containment isolation valve that is in the
"A" flow path leading from the Borated Water Storage Tank (BWST) to the Reactor Vessel (RV). This valve has not been opened since the time of the accident (circa March 28,1979) and is maintained closed unless a flow of borated water is to be established from the BWST to the R A Job Ticket (CH 694) and UWI 4220-3212-87-H694 were issued to investigate the cause of the malfunction and complete repairs. Upon entering the valve area and gaining access to the valve and operator, tecN.icians found that the locknut had backed out of the drive sleeve, the drive sleeve was cracked circumferentially a few threads down from the top and the stem nut had run up the valve stem far enough to disengage from the splines on the inside of the drive sleeve. It appeared that the locknut was never secured thus allowing it to back out of the drive sleeve. From this information it was determined that the valve operator would run in the close direction; however, without the locknut in place, the stem nut would run up the valve stem instead of pushing it down to the closed position, thereby never developing closing torque to open the torque switch and de-energize the "close" contacto With the operator continuing to run in the "close" direction the geared limit switches would change positions after enough turns (similar to an automobile odometer rolling over) to cause the position indication lights in the control room to change state and give the impression the valve was cycling open and closed. While in fact, the valve stem was remaining stationary in the closed positio Following an evaluation of the causes of the malfunction, the valve operator was repaired using replacement-in-kind parts from a spare limitorque valve operator that was in onsite storag To ensure that a similar condition did not exist in an identical valve, DH-V-48, in the redundant flowpath, the valve operator was inspected and found to have the locknut properly secure While performing repairs to the valve actuator, technicians found a discrepancy between the controlled drawing and the actuator circuitr The drawings indicated that the seal-in circuits for the actuator were removed by Engineering Change Memorandum (ECM) 3475 677 Rev. O but, in fact were still in the control circuits for DH-V-4A and DH-V-4 Upon receiving concurrence from the Engineering Department, the seal-in circuit was removed from the control circuit for DH-V-4A while performing the repairs per the UWI. A separate UWI was to be issued to perform a similar modification to the circuitry to DH-V-4B; but, subsequently, the Engineering Department discovered that ECM 3475 677 Rev. O was cancelled prior to implementation and that the drawings were prematurely revised indicating that the changes to the circuitry had been completed when, in fact, no changes had been made. Action is being taken to correct the drawings to show the scal-in circuits in place and to restore the seal-in circuits for DH-V-4A to their original configuratio _ _ _
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The inspector discussed the event with cognizant licensee representatives and reviewed the documentation relative to troubleshooting and repair of DH-V-4A. The inspector determined that the requirements of Technical Specifications (TS) 3.6.1.1 for maintaining containment integrity were met in that DH-V-4A was not opened initially and that the closure of DH-V-159A assured containment integrity while troubleshooting the
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actuator failure. The inspector also determined that the requirements (TS 3.1.1.1) for maintaining two operable flow paths to the RV from the BWST were met in that maintenance personnel demonstrated that the valve could be manually operated during their investigation. Through review of the job ticket and UWI, the inspector concluded that the Quality Assurance Department and Quality Control group performed their respective reviews and verification, as required, for repair of this "important-to safety" component. Since repairs were to be performed in a high radiation area, the inspector reviewed the radiation work permit and determined that the controls were implemented to minimize dose and preclude contamination to personne No violations were identifie .0 Defueling Operations Defueling operators continued the steady removal of stub fuel assemblies from the lower grid pad. Of the 177 original partial length fuel assenblies, 175 have been completely remove The two remaining stub assemblies, in the R-6 and R-7 positions, contain once molten, resolidified material. They are apparently fused to the lower grid and core former walls as an upward force of 19,600 lbs would not free the The end fittings on these assemblies deformed during the removal attemp An air operated chisel will be used in an attempt to break these assemblies free. To-date about 193,000 lbs of a total of approximately 300,000 lbs of core debris and other materials have been remove Presently, defueling of the core region continues with pick and place techniques and vacuuming using the mini-air lift tool. Following removal of the remaining loose pins and vacuuming of loose debris on the grid pad, drilling out of the 52 in-core guide tubes and 48 support posts of the lower core support assembly is anticipated. The licensee will be submitting, for NRC review, a safety evaluation addressing the planned technique for sectioning and removing the lower core support assembly to facilitate defueling of the lower hea In late October, defueling operations were temporarily suspended as a result of the inoperability of the reactor building service crane (RBSC)
due to a broken drive shaft on the crane's bridge. As an interin measure the licensee provided the NRC a safety evaluation that proposed the use of the reactor building polar crane auxiliary hook for defueling related activities. Upon approval of the safety evaluation by the THI-2 Cleanup Project Directorate staff, use of the auxiliary hook was authorized provided the following restrictions were implemented:
-- The raising of all loads in the reactor vessel (RV) will be performed in the slow speed (approximately 4 inches / minute) until the load clears all possible interferences below the shielded work <
platform (SWP).
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The polar crane main block will be maintained in the parked positio To prevent accidental "runaway" movement of the auxiliary hoist when it is handling a load inside the RV, an individual will be stationed at a polar crane power disconnect switch or circuit breaker to cut power if such an event occurs. The individual will be in direct comunication with the polar crane operator and have no concurrent duties. The individual will be frequently relieved or rotated from this dut Exposure to personnel on the SWP will be controlled by continuous radiation monitoring on the SWP when debris is closer than 4 feet to the surface of the RV water leve To verify implementation of these controls, the inspector observed defueling activities in which the auxiliary hook was being used and reviewed the procedural revisions that incorporated the restrictions 'into operating procedure No violations were identifie Repairs have been made to the RBSC drive shaft. Non-destructive testing and post-repair inspections have been performed by the licensee and the crane manufacturer. The RBSC was subsequently returned-to-service, however, the crane's load limit rating has been decreased from 5 tons to a maximum of 2 tons by the crane's manufacturer pending a replacement of other component .0 H_ealth Physics and Environmental Review 7.1 Plant Tours The NRC site Radiation Specialists performed inspection tours of the l plant, including all radiological control points and selected radiologically controlled areas. Among the areas inspected were the Reactor Building, the Auxiliary and Fuel Handling Buildings, EPIC 0R-II, the Radiochemistry Laboratories, the Laundry and Respirator Maintenance Facility, the Waste Handling and Packaging Facility, and the Interim Solid Waste Storage Facility,.
Among the items inspected were:
-- 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
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-- Adherence to' radiation protection procedures
-- 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 for 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 No violations were identifie .2 Reactor Building Er.tries 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:
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The planning and coordinating of RB entries, including ALARA reviews, personnel training, and equipment preparatio The planning and implementation of radiological safety measures, including the use of RWPs, locked high radiation area access authorizations, specific work instructions, alarming self-reading dosimeters, and breathing zone air sampler Reactor building entry personnel 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 equipment.
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The inspector observed reactor building radiological and industrial safety conditions during entries made on October 21 and November 23, 1987. Some housekeeping problems were observed and reported to the licensee as a result of the October 21 reactor building inspectio It was observed on November 23 that housekeeping conditions had deteriorated significantl There was no obvious evidence of an intention to disregard safety needs. However, it appeared that the press of work in the reactor building may have detracted from the licensee's attention to housekeeping and industrial safety conditions. Such things as a large number of small items of trash and equipment adrift on floor areas, inadequately identified containers of material, defueling equipment staged in posted
"contaminated" areas but extending beyond the contaminated area rope boundaries, equipment and tools stored in an unworkman-like fashion ,
in the contaminated tool repair area on the 347' level, and a digital dosimeter adrift on top of the "A" D-ring, were pointed out to the licensee representative accompanying the inspecto _- __--. _
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Corrective actions'were described to the inspector at the time of the exit interview and will be reviewed during the inspector's next reactor building entr (320/87-14-01)
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7.3 Processed Water Spill in Protected Area Yard On October 15, 1987, while preparing to perform a hydrostatic test of a section of rubber hose extending from the truck fill connection at EPICOR. II (ALC-V7/V8) to the temporary decontamination water supply pump, workers inadvertently spilled about 15 gallons of contaminated water on the groun The workers had the hose isolated and drained for the test. The design of.the hose arrangement, such that the drain point did not ensure the entire line had drained, contributed to the failure. One individual's clothing was contaminate The decontamination water, which is used within the plant to spray / wash highly contdminated surfaces, is itself contaminated to
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about IE-4 uCi/ml. The valves are contained inside a steel box intended to provide some protection against small leakage getting to the ground. Thez box is about 18 inches long by 8 inches wide by 6 inches deep. The box could contain about one-half gallon, far below the spill volum .
The ground where the water was spilled was collected until no further dirt was found contaminated. The soil collected was disposed of as radioactive waste. The hose hydrostatic test program was placed on hold until all hoses could be walked down, an appropriate test area was identified, and a methodology for testing hoses in place or assuring hose draindown could be implemente The inspector determined that the actions taken provided reasonable assurance that there would be no recurrenc The inspector had no further questions on this matter.
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7.4 Personnel Contamination Control
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Licensee records concerning worker personal clothing and skin contamination events are routinely reviewed by the inspector. Also, the availability, operability and use of personnel frisking equipment is observed. Although many pancake, hand-held friskers are in use throughout the plant, frisking booths ("wholebody friskers") have replaced the hand-held friskers at some location Although studies were done by the licensee to determine the acceptability of the frisking booth as a substitute for hand-held friskers, concern has continued as to the efficacy of the frisking booths because of the existence of "blind spots", i.e. areas of the body not "seen" by the detector array. Limitations of the frisking booths recently demonstrated when a worker had successfully passed through a booth with a "hot particle" on his clothing. (The particle was detected by a portal monitor as the worker was leaving the protected area.) As a result, the licensee did another study of
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the relative effectiveness of frisking booths and hand-held friskers, including consideration of this particular cas It was concluded that, based on a. comprehensive assessment of the pros and cons-of each frisking method, the booth should be superior to the hand-held friskers at detecting "hot particles" when the booth is properly used by worker Based on a review of -the licensee's study, licensee' records and observation of worker frisking practices, the inspector determined that although hand-held friskers still fill a need in the plant, the use of frisking booths can be advantageous and is acceptable as currently practiced in the plan .5 Defueling of Steam Generator "B_'_'
m The "B" Once Through Steam Generator (OTSG) was defueled on October 12 - 14, 1987. Various sized pieces of core debris were found on the upper tube sheet of the OTSG's. Reactor coolant flow is from top to bottom in the OTSG's. Material carried from the reactor core to the OTSG which was too large to pass through the approximately one-half inch tubes lodged there or was broken up into pieces small enough to pass. Smaller pieces of debris settled out after water flow cease As rehearsed at the mockup and used successfully at the "A" OTSG, workers assembled the defueling vacuuming system at the "B" 0TSG with three exceptions. First, a defueling engineer assembled a high efficiency particulate air filter (HEPA) unit improperly, such that the flow of air being filtered went backwards through the HEPA filter then through the protective roughing filte The HEPA filter was designed and tested to remove 99.97% of particulate matter exceeding 0.3 micron size. The roughing filter is intended to remove larger pieces of material. When operated properly, naterial is filtered first by the roughing filter, then the HEPA filte However, it was installed backwards and material which had been deposited on the roughing filter was blown off the filter to the vacuum sourc No external flow markings existed. Secondly, while testing the debris collection assembly, only two bolts were used to secure the head to the shielded debris ca The unit's flow enters the head, passes down through a gasket-sealed fabric collection bag, through the walls of the collection bag to a chamber outside the bag, up through the head and into the discharge hose leading to the roughing filter, HEPA filter and vacuum source (Kelly Vac). While two of the debris-collection cans were capable of being used with a single unit head, there was also available a third can. This third can had been manufactured so that the gasket-seat surface would only mate with a head with a different bolt pattern, although two bolts could mate up with the other when coupled, the odd assembly had a 1 inch gap between the head / collection can sealing surfaces which could not be sealed. The test assembly leak check procedure required that all external surfaces seal and did not check the internal sealing of the
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head / collection can/ collection bag. There was no intention to use the unique collection uni To obtain a fresh sample of material from the "B" OTSG to verify isotopic ratios, the third can and its head were taken to the job site. On October 12, 1987 the unit was installed and filled by the
- day's last crew. The collection can was removed, capped and set aside. The third error occurred when the head was not disconnecte When the first job crew arrived the next morning no turnover indicated the status of the sample can and head. The job crew assembled the odd head and one of the other collection cans. When only two bolts could be inserted, job supervision allowed the operation to proceed. After operating the vacuuming system for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, a sudden rise in dose rates at the HEPA filter from 300mR/hr to 1.4 R/hr was noted. The job was stopped at this time for two reasons, one being the direction of the radiological engineer and second, by the job crew because no further work was needed. Initial theory was a penetration of the collection bag had permitted a piece of debris to get to the HEPA filte Investigation revealed the incorrect head /can assembly and the reversed HEPA unit. The unit had operated for two days with the HEPA improperly installed. A critique was held on October 15, 1987, at which the failures were noted and appropriate corrective actions assigne The inspector had no further question .6 Unplanned Airborne Exposure at Waste Handlina Facility This event occurred November 4, 1987, when a crew was emptying a steel box of radioactive, non-compactible reactor building waste into a high-integrity container (HIC). The crew, consisting of five persons, was working under the provisions of a Radiation Work Permit (RWP) and was accompanied by a' Radiological Controls Technicia When the box was almost empty, a quantity of absorbent material was noted in the box's plastic liner. As the technician attempted to close up the plastic liner, a dusting of powder was noted in the i, area. A survey showed the area to be contaminated. In addition, five individuals were contaminated, three had nasal contaminatio One individual had nasal contamination of 2800 cpm and analysis of his breathing zone air (BZA) sampler filter showed an exposure of 70 MPC-hours, mostly Sr-90 and Cs-137. Whole body counts of the individuals showed internal depositions of 12.3, 65.8, and 47 nCi in three of them. The highest individual showed 8.8 nCi the next da It was later determined that one of the individuals had eaten Canadian caribou meat containing Cs-137 originating fron fallout.
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The incident was critiqued and actions assigned to prevent
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recurrence. Among these were: ventilation to exhaust air from opened boxes; the use of a BZA by each individual involved in this
' pe of work; the collapsing of bags of material by suction with a
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vacuun cleaner rather than by hand compression; and, the cessation of work upon the discovery of loose material and the evaluation of
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any loose materia The individual exposures have not been entered in the dosimetry files. The licensee is tracking the event under Incident Event Report 50-320/87-10 .7 Contrc,1 of Radioactive Material _
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 August 26, portions of the bed of a truck were found by licensee survey to be contaminated. There was no indication that the truck had been released from radiological controls in this conditio However, since the source of the contamination could not be determined, the potential existed for release of the vehicle to unrestricted areas, and the contamination levels exceeded the release limits stated in the licensee's Radiation Protection Plan (Procedure 1000-PLN-4010.01), the inspector has followed up on licensee survey practices and result On October 7,1987, the licensee implemented additional vehicle contamination control measures, including the designation and posting of certain vehicles to be specifically used for radioactive materials transport, the covering of the vehicle beds with Herculite to preclude bed contamination, and increased emphasis on radiological surveys and visual inspections. The inspector has not noted any contamination problems following implementation of these control measures, but will continue to monitor this area of radiological protection practice .8 Radioactive Material Shipments The inspectors reviewed the preparation and conduct of radioactive materials shipmerts en October 1, 12, 14, 20, 27, and November 13, 23, 24, 25, 1987. The inspectors also observed preparations and execution of railcar-mounted cask shipments of THI-2 core debris from THI to the US Department of Energy on October 25 and November 15, 198 The inspector's reviews covered:
-- Verification that the recipient is properly licensed
-- Verification of compliance with 10 CFR Part 61 radioactive waste disposal regulations
-- Verification of compliance with approved packaging and shipping procedures
-- Completed shipping papers
-- Package labeling and vehicle placarding
-- Instructions to vehicle operators
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-- 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 the examination of shipping papers, procedures, and vehicle No violations were identified. A problem was identified at a burial site with respect to solidified sludge liners as de cribed in paragraph .9 Unsolidified Waste Liner at Burial Site Enforcement Action taken by Aareement State In a letter dated November 4, 1987, the State of South Carolina Department of Health and Environmental Control rotified the licensee of suspension of burial privileges for solidified sludge at the Barnwell, South Carolina facility. The suspension required GPUN to submit corrective actions to the State of South Carolina by November 25, 1987. A GPUN letter dated November 25, 1987 documents an extension to December 31, 1987. The State enforcement action was taken following examination of a solidified sludge waste liner on October 23 and 26, 1987 at the Barnwell disposal facility. The inspection revealed the material exhibited a moist, putty-like consistency vice the described Class B-stable solidified waste. The condition was contrary to Agreement State Radioactive and Environmental Controls Regulation Background Infomation The waste was evaluated by the State of South Carolina on October 23 and 26, 1987 at the Chem Nuclear Disposal facility in Barnwell, South Carolina. Periodically, State inspectors at Barnwell request that liners be punctured to determine the presence / absence of free-standing liqui The moist, putty-like material is not acceptable for burial. The liner was isolated and reinspected on October 26 and 27, 198 The liner was placed in a shield and the liner lid was removed. An extremely strong ammonia odor was present. The liner had not solidified as cf hovember 25, 1987. The solidification contractor has presented a theory stating ammonia generating compounds significantly delays solidificatio When vented, ammonia evolves from the media, and solidification takes place from the outside inward. In this case with the lid removed, the liner is hardening from the top downward. Chemical analysis of the sludges did not reveal any ammonia generating compounds as defined by GPUN to the contracto _ _ _ _ _ _ _ _ _ _ _ _
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Source of Solidified Liner and Similar Liners The liner currently at the Barnwell site originated with Auxiliary Building Sump sludge, solidified at THI-2 on March 30, 1987. This liner is the second of four used. The first has been buried at Barnwell, the other two are at THI in the waste storage module There are also two reactor building basement sludge solidified liners. A seventh, a solidified liner of cleanup demineralizer resins would not fit the criteria of solidified sludg The only abnormality noted in the campaign of solidifying these liners was an ammonia-like odor fron this liner while the mixer was operatin There were no abnormalities noted during the conduct of the Process Control Program evaluations in developing mixtures for solidifying the waste stream Shipment to Burial Site Radioactive shipment 87-133-II was prepared by a GPUN Radioactive Materials Coordinator for liner CN- This liner is also listed as CNS1 1087-168, and CNSI serial number L443649-2, under State of South Carolina Radioactive Waste Pernit No. 0064-37-87-X. The shipment departed THI-2 on October 20, 1987 under overweight permit routing, loaded into a CNSI Model 8-120 cask (NRC Certificate of Compliance USA /9168/8(U)). Total radioactivity was 159.64 curie The sh'pment arrived at the burial site on October 22, 198 Future Actions GPUN and CNSI intend to evaluate the status of the other liners at THI prior to the end of 1987. This item will remain unresolved, pending completion of corrective and investigative action (50-320/87-14-02)
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7.10 Records Review I The inspector reviewed selected licensee records related to l occupational radiation exposure with respect to their accuracy and l 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 meAical examination 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 per RWP hour, decontamination status, skin contaminations, environmental nonitoring, progress toward achieving goals and objectives, storage tank radioactivity content, airborne radioactivity, effluent releases (including sump releases and sources of sump contaminaticn), and the cumulative dose to plant personne No violations were identifie . ...
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8.0 Open Item
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Matters that require further review and evaluation by the inspector Open items are used to document, track, and ensure adequate followup on macters of concern to the inspector. Open items are addressed in paragraph 2.0 and 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 2.0 and .0 Exit Interview The inspectors met periodically with licensee representatives to discuss inspection findings. On November 25, 1987, the site inspectors summarized the inspection findings in a meeting with the following personnel:
J. Byrne, Manager, TMI-2 Licensing S. Levin, Defueling Director S. Hervine, Fire Protection Engineer '
W. Potts, Site Operations Director .'
T. Seaver, TMI QA Auditor J. Tarpinian, Manager, Radiological Engineering At no time during the inspection was written material provided to the !
licensee by the inspectors.
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