IR 05000320/1989002
| ML20245H860 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/26/1989 |
| From: | Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245H859 | List: |
| References | |
| 50-320-89-02, 50-320-89-2, NUDOCS 8905030551 | |
| Download: ML20245H860 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nc,.
50-320/89-02 I
. Docket No.
50-320
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License No.
OPR-73 Priority
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Category C
Licensee:
GPU Nuclear Corporation, P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island Nuclear Station, Unit 2 Inspection At: Middletown, Pennsylvania Inspection Conducted: January-29 - March 4 and 6, 1989 Inspectors:
T. Moslak, Senior Resident Inspector (Acting)
A. Sidpara, Resident Inspector (Reportirg Inspector)
D. Johnson, Resident Inspector Approved by:
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J6 C. CowgifT, C g, Reactor Projects Section 1A
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l Inspection Summary:
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Areas Inspected: Routine safety inspection by site inspectors of defueling and decontamination activities, including the proper implementation of radiological controls and housekeeping measures, and licensee actions on previous inspection findings.
Results: Licensee personnel conducted defueling activities in a safe controlled manner.
No major problems occurred.
Eight previous inspection findings were closed based on inspector review for current applicability and licensee actions to resolve the issues.
8905030551 890426 PDR ADOCK 05000320
PDC I
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TABLE OF CONTENTS PAGE 1.0 0verview.................................................
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1.1 Licensee Activities...........................
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1.2 NRC Staff Activities.
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I 1.3 Persons Contacted...
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2.0 Defueling/ Decontamination Activities (NIP 71707)....................
2.1 Scope of Review.................................................
2.2 Dropped Resin L1ner...................................
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2.3 General Findings................................................
3.0 Licensee Action on Previous Inspection Findings (NIP 92701/92702)....
3.1 (Closed) Inspector Follow Item (320/84-12-01): Implementation of Activity Classi fication Li st...................
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3.2 (Closed) Unresolved Item (320/84-12-04): Lack of QA Department Review of Liquid Radwaste Procedures..........................
i 3.3 (Closed) Unresolved Item (320/84-19-01): Modification to the P o l a r C ra n e...................................................
3.4 (Closed) Unresolved Item (320/83-10-01): Non-Applicable TMI-2 Site References in the Administrative Procedures..............
3.5 (Closed) Inspector Follow Item (320/84-19-03): Updating Instrument Li sts for Recovery Mode Systems...................
3.6 (Closed) Inspector Follow Item (320/85-13-01): Incorporation of Equipment /Precedures in Requalification Program...............
3.7 (Closed) Violation (320/85-21-01): Failure to Maintain Two Valve Isolation at Sample Sink......................................
3.8 (Closed) Violation (320/83-89-01): Failure to Follow Administrative Procedures for Start-up Testing and Training of On-Site Contractors...
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4.0 Management Meeting.............
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L DETAILS
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1.0 Overview 1.1 Licensee Activities-Following removal of the Incore Guide' Support Plate from the reactor vessel in mid-January, defueling resumed. Using pick and place methods-and air lifting tools, debris was removed from atop and below the Elliptical Flow Distributor (EFD). About 24,000 pounds of debris were removed during this reporting period. Approximately 67,000 pounds
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of material remain in the vessel. After loose debris was cleared I
from the EFD, the plasma arc cutting equipment was reinstalled and
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L cutting of the EFD began.
The current plan called for 103 ct,ts to be made which would result in l
the EFD center section being severed into 25 separate pieces.
In-itially, EFD cutting progress was hampered by problems with the torch manipulating bridge. The bridge was removed from the vessel, cleaned, and then reinstalled and cutting resumed.
Such interrup-tions in the cutting operation were expected to reoccur as a result of debris fines fouling bearing surfaces of the drive system. To
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date, forty-eight cuts have been completed.
Following completion of cutting the EFD into sectiors, the licensee is planning to make 8 vertical cucs in the core baffle plates.
These cuts will facilitate removal of the baffle plate permitting defueling of material relocated to the annular areas outside the core region.
Upon cutting the baffle plates, severed EFD sections will be removed and defueling of the vessel's lower head will resume.
Overall, during this report period, in spite of minor problems as-sociated with the cutting'equioment, the licensee made steady pro-gress in defueling of the reacv.or vessel.
1.2 NRC Staff Activities
.i The purpose of this inspection war to assess licensee activities
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during defueling and decontamination activities. The inspectors made this assessment through actual obser.'ations of licensee activities, interviews with licensee personnel, or review of applicable docu-ments.
NRC staff inspections use the acceptance criteria and guid-
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l ance of NRC Inspection Procedures (NIP's). These NIP's are annotated in the Table of Contents to this report.
The inspectors participated in the licensee follow-up related cri-tiques to the SDS liner incidents (Section 2.2) and concentrated their efforts in the review of licensee's action on previously opened items.
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1.3 Persons Contacted
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During this inspection, the following key licensee personnel provided substantial information in the development of the inspectors' find-ings, j
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- J. Byrne, Manager, TMI-2 Licensing
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W. County, Quality Assurance (QA) Auditor l
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J. Fornicola, Manager, TMI QA I
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- G. Kuehn, Site Operations Director, TMI-2
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- S. Levin, Defueling Operations Director
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- W. Marshall, Manager, Plant Operations
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H. Mumford, Post-Defueling Monitored Storage Manager l
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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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2.0 Defueling/ Decontamination Activities I
2.1 Scope of Revie_w
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The inspector observed and/or reviewed licensee defueling/decontami-nation activit Ns to: (1) ascertain factual stn.;s of such activities ud (2) assure proper adherence to applicable pcacedures.
The in-
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spector also made observations in facility areas with respect to i
proper housekeeping, fire protection, and radiological controls. The general acceptance criteria for this review was Section 6 of the TMI-2 Technical Specifications (TS).
In performing the above inspections, the inspectors focused on the following areas of licensee performance:
control of operations in progress by supervisory personnel;
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knowledge of the task by technicians and support personnel; 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
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witnessed; and, assess the material condition of the plant.
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2.2 Shipping ~of Submerged Demineralized System (SDS) Vessel On February 23, 1989, a spent resin liner, used in the Submerged De-
-mineralized System (SDS), w s' dropped approximately one foot while being placed in a shipping u sk. The incident occurred wF n the
liner was being transferred from its underwater storage location, in the Spent Fuel Pool, to a shipping cask in preparation for shipment offsite to a waste disposal facility. The liner was initially placed in a transfer bell and was being positioned in the snipping cask when
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the liner lodged up inside the transfer bell. This condition was indicated by the crane cable going slack before the landing position was reached.
Loading was stopped and licensee supervision evaluated corrective actions to secure the load. Upon reattaching the hook and manipulating the cable, the liner was. freed and lowering the liner into the cask was continued.
However, when the liner was about one foot above the bottom of the cask the cable parted and the liner dropped to its intended position. The licensee conducted an engi-neering evaluation to determine damage to the liner and the cask as a result of the drop.
This engineering e' valuation concluded that any shock created by the drop was absorbed without causing any damage. The licensee based this conclusion on the facts that the bottom of the shipping cask was lined with a 10 inch thick shock absorbant foam-like material covered with one quarter inch thick plastic and the cask was mounted on a truck bed.
The licensee attributed the load hang-up and subsequent cable failure to the off center movement of the liner into the shipping cask.
Based upon the assessment, the licensee is taking corrective actions to preclude a similar occurrence.
These actions included installa-tion of cable position markers, additional testing of limit switches and upgrading procedures.
The inspector reviewed the licensee's initial response to the inci-dent and follow-up actions. The inspector concluded that the licen-see responded appropriately, with a high regard for industrial and radiological safety. The inspector determined the licensee's cor-
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rective actions and evaluation were adequate and there were no vio-lations of regulatory requirements.
I 2.3 Other General Findings
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As a result of the routine review noted above, the inspectors iden-tified no major discrepancies.
In general, licensee representatives properly implemented procedures.
Defueling activities and cleanup activities were conducted in a sa'+ and controlled manner.
Repair activities required for the plasrr arc torches and reactor vessel cutting equipment were accomplished appropriately.
No unacceptable conditions were identified.
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3.0 Licensee Action on Previous Inspection Findings (NIP 92701/92702)y q
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3.1 (Closed) Inspector Follow Item (320/84-12-01): Implementatierr of3
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Activity,,C_ classification List p
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Following a review of the licensee's procedure 4000-ENG-6313.1,
" Quality Classification List", the inspector noted some weaknesses'in the review process for the items not important to safety (NITS).
Specifically, the NITS items received shorter review and had limited Quality Assurance (QA) requirements even when the NITS items were critical to the TMI-2 recovery actions or provided major radiological projections.
In response, the licensee formed a special group to
. produce a formal', approved activity, classification list, followed by necessary training for plant personnel.
Th inspector determined the licensee actions were adequate and no further follow-up was necessary.
3.2 (Closed) Unresolved Item (320/84-12-04): Lack of QA Department Review of Liquid Radwaste Procedures This item dealt with the QA department not reviewing the site oper-ating procedures in the area of liquid radwaste as required by the approved QA plan. The inspector determined the program was in place to perform the reviews but, lacked defining the frequency of review,
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as well as review of the procedure revisions. The licensee responded by issuing a Procedure Change to the Unit-2 Administrative Procedure (4000-ADM-1218.2).
The PCR addressed all the procedures receiving in-line QA review. The inspector had no further concerns.
3.3 (Closed) Unresolved Item (320/84-19-01): Modification to the Polar Crane This item involved design, manufacture and installation of a band-release mechanism for the main hoist brake system without proper ad-ministrative controls.
The licensee completed all the required cor-rective actions.
Following a review by the Office of Nuclear Reactor Regulation (NRR), the licensee was reauthorized unrestricted use of the crane via the NRC letter of January 9,1985 from Bernard J. Snyder, Program Director, TMI-Program Office to F. R. Standerfer, Vice Presi-dent / Director, TMI-Unit 2.
This item was closed.
3.4 (Closed) Unresolved Item (320/83-10-01): Non-Applicable TMI-2 Site References in the Administrative Procedures During the review of Fire Protection / Prevention Program documents, the inspector noted several documents were not applicable to the i
program referenced in the administrative procedures.
The licensee l
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l concurred in these findings and implemented new procedure 4000-ADM-3680.01, " Fire Protection Program, Organization, Responsibilities and Authorities".
The inspector noted the new procedure had deleted non-applicable references for the TMI-2 site.
3.5 (Closed) Inspector Follow Item (320/84-19-03): Updating Instrument Lists for Recovery Mode Systems During the review of 'he instrument calibration program for the diesel generator, ti.w inspector noted excessive delays in the pro-cedure reviews conducted by the licensee for the systems required for the recovery mode.
In order to perform more timely reviews of the instrument lists, the licensee implemented two procedures 4000-ADM-3600.01, " Instrument List and Safety / Relief Valve List" and 4000-ADM-1218/02, "TMI-II Document Evaluation, Review and Approval".
Following review of these two procedures, the inspector determined the review was adequate and no further follow-up was necessary.
3.6 Glosed)InspectorFollowItem(320/85-13-01): Incorporation of Equipment / Procedures in Requalification Program During the review of the licensee's training program for requalifi-cation of Senior Reactor Operators (SR0s) the inspector questioned the methods used to identify equipment and procedure changes and timely incorporation of these changes into the requalification training program. The licensee advised that administrative procedure 4200-ADM-3000.01, " Implementation of Control Room Required Reading Book", provided necessary guidance and instructions to review all the changes prior to assuming the shift and implement the required ac-tions. Other documents such as Safety Evaluation Reports, Technical Evaluation Reports, System Descriptions and Equipment / system changes were reviewed by the training department which in turn took appro-priate actions such as revision or development of classroom lessons, and distribution of training documents.
The licensee had implemented a formal log book for tracking all the changes, and scheduling special training sessions when warranted due to significant changes, j
The inspector determined the licensee had adequate administrative
controls in place and no further follow-up was necessary.
3.7 (Closed) Violation (320/85-21-01): Failure to Maintain Two Valve Isolation at Sample Sink During the NRC review of Operating Procedure No. 2104-4.132, Revision
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1, " Sampling and Chemical Addition to OTSG A", it was determined fol-
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lowing certain steps of the procedure a potential existed for not meeting the double valve isolation requirement while performing other
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The conflicting steps in the procedure caused a violation of the Technical Specifications, section 6.8.1, which required procedures be established, implemented and maintained covering samples.
The licensee resporse to the violation included
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cancellation of the subject procedure and issuance of.the new proce-dure 4212-0PS-3562.01. The new procedure adequately addressed the double. isolation requirements. The licensee upgraded their training program to review " lessons learned" from this event. The inspector found the licensee response timely and satisfactory.
3.8 (Closed) Violation (320/83-89-01): Failure to Follow Administrative Procedures for Start-up Testing and Training of On-Site Contractors The violation dated February'3,1983 was issued by the NRC Office of Investigation.following an investigation of allegations raised by
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former TMI-2 site operations personnel.
The investigation identi-fied several deficiencies, including: (1) Tests were performed with--
out prior approval by the Test Working Group, (2) the Quality Assur-ance Department did not review administrative policies, procedures and instructions as required by the Recovery Quality Assurance Pro-gram,-(3) The work packages prepared by Bechtel Northern Corp. (BNoC)
to perform modifications to the polar crane were not in accordance with the. Administrative Procedure (AP) 1043, " Work Authorization Pro-cedure", (4) There was no formal training program for BNoC personnel performing an activity important to :afety, (5) Other minor activi-ties where administrative procedures were not followed.
The licensee response dated February 28, 1983 was timely.
The in-spector concluded the corrective actions implemented by the licensee for each of the deficiencies identified were adequate and no addi-tional follow-up was necessary. The violation is closed.
4.0 Management Meeting The inspector discussed the inspection. scope and findings with licensee management periodically during the course of the inspection and at a final meeting conducted March 6, 1989.
Licensee management personnel E. tending the final exit meeting are 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 safeguards information.
Unresolved Items are matters about which information is required in order to ascertain whether they are acceptable, a violation, or a deviation.
These items are addressed in Section 3.0.
Inspector Follow Items are matters which were established to administra-tively follow open issues b4 sed on inspector judgement or on licensee / staff commitment. These are also addressed in Section 3.0.
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