IR 05000320/1988016

Insp Rept 50-320/88-16 on 881009-1109.No Violations Noted. Major Areas Inspected:Defueling & Decontamination Activities Including Proper Implementation of Radiological Controls & Housekeeping Measures

ML20206J541
Person / Time
Site:	Three Mile Island
Issue date:	11/23/1988
From:	Conte R, Cowgill C, Dante Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206J540	List: IR 05000320/1988016 ML20206J538
References
50-320-88-16, NUDOCS 8811290026
Download: ML20206J541 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /88-16 Docket N License N 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 Conducted: October 9 - November 9, 1988 Inspectors: R. Conte, Senior Resident Inspector D. Johnson, Resident Inspector (Reporting Inspector)

T. Koslak, esident Inspector Approved by: . CluAutt , kYY C, Date wgill, Chief,ReactorPpjectsSectionlA D spection Summary:

Areas Inspecte_d: Routine safety inspection by site inspectors of defveling and decontamination activities, including the proper implementation of radiological controls and housekeeping measures, and licensee actions on previous inspection finding Results: Licensee personnel conducted clean-up operations in a safe manner. De-fueling activities conducted inside the reactor vessel continued at a slow, but safe, pace, No major problems occurre No unresolved items were generated during this inspection perio Twenty-six previous inspection findings were closed based, mostly, on inspector review for current applicability and to a certain extent licensee actions to resolve the issues, r:.j1Qfh $h; {0

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TABLE OF CONTENTS PAGE 1.0 Overview,.... ...................................................... 1 1.1 Licensee Activities............................................. I 1.2 N R C S t a f f /.e t i v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1.3 Persons Contacted............................................... 2 2.0 Defueling/ Decontamination Activities (NIP 71707)..................... 2 2.1 Scope of Review................................................. 2 2.2 General Findings................................................ 2 3.0 Licensee Action on Previous Inspection Findings (NIF 92701/92702).... 3 3.1 (Closed) Violation (320/79-10-10): Inadequate Plant Operations Review Committee's Review of Procedures....................... 3 3.2 (Closed) Unresalved Item (320/79-19-05): Fire Door Size......... 3 3.3 (Closed) Inspector Follow Item (320/79-80-18): Audibility Problems for Evacuation of Personnel From High Noise Areas.... 3 3.4 (Closed) Unresolved Item (320/80-11-07): Resolve Exceptions / Deficiencies on a Surveillance Procedtme........... A 3.5 (Closed) Inspector Follow Item (320/80-BU-24): P"evention of Damage Due to Water Leakage Instde Containment................ 4 3.6 (Closed) Violation (320/81-12-01): Failure to Properly Control Drawings; Violation (320/81-12-02): Failure to Properly Implement Submerged Demineralizer System (SDS) Procedures; dnd, Violation (320/81-12-04): Failure to Properly Control SDS Procedures and Instructions............................... 4 3.7 (Closed) Violation (320/81-14-02): Failure to Document Valves / Breaker Positions on "Clearance of Work"............... 5 3.8 (Closed) LER's (320/81-LO-21, 26, 28, 29, 30, and 32): Previous Licensee Event Reports.................................. ..... 5 3.9 (Closed) Violation (320/82-01-02): Failure to Establish Adequate Measures to Assure Procedure Revisions After Modification Work.......................................................... 5 i

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' Table'of Contents PAGE 3.10 (Closed) Unresolved Item (320/82-02-03): Licensee to Update Licensee Event Reports........................................ 6 3.11 (Closed) Unresolved Item (320/82-02-04): Licensee to Clarify Records Storage Requirements.................................. 6 3.12 (Closed) Unresolved Item (320/82-04-04): Licensee Review Mal function of Reach Rod (Stowe Operator) for MU-V-342A. . . . . . . 7 3.13 (Closed) Violation (320/82-04-06): Failure to Properly Correct Under-Drain Filter Bypassing.................................. 7 3.14 (Closed) Violation (320/82-04-07): Failure to Retrieve Record ,15 (Closed) Inspector Follow Item (320/85-19-02): Toxic Gas Sampling...................................................... 7 3.16 (Closed) Inspector Follow Item (320/85-21-02): Garbled Communications at the Defuelirg Shielded Work Platform........ 7 3.17 (Closed) Inspector Follow Item (320/87-03-01): Defueling Water Cleanup System Hose Rupture................................... 8 4.0 Exit Meeting (NIP 30703)............... ............................ 8

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DETAILS 1.0 Overview 1.1 Licensee Activities Defueling activities in the lower core support region continued with cutting of the grid forging. (The grid 'orging is the third of five plates that comprise the Lower Core Support assembly (LCSA) that is to be removed to provide access for defueling the lower head of the reactor vessel.) Progress remained slow as the cutting equipment continued to experience a short lifetime when making cuts. The licensee has employed a special (kerf-type) tool to break up the hardened slag that remains in the cut area after the initial attemp This was fairly successful, although many of the cuts required re-cutting using the plasma arc torc Also, a considerable amount of time was spent performing visual inspec-tion of the forging cuts. Each cut must be verified to be severed com-pletely prior to an attempt to remove the forging piec Visual in-spection was accomplished using an underwater video canera. At the end of the reporting period, the licensee was installing the clamping device, which will be used to lift the first of four forging segments out of the Cor Also, the licensee slowed the pace of activities in the auxiliary / fuel handling buildings relateo te. transfer of these areas to Post-Defueling Monitored Storage (PDMS) status. Major work emphasis was transferred to the reactor building to ensure that this portion of the decontamina-tion effort will be completed firs The majority of the 143 cubicles in the auxiliary / fuel handling buildings has been decontaninated and work remaining consists of verifying that the cubicle is isolated, equipment secured, and the cubicle is ready for the reduced monitoring in the PDMS phase. Six plant areas are isolated from routine use and placed in an interim PDMS statu .2 NRC Staff Activities The purnose of this inspection was to assess licensee activities during defuel .g and decontamination activitie 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 in NRC Inspection Procedures (NIP's). These NIP's were annotated in the Table of Contents to this repor The main focus during this inspection was NRC staff review for current applicability of previous inspection finding . _ _ _ _ _ _ ____ ______ __________ ___ _ ___-__ __ _ _ _ _ _ _ _ _ _ _

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g 1.3 Persons Contacted During this inspection, the following key licensee pcrsonnel provided substantial information in the development of the inspectors' finding *J. Byrne, Manager, TMI-2 Licensing

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• W. County, Quality Assurance (QA) Audi or

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G. Kuehn, Site Operations Direcuc . TMs-2

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• W. Marshall, Manager, Plant Operations

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H. Mumford, Post-Defueling Monitored Storage Manager

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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/ Decontamination 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 apnlicable procedures. The inspector also made observations in facility spaces with respect to proper housekeeping, fire protection, and radiclogical control The general acceptance criteria for this review was Section 6 of the TMI-2 Technical Specifica-tions (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 progre:s by supervisory perscnnel;

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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 (RdP's);

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alertness of various controlling station personnel;

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assess the quality of implementation of selected evolutions wit-nessed, and,

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assess the material condition of the pla,1 A backshift inspection occurred on Saturday October 22, 1988, between 9:00 p.m. and 11:00 .2 General Findi_ngs As a result of the routine review r.oted above, the inspectors identified no major discrepancie In general, licensee representatives properly implemented procedure Defueling activities and cleanup activities were

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conducted in a safe and controlled manner. Repair activities reiuired for the plasma arc torches and reactor vessel cutting equipment were accomplished approp.-iately. There were no specific events or ircidents that the NRC staff reviewed during this irspection perio .0 Licensee Action on Previous Insp?ction Findings 3.1 (Closed) Violation (320/79-10-10): Inadequate Plant Operations Review Committee's Review of Procedures This item concerned one portion of a violation that was issued to the licensee as a result of the TMI-2 accident. It related to an inadequate review of procc.ures by the Plant Operations Review Committee (PORC).

The PORC was deleted from the TMI-2 site organization; and, as approved by the NRC staff, they were replaced with other review organizations and practices. The Safety Review Group (SRG) accomplishes some of the tasks previously done by the PORC. Additionally, the Independent Safety Review (ISR) concept was implemented to accomplish other PORC function These activities have been and will continue to be reviewed by the NRC staf Based on previous inspections, the SRG activities and their evaluation of plant events continues to be a strength in the TMI-2 or-ganizatio .2 (Closed) Unresolved Item (320/79-19-05): Fire Door Size Tnis item was not intended to be an open item for TMI-2. NRC Inspection Report No. 50-320/79-19 was combined with 50-289/79-17 for TMI-1. An item in this report (289/79-17-01) discussed a problem with fire doors in the control building of TMI- This problem was corrected. Therefore, 320/79-19-05 for TMI-2 is administrative 1y clo:e .3 (Closed) Inspector Follow Item (320/79-BU-18): Audibility Problems for Evacuation of Personnel from High Noise Areas This bulletin described problems with the communication / paging system and the effectiveness of these systems to adequately communicate evacu-ation orders to plant personnel should the need aris In a letter dated August 2, 1982, in response to the bulletin, the licensee noted that they surveyed all plant areas and determined that communication was a problem in two areas, the in-take structure and the 328-foot elevation of the auxiliary buildin The speaker in the in-take structure was repaired and additional speakers and page phones were added to the auxiliary buildin The reactor building (RB) had speu. 1 problems which have been corrected sirce this bulletin was issued. The licensee employed direct two-way con..iunication between individual workers on the defueling platform and the command center. The system was adequate. The inspectors observed

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no problems with communication between the RB and the command cente Tours of the auxiliary / fuel handling buildings revealed no areas (due to hutdown conditions) with excessive noise that would prevent evacu-ation of personnel in an emergency. Overall, licensee actions for this item appeared to be effectiv .4 (Closed) Unresolved Item (320/80-11-07): Resolve Cxceptions/ Deficiencies on a Surveillance Procedure The inspector reviewed the 1>mt completed copies of Surveillance Pro-

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cedure (SP) 3303-A1, Puision 20, "Fire System Valve Cycling." They observed no incomplete Esception and Deficiency (E&D) sheet .5 (Closed) Inspector Follow Item (320/80-BU-?4): Prevention of Damage Due to Water Leakage Inside Containment The licensee responded to NRC Bulletin 80-24 in a letter dated May 26, 1982. The bulletin was evaluated as not specifically applicable to THI-2 due to the present condition of the reactor buildin The licensee pro-vided information in the response which characterized the one example of an "open" cooling water system inside containment. This systen, the Reactor Building Emergency Cooling, was isolated and no longer required by Technical Specifications (TS).

Additionally, the present plant conditions at TMI-2 require that approxi-mately 45,000 gallons of water remain in the RB basement to preclude dryout and release of airborne contaminatio The water level in the pit beneath the reactor vessel (RV) is maintained full of borated water in the event of loss of RV contents (fuel) through a leak in the lower RV hea Due to the above considerations, the licensee response to Bulletin 80-24 is considered adequate and no further action on this item is necessar .6 (C_losed) Violation (3.2_0/81-12-01): Failure to Properly Control Drawings; Violation (320/81-12-02): Failure to Properly Implement Subm.eg ed Demineralizer System [SOSTProc.edures; and, Violation (32L/81-1F04):

Failure to Properly Control SDS Procedures and Instructions These items related to an inspection accomplished after the start-up of the Submerged Demineralizer System (SDS), which was used to filter and clean the contaminated water which remained af ter the accident. Imme-diate corrective actions were taken by the licensee as noted by on going NRC staff presence at TMI-2 during that time and as noted in the licen-see's response to the violations. The SOS was shut down and removed from service. The majority of the equipment will be shipped off site as rad-wast Action to correct these specific problems are no longer c. lic-able to TMI- . .

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3.7 (Closed) Violation (320/81-14-02): Failure to Document Valves / Breaker Positions on "Clearance of Work" This violation concerned the lack of documentation of valve / breaker positions after blue tag removal when work stas completed. Subsequent inspections have not revealed any problems with this documentatio Licensee corrective action was noted to be adequate as evidenced by improvements made at the conclusion of the initial inspection perio .8 (Closed) LER's (320/81-LO-21, 26, 28, 29, 30, and 32): Previous Licensee Event Reports NRC Inspection Report No. 50-320/81-23 documented the inspector's samp-li19 review (in-office) of the below-listed Licensee Event Reports (LER's)

(Nos. 81-21, 26, 28, 29, and 30). As noted in that inspection report, *

the inspector had no residual issues associated with these event How-ever, for reasons unknown, the inspectors, at that time, lef t these par-ticular LER's open on the Region I outr.<nding items listing. Accord-ingly, the inspector again reviewed these LER's for current issue ap-plicab'lity and he concluded no further reviaw was warrante Further, LER No. 81-32 of November 5,1981, concerned the auxiliary building exhaust flow being below required TS limits. The LER was simi-lar to LER Nos. 80-22, 61-21, 81-26, and 81-28. The casual link among these LER's was that TS 3.9.12 was unnecessarily restrictive for the system design. The licensee's updated repart (August 25,1!82) for the LER reflected the NRC staff's approval of revised T5 limits and survu l-lance requirement The inspector considt 4ed these LER's adm.inistratively close Also, a number of inspection reports in 1982 and 1983 lef t ceruin LER's not listed in Region I outstanding items file open pending "in-plant" reviews based on the in-office review. This selection was usually done on a sampling process. No NRC inspection report further documented this effort apparently because of high priority NRC staff work associated with cleanup activitie The inspector re-reviewed these LER's and he con-cluded that no further action was warrante .9 (C_losed) Violation (320/82-01-02): Failure to Establish Adequate Measures to Assure Procedure Revisions After Modification Work This violation concerned a modification made to the main feedwater and condensate systems in the turbine building that affected procedures for recirculating Once-Through Steam Generators (OTSG's). OTSG's are no longer needed for decay heat removal at TMI-2. The inspector reviewed the applicable modification control procedure 4000-ADM-7350.01, Revision 003-00, "iMI-2 Plant Modification Control Program." The inspector was satisfied that adequate procedural controls existed to assure affected procedure updates following modification of plant systems. The NRC staff is not aware of current problems in the area at TMI- . .

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3.10(Closed)UnresolvedItem(320/82-02-03): Licensee to Updato Licensee '

Event Reports During this previous review, the inspector noted that for LER's in 1979, ,

1980, and 1981 the licensee had comitments to resolve certain open issues about the related events; but, there was no docketed update on these actions. As a result of this observation, the licensee conducted a review of these LER's and they submitted letters dated May 19, August 5, and October 31, 1933, and October 12, 1984. These letters updated a number of LER's. However, the inspector observed that the licensee addressed only .,ne of the five LER numbers listed under this unresolved ite Upon further review, the inspector determined that specific updates on

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the listed LER's were unwarranted. For LER 79-012, dealing with inoper-able fire penetration seal material, a number of subsequent LER's updated this issu The remaining LER's dealt with inoperable emergency diesel generator (EDG) events. Although the EDG's were no longer required by current TS, sufficient internal licensee documentation existed to dispose of related open issues. To require updates for these old events would be unwarranted in light of TMI-2's present conditie The inspector then pursued how current LER's would be update Licensee ..

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representatives repceted that if there was an open issue listed in an LER, an action item (administrative tracking system) would be written to assure a revised submittal. The inspector noted updates for two relatively recent LER's (Nos.86-001 an 186-005).

I The inspector concluded that an effectiva system exists at TMI-2 to assure appropriate updating to current LER' .11 (Closed) Unresolved Item (320/82-02-04); Licensee to Clarify Records

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Storage Requirements

This item was listed in the NRC staff open items list as 82-03-04 This item concerneJ the records storage facility at the TMI-2 Administration Building. A concern was generated over electrical cabling used for in-terior lighting that ran through the door which necessitated the door l

being kept open during working hours. This was not in accordance with i ANSI /ASM NQA-1-107 to which the licensee was committed by the Recovery Quality Assurance Pla The inspector observed the area of the licensee's records storage facil-ity in the TMI-2 Administration Building and verified that no power

cables are required to be run through the door during working hour Permanent lighting was installed. The licensee's corrective action for this problem was considered adequate.

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3.12 (Closed) Unresolved Item (320/82-04-04): Licensee Review Malfunction of Reach Rod (Stowe Operator) for MU-V-342A This item concerned the possible malfunction of MU-V-342A due to slippage of the "Stowe" operator or reach rod assembly. MU-V-342A is no longer used. The seal injection system for the reactor coolant pumps (RCP's)

is not required as the Reactor Coolant System (RCS) is depressurize The operability of MU-V-342A is no longer a safety consideration at THI- .13 (Closed) Violation (320/82-04-06): Failure to Properly Correct Under-Drain Filter Bypassing This violation concerned the failure to properly correct the under-drain filter bypass problem in the auxiliary / fuel handling buildings' ventila-tion syste The problem occurred in June 1980 and was corrected as evidenced in the January 8, 1982, unusual event. No releases occurred that bypassed the filters due to improper pl yging of under-drain bypass plugs. Corrective action for this item was considered adequate by the inspecto .14 (Closed) Violation (320/82-04-07): Failure to Retrieve Records This violation concerned the licensee's inability to bcate certain re-quired records. Subsequently, the records were located and reviewed by the inspecto The records were temporarily unavailable due to reloca-tion of the licensee's department in charge of the test record This situation was correcte ,15 (Closed) Inspector Follow Item (320/85-19-02): Toxic Gas Samplinj Through interviews with licensee personnel responsible for preparing radioactive materials for transport, the inspector determined that methylene biphenyl isocyanate (MBI) was not routinely used in the pro-duction of a urethane foam packaging material. Instead of using the urethane foam, inert absorbant was used to stcbilize materials for ship-ment. The licensee's Manager of Industrial Safety and Health informed the inspector that MSI could be used. Airborne sampling will be per-formed to monitor concentrations to wnich workers may be exposed. The inspector had r,o fur *.her questions on this ite Item (32 Garbled Communications 3.16 (Closed)_ Inspector Followat thetform Defueling Shielded Work Pla_0/85-21-02):

The inspector previously noted that garbled communications at the shielded work platform (SWP) detracted from the overall ef ficiency of defueling operations. (The inspection report erroneously identified this item as 320/85-19-02).

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Based on observations of work at the SWP and at the reactor building command center (in the tur'ine o building), the inspector noted excellent communications. The inspector concluded that communications were not an adverse factor in overall efficiency at these work station Licensee corrective actions were apparently effectiv .17 (Closed) Inspector Follow Item (320/87-03-01): Defueling Water Cleanup Sy_ stem Hose Rupture On May 3, 1987, an event occurred in which a three-inch diameter defuel-ing water cleanup system (DWCS) reinforced rubber hose ruptured and sprayed contaminated water on three individual The previous inspection report documented the details of licensee corrective actions, including contamination levels of the affected individuals. The inspector left this item open pending further revie There was no overexposure to the affected individuals based on a review of their contamination level Licensee corrective actions were ap-parently effective, since similar events did not recur at that section of the DWCS. The inspector concluded that further review of the details of this isolated event was not warranted. NRC inspectors have addressed the adequacy of licensee root cause analysis for such events in a recent inspection report (320/88-10-01).

4.0 Exit Meeting The inspector discussed the inspection scope and findings with licensee man-agement at a final interview conducted November 9.1988. Licensee management personnel attending the final e.<it meeting are noted in paragraph The inspection results, as discussed at the meeting, are summarized in the cover page of the inspection repor Licensee rzpresentatives 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, violation, or deviation These items are addressed in Section Inspector Follow Ite_ms are matters which were established to administratively follow open issues based on inspector judgemert or on licensee / staff commit-ment. These are addressed in Section 3.0.