ML20126C879

Forwards Inquiry Evaluation of Licensee Performance Re 800211 Local Emergency & 800212-13 Minor Gaseous Leak.Addl Review Will Be Done During Subsequent Monitoring Activities. Certain Areas Examined Are Subj to Enforcement Actions

ML20126C879
Person / Time
Site:	Three Mile Island
Issue date:	03/10/1980
From:	Jay Collins Office of Nuclear Reactor Regulation
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
CON-NRC-TMI-80-038, CON-NRC-TMI-80-38 NUDOCS 8004100579
Download: ML20126C879 (25)

Text

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f MEMORAHDUM FOR: Victor Stello, Jr., Director, Office of Inspection and Enforcement I' THRU: Richard 'H.' Vollmer Director, NRC/1NI Technical Support, Staff i i FROM: John T. ' Collins, Deputy Director, NRC/1NI Technical j Support, Staff

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SUBJECT:

IHQUIRIES AT THI-2 Your memorandtsu for E. G. Case, dated February 20,1980, required an inquiry-type evaluation by the NRC/TMI Technical Support Staff of l licensee performance related to the local emergency which had occurred I on February 11,1980, and the. minor gaseous leak which had occurred on

February 12-13, 1980. The reports containing these evaluations are l attached. .

The review consisted of sele'ctive examinations of procedures and records, .

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' interviews local with licensee evacuation of the Unitpersonnel, 2 Auxiliaryand direct observations Building (Local Emergency during)the and j during routine operations. .

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Certain areas examined will require additional review and evaluation  ;

which will be done during subsequent monitoring activities by the i NRC/THI Technical Support Staff. In addition, certain of the areas j examined appear subject to appropriate enforcement actions. The NRC/THI i

staff will complete all activities related to this inquiry and document '

, the findings in the February. inspection report. .

I -

John T. Collins l , Deputy Director NRC/TMI Technical Support Staff-l

Enclosures:

(1) Inquiry Pl'an for Evaluation of Licensee Performance Related to Radioactivity Releases (2)' Evaluation of Water Leak from Makeup Pump Instrumentation (3) Evaluation of Sample of the Containment Atmosphere D

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4 INQUIRY PLAN ,

Evaluation of Licensee Performance Related to Releases of Radioactivity in Gasecus Effluents Conduct record review, direct observation, or discussion with licensee personnel to the extent necessary to complete the folicaing inquiry requirements.

1. Event Discovery and Notification

a. Determine method of discovery of off-normal radioactivity release, e.g., increasing radiation monitor levels, alarms, sample results, visual and/or off-normal leakage.

b. Determine sequence of licensee actions which led to confirmation of release point.-

c. Determine nature and extent of radioactivity release.

d. Determine initial and subsequent notifications made by licensee '

personnel to licensee management, NRC, state and local agencies, off-site support facilities, press.

e. Ascertain whether the above actions are acceptable based on regulatory requirements, and procedural controls.

2. Corrective Action - Technical

a. Ascertain that immediate corrective actions taken to terminate the off-normal radioactivity release were appropriate to correct the cause of the release and were taken satisfactorily.

b. For specific and generic measures planned to prevent recurrence, including equipment / component modifications, procedural changes, and training, verify that responsibility has been assigned for assuring completion thereof.

c. Determine adequscy of above actions to assure prompt termination of the release and to prevent recurrence. .

3. Safety of Operations - Technical Ascertain whether the event involved continued operations in violation of regulatory requirements or license conditions. ,

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A. Persons Contacted

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'r. 5. Elam, ;'anager, Plant Engineering Mr. R. H. Heward, Jr. , ":rager, Radiological Control, Uni 2 Mr. G. A. Kunder, Supervisor of Comoliance Mr. J. A. Renshaw, Radiological Field Operations, Unit 2 Mr. P. E. Ruhter, Radiological Engineering, Unit 2 Mr. B. G. Smith, Shift Supervisor, Unit 2 Nuclear Succort Services Mr. R. Rolph, Dosimetry Foreman Mr. J. Spratley, Health Physics Lead Supervisor, Unit 2 Mr. E. Suter, Senior Health Physics Technician, Unit 2 B. Documents Reviewed

-- Station Administrative Procedure 1001, Revision 21, September 21, 1979, TMI Document Control;

-- Three Mile Island Emergency Plan, Administrative Procedure 1004, Section 2.0, Revision 2, " Emergency Conditions," February 15, 1978;

-- Station Radiation Emergency Procedure 1670.1, Revision 6, February 13, 1978, Local Emergency Procedure;

-- Station Radiation Emergency Procedure 1670.2, Revision 9, November 22, 1978, Site Emergency Procedure;

-- Station Health Physics Procedure 1670.8, Revision 0, " Emergency Re-Entry for Repair or Rescue," January 16, 1978;

-- Station Health Physics Procedure 1670.15, Revision 0, " Post .

Accident Re-Entry and Recovery Plan," January 16, 1978;

-- Unit 2 Operating Procedure 2104-1.14, Revision 0, December 25, 1979, Standby Reactor Coolant Pressure Control System (SPC);

-- Unit 2 Emergency Procedure 2202-1.3, Revision 11, October 6, 1978, Loss of Reactor Coolant / Reactor Coolant System Pressure;

-- Unit 2 Emergency Procedure 2202-1.7, Revision 3, December 12, 1979, Excessive Radiation Level;

-- Unit 2 Emergency Procedure 2203-1.5, Revision 2, September 7, 1978, Loss of RC Makeup;

-- Radiation Work Permit 80B-0862, " Health Thysics and Surveillance,"

and Sign-In Sheets dated February 11, 1980; D*

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" Lessons Learned-Auxiliary Building Local Emergen:y of Fenr arj 11, lii;; I

.ni c.;r Sample Log Sheets dated February 11,19?^:

-- Unit 2 Personnel Contamination Reports, dated February 11, 1980;

-- Summary of Internal and External Exposures of Individuals in the Unit 2 Auxiliary Building during the Local Emergency on  ;

February ll, 1980; and,

-- Radiological Survey of Unit 2 Makeup Pump, Revision IB, dated February 11, 1980.

Operational Evaluation 7

C.

1. Description and Cause of Release e

On February 11,1980, at 12:20 P.M., an operability test of the 1A Makeup Pump was initiated. After starting the pump, a 1cw discharge pressure alarm was received for the 1B, Makeup Pump, followed by confirmation of a 9 gpm leak based upon decreasing Makeup tank level. An evacuation of the Auxiliary Building was ordered at 12:50 P.M., and a local emergency was declared at 12:58 P.M..

The operational sequence of events and key management decision points are described below.

TIME EVENT 1220 Initial conditions - MU-P-1B in operation maintaining reactor coolant system pressure, while in natural circulation cooling mode. .- ,

1220 started MU-P-1 A to test pump operability.

I 1221 Received low discharge pressure alarm on fiU-P-18.

1237 Stopped MU-P-1A. Makeup tank level was dropping.

1237- Low discharge pressure alarm for MU-P-1B still existed. -

1240 Calculated leak rate based on level drop - approximately 9 gpm.  ;

1250 Shift Supervisor evacuates personnel from Auxiliary Building. .

Eleven people were on respirators in the building at the time of the event. NRC/TMI staff members are dispatched to I

Unit 2, based on public address announcement.

i I' 1258 Shift Supervisor declares localL emergency.

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1305 Initiated maintaining status boards in Unit-2 Control Room. Dose Assessment group is formec anc prepared to calcula:e off-si e cose 13:5 MMS-3 mir Sample is 3 7. iv-I unice a 281' elevatia c.-u ; =;5

,ast '.5 lts.

131: There is a rcported increase " levels on monitors U7-3. 204, 205, 207 on the 281' elevation of the Auxiliary Building.

1310 TMI-2 Manager, Site Operations, assumes command of local emergency (Emergency Director).

i 1310 Local NRC/TMI staff notified. i 1314 The pressure gage downstream of the check valve on MU-P-18 is still in alarm low. It is suggested to start 11U-P-1 A to seat the  :

check valve. By starting MU-P-1 A, there is a risk of more damage being caused. Decision is made not to restart MU-P-lA. ]

1314 Emergency Director and Shift Supervisor discuss securing the Makeup System and maintaining pressure using the Standby Pressure Control (SPC) system. It is noted that the SPC system has always been operated in parallel with the Makeup System. By securing the Makeup System, there is the risk of losing the reactor coolant pump seals.

1315 Licensee senior management and communichtions personnel notified of local emergency. i 1316 There is a suspected tubing failure downstream of MU-V1758.

1317 Emergency Director directs Shift Foreman to place SPC system on recirc.

1318 Shift Foreman informs Emergency Director that SPC-P-1 A is on recire in preparation for fiakeup System isolation. Emergency Director requests a survey of the Makeup System to determine the location of the leak.

1320 NRC Senior Resident Inspector is briefed of the situation by the ,

Emergency Director and the Shift Supervisor.

i 1322 Two mechanics are dispatched to Unit-2 HP control point as the repair party to get suited for possible entry into the Auxiliary Building. l 1330 There is discussion in ECS about the pressure switch by the door of MU-P-1B cubicle. There is concern about switch location so that exposure would be minimi:ed if maintenance was performed on this switch. It is estimated that the entry team will be ready in five minutes.

1333 Confirmation is received that there is 2-feet left in the Auxiliary-Building sump (approximately 3000 gallons). ]

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TIME EiENT (cont) 1335 TMI-2 Director contacts Emergency Director for status report. He indicates that MU-P-1B is running, operations is reacy to isolate

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7 c;m, %xiliary Suilding sump level is rising at a;;:rcximately E 30m.

13-; :2 Department attempts to verify whether low discharge pressure alar-i: valid.

1340 Notified the Pa. Department of Environmental Resources. It was discovered that they had already been notified by the NRC.

1351 Communication Services representative reads draft news release to Emergency Director. Makeup tank level continues to drop. Operations '

is making up to the tank to maintain level.

1354 TMI-2 Director arrives in the Control Room.

1359 The Emergency Director is briefed of possible water movements.

Options discussed are:

1) Move Misc. Waste Holdup Tank (MWHT) into neutralizer feed tanks.

2) Pump Auxiliary Building sump to MWHT.

1402 MU-P-1B pressure gage alarm is confinned valid by I&C Department based on measuring field contacts.

1406 Emergency Director directs Shift Supervisor to proceed to isolate Makeup System and maintain RCS pressure using the SPC system.

1410 The Emergency Director is informed that there is five hours capacity in the Auxiliary Building sump at the present leak rate.

1415 The Emergency Director is informed that there is 500 gallons in the SPC mix tank. At the present loss rate, there is approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of water in the SPC system.

1415 The preliminary report from the inspection team is as follows:

1) 1.5 R/hr at door to MU-P-1B cubicle.

2) The leak is from an instrument line in the MU-P-1B cubicle. -

1 a) The leak is 3-feet into the room just to the left of the doorway, i

b) Line No. 1762 B is leaking,

3) No leak in'MU-P-1A cubicle.

4) The team did not inspect MU-P-1C cubicle because they obtained 4 R/hr reading at door.

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4 S l T!KE EVENT (cont) 1415 Shift Foreman reoorts to Emergency Director that the Makeup System (RCP seals) is isolatec from tne RCS.

1423 M -;-lE is secured.

14;5 r.e repair party is ':Ein; de:riefs: *: FF centrol ;eint.

1428 First press release issued by Cc-~d:stions Services. i 1429 The Shif t Supervisor informs the Erergency Director that the  !

instrument line must be isolated so that the pump is not air -

bound. The reason is that there is no way to vent the pump.

1435 There is indication that the leak has stopped. ,

1440 Preparations are made for repair party entry. The briefing of i the repair party will cover the following areas: p

1) Isotopic mix of airborne. I

2) Best surveys available. (

3) What was seen specifically.

4) Look at pictures.  ;

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5) Compare pictures with what was seen.

6) ALARA briefing. j

7) Control Room comunications and permission. ,

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8) Plan of attack.

9) Contingency plans.

10) Discuss exposures. f 1445 MU-V12 appeared to be leaking through (seat leakage) based on a slight decrease in makeup tank level with the valve shut.

MU-V12 is the suction isolation valve between the makeup tank and makeup pump suction header, ,

i 1445 Obtained photographs and additional drawings for further investigation ,

and assistance for _ repair crew memoers. i 1453 It is recommended to isolate the instrument rack because the rack ,

l isolation valve is right inside the MU-P-1B cubicle. The Emergency. ,

l Director is concerned about losing other vital instrumentation and '

l requests what other instrumentation will be lost.

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TIME Ei/E.',T_ (con:) i 1457 It was reported that.the instrumentation on the rack consists.of tne pressure Siarm, a local pressure gage and space heaters.

1503 Tne Er.er:ency Lice;;ce instructs tne Shif Foreman Oc lock 6- ne ri s 1n2 runen rescinos anc cneck for inconsistar.cies fr:.r ;rs'.i!.:I f

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. M s 75a:ic; . } i is a : heck to see if any otner plant parameters are :er.a,1c; erra::c.

e 1520 Pa. Ospartment of Environmental Resources notified of updated plant status.

1525 Decision is reached to send two repair party personnel into the cubicle to shut both the instrument valve and the root valve.

1530 The Emergency Team Management agree on the following course of action:

1) Shut both instrument valve and root valve.

2) Open MU-V12.

3) Confirm leak contained (visually). ,

4) flake a water balance inventory for the primary system.

5) Remain on the SPC system.

6) Prepare makeup system for restart if needed in the future.

1530 Debriefed the NSS inspection team who verified the leak.

f 1542 Complete briefing of repair party entry team for closure of instrument rack isolation valve and MU-V175. Repair party consists of one HP technician and two repairmen. 3 1545 Repair party is released to enter and secure valves.

1608 Repair party confirmed closing MU-Vl75B and instrument valv,e.

1610 Both valves isolated. -

1515 -Repair party exits Auxiliary Building.

i 1637 The readings Emergency)

(max for the Director two initialwasentry advised HP technicians.by HP of the fio extremity TLD overexposures were reported.

Second press release issued. .  :

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TU;E EVE l.T_ (cont) 1700  % chage in activity or radiation levels.

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and tr.e lea' ..as inceed termir.atsc. Tne foii:.;vg is tre sequence :

events and toe ensoir.g rep;rt ;f :ne 5 :.t.: : ~ ?. . .2ives.

1820 Maintenance man enters :<'J-P-lE cubicle :: ' r/sWy condition of instrument line.

1842 Individual exits.

1850 Valve status debrief.

Entered the cubicle and found that the capped instrument valve had carried away taking it's connecting fitting with it. A minor drip was still evident at the rupture point valve MU-V-175B was checked shut and the drain valve was checked out.

A compression fitting cap was placed at the T and stopped all further leakage. The valve which had carried away was located en the floor and moved to the wall under the instrument rack.

Observation of the cubicle showed that it was almost dry. There was no evidence of any spray damage in the compartment.

Individual's dosimeter indicated = 35 mrem.

1855 Secured from the local emergency based on air samples in the Auxiliary Building.

2030 Final press release issued.

As noted in the above sequence, the apparent cause of the Makeup System leak was dislodgement of the 1B makeup pump discharge pressure instrument valve, upon starting the 1A -

makeup pump for testing. It is not considered feasible or beneficial to assess the contribution of the instrument line fitting to the incident due to radiological considerations.

2. Corrective Actions In order to minimize a recurrence of this type of event, several precautions are receiving an engineering evaluation by the licensee. These actions include operating only one makeup pump at a time and isolating all instr' msr.tation that is not required for pump operation or system operation in the present plant configuration. The isolation of all superfluous instru-mentation would reduce the number of comoression type fittings )

which may become a source of leakage. These actions will be described in the licensee's thirty day written report of the )

event and reviewed by the NRC/iNI staff.  !

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In orcer to immediately improve tne operational prepare ness for put.enciai reicaacs, a.c I::-: ..s..cgar, Site Opsrcti:::, -

iss;ed ? -e-arandum'en February 22, 1980. The memorandum stated tnat in the future wnenever a system / component change i s -i s. :_..... .;; ...: ...; ... .. . celease Cf ri i;- -

act 4vd -" e-ar=t ons .nenart ent cersonnel should be suited-up i

ar.d reah to go ir.to the building / area to perform surveillance anc/or to ce ready to tuse ccrrecti.e measures, as appropriate. -

This policy nas seen transmitted to all Operations Department supervisory personnel.

3. Findines ,

a. Notifications to outside agencies (including NRC) were in compliance with existing approved emergency procedures.

The event was properly classified as a local emergency in accordance with the approved Emergency Plan in effect at '

the time of the event. It should be noted that the plan's local emergency procedur,e required no notification to outside agenr.ies. However, the staff believes that the licensee should have notified the appropriate state and local officials of the occurrence in recognition of l the public sensitivity to the activities being performed at TMI. As a result of this event the licensee has gedified his emergency procedures to include items of i potential public significance.

The licensee has initiated interim measures to upgrade ,

the Emergency Plan to the lates.t guidance (effective February 29,1980) on notifications to the NRC through the use of the OPX telephone network.  ;

Communication problems with the OPX and Health Physics Network (HPN) lines during the event have been documented in separcte NRC office correspondence. l D

b. The leak was not isolated until approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> into the event. The licensee gave the following reasons- .

for the apparent long time interval: l

-- The radiological assessment and leakage rate'of '

about 9 gpm did not warrant a rush into the unknown '

affects from a Makeup System Isolation. These unknown affects are described below.

-- The SPC (alternate system for RCS pressure control)- [

was never operated with the Makeup System isolated. '

.It was not known what affects, if any, would occur on Natural Circulation in the RCS with the Makeup j System. isolated.

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-- The exact source of tne leak was no precisely ,

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-- Since the nature cf tne leak '.;as unknc.;n, reliance ,

on F.aseup Tank neac pressLre l!.igh; r..:. ;. .i ;.fficient  !

force to quickly identify tne leak witn ris;ec to exposure and release censiderations.

t The NRC/TMI staff acknowldeges the licensee's logic and decisions for leak isolation. In light of the potential radiological consegunces (total S/y 116 uCi/ gram) of the j

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leak, we believe the licensee should have responded more quickly in making the decision to isolate the Makeup i

System.

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c. In the area of contingency plans for the recovery mode, 1 no Emergency or Abnormal Procedure deals specifically with leak isolation on the Makeup System. However, the operating procedure for the SPC System does give direction ,

on isolating the Makeup Pumps.

This Operating Procedure was used during the event to e isolate the Makeup Pumps.  ;

The LOCA Procedure (OP 2202-1.3) considers the Makeup  !

System part of the RCS, but it is a preaccident procedure, ,

and it is somewhat outdated with respect to present plant conditions.

The issue of upgrading preaccident procedures (especially Emergency / Abnormal Procedures) was addressed in a previous '

inspection by the NRC/TMI staff. This included the incorporation of Temporary Emergency Procedures into the formal Facility  ;

Procedure System. j Progress in this area has been noted with respect to ,

operating procedures. However, in the area of Emergency Procedures, progress has been relatively slow.

The NRC/TMI staff will place increased erchasis on upgrading  ;

of Emergency / Abnormal Procedures. ;l

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Contingency plans continue to be reviewed by the licensee I and will be followed by the NRC/TMI staff. j

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D. Radioloaical Evaluation ,

1. General  !

The February 11, 1980, makeup system. instrument line failure 1 was calculated to cause a total leakage of 1,000 gallons of  !

- primary system water. (total. 3/y 116 uCi/ gram) to the Auxiliary l

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Building sump via the floor drain system. As a resuit of :nis leak, ai roorne act iv ii.y ii.ci ease- iicai ...e . . .c. . . ; , , - . . . , . . . . -

and the other general areas in the lower levels of the Auxiliary Building. Individuals working in the Auxiliary Building, at tne time of tne leak, were evacuat.c. dos 5 .m . e .c rgec.:j ..a declared. Upon announcement of the local emergency onsite NRC/TMI staff members were immediately dispatched to the Unit 2 Control Room and to the Unit 2 Healtn Physics Control Point. Personnel entries to the Auxiliary Suilding were observed by the NRC/TMI staff members at the health physics control point. Dosimetry data for all personnel originally present in the Auxiliary Building and those who participated in the survey and repair teams, showed exposure well below the regulatory limits. All releases to the unrestricted area were calculated by the licensee and verified by the onsite NRC/TMI staff. A total of about 300 mci of Kr-85 was released.

Offsite dose estimates were made by the licensee and independently verified by the NRC/TMI staff. Offsite dose calculations indicated that the dose to a theoretical individual at the site fence throughout the release period was minimal.

The radiological sequence of events were recorded by onsite NRC/TMI staff and discussed witn the licensee. The following is a sumary of radiological sequence of events:

TIME EVENT 1220 started Makeup Pump-1A (MU-P-1A) to test pump operability  ;

s 1230 Local Continuous Air Monitor (CAM) alarming near Decay Heat Vault s 1240 Grab air sample 10-7 uCi/ml gross Beta-Gamma 281' elevation S 1250 Eleven people evacuated from Auxiliary Building 1258 Local emergency declared ,

s 1300 NRC inspectors arrived at Unit-2 Control Point s 1305 Inspectors observed and reviewed the following:

Air sample data Radiological survey data Respiratory protection equipment ,

Dosimetry Protective clothing Briefings 1305 Wind speed: 14-16 mph Wind direction: 210 -240 s 1310 NRC/TMI staff members examined the Auxiliary Building vent monitors and noted a slight increase in gaseous activity

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T_I :_E E.ENT-(cont) 1:1 ? 0 -:ite survey team is-formed

.;_i ...-:..y avrvey team sei. ;. ......- . .. -s 1325  :<-site survey team repor: r,c isvsis above bacngrounc at

ortn Eridge 1325 Gra; samplo at Decay Heat 's.lt : x 10-7 uC1/ml.

• Grao sample at middle of Aasiliary Suilding 281' elevation 6 x 10-9 uCi/mi Grabsamp]ginnorthestcornerofAuxiliaryBuilding 6 x 10- U uCi/mi 1350 Grab sample Decay Heat Vault area 2 x 10-7 uCi/ml 1357 AM-4 is out of service 1358 AM-3 and 4 are brck in service ,

1400 Fuel Handling Buildigg near intermediate coolers at .

281' elevation 10-' uCi/ml. Decay Heat Vault 10-7 uC1/mi 1405 Initial entry team entered Auxiliary Building and observed pump leaking in MU-P-1B and observed initial dose rate of 1.5 R/hr/ gamma and 2 Rad /hr/ beta at the doorway of MU-P-1B Team also observed a dose rate of 4R/hr at the door to MU-P-lc 9 1435 Grab sample at door to Mb-P-1B 4 x 10-7 uCi/ml 1505 It is confirmed that airflow is into the Auxiliary Building 1518 Air activity near the Decay Heat Vault 3 x 10-8 uCi/ml 1528 No increase in radiation levels at the North Gate 1600 Repair tenin enters Auxiliary Building and remain in MU-P-1B less than two minutes 1615 Repair. team exits Auxiliary Building. Maximum dose l received was 160 mR (gamma) whole body for one person-and 150 mrad (oeta) whole body for a second person -c 1615 Survey done as Repair Team entered 'MU-P-1B indicates dose. rates up to 140 rad /hr (beta) and up to-15 R/hr (gamma) .;

I 1700 No ' change _ in activity or radiation . levels l

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a. rs-m? EVENT (cont) iC Maintanance can entered MU-P-lE C bicle t: verify

' hat leak was c^ ~e *

• io,1 Maintenance man exited A uil W , ".ild b;.

ra:sh ed by individual was 15 m? (camma) wnole ocdy and 95 mrad-(beta) whole body.

1855 Local emergency terminated.

The NRC/TMI staff. reviewed.the response of the Health Physics (Rad / Chem) Group to the local emergency and verified compliance with certain sections of the' Site Emergency Plan Implementation Procedures and 10 CFR Part 20. Emergency response was reviewed against implementation. procedures pertaining to local emergency response, re-entry operations, post accident recovery, notification, and the classification of the emergency. The licensee's response relative. to requirements of 10 CFR Part 20 was reviewed as it pertained to instructions to workers, personnel dosimetry, external and internal personnel exposure, and radiological surveys.  ;

2. Findinos

a. Site Emergency Plan Implementation In accordance with Procedure 1670.1.,a report of a significant increase of airborne radioactivity reported by the Rad / Chem Control Point led to the classification and page announcement .

of the condition as a local _ emergency. An evacuation of the Unit 2 Auxiliary Building was ordered. After the building was evacuatec, emergency teams were assembled, protective clothing, dosimetry, and respiratory protection requirements specified; and briefings were conducted before individuals were dispatched to make either radiological surveys or perform operations to secure the valve leak .

causing the rise in airborne radioactivity. Entries into the Unit 2 Auxiliary Building were made to verify the location.of the valve leak, to perform surveys, to secure the valve leak, and then to recheck the status of the valve leak.

After the valve leak was. secured and the Auxiliary Building air sample results: decreased to normal levels'(of the .

order of magnitude of.10-10 uCi/ml in Auxiliary Building general areas) the licensee terminated the. local emergency -

classification and decontamination of the Auxiliary Building corridors began. (The. corr _idors became contaminated when  ;

personnel leaving the makeup pump-room, a high contamination area, spread this to the relatively. low. contamination area.)

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ine licensee's implementation Of =e s :: =._se;ency pian

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o. Raciologica; Controls Tne ',R:/T C Inff revis..ed the res;;r.fi :: :ne local emer;ents at tne sacf . en ontrol Point, wi:n ::5_: ; a u.;..icc; Of tne per::~ El of tne local de:ecti:". sc3katica., and exposure crc.cC Of the radiological ::~f'ti:u in the Unit 2 Auxiliary Building.

The continuous air sampling readings and " grab" ai_r i samples indicated airborne radioactivity concentrations of approximately 1.95 E-7 uCi/ml on the 281' elevation ,

and 1.13 E-8 uCi/ml on the 305' elevation. An area' continuous air monitor had alarmed at 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br />. This information was comunicated to the Control Room and a local emergency was announced., Personnel were instructed to evacuate from the Unit 2 Auxiliary Building, i l

Personnel, who made re-entries into the Auxiliary Building, made entry under RWP 808-0862, " Health Physics Coverage  ;

and Surveillance." All personnel were required to wear a (

self-contained breathing apparatus for entry to the Auxiliary Building. Individuals who entered the area of the leaking valve, Make-up Pump Room IB, on the 281' elevation, wore dosimetry to monitor extremity, skin, and whole body exposure. Protective clothing requirements included coveralls, plastic rain suits, and heavy rubber boots and gloves. The on-site NRC/TMI staff reviewed the licensee's exposure summary of the individuals who made entries into the Auxiliary Building during the local emergency. Whole body exposures ranged from no indicated exposure (for an operations individual stationed as a back-up) to 100 mrem (to an operator who entered the Make-up Pump Room).

Extremity exposures ranged from no indicated exposure to 70 mrem. Skin exposure ranged from no indicated exposure to 100 mrem. None of the-limits specified in 10 CFR 20.101,

" Exposures of Individuals to Radiation in Restricted Areas," were exceeded as a result of the entries.

5 The NRC/TMI staff reviewed a licensee radiological survey of the Makeup Pump Room 18, dated February ll,1980, taken to evaluate conditions for entry to the room. ~ It was noted from the radiological survey that the work-area '

and the general area gama and beta radiation ' dose rates were specified. However, the beta radiation dose 'r'ates-at contact ..ith either valve (which licensee operators manipulated during the emergency) were not.specified.

One survey taken in the general arer. of one valve udicated c a beta radiation dose rate of approximately 40 rad /hr, beta radiation, and "less than" 8 R/hr, gamma radiation.

It is noted that although personnel extremity exposures L were relatively low for the individuals who: manipulated

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tne valves,10 CFR 20 states, uncer tne sa:se: tun on "Precasticr. cry Pr:::9.-: : , " " S e - * * # ?n' M h surveys necessary to comply with Part 20 shall be made, in this case regarding extremity monitoring. Inis item is scresci d; ;ic....; L . . . ':: -- :- T :- : -

representatives to determn.e wnetner c:ner radiological surveys would indicate Ina a oeta raciation sarvey was taken at contact ..ith the valves in questicn befcre 7ey were manipulated by the operators.

Air sample results taken during and after the local emergency were reviewed by the NRC/TMI staff. An NRC staff member asked licensee representatives whether an air sample was taken in Makeup Pump Room 1B. The licensee representative stated that there were two air samples listed near that location but it was thought that they were taken in the corridor. It was noted that Makeup Pump Room IB was under a negative air pressure such that the air flow was from the corridor into the room. Air sample results from the corridor were of the order of 10-/ uCi/ml . Therefore, the actual room air concentra-tions could be higher. It was further noted that 10 CFR 20.103, " Exposures of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas,"

requires in Section 20.103(a)(3) that suitable measure-ments of concentrations of radioactive materials shall be used. The NRC/TMI staff detennined, through review of the Sign-In Sheets for RWP 808-0862 and the air sample log sheets for February 11, 1980, that a suitable air sample to represent the air concentrations in Makeup Pump Room IB was not taken (either at the time of room entry or at the location of the entry inside the room). The Radiological Field Operations Supervisor and the Rad / Chem Technicians, who took air samples during the local emergency, confirmed that no air sample was taken within Makeup Pump Room 1B on February 11, 1980. The item is considered a potential item of noncompliance with 10 CFR 20.103(a)(3).

The licensee has calculated MPC-Hours for the individuah who made entries and these calcuations show that no MPC-Hours need to be assigned. (However, the basis for calculation of the MPC-Hours mt:rt be based upon a representative air scmple result.) The item regarding calculation of MPC-Hours is unresolved pending discussion with licensee represer.tstives as to the appropriateness of the air sample data regarding the specific location of air sample.

The licensee performed whole body counts for individuals who were either in the Unit 2 Auxiliary Building at the initiation of the local emergency or who made entries c

during the local emergency. All of the results were below the licensee's screening limit, of 3% of the Maximum Permissible Organ Burden for Cesium-137, which was the principal isotope comprising the airborne radio-activity increase.

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--+=~4a= tad d" ring 5 the course of the local emeroency. Two individuals received skin contamination on tne forearm anc nanc

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ina:ec to less tnan 1,00C dpa. The c:ntanica:i:n occ.cred unen :ne two indiviouais were at toe Rac,Cne...entrcl . i

?:i .: nd changing out cer:3-4 !:ed air bet:1es for pers.:r.r.el who had entered ::.e r.iliary hildin;. The

-d : dndividual received ceate-ination to his left hand, wri:t and hair ranging from 5,000 dpm to 8,000 dpm.  ?

Records indicate that the wrist and hair were decontam- "

inated to less than 1,000 dpm but that the hand remained contaminated at 8,000 dpm. This individual had been a Rad / Chem Technician in the Unit 2 Auxiliary Building ,

during the local emergency. The licensee's contamination ,

record did not indicate specifically how the contamination '

occurred and the individual has since terminated his employment. This item will be followed up to determine l the acceptability of releasing the individual with the fixed 8,000 dpm skin contamination level.

c. Releases and Offsjl) Dose Calculation  ;

The radiological monitors for iodine, particulate and  ;

I noble gases in effluents were examined by the NP.C/TMI staff and estimates of total releases were alculated.

On February ll,1980, about 300 mC1 of Kr-85 was released to the environment as a result of the instrument line leak in the Auxiliary Building. This calculated release ,

was based on an instrument sensitivity factor for the  !

AM monitors, which was provided by the licensee. Neither particulate nor iodine samples showed any appreciable 5 increase on the AM monitors (AM-2 through AM-5). Auxiliary ,

1 Building exhaust monitor AM-1 was out of service at the time of the release. This release was well below the regulatory limits of 10 CFR 20 and the TMI-2 Environmental  :

Technical Specification (ETS). -

Preliminary offsite dose calculations were performed by r the NRC/TMI staff. The total skin beta and whole body '

deses at the highest 7/Q location were approximately O.0013 mrem and 0.000015 mrem, respectively.

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f ebrua ry 12-T3.1980 '

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, Persons Contacted .

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Metropolitan Edison Company-TMI-2

( ' , :?%::, 9.e.

Mr. J. J. Carton, Manager, m!-2 Operations ' ' ?i -

, Mr. J. J. Chwastyk, Supervisor of Operations r

Mr. R. F. Tenti, Senior Site Quality Assurance Auditor Mr. Y.. M. Frederick, Supervisor of Results. Radiochemistry ,

, Mr. J. W. Garrison, Shift Foreman Mr. C. L. Guthrie Shift Forman

![y Mr. G. A. Xunder, Supervisor of Compliance '

Mr. J. A. Renshaw, Radiological Field Operations Supervisor Mr. P. E. Ruhter, Radiological Engineering Supervisor i Mr. B. G. Smith, Shift supervisor

^

B. Documents Reviewed r

Station Administrative Procedure 1001, Revision 4, September 21,1979, "THI Document Control;"

Health Physics Procedure 1631.2, Revision 5, October 30, 1979

" Sampling of Reactor Building" (Unit 2 only);

Statiun Radiation Onergency Procedure 1670.1, Revision 6 February 13,1978, " Local Emergency Procedure;"

Metropolitan Edison Company Inter-Office Memorandum (K. Frederick to D. D. Elam) TMI-II-R-4015, dated January 7,1980, " Reactor Building Atmosphere Sampling Using HPR-227;"

Metropolitan Edison Company Inter-Office Memorandum (J. J. Barton to Distribution), THI-II-R-6351, dated February 15, 1980,

" Procedures-Approval and Control;"

Supervisor of Operations, Memo No.,2-80-3. dated February 20, 1980, "Use of Procedures;" ,

Personal Memorandum p572 (J. G. Herbein to G. P. Miller),

dated February 21,1980, " Procedure Team," and, *

-- Sample Request Tag Sheets for Unit No. 2 HPR 227, Reactor -

Building Particulate Samples Nos. 29867, 29868, 30403, 30404, l 31210, 31211, 31825, 31826, 32452, and 32453. ,.

l l C. Release Evaluation .

1. General On February 12,1980, at 6:50 P.M.. a sample line recircu- l 1ation purge was initiated in preparation for obtaining a .

sample of the Heactor Building atmosphere. The purge was -

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continued for more than 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> prior to getting tne sim;ie

...; i..".t'.., t.'.e line at 12:30 P.". rg;_,e q. $3, togn Durino the recirculation period an increase in Auxiliary Building radiogas monitor (AM-5) activity was notec by tne +

.. ..~.. ...ft radiation specialist. TP5 :t:tt.:t'- ' ::

recortec to both the licensee and NRC/TMI site staff super-visory personnel . Initial reaction by botn tne licensee and the MRC/Tal staff personnel was that the increase was only sligntly above the normal activity levels and well within the allowable release limits. No action was taken to stop the gas  :

sample evolution which was attributed as being the cause of the release since this was the only evolution occurring in the plant during this period. However, extensive review of the  ;

release was subsequently performed by both the licensee and the NRC/TMI site staff. The preliminary evaluation results of the gas sampling evolution has identified several areas of concern as described below.

2

2. Findinas

a. Procedure Controls and Adherance The shift engineer who implemented the air sample pro-cedure did not use the effective procedure-(Revision 5) at the time of the event. This resulted because the individual did not obtain a controlled copy of the procedure as established by Ap 1001. The procedure used i by the shift engineer was a draft version of a proposed revision to 1631.2. This draft was properly approved both by the licensee and NRC/TMI staff, but it was in the typing stage, and was not yet effective (final copy not in the Control Room).

The Control Room operators were aware of the sample in progress since it was discussed at a preshift briefing and the Control Room operators manipulated valves as part of the initial lineup procedure. However, one shift foreman on duty at that time indicated that no one in the Control Room referred to the procedure (Revision 5) from the Control Room files during the sampling evolution.

The effective procedure (Revision 5), contained criteria i for tenninating the sampling if an excessive increase in air activity is observed (three times the reading prior to sampling). Our critical review of the strip charts '

following this event shows that the criteria had been .

exceeded during February 12-13, 1980, as well as~during previous occasions-(paragraph 2.c).

The failure to follow document control. procedures and the resultant failure to properly implement procedure HP 1631.2 will be subject to subsequent enforcement action.

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b. Froce: re :::lementaticn Training Based on a discussion with the responsible engineer's supervisor of tr.e air sampie event, tne engineer 1:+icaentir.g T.. - '

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Ine estcolished acmir.istrative controls of :ne 11: uses.

ine engineer is a ce ter c7 cne of tne contrac;or s e r . u.e

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;;s providec f:r  : r:::very staff.

Licensee management ir'i rted that the engineer's surervisor was responsible for conducting training of these ad inistrative controls. The supervisor indicated that this responsibility was not clearly delineated. The supervisor did possess a general familiarity with AP 1001 but he stated that the specifics of how to get a control procedure was not discussed with the engineer who implemented the air sample procedure.

The licensee's initial corrective action following this

~

event is summarized below.

-- An internal memorandum from the Manager, Site Operations, was issued to all station personnel (including vendor personnel) reiterating procedure control require-ents. Further, all supervisors are responsible for ensuring that personnel who utilize station procedures read and understand Ap 1001, TMI Document Control. In addition, this action was to be documented by each department supervisor.

-- Further responsibilities to Shift Foreman in this area were reiterated in an internal memorandum with additional measures to ensure the Control Room is informed of all procedural implementations during the shift.

This effectiveness of these measures will be followed by the NRC/TMI Technical Support Staff.

Issues that remain to be discussed with licensee management are as follows:

-- More specific training (i.e., classroom sessions conducted by licensee personnel) for contractor personnel who use licensee procedures is required. -

The above measures are considered interim measures and classroom training would be appropriate when Ap 1001 (a statien procedure) is converted to a Unit 2 specific Acministrative procedure.

-- The guidance issued in the above referenced internal memoranda must be formalized into the new administrative controls for Unit'2.

c. Release and Offsite Dose Calculations n,,rino the ceriod of February 12,1980, at 1951 hours0.0226 days <br />0.542 hours <br />0.00323 weeks <br />7.423555e-4 months <br /> ihroucnFebruary 13,1980, at 1245 nours, the total ,

_ _ . : .. w in: tna T.ea;;;r s.' ;. .1 - - -

1.=$ l$ 5chhEea, o. . ,v tne NRC/TMI staff to oe 4.1 Curies gf ,

d~25.

Tre u-85 release was based on integratgn g toe rise ca tne ait 2 vent radioga; moni cr cnart e.n-:,

As prt Of this evaluation tne NRC/TMI staff reviewed the Unit 2 radiogas releases during the months of January and February 1980. Approximately 80 Curies of Kr-85 have been released from Unit 2 during the month of January 1980.

Part of this release was due to leakage in the hydrogen purge line during recirculation operations since it was known by the licensee that this system had leaks in it. ,

i For the month of January and through February 13, 1980, 18.1 Curies of Kr-85 have been released during the hydrogen purge line recirculation operation. These releases are shown below.

HPR-227 Recirculation Times Kr-85 Curies Released 1/2 :t 1445 to 1512 0.07 1/3 at 0510 to 0605 0.16 1/9 at 1110 to 1300 0.30 '

1/15 at 1815 to 1/16 at 1425 3.10 1/23 at 1015 to 1115 0.30 1/30 at 0108 to 1433 4.60 2/6 at 0250 to 1700 5.50 2/12 at 1915 to 2/13 at 1245 4.10 These releases are well below the regulatory limits of 10 CFR 20 and TMI-2 Environmental Technical Specifications (ETS).

i Preliminary offsite dose calculations for the February 12-13 release were perfrmed by the NRC/TMI staff. The total skin beta and whole body gamma does at the highest X/Q location were approximately 0.017 mrem and 0.00021 mrem, respectively.

The NRC/TM1 staff reviewed the licensee's strip chart recordings for eight releases during January and February ~

and noted values as indicated by the AM-5 (gas) monitor.

j These values as shown in Table 1 indicate that six of the eight releases resulted in AM-5 monitor readings at AM-5 greater than (or equal to) three times the monitor reading prior to the release which is in violation of the effective procedure (Revision 5) for this sampling evolution.

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Tne :J.C/TMI staff note: Inat tne licensee's AM-5 : r en:e:

......,..u,6 .u.. .~..............:... ..:. t ; / , ..'.h.'. , i

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naadle fluctuat ion, nav not have indicated a value .

greater than three tines tne reacing prior to sampling.,

. . . . - . . . . . . . . . . . . . . . . . . .. .. . . ..:a :. :. .:

c' tne values as read bv licer.ses c;erators are less tr.ir.

r.ost of tr.e values listed ir. T::ie 1. However, Ins J,:,/TMI staff n:tes that -h.. . ..act t..o instar.:ss #:c whicn the licensee was aware ..ica AM-5 values t.ere greater than three times ths .1;e prior to the release. r

d. AM Monitors Calibration The Auxiliary Building exhaust monitors calibration procedures and calibration records for Kr-85 were discussed with the licensee. The licensee stated that the Auxiliary Building exhaust monitors AM-1 through 4 were calibrated for Kr-85. The NRC/TMI staff reviewed the Auxiliary '

Building monitors calibration data and noted that Kr-85 was used to calibrate AM-1 through 4 monitors. "he {

calibration data and plots were reviewed by the NRC/TMI i staff and fcund to be acceptable for the four downstream monitors ( AM-1 through 4). AM-5, upstream of AM-1 through 4 and in series, was designated by the licensee to ,

be their " Official" radiogas release monitor rather than i AM-1 through 4. Monitor AM-5 is used to monitor the '

entire flow of the Auxiliary Building exhaust prior to its branching into four exhaust ducts (1, 2, 3, and 4) which are monitored by AM-1 through 4 respectively. -

Initial review of AM-5 calibration records showed that AM-5 was not calibrated for Kr-85.

The Auxiliary Building exhaust (AM-5) monitor calibration -

procedures and calibration records for Kr-85 along with procedures for calculating releases of Kr-85 are still being evaluated by the NRC/TMI staff.

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TABLE 1

--.....,e-. n- , . ., g ..n.,, .n o o p n 7,,,g e

4 A"-5 I'.cnitor Readings" Reading Reading Prior to Sampling During Sampling 1/2/80 30 60 1/3/80 30 100*

1/9/80 40 120*

1/15/80 40 80 1/23/80 30 150*

1/30/80 30 200*

. 2/5/80 30 200*

2/12/80 40 125*

" denotes readings during sampling greater than or equal to three times the reading prior to sampling.

' data taken from licensee strip charts as read by NRC/TMI staff.

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':T: :::.' :.' "".I ":":T:' 'I' ..:S

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5.5 Reacin; eacing Price to Sampling During Sampling 40 60 1/2/80 35 100 1/3/80 35 100 1/9/80 40 70 1/15/80 50 100 1/23/80 1/30/80 35 200*

2/6/80 40 200*

2/12/80 40 150

• denotes readings during sampling greater than three times

.the readings prior to sampling.

1. data taken f rom the licensee's " Auxiliary Roof Monitor Calculation Sheet."

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