IR 05000320/1988001
| ML20150C627 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/08/1988 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150C606 | List: |
| References | |
| 50-320-88-01, 50-320-88-1, NUDOCS 8803210120 | |
| Download: ML20150C627 (11) | |
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V.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-320/88-01 Docket No.
50-320 License No.
DPR-73 Priority
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Category C
Licensee GPU Nuclear Corporation P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Un.t 2 Inspection At: Middletown, Pennsylvania Inspection Conducted: January 1-29, 1988 Inspectors:
T. Moslak, Resident Inspector (TMI-2)
J. Bell, Senior Radiation Specialist D. Collins, Radiation Specialist
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Approved By:
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C. Cowg fl, hi f, Reactor Projects Section 1A Date Inspecti m Summary:
Areas Inspected: Routine safety inspection by site and regional inspectors of plant operations, defueling operations, plant housekeeping conditions, shipment of radioactive materials, implementation of radiological controls, event follow-up, control of radioactive materials, and licensee action o. previous inspection findings.
Results: The inspectors reviewed a number of licensee identified items, in:luding exceeding a load height limit, having an inoperable wind speed indicator, and failing to properly use personnel dosimetry. A violation was identified for a failure to properly prepare radioactive waste for burial.
8803210120 880311 PDR ADOCK 05000320 Q
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DETAILS 1.0 Routine Plant Operations Inspections of the facility were conducted to assess compliance wish the re-quirements 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 logkeeping practices; radiological controls; and, security plan implementation.
Inspections of the control room were performed during regular and back shift hours. The Shift Foreman's Log and selected portions of the Control Room Operator's Log were reviewed for the period January 1-29, 1988. 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 Log Sheets.
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 adequate.
No violations were identified.
During this inspection period, the inspectors conducted back shift and weekend
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inspections on the following days.
1/17/88 7:30 p.m. - 11:00 p.m.
1/24/88 8:00 p.m. - 11:00 p.m.
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1/27/88 6:30 a.m. - 7:30 a.m.
1/28/88 4:30 p.m. - 5:30 p.m.
2.0 Defueling Operations With defueling completed in the normal core region, defueling crews conducted video inspections of.he Lower Core Support Assembly (LCSA), completed in-stallation of drilling equipment on the Defueling Work Platform (DWP), and began drilling out the in-core instrument guide tubes.
l The drilling machinery consists of the core boring equipment previously usec I
to obtain stratified samples from the core debris in the summer of 1986.
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is being used to disassemble the LCSA so that the lower reactor head can be l
accessed for defueling.
All fifty-two in-core instrument spiders in the lower i
grid rib section of the LCSA have been drilled out.
Drilling out of fourteen
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in-core instrument guide tube positions through the upper flow distributor
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plate to the grid forging is in progress.
This will be followed by drilling out of the support posts and plasma arc cutting and removal of the five
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structures that make up the LCSA. As fuel and core debris are found during this process, they will be removed or relocated to the reactor vessel lower head.
3.0 Installation of Drilling Equipment Over the Reactor Vessel e
Following the installation of the drilling equipment on the Defueling Work Platform (DWP), the licensee identified an event in which a heavy load was transported over the reactor vessel in excess of the maximum allowable height.
The following details of this event were reported to the on-site NRC staff.
On January 6, 1988, the drilling macntne was installed on the DWP over
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the TMI-2 reactor vessel.
Subsequently, the Drill Indexing Platform
. Structure (DIPS), which supports the machine, was determined to be in-
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correctly oriented, 180 degrees from its proper position. As a result of the mis-orientation of the DIPS, engineers concluded that, for the drilling machint to be installed, it had to be transported over the reactor vessel at a height which exceeded the maximum allowable height (by 18 inches), as stated in the supporting Safety Evaluation Report
(SER).
Through discussions with licensee representatives and document review, the inspector determined that on January 5,1988, while preparations were in progress for the installation of the drilling machine on the DWP, the DWP was rotated from north to east to verifv that it was level.
Follow-ing this verification the DWP should have
,en rotated fron east to south
for installation of the DIPS. This action would have ensured that the subsequent transport of the drilling rig would have been along a proper load path within the allowable height requirements of the NRC-approved SER as referenced in Technical Specifications (TS) 3.10.1.
Due to con-current activtties being performed on the DWP, the DIPS was installed with the DWP positioned to the east.
The DIPS was installed but, unknown to defueling personnel, was oriented 180 degrees from its correct position.
Prior experience with this evolution did not indicate the capabity to inversely install the DIPS.
On January 6, 1988, the task supervisor, unaware that the DIPS had been incorrectly installed, completed the installation of the underwater structure of the drilling machine. This component weighs about 5000
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I pounds (a heavy load per Technical Specification 3.10.1) and, as such, requires that a specific load path be followed and the height of the load
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be restricted when it is transported over the reactor vessel.
However, due to the misorientation of the DIPS, the load path that was travelled was inappropriate, resulting in the load being lifted eighteen inches higher than permitted per the requirements of the SER.
When the event was identified on January 7,1988, the drilling machine and associated support structures were removed and oriented to their corrected position.
A critique was held on January 8,1988, to identify the root cause and
initiate corrective actions to preclude a recurrence of a similar inci-dent.
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Immediate corrective actions. included revising the Unit Work Instruction to provide clearer guidance for verifying the alignment of the DIPS on
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the DWP and including more detailad steps relating to the installation
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of the underwater structure. Additionally, the licensee is performing a load drop analysis to determine what the effects of a hypothetical load
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drop at a height of eighteen inches greater than SER requirements would be on. reactor vessel components.
From the review of the circumstances resulting in this event, the in-
.spector determined that exceeding the height restrictions for transport-i y a heavy load over the reactor vessel was contrary to the requirements of an NRC-approved SER per Technical Specification 3.10.1.
However, the
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inspector determined that the criteria of Appendix C of 10 CFR 2 apply in this event in that the incident was an isolated event which had not F
previously occurred, the corrective' actions were appropriate and expe-ditiously implemented, the incident was reported to the NRC in a timely
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manner, and had minor safety significance.
Accordingly, a Notice of
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Violation will not be issued for this licensee-identified event.
The licensee is preparing a special report for the NRC in accordance with Technical Specification 3.10.1, documenting the details of this event.
4.0 Corrective Maintenance On January 15, 1988, when licensee personnel attempted to energize the Reactor
Building Polar Crane by closing the disconnect switch, they observed a bright flash of light on the Polar Crane. Subsequently, alarms were received in the control room, indicating that the motor control center for the Polar Crane had tripped off line. An investigation determined that an insulator and in-sulator washer for the power feed to a 480 volt solenoid to the No. 4 Park
Brake on the Polar Crane had malfunctioned.
The event was reported by shift
personnel to the appropriate levels of site management and to the on-site NRC staff.
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The inspector reviewed the documentation generated for troubleshooting the c
malfunction and performing the corrective maintenance. Through examination
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of the Job Ticket (CH-970) and the Unit Work Instruction (4220-3882-88-H970),
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the inspector determined that the appropriate procedures were implemented and r
the task received the appropriate reviews.
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No violations were identified.
5.0 Inoperable Wind Speed Indicator
s On January 26, 1988, the licensee notified the inspector that the eight-hour time clock for returning the wind speed indicator to service on the meteoro-
logical tower would be exceeded.
The wind speed indicator was determined to
be inoperable at 3:15 p.m. on January 26, 1988, because of an ice buildup on the rotating components and, subsequently, the licensee entered the action statement of Technical Specification 3.3.3.4.
Because of personnel safety
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considerations caused by high wind gusts and inclement weather, the licensee chose to delay performing repairs until weather conditions permitted such work.
In the interim, the licensee relied on meteorological data provided by the Harrisburg International Airport and the Capitol City Airport.
The wind speed indicator was made operable at 12:45 p.m. on January 27, 1988.
The inspector reviewed the event and determined that the licensee had taken the appropriate actions to have accurate wind speed data availaile, including determining a modifying factor that would correlate the wind speeds provided by the local airports with on-site conditions, Local airports use 30-foot towers and the licensee's meteorological tower is 100 feet in height.
As such, the licensee was able to extrapolate the data provided by the local airports and determine wind speed at the 100-foot elevation.
The licensee is preparing a special report for the NRC in accordance with Technical Specification 3.10.1 documenting the details of thic event.
The inspectors will review the results of this report.
6.0 Routine Health Physics and Environmental Review 6.1 Plant Tours The NRC site radiation specialists performed routine plant inspection tours throughout the inspection period. These tours included all radio-logical control points and selected radiologically controlled areas.
Among the items inspected were:
access control to radiologically controlled areas, including the
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reactor building and areas of the auxiliary and fuel handling buildings;
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log books recording unusual and routine occurrences within both operations and radiological areas;
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adherence to Radiation Work Permit (RWP) requirements and to proce-dural requirements;
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proper use of respiratory protection equipment and maintenance of (
emergency respiratory protection equipment throughout the plant;
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proper use of radiological survey meters, especially personnel friskers and frisking techniques; and, i
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calibration and source checks on radiological instruments.
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6.2 Worker Attentiveness During a routine plant walkthrough inspection, the inspector noted a worker who appeared to be inattentive to his duties in the vent header room (AX-128) on the 305-foot level of the auxiliary building. The room is a radiation area and work in this room must be done under a Radiation i
Work Permit (RWP).
Part of the room is used as a work area for repairing and servicing contaminated radiological instruments.
The location and condition of the worker were reported by the inspector to the Deputy Manager, Radiological Field Operations, who returned with the inspector to the room where the Deputy Manager interviewed the worker and deter-mined tnat AX-128 was not his assigned work location at that time.
The worke" was signed on as "General Decon" RWP that would cover certain transient or temporary duties in AX-128.
However, his supervisor stated that, at the time he was found in the room, the worker had no assigned duties to perform in that area.
The worker was terminated and all other laborers counselled with respect to their conduct on the job.
Based on the past identification of licensed and non-licensed personnel sleeping while on duty at TMI-2, the inspector is considering the above incident to be unresolved pending the outcome of NRC and licensee inves-tigations and subsequent NRC Region I review of such incidents which may indicate a programmatic problem (320/88-01-01).
6.3 Measurement and Control of Personnel Dose As described in NRC Inspection Report No. 50-320/87-15, digital alarming, self reading dosimeters (SRD's) gave unexpectedly high dose readings.
The inspector discussed the readings and the performance of the SRD's with licensee personnel involved in using and servicing them. The lic-ensee personnel described a program designed to define the performance characteristics of the SRD's so that they may be more effectively used in the radiological controls program.
The inspector had no additional comments.
6.4 Person-Rem Goals / Records Review The licensee's goal for 1987 was 1175 person-rem.
The actual collective dose for 1987 was 975 person-rem.
The 200 person-rem difference is at-tributed to lowered dose rates on the defueling work platform, a lowered manhour expenditure on the platform, and the deferring of certain man-rem intensive tasks to 1988.
The licensee's goal for 1988 is 990 person-rem.
The inspectors reviewed other licensee generated records, such as Dosi-metry Investigative Reports, Radiological Awareness Records, Incident Event Reports, Radiation Work Permits, and Radiological Reviews.
No violation was identified.
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- 6.5 Measurement Verifications The U.S. Environmental Protection Agency, Middletown Field Office, col-lected and analyzed water from the TMI site discharge and provided the results to site inspectors. The inspectors reviewed the results of these measurements and determined that they were within the regulatory limits in 10 CFR Part 20.
No violation was identified.
6.6 Reactor Building Entries Work being done within the reactor building requires a more detailed review and procedure preparation than work performed elsewhere within the plant.
The inspectors observed work being done in the reactor building and determined that the basic -equirements were being imple-mented, that personnel were appropriately briefed as to radiological conditions prior to entering the building, and were instructed as to removal of protective clothing when exiting the building.
The licensee has noted an increase in skin and personal clothing conte.minations at the reactor building control point and has begun taking steps to assist personnel and ensure that proper removal steps are taken by workers.
No violation was identified.
6.7 C,ontrol of Locked High Radiation Fire Docrs The inspector checked all in plant locked high radiation area doors during a back shift inspection tour of the plant on January 17, 1988.
The control of the keys to these areas was also observed. All doors were locked or access through them was otherwise properly controlled.
No violations were identified.
6.8 Balance of Plant Housekect ng i
During a back shift inspection tour on January 17, 1988, the inspector noted that the main corridor to the auxiliary building sump filter room on the 281-foot level was virtually blocked by an accumulation of hases, lead shielding blankets, tools, and other equipment.
This is a contamin-ated area and any difficulty in egress or ingress could contribute to personnel contamination.
The condition of the corridor was reported to a licensee represcotative who indicated that action would be initiated immediately to improve the condition of the corridor.
On January 2o, 1988, during a back shift plant inspection tour, the in-spector noted that the area was much improved, permitting easy passage through the corridor.
The inspectors will continue to review housekeep-ing in reutine tours.
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i 6.9 Control of Health Physics Tec'inician Qualification On January 19, 1988, the licensee notified the inspector '. hat the train-ing qualifications of ) senior health physics technician (HPT) had lapsed l
.several months in the past.
Each HPT's qualifications must be renewed every two years in accordance with the licensee's procedure, "Radiologi-cal Field'0perations Personnel-Qualification / Training Standard" (9100-ADM-2622.01, Revision 0, Effective June 24,1987).
The licensee's im:nediate corrective actions included disqualification of the HPT, a record check of all HPT's currently on shift, as well'as all those who had been employed during the previous eighteen months, and a review of the HPT's work during the lapsed period.
It was determined that all other HPT's qualifications were in proper order.
It was determined that the qualification lapse resulted from the HPT's failure to recognize his responsibility to maintain his qualifications current and the lack of a record of his qualifications in the. licensee's requalification tickler syster.
Consequently, the licensee is reissuing a notice to HPT's reminding them that each of them is personally re-sponsible for qualification renewals. Also, the licensee is developing a "Radiological Control Unit 2 Employer Check-In/ Check-Out Procedure" checklist which, if properly completed, should preclude the above-noted problem. This should result in each HPT's qualification record being available for examination on the licensee's tickler list and it should require that all Radiological Controls group supervisors (foremen) com-pare, monthly, the list of active HPT's against a list of those currently employed in the plant.
These actions are reasonable to assure that qualification informat?an on each and every currently employed HPT is in the appropriate rec rd system.
The failure to requalify the HPT is an apparent violation of the licen-see's procedural requirements.
However, the occurrence was identitied by the licensee, the health and safety significance of the occurrence is considered to be minor, appropriate corrective actions have been in-itiated, and the occurrence could not have been prevented by the 11cen-see's correctivt action for a previous violation.
Therefore, in accord-ance with Appendix C of 10 CFR Part 2, a Notice of Violation will not be issued.
The licenseets corrective and preventive actions will be reviewed when completed.
6.10 Incident Followup The inspector reviewed an c,ccurrence of a worker entering a locked high radiation area (LHRA) without proper dosimetry as required by the RWP covering the job.
It was reported to the inspector by the licensee on January 25, 1988, that a worker had returned to the neutralizer tank room on the 281-foot level of the auxiliary building without being equipped with a thermolu-
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minescence dosimeter (TLD) or a self-reading pocket dosimeter (SRPD) as required by the RWP covering his work in the room. The worker was equipped with an alarming digital readout dosimeter from which his ap-propriate dose was determined.
The. dose indicated by his digital dosi-meter was confirmed by the SRPD readings of a fellow worker in the room on the same job. The licensee's Dosimetry Investigative Report found-that the-worker's dose for the job was 80 millirems.
Tha inspector re-viewed the report and the records on the critique of the event and in-terviewed involved personnel. Both the worker and HPT providing job coverage have been counselled regarding their responsibilities for com-plying with RWP requirements. The inspector had no further questions concerning the event.
Wnrking in the LHRA without the personnel dos' meter required by the job-specific RWP is an apparent violation of the licensee's procedure.
How-ever, the occurrence was identified by the licensee, the ralth and safety significance of the occurrence is considered to be minor, appro-priate corrective actions have been initiated. Therefore, in accordance with Appendix C of 10 CFR Part 2, a Notice of Violation will not be issued.
6.11 Licensee Actions on Previously Identified Items
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(0 pen) Inspector Following Item (50-320/86-09-02)
On-site NRC staff and a representative from Nuclear Materials Safety and Safeguards attended a meeting on January 22, 1988, with the licensee that outlined how the radwaste material contained in liner Nos. 19 and 23 would be disposed of.
These liners had been deter-mined to be unsuitable for shipment as a result of the expansion of the waste form and subsequent deformation and rupture of their metal containers.
Present plans for liner No.19 call for vacuuming the loose material from the storage module, sizing the waste form, ther, placing it in a high integrity container in preparatior, for eventual shipment to a burial site.
Prior to conducting this oper-ation, an enclosure will be constructed over the module to preclude an environmental release of any airborne radioactive material that may be generated during the clean-up.
Since liner No. 23 is intact and there is no indication that material has been extruded, the liner will be transferred from the storage module to the auxiliary b.ilding so that a more detailed examination can be made of the waste form. As part of these operations, samples of the waste material will be obtained and evaluated to determine the mechanism that caused the waste form to expand. These activities are sched-uled to begin in the second quarter of 1988.
Site inspectors will cons.nue to follow licensee progress on this item.
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. Closed) Unresolved (50-320/87-14-02): Suspension of Burial
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P,r_ivileges for Sclidified Sludge at Barnwell, South Carolina On October ~ 23,-1987, the contents of a radwaste liner containing solidified sludge from TMI-2 were inspected by the South Carolina Department of Health and Environmental Controls (SCDHEC) at the Chem-Nuclear Waste Management Facility in Barnwell South Carolina.
The. findings were that the material in the liner exhibited a moist, putty-like consistency, instead of being. 'ree standing solid mass.
Based:on these results, the State of Sou.".arolina issued a notice of infraction to the licensee on N ember 4, 1987, s'uspending the authorization to ship solid.ified sledge to the Barnwell facility until actions were implemented that would assure that future ship-ments of sludge w3re solidified. The licensee submitted his pro-posed corrective actions to SCDHEC on December 24, 1987, and these actions were accepted ~by SC0 HEC on January 5, 1988.
-On-site NRC 'nspectors reviewed the details of this incident.
Through examination of the applicable documentation, the inspectors determined that the liner contained sludge from the: Auxiliary Building Sump, having a-strontium-90 concentration of 42.7 curies per cubic meter and a ceslum-137 concentration of 9.35 curies per cubic meter. These activities required that the shipment be pack-aged as Class B waste.
The waste form must comply with the re-qui,ements of 10 CFR 61 for disposing by burial.
10 CFR 61.56 re-quires that Class B waste have structural stability.
The condition of the solidified sludge as identified by SCOHEC is
contrary'to the requirements of 10 CFR 61.56 in that the putty-like consistency was not a waste form that would maintain its physical dimensions and its fora under the expected disposal conditions (320/
88-01-02). Accordingly, tiiis condition-is a violation of regulatory requirements.
The inspectors reviewed the licensee's corrective actions taken to ensure the proper solidification of liquid radwaste and determined that they are acceptable. These actions included:
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All liners will be removed from storage and sounded to deter-mine their current condition.
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Following sounding, liners which appear to be solidified will have holes drilled through the liner sidewall to visually view the matrix and verify solidification. Upon verification of solidification, these holes will be plugged and the liner pre-pared for shipment.
If, af ter drilling, any liners show evi-dence of ammonia off gassing or unsolidified material, the liner will be allowed to vent in accordance witn the following step.
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..Any liner which'shows 'vidence of not-being solidified, either-e
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after sounding or after; drilling, will be allowed to' vent:for a H
period of eight to ten weeks.
This time period is based'en-the-J.
findings with liner 1443649-2 at~the:Barnwell site.
Following
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venting,.these ' liners will undergo visual verification inL accordance with StepL2 above.
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In addition to providing this'information:to.SCOHEC and1to on-site NRC inspectors, the licensee' submitted this as docketed,information
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in a letter dated February 3,1988. Accordingly,'no' response is'
required to this violation.
7.0 'Open Item Matters that require-further review and: evaluation by the. inspectors.
Open
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8.0 Exit Interview
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The inspector met periodically with licensee representatives to discuss in-spection findings. On January 29, 1988, the site inspectorsisummarized-the inspection findings in a meeting with the following personnel:
J. Byrne, Manager, TMI-2 Licensing W. County, QA' Auditor W. Conaway, Radwaste Support Manager S. Levin, Defueling Director i
W. Potts, Site Operations Director R. Rogan, Director, Licensing and Nuclear Safety D. Turner, Director, Radiological Controls, TMI-2
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R. Wells, Senior Licensing Engineer-l
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