ML20155E525

Safety Insp Rept 50-320/88-13 on 880806-0909.No Violations Noted.Major Areas Inspected:Defueling & Decontamination Activities & Implementat/On of Radiological Controls & Housekeeping

ML20155E525
Person / Time
Site:	Three Mile Island
Issue date:	10/05/1988
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155E516	List: ML20155E511 ML20155E525
References
50-320-88-13, NUDOCS 8810120328
Download: ML20155E525 (11)

See also: IR 05000320/1988013

Text

.'

-

..-

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-320/86-13

Docket No. 50-320

License No. OPR-73 Priority --

Category C

Licensee: GPU Nuclear Corporation

P. O. Box 480

Middletown, Pennsylvania 17057

Facility Name: Three Mile Island Nuclear Station, Unit 2

Inspection At: Middletown, Pennsylvania

Inspection Conducted: August 6, 1988 - September 9, 1988

Inspectors: R. Conte, Senior Resident Inspector

D. Johnson, Resident Inspector

T. Moslak, Resident Inspector (Reporting Inspector)

A. Si cara, Resident Inspector

Approved by: / d 8 m 84- /( /N

C. CoTg'ill, CMef, Nactor Projects Section 1A Date

Inspection Summary:

Areas Inspect _ed: Routine safety inspection by site inspectors of defueling and

deccntamination activities, including the proper implementation of radiological

controls, housekeeping, fire protection measures, review of selected events, and

recent management changes.

Results: Licensee personnel conducted clean-up operations in a safe manner. Con-

tamination control measures degraded in the reactor building as a result of plasma

arc cutting operations. Housekeeping conditions have also degraded in certain

areas in the auxiliary and fuel handling buildings. The licensee has recognized

these problems and is taking actions to correct the situations.

G910120329 881005

F t.R

ADOCK 05000320

PDC

.

. .

.

. .

, .

TABLE OF CONTENTS

PAGE

1.0 0verview............................................................. I

1.1 Introduction.................................................... I

1.2 Defueling Operations.............. ............................. 1

1.3 Decontamination / Dose Reduction Activities....................... 2

'

1.4 NRC Staff Activities................................ ........... 3

1.5 Persons Contacted............................................... 3

2.0 Defueling/ Decontamination Activities (NIP 71707)..................... 3

2.1 Scope of Review................................................. 3

2.2 General Findings................................................ 4

2.3 Reactor Building Conditions..................................... 4

2.4 Auxiliary / Fuel Handling Building Conditions..................... 5

2.5 Event Report (NIP 93702)........................................ 5

2.6 Summary......................................................... 8

3.0 Licensee Action on Previous Inspection Findings (NIP 92701).......... 8

4.0 Exit Meeting (NIP 30703)................ .................. ......... 9

4

.. .

, ,

.

.

DETAILS

1.0 Overview

1.1 Introduction

During this reporting period, cutting of the grid forging began. The

grid forging is the third of five plates that comprise the Lower Core

Support Assembly (LCSA) that is to be removed to provide access for de-

fueling the lower head of the reactor vessel. Decontamination of plant

surfaces and sy'tems continues. Three plant areas are isolated from

routine use and placed in an interim Post-Defueling Monitored Storage

(PDMS) status. Five other plant areas are scheduled for verification

to determine if they meet the interim PDMS isolation criteria.

On September 1, 1988, the licensee announced the resignation of Mr.

Franklin R. Standerfer and the assignment of Mr. Michael B. Roche as Vice

President and Director of TMI-2. The turnover process from Mr. Standerfer

to Mr. Roche began immediately and is expected to be enmpleted in early

October. Mr. Roche was formerly the Vice .oresident and Director of

Radiological and Environmental Controls of GPU Nuclear.

1.2 Defueling p erations

Upon completion of clearing loose debris from the grid forging, defueling

crews installed the plasma arc cutting equipment in the vessel and re-

sumed cutting operations. Initially, thirty-three in-core guide tubes

and twenty support posts were severed, then removed from the vessel to

preclude interference with cutting the grid forging. io date, twenty-

three cuts have been made in the northwest quadrant of the forging. An

estimated total of twenty-six cuts are required to completely sever this

quadrant. Of a total of seventy-seven cuts needed to cut the grid forg-

ing into four sections, twenty-seven have been completed.

Progress has been slowed by several factors. During the cutting opera-

tion, the plasma cutting and cover gases acted as an airlift in the forg-

ing to move loose debris ' rom the flow holes and to be deposited in the

bridge drive system of the cutting equipment. This required the cutting

operation to be shut down; the bridge removed from the vessel; the bridge

components disassembled, cleaned, lubricated, and reassembled; and, the

bridge re-installed in the vessel. Additionally, bridge contamination

impeded work progress. Extensive decontamination of the bridge was done

prior to its removal from the vessel. However, as the liquid contamina-

tion dried on the bridge, loose contamination levels increased, primarily

on the defueling platform and the tool repair area of the reactor build-

ing. This required extensive decontamination of the work areas where

the bridge is handled during repairs. Various licensee departments are

,' ...

.

.

2

evaluating different equipment and techniques to resolve these problems.

Further, the material suspended as a result of the airlift effect has ,

interfered directly with the plasma arc cutting process, causing re-cuts

to be made.

While performing plasma arc cutting, it has been observed that small

amounts of Krypton (Kr-85) gas are released when the ceramic fuel frag-

ments are heated. The quantities released are within the regulatory

limits.

The licensee is conducting surveys to cetermine fuel quantities ir other

portions of the Reactor Coolant System (RCS). In parallel with these

surveys, various defueling techniques are being evaluated should fuel

be found to be present.

No shipments of casks containing core debris have been made during this

reporting period.

1.3 Decontamination / Dose Reduction Activities

'

Scabbling, steam cleaning, hands-on decor.'. amination continue in the

,

auxiliary and fuel handling buildings. To date, 120 of 143 cubicles have

!

been decontaminated to end point criteria. The remaining cubicles con-

tain contaminated plant systems that first must be cleaned before the

cubicle is decontaminated. Flushes of these systems are being performed

to lower dose rates in these cubicles.

Filling and draining of the block wall in the reactor building (RB)

basement has been completed. An evaluation is being performed to deter-

mine the effectiveness of the fill-and-drain operation.

Attempts to transfer highly contaminated resins from the "A and "B"

make-up (MU) demineralizers have been unsuccessful. Two attemots to

I employ a hydrolance device through the resin discharge piping into the

"A" MU demineralizers have also been unsuccessful. Presently, no efforts

will be made to transfer material until a thorough examination is con-

ducted to determine the quantities and consistency of the remaining

i material.

l The licensee continues to assess specific plant areas for placement of

'

these areas into an interim PCMS condition. To date, three areas have

been verified to meet the interim PCMS criteria and have been isola;ed

from routine access to assurr that they would not become recontaminated,

nor be impacted by other plant operations. These areas are the seal

return cooler / filter room, the two "1E" switch gear rooms, and the two

"2E" switch gear rooms. Five other areas are scheduled for verification

and eventual isolation from the balance of plant.

I

!

l

,', .. .

.

.

3

1.4 NRC Staff Activities

The purpose of this inspection was to assess licensee activities during

defueling and decontamination activities. The inspectors made this as-

sessment through actual observations of licensee activities, interviews

with licen<ee personnel, measurement of radiation levels, or review of

applicable documents. NRC staff inspections use the acceptance criteria

snd guidance of NRC Inspection Procedures (NIP's). These NIP's were

annotated in the Table of Contents to this report.

1.5 Persons Contacted

During this inspection, the following key licensee personnel provided

substantial information in the development of the inspectors' findings.

--

J. Bondick, Radiological Engineer, TMI-2

--

"J. Byrne, Manager, TMI-2 Licensing

--

• G. Kuehn, Site Operations Director, TMI-2

--

• S. Levin, Defueling Director

--

W. Marshall, Operations Engineer

--

• R. Rogan, Director, Licensing and N; clear Safety

--

• E. Schrull, TMI-2 Licensing Engineer

,

--

"F. Standerfer, Vice President and Director, TMI-2

--

• 0. Turner, Director, Radiological Controls

--

R. Wells, Licensing Engineer

2.0 Defue_139/ Decontamination Activities

2.1 . Scope of Review

The inspector observed and/or reviewed licensee defueling decontamination

activities to: (1) ascertain factual status of such activities; (2) as-

sure proper adherence to applicable procedures; and, (3) select and re-

view significant events warranting further inspection follow-up. The

inspector also trade obseavations in facility spaces with respect to pro-

per housekeeping, fire protection, and radiological controls. The gene-

ral acceptance criteria for this review was Section 6 of the TMI-2 Tech-

nical Specifications (TS),

In performing the obove inspections, the inspectors focused on the fol-

lowing areas of licensee performance:

--

control of operations in progress by supervisory personnel;

--

knowledge of tht task by technicians and support persons;

--

appropriateness of gover91ng documents, including procudures and

Radiation Work Pumits (RWp's);

--

alertness of various controlling station personnel;

. _ _ _ . . _ _ - . _ _ _

-

t

.'. ' ' -

.

.

4

--

assess the quality of implementation of selected evolutions wit-

.ssed; and,

--

assess the material condition of the plant.

The inspections were made at random intervals and during the following

back shift hours (10:00 p.m. ar.d 6:00 a.m.).

Day /Date Time Periods Hours

Thursday, 8/18/88 10:00 p.m. - 12:00 Midnight 2.0

Monday, 8/29/88 5:00 a.m -

7:00 a.m. 2.0

Saturday, 9/3/88 10:00 p.m. - 12:00 Midnight 2.0

2.2 Gene _ral Findings

As a result of the routine and off-shift review noted above, the inspec-

tors identified no major discrepancies. In general, licenseo represen-

-

tatives properly implemented procedures, except as noted fo- 'rtain

events listed within this report. Addressed below were spe< ie obser-

vations in the area of housekeeping, fire protection,'and event review.

Of particular note was the licensee's low thrtshold for documenting and

reporting off-normal events that were below reporting requirement thres-

holds,

2.3 Reactor Building Conditions

On September 8, 1933, two NRC staff members entered the Uni 2 reactor

building (RB) to assess industrial safety and radiological conditions.

Housekeeping was found to be adequate but not exemplary. Tripping

hazards were identified in that an excess number of hoses were located

on the north / northwest area of the work platform and an excess number

of electrical extension cords were on the southeast side of the platform.

j Walkways were congested due to equipment and systems that were staged,

being operated, or being repaired in available areas. Overall, most of

, the equioment was stored in a reasonable manner.

Contanination control is a current problem. High levels of loose con-

tamination associated with tools / equipment removed from the reactor

vessel cause the need for multiple layers of protective clothing and the

use of respirators throughout the RB. This negative trend in contamina-

tion control measures is a contributing factor to the rising number of

skin contaminations.

Through discussions with licensee representatives about their observa-

! tions, NRC staff members determined that the licensee acknowledged the

, negative trend in housekeeping and contamination levels anc is taking

actions to ir. prove coaditions.

_ - - _ _ _ _ _ _

.'. **-

.

5 ,

2.4 Ae3111ary/ Fuel Handling Buildings Conditions

Resident inspectors conducted inspections of plant areas during the nor-

mal working hours and on the off-shifts to assess industrial safety and

radiological conditions. As a result of these inspections, the inspec-

tors concluded that performance in the housekeeping area has trended

downward on the 281-foot elevation of the auxiliary building (AB) and

fuel handling building (FHB) and on the 347-foot elevation cf the fuel

handling building. This condition was evident by:

--

hoses and electrical cords hanging down from the overhead and being

scattered on the floor of the corridor in the 281-foot AB;

--

various materiais and equipment staged in the 281-foot AB corridor

that constricted personnel traffic, blocked fire extingaishers and

hose reels, and provided a large inventory of combustib'e materials

in a small area;

--

large amounts of plastic and paper materials randomly staged in the

281-foot FH3; and,

--

various and sundry pieces of equipment, including portable survey

instruments, nuts, and bolts, and combustible trash oa the floor

on the 347-foot FH3 near the control panels for the Submerged De-

mineralizer System.

Inspectors notified licensee representatives of their findings. The

licensee acknowledged the observations of the inspectors and took Actions

to improve overall conditions.

No violations of regulatory requirements were identified.

2.5 Event Review

A number of events were identified by the licensee in their internal

reporting system and they were reported to the resident inspectors.

2.5.1 Sp1Il in Fuel Handling, Building

_

The inspector examined the circum.tances that resulted on a

small spill of contaminated water from the Reactor Coolant

System (RCS) on to the floor of the fuel handling building on

September 5, 1988. Through discussions with licensee repre-

sentatives and record review, the inspector determined that

a spill of about 50 gallons of RCS occurred when a 55 gallon

drum overflowed as a result of a failure to open a drain valve

, on the drum, if the valve had becn open, the drum would have

<

drained to a floor drain aid would not have overflowed. The

. - ,

. - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

.

. .

• • -

t

6

drum is a vent catch for RCS being processed through the de-

mineralizer (K-1) sub-system of tb? Defueling Water Cleanup

System.

Through reviewing the "Unit 2 Spill Form," the inspector de-

termined that the Radiological Controls Department had taken

expeditious action to evaluate, decontaminate, and survey the

affected areas.

Additionally, control room personnel had submitted an Engi-

neering Services Requesc to have plant engineering troubleshoot

the sub-system to identify additional factors that may have

contributed to the spill. As a result, plant engineers iden-

tified the need to modify the K-1 level control instrumentation

to reduce the amount of RCS vented to the drum.

No violations of regulatory requirements were identified.

2.5.2 Krypton Releases During Plasma Arc Cutting Operations

While plasma arc cutting operations were in progress on the

grid forging, control rocm personnei observed an increase in

the count rate cn the noble gas channel of the RB purge exhaust

monitor (HP-R-225). Subsequently, the Radiological Controls

Department correlated strip chart data with plasma arc cutting

and concluded that noble gas releases occurred when cutting

was performed in the fuel bearing areas in the grid forging.

This off gassing was a direct result of heating the ceramic

fuel fragments during cutting. Through analyzing airborne

samples taken from the effluent flow path, the licensee deter-

mined that the radioisotope was Krypton (Kr)-85.

The inspector discussed with licensee representatives the re-

sults of their evaluation and determined that the Kr-85 con-

centrations released were well within the regulatory limits

stated in the Technical Specifications (TS) and that the lic-

ensee was accounting for these releases in their Semi-Annual

Effluent Report that will be submitted to the NRC.

No violations of regulatory requirements were identified.

2.5.3 Failure of Thaxton Plug

On August 10, 1988, the resident office was informed by the

licensee that the Idaho National Engineering Laboratory (INEL)

had identified a failure of a Thaxton plug in a knockout canis-

, ter stored at INEL. The canister had been previously shipped

from TMI-2 and, subsequently, placed in storage in a water pool

at INEL. Thaxton plugs are devices used to seal the influent

and effluent ports on knockout and filter cans to prepare them

, _,, _ ___ _

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

..

,,

.

7

for shipment and eventual s'.orage at INEL. Accordingly, each

canister contains two plues. The failure was identified when

INEL personnel found tha', the plug's mandrel bolt had broken,

allowing the plug to disassemble. The failed plug was found

lying atop the storagr rack in the pool adjacent to its canis-

ter. There was no apparent release of material from the canis-

ter to the pool. I.cmediate steps were taken to address this

problem.  ;

The supplier, F,abcock and Wilcox (B&W), of the plugs was con-

tacted to review the design to identify any design fla<fs that

may have corcributed to the failure. INEL performed stress

analyses a*,d metallurgical examination of the broken section.

Additioneily, an engineering evaluation was performed to de-

termine if the torque (200 foot pounds) that is applied to the

plugs had overstressed the materials and contributed to the

f a i li,re.

As a result of these evaluations, the licensee has taken the

'ollowing actions.

--

Knockout and filter canisters, tnat previously had been

loaded into the three shipping casks presently staged on

site, will be retrieved from their casks and new Thaxton

plugs will be installed with a lower torque (45-50 foot

pounds). Prior to installation, the replacement plugs

will be tested, using the magnetic particle examination

technique, to verify their integrity. Installed plugs

removed from the canisters will be discarded.

--

In the future, re-designed plugs will be used. The new

design will include a longer externally threaded shank

and a shallower internally tapped hole. The licensee is

performir.g tests and analyses to confirm the adequacy of

design changes and new specifications for the Thaxton

l plugs.

Site inspectors will continue to follow licentee progress on

this matter.

,

2.5.4 Licensed Operator _ Employment Terminstion

On August 18, 1988, the licensee informed the resident office

that an altercation occurred between a licensed operator and

,

an auxiliary operator in a lunch room. Following the incident,

the licensed operator's fitness for duty was questioned and

he was sent to the licensee's medical department for testing.

He was placed on suspension pending the outcome of the inves- l

i

' - - . -__ _ _ .

-_

.- , - - _ . - - - , . - _ _ . _ _ - . _ _ . __ . - _ _

______ _________ ____ _ -____

__-.

'

-

, , ,

,

..

8

tigation of the incident. At the time of the incident, the

licensed operator was assigned to the Radwaste Operations De-

partment and was not performing licensed duties.

On August 29, 1988, the licensee informed the' resident inspec-

tors of the results of the testing. Positive results were

obtained for both alcohol and non prescribed drugs. The indi-

+

vidual's blood alcohol content was greater than 0.1 percent

and a positive indication for a controlled substance was ob-

tained. Baseo on this information, the licensee terminated

, the employment of the individual.

i

2.6 Summary

! The licensee acknowledged the declining trends in controlling contamina-

l

tion in the reactor building and maintaining a high level of housekeeping

in the balance of plant. Actions are being taken to improve performance

, in these areas. Plant events are appropriately documented and detailed

! investigations are performed to identify actions to preclude recurrences.

Personnel fitness for duty policies are strictly enforced and actions

,

are taken in a timely manner.

l 3.0 Licensee Action on Previous Inspection Findings

3.1 (Closed) Unresolved Item _(320/88-12-02): Evaluate Qualifications of

Recently Assigned Site Operations Director

.

On August 31, 1988, site inspectors reviewed the qualifications of the

new Site Operations Director, Mr. George Kuehn, and compared his creden-

l tials to the requirements of ANSI 18.1-1971. This was done to verify

! compliance with Technical Specification 6.3 that requires each member

l of the unit 2 staff meet or exceed the minimum qualifications of ANSI

18.1-1971, "Selection and Training of Nuclear Power Plant Personnel."

.

!' Through interviews with licensee representatives and review of supporting

documents, the inspectors determined that Mr. Kuehn's education and ex-

j pertence with the military and nuclear power industry meet the criteria

, of ANSI 18.1-1971. Mr. Kuehn is not an NRC-licensed operator at TMI-2

and because of the limited duration of the position of Site Operations

! Director, TMI-2, which will be eliminated upon completion of cleanup

I operations, it would not be practical for Mr. Kuehn to enter a lengthy,

! formalized, licensed operator training program. However, due to the

unique nature of defueling and decontamination accivities conducted at

,

TMI-2, Mr. Kuehn should have in-line subordinate managers who are lic-

i ensed senior reactor operators (SRO's) to provide strong technical input

i into management directie- and could serve as principal alternates in

J ,Mr. Kuehn's absence. Therefore, the licensee has assigned licensed SR0's

,1 in-line positions of .' tanager, Plant Operations and Plant Operations Man-

l

l

l

l

l

l

l

• • '

.'.

9

i

ager reporting directly to Mr. Kuehn. Accordingly, such a chain of com-

mand strengthens the experience and education qualifications of overall

management within the Site Operations Department.

The inspectors have no additional questions on this matter.

4.0 Exit Meeting

The inspectors discussed the inspection scope and findings with licensee

management at a final exit interview conducted September 9, 1988. Senior

licensee management personnel attending the final exit meeting are noted in

Section 1.3.

The inspection results, as discussed at the meeting, are summarized in the

coverage page of the inspection report. Licensee representatives indicated

that none of the subjects discussed contained proprietary or safeguards in-

formation.

Unresolved Items are matters about which information is required in order to

ascertain whether they are acceptable, violations, or deviations.

l

l

,

.

. _ _ _ - . . - . _ . . __ _ _ . . _ . _ _ . _