ML19308A721

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IE Insp Repts 50-289/79-18 & 50-320/79-22.Noncompliance Noted:Uncontrolled High Radiation Areas,Failure to Use Breathing Air Sys Properly & Improper Calibr of Equipment Used to Measure Airborne Concentrations
ML19308A721
Person / Time
Site: Crane  
Issue date: 09/18/1979
From: Crocker H, Haverkamp D, Neely D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19308A720 List:
References
50-289-79-18, 50-320-79-22, NUDOCS 7912040179
Download: ML19308A721 (38)


See also: IR 05000289/1979018

Text

U.S. NUCLEAR REGULATORY COMMISSION

0FFICE OF INSPECTION AND ENFORCEMENT

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td

Region I

50-289/79-18

Report No.50-320/79-22

50-289

Docket No. 50-320

DPR-50

License No. DPR-73

Priority

Category

C

---

Licensee: Metropolitan Edison Company

P.O. Box 542

Reading, Pennsylvnia 19640

Facility Name: Three Mile Island Nuclear Station, Unit 2

Inspection at: Middletown, Pennsylvania

Inspection conducted:

July 18 - August 14, 1979

Inspectors: Obb

3 ~

Sf pb9

D. R. Haverkamp, Lead Reactor Operations

date signed

Inspector

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bv

S)d M

D. R. Neely, Lead Radi& tion Specialist

date signed

>

date signed

Approved by:

CA-A -

9 / /f / d

'H. W. Crocker, Drief, IE Resident

66te sfigned

Office - TMI 2

Inspection Summary:

Inspection on July 18 - August 14, 1979 (Report Nos. 50-289/79-18 and

50-320/79-22)

Areas Inspected:

Special inspection by IE Resident Office Staff and

shift inspectors of:

licensee action on previous inspection findings; Unit 2

new and revised procedures; Unit 2 plant operations including records, per-

formance of tests, and general plant tours; in-plant health physics including

documentation, posting and labeling reviews, witnessing of (Unit 1 and 2)

activities, and area tours; and preoperational status of EPICOR II System. The

inspection included continuous shift coverage by both reactor operations

and radiation specialist inspectors.

Results:

Significant findings were brought to the attention of the

licensee management when identified.

7912040f

_

9

.

DETAILS

1.

Persons Contacted

Principal licensee and contractor personnel contacted during this

inspection are identified in the exit interview section of this

report.

2.

IE Inspection Participants

The following tabulation identifies the TMI-2 Resident Office

professional personnel participating in this inspection.

a.

Resident Office Staff

R. Conte, Reactor Operations Inspector, IE:RI, July 18 -

August 14, 1979

H. Crocker, Chief, IE Resident Office, IE:RI, July 30 -

'

August 14, 1979

P. Graham, Reactor Operations Inspector, IE:RI, August 6 -

August 14, 1979

D. Haverkamp, Lead Reactor Operations Inspector, IE:RI, July

18 - August 7,1979

J. Kinneman, Radiation Specialist, IE:RI, July 19, 31,

August 1-3, 1979

H. Kister, Chief, IE Resident Office, IE:RI, July 18 - July

31, 1979

R. Knoll, Reactor Operations Inspector Co-op, IE:RI, August

<

3 - August 14, 1979

D. Neely, Lead Radiation Specialist, IE:RI, July 18 - August

3, August 13-14, 1979

W. Raymond, Reactor Operations Inspector, IE:RI, July 18 -

August 14, 1979

J. Serabian, Radiation Specialist, IE:RI, July 18 - August 8,

August 14, 1979

'

C. Sweinhart, Reactor Operations inspector Co-op, IE:RI, July

18 - August 3,1979

J. White, Lead Radiation Specialist, IE:RI, August 6 - August

10, 1979

,

b.

Shift Reactor Operations Inspectors

J. Ashendon, IE:RII, August 7 - August 14, 1979

C. Brown, IE:RIII, July 18 - July 30, 1979

J. Carlson, IE:RV, July 18 - July 24, 1979

C. Chow, IE:RIII, July 31 - August 14, 1979

T. Daniels, IE:RIII, July 18 - July 30, 1979

R. Masse, IE:RIII, August 13 - August 14, 1979

J. Mcdonald, IE:RII, July 25 - August 8,1979

D. Price, IE:RII, August 8 - August 14, 1979

R. Smith, IE:RIV, August 7 - August 14, 1979

A. Wagner, IE:RII, July 18 - July 25, 1979

T. Young, IE:RV, July 24 - August 7,1979

'

.

2

c.

Shift Radiation Specialists

J. Everett, IE:RIV, July 18 - July 23,1979

J. Ewald. IE:RII. July 18 - July 27, 1979

R. Fish, IE:RV, August 7 - August 13, 1979

J. Hiatt, IE:RII, August 7 - August 14, 1979

'

L. Hueter, IE:RIII, July 26 - August 6, 1979

W. Millsap, IE:RII, August 6 - August 14, 1979

D. Miller, IE:RIII, July 18 - July 25, 1979

B. Murray, IE:RIV, July 24 - 30, August 2 - 6, 1979

T. Troup, IE:RII, July 18 - July 27, 1979

J. Wray, IE:RII, July 27 - August 6, 1979

L. Wilborn, IE:RIV, August 6 - August 14, 1979

R. Zavadoski, IE:RII, July 27 - August 7, 1979

3.

Licensee Action on Previous Inspection Findings

(0 pen) Inspecton Finding (320/79-13-01):

Qualification of Licensee

Contractor Health Physics (H.P.) Personnel.

The licensee has

submitted a draft Radiation Protection Plan that contains specific

requirements in the area of H.P. personnel qualifications.

Pending

review and final approval of the plan this item will remain open.

(0 pen) Inspection Finding (320/79-13-02):

High Radiation Area,

Posting, Barricading and Access Control.

Inspector tours of

licensee controlled areas identified six High Radiation Areas

either not posted, barricaded or controlled (i.e. locked or manned).

(Details paragraph 6.b).

(0 pen)

Inspection Finding (320/79-13-03):

Dosimetry QA Irregularities.

In-depth inspector review identified areas remaining to be addressed

and corrected by the licensee.

(0 pen) Inspection Finoing (320/79-13-04):

Failure to perform job

specific airborne radioactivity evaluations. A technical meeting

was held on July 26, 1979, with resident staff in attendance, in

which the above inspection finding was discussed.

Based on the

above and other meetings, the licensee, in a letter dated August 6,

1979 has comitted to the review and revision of those procedures

defining the airborne radioactivity sampling program implemented to

meet the requirements of 10 CFR 20.201 (b).

Pending review of

procedural changes and field observation of implementation, this

item will remain open.

(0 pen) Inspection Finding (320/79-17-09):

Posting and Labeling of

Radioactive Waste. Additional inspector review identified a non-

posted Radioactive Materials storage area (Details, paragraph 6.a

(2)).

'

.

3

(0 pen) Inspection Finding (320/79-17-20):

Curie Level Determination

of Radioactive packages for shipment.

Inspector review of revised

curie / rem conversion factors indicated possible underostimation of

total activity.

(Details, paragraph 6.a (1)).

4.

Facility Procedure Review

Operating Procedures (0P), Emergency Procedures (EP), and Special

Operating Procedures (SOP), including subsequent evisions, were

reviewed by the Resident Office during this inspection. The S0P's

are temporary procedures written for the TMI-2 Recovery Program

which govern special evolutions and/or use of off-normal plant

systems and these are de.mignated "Z" or "R" procedure depending on

date of generation.

Procedure review included both Health Physics and Operations aspects

with consideration of the following: (1) the procedure, when

implemented, would not degrade the containment of radioactive

material, jeopardize core cooling, or result in excessive personnel

exposure; (2) the procedure conforms to the general criteria of TS 6.8, " Procedures", TS 6.11, Radiation Protection Program, ANSI

18.7Property "ANSI code" (as page type) with input value "ANSI</br></br>18.7" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., 1976; (3) the technical content of the procedure is adequate

to perform the intended evolution.

Procedures reviewed during this report period are listed below

together with dates (in parenthesis) on which IE comments were

completed.

2104-5.16, Chemical Cleaning Building Ventilation System, Revision

--

0, (July 18, 1979)

--

R-2-79-025, U-2 R. B. Atomsphere Gas Sampling Using HP-R-227,

Revision 1, (July 18, 1979)

  • Design Criteria for WG-19-Temporary Sampling System, Revision 0,

--

(July 19, 1979)

Operating Procedure for CNSI Electro-Con Unit, (July 10,1979)

--

Radiological Controls Procedure for CNSI Electro-Con Unit

--

Operation,(July 20,1979)

--

CG-A.1 to CG-A.6, Capgun Alarm Responses, Revision 0, (August

3,1979)

--

OP 2104-4.9 EPICORE Prefilter and Demineralizer Changeout,

Revision 0, (July 27, 1979)

--

Transfer of WDL-T-2 (MWHT) to WDL-T-8A/B Primary

Neutralizer Tank, Revision 0, (July 18, 1979)

Containment Assessment Program - Procedure to Obtain Air

--

Sample and Preliminary Dose Map of Air Lock No. 2,

(July 25, 1979)

<

.

4

2203-4.1 Loss of Demineralized Water for EPICOR-2 (July 20,

--

1979)

PCG-A.1 to .3 - Alarm Response (EPICOR II) Prefilter and

--

Demineralizers(August 3,1979)

Long Term B System Alarm Responses (July 20,1979)

--

Operation of SPC-P-3 in Recirculation Mode (July 20,1979)

--

--

OP 2203-1.9 Standby Pressure Control System on Rising RCS

Pressure (July 20,1979)

Fill Procedure for Steam Generator "B" with Water (July 20,

--

1979)

Long Term OTSG B Cooldown System Operating Procedure (July 20,

--

1979)

Condensat? Polisher Resin Removal (July 20,1979)

--

--

Containment Assessment Program - Procedure to Measure CB

Radiation Using Penetration R-626 (July 25,1979)

Filling BAMT with Boric Acid /and with Caustic Soda (July 30,

--

1979)

Z-51 Liquid Releases from Three Mile Island, Revision 4, (July

--

26,1979)

  • TMI-2 Permanent Sample System Draft Criteria (August 1,1979)

--

  • EvaporatorProject(July 23,1979)

--

Radiological Controls for B&W Counting Area, Revision 0, (July

--

25,1979)

Unit 2 Auxiliary and Fuel Handling Building Ventilation Flow &

--

Mixing Measurement, Revision 0, (July 26, 1979)

EP 2202-4.4 Fire in Auxiliary Building Liquid Process System

--

(EPICOR II), Revision 0, (July 27,1979)

R-2-79-40 Radiation Controls B&W Chemical Trailer - CAPGUN B

--

Counting, Revision 1 (July 25, 1979)

Operating Procedure for CNSI ELECTR0-CON Unit, aevision 0,

--

(July 25,1979)

Radiation Controls for CNSI ELECTR0-GUN Operations, Revision 0

--

(July 25, 1979)

Processing Tank Truck Water Through " Cap-Gun"/ System (July 25,

--

1979)

'

t

5

Depressurization of th JH System on the DH pump side of

--

DH-V3, DH-V4, V-4B (July 30, 1979)

Moving Laundry and Respiratory Equipment to a Cleaning Facility

--

Outside the Plants Protective Area, Revision 0, (July 27,

1979)

1618.A Shipment of Radioactive Material and TCN to 1618,

--

Radioactive Material Shipping (July 31,1979)

2104-4.12 EPICOR II Sampler Operations, Revision 0, (August 2,

--

1979)

2107-l.5 Balance of Plant (BOP) DG-B (White) Diesels and

'

--

Auxiliaries, Revision 0, (August 1, 1979)

,

2107-1.6 Balance of Plant (B0P) DG-A (Gray) Diesels and

--

Auxiliaries, Revision 0, (August 1,1979)

OP 2104-4.11 Crud Filter Change-Out ALC-F-5, Revision 0, (July-

--

27,1979)

Transfer of Radioactive Resin Liners from EPICOR I to Onsite

>

--

Staging Area, Revision 0, (July 31, 1979)

3104-4.4 Transfer U2 MWHT to Ul RCBT, Revision 0, (August 1,

--

1979)

--

Moving Laundry and Respiratory Equipment to Cleaning Facility

Outside Protected Area, Revision 0 (July 30, 1979)

R-2-79-35 Testing the SPC System, Revision 2, (July 31, 1979)

--

Recovery Operation Reactor Building Remote Access (July 31,

--

1979)

Reactor Building Water Sampling (August 3, 1979)

--

Unit 2 Auxiliary and Fuel Building Ventilation Flow and Mixing

--

Measurements (July 31,1979)

3104/4.4 Transfer from U-2 MWHT Te Unit 1 RCBT (August 1,

--

1979)

Moving Laundry and Respiratory Equipment to a Cleaning Facility

--

Outside the Plant's Protective Area (July 31,1979)

Hydro Lansing of Unit I Sump (Auxiliary Building) (August 1,

--

1979)

  • Evaluation Program - Post Decontamination Leaching Program

--

(August 3,1979)

6

-

.

2204-302B Radwaste - Gas and Solid, Revision 3, (August 3,

--

1979)

2104-4.50 Fuel Pool Waste Storage System, Revision 1, (August

--

2,1979)

2104-4.2 Waste Gas Disposal System (Including TCN), Revision

--

2,(August 3,1979)

Operation of Supplemental Fans and Filters (Auxiliary Building

--

Roof) (August 10,1979)

Loss of Service Air for EPICOR II (August 2,1979)

--

Filling BAMT with Boric Acid and Caustic Solution,. Revision 0,

--

(August 3,1979)

Helium Leak Testing of Waste Gas System, Revision 0, (August

--

3,1979)

Respirator Facemask Cleaning and Testing Facility, Revision 0,

--

(August 3,1979)

--

  • Design Criteria Environmental Barrier Wall (August 13, 1979)
  • Criteria Document and Scope Document for the Mini Decay Heat

--

,

Removal System (August 15,1979)

'

--

EP (Draft) EPICOR I/II Transporter Vehicle Accident During

DemineralizerTransfer(August 14,1979)

Transfer Out of Spec Water from Unit II WDC-T-9A/B to EPICOR

--

CC-T-1 (August 14, 1979)

--

2104-4.7 Operation of Axiliary Building Emergency Liquid

Cleanup System, Revision 0 (August 14,1979)

CG-A.2,

.3, .5 GAPCUN Alarm Responses (August 10,1979)

--

PCG-A.1 to .3 Alarm Responses (EPICOR II) Prefilter and

--

Demineralizers (August 10,1979)

--

Discharge of WDG-T-1A(B) to Reactor Building, Revision 0,

(August 10,1979)

1618 B Receipt of Radioactive Materials, Revision 0, (August

--

14,1979)

2104-4.11 Change Out of Crud Filter (ALC-F5) Cartridge,

--

Revision 0 (August 14,1979)

3104-4.4 Transfer from Unit 2 MWHT to Unit 1 RC Bleed Trank,

--

Revision 0(August 10, 1979)

--

  • TMI-2 Criteria for Loss of 0FF-SITE BOP Electrical Power

(August 14, 1979)

.

.

7

Z-39 Natural Circulation Operation, Revision 2 (August 14,

--

1979)

Transfer of WDL-T-10 (Unit I) to WDL-T-2 (Unit II), Revision 0

--

(August 14,1979)

1618-C Radioactive Material Handling, Revision 0 (August 15,

--

1979)

,

CNSI/VIREM DC-3 Support Procedure for Solidification of Radiac

--

Wash Waste Stored in U-2 Auxiliary Building, Revision 0

(August 15, 1979)

  • Temporary Sampling System, Revision 0 (August 15, 1979)

!

--

  • These are design criteria also submitted by the licensee and

.

'

reviewed for technical adequacy.

Composite NRC connents on procedures were forwarded to the licensee by

Office of Nuclear Reactor Regulation (NRR).

No instances of failure to

resolve NRC comments were identified.

5.

Review of Plant Operations

a.

Test Perfonnance/ Procedure Implementation.

The following tests / procedure implementations were witnessed.

R-2-79-42 Fuel Pool Waste Storage System, Revision 0

--

(July 18,1979), on July 29, 1979

--

R-2-79-52 Depressurization and Draining of Decay Heat

System on DH Pump Side of DH-V3, V4A, V4B, Revision 0

(July 27, 1979), on July 29, 1979 to August 14, 1979

l

OP 2104-4.13 Transfer of Radwaste Resin Liners, Revision

--

0, (July 31, 1979), on August 1, 1979

SOP No. R-2-79-56 Reactor Building Remote Access, Revision

--

0 (July 31,1979), on August 6, 1979 to August 14, 1979

R-2-79-15 Balance of Plant Diesel Generator (Grey) and

--

Auxiliaries Operating Procedure, Revision 0 (August 9,

1979), on August 9,1979

2303-M16D Emergency Diesel Generator and Cooling Water

--

Valve Operability Test (B Diesel), Revision 9 (March 26,

1979),onAugust9,1979

R-2-79-52 Drain of DH-V3 Header, Revision 0 (July 16,

--

1979), on August 12, 1979

.;

-

- - - - .

- -

.

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8

R-2-79-14 Balance of Plant Diesel (White) and Auxiliaries

'

--

Operating Procedure, Revision 0 (August 15,1979), on

August 11, 1979

Z-2 Discharge of WDG-T-1B to Reactor Building, Revision 2

--

(April 6,1979), on August 12, 1979

R-2-79-44 SPC-P-3 in Recirculation Mode, Revision 0 (July

--

20,1979), on August 12-14, 1979

2107-1.6 Balance of Plant Diesel (Grey) and Auxiliaries

--

Operating Procedure, Revision 0 (August 15,1979), on

August 17, 1979

2303-M16C Emergency Diesel Generator and Cooling Water

--

Valve Operability Test (A Diesel), Revision 9 (March 26,

,

1979), on August 20, 1979

/

b.

Plant Tours

,

During the period July 18, 1979 through August 14, 1979, tours

of the following areas were conducted (number of tours are

indicated in parenthesis).

Cleanliness / Housekeeping conditions

were observed along with Radiological and Fire Protection

Measures.

In addition, for the specific areas listed, construction

status and testing progress were noted.

--

General Plant Area including outside and inside of the

protected area (4).

Fuel Handling Building accessible areas on elevation 305'

--

(11) and elevation 348' (11).

--

Chemical Cleaning Building including the Auxiliary

Building Emergency Liquid Cleanup System (EPICOR II)

(32).

Turbine Building, accessible areas on elevation 281'

--

(40), elevation 305 (49), and elevation 331' (47).

--

Diesel Generator Building accessible areas on elevation

305' (13) and elevation 280' (5).

Balance-of-Plant Diesel Generators Trailers & Fuel

--

Storage Area (5).

Control Building accessible areas on elevation 280' (40),

--

elevation 305' (32) and elevation 331', including the

Control Room (33).

Auxiliary Building control point on elevation 305' (26).

--

.

.

9

c.

Logs and Records

CR0 Log for period of July 24, 1979 through July 25, 1979, on

July 25, 1979.

Shift Foreman Log for period of July 24, 1979 through July 25,

1979, on July 25, 1979.

Locked Valve list on July 26, 1979.

CR0 Log for period of July 25, 1979 through July 26,1979, on

July 26, 1979.

Shift Foreman Log for period of July 25, 1979 through July 26,

1979, on July 26, 1979.

CR0 Log of July 26, 1979 on July 27, 1979.

Shift / Foreman Log of July 26, 1979, on July 27, 1979.

CR0 Log of July 28, 1979 on July 28, 1979.

Leak Rate Chart for period of July 26, 1979 through July 28,

1979, on July 28, 1979.

d.

Findings

The following Significant Inspection Findings were identified

during this review and details are appended to this report.

Inadequate Administrative Controls for Recovery Special

--

Operating Procedures (R-SOP) (Significant Inspection

Finding No. 79-22-01).

Adequacy of Fire Protection in Diesel Building (CLASS IE)

--

and Cable Spreading Room (Significant Inspection Finding

No. 79-22-02).

Adequacy of Operational Preparedness for Balance of Plant

--

(B0P) Diesels (Significant Inpsection Finding No. 79-22-03).

6.

In-Plant Health Physics

a.

Solid Radioactive Waste

The shipping, storage, handling and analysis of solid radio-

active waste was reviewed for compliance with the following:

10 CFR 20, " Standards for Protection Against Radiation".

--

10 CFR 71, " Packaging of Radioactive Material for Transport

--

and Transportation of Radioactive Material Under Certain

Conditions".

I

.

.

10

Station Health Physics Procedure 1620 Revision 4,

--

" Radiological Controls for Processing Radioactive Solid

Waste", dated February 9, 1979.

Special Operating Procedure, S0P No. R-2-79-6, Revision

--

1, "On-Site Solid Waste Storage for TMI-2", dated May 8,

1979.

Station Health Physics Procedure 1618, Revision 6,

--

" Shipment of Radioactive Material, D0T Regulations",

dated March 6, 19/9.

The review included:

documentation; truck placarding; isotopic

determination review; storage area review; and the performance

of independent radiation intensity measurements.

(1) Shipment

The following radioactive waste shirnents were reviewed:

Shipment No.

Date

Item

Total (mci)

79-75

7/18/79

U-l Trash

109.772

148 drums

79-76

7/18/79

Filter

0.006

79-77

7/18/79

Laundry

5.97

79 drums

79-78

7/20/79

Laundry

7.60

72 drums

79-79

7/24/79

RCS Liquid

3.60

79-80

7/25/79

Laundry

11.666

76 drums

79-81

7/30/79

Charcoal

0.080

Sample

79-82

7/31/79

RCS Liquid

13.28

79-83

8/1/79

Laundry

15.63

144 drums

79-63

8/7/79

U-2 Trash

3440.0

157 drums

79-86

8/8/79

Liquid

0.036

Sample

79-87

8/9/79

Liquid

.0992

Sample

79-88

8/9/79

Laundry

8,53

74 drums

79-89

8/14/79

HEPA Filters

3.812

No unacceptable conditions were identified in the above

shipments.

.

.

11

The licensee has revised the conversion factors of curie

estimates for shipments of packaged radioactive material.

The original factors, delineated in procedure 1620,

presented a method whereby curie estimates could be made

by utilizing a curie / rem conversion factor and a contact

gamma doserate of the package. This method however did

not address beta activity determination of the package.

Preliminary review of the revised conversion factors

indicate a possible underestimation of total curie

content.

(2)

Storage of Solid Radioactive Waste

Inspector tours of solid radioactive waste storage areas

identified one Significant Inpsection Finding. The item,

failure to label a radioactive materials storage area, is

appended to this report as Significant Inpsection Finding

Nos. 289/79-18-02; 320/79-22-07.

b.

Posting and Area Control

Tours of controlled and noncontrolled areas were made to

verify licensee compliance with the requirements of 10 CFR 20.203, " Caution signs, labels, signals and controls", Technical Specification Section 6.12, "High Radiation Area" and Station

Health Physics Procedure 1610, Revision 7, " Establishing and

Posting Areas", dated September 30, 1977.

The area tours and the performance of independent radiation

intensity measurements identified the following Significant

Inspection Findings which are appended to this inspection

report:

Number

Item

Date Identified

320/79-22-04

Failure to Post, Barricade

7/22/79

and/or Control (>lR/hr)

Access to High Radiation

Areas

320/79-22-05

Failure to Post, Barricade

8/5/79

and/or Control (>1R/hr)

Access to High Radiation

Areas

The licensee has, in a letter dated August 6,1979, conmitted

to the review and revision of those procedures dealing with

the control of High Radiation Areas.

The revised procedures

will include:

1) specific steps for the control of High

Radiation Area access 2) a surveillance program for identifi-

cation of new High Radiation Areas and 3) a surveillance

program to ensure all High Radiation Areas are properly

controlled.

.

.

12

c.

Radioactive and Contaminated Material Control

Radioactive and contaminated materials control was reviewed

for compliance with the requirements of 10 CFR 20.203 (f)

" Containers" and Station Health Physics Procedure 1682,

Revision 2, " Control of Contaminated Tools, Equipment and

Material", dated April 28, 1977.

The review identified one significant inspection finding. The

finding, relating to control of radioactive and contaminated

material, is appended to this inspection report as Significant

Inspection Finding No. 289/79-18-01; 320/79-22-06.

d.

Radioactive Effluent Releases

c

(1)

Liquid Effluent Releases

Radioactive liquid effluent releases from the plant were

reviewed against the following:

-- 10 CFR 20.106, " Radioactivity in effluents to

unrestricted areas".

-- Station Health Physics Procedure 1621.2, Revison 4,

" Releasing Radioactive Liquid Waste from Unit 2",

dated Jaunary 5, 1979.

-- Special Operating Procedure, S0P No.Z33, Revision 2,

" Water Sump Discharges to IWTS and IWFS", dated

May 18, 1979.

-- Special Operating Procedure, S0P No. Z51, Revision 4,

dated August 14, 1979.

The licensee performs gama spectroscopic analysis of

liquid waste prior to its release from the site.

Based

on inspector review of the analysis, the follcwing

Significant Inspection Findings were identified and are

appended to this report:

Number

Item

Date Identified

'

79-22-12

Failure to Perform Gross

7/20/79

79-18-03

Beta Analysis

79-22-13

Failure to Perform Gross

7/27/79

79-18-04

Beta Analysis

(2) Gaseous and Particulate Effluent Releases

The licensee maintains a supplemental Vent Radiation

Monitoring System to monitor gaseous and particulate

effluent releases from Unit 2.

,

.

13

The system operation was reviewed with respect to the

following:

10 CDR 20.106, " Radioactivity in Effluent to Unrestricted

--

Areas".

Technical Specifications, Appendix B, Section

--

2.1.2., Gaseous Effluents

No unacceptable conditions or significant discrepancies

were identified.

e.

Respiratory Protection

The licensee utilizes the service air system as a source of

breathing air.

On July 30 through August 7,1979; the licensee placed this

system in service as a source of breathing air to specific

work areas of the 281' el of the Fuel Handling Building.

A review of the system utilization was performed. The review

encompassed the requirements of Regulatory Guide 8.15, " Acceptable

Programs for Respiratory Protection".

Based on the review, one Significant Inspection Finding was

identified and is appended to this report as No. 320/79-22-08.

f.

Counting Equipment.

The calibration of licensee radiation counting instrumentation

is performed by a calibration contractor. As a result of beta

contamination identified in smear and air sample results, the

licensee's beta detection and counting instrumentation was

reviewed.

The review encompassed:

(1) use of NBS traceable

calibration sources, (2) use of established and approved

calibration procedures, (3) use of established and approved

operation procedures, and (4) the comparison of licensee

results with those obtained during independent calibration

determinations using calibrated sources obtained from national

laboratories.

Based on the above review, the following Significant Inspection

Findings were identified and are appended to this report:

Number

Item

Date Identified

79-22-09

Calibration and Operation

7/19/79

Deficiencies of Air Sample

and Proportional Counters

79-22-10

Inaccurate Calibration of

7/26/79

Friskers and Smear Counters

_

-

.

14

Number

Item

Date Identified

,

79-22-11

Inaccurate Cs-137 Counting

8/10/79

Efficiencies for Licensee

Proportional Counters

(Contractor Supplied)

.

g.

Augmented Systems

.

The licensee has retained the services of a contractor to

provide for decontamination of small metalic objects (i.e.,

tools,pipesections,etc.).

Prior to initial operation of

the facility, review of facility design, contamination control,

.

. air monitoring, ventilation system design and radioactive

material control was conducted on July 23, 1979.

Minor discrepanices were identified to the licensee. Acceptable

corrective action was completed prior to facility operation.

l

The discrepancies and corrective action taken were as follows:

'

No ventilation was provided in area of initial contami-

--

,

nated material handling. As corrective action, the

'

licensee contractor installed a table with hood where

'

contaminated material will be handled initially.

Dampers

permit regulation of air flow.

Total exhaust flow rate from the facility was measured to

--

be 560 cfm.

As corrective action, the licensee con-

'

'

tractor realigned existing fan and motor system.

Exhaust

flow rate after realignment exceeded 2,000 cfm.

h.

Plant Tours

Tours were made of both controlled and noncontrolled areas to

r

examine:

access control; personnel frisking; use of survey

meters; adherence to Radiation Work Permit (RWP) requirements

and proper use of respiratory protection equipment.

No unacceptable or condition or significant discrepanices were

identified.

7.

EPICOR II Preoperational Status

The following items were identified during a preoperational review

of the EPICOR II system and procedures and have been discussed with

licensee representatives.

The present CCB operating procedures do not contain a definition

--

of normal operating limits which identify proper operation of

the ventilation system moisture separator, preheater, HEPA

filters and charcoal absorbers. Operating limits for these

-

.

15

paramters will be identified during preoperational testing'and

initial operation of the ventilation system and then incorpo-

rated in a subsequent revision to the Vent System Procedures

(OP 2104-5.16).

Drip pans for CAP GUN PUMPS ALC-P-1, 2, 3, 4 have drain

--

connections which will not drain water to less than 1/2 inch

in the pan and can become a significant radiation source.

Resolution has not been determined.

Drain lines from prefilter/demin pits will leave 1/4 inch of

--

water standing in cavity (same concern as above).

Resolution

has not been determined.

Instrument cables to radiation detectors in prefilter/demin

--

pits need to be tied down/ protected from damage (apparently

has been pinched by moveable ladder leaning on them).

Adequacy of the vent system radiation monitor (ALC-RE-18)

--

sample lines with respect to number of bends, discharge point,

etc. needs to be reviewed.

Need to incorporate a flow meter conversion chart for ALC-FE-17

--

in the operating procedure for the vent system to allow

reading of meter over expected range of operation.

The above items along with system procedural deficiencies were

discussed with licensee representatives.

Resolution of these items

will be followed by the NRC:TMI Support Staff (320/79-22-14).

8.

Exit Interviews

Meetings were held with licensee management to discuss inspection

,

findings and concerns as noted below:

a.

Meeting on August 23, 1979

Licensee Representatives

R. Arnold, Corporation Vice President-Generation, General

Public Utilities Service Manager - TMI Site Operation

R. Dubiel, Supervisor of Radiation Protection and Chemistry

D. Limroth, Superintendent, Administrative / Technical Support

'

I. Seybold, Supervisory Dosimetry

C. Wiblin, Supervisory Respiratory Protection

NRC Representatives

i

J. Collins, Deputy Director, TMI Support

H. Crocker, Chief, TMI Resident Office

D. Neely, Lead Radiation Specialist

f

-

.

16

Items concerning licensee immediate actions to NRC concerns,

contained in a letter.from J. Herbein to B. Grier, dated July

18, 1979, were discussed.

b.

Meeting on August 22, 1979

Licensee Reoresentatives

R. Dubiel, Supervisor of Radiation Protection and Chemistry

J. Herbein, Vice President-Generation, Metropolitan Edison

Company

D. Limroth, Superintendent, Administrative / Technical Support

J. Logan, Unit 2 Superintendent

J. Seelinger, Unit 1 Superintendent

NRC Representatives

R. Conte, Reactor Inspector

H. Crocker, Chief, TMI Resident Office

D. Haverkamp, Lead Reactor Operations Inspector

D. Neely, Lead Radiation Specialist

'

The following items were discussed:

Significant Inspection Finding Nos. 320/79-22-01 through

--

13; and,

-

EPICOR II Concerns.

--

,

I

%

.

-

- - -

_

_ _ _ _ _ _ _

. . _ _ _ _ _

_

_

_

,

.

..

ENCLOS{ IRE (1) to TMI-2 STANDING ORDER NO. 2

-

~

.

I

.

79-22-01

SIGNIFICANT INSPECTION FINDING NO

.

Inadequate Administrative Controls for Recovery Special Operating

SHORT TITLE:

Frocedures (K-due)

(Details attached) Summary below:

DESCRIPTION

tio PORC review and subsequent Superintendent /NRC approval on a Revision to the 80P

.l.

Diesel Operating Procedures.

2.

Procedure. implementation problem not being formally identified.

handwritten copies of procedures (with cross-outs / changes) make pre-approval

J.

Uriginal

anc post approval changes indistinguishable.

'

4.

It appears post-approval cnanges were not reviewed ano approvea.

due cancel tation instructions are not always rol towec.

a.

This reoresents a failure to fulfill 10 CFR 50 Accendix B Criterion VI requirements for

Control of Documents.

IDENTIFYING

LICENSEE REP.

NOTIFICATION

ACCOMPLISHED BY

NRC OFFICIAL

NOTIFIED

~

R. J. Conte % %

Er

SIGNATURE

R. J. Conte nh

_11. Bezilla

R. J. Conte

V

NAME

R. J. Conte

v

TITLE

Reactor Inspector

PORC: Administrator

Reactor Inspector

DATE/ TIME

//12//9 4:00 p.m.

_

__ - ) p-

~

//l///9

10:00 a.m.

,

LICENSEE ACTION TAKEN:'

VERIFICATION.DATE/ TIME 7/31/79 6:00 p.m.

.

A licensee audit of the Control Room R-SOP file was conducted 'sith the following actions

taken:

'

was

-- item i aucve was contirnied anc tne previotisTy~alfproved revision (nevision i)

'

(

reinstaceo in r1te.

Item 2, the specific problem (Missing indicators for BOP Diesel) has been identified

--

to licensee engineering staff who are in consultation with vendor for resolution.

Items 3 & 4, other than that addressed above, no post approval changes were made with-

--

out proper review and approval. Furtner, all effective copies have been (cont, see

Verified by: R.J. Conte, Reactor Inspection (per sampling basis) pi g n

attached)

Name/ Title and Signature

\\J

'

Disposition Recommendation

.

t

/XX /

Document in Inspection Report.

/

/

Additional Enforcement Action because of inadequate licensee action.

/

/

Cancel. Does not warrant inspection documentation.

/h/

Carry as outstanding item for further inspection.

0 1/f f

l

D

u m e=

,w_

p

D. Haverkamp 8/1/79

Lead Ops or HP Inspector

.

Disposition

Af A A

A M

/L

f

ker

Chief, IE Resident Office, THI-2

8/1/79

Date

-

-

!

-

_

_ . _ _

_

_

_

_ _ _

-

.

.

'

,2

.

Significant Inspection Finding No 79-22-01 (CONT)

,

.:

.

-

'

Description (cont)-

..

'

--

.

.

A.

References

-

,

,

'

l.

Control Room Copy of Recovery Special Operating Procedures (R-SOP) Binder.

2.

SOP-2-79-R-14, Revision 2, June 20,1979, BOP Diesel Generator (DG-A) Gray

and Auxiliaries Panel.

3.

SOP-2-79-R-15, Revision 2, June 20,1979, 80P Diesel Generator (DG-B)

White and Auxiliaries Panel.

B.

Details

1.

Revision 2 to SOP-2-79-R14 and 15 did not have indication of PORC

.

review and subsequent Superintendent /IIRC approval. The associated change

request fann was partially completed. The revision added parameters

to be monitored on the data sheet attached to the procedure.

2.

Although the Data Sheet (addressed above) requires that Crankcase

Pressure and Exhaust Temperature be recorded, instruments to measure these

parameters do not appear to exist. This was based on observation by the

inspector and discussion with the licensee's operator.

(It is not clear whether

or not these parameters are needed to be monitored for the safe operation

of the equipment.)

Further, it appears that these instruments had not been installed

during construction.or initial operation testing of the systems (May 1979).

This 50P was implemented on several occasions and no formal operator

identification of the problem was made.

3. _0riginal handwritten copies of R-SOP procedures (with cross-cuts / changes)

are on file in the Control Room with pre-approval and post-approval changes

being indistinguishable.

In 18 of 32 effective procedures the original was

on file, and in 8 of the 18 cases, significant technical changes (e.g., valve

'

position changes, step reversals, etc.) were noted. This applies to

S0P-2-79-R 1, 2, 12, 17, 19, 22, 29 and 37.

4.

Of the remaining,14 procedures which were not. originals, 5 had technical

changes with no documentation of appropriate review and approval.

It

appears these were post-approval changes.

This applies to SOP-2-79-R-3,10,16, 32 and 38.

Further, in 2 other cases, extraneous marks, notes, questions were

noted on the procedure. This applies to SOP-2-79-R 14 and 38.

l

~

l

-,

_A

,

%*

'

,

a'

3

Significant Inspection Finding fio 79-22-01 (cent)

'

5.

It does not appear cancellation instruction for SOP's (on cover page

of each procedure) are always being followed.

In 8 of 32 effective procedures

'

cancellation instructions were "Upon completion of procedure" or " test".

Some of these tests were issued mid-May 1979 and they appear to be no longer

applicable yet they are still on file. This applies to SOP-2-79-R-5, 12,

,

13, 17, 16, 19, 22 and 24.

Further in three procedures on file in the control room, data is

>

completed on the file copy. This precludes using the file copy to generate

t

a working copy for test records. This applies to S0P-2-79-R 13, 32 and 36.

i

Licensee action _Eulen (cont)

photostated so that post approval change can be identified.

'

-- Item 5, outdated 50P's have been cancelled and removed from file.

In a separate memo, the licensee representative indicated that once Racovery

t

TS are issued a " concrete format for procedure review and approval....will

be clearly defined" Item 2 and Recovery Admin Controls will be followed.

L

[

s

I

'

l

,

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..----m..

m

...

F

_.

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,

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. . .

.

ENCLOSURE (1) to TMI-2 STANDING ORDER NO. 2

-

,

i

f

.

SIGNIFICANT INSPECTION FINDING NO 79-22-02

f

Adequacy of fire protection in Diesel Building (Class IE)

SHORT TITLE:

and Cable Spreaoing Room

-

.

,

,

DESCRIFIION

'

l.

Five fire doors blocked open but required to be keot closed (for access to

A & D Diesel and between rooms)

2.

All portable fire extinguishers were overdue for routine checks in Diesel areas.

3.

Excessive oil leakage for Diesel 1 A

4.

Excessive combustible material in Cable Spreading Room with no hourly fire

!

watch patrol (AP 1034)

License Commitments - See attached

IDENIIFYING

LICENSEE REP.

NCIIFICATION

NOTIFIED

ECOMPLISED:3 IiY

AtRCJdICIAL

/

SIGNATURE

MM 4/ -

-f

_

_Xr

~

-C M t'd M d

NAME

) Eric K. bwanson/

lom U'Lonnor Ext. 236

M . b. Ko t taz /

Keactor inspector

,

TITLE

KeacLar inspecLar

~

same as Detore

,

w --

DATE/ TIME

//ia//y - 440u

VERIFICATION.DATE/ TINE 8/l/79 - 2400

'

LICEN3EE ACTION TAKEN:

.

Door between diesels were locked, doors' closed, hourly surveillarice initiated.

1.

-

-

2.

All portable fire extinguishers were checked for July,1979.

3.

Excessive oil leakage was corrected.

!

4.

runount or comDustible material in Cable bpreading Room was establisned at

an acceptacle level.

.

/

?

/

O2/LL- A

Verifisd by%E." T. Chow, Vgactor Inspector

[Name/TitleandSignature

'

Disposition Recommendation

,

i

!

/^ /

Document in Inspection Report.

o

/

/

Additional Enforcement Action because of inadequate licensee action.

/ /

Cancel. Does not warrant inspection documentation.

/ s/

Carry as outstanding item for further inspectiong

nn/ f/

r7

v kamp

Lead Ops or HP Inspector

Disposition

As stated

M&0- , /

k

c,/ /

W' C

g

'

Chief, IE Resident Office, TMI-2

i

R/?f70

Date

i

_. _

_

~

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_

_.

4

-

.

i~ kNCLOSURE (1) en TMI-2 STANDING ORDER NO. 2

-

,

t

SIGNIFICANT INSFECTION FINDINC NO

79-22-03

.

5,

,

SHORT TITLE:

Adequacy for Operational Preparedness for Balance of Plant

.

(B0P) Diesels-

-

.

.

.

,

.

.

DESCRIPTION

uuring tne review of this system from August 9 - 17, 1979, severai questions

were raised on the adequacy of the program for making the buP U1esels operacionai

.

in the tollowing areas:

--Uperator training (including Ene implementation or acministrative concruis

!

for orocedures)

'

l

--Procedure orecaration to reflect desian and as built conditions.

Specific examDies of shortcominas in these areas are attached.

IDENIIFYING

LICENSEE REP.

NOIIFICATION

NRC OFFICIAL

N u u r J.t.u

ACCOMPLISHED BY

SIGNATURE

HNLA

_

_

>G--

~

- f 1Kh

NAME

D. Price /R. Conte

J. Chewastzk/ i.Krailling

R. Js Conte

Reactor Inspector

TITLE

Heactor Inspector

Shif t Supervisor / Engineer ~

August 13, 19/9/1100

DATE/ TIME

Aug. 9-17, 19/9

-^'

'

LICENSEE ACTION TAKEN:

VERIFICATION _DATE/ TIME

-

.

1.

Procedural problems have been corrected in subsequent revisions cu

both Uperating Procedures for the Caray and Miite biesels.

-

"'"-

~

'

2.

Fire Protection discrepancies are currently under review by tne licensee.

7

\\

.

Verified by:

10 . Mrv

P .1 C , A t

P , , , t ,, . T x w,,

'

_

.

v

Name/ Title >and Signature

Disposition Reconsnendation

,

',

-

-

i

!

@

Document in Inspection Report.

/ /

Additional Enforcement Action because of inadequate licensee action.

/

/

Cancel. Does not warrant inspection documentation.

/X'/

Carry as outstand'ing item for further inspection.

'

D

-

/.

'

YY

-

.

.

LeadOpsorHPIn/pector

.

,

Disposition

.

M

Chief, I F Resident Office, THI-2

'

Date

!

.

__.

. __L

-

-

-

a

.

,

.

.

AttacNnent 1

'

DESCRIPTION

'

'

'

A.

The following observations were nide during the performance of the

operational test on August 9,1979 of the Gray Diesel, R-2-79-15,

Balance.of Plant (B0P) DG-A (Gray) Diesel and Auxiliaries Operating

Procedure, dated August 9,1979.

1.

Sections 4.2.1 and 4.2.2 require that fuel oil day tank be at least

200 gallons and the storage tank for the Gray system be at least 3500

gallons. The recorded values were 175 gallons and 2750 gallons

respectively.

The procedure was completed with no formal change to the

procedure and/or identification of the problem to management.

It was later determined (that same day) that the White diesel was run

without meeting the required fuel storage tank limit as specified in

the procedure. Several days later the tank curve for this system was found

to be in error in a conservative direction.

In actuality the procedural

limit (which reflects proposed T.S. limits) was met.

2.

On August 9',1979 both the White and Gray Diesel .were tes'ted simultaneously.

This is contrary to Revision 1 of TMI-2 Criteria for Loss of ~0ff Site 80P

Electrical Power.

Both operating procedures did not preclude simultaneous

testing.

3.

Section 4.1.1.3 of the Gray Diesel Operating procedure states the

!

operator was to verify immersion heater control of jacket water temperature

between 125 F and 1550 F.

The recorded value on startup lwas 1200 F which

came up to the specified range. The procedure was completed.

It was later determined by the licensee representative in consultation

with the vendor, that controlling temperature was set for 1150 F to 1550 F.

,

4.

Section 4.3.11.5 required that the operator verify a current of

approximately 434 amperes with a load of 2500 KW, 4160 volts, 60 Hz. The

actual indication was 343 amperes.

It was later determined that the 434 amperes value. !was a maximum limit.

5.

Section 3.1 required the check of instrument root valve position,.

The

operator initially indicated that they were inaccessible and used

indication on one gauge as verification of valve position.

The operator

later (dur.ing the conduct of the startup procedure) consulted a.n ,

engineer who directed the proper valves to be checked which were accessible.

6.

The data sheet requires a check of level in the Fu'el Oil Return

-

Sight

Glass and Fuel Oil Bypass Sight Glass. The operator claimed

they didn't exist. .The procedure was completed wi,thout recording the

value.s. . The Sight . Glasses do exist.

'

'B.

The cover memorandum for Revision 2 to TMI-2 Criteria for Los~s' of Off-Site

80P Electrical Power states that Revision 2 incorporates as built fire

protection for the Gray and White Diesel. Based on actual observation tha

following discrepancies were noted with respect to Revision 2:

-

ame

-

-

.s

,'

.

-

- . . .

Attachement 1

.

2

.

1.

Oike for the White diesel storage tank is not completed.

.

.

2.

No fire detection devices exist in diesel or storage areas.

'

3.

Only one fire extinguisher is in the White Diesel enclosure

'

making it inaccessible with fire inside the enclosure.

-

4.

A local fire hydrant with hose storage is not addressed in the

criteria.

C.

During a test of the Gray Diesel on August 17,1979 (10:00 p.m.) it

was observed that the operator waited until completion of the procedure

to initial off completed steps. When the procedure was signed off,.

!

3 lines were left blank and one "large" initial was to cover several

lines of the valve line-up sheets (Attachment )). The blank s,teps were

3. 5, 4.4.1.1, 4.4.1. 2.

This is contre.ry to AP1001 paragraph 3.8.5.a,

4

which requires that plant operating procedures shall be followed and

signed off step-by-step, and paragraph 3.8.5.f which states that Special

Operating Procedures are subject to the same level of control and approval

4

as operating procedures.

!

.

O

.l .

_.

_.

-__

-- ._

-

i

'

"': i.cstf7I (IT to TF1-2 ST!JC:NC OT.DET. NO. 2

-

i

!

/79-22-04

"

SIGNIFICANT INSPECTION FINDING NO

SHORT TITLE:

High Radiation Area Control / Posting and Barricading

.

s-

..

-

. ;.

,

.-

, '

' " * :? : *; -

.

..

,. . . . . ,

.

.-

,

,

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? ' . ' O S -

,

DESCRIPTION

-

m'

,

.

See attached.

.. -

.-

.

1

'j

.

..

i

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. -

IDENTIFYING

LICENSEE REF.

NOIIFICATION

--

NRC OFFICIAL

NOTIFIED

~ACCOMPl.IS}-TD EY

' i - Ja n u, ,L.

l.AJ

'

-

~

SIGNATUREIV ArmL, fx1

--

NAME

l'

R. J. h45ett.

l

Paul Schaule

(l

~'R'. J. Eferft't

ll

Radiation Specialist

-

TITLE

i

Radiation Specialist

i

NSS H.P. Supervisor - ll

7/23/79 @l530

} }M-

DATE/ TIME l

7/22/79 @l500

{:

=

-

.

,

LICENSEE ACTION TA}2N:

VERIFICATION 2 ATE / TIME

'

Per ' discussions with Schaule, the licensee will :

l*

Place lead blankets in area near containment wall.

2.

Place lead wall and locks to be utilized at valve room outside

make up tank.

3.

Fabricate door to control access to cast corridor of FHB.

.

Verified by:

Name/ Title and Signature

Disposition Reco=endation

3

ACX /

Document in ' Inspection Report.

/

/

Additional Inf orc ement Action because of inadequate licensee action.

/

/

Cancel. Does not wa rr,,nt inspection documentation.

/XX /

Carry as outstanding item for further inspection.

/

/

.- .

Q

l(.-7

'

.R.

Neely

Lead Ops or HP Inspector

.

,

<

Disnosttion

x/

A0

A

&VfW ^ '

H.W. Crocker

Chief , IE Resident Office,"I'MI-2

?&f

'

-

Date

--

.

n

.

f

e

1

4

"

j

..

Description

The following High Radiation areas, emanated whole body dose rates greater

than 100 mnem/hr and were either not controlled (i.e., locked or manned in

^

the case of those areas greater than 1000 mrem /hr) and/or were not posted

and barricaded as required by Technical Specification 6.12 and 10 CFR 20.203(c)

4

Date

Area

Whole Body Dose Rate (mrem /hr)

7/22/79

Unit 2 - Aux. Bldg

3000

328'el - Concentrated

(access not controlled)

Waste Tank Cell

1

!

305'el - Area Near

2000

HP-R-227

(decess not controlled)

'

281'el - Open Elevator

200-300

i

Shaft

(not posted or barricaded)

. - .

--

-

l'.

-

-

-

.

7""" 05 t~.I

/I S te T.0-2 STA'Q!?;O ORDEE N:). 2

-

~

~

'-

?

. . _

.

SIGNIFICANTINSPECTIONFINDINON0h9-22-05

SHORT TITLE:

High Radiation Area Control / Posting and Barricading

.

. . .

..

.

..

. . , .

.

. #'US..

.

.

' '

P:'

DESCRIPTION

-

.

-.

~

T *-> >

~2 C'

-

'

See attached.

-

.-

-

.

.j

-

.

. ..

J

9

3

o

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IDENTIFYING

LICENSEE REP.

NCIIFICATION

---

NRC OFFICIltL

NOTIFIED

'ACCO."F"ISEED BY

SIGNATURE l

10 d,M i .1,. _ [,t

I _ t-

X

' -Myt . L .h

i

gug

l l ' Blaine Jiuf ry

P. Schaule

l BlainTe @ riff

TITLE

'l l

Radiation Specialist

NSS H.P. Supervisor

l Radiation Specialist

-

DATE/TIMEi!

W"

ll

- -- Er

ll

8/5/79

,

.

~

~

LICENSEE: ACTION Tal'EN:

VERIFICATION 2 ATE /IIME

Licensee to secure,. post and barricade as necessary

.

I

verified by:

Name/ Title and Signature

Disnosition Beco=nendation

'

-

/W

Doct=nent in Inspection Report.

/

/

Additional Enforce:nent Action because of inadequate licensee action.

/

/

-Canc el . Does not warrant inspection documentation.

M

Carry as outstanding it e= f or further inspection.

/

/

. , ,

,

.

.

Lead Ops or HP Inspector

.

i

Disnosition

M/I-,/MJ

/L

^'

W

oc

(

'

Chief,

E Resident Of fice, TMI-2

of-

/ &

F '7/ J 7

f

'Df t e'

/

-

c

_

.t...._-

_

..

.

.

,

.

re -

Description

The following High Radiation Areas, emanated whole body dose rates greater

than 100 mrem /hr and were either not controlled (i.e., locked or manned in

the case of those areas greater than 1000 mrem /hr) and/or were not posted

and barricaded as required by Technical Specification 6.12 and 10 CBR 20.203(c) .

Date

Area

Whole Body Dose Rate (mrem /hr)

8/4/79

Unit 2 Aux. Bldg.

4000

328'el. 4 Aux. Bldg

(access not controlled)

Filter Room

305'el. - High Radiation

7000

area near pipe

(not posted and not

at entrance to

barricaded)

MU Tank Room

281'el. - Aux. Bldg. Sump

4000

Filter Cell

(access not controlled)

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e n Trn-2 3 /.r n::: orm; to. 2

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S2 CNITICA1;T INSFECTION FII; DING 1;o 79-22-06

,

SHORT TITLE: Contaminated Haterial Control

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DESCRIPIION

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nn inspector tour on 7/23/79 identified 6 semi-trailers located 'near tiie Uffi't'l Raartnr

Buiioing equipment Hatch.

Ine trailers contained lumber and equipment and were costed

.

rouivoccive. n raciation/ contamination survey performed by the licensee health ohvsics

n

congactor,1ndicated radiation dose rates and contamination up to 5 mR/hr and s 1000

_.

upiiy suu cmc respectively on the uncontrolled radioactive materi als. The licensee did Hnt

nave any means to assure that the radioactive material (i .e. lumber. eauinment. prc )

were not used in an uncontrolled area (i.e. c19an araae)

Tha ahnun renresen.tr fai hr

to adhere to Station Heal th Physics Procedure 16R2. "rnntrn1 nf cnntn.,innted teels,

equipment and materials, Rev. 2 dated 4/28/77 Section 5.2.

IDEhIIFYING

LICENSEE REP.

NCIIFICATION

-

NRC OEF1CIAL

1;OTI- IED

. ACCO.MISHED EY

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M=

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l " NO W> '/L

SIGNATUREi- MORA I'd

I i

"-

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pgu, g

51aintifiutiy

i

B. Good

BlaineMurrvh

TITLE

l Kauiation dpecia list

I

i

Radiation Specialist

--

DATE/ TIME l l //24//9

1600

l

-N"

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7/24/79

1600

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VERIFICATION .DATE/IIME .7/26/79

1400

LIkENSEE : ACTION TAKEN:

nspector review on 7/26/79 noted alTiocks to be installed on above trailers

anu securea t.o prevent unauthorized removal of equipment

.

.

Verified by:

Blaine Murrv. Radiation Snacialiet

/6 Atm /.. b)

Name/ Title and Signature

7[

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Disposition Reco:cendation

/y/

Document in Inspection Report.

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Additional Enf orcement Action because of inadequate licensee action.

Q

Cancel.

Does not warrant inspection documentation.

/

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Carry as outstanding item f or further inspection.

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Lead Ops or HP Inspector

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i'

Dianosition

sLW

/)

Chici, IE Resident Office, TMI-2

h lf

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Date' ' '

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S2 CNITICANI INSIICTION TIliD1110 1;0 79-22-07

sHORT TITLE:

Improper Posting of Radioactive Material Storage Area

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DESCRI PTION

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itumerous 55-gallon drums . stored on El 305', Unit 1 Turbine Deck were -labeled wi' h

t

wnite-i or ye t low-11 iaoeis. Raciation oose rates measureo u.i-2..+ mR/ nr.

'

ine crum storage area was not postec as a racioactive materiai area as

,

,

required oy 10 M H zu.zu.s (e) (i),

ine Unit I turoine cecK nas oeen

a

utilized as a storage area for low level Unit 2 trasn.

IDEh'TIFYING

LICENSEE REP.

NCIIFICATION

--

NRC OFFICIAL

Nuur IED

' ACCOMPLISHED EY

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i - G. L. Troup )10%L 44

SIGNATURE l -

//)Pu,Je

,M

l

i

1

G. L. Troup'~~

/d

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NAME

l'

'G 7L . Tri/u p'..~

l

M. A. Janowski

i

TII1E

.l L Radiation Sdecialist

l Met. i.d Senior H.P. Tech.

Radiation Specialist

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l

19 July - 1735

DATE/ TIME ll 19 July - 1725

IICENSEE!ACHON TAKEN:

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VERIFICAHON .DATE[IIME

19 July-lh55

The ' area was barricaded with yet low rope and posted with. " Caution -

Haaloactive Materials".

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verified by:

A) F w A #c

,

, _ , , , , n a , + - ., e _ 4,,4,.

' " ' " ' ' " """'"'

' ' " " '

Name/ Title add Siggat'ir e " M

I

.

Disposition Reco==endation

/X/

Document in Inspection Report.

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/

Additional Enforcement Action because of inadequate licensee action.

/

/

Cancel. Does not warrant inspection documentation.

/

/

Carry as outstanding item f or further inspection.

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f P. Rih

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Lead Ops or HP Inspector

.

Disvosition

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e

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H 'CEici, ~15R e sid ent Office, THI-2

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Datef

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' 'ETC1.05URE. (1) to TMI-2 STANDING ORDER N0. 2

79-22-08

SIGNIFICANT INSPECTION FINDING N0.

SHORT TITLE:

Failure to utilize breathing air system properly

DESCRI'PTION:

See Attached

' IDENTIFYING

LICENSEE REP.

NOTIFICATION

NRC 0FFICIAL r

NOTIFIED

ACCOMPLISHED BY

SIGNATURE

h ,, L.

M

2

/0P M /

NAME

Nilliam J. Itillsap

Earl Gee

0?neely/W. / Mil l sap

TXTLE

Radiation Specialist

Safetu Supervisor

0 ATE / TIME

8/12/79 /0830

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,Y

8/17/79

LICENSEE ACTION TAKEN:

VERIFICATION DATE/ TIME

A technical meeting was held on August 17, 1979 to discuss the licensee's

respiratory protection program witn respect to the above items.

Specific

items included minimum program requirements as specified in Regulatory

Guide 8.15 and the guidance of NUREG-0041.

The licensee indicated the

breathing air system will be audited and an action item list developed.

Verified by:

Name/ Title and Signature

Disposition Recommendation

lX

Document in Inspection Report.

Additional Enforcement Action because of inadequate licensee action.

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Cancel. Does not warrant inspection documentation.

X

Carry as outstanding item for further inspection.

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Lead Ops or HP Inspector

Disposition

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MmMM . J n'

W y v i L, r w wp

H. W. Crocker

l

Chief, IE Resident Office, TMI-2

h

/Date'

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Attachment 1

DESCRIPTION

The licensee utilized the breathing air system (service air) in support

of work being performed on the 281 ft. elevation of Unit 2 FHB during the

period July 30 thru August 7, 1979. A review of system utilization

indicated the following:

- During the above period, contractor personnel utilized an air supply

manifold in conjunction with full face piece air supplied respiratory

equipment. The face piece was designed to operate properly at 80 psi

however the manifold was providing only 40 psi. Consequently the

proper air flow was not being provided to the user.

The full face piece breathing air regulator used with the manifold

-

was found on August 7,1979, to have been modified to allow the

regulator to remain in a fully open position, thus providing full

air flow. The regulator had been jammed open by means of tape.

- As a result of pressure problem identified in MSA manifold, the air

manifold was removed on August 7,1979. The full face piece

respirator was connected via hose directly to the service air sparger.

An in-line filter was placed in the line to remove rust identified

during previous sparger blowdowns. As a result of filter clogging

personnel were not provided air of sufficient quantity on

August 13, 1979 in that personnel suffered loss of adequate breathing

air.

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Attachment 1

FINDINGS

A standard f Source, Sr-90/Y-90 .0034uCi electroplated, was submitted

to the licensee for counting. The results of the counting were

compared against the licensee's standard source, Eberline Cs-137.

The following was noted:

Sr-90/Y-90 Results

(uCi)

Source

Proportional Counter

Eberline Probe

Position

(PC-4)

(H.P.-210)

bare

.0035113%

.0021 + 2.5%

Thru 1 filter

.0021 1 1.8 %

.0020 1 2.5%

Thru 2 filters

.0014_+2%

.0018 1 2.7%

The above indicates a recovery of 62% of true activity for the H.P. 210

probe and 103% for the proportional counter.

The following deficiencies were noted:

1.

The H.P.-210 detector underestimates the total activity by 38%.

2.

The calibration performed by the licensee is not typical of samples

analyzed.

3.

The accuracy of the standard calibration source is questionable

and not traceable to NBS.

4.

There is no management or independent audits of activities in this

area (i.e. submission of standard sources to contractor for counting).

5.

The following procedural deficiencies were noted:

a) No approved calibration procedures are being utilized.

b) No QA/QC controls are implemented.

c) No approved procedures are being utilized for:

1) decay correction,

2) sample handling, 3) counting time determinations, 4) resolving

time corrections and 5) sample activity determinations,

d) No approved procedures are being utilized for additional evaluations

and acceptance criteria of final sample data.

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'NCLOSURS (1) to TMI-2 STANDIf4G ORDER N0. 2

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SIGNIFICANT INSPECTION FINDING NO.

79-22-09

SHORT TITLE:

Calibration and Operation Deficiencies of Air Samp1.e and Proportional

Counters Operated by Licensee Contractor

DESCRIPTION:

a review was made of the calibration, operation, procedures and QC and the adequacy

of equipment used to evaluate airborne concentrations. A standard sample was

suomitted tor counting and the perf ormance evalua ted.

de v le"v 11ncings are noted on

the attached sheet.

.

TDMTIFYING

LICENSEE REP.

NOTIFICATION

NRC 0FFICIAL

o

NOTIFIED

ACCOMPLISHED BY

StGNATURE

21(ks , e /w V.n)

X

DAM,&v

NAME

R .' J . Evete t W

D. Limroth/R. Dubiel

'D. 'Neely/d . Everett

TITLE

Radiation Spe'cialist

Met. Ed.

DATE/ TIME

7/19/79

X

LICENSEE ACTION TAKEN:

VERIFICATION DATE/ TIME

Meetings were held to address licensee deficiencies in the area of procedures,

quality control, use of NBS traceable sources,

fue meeting nela inalcatea a review

and procedural revision would be conducted to correct the above.

Verified by:

Name/ Title and Signature

Disposition Recommendation

lX

Document in Inspection Report.

Additional Enforcement Action because of inadequate licensee action.

-

U

Cancel.

Does not warrant inspection documentation.

X

Carry as outstanding item for further inspection.

_ _ _

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.N

Lead Ops or HP Inspector

Dispositio_n

//

/) F

/

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Chief, IE Resident Office, TMI-2

F/x2 /29

7

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ENCLOSURE (1) to TMI-2 STANDING ORDER NO. 2

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79-22-10

SIGNIFICpYr INSFECTION FINDING NO

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Inaccurate Calibration of " Friskers" and smear counters

SNORT TITfE:

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DESCRIPTION

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cattorated CS-137 source was used on July 26, 1979 to verify lic'ensee' efficiency

Acalculations tor scalers and " Friskers" using the Eberline H.P. 210 probe

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Based on the etticiency check, a value of 15 to 187.was obtained.

as cetector.

Ine Licensee currently uses .30 to 407..

This results in an underestimation of

accivtcy oy a tactor or approximately 2.

l

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IDENTIFYING

LICENSEE REF.

NOIIFICATION

ACCOMPLISHED BY

NRC OFFICIAL _

NOTITIED

,

-li O +%A $4/

SIcNATURE

lhe AL.f v F#

'5'.'Ewa1d / /

NAME

~St' eve' EwiYd /f'

R. Jaeobs

Radiation Spe'cialist

Supervisor Rad Services

Radiation Specialist

TITLE

- *-

~

7/27/79/1000

DATE/ TIME

7/26/79/1000

VERIFICATION.DATE/ TIME

LICENSEE ACTION TAKEN:

Pending 1icensee receipt of NBS' traceable sources, the licensee will

adwints tratively set tne etticiency at the H.P. 210 probe at 157..

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Verified by:

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Name/ Title and Signature

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Disposition Recou:mendation

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/X/

Document in Inspection Report.

Additional Enforcement Action because of inadequate licensee action.

L/

/

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Cancel. Does not warrant inspection documentation.

JX-[

Carry as outstanding item for further inspection.

D

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Lead Ops or HP Inspector

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Disposition

i

/A D

A

a

Chief, IE Resident Office, TMI-2

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ENCLOSURE (I) to TMI-2 STANDING ORDER NO. 2

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SIGNIFICANT INSFECTION FINDING NO

79-22-1l

i

Inaccurate CS-137 Counting Efficiencies for Licensee

SHORT TITLE:

Proportional Counters

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DESCRIPTION

On August 4 and 10,1979, a CS-137 source was submitted to the licensee's counting

ine source cocained invi.ia

contractor for counting and subsequent evaluation.

uvuotin3

lab, indicated a 3/-4U2 counting erriciency on nne cont.couturs

national

equipment. The licensee's plated CS-137 source (non-traceable) indicated

u5-707. efficiency. Based on these results, the licensee will under estimate total

'

beta activity by a factor of 2.

IDENIIFYING

LICENSEE REP.

NOIIFICATION

NRC OFFICIAL

NOIIFIED

-ACCOMFLISHEDrBY

SIGNATURE

})(hAo le {+

~

"~

~

- ELI YIP 1Y'V W

NAME

'Wrillam /1iifJp

K. i-redricks/0. Limrotn

William MiTisfp ~

TITLE

Radiation Specialist

Met. Ed.

Radiation Specialist

"-

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August 10, 1979

DATE/ TIME

August 10, 1979

'

LICENSEE ACTION TAKEN:

VERIFICATION .DATE/ TIME 10 -

The licensee will administratively set the proportional counter counting

ef ficiency at eu, until sucn time that ttle licensee can obtain an adequate

-

i

coiioracion source.

i

.

Verified by:

.

Name/ Title and Signature

Disposition Recommendation

-

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!

h/

Document in Inspection Report.

/ /

Additional Enforcement Action because of inadequate licensee action.

/ /

Cancel. Does not warrant inspection documentation.

h/

Carry as outstanding item for further inspection.

N

R f

-

-

Lead Ops or HP Inspector

,

m/wJ ff

//,

L-

McMQMW

_

U. Crocker

u

C'..ief, IE Resident Office, TMI-2

hk

' Date' f

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ENCLOSURE (1) to TMI-2 STANDIl1G ORDER NO. 2

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SIGNIFICANT INSPECTION FINDING N0. 79-22-12

SHORT TITLE:

Failure to perfonn gross beta analysis

DESCRIPTION:

A review of isotope data for a pending liquid waste release on July 20, 1979

_

(No. 14102) revealed tile presence of Ba-La-140 (20 MiPL).

51nce bd-La- WU are

fission products, this inoicated the possio111ty or unicentitiea oeta

emitters in the 11guld. As a result a gross Deta analysis snoula nave oeen

performed prior to release of tne tank. 51nce the release or tne Waste

Evaporator Condensate Tank was pending, tne inspector orougnt Unis to Ene

attention of licensee representatives who cycled tank back tor treatment.

This is a failure to survey (20.20lb) to meet 20.106.

IDENTIFYING

LICENSEE REP.

NOTIFICATION

NRC 0FFICIAL e

NOTIFIED

ACCOMPLISHED BY

SIGNATURE

A Emh L

X

/dgab

h

NAME

~5.'C.

Ewaild 0

unit i bnir'.

d.

t.

twa w

6

T1TLE

Radiation Specialist

dupervisor

Maoiation Specidiist.

DATE/ TIME

//20/79 / 1400

,X

_

7/zo//9

1640

LICENSEE ACTION TAKEN:

VERIFICATION DATE/ TIME

Licensee is reviewina procedural controls to preclude similar events, as based

on discussions with D. Limroth and R. McGoey on July 23, 1979.

Verified by:

S. Ewald / Radiation Specialist

Name/ Title and Signature

Disposition Recommendation

lX

Document in Inspection Report.

Additional Enforcement Action because of inadequate licensee action.

_

l]

Cancel.

Does not warrant inspection documentation.

X

Carry as outstanding item for further inspection.

.'

Lead Ops or HP Inspector

01sposition

.

-

A / -?W&

/4 .

o

Chief, IE Resident Office, TMI-2

P/7&M

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'dlCLOSURE (1) to TMI-2 STANDIliG ORDER N0. 2

.

SIGNIFICANTINSPECTIONFINDNGNO.

79-22-13

SHORT TITLE:

Failure to perform gross beta analysis

DESCRIPTION:

See attached

' IDENTIFYING

LICENSEE REP.

NOTIFICATION

NRC 0FFICIAL

NOTIFIED

ACCOMPLISHED BY

,

SIGNATURE

dit k' M u L

/. ed

X

/JLIE- m d -

NAME

' S . 'C'. Ewa l d/ ji~

Gary Miller

D. ~R. Neelf

TITLE

Radiation Specialist

Station rianager

Lead Radiation Spec.

DATE/ TIME

7/27/79

1030

X

7/27/79

1430

LICENSEE ACTION TAKEN:

VERIFICATION DATE/ TIME

Licensee is analyzing sample for Sr-90. Additional procedures requiring

gross beta analyses of liquid effluent samples will be developed

Verified by:

Name/ Title and Signature

Disposition Recommendation

lX

Document in Inspection Report.

'I

_J

Additional Enforcement Action because of inadequate licensee action.

I

I

Cancel. Does not warrant inspection documentation.

1

Carry as outstanding item for further inspection.

.d'

v[

l

Lead Ops or HP Inspector

Disposition

MW/d5

/J

l

YCN

Chief, IE Resident Office, TMI-2

&

F63/#

(

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Attachment 1

DESCRIPTION: Failure to perform Gross Beta Analysis.

The licensee halted a liquid release (No. 112) after the inspector brought

it to the licensee's attention that no gross beta analysis of tank contents

had been performed. The Waste Evaporator Condensate Storage Tank B had

been pumped to the river from 0655 to 1505 on July 27, 1979. A gamma

spectrum of the tank contents indicated Ba-La-140 (3.0E-SuCi/cc). A

subsequent beta analysis of tank contents indicated 8.32E-4uCi/cc. The

resulting release to the river was 170% of the instantaneous limit of

10 CFR 20 Appendix B Note 3 b.

For the purposes of 10 CFR 20.106, the

,

concentration may be averaged over one year.

The above indicates licensee failure to survey (10 CFR 20.201 b) to

meet the requirements of 10 CFR 20.106.

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