IR 05000320/1988014

Safety Insp Rept 50-320/88-14 on 880910-1008 & 11.No Violations Noted.Major Areas Inspected:Defueling & Decontamination Activities,Including Proper Implementation of Radiological Controls,Housekeeping & Licensee Actions

ML20205Q329
Person / Time
Site:	Three Mile Island
Issue date:	10/26/1988
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205Q318	List: IR 05000320/1988014 ML20205Q313
References
50-320-88-14, IEB-78-08, IEB-78-14, IEB-78-8, NUDOCS 8811090195
Download: ML20205Q329 (10)

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U.S. NUCLEAR REGULATORY COMMISSION L

REGION I

Report N /88-14  ;

i Docket N !

License N DPR-73 . Priority --

Category C i

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Licensee: GPU Nuclear Corporation l P. O. Box 480 Middletown, Pennsylvania 17057 i

Facility Name: Three_ Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania '

Inspection Conducted: Septembce 10 - October 8 and 11, 1988 Inspectors: D. Johnson, Resident Inspectoi' (Reporting Inspector)

T. Moslak, Resident Inspector Approved by: $ /0/M!ff C. CowgAll, (hjpf, Reactor Projects Section lA Date

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Inspection Summary:

Areas Inspected: Routine safety inspection by site inspectors of defueling and de-

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contamination activities, including the proper implementation of radiological con- i trols, housekeeping, and licensee actions on previous inspection findings.

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Results: Licensee personnel conducted clean-up operations in a safe manner. De- [

fueling activities were slowed by several failures of the plasma arc cuttirig  ;

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equipment, but repairs were made and operations continued in a controlled manne [

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No unresolved items were generated during this inspection perio i l l

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TABLE OF CONTENTS PAGE ( verview..................................... ....................... 1 l

l Introduction.............. ..................................... 1 l

1.2 Defueling Operations.................................. ......... 1 l 1.3 Decontamination / Dose Reduction Activities....................... 2 l 1.4 NRC Staff Activities............................................ 2 l 1.5 Persons Contacted............................................... 2

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! 2.0 Defueling/ Decontamination Activities (NIP 71707)..................... 2

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l l 2.1 Scope of Review................................................. 2 GeneralFindings................................................ 3 3.0 Licensee Action on Previous Inspection Findings (NIP 92701/92702).... 3 4.0 Exit Meeting (NIP 30703).......................................... . 8

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DETAILS 1.0 Overview 1.1 Introduction During this reporting pericd, cutting of the grid forging continue The grid forging is the third of five plates that comprite the Lower Core Support Assembly (LCSA) that is to be removed to pro /ide access for de-fueling the lower head of the reactor vessel. Decontamination of plant surfaces and systems continues. Three plant areas are isolated from routine use and placed in an interim Post-Defueling Monitored Storage (PDMS) status. Five other plant areas are scheduled for verification to determine if they meet the interim l'DMS isolation criteri .2 Defueling Operations Upon completion of clearing loose debris from the grid forging, defueling crews installed the plasma arc cutting equipment in the vessel and re-sumed cutting operations. All in-core guide tubes and support posts have been severed and removed from the vessel to preclude interference with cutting the grid forging. To date, fif ty-five cuts have been rnade in the forging. Of a total of seventy-seven cuts needed to cut the grid forging into four sections, seven have been verified as completely cu The licensee is conducting surveys to determine fuel quantities in other portions of the Reactor Coolant System (RCS). In parallel with these surveys, various defueling techniques are being ovaluated should fuel be fuund to be present. Surveys of several areas of the plant have been completed, including the letdown heat exchangers and the plenum assembl '

Resd ts of these completed surveys were reported to the NRC staff by the licensee in a letter dated September 30, 1988. The letter transmitted two completed Post-Defueling Survey Reports (PDSR's). These surveys detailed how the determination was made that no further defueling was

necessary for these areas, the types of rneasurements made and evaluations l

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completed to support the determinations. The licensee has completed several other surveys (Once-through Steam Generator (OTSG) lower heads and hot legs) and has determined that no further defueling is required in these areas either. No other pDSR's have been issued to date. The

, licensee plans on surveying forty-seven areas in the fuel handling /

l auxiliary buildings and twenty-four components / areas in the reactor

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building to evaluate the need for fuel removal. The NRC staff will re-view the entire POSR package for evaluation of the completion of defuel-ing efforts.

j 1.3 Decontamination / Dose Reduction Activities Scabbling, steam cleaning, hands-on decontamination continue in the auxiliary snd fuel handling buildings. To date, 120 of 143 cubicles have been decontaminated to end point criteria. The remaining cubicles con-

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tain contaminated plant systems that first iaust be cleaned before the cubicle is decontaminated. Flushes of these systems are being performed to lower dose rates in these cubicle .4 NRC Staff Activities The purpose of this inspection was to assess licensee activities during defueling and decontamination activities. The inspectors made this assessment through actual observations of licensee activities, interviews with licensee personnel, or review of applicable documents. NRC staff inspections use the acceptance criteria and guidance of NRC Inspection Procedures (NIP's). These NIP's were annotated in the Table of Contents to this report.

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1.5 Persons Contacted

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"J. Byrne, Manager, TMI-2 Licensing

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• J. Hernan, Site Quality Assurance Auditor

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• G. Kuehn, Site Operations Director, TMI-2

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W. Marshall, Manager, Plant Operations l

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R. Rogan, Director, Licensing and Nuclear Safety

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E. Schrull, THI-2 Licensing Engineer

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• D. Turner, Director, Radiological Controls

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R. Wells, Licensing Engineer 2.0 Defueling/0econtamination Activities 2.1 Scope of Review The inspector observed and/or reviewed licensee defueling decontamination activities to: (1) ascertain factual status of such activities and (2) assure proper adherence to applicable procedures. The inspector also made observations in facility spaces with respect to proper housekeeping, fire protection, and radiological controls. The general acceptance cri-teria for this review was Section 6 of the TMI-2 Technical Specifications (TS).

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

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control of operations in progress by supervisory personnel;

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knowledge of the task by technicians and support persons;

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appropriateness of gover,iing documents, it cluding procedures and Radiation Work Permits (RWP s);

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alertness of various controlling station personnel;

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assess the quality of implementat*on of selected evolutions wit-nessed; and,

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~ assess the material condition of the plan i 2.2 General Findings As a result of the routine review noted above, the inspectors identified no major discrepancies. In general, licensee representatives properly implemented procedures. Defueling activities and cleanup activities were conducted in a safe and controlled manner. Repair activities for the

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plasma arc torches and reactor vessel cutting equipment were accomplished 1 appropriately. No major contamination events occurred during removal

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of the X-Y bridge equipment from the reactor vessel. There were no specific events or incidents that the NRC staff reviewed during this inspection period, t

3.0 Licensee Action on Previous Inspection Findings 3.1 (Closed) Inspector Folicw Item (320/78-10-07): Review Control of Tech-nical Manuals The inspector reviewed Administrative Procedure (AP) 4220-ADM-3052.01,

"TMI-2 Plant Maintenance - Control of Technical Manuals," and determined that the licensee has established a method by which the Plant Maintenance Department administrative 1y controls and maintains vendor manuals and books. Through spot checks of manuals, the inspector determined that the procedure is implemented as required in that manuals were red stamped for control in designated library locations and that "pen and ink" changes to a manual received concurrence by a vendor representative and a cognizant engineer prior to being incorporated in a manua The inspector had no further questions on this matte .2 (Closed) Inspector Follow Item (320/78-10-08): Review Implementation of Program in Area of Tests and Experiments This item was opened to track incomplete inspector action for review of the 10 CFR 50.59 program, which was to have been completed as part of a routine inspection. The licensee currently has in place an adequate 10 CFR 50.59 program for test and experiments. This program is imple-mented in part by site procedures 4000-ADM-1218.02, Revision 2-01, "TMI-2 Document Evaluation Review and Approval;" 4420-ADM-1000.01, Revision 2-01,

"TMI-2 Safety Review Group Organization, Responsibility and Authority;"

and, 4420-ADM-1010.01, Revision 1-03, "TMI-2 Safety Review Group (SRG)

Conduct of Business." The inspector reviewed the latest changes to these procedures to verify that they adequately addressed the requirements of 10 CFR 50.59. The inspectors routinely review procedure changes and on-going evolutions to verify proper implementation of the program. This item is close _ _ _ _ _ _ _

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3.3 (Closed) Unresolved Items (320/78-37-04, 320/78-37-05): Check Valve Operability Tests Not Per IWV-3520 and Procedures Do Not Address Testing of Valves with Fail Safe Actuators Per IWV-3410E These items were opened to track deficiencies in the licensee program for inservice testing of pumps and valves in accordance with ASME (American Society of Mechanical Engineers) Boiler and Pressure Vessel Code Section XI. This testing per ASME Section XI is no longer required at TMI-2 per Technical Specifications. The only inservice inspection per ASME XI that is accomplished is done in accordance with AP 4210-ADM-3274.01, Revision 1.00, "Inservice Inspection System." This procedure lists several valves in the decay heat and control building ventilation systems that are still required to be inspected after maintenance prior to return to service. These va'.ves are not check valves or valves with fail safe actuators. These items are therefore ciose .4 .(Closed) NRC Bulletin No. 78-08: Radiation Levels From Fuel Element Transfer Tubes This item was opened to track a concern for high radiation levels created by the transfer of spent fuel from the reactor building (RB) to the spent fuel building. At the time of issue of this bulletin, no spent fuel had been transferred and a commitment was made to accomplish these surveys when the first refueling outage was completed. Subsequently, due to the accident, the traditional movement of spent fuel was never accomplishe However, the licensee did accomplish a detailed radiation survey program when the first transfer of damaged fuel debris was transferred from the RB to the spent fuel poo No major problems were noted. The licensee action for NRC Bu11etir. No. 78-08 was adequate. This item is close .5 (Closed) NRC Bulletin No. 78-14: Deterioration of Buna-N Components in ASCO Solenoids Due to the fact that the primary problem was an 0-ring in a specific ASCO solenoid valve used in boiling water re?.ctor system for control rod scrams; i.e., control rod drive mechanism (CRDM) scram solenoid valves, this bulletin required no response from the license The licensee did not respond to this bulletin and the inspector concluded that no response to the information contained in the bulletin is warranted for TMI- This item is close .6 {_ Closed) Unresolved Item (320/79-01-01): _ Corrective Action for Inoper-

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abTe Battery Chargers This item was opened to track a pioblem that occurred during station battery load service testing, This type of load test is no longer re-quired by THI-2, although the batteries are still required by technical specifications to be operabl Ti.e inspector reviewed recently completed surveillances for weekly battery checks -- 4223-SUR-3730.03, Revision 2-00, "Station Batteries Inspection," and 4223-SUR-3734.02, Revision 3-00,

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"Station Storage Batteries and Chargers Weekly Check -- to verify that they were properly implemented. No problems were noted. This item is close .7 (Closed) Unresolved Item (320/79-01-02): Corrective Action for Diesel Generator Lead Sequence Timers This item was opened due to setpoint drift for twelve load sequence timers for the Emergercy Diesel Generator (EDG). The diesel generators are no longer in service at TMI-2 and are not required for emergency power or r.r.. ired by technical specification This item is close .8 (Closed) Unresolved Items (320/79-07-02): Complete Corrective Actions for LER 79-05 Regarding Decay Heat System Piping Cracks (320/79-07-03):

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~ Submit Update to LER 79-10/1T for Out-of-Specification Boric Acid Mix

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Tank; and (320/79-07-04): Perform Additional Review LER 78-74/3L Re-garding Diesel Generator Fuel Oil Preventive Maintenance and Quality Concerns These items were opened to track additional licensee corrective action for review of three items concerning components or systems that are no longer required at IMI-2 for any safety-related function These systems and components were removed fron, the technical specifications. The in-spector reviewed the licensee corrective action tracking system for all 1988 Licensee Event Reports (LER's) to verify that an adequate system exists to track and resolve corrective actions resulting from LER' The system appeared to be a comprehensive system that would assure that

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any corrective action assigned would be completed. Also, the LER's issued in 1988, to date, were complete and the information presented was accurat LER's 88-05, 06, 07, 08, and 09 were reviewed in NRC Inspection Report No. 50-320/88-10 and no problems were noted. Generally, LER's issued by THI-2 are of good quality and contain accurate information and have adequate corrective action The three items concerning systems no longer required are considered close .9 (Closed) Violation (32n/79-13-09): Facili'y Procedures Require Compre-hensive Review for a Major Revision The inspector reviewed the following licensee procedur ADM-1218.01, ef fective July 7,1988, "TMI-2 Procedure Numbering, Format, Content, Implementation and Compliance"

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4000-ADM-1218.02, effective May 31,1988, "TMI-2 Document Evaluation, Review, and Approval"

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4000-ADM-1218.03, effective August 29, 1988, "Procedure Change and Revision" From this review and through an examination of various procedures, Pro-cedure Change Requests (PCR's) and Temporary Change Notices (TCN's), the inspector determined thet the licensee has a comprehensive mechanism for evaluating, performing preliminary safety and technical reviews and com-pleting final concurrence and approval to procedures and changes to pro-

edure The inspector had no further question on this matte .10 (Closed) Violation (320/79-20-05): Material Purchased and Modification Performed Without Quality Assurance Controls The subject violation refers to the implementation of Change Modification 0343 where isolation valves for the pressurizer steam space sample bomb (SN-V-111 and SN-V-112) were replaced without quality assurance (QA)

controls on the work performed or on the procured material Since the configuration of TMI-2 is a reactor that is defueled and a primary system that is or will not be subject to temperature and pres-sures associated with an operating nuclear power plant, the item is not relevan+, to present or future plant condition Based on on going in-spections at TMI-2, there is evidence of QA control on procured materials which are important to the recovery activitie The inspector had no further questions on this matte .11 (Closed) Unresolved (320/79-20-14): Material Received and Issued Without Quality Contro M eceipt Inspection The inspector reviewed Quality Assurance Procedures:

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6110-QAP-7210.08, effective December 30,1985, "Use of Sampling Plans in Receipt Inspection;"

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6110-QAP-7203.01, effective August 26, 1985, "Review and Approval of Engineering Evaluations;" and,

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6110-QAP-7206.01, effective March 13, 1985, "Modification / Operation Quality Assurance Document Review."

Through this review, the inspector determined that guidance is provided for the selection of sampling plans for performing receipt inspections of materials, components, and equipment for use in important-to-safety or not-important-to-safety system This procedure is implemented by QA engineering personnel involved in the review of procurement documents and to quality control (QC) receiving inspection personne _ _ _ _ _ _ _ - _ _ _ _

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t 7 3.12 (Closed) Unresolved (320/81-19-01): Reactor Building Fire Protection Based upon previous inspections performed by the NRC staff and reviews of the licensee's TMI-2 Fire Protection Program Evaluation, including combustible control procedures and fire fighting training, the NRC staff concluded that the program in place at TMI-2 satisfies Appendix A to Branch Technical Position (BTP) 9.5-1 and provides an acceptable level of fire protection that is normally expected at an operating nuclear power plan These measures appear to be conservative due to the current shutdown mode of the plant in that the potential consequences of a fire at TMI-2 are significantly less than those which could be postulated for an operating facilit Implementation problems were noted during recent inspections and these were separately tracked by NRC staf The inspector had no additional questions on this matte .13 (Closed) Deviation (320/81-19-02): Lack of Three-Hour Ratings on Fire Barrier Penetrations, and Unresolved Item (320/79-26-05): Cracked Fire Barrier Penetration Seals These items addressed: (1) a deviation from a commitment, specifically with regards to conformance to a section of BTP 9.5-1, Appendix A, Sec-tion 03 in that "the fire barrier seals using Firewall 50 material do not have the same fire rating as the wall or floor they penetrate" and I (2) cracking of these fire barrier penetration seals. Subsequent to identification of these findings, the licensee initiated a program to replace Firewall 50 with a Dow Corning Silicon foam material (DC-3-6548)

that provides the equivalent fire ratin The program began in December 1982 and was completed in the spring of 1985. A series of fire protec-tion program inspections were performed by the NRC staffing following completion of the seal replacement program in which the determination was made that the licensee's fire protection program now satisfies the applicable sections of BTP 9.5- The inspector had no additional questions on this matte .14 Emergency Exercise Findings For the below-listed THI-2 findings, a Region I inspection team addressed these issues in a TMI-1 NRC Inspection Report (50-289/87-16). Accord-ingly, based upon discussions with licensee representatives, examination of records, plans and procedures, and observations made by that NRC team during the above-noted inspection, the following items were acceptably demonstrated and are close (Closed) Inspector Follow Item (320/86-14-01): The Emergency Direc-tor (EO) initially did not effectively utilize Technical Support Center personne . .

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(Closed) Inspector Follow Item (320/86-14-02): Follow-up notifica-tions to off-site agencies were slo (Closed) Inspector Follow Item (320-86-14-03): Continuous account-ability was not maintained in the Operations Support Center and the design made command and control difficul (Closed) Inspector Follow Item (320/86-14-04): Call-out and mobili-zation of emergency response personnel off hours was_not demon-strated during this exercise due to a large portion of the staff being on site fe support of the outag (Closed) Inspector Follow Item (320/86-14-05): Additional training is needed for proper call-in procedures by emergency response per-sonnel.

,- 4.0 Exit Meeting The inspectors discussed the-inspection scope and findings with licensee man-

, agement at a final interview conducted October 11, 1988. Senior licensee management personnel attending the final exit meeting are noted in Section 1.3.

The inspection results, as discussed at the meeting, are summarized in the 4 cover page of the inspection report. Licensee representatives indicated that none of the subjects discussed contained proprietary or safeguards informatio :'

Unresolved Items are matters about which information is required in order to ascertain whether they are acceptable, violations, or devfations.

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Inspector Follow Items are matters which were established to administrative 1y 1 follow open issues based on inspector judgement or on licensee / staff commit-

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