IR 05000289/1972013
| ML19276H293 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/13/1972 |
| From: | Brunner E, Mcleod B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276H275 | List: |
| References | |
| 50-289-72-13, NUDOCS 7910160637 | |
| Download: ML19276H293 (12) | |
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U. S. ATOMIC ENERGY COMMISS103 DIRECTORATE OF REGULATORY OPERATIONS REGION 1 RO Inspection Report No. 50-289/72-13
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Subject: Metrooolitan Edison Comnanv
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Three Mile Island - 1 License No. CPPR-40
Location: Middletown, Pennsylvania Priority Category B
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- I Type of Licensee
- Pcwer Reactor (PWR)
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l Type of Inspection: Routine, unannounced i
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Dates of Inspection: August 2-4 and 28. 1972 Dates of Previous Inspection: July 11-14, 1972 i
/C -/3 f L Principal Inspector:
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Date B. K. McLeod, Reactor Inspector
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Accompanying Inspectors:
None Date
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Date Other Acccmpanying Personnel: None Date
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/0-/3-72
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Reviewed By:
E. J. Brunner, Chief, Reactor Testing & Startup Br.
Date Proprietary Information: None
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Section I
Enforcement Action None Licensee Ac'; ion on Previously Identified Enforcenent Matters No c3 orcement items were identified in the previous Startup and f
Testing Program Inspecticn Report.
Unresolved Items
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Inadequate integrated testing of the instrument air system.
a.
(Paragraph 7.b. (4))
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Review of preoperational test procedures.
(Paragraph 7)
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Status of Previously Recorted Unresolved Items No unresolved items were iden.tified in the previous Startup and Testing Program Inspection Report.
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Unusual Occurrences
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None Persons Contacted Metropolitan Edison Cor.pany J. L. Wise - Supe.rintendent, Three Mile Island Nuclear Station
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J. G. Herbien - Station Engineer J. Colitz - Supervisor of Operations J. R. Floyd - Nuclear Engineer H. Morris - Supervisor of Maintenance General Public Utilities Service Corporation J. J. Barton - Startup and Test Manager R. J. Toole - Assistant Test Superintendent M. A. Nelson - Technical Engineer T. W. Hawkins - Shift Test Engineer Burns & Roe Incorporated M. E. Dickinson - Engiaeer, Special Projects
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Management Interview Management interviews were conducted at the conclusion of the in-spection visits with Messrs. Wise and Toole.
The commitments made by Mr. Toole were confirmed by Mr. Barton on September 21, 1972.
The following items were discussed during the mangement interviews:
Preoperational Test Program
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The inspector stated that he had received 19 preoperational test pro-cedures which had been prepared by Met Ed prior to GPUSC assuming res-ponsibility for the technical content of the preoperational test program.
He stated that R0:1 review of three of these procedures indicated that they were grossly deficient and that further review of the remaining test procedures in this group would not be warrented until the licensee had revised all of these procedures.
The inspector stated that his ob-servations indicated that these test procedures do not conform to the licensee's administrative procedures, they do not ccntain appropriate acceptance criteria, they do not test all the functions and components of the systems as described in the FSAR and they are not approved by the TWG (Test Working Group) as required by the licensee!s administrative procedures.
The inspector stated that it was his position that these
procedures must be revised to conform to the present administrative controls and upgraded to provided an adequate test of the sytems. He stated that failure to do so would result in appropriate enforcement action being initiated.
Mr. Toole stated that these procedures will be revised to conform to the current administrative procedures and up-graded to provide an adequate test of each system.
The inspector stated that R0:I review of test procedures is a sampling inspection and that it is not intended to identify every deficiency
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in every prc,eedure.
He stated that he expected his comments to be applied broadly and that the licensee should review all proposed test procedures for similar deficiencies.
Mr. Toole stat.ed that inspector's comments were so interpreted.
The inspector stated that RO:I review of one test procedure which had been prep ared by the GPUSC Test Organization, revealed some deficiencies He stated that satisfactory resolution of these deficiencies had been obtained.
(Paragraph 7)
Facility Operating Procedures The inspector emphasized the need for prompt attention to the Facility Operating Procedures. He stated'that it was apparent that in many areas the scope of the program has not yet been defined; and that this and the lack of a firm schedule for completion of the task were of concern to RO.
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}k. Wise. acknowledged the inspector's concerns and stated that ef forts 7g.peratingProce-O to define and develop the missing areas of the Facility c
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.dures were getting underway.
(Paragraph 5)
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-3-G Section II Additional Subjects Inspected, Not Identified in Section I Where No Deficiencies Or Unresolved Items Were Found 1.
General The inspector reviewed the status of system turnover for testing and of test procedure development.
As a result of this review, the R0 date for fuel loading was revised from June - 1973 to August - 1973.
2.
OA Program for Cperations The inspector inquired as to the status of development of the licensee's QA Program for Operations.
Mr. Wise stated that a
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draft program had been prepared by GPUSC and was being reviewed by Met Ed.
He stated that Met Ed had hired a QC Engineer for the plant staff and would have him on board in the near future.
The inspector stressed ths need for development of this program at an early date and indicated that the approved program should be available for RO review a minimum of four to six months prior to the date that Met Ed expects an operating license.
3.
Personnel a.
A test superintendent, to replace W. E. Baker who resigned, has not yet been hired.
GPUSC is actively recruiting to fill this position.
As an interim measure, Mr. J. J. Barton, Manager of Testing and Star. tup, is serving as the Test Superintendent.
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R. G. Toole, formerly a Shift Test Engineer, has been promoted to Assistant Test Superintendent.
The Shift Test Engineer vacancy has not been filled. GPUSC plans to fill the vacancy.
4.
Post Erection Cleaning The inspector discussed,the licensee's post erection cleaning program with Mr. Hawkins.
Mr. Hawkins provided the inspector with a copy of TP 250/4 - General Procedure for Cleaning and Flushing Systems and Components for RO:I review.
Details of Subjects Discussed in Section I 5.
Facility Operatine Procedures and schedule The inspector inquired as to the status of development,
for completion of the various categories of Station Operating Pro-The licensee's response to these questions was as follows:
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-4-G Administrative Control Procedures a.
Mr. Herbien stated that an index of these procedures has not been prepared.
He stated that none of these procedures have been written and there is, at present, no schedule for ccm-pletion of these tasks.
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Systems Operatine Procedures Mr. Colitz stated that an index has. been prepared and that 80%
of these procedures are in final draf t form.
He indicated that there is no firm schedule for completion.
Mr. Colitz provided the inspector with an index of these procedures and with copies of 22 of the procedures for review by RO:I.
Mr. Colit:: agreed to send copies of the remaining draft procedures,which are avail-able,to RC:I for review,
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General Procedures for Reactor Startuo, Shutdown and Operation c.
at Power Mr. Colitz provided the inspector with an index of these proce-dures and indicated that copies of final draf t procedures will G(
be forwarded to RO:I for review, as they become available.
d.
Emergency Procedures Mr. Colitz provided the inspector with an index of these proce-dures.
He stated that 50% of these procedures are in final draft form.
Mr. Colitz stated that he would forward copies of the procedures that are in final draft form to R0:I for review.
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Abnormal Procedures e.
The licensee presently includes these as emergency procedures.
Af ter discussion with the inspector, Mr. Herbien stated that it may be to Met Ed's benefit to make a distinction between abnormal and emergency procedures and that this approach will be considered.
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Surveillance Procedures Mr. Herbien provided the inspector with an index of these proce-He stated that less than 5% of these procedures have been dures.
written.
Mr. Herbien stated that Met Ed does not intend to write some of the surveillance procedures (these tests not due until refueling) until some time during the first year of operation.
The inspector stated that the RO:I position was that procedures must be complete prior to licensing and that exceptions are grant-O_
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justification.
Mr. Herbien provided the inspector with a list of procedures that Met Ed does not plan to write prior to licensing.
The inspector indicated that Met Ed should reconsider their posi-tion and that he would discuss this issue with Met Ed manage-ment during the next inspection.
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Alarm Procedures
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Mr. Colitz indicated that none of these procedures had ceen written. He stated that an index is in preparation and a copy will be sent to RO:I for review when it is complete.
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Maintenance ?rocedures Mr. Wise provided the inspector with a copy of the proposed
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index for plant maintenance procedures.
He indicated that none of these precedures have been written and that no schedule for completion has been formulated.
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Reactor Engineering Procedures
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Mr. Herbien stated that there is presently no index of these procedures and that less than 10% of these procedures have been written.
He stated that there is presently no schedule for com '
ple..on.
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Rad Con and Radio-Chem Procedures Mr. Herbien stated'that the rad con and radio-chem procedures
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are currently being prepared.
He indicated that he was in doubt The in-as to just what exactly the AEC required in these areas.
spector stated that an inspection in these areas vould be forth-coming in the relatively near future.
6.
PORC Meeting Minutes
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The inspector reviewed the PORC meeting minutes for the period of
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January 7,1971 to July 7,1972.
The deficiencies noted and the inspector's and licensee's comments were as follows:
Deficiency - The minutes do not state the action recommended by the Committee on the items reviewed.
Licensee Comment - Mr. Wise stated that this information would be included in future PORC meeting minutes.
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Preoperational Test Procedures The inspector conducted a review of certain preoperational test procedures and identified several apparent deficiencies which re-quired resolution.
The apparent deficiencies which were identified and the inspector's and licensee's comments relative to these defi-ciencies were as follows:
a.
TP203/4 - Decay Heat Removal System Functional Test
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(1)
Deficiency - This test procedure is not approved by the TWG (Test Working Group) as required by Test Instruction No.18, which defines the methods for preparing, reviewing, modifying, and approving the various test procedures.
_ Licensee Concent - Mr. Toole stated that this test procedure was one of the test procedures prepared by Met Ed prior to GPUSC assuming responsibility for the Technical Content of the TMI-l Test program.
He indicated that this test proce-dure would be revised to conform to the present administrative procedures.
(2) Deficiency - It was not apparent to RO:I during their review 9,(
of the test procedure that the pump vault leakage detectors will be tested.
Licensee Comment - Mr. Toole stated that the pump vault leakag detectors will be tested and that the test procedure will be modified to include this test.
(3)
Deficiency - There are no sign-off requirements for verifiedtic that the required prerequisites for the test have been satis-fled. There are also no sign-off requirements for verification that the required plat t status has been established.
Licensee Comment - Mr. Toole stated that the test procedure will be modified to include sign-off for prerequisites and required plant status.
(4)
Deficiency - Several alarm set points are missing from the procedure.
Licensee Comment - Mr. Toole stated that this information would be added to the procedure as soon as it is known and that it would be included in the procedure prior to approval of the test procedure for performance.
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Deficiency - Step 9.1.1 of the test procedure references (5)
There step 4.4.2.1.(5) in operating procedure - 1104-4.
is no step 4.4.2.1.(5) in that operating procedure.
Licensee Comment - Mr. Toole stated that this error would be corrected.
this item Inspector's Comment - The inspector stated that was an example and that the problem had been noted in other He stated that he places in this and other test procedures.
expected this comment to be applied broadly and that other procedures should be reviewed for similar problems.
Licensee Comment - Mr. Toole stated that otner test procc-dures will be reviewed for sim'lar problems.
(6)
Deficiency - The procedure does not give predicted operating times for non-safety related valves nor does it specify accept-ance criteria for safety related valves.
Licensee Comment - Mr. Toole stated that valves which do not perform a safety related function will be operationally check-ed and timed during the mechanical test of system components O
prior to starting the preoperational test.
He indicated that in these tests the valve operating times will be recorded and compared to predicted values.
He stated that valves performin safety functions will be handled in a similar manner with the exception that specific acceptance criteria would be included in the component test procedures.
Inspector's Comment - The inspector stated that since the
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tests will not be TWG reviewed the perf ormance of component safety related valves would also not be reviewed by the TWG.
He stated that it was his position that the performance tests TWG, of safety related valves must be reviewed e,
Licensee Comment - Mr. Toole stated that consideration would be given to including the timing of safety related valves in the preoperational test procedures, which are reviewed by TWG.
Subsequently, during the exit interview, Mr. Toole stated that the testing of safety related valves would be included in pre-operational test procedures.
(7)
Deficiency - The procedure only requires a check of 1 point This does not appear to be suf ficiet.t to on the pump curve.
verify pump performance.
Licensee Comment - Mr. Toole stated that more than 1 point on the curve would be checked to verify pump performance.
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-8-(8) Deficiency - The procedure states that the pumps and motors should be monitored for vibration; however, it is not specific in stating where the measurements will be taken nor what data shall be recorded nor what level of vibration is acceptable.
Licensee Comment - Mr. Toole stated that specific require-ments would be incorporated in this and other procedures where vibration monitoring is appropriate.
(9) Deficiencv - It was not apparent that the exit temperature alarm for the decay heat coolers would be tested.
Licensee Comment - Mr. Toole stated that this alarm would be checked in the electrical pre-check procedure, which is a pre-requisite for the conduct of the preoperational test precedure
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(10) Eeficienev - A number of components described in the FSAR are not tested in this procedure. Additionally, several perfor-mance specifications are not verified.
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Insnector's Comment - The inspector stated that it was point-less to identify each of the items since there are a large number and the test procedure requires extensive revision.
Licensee Ccmment - Mr. Toole indicated that the test proce-dure will be revised to cover all equipment within the sytem and verify performance data given in the FSAR.
b.
TP256/3 - Instrument and Control Air Svstem Functional Test (1) Deficiency - This test procedure is not approved by the TWG '
(Test Working Group) as required by Test Instruction No.18, which defines the methods for preparing, reviewing, modifying, and approving the various test procedures.
Licensee Comment - Mr. Toole stated that this test procedure was one of the test procedures prepared by Met Ed prior to GPUSC assuming responsibility for the technical content of th TMI-l test program.
He indicated that this procedure will be revised to conform to the present administrative procedures.
(2) Deficiency - There are no sign-off requirements for verifica-tion that required prerequisites have been satisfied.
There are also no sign-off requirements for verification that the required plant status has been established.
Licensee Conment - Mr. Toole stated that the test procedure O
will be modified to include sign-off for prerequisites and
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required plant status.
(3) Deficiency - There are no acceptance criteria for such items as:
Unloader operation Loaded compressor current
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Exit air temperature Safety valve set point
Dryer regeneration temperature Licensee Comment - Mr. Toole stated that the procedure would be modified to include appropriate acceptance criteria.
(4)
Deficiency - It is not apparent that the licensee plans to conduct the following tests of the instrument air system:
Compressor capacity System design flow Plant response to a loss of instrument air.
Licensee Comment - Mr..Toole stated that this test procedure will be modified to include a test of compressor capacity.
He stated that consideration would be given to conducting a system design flow test and a plant response to a loss of instrument air test.
He indicated that the latter two tests, if conducted, would be incivicd in a dif ferent test procedure since they would be run later in the test program.
Inspector's Concent - The inspector stated that it was his position that these tests must be run in order to adequately ~
verify system performance.
He indicated that failure to run these tests would represent a deficiency in the licensees pro-gram.
TP273/3 - Emergency Feed Water System Functional Test c.
(1) Deficiency - This test procedure is not approved by the TNG (Test Working Group) as required by Test Instruction No. 18, which defines the methods for preparing, reviewing, modifying, and approving the various test procedures.
Licensee Comment - Mr. Toole stated that this test procedure was one of the procedures prepared by Met Ed prior tc GPUSC assuming responsibility for the Technical Content of the TMI-l Test program.
He indicated that this test procedure would be revised to conf orm to the present administrr.tive pro-G cedures.
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(2) Deficiency - The procedure does not contain appropriate acceptance criteria.
Examples are as follows:
Turbine overspeed trip setting Turbine driven pump capacity Valve operating times Licensee Come.ent - Mr. Toole stated that the procedure will be revised to include appropriate acce,ptance criteria.
the performance of Deficieqcy - The procedure does not test (3)
a number of motor operated valves whose functioning is essential to the capability of the unit to perform its design safety function.
Licensee Cocment - Mr. Toole stated that the procedure would be revised to include tests of these valves.
TP401/3 - Station Batterv Discharce and Charae Tests d.
- The test does not verify the function of the (1) Deficiency battery charger trouble and the de voltage low alams.
Licensee Comment - Mr. Toole stated that these alarms will be tested.
Deficiency - The test data sheets for the charge test do not (2)
record individual charger output currents.
Licensee Comment - Mr. Toole stated that the data sheets will
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be modified to record individual charger currents.
(3) Deficien v, - Battery chargers lE and 1F are not tested.
Licensee Comment - Mr. Toole stated that these chargers will be tested in another procedure.
7.
Preoperational Test Index The inspector reviewed the Master Test Index (MTX) relative to the The deficiencies noted and the preoperational testing procedures.
inspector's and licens m 's comments were as follows:
- The inspector stated that the RO:I review had identified Deficiency 42 test procedures which are not apparently scheduled to be reviewed l
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by the TWG, but which appear to be safety related.
He stated that TWG review and approval of these test procedures and the test data would appear to be appropriate and in accordance with the licensee's administrative controls for the test program and FSAR commitments.
Licensee Comment - Mr. Toole stated that this list would be pre-serted to TWG for their review and that consideratien would be given to providing TWC review for those procedures.
Mr. Toole stated that he would advise the inspector of the results of this index review by TWG, He also stated that if Tk'G declined to review any tests, ho would indicate to the inspector the basis for that decision.
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