IR 05000320/1988020
| ML20235G976 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/15/1989 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235G974 | List: |
| References | |
| 50-320-88-20, NUDOCS 8902230426 | |
| Download: ML20235G976 (11) | |
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U.S. NUCLEAR REGULATORY' COMMISSION
REGION I
Report No.
50-320/88-20'
Docket No.
50-320 License No.
Priority Category _
C
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Licensee:
GPU Nuclear Corporation P. O. Box 480 Middletown, Pennsylvania 17057
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Facility Name: 'Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania.
Inspection Conducted: December 18, 1989 - January 28 and 31, 1989 Inspectors:
R. Conte,' Senior Resident Inspector
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D. Johnson, Acting Senior Resident Inspector T. Moslak, Resident Inspector A. Sidpara, Resident Inspector (Reporting Inspector)
' Approved by:
M[ E-h/id7 C.Cowsill,C(Jef,ReactorProjectsSection1A Date Inspection Summary:
Areas Inspected: Routine safety inspection by site inspectors of defueling and decontamination activities, including the proper implementation of radiological controls and housekeeping measure::, and licensee actions on previous inspection findings.
Results: The licensee personnel conducted the defueling activities in a safe manner.
No major problems occurred. Ten previous inspection findings were closed based on inspector review for current applicability and licensee actions to resolve the issues.
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8902230426 890216 PDR ADOCK 05000320 Q
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' TABLE OF CONTENTS PAGE-1.0 0verview..............................................................
I 1.1 Licensee Activities.............................................
-1 1.2 NRC Staff Activities............................................
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1.3 Persons' Contacted...............................................
.1-L 2.0 /Defueling/ Decontamination Activities (NIP 71707).....................
2.1 Scope of Review.........~........................................
2.2 Emergency Medical Dri11..........................................
2.3 Ge n e ra l F i n d i n g s................................................
3.0 TMI-2 Clean-Up Program Status Meeting................................
4.0' Licensee Action.on, Previous Inspection Findings (NIP 92701/92702)....
4.1 (Closed) Unresolved Item (320/83-07-02): Air Intake Tunnel (AIT)
Halon System Intentional Deactivation.........................
4.2 (Closed) Unresolved Item (320/83-08-06): Work Under Expired Special Operating Procedures..................................
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'4.3 (Closed) Unresolved Item (320/83-12-01): Method for Control of Lo c k e d Va l v e Li s t.............................................
4.4 (Closed) Inspector Follow Item (320/83-12-03): Control of Safet)
and Non-Safety-Related We1 ding................................
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4.5 (Closed) Deviation (320/83-14-01): Independent Design l
Verification by Supervisory Staff...........-..................
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4.6 (Closed) Inspector Follow Item (320/83-14-02): Informal Transfer j
of Work Between Plant and Site Engineering....................
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4.7. -(Closed) Violation (320/83-19-01): Inadequate Precautions to j
Prevent Overpressurization of Piping Systems..................
j 4.8 (Closed) Bulletin (83-BU-03): Check Valve Failures in Raw Water l
Cooling of Emergency Diesel Generator.........................
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4.9 (Closed) Bulletin (83-BU-07): Fraudulent Products Sold by Ray l
Miller, Inc...................................................
l 4.10 (Closed) Unresolved Item (320/84-09-02): Purging of Containment j
witn One Isolation Valve Inoperable...........................
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5.0 Management Meeting...................................................
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DETAILS i
1.0 Overview 1.1 Licensing Activities Following removal of the grid forging from the reactor vessel, core debris was removed from the next lower plate of the Lower Core Support Assembly (LCSA), the Incore Guide Support Plate (IGSP). Upon clearing l
the debris from the support plate, the two-inch thick IGSP was cut into four quadrants and completely removed from the vessel on January 12, 1989.
With the IGSP out of the vessel, defueling crews are air lifting core debris found on the fifth and final plate, the elliptical flow distri-butor. Once this debris is removed, the flow distributor will be cut using the plasma arc technique.
Removal of the flow distributor will provide access for defueling the approximately thirty tons of debris
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in the lower head of the reactor vessel 1.2 NRC Staff Activities The purpose of this inspection was to assess licensee activities during defueling and decontamination activities. The inspectors made this as-sessment through observations of licensee activities, interviews with
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licensee personnel, and review of applicable documents. NRC staff in-spections use the acceptance criteria and guidance of NRC Inspection Procedures (NIP's).
These NIP's were annotated in the Table of Contents
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to this raport.
The inspectors reviewed licensee's procedures implementing control on several interfacing systems with the reactor vessel to assure adequate controls were in place to prevent uncontrolled boron dilution. The in-spectors also reviewed the instrument calibration switching and tagging of valves, approval authority, and responsibilities of the operations personnel.
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1.3 Persons Contacted During this inspection, the following key licensee personnel provided substantial information in the development of the inspectors' findings.
J. Byrne, Manager, TMI-2 Licensing
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W. County, Quality Assurance (QA) Auditor
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G. Kuehn, Site Operations Director, TMI-2
- S. Levin, Director, Defueling
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- W. Marshall, Manager, Plant Operations H. Mumford, Post-Defueling Monitored Storage Manager
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M. Roche, Director, TMI-2
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- R. Rogan, Director, Licensing & Nuclear Safety, TMI-2
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- E. Schrull, TMI-2 Licensing Engineer
- D. Turner, Director, Radiological Controls
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R. Wells, Licensing Engineer
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- Attended the final management meeting.
2.0 Defueling/ Decontamination Activities
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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-terid 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; knowledge of the task by technicians and support persons;
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appropriateness of governing documents, including procedures and
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Radiation Work Permits (RWP's);
alertness of various controlling station personnel;
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assess the quality of implementation of. selected evolutions wit-nessed; and, assess the material condition of the plant.
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2.2 Emergency Medical Orill On December 15, 1988, the annual emergency medical drill was held. An NRC regional emergency preparedness specialist observed the drill.
The drill scenario involved an individual performing oxy-acetylene' cutting in the turbine building in a temporary Radiation Work Permit (RWP) area.
According to the drill, the torch malfunctioned and exploded in the wor-ker's face. The worker hypothetically suffered a lacerated neck and facial burns and was supposed to be contaminated. The severity of the hypothetical injury required off-site medical assistance and transport to an off-site medical center.
Areas where the licensee performed satisfactorily included:
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medical technicians treated the patient quickly;
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an unusual event was declared and notifications were completed in
'y a timely manner; the off-site ambulance crew arrived very quickly and were at the
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scene within minutes of arriving on site;
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security control was evident at both the accident scene and the
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hospital;
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contamination control techniques were ad quate; and,
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posting of radiation area was evident at the hospital.
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Areas where improvements can be made included:
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interface between radiation control technicians and medical tech-
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nicians;
timely identification of injured person; and,
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improved preparation for the drill; the " injured" person did not have any protective clothing (PC) and, thus, the removal of the contaminated PC's was not performed.
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In summary, licensee performance was adequate to protect the health and safety of the public.
Licensee action on previously-identified weak-nesses was also adequate.
2.3 Other General Findings As a result of the routine review noted above, the inspectors identified no major discrepancies.
In general, licensee representatives properly implernented procedures.
Defueling activities and clean-up activities were conducted in a safe and controlled manner.
Repair activities re-quired for the plasma arc torches and reactor vessel cutting equipment were accomplished appropriately. There were no specific events or in-cidents that the NRC staff reviewed during this inspection period.
No unacceptable conditions were identified.
3.0 TMI-2 Clean-Up Program Status Meeting 3.1 Overview i
l The NRC staff met with the licensee staff in the Region I office on January 11, 1989, to discuss the status of on going defueling and decon-tamination activities conducted at Unit 2.
Senior site management pre-
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sented information on the topics of schedule, budget, defueling status, defueling completion reports, water disposal status, Special Nuclear
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' Material Measurement (SNMM) program, radiological conditions, and pro-posed criteria for eventually entering Post-Defueling Monitored Status
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(PDMS).
l Information sheets provided by the licensee are in Attachment I to this-report.
NRC and licensee staff attending this meeting are listed in Attachment 2.
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3.2 Decontamination Efforts
The licensee is concentrating its resources to complete defueling of the reactor vessel and primary system by the summer of 1989.
To achieve this I
goal, efforts.to decontaminate the auxiliary and fuel handling buildings are being deferred until defueling is accomplished. This shift in em-phasis from performing defueling and decontamination efforts in parallel to completing these activities one after the other is intended to mini-mize the need to repeat decontamination and to better utilize the avail-able resources.
3.3 Exposure Status The licensee has met or exceeded'short-term and collective goals for controlling radiation exposure to personnel throughout the decontamina-tion and defueling effort.
Total worker exposure from March 28, 1979 through December 31, 1988, was 5,541 person-rem.
It is currently esti-mated that a cumulative total of approximately 6,000 person-rem will be expended for the entire clean-up.
During 1988, total person-rem expended'
was.approximately 12 percent of the estimated exposure of 994 person-rem.
The licensee attributed these exposure results to proper ALARA (as low as reasonably achievable) planning. The NRC staff considered that the programmatic exposure control efforts to be effective.
3.4 Data Management The NRC staff was briefed on the licensee's program to measure and docu-ment the residual fuel that may remain in plant systems following com-pletion of clean-up activities. The various measurement techniques used to quantify the SNM were discussed.
Post-Defueling Survey Records and the Defueling Completion Reports will be the measurement documentation that provide the basis for the licensee's final SNM (fuel) accountability.
3.5 Meeting Summary The licensee provided detailed information on the progress of clean-up activities.
It was agreed that future meetings of this nature would be useful for assessing the overall status of TMI-2.
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4.0 L Licensee Action on Previous Inspection Findings
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4.1 (Closed) Unresolved Item (320/83-07-02): Air Intake Tunn'el (AIT) Halon System Intentional Deactivation
The licensee, on several occasions, intentionally deactivated the'AIT Lj l.
to prevent inadvertent-actuation by lightning. The objective behind the j
deactivation was based on the assessment that' reactivation-of the AIT-
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following a thunderstorm would take significantly.less time than recharg-ing system following a spurious discharge. This mode of the operation placed the plant in the Action Statement of the Technical Specification-
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(TS) Section 3.7.10.3, which required restoration of the system to oper-able status within fourteen days.
The. licensee also prepared the re-quired Licensee Event Reports (LER's).
The' inspector,'following review of the LER's, determined that the corrective actions requiring immediate restoration of the AIT system to operable status and installation of louvers to protect the AIT system detectors from exposure to the. light-ning were adequate. This item is closed.
4.2 (Closed) Unresolved Item (320/83-08-06): Work Under Expired Special Operating Procedures This item involved operation of the two containment isolation valves DSA-V-004 and DSA-V-005 under expired Special Operating Procedure (SOP).
Operation of these valves without a valid procedure violated TS Section 3.6.1 requirements and was reportable pursuant to TS 6.9.1.8(b)..
The licensee issued a LER, which was later updated. The licensee addition-
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ally identified a total of sixteen such violations and determined the i
root cause to be the failure of operations personnel to include these
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valves in the SOP, as well as failure to follow the administrative pro-cedure governing validation of SOP's.
The NRC review of the LER indi-cated the immediate corrective action of discontinuing operation of these.
valves until a new S0P was issued and the long-term corrective action to counsel operations personnel emphasizing performance of activities in accordance with approved procedures were adequate. No further actions were required. This item is closed.
Ha 4.3 (Closed) Unresolved Item (320/83-12-01): Method for Control of Locked Valve List The inspector identified some weaknesses in the area of control of locked valves, including authority to initiate changes and assignment of valves to the systems as well as maintenance of log sheets.
In response, the licensee revised Administrative Procedure (AP) 4210-ADM-3020.05, " Con-trolled Key Locker." This procedure addressed inventory of keys for
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important-to-safety facilities; system interlocks and locked valves; and, responsibilities, authorities, and maintenance of required logs. The
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inspector, following review of this procedure, determined that the pro-
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cedure was adequate and there was no need for further actions. This item is closed.
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4.4.(Closed) Inspector Follow Item (320/83-12-03): Control of Safety and
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Non-Safety-Related Welding-The inspector identified a concern that the licensee's Administrative
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Procedure (AP) 1063, Revision 1, " Control of Welding,'! did not require site welding engineering personnel to review welding qualification:docu-mentation for safety and non-safety-related equipment. This problem was.
. corrected by' revising the procedure incorporating.the requirement. The-inspector also had concerns about the interpretations of Weld Procedure-Specification (WPS) and Procedure Qualification Report (PQR) documenta-tions, specifically regarding the qualified-thickness ranges for American-
Society of Mechanical Engineers (ASME) and American Welding Society (AWS)
welding specifications. The licensee stated that the welding program
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required all WPS's to be qualified in accordance with Section IX of the.
ASME Code..NRC review of licensee documents indicated satisfactory re -
sponse to the concerns.
This item is closed.
4.5 (Closed) Deviation (320/83-14-01): Independent Design Verification by Supervisors This issue dealt with an administrative weakness in the area of super-visors performing independent design verification where the design was
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performed by subordinate engineers.
In response, the licensee revised procedure 4000-ENG-7310.3, " Engineered Document Verifici, tion Procedure." -
The inspector determined that the licensee's revised procedure was ade-quate. This item is closed.
4.6 (Closed) Inspector' Follow-Up (320/83-14-02): Informal Transfer of Work-Between Plant and Site Engineering This item involved an administrative weakness concerning informal trans-fer of work between plant engineering and site engineering even though.
both groups had good communication and the. informality did not result-in any problem.
The licensee, in order to strengthen the current engi-neering controls, revised AP 4000-ADM-7350.02, " Engineering Service Re-quest," to add formal instructions.
Following review of this procedure, the inspector determined the corrective actions to be adequate. This item is closed.
4.7 (Closed) Violation (320/83-19-01): Inadequate Precautions to Prevent-Overpressurization of Piping System i
The violation occurred during flushing of the discharge line between the i
concentrated waste storage tank (CWST) and the associated liquid waste i
pump. The flushing pressure of 56 psig exceeded the bursting pressure limit of the rupture disc in the line.
The root cause was determined to be the failure to provide appropriate precautions or limits in the Unit Work Instruction (UWI) 4220-3233-83-0768. The licensee's corrective actions included review of the incident with the appropriate personnel, as well as combining of two Maintenance Procedures (MP's) 1410-Y-17, l
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" Cleaning of Clogged Lines," and 1430-Y-24, " Clearing Instrument Lines of Moisture, Blockage, or Lowering Radioactive Levels," into a single new procedure 4220-CMG-3921.03, " Clearing All Lines of Moisture, Blockage, or Lowering Radioactivity." Th2 inspector, following review of this procedure determined that it included necessary precautions and instruc-tion to establish maximum allowable pressure for flushing. The licensee response was adequate. This violation is closed.
4.8 (Closed) Bulletin (83-BU-03): Check Valve Failures in Raw Water Cooling of Emergency Diesel Generators This bulletin dealt with the failures of check valves in the raw water cooling system of diesel generators at the Dresden and Quad-Cities nuc-lear plants, as well as other related events.
In response to this bul-letin, the licensee reviewed the existing testing and surveillance pro-gram for similar valves and addressed all the concerns _ identified in the bulletin. Additionally, the licensee tested the affected valves to verify operability and did not identify any problem. The licensee re-
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sponse was timely and adequate. The inspector also noted that the two emergency.diese'l generators at Unit-2 were not required by the current TS. This bulletins requirements were satisfied and it was closed.
4.9 (Closed) Bulletin (83-BU-07): Fraudulent Products Sold by Ray Miller, Inc.
The bulletin provided a comprehensive. list of customers who had apparently received fraudulent products from Ray Miller, Inc. for the years 1975 through 1979. The licensee reviewed the list and identified one customer who supplied some materials that were originally received from Ray Miller, Inc. However, the 1_icensee determined that the material was not part of any safety-related system and it did not have any safety significance.
The licensee also provided information on the procured items directly
.from Ray Miller, Inc. beyond the ' period specified in the bulletin. The licensee's assessment on e_ach such item did not present any problem.
The inspector reviewed the licensee response and determined that it was adequate and no further actions were required. This bulletin was closed.
i 4.10 (Closed) Unresolved Item (320/84-09-02): ' Purging of Containment with One Isolation Valve Inoperable Based upon the review of operations logs, the NRC inspector discovered that the licensee purged the containment using train "A" even though the isolation valve AH-V-4A was inoperable.
This action did not comply with TS Section 3.6.1.1, which required that for each containment penetration, two isolation valves be maintained operable and closed unless allowed open pursuant to an approved procedure.
It also required that with one valve open or inoperable the second isolation valve should be deactivated and secured in the isolation position.
In this event, valve AH-V-4A (outside of containment) failed to close following a surveillance test; however, the purging of containment continued. This event was reportable pursuant to 10 CFR 50.73(a)(2)(i)(B) and, therefore, the licensee issued
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Licensec Event Report (LER) 84-07.
Review of the LER indicated that the event was caused by misinterpretation of TS requirements.
The corrective action involved deactivation of the isolation valve AH-V-3A (inside con-tainment) as required by the TS, as'well as review of the incident with operations personnel. The inspector did not have any further concern and determined that the' licensee actions were adequate.
5.0 Management Meeting The inspector discussed the inspection scope and findings with licensee man-agement periodically during the roerse of the inspection and at a final meet-ing conducted January 31, 1989.
. Lensee management personnel attending the final exit meeting is noted in paragraph 1.3.
The inspection results, as discussed at the meeting, are summarized in the cover page of the inspection report.
Licensee representatives indicated that-none of the subjects discussed contained proprietary or safeguarcis information.
Unresolved Items are matters about which information is required in order to ascertain whether they are acceptable, violations, or deviations.
These items'
are addressed in Section 4.0.
Inspector Follow Items are matters which were established to administrative 1y follow open issued based on inspector judgement or on licensee / staff commit-ment.
These are addressed in Section 4.0.
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