ML20207D359

Safety Insp Rept 50-320/86-06 on 860510-0611.Violations Noted:Failure to Conduct QC Program Assuring That Free Standing Water Requirements for Waste Packages Not Exceeded & QA Dept Failure to Review Radwaste Shipment Procedures

ML20207D359
Person / Time
Site:	Three Mile Island
Issue date:	07/09/1986
From:	Bell J, Clemons P, Dan Collins, Cook R, Cowgill C, Moslak T, Myers L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
To:
Shared Package
ML20207D295	List: ML20207D289 ML20207D315 ML20207D359
References
50-320-86-06, 50-320-86-6, NUDOCS 8607220081
Download: ML20207D359 (15)

See also: IR 05000320/1986006

Text

.

.

U. S. NUCLEAR REGULATORY COMMISSION

Report No. 50-320/86-06

Docket No. 50-320

License No. DPR-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: Middletcwn, Pennsylvania

inspection Conducted: May 10, 1986 - June 11, 1986

Inspectors:

C60k

/.y tems

d i eer

'7/8/86

date signed

,

W . 7/T Rd

T. KoslaE, Resident nspector (TMI-2) date signdd

kJ YWN

( J. BM 1, Senior Rad '

a9-

ion Specialist 7/r/es

da/te signed

<

, NJ W - &

ol ins, Radiation Specialist

/I"

7't'esigned

da

' ,/a/AL

wkn

LT'Myers,fRadiatif Specialist d $e signed

t%awCv

P. Cletnons

~

adiatynSpecialist

,4la

date signed

Approved By: Ac0ftL/E 7/ 95

C. Cd91i'll, ef, TMI-2 Project Section date signed

Inspection Summary:

i Areas Inspected: Routine safety inspection by site and regional inspectors of

,

plant operations (long term shutdown) incitding reviews of radioactive waste

'

packaging and transportation program, failure of a Jib Crane resulting in a

personnel injury, implementation of an In-Service Inspection program for Type

B and C valves, radiation worker training program, radiation protection

program staffing, l.icensee assessment of Quality Assurance activities for

1985, events resulting in contamination of plant areas, the status of

defueling operations and licensee actions on previous inspection findings.

Results: Two violations were identified. One violation resulted for failure

to conduct a quality control program to assure that waste packages did not

exceed free standing water requirements (paragraph 3b). The second violation

resulted for failure of the Quality Assurance Department to review certain

'

procedures regarding the preparation of radioactive waste for shipment

(paragraph 3c).

pag 72ggggggo

G

.

.

DETAILS

1.0 Ongoing Recovery Operations

Routine Plant Operations

Inspections of the facility were conducted to assess compliance with the

requirements of the Technical Specifications and Recovery Operations Plan

in the following areas: licensee review of selected plant parameters for

. abnormal trends; plant status from a maintenance / modification viewnoint,

including plant cleanliness, control of switching and tagging, and fire

protection; licensee control of routine and special evolutions, including

control room personnel awareness of these evolutions; control of

documents, including log keeping practices; radiological controls, and

security plan implementation.

Random inspections of the control room during regular and backshift hours

were routinely conducted. The Shift Foreman's Log and selected portions

of the Control Room Operator's Log were reviewed for the period May 10

through June 11, 1986. Other logs reviewed durin

included the Submerged Demineralizer System Operations(SDS)g the inspection period

Log,

Radiological Controls Foreman's Log, and Auxiliary Operator's Daily Log

Sheets.

Operability of components in systems required to be available for

response to emergencies was reviewed to verify that they could perform

their intended functions. The inspectors attended selected licensee

planning meetings. Shift staffing for licensed operators, non-licensed

personnel, and fire brigade members was determined to be adequate.

No violations were identified.

2.0 Licensee Action on Previous Inspection Findings

(Closed) Violation 50-320/85-21-06 Unplanned intake of radioactive

materials and the assignment of 40 MPC-hr exposure to a worker.

The inspector reviewed the corrective actions taken to prevent a

recurrence of the event and the methods used to assign the 40 MPC-hr

exposure to the worker. The principal cause of the event was a breakdown

in communications between Radiological Control technicians and other

workers. Cyclic training included a seminar which studied the event with

emphasis on clear, concise and effective communications in setting up a

job and providing protection to workers. The inspector reviewed the

seminar plan and attendance records and determined them to be adequate.

The assignment of 40 MPC-hrs to the worker was reviewed and found to be

adequate. The corrective actions are completed.

The inspector had no further questions.

(Closed) Inspector Follow Item 50-320/85-21-09 Knowledge and training of

Radiological Control Field Operations personnel concerning follow-up of a

personnel contamination event.

.

-

3

Cyclic training of Radiological Control technicians and supervisors

included a seminar that addressed follow-up measurements and evaluations

to be made after a personnel contamination event. The seminar used the

event as the basis for study and review of the methods of characterizing.

internal contamination for determining an intake to a worker,

requirements for prompt whole body counting and reporting of such events

to management. The inspector reviewed the seminar plan and the

attendance records and found them to be adequate.

The inspector had no further questions. ,

3.0 Radioactive Waste Packaging and Transportation Program

a. Management Control

The inspector reviewed the radwaste organization to ensure that

proper lines of authority and responsibility existed. Procedure No.

4230-ADM-1000.01, "TMI Unit 2 Waste Management Organization,

Responsibility and Authority" states that the Manager, Waste

Management, is responsible for all normal administrative functions

having to do with his organization. He has delegated responsibility

for radwaste operations to the Radwaste Support Manager and the

Waste Management Manager. The Radwaste Support Manager is

responsible to assure that the onsite storage, packaging, and

shipment of all radioactive materials from TMI are done in

accordance with regulatory requirements. The Supervisor, Waste

Disposal, has been charged with responsibility day-to-day radwaste

operations to ensure proper storage, packaging, shipment, and

disposal of radioactive waste from TMI in accordance with applicable

procedures, regulations, and licenses.

Within the scope of this review, no violations were identified.

b. Quality Control

The licensee made numerous shipments of dewatered radioactive resin

to a burial site in the State of Washington. The shipments were

reviewed against the criteria contained in 10 CFR 20.311.

The licensee's performance relative to these criteria was determined

by discussions with Waste Management personnel; the Supervisor,

Waste Disposal; the Quality Assurance / Quality Control Monitor; and

by reviewing appropriate documents.

, Within the scope of this review, the inspector identified the

'

following inadequacy:

The inspector determined that several shipments of radioactive waste

,

composed of dewatered resins in EPICOR liners were made to a burial

site in the State of Washington during 1985.

The inspector determined by questioning the Quality

Assurance / Quality Control Monitor that he had not performed any

quality control functions on any dewatered resin shipments during

3

L

. . _ .

.

-

4

1985. The inspector determined that the Waste Management personnel

charged with the responsibility for performing dewatering operations

had not performed quality control functions on the operations they

were responsible for, and neither had they been charged with the

responsibility to perform the quality control function in the areas

in which they were responsible for doing the work. 10 CFR

20.311(d)(3), " Transfer for disposal and manifests" requires that a

licensee who transfers radioactive waste to a land disposal facility

conduct a quality control program to assure compliance with 10 CFR

61.56. 10 CFR 61.56 requires that freestanding and non-corrosive

liquids not exceed one percent of the volume of solid wastes. The

failure to conduct a quality control program is a violation of 10

CFR20.311(d)(3). (320/86-06-01)

c. Review and Approval of Procedures

'

The adequacy and effectiveness of the licensee's procedures were

reviewed against criteria contained in Technical Specification 6.8,

" Procedures."

The licensee's performance relative to the criteria was determined

from discussions with Waste Management personnel, Operations Quality

Assurance personnel, and by reviewing appropriate procedures.

Within the scope of this review. the inspector identified the

following:

Section 4.6.6.2 of Procedure No. 4000-ADM-1218.02, "TMI-2 Document

Evaluation, Review and Approval," Revision No. 6-00, dated July 22,

1985, requires Quality Assurance concurrence on all procedures,

classified Important to Safety, dealing with final preparation for

shipment of radioactive material, including dewatering.

The inspector determined that two procedures classified as Important

to Safety were not reviewed and concurred in by Quality Assurance.

Procedure No. 4215-0PS-3526.18, " Dewatering of EPIC 0R Liners at

,

EPIC 0R II," Revision 1-00, dated August 6, 1985 and Procedure No.

i 4215-0PS-3233.08, "EPICOR II 4x4 and 6x6 Liner Supplemental

'

Dewatering," Revision 1-00, dated February 3,1986, have not been

reviewed and concurred in by the Quality Assurance Department.

The failure to properly review and approve dewatering procedures is

a violation of the requirements of Technical Specification 6.8.

(320/86-06-02)

d. Shipment of Radioactive Material

! The licensee's program for the transportation of radioactive

material was reviewed against the criteria in 10 CFR 71.12, " General

License: NRC Approved Packages."

The li-:ensee's performance relative to these criteria was determined

by interviewing the Supervisor, Waste Disposal, and by reviewing

appropriate shipping dncuments.

.

i

, - - . - , - - - - - -

.

.

-

5

Within the scope of this review, the following was identified:

On December 5,1985, the licensee shipped 275.61 curies of

radioactive material in a cask identified as a Hittman HN-500 cask.

This identification was listed on the U. S. Ecology disposal

manifest and the licensee's Bill of Lading. The licensee also

identified the Certificate of Compliance (C of C) 9073. C of C 9073

does not identify the Hittman HN-500 cask as an approved package.

The licensee showed the inspector documents that identified the cask

as a Model 0H-142 MKI cask which is authorized by C of C 9073. The

'

inspector discussed with the licensee the importance of identifying

the correct model number on shipping manifests. The licensee

representative acknowledged the inspector's statements and stated

that the correct numbers would be used in the future.

The inspector had no further questions regarding this matter,

e. Audits

The licensee's program for the auditing of transport packages was

reviewed against the criteria contained in Criterion II " Quality

Assurance Program," and Criterion XVIII, " Audits," of the licensee's

Quality Assurance Program.

The licensee's performance relative to these criteria was determined

i by discussion with the TMI-2 Audit Supervisor, and by reviewing

appropriate documents.

Within the scope of this review, no violations were identified.

4.0 Defueling Operations

Defueling efforts during this reporting period were aimed at improving

, visibility in the reactor coolant system (RCS). This was accomplished by -

+

adding hydrogen peroxide as a biocide to the RCS. A feed and bleed

technique was used to drain down four 15,000 gallon batches, while an

equivalent amount of treated water was added as make-up. Use of hydrogen

'

'

peroxide, in conjunction with filtering, has improved the visibility to

approximately 6 to 8 feet in the reactor vessel.

On June 4, 1986, the NRC approved the use of a heavy duty tong tool,

heavy duty spade bucket and a hydraulic impact chisel fcr testing. To

date, the licensee has tested the heavy duty spade bucket. Tests were

inconclusive due to bending of the spade bucket vertical jaw.

Defueling support operations were periodically observed by the Resident

Inspector via closed circuit T.V. from the Defueling Coordination Center

during the reporting period.

No violations were identified during the conduct of these operations.

l

. --

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

.

-

6

'

5.0 Jib Crane Failure

On May 12, 1986, an operator was injured in the Reactor Building when a

trolley / winch assembly disengaged from the No. 1 Jib Crane on the

Shielded Work Platform. The operator's injury was limited to a

laceration of the scalp. No loss of consciousness occurred., The

operator was escorted from the Reactor Building and taken to a hospital

for examination.

The licensee conducted an investigation to determine the cause and what

corrective action should be taken to preclude a recurrence. The

inspector followed the licensee's actions.

A critique was held within twenty-four hours of the accident with the

workers, supervisors, and site management. At the critique, it was

'

determined that the (injured) operator had just completed transferring a

load from the No. 1 Jib Crane to the No. 2 Jib Crane when the No. 1

trolley / winch assembly (weight a 200 lbs.) came apart and fell from the

support I-beam first striking the operator, who was standing on a ladder

approximately 6 feet below it, and then falling into the reactor vessel.

The operator was making the load transfer because the wheels on the No.1

trolley had spread disabling the trolley. An attempt was made to

retrieve the components that had fallen into the reactor vessel to

determine the failure mode; however, only the larger components were

obtained. Smaller components (e.g. , cotter pins, spacer rings, nuts,

bolts, etc.) could not be retrieved because of limited visibility.

Based on the information and components available, the licensee concluded

that the failure occurred when a cotter pin fell out of a keeper pin

causing the trolley / winch assembly to dicassemble.

Imediate actions taken by the licensee included removing both Jib Cranes

from service, conducting an engineering evaluation of corrective actions,

and contacting the crane manufacturer (Harrington Hoist) regarding

generic trolley design issues.

Through discussions with licensee representatives the inspector

determined that the only corrective action implemented was to replace the

cotter pin with a bolt, nut and lock wire combination to secure the

keeper pin in the trolley / winch assembly on the two Jib Cranes on the

work platform in the Reactor Building and the two Jib Cranes on the

!

Defueling Test Assembly in the Turbine Building.

The inspector expressed the following concerns regarding licensee

corrective actions:

-- neither cotter pin replacement nor an evaluation was performed on

other Jib Cranes used in other plant areas (e.g., Spent Fuel Pool,

Truck Bay, Auxiliary Building). These cranes could experience

similar failures.

-- the monthly inspection of the Jib Cranes in the Reactor Building is

limited to operational checks performed by an inspector using the

pendant controls at a considerable distance from the operating

_ . .

.

-

7

components. No close, frequent, hands-on inspection is performed of

the trolley / winch assembly.

Licensee personnel acknowledged the inspector's concerns and stated that

more extensive action is being evaluated. Licensee performance in

cperating and maintaining plant Jib Cranes will be monitored in future

NRC inspections. (320/86-06-03)

6.0 In-Service Inspection (ISI) Program

The licensee is implementing an ISI program to determine the operational

readiness of Category B and C valves in safety related systems. This

program is established in response to an NRC letter dated April 27, 1981

from the Director of the TMI Program Office which stated in part that,

"... Category 8 and C valves in safety related systems in-service

should be exercised at least once per 92 days where practical to

determine their operational readiness. Relief from the test

-

requirements for Category B and C valves in safety related systems

specified above will have to be submitted on an individual valve

basis."

Prior to the accident of March 28, 1979, Technical Specifications

required ISI of approximately 326 valves when the plant was in

Operational Modes 1, 2, 3, or 4. For the non-operational, recovery mode,

the licensee has identified approximately 244 valves which do not need to

be tested and 82 valves which will be tested in accordance with Section

XI of the ASME Boiler and Pressure Vessel Code. The determination not to

test specific valves was based upon the following criteria:

-- The system is out-of-service for the recovery period

--

The valves-have been previously exempted from testing by the NRC

-- The valves do not perform a safety related function

--

Testing would require personnel to received a significant radiation

j dose

--

Testing could contaminate clean systems or be impractical due to

present system configuration.

The inspector determined that a period of approximately five years

elapsed before the licensee took action to implement an ISI program. The

item is considered unresolved pending further review and examination by

the NRC. (320/86-06-04)

7.0 Systematic Assessment of Licensee Performance (SALP)

On May 22, 1986, a meeting was held with licensee management at the NRC

Region I office to discuss the SALP report. The report summarized the

licensee's overall safety performance at the Three Mile Island (TMI)

Nuclear Station, Unit 2, for the period May 1,1984 through February 28,

1986. The report addressed those activities required for defueling the

4

- - ~ ,. , _ - . _ _ . _

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

. .. - _ . - _ _

.

~

8

i

reactor, decontaminating plant areas, and implementing plant

modifications required for the safe movement of fissile and radioactive

waste material generated as a result of the March 1979 accident. ,

At the meeting, licensee management discussed plans to improve staff

! performance in the areas of Plant Operations and Design Engineering with

particular emphasis placed on upgrading the adequacy of new procedures.

8.0 Quality Assurance Annual Assessment for 1985

On May 12, 1986, in accordance with Quality Assurance (QA) Plan

requirements, the licensee's QA organization presented its yearly

'

assessment of the effectiveness of the QA program to senior management.

4

The inspector attended this presentation. Managers of sections within

the QA department, including QA Engineering, Site Welding, Quality

Control, Operations QA, Site Audits, and QA System Engineering,

identified their respective program's strengths and weaknesses, then made

recommendations for improving performance. Examples of the recommended

actions included:

-- establish a design program-to manage minor modifications made to

existing systems

-- improve the organization and methods of the tie-in control and

,

return-to-service programs

-- reduce the redundancy and duplication of procedures

-- increase the communications and interfacing of the TMI site with

vendor facilities.

The inspector determined that presentations were candid and that the

assessment was accurate and consistent with findings identified in NRC

'

inspections.

9.0 Health Physics and Environmental Review

a. Plant Tours

,

The NRC site Radiation Specialists performed plant inspection tours

which included all radiological control points and selected

radiologically controlled areas. Among the areas inspected were:

the Auxiliary, Fuel Handling, and Diesel Generator Buildings;

Radiochemistry Laboratories; Solid Waste Storage Facility; Interim

Waste Storage Facility; Waste Handling and Packaging Facility (under

construction); Respirator Cleaning and Laundry Facility; and the

'

Radiological Controls Instrument Facility.

Among the items inspected were:

'

-- Access control to radiologically controlled areas, including

high radiation areas and rad tag key areas

-- Adherence to Radiation Work Permit (RWP) requirements

,

s -. . . _ , - - , . n.

. ~ = _

.

'

9

-- Proper use and storage of respirators and associated equipment

-- Adherence to radiation protection procedures

-- Use of radiological instruments

-- Radioactive waste reduction, cleanliness and housekeeping; and

-- Fire protection.

The inspectors reviewed the conduct of operations during normal

hours, backshifts, and weekends. Log books maintained by

Radiological Controls Field Operations, Radiological Engineering and

Fuel Handling Senior Reactor Operators were reviewed. All notebooks

contained appropriate entries and showed evidence of management

review.

No violations were idantified.

b. Radiological Shipments

The inspectors examined shipments from the site on May 14 and June

2, 1986 for the following:

--

External vehicle contamination

--

External package contamination

-- External radiation levels at vehicle surfaces, two meters away,

and inside the tractor cab

-- Radiation levels at package surfaces

--

Verification of recipient license

-- Verification of shipping documents; and

--

Appropriate markings and placarding.

No violations were identified.

c. Measurement Verifications

Measurements of levels of radiation and contamination were made by

'

the inspector using NRC-calibrated instrumentation. The results

verified the findings of licensee surveys. The measurements were

,

made on shipments and areas within the radiologically controlled

areas of the plant. Additionally, the inspector reviewed the

licensee's measurements of radioactivity in water discharges to the

river and compared licensee results with the results obtained by EPA

from samples at the plant discharge.

No violations were identified,

i

l

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

.

10

d. Records Review

The inspector reviewed selected radiological records during the

period to assure the accuracy and completeness of the licensee's

documentation of occupational exposure. The records reviewed

included Radiation Work Permits, Dosimetry Investigative Reports,

Incident Evaluation Reports, Radiological Awareness Reports, and

Dosimetry Exception Reports.

No violations were identified.

e. Reactor Building Work

The inspectors monitored the licensee's conduct of work in the

reactor building (RB) throughout the inspection period. The

following were reviewed by representative sampling during the

period:

-- The RB entry was planned and coordinated so as to ensure that

ALARA review, personnel training, and equipment testing had

been conducted.

--

Radiological precautions were planned and implemented;

ir.cluding specific work instructions, alarming self-reading

dosimeters and breathing zone air samplers.

-- Individuals making entries to the RB had been properly infonned

of conditions, properly trained and understood emergency

procedures.

-- Unique tasks were performed using specifically developed

procedures, and mock-up training had been conducted when

warranted.

Entries 916 through 942 were conducted during the reporting period.

The reactor building entries were conducted around the clock for the

most part. Defueling activities were conducted over two shifts and

maintenance was performed on the third shift.

No violations were identified.

f. Planned Decontamination Activities

On May 28, 1986, members of the licensee's staff briefed the TMICPD

staff with respect to radioactivity and radiation dose rate

characterization, current and planned decontamination and dose

reduction activities, cumulative and individual dose figures, ALARA

concept implementation, and scheduling of activities in the reactor

building. It is anticipated that future briefings will occur at

approximately three month intervals. Current progress on plant

decontamination is satisfactory. TMICPD will monitor ongoing

activities.

.

11

g. Staffing and Workload

The inspector reviewed the hours of work for Radiological

Technicians and Supervisors with respect to the requirements of

4000-POL-2002.01, Revision 1-01, dated June 9, 1986, " Unit 2

Standards of Conduct." This policy superseded procedure

4210-ADM-3020.01, " Conduct of Operations." The inspector determined

that the new policy statement incorporates the criteria of NRC

Generic Letter 82-02 " Nuclear Power Plant Staff Working Hours."

The inspector determined that the technician hours of work and

staffing level for activities in both the reactor building and in

the balance of the plant were adequate to meet requirements.

No violation was identified.

10.0 Radiological Controls Training

a. Requalification Training

During this review, the inspector observed the instruction of

Radiological Field Operations technicians in the filter change-out

of an airborne radioactivity monitor (Eberline Model AMS-3). -The

inspector concluded that the training was effective, having the

appropriate scope ano lepth. However, the inspector noted the

following areas for improvement.

--

A " dry-run" change-out should be performed in a clean area

prior to changing out an operating AMS-3 in a radiation area.

Such preparatory training would reduce the possibility of

cross-contaminating clean, operating equipment, during

training.

--

"0" ring seals were missing from the AMS-3 that was being

changed out. Closer attention should be made by technicians to

insure "0" rings are installed on the AMS-3 filter holder.

Licensee personnel acknowledged the inspector's concerns and

stated that they would be subsequently addressed. Inspectors

will continue to monitor licensee progress in this matter.

(320/86-06-05)

No violations were identified.

b. Respiratory Protection Mainterance Training

The inspector reviewed the requirements of Procedure

9000-ADM-4020.01, " Respiratory Protection Program," and found that

the program of training described for the individuals who maintain

and inspect respiratory protective equipment to be acceptable. The

supervisor currently provides 0JT, maintains records of specific

training and schedules vendor training. The required annual

l

frequency has been met. Training records formerly maintained by the

Radiological Training Group are now maintained by the Maintenance

I

.

12

Group Supervisor. Vendor certificates comprise the bulk of the

records. Although training records were adequate, no consolidated

record of training for specific individuals exists at present.

A February 18, 1986 memorandum to the Plant Training Department from

the Respiratory Protection Supervisor requests that a formal program

be established for the maintenance technicians. The requested

program would develop within the Training Group the qualifications

to instruct and qualify technicians in respiratory equipment

maintenance thus reducing the dependence on vendor training

schedules. The program would enable better use of classroom and

instructor time, and would integrate this specialized training

program into the plant non-licensed training program.

No violations were identified,

c. Supervisor and Technician Training

Theoretical and practical training, scheduling, oral boards, and

qualification record maintenance is the responsibility of the

Radiological Training group within the Radiological Controls

Department. Initial training for an entry level Radiological

Controls technician (RCT) is 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of instruction. Each

technician must pass the written examination, complete practical

factors training and qualify for the oral board exam. Upon

completion of the oral board, the technician is classified as RCT

"A", "B", "C", or Group Radiological Control Supervisor (GRCS),

depending upon his experience and qualifications. Requalification

is required biannually. This is accomplished through written and

oral examinations.

The training and qualification records of 12 randomly selected

RCTs/GRCSs were reviewed with respect to criteria in GPUN Radiation

Protection Plan, 4000-ADM-4010.01 and Procedure 9000-ADM-2622.01

" Radiological Field Operations Personnel Qualification / Training

Standard."

The inspector attended RCT job turnover briefings, job briefings on

sealing of floor penetrations on the 305' elevation of the reactor

building, and mockup training in the removal of ' internal vent valves

from the reactor vessel. This training was consistent with criteria

in 4000-ADM-2600-019, " Job Briefing and Mockup Training."

Within the scope of this review, no violations were identified.

d. Personnel Interviews

During May and June 1986, the inspector formally interviewed six

members of the TMI-2 Radiological Field Operations staff (four

senior technicians and two GRCSs) concerning their impressions of

the present training programs based on their work experiences. Each

individual was also asked about his or her knowledge of the content

and requirements of licensee procedures and Federal regulations, as

well as the individual's knowledge and practice of generally

_ _

.

13

accepted good radiological safety practices. All individuals

interviewed responded adequately. Similarly, all of those

interviewed indicated that the training of radiation protection

personnel was generally adequate. Some individuals expressed a

desire for additional practical factors (on-the-job) training. The

results of the interviews were discussed with appropriate

radiological controls training personnel,

e. Informing Personnel of Procedure Changes

The licensee's Radiological Controls Department uses various methods

to make people in the field aware of changes to procedures. One

method is specified in Procedure 9000-ADM-4000.04, Rev. O,

" Radiological Controls Notification of Change." The procedure

states that Section Heads, after designating who shall review

changes to particular procedures, should ensure that the reviews are

conducted within seven days.

The inspector noted that several procedures were overdue for

completion of review. The inspector noted that a March 12, 1986

procedure change had not been reviewed by all the dosimetry

technicians by May 27, 1986. There were three procedures with April

1986 effective dates in the instrument repair shop area on May 27,

1986 which had not been reviewed by all required persons. At the

Health Physics office in Unit 2 a large number of procedures, some

dating to January and February 1986, were not signed off by the

required persons. The inspector asked about these problems.

Radiological Controls Supervisors stated that important procedure

revisions were covered in staff meetings. The inspector interviewed

selected Rad Con technicians to determine if they were aware of

changes. All persons interviewed were familiar with recent

revisions. The. inspector expressed concern that the procedure

review was not being accomplished as stated.

The inspector will continue to follow this matter to determine any

adverse impact on radiological controls. (320/86-06-06)

11.0 Events Resulting in Contamination of Plant Areas

a. Liquid Spill

On May 20, 1986 at approximately 2:30 PM, a contamination event

occurred in the 305' elevation of the Turbine, Auxiliary, and Fuel

Handling Buildings. The contamination was caused by a leak from a

chemical waste container containing radioactive material being

transported from the Babcock and Wilcox Hot Laboratory to a waste

sink in the model room of the Fuel Handling Building. The highest

, contamination level detected was 50,000 cpm /100 cm2 The areas

involved were isolated, surveyed and decontaminated immediately

following reporting of the leak by the workers transporting the

chemical waste. A control point was established at the exit from

the Protected Area to monitor individuals for contamination.

Several workers who transversed the corridor of the Auxiliary

Building before the area was isolated were found to have

!

l

'

,_ -_.

- . . - -. .- -. . -

- . _

_ _ _ .-

.

14

l contaminated shoes at the control point. The shoes were

decontaminated and returned. There was no airborne contamination as

a result of this event.

Licensee investigation determined that the closure seal leaked from

one of the two 5-gallon carboys containing radioactive liquid waste

including reactor coolant system samples. This leakage then

passed through holes torn in the polyethylene bags containing the

carboys. The carboys were separately double bagged with heavy

polyethylene bags and then taped to a twc-wheel hand cart. The bags

were most likely torn while going through one of the four doors or

passing some of the equipment along the pathway. Incident / Event

Report 86-047 was initiated and a critique was held to determine the

cause of the event and corrective actions. The corrective actions

were to 1) place the carboys in a rigid container sufficient to

contain the volume of the carboys, 2) transport the container by a

four-wheel cart, and 3) assure that the carboy closure seals are

properly seated.

The inspector considered the corrective actions to be appropriate.

b. Airborne Contamination from Plant Nitrogen System

On May 31 and on June 9,1986, the 281' elevation of the Auxiliary

Building was contaminated by a release from the internally

contaminated plant nitrogen system. Releases occurred when relief

valves, NM-R-8 and NM-R-9, lifted due to overpressurization of the

Nitrogen manifold. The plant nitrogen system is used to provide

overgas to Reactor Coolant Bleed Tanks (RCBT) during drain downs.

The valves relieve locally to the atmosphere of the Auxiliary

Building on the 281' elevation creating airborne contamination. The

first event caused the 281' elevation to be declared an Airborne

Radioactivity Area for about five hours. The release was stopped

< when operations secured the plant nitrogen system. Incident / Event

Report Number 86-050 was initiated June 6,1986. The interim

corrective action was to enclose the relief valves with a filtered

housing and to install a bag filter of sufficient capacity on the

.

atmospheric discharge vent. The modification of the relief valve

! housings had been completed but the bag filter had not been

installed on the atmospheric discharge vent when the second event

occurred.

i

Decontamination efforts to recover all of the 281' elevation were

proceeding when the second event occurred while processing the "B"

RCBT through the Submerged Demineralizer System. The second event

was more limited in effect than the first event.

f

'

A critique was held on June 10, 1986 which discussed the causes of

the two events and reviewed the short term corrective actions and

suggested long term corrective actions. The bag filter was

i

installed June 10, 1985. The inspector will monitor the adequacy of

the long term corrective actions. (320/86-06-07)

t

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

.

15

12.0 Inspector Follow Items

Inspector follow items are inspector concerns or perceived weaknesses in

the licensee's conduct of operation (hardware or programmatic) that could

lead to violations if left uncorrected. Inspector follow items are

addressed in paragraphs 2.0, 5.0, 10.0 and 11.0.

13.0 Unresolved Items

Unresolved items are findings about which more information is needed to

ascertain whether they are violations, deviations, or acceptable.

An unresolved item is addressed in paragraph 6.0.

14.0 Exit Interviews

The inspectors met periodically with licensee representatives to discuss

inspection findings. On May 30, 1986, the regional inspector summarized

the inspection findings to the following personnel:

J. Byrne, Manager, TMI-2 Licensing

W. Conaway, Radwaste Support Manager

L. Edwards, Quality Assurance Lead Monitor

R. Hahn, Supervisor, Waste Disposal

S. Levin, Director, Site Operations

J. Renshaw, Manager, Waste Management

R. Rogan, Director, Licensing and Nuclear Safety

On June 11, 1986, the site inspectors summarized the inspection findings

to the following personnel:

J. Byrne, Manager, TMI-2 Licensing

W. Craft, Manager, Radiological Controls Field Operations

C. Dell, Licensing, Technical Analyst

S. Levin, Director, Site Operations

M. Pastor, Defueling Operations Director

W. Ream, Lead Mechanical Engineer

R. Warren, Manager, Plant Engineering

At no time during the inspection was written material provided to the

licensee by the TMICPD staff except for procedure reviews pursuant to

Technical Specification 6.8.2.