IR 05000320/1988012

Insp Rept 50-320/88-12 on 880708-0805.No Unacceptable Conditions Noted.Major Areas Inspected:Defueling & Decontamination Activities,Including Proper Implementation of Radiological Controls & Fire Protection Measures

ML20154B264
Person / Time
Site:	Three Mile Island
Issue date:	09/02/1988
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154B260	List: IR 05000320/1988012 ML20154B257
References
50-320-88-12, NUDOCS 8809130293
Download: ML20154B264 (9)

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U.S. NUCLEAR REGULATORY COMMIS$10N

REGION I

. Report N /88-12

Docket N License N OPR-73 Priority --

Category C Licensee: GPU Nuclear Corporation P. D. sox 480 Middletown, P'ennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania Inspection Conducted: July 8 - August 5, 1988

Inspectors: R. Conte, Senior Resident Inspector .

D. Johnson, Resident Inspector T. Moslak, Resident Inspector (Reporting Inspector)

A. Sidpara, Resident inspector C.dh #441 M- Projects SectionM+/$Y Approved by:

Cowgill, Cht[ef, Reactor 1A Date ,

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Inspection Summary:

Areas Inspected: Routine safety inspection by site inspectors of defueling and decontamination activities, including the proper implementation of radiological controls, housekeeping, fire protection measures, review of selected events, recent management changes, and licensee actions on past circular Results: Licensee personnel conducted clean-up operations in a safe manner. The

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inspector identified no adverse conditions with respect to the licensee's radio-logical controls and fire protection programs. Housekeeping in the reactor build-  ;

ing improved significantly. Minor procedural implementation problems were identi- '

fled in the maintenance area as noted in the specific event, concerning the yard engine, as contained in paragraph 2.4 in this repor Licensee actions in response to NRC staff circulars were acceptabl '

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8309130293 880906 2 PDR ADOCK 05000320

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TABLE OF CONTENTS '

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f 1.0 Introduction and 0verview............................................ 1

1.1 Defueling Operations................................ ........... 1

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1.2 Decontamination / Dose Deduction Activities....................... 1 i l 1.3 NRC Staff Activities............................................ 2

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1.4 Persons Contacted............................................... 2 l

l 2.0 Defueling/Decontaminat ion Activi ties (N!P 71707) . . . . . . . . . . . . . . . . . . . . 2  ;

i 2.1 Scope of Review.................................................. 2 l 2.2 General Findings................................................ 3 2.3 Reactor Building Conditions.......................-.............. 3 f l 24 Eve n t Rev i ew ( NI P 93 702) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 }

l 2.5 Decontamination /Defueling Summary............................... 6 f L

3.0' Management Actions in Response to Investigation of Operator Sleeping

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Issue (N!P 35502).................................................. 6 j I f 4.0 Licensee Action on NRC Staf f Circular /Inferraation Notices i (NIP 92701)........................................................ 6 l 5.0 Exit Meeting (NIP 30703)............................................. 7 I

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I OETAILS (

1.0 Introduction and overview f

1.1 Defueltito Operations r

Defueling crews completed removal of the upper flow distributor (UFD) [

from the reactor vessel and placed it in storage in a modified core fined tank. The UFO was the second of five sections comprising the Lower Core 1 L

Support Assembly (LCSA). The licensee cut this section into pieces, !

using the plasma arc technique, and they removed it from the vesse i In preparation for cutting the next plate -- the grid forging -- defuel- l ing crews cleared debris from the top and flow holes of the forgin '

This debris contained a significant amount of chips and dross material :

created by the drilling and cutting operations, respectively, in addition !

to short length fuel rods. Workers used manual pick-and place techniques !

to clear rods from the forging. Then, they used airlift operations ts ,

clear vacuumable debris from in and around the forgin ;

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With the forging cleaned, plasma are equipment will t,e installed and !'

Mtting operations will resum i Also, the licensee conducted surveys to determine fuel quantities in !

other portions of the primary system. In parallel with these surveys, the licensee was in the process of evaluating various defueling tech- l t

niques should fuel be found, f

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No shipments of casks containing core debris were made during this re- l pcvting period, l

1.2 Decontamination / Dose Reduction Activities [

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Scabbling, steam cleaning, and hands-on decontamination continues in the auxiliary and fuel handling buildings. To date, 119 of 143 cubicles are (

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decontaminated to end point criteria, with three cubicles presently :

undergoing evaluation to assess their status. The remaining cubicles !

contain contaminated plant systems that first must be cleaned before the I cubicle is decontaminated. Workers are performing flushes on these j systems to lower dose rates in these cubicles, t

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Filling and draining of the block wall in the reactor building (RB) {

basement is on going. As a result of the low concentration of contamin-ation in the flush water, the RB sutp water is being processed through the EPICOR II water clean-up system, in lieu of the Submerged Demineral- [

izer System (SDS). An evaluation is being perforced to determine the !

effectiveness of the fill-and-drain operatio l Attempts to transfer highly contaninated resins from the "A and "B" make-up coinertlizers were unsuccessfu Preparations were being made :

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to install a hydrolance in the "A" demineralizer discharge piping in an l effort to break up the material, using high pressure water, to permit i f

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J sluicing to a receiver tank. A delumper also is being installed in the 1 recirculation flowpath of the reeceiver tank to increase the sluicability j of the discharged materia The licensee implemented the initial phase of assessing specific plant areas for eventual placement of these areas into a Post-Defueling Moni-tored Storage (PCMS) condition. Following its assessment, the seal re-turn cooler / filter room was the first area to be isolated from routine access to assure that it would not become re-contaminated, nor be im-pacted by other plant operation , 5even other areas are currently scheduled for verification and subse-l quently should be isolated from the balance of plan .3 NRC Staff Activities The purpose of this inspection was to assess licensee activities during j defueling and decontamination activities. The inspectors made this I

assessment through actual observations of licensee activities, interviews with licensee personnel, measurement of radiation levels, or review of

, applicable documents. NRC staff inspections use the acceptance criteria i and guidance of NRC Inspection Procedures (NIP's). These NIP's were j annotated in the Table of Contents to this report, l 1.4 Persons Contacted i

i During this inspection, the following key licensee personnel provided i subst.attel i fn Wation in the development of the inspectors' findings.

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l 'J, B> rne, Hanapr, TMI-2 Licensing

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'C Incorvati, iMI Audit Manager

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$. Levin, Defuelittg Director

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W. Marsha't, Operations Engineer

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W. Potts, diractor, Plant Operetions

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• J. Redabaugh, Defueling Task Manager

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" hgan, Di' Jctor, Licensing and Nuclear Safety

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• E. Schru11. TMI-2 Licensing Engineer

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L. Shamenek, Planning and Scheduling Manager

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• R. Sieglitz, Manager, Waste Management

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J. Tarpinian, Manager, Radiological Engineering

-- *0, Turner Director, Radiological Centrols

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D. Tuttle, Manager, Radiological Field Operations

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R. Wells, Licensing Engineer 2.0 Defueling/ Decontamination Activities 2.1 !Jope of Review The inspector observed and/or reviewed licensee defueling decontamination activities to: (1) ascertain factual status of such activities; (2) as-sure proper adherence to applicable procedures; and, (3) select and re-

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i view significant events warranting further inspection follow-up. The l inspector also made observations in facility spaces with respect to proper housekeeping, fire protection, and radiological controls. The l general acceptance criteria for this review was Section 6 of the TMI-2 i Technical Specifications (TS). '

In performing the above inspections, the inspectors focysed on the fol-lowing areas of licensee performance:

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control of operations in progress by supervisory personnel; i

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knowledge of the task by technicians and support persons;  !

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appropriateness of governing documents, including procedures and  !

Radiation Work Permits (RWP's);  !

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alertness of various centro 111ng station personnel;

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assess the quality of implementation of selected evolutions wit-  !

nessed; an '

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assess the material condition of the plan The inspections were made at random intervals and during the following (

back shif t hours (10:00 p.m. and 6:00 a.m.). l I

Date/_ Day Time Periods Ho u_r_s  ;

i 7/16 Saturday 10:00 a.m. - 11:00 ^ /20 Wednesday 9:30 p.m. - 11:30 .0 7/30 Saturday 10:00 p.m. - 11:30 .5 l

2.2 General Findings As a result of the routine and off-shift review noted above, the inspec- '

tors identified no eajor discrepancie In general, licensee represen- l tatives properly implemented procedures, except as noted for certain j events listed within this report. Addressed below were specific obrer-vations in the area of housekeeping, fire protection, and event revie !

Of particular note was the licensee's low threshold for coc eenting and [

reporting off-normal events that were below reporting requirement thres-  !

hold !

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2.3 Reactor Building Conditions  !

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i On August 3,1938, the inspector entered the reactor building (RB) to i evaluate overall radiological and industrial safety condition The [

inspector determined that housekeeping had impreved significantly for j the racn'aste storage areas, equip ent staging / repair areas, and general I werk areas on the 305-foot and 347-foot elevatiens of the k l l

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! The inspector also accompnicd a defueling crev on the shielded work [

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platform while the team was clearing debris frcm grid forging holes and i verifying the cleanliness of previously cleaned holes. From observing i the work in progress, the inspector determined that the activities were l conducted in accordance with the procedures and radiation work permits (RWP's).

In support of this RB entry, the inspector reviewed RWP No.17511 and i determined that the protective clothing, respirators, and dosimetry i specified were appropriate for the tasks being performed. By attending l

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a pre-job briefing, the inspector concluded that the command / coordination ;

center was adequately staf fed with licensed supervisory, engineering >

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support, and radiological controls personnel and that these persennel (

were cognizant of present RB conditions and the status of on going ac- i

4 tivities. No violations were identifie I

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During this entry, the inspector observed that posting of radiation areas i

{ was appropriate, that low dose rate areas were conspicuously marked, and ;

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that contaminated equipment and materials were appropriately segregated, 1 bagged, and tagged. For large pieces of contaminated equipment, tempor-

! ary shielding was installed to lower dose rates in the general are ;

l 2.4 Event Review l

} I J A number of events were identified by the licensee in their internal l reporting system and they were reported to the resident inspector !

l\ i l 2. Inattentiveness to Outy l l  !

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On July 19,198B, the operator of the RB polar crane was

! found to be asleep at his operating station. This oc- f

curred during a "lull" in activities during the removal j of a section of the UFD. The hanging piece was supported ;

by the polar crane wire rope and brake system of which [

the effectiveness was not dependent on the polar crane [

eperator. He was subsequently discharged from the sit !

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On July 19, 1983, a worker was found to be asleep in the !

Contaminat, ton Control Cubicle (c-cubed). Subsequently, he was oisenarged frem the sit l l

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On August 3, 1953, a worker was found asleep in the auxiliary building. He was subsequently discharged from the site,

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I No licensed cperaturs were involved in tFe three events de- l scribed. These events do refleet a continuing problem regard- ;

ing manace ent of idle t h e of worker I f

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2. Railcar Movement At approximately 1:30 p.m. on July 26, 1988, a railcar carrying a loaded shipping cask and its unmanned yard engine drifted for approxirrately 60 yards on site. The engine and railcar came to a final rest ' 4 result of an increase in the natural grade of the rail Prior to this occurrencs workers were preparing the cask for shipment off site, but U ;y stopped work because of a severe electrical storm. In their haste, they failed to set the engine's hand brake. Following their ceparture, the engine's air brake slowly bled off, which released the air brake, and resulted in the engine and railcar slowly drifting. The engine struck a portable traffic sign in its path before coming to res No damage occurred to the engine, railcar, or shipping cas The shipping cask contained seven cans of core debri No release of radioactive materials occurred. No personnel were injured. There was also no impact on any security bound-ary for either TMI-1 or The licensee began an immediate investigation to determine the circumstances surrounding the incident anti to establish actions to precluoe a recurrence. The root cause was determined to be the failure to set the engine's hand (manual) brake (per the procedure) prior to leaving the engine's cab. Corrective actions included revising the Maintenance Implementing Proce-dure 4220-!MP-3125.01, "Operation of the Yard Switcher Loco-motive," to highlight setting of the hand brakt before the operator leaves the engine for any reason, placing a sign in the engine cab directing the operator to apply the hand brake prior to exiting the cab, and retraining all engine operators in the theory and operation of the air and rechanical brake system Site inspectors reviewed the licensee's investigation and corrective actions and deternined thcm to be satisfactor The inspector also reviewed Licensee Internal Report Serial No. 4420-88-0060, dated July 15, 1933, regarding the results of a trend analysis performed by the licensee's $afety Review Group. The trend analysis was performed on a series of inci-dents that have recently occurred to identify their root causes and to provide recomerdations to site rnaragement on what ac-tions should be taken to reduce the frequency of such incident From this review, the inspector concluded that the report was thorough and ptovided specific actions for licensee managevent to focus their attention to reduce the frequency of such inci-dent The inspector will continue to ronitor the iepleentat, ton of the licensee's actions to determine their effectivenes _________ _ _ - _ _ _ _ _ - _ _ _ - _ _ _ _ _ . __ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ . _ _ _ - _ _ _

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l 2.5 Decontamination /Defueling Summary l

t Defueling/ decontamination activities proceeded as plannod and were car- l ried out safely. The events noted above did not result in any signific-  ;

ant radiological consequenc I

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The licensee's internal reporting system is an organizational strength; (

the effectiveness of which is being reviewed by NRC Region I in light  ;

of events noted outside this inspection perio [

Overall, housekeeping and fire protection measures have steadily improved in the RB and in the balance of plan .0 Managelent Actions as a Result of Licensee Investigation _of Operator Sleeping Issue  !

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On July 20, 1938, the licensee announced the completion of its independent i investigation into management resconse to allegations that a shift supervisor (

at TMI-2 slept while on shif The report was received by GPU Nuclear (GPUN) t Corporation and forwarded to the Nuclear Regulatory Commission. The indepen- l dent investigation was conducted for GPUN by Edwin H. Stier, former director i of the New Jersey Division of Criminal Justice. In Novem5er 1987, Mr. Stier i confirmed that the shift supervisor slept on a number of occasions or other- [

wise was inattentive to his job. Subsequently, the individual was fire In the second phase of the investigation, Mr. Stier was critical of site man-agement's handling of the allegations concerning the behavior of the shif t supervisor, As a result of the completion of the investigation, the licensee took a number of disciplinary actions affecting TMI-2 site reanagement. These actions included a dismissal, reassignments to positions not involving super-vision of licensed operators at TMI-2, and formal reprimand Site inspectors will review the qualifications of the individuals chosen by the licensee to replace those affected by the disciplinary actions. This will be done to verify that the individuals qualifications are in accordance with Technical Specifications (TS) 6.3. The results of this review will be docu-rented in a future NRC inspection report (Unresolved Item 320/83-12-01).

4.0 Licensee Action on NRC Staff Circulars /Information Notices Prior to 1932, the NRC staff routinely informed licensees of generic informa-tion and/or operating experience feedback using the "circular" system. The licensee did not have to respond to a circular, but NRC staf f espected licen-see to review this information for applicability and to take appropriate cor-rective action In 19S2, NRC staf f started to use two systems to pass on such information to licensees. One was Generic Letters issued by the Office of Nuclear Reactor Regula*. ion (NRR) and the other was Information Notices issued by the Of fice of Inspection and Enforcement (IE). (The functions of IE have been absorbed into other NRC offices, such as NRR, for the issuance of Information Notices.)

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When the circular system was in effect, the regional inspectors placed the circulars in an internal Region I "open items tracking system" (0! list) for possible future inspection depending on the type of inspection It was nevu intended that all circulars be formally closed in inspection reports. This is currently unrealistic considering the number of Information Notices issued per year (close to 100). Accordingly, no Information Notices were specific-ally listed on the O! list for Unit 2 but these were resiJual "open" circy-lars listed on this syste Past inspections in the area confirmf;d: (1) many circulars (Information No-ticos) were not applicable to THI-2 because of its unique conditions; (2) the licensee had a review process for determining current applicability for imme-diate action in distinction to Jeferred action because of applicability for an operating unit; and, (3) licensee decisions of an immediate or deferred corrective action for selected circulars were acceptabl During this inspection, the inspector reaffirmed the above-noted conclusion For example, Circuitr No 79-05 dealt with equipment environmental qualifica-tion for design basis events. This was appropriately deferred for acticn because environmental qualification requirements were applicable to only an operating reactor. However, Circular No. 75-12 en emergency diesel generator (EDG) problems were reviewed for applicability when the EDG's were required to be operable (Licensee Action Item (LAI) No. 2-S0-039).

Based on the review criteria stated above, the following circulars, as listed en the Region ! O! Itst for TMI-2, are considered administrative 1y closed:

77-14; 78-16; 79 02, 04, 05, 10, 12, 17, 19, 20, 23; 50-01, 03. 04, 05, 10, 11, 12, 22, 23; 81-01, 05, 06, and 0 As a part of the routine inspection program, Region I will continue to review this area for generic information appitcable to current TMI-2 condition .0 Exit Meeti,ng The inspectors discussed the inspection scope sna findings with licensee man-agement at ) final exit interview conducted August 5, 1958. Senior licensee persona,vi sttending the final exit treeting were noted in Section The inspection results, as discussed at the meeting, are su*marized in the cover page of the irspection report. Licensee representatives irdicated that none of the subjects discussed contafned proprietary or safeguards information.