IR 05000289/1972017
| ML19260A077 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/16/1972 |
| From: | Brunner E, Mcleod B, Rebelowski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| References | |
| 50-289-72-17, NUDOCS 7910290699 | |
| Download: ML19260A077 (12) | |
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MEM0 ROUTE SLIP Sa * * ' 'wa ta'*-
'" aac""*aa-
'"***a-Form AEC-9) (i.ev. May 14.1947) AECM 0240 Note and return.
For sleatu *.
For Inform ation.
TO (Name and unit)
MunES AlaAAAES DO I?'?PECIO!f ?PTT I'O. 299/72-17
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oAn METROPOLITAN EDISON COMPANY J. G. Keppler, RO THREE MILE ISLAND 1 70 (Name and unet)
puTIALs ut1MAAKs The attached insoection recort is forwarded cc: J. B. Henderson, FO
' # 7 "#
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RO:HQ.(5)
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entral Files Copies of the report will be forwarded to TO (Name and un t)
pengs AEMAAK3 Reg. Standards (3)
the PDR, Local PDR, NSIC, DTIE and State Dir. of Licensing (1M C^"
Region III renresentatives after *eview by the 14cen,ee
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for proorietarv information.
FROM (Name afd unst)
AEMAAKS n
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. J. Brunner, RO: I
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PMont NGL DATE 11/16/72 U51 OThEA SIDE FOR ADotTIONAL REMAAK$
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U. S. ATOMIC ENERGY COMMISSION
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION I
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50-289/72-17 Docket No.:
50-289 RO Inspection Raport No.:
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Licensee:
Metropolitan Edison Company License No.:
CPPR-40
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Priority:
I B
Category:
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Iocation:
Middletown, Pennsylvania
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wer eactor @ $
Type of Licensee:
Rot. Ine, Unannounced
Type of Inspection:
et er 9,
6, & 27, 1972
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Dates of Inspection:
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September 27, 1972
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Dates of Previous Inspection:
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Principal Inspector:
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72 B.K.McLeod,[eactorInspector, Reactor Date
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Testing and Startup Branch Accom'panying Inspectors : dd
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'7 2.
T.A.Rebeldtski,ReactorInspector,
' Date
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Reactor Testing and Startup Branch Date None
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Other Accompanying Personnel:
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////d/~7 V Reviewed By:
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s E./J.Brunner, Chief,Reacto,rTestingandStart-Date
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up Branch
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SUMMARY'0F FINDINGS -
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Enforcement Action
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Violation Criterion II of Appendix B to 10 CFR 50 - Failure to establish a
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quality assurance program, which complies with the requirements of Appendix B to 10 CFR 50.
(Paragraph 2)
Licensee Action on Previousiv Iderttified Enforcement Items
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No enforcement items were identified in the previous startup and I
testing program inspection report.
Design Changes None Unusual Occurrences
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None
Other Sienificant Findines i
A.
Current Findines e
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The licensee has not yet defined the test program for pri-
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mary coolant leak detection systems. This item remains un-
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i resolved pending licensee review of his program.
(Paragraph 3.a)
2.
The licensee has not committed to the performance of in-place testing of relief and safety valves on the primary and second-ary coolant systems.
(Paragraph 3.b)
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B.
Status of Previousiv Recorted Unresolved Items i
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1.
The licensee has committed to the perlarmance of a plant response to a loss of instrument air test and a maximum transient flow test on the instrument air system. This ites
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is considered resolved.
(Paragraph 3.c)
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2.
The licensee has expanded the number of preoperational test procedures scheduled to be reviewed by TWG.
This item re-mains unrese'.ved pending licensee consideration of review of additional procedures.
(Paragragh 3.d)
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Management Interview i
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Management interviews were conducted at the conclusion of the inspec-l tion visits with Mr. Barton.
The following items were discussed during these interviews:
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RO Insoection P.eoorts The inspector infor=ed the licensee representatives of the AEC's new procedures, pursuant to 10 CFR 2.790, for placing inspection reports
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in the Public Document Room af ter the licensee has had an opportunity
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to review the reports for proprietary information..This information
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was also discussed with Mr. J. L Wise.
Quality Assurance
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The inspector stated that it appeared that the lack of an approved quality assurance program covering testing and startup activities for Three Mile Island 1 was a violation of Criterion II of Appendix B to 10 CFR 50, and that enforcement action would be initiated. He stated that testing of safety related systems and components is in progress and that the QA program covering this phase had not yet been approved nor was it in a complete form and ready to be approved. He emphasized that this had been an area of concern for a number of months and that he had discussed this particular item several times with licensee
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Esnagement. The inspector stated that he had reviewed the program and discussed the obvious deficiencies in the program with a licensee representative.
(Paragraph 2)
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Preonerational Test Procram The inspector stated that his discussions of the testing of primary coolant leak detection systems and the testing of safety and relief valves with licensee representatives indicated that the licensee was not ready to state a position on these tests. The inspector stated that his position was that all primary coolant leak detection and mon-itoring systems must be preoperationally tested to verify the sensitivities and accuracies presented in the FSAR, and that failure to conduct in-place testing of safety and relief valves could represent a deficiency in the licensee's program.
The licensee stated that he understood the inspector's pcsition and that he would review the olans for testing in these areas and discuss. them with the inspector during a subsecuent inspection visit.
(Paragraphs 3.a and 3.b)
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i The inspector stated that there were still four additional test i
procedures which appeared to warrant review by the Test Working i
Group (TWG).
The licensee indicated that he was aware of the in-spector's position and that he would reconsider the. advisability ij of TWG review of the procedures.
(Paragraph 3.d)
h Inconsistencies Between the FSAR and the Administrative Controls For j
the Preoperational Test Program
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The inspector stated that he noted several statements in the FSAk which did not agree with the administrative controls for the test
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program, as defined in the licensee's test manual. He stated that i
these must be resolved by either changing the test manual or amend-j ing the Final Safety Analysis Report to reflect the present ad-g ministrative controls for the test program.
The licensee stated j
that he was aware of the inconsistencies referred to by the inspec-
tor and that an effort was being made at the present time to amend
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the FSAR to accurately reflect the test program.
The licensee
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stated that he felt'the proposed administrative controls for the
test program were adequate and that amending the FSAR would be an acceptable approach.
(Paragraph 3.e)
ks Post-Erection Cleaning
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The inspector stated that RO review of the generic procedure for post-erection cleaning indicated that some corrective measures were necessary.
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The licensee stated that he was awsre of the RO concerns and that cor-J i
rective action would be considered.
(Paragraph 5)
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Preoperational Test Procedures i
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The inspector stated that the RO:I review of certain preoperational i
test procedures indicated that there are some deficiencies which re-i quire corrective action.
He stated he had discussed these deficiencies
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with members of the testing staff and obtafned commitments for re-
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solution. The licensee stated that he was aware of those commitments and that he concurred with them.
(Paragraph 4)
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DETAILS
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Persons Centacted
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Metropolitan Edison Comoany i
J. L. Wise, Superintendent, Three Mile Island Nuclear Station J. G. Herbien, Station Engineer
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J. R. Floyd, Nuclear Engineer
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General Public Utilities Service Corporation J. J. Barton, Startup and Test Manager (Acting Test Superintendent)
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R. J. Toole, Assistant Test Superintendent M. A. Nelson, Technical Engineer T. W. Hawkins, Shift Test Engineer Burns and Roe. Incorporated i
ef N. E. Dickinson, Engireer, Special Projects 2.
Quality Assurance
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The inspector reviewed a document entitled, "Three Mile Island Test Manual" (Preliminary Draf t).
This manual states that it is the QA
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i program for GPU activity associated with testing.
The apparent deficiencies which were identified and the inspector's and li-
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censee's comments relative to these difficiencies were as follows:
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a.
Deficiency - The test manual is not approve /. and the required approvals are not specified. This is contrary to Criterion II
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of Appendix B to 10 CFR 50 which states in part that, "The
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applicant shall establish at the earliest practicable time, i
consistent with the schedule for accenplishing the activities, a quality assurance program which complies with the require-
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ments of this appendix. This program shall be documented by written policies, procedures or instructions.
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Insnector's Comment - The inspector stated that the licensee appeared to be in violaticn of AEC regulations since pre-operational tests of safety related systema are being con-ducted and an approved qyality assurance program is not in existence.
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Deficiency - The inspector noted that there was apparently no QA program for Met Ed participation in the test program.
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Licensee Comment - A licensee representative stated that.
the test manual was also intended to be the QA program for
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Met Ed participation in the test program, although it is not i
specifically stated in the manual.
I Deficiency - Section III.b includes a statement which allows c.
exceptions to the. requirements of 10 CFR 50, Appendix B, on the approval of the GPU-QA manager and the GPU Startup and Test Manager.
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j Inspector's Comment - The inspector stated that this state-
ment appeared to be an authorization to deviate from AEC re-j gulations. He stated that compliance with AEC regulations is not optional.
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Deficiency - The test manual does not address several of the
,..i 18 criteria of Appendix B to 10 CFR 50 nor does it reference where these are addressed or how compliance will be assured.
I Licensee Comment - A licensee represectative stated that corrective action would be taken.
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Deficienev - The manual lists 22 test instructions which the j
manual defines as documehts used to control the various activ-ities of the test program. Of these 22 test instructions, only
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4 are issued and approved.
Licensee Comment - A licensee representative stated that ef-forts are in progress to issue more~ of the test instructions
and that unnecessary test instructions will be deleted.
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The inspector stated that these few cecsents were the result of a
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very brief and general review of the subject document. He stated that due to the incompleteness of the program, a detailed review
at this time was not warranted.
The inspector stated that a citation would be written which would be against Criterion II of Appendix B to 10 CFR 50.
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3.
Preonerational Testing Procram a.
Primary Coolant Leak Detection and Measurement
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The inspector stated that there was no indication in the li-censee's Test Index that specific tests of primary coolant leak detection and measurement systems would be conducted. The
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i inspector inquired as to the licensee's plans for testing i
of these systems. A licensee representative stated that he was not sure of what testing of this equipment would be per-
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formed but that it would be checked into and the results dis-
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cussed with the inspector during a subsequent inspection visit.
The inspector stated that his position was that all primary coolant leak detection and leak rate measurement systems must be preoperationally tested, to the extent practicable, to determine that these systems meet the accuracies and sensi-
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tivities indicated in the FSAR.
b.
Testing of Safety and Relief Valves I
The inspector inquired as to the licensee's plans for testing l
of safety and relief valves on the primary and secondary coolant j
systems. The licensee representstives stated that present plans i
were to perform testing of safety and relief valves in the fol-l loving manner:
-k (1) Primary system safety and relief valves would be set and L'
tested by the manufacturer prior to receipt on site.
(2) Secondary system safety varves would be tested in place
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with steam pressure in the line; however, the valves would be lifted with a hydraset rather than by increasing
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system pressure to the set points.
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I The inspector stated "that it was his position that these
.I valves must all be tested in place and with pressure sup-i
plied from the protected system only.
The licensee re-j presentatives indicated that there could be some dif-i ficulty in performing these tests in that manner. They stated that they would review the possibility of doing i
i the tests and would discuss the results of this review with the inspector.during a future inspection.
c.
Instrument Air Systems Testing *
The inspector reviewed Master Test Index Revision No. TCN-7 and verified that a test of plant response to loss of instru-ment air had been added to the Master Test Index. Additionally,
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- RO Report No. 50-289/72-13, Paragraph 7.b. (4)
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licensee repre:antatives stated that a maximum transient flow test on the instrument air system would be conducted prior to hot functional testing.
d.
Review of Safety Related Preoperational Test Procedures
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J A previous RO inspection * had identified the 42 test pro-cedures which were not apparentir scheduled to be reviewed by the TWG buc which appeared to be s 3fety related. As a i
result of that inspection, the list wts reviewed by the Test l
Working Group and one of the following actions taken for each I
test:
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l The test was scheduled for TWG review.
The test was incorporated into another test which is scheduled for TW review.
(~T The safety related aspects were incorporated into other tests which will be TWG reviewed.
It was elected not to schedule the test for TWG review, j
and the basis"for the decision was reviewed with the in-
spector.
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I The resolution of all but. the following 4 tests was satisfactory:
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Diesel oil flush
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Liquid waste disposal Intermediate cooling system f
Solid waste disposal system operation. test A licensee representative stated that further cons.deration
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would be given to TWG review'of these 4 tests.
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Inconsistencies Between FSAR Statements and Pronosed Admin-e.
istrative Controls for the Test Procram The inspector stated that he had noted seve:21 areas in which the proposed test program administrative controls were not consistent with statements in the Final Safety Analysis Re-
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part.
The inspector reviewed the specific differences with
1479 265 l
- RO Report No. 50-289/72-13 Paragraph 8
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the licensee.
He indicated that the problem must be re-solved or appropriate enforcement action would te initiated.
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4.
Preoperational Test Procedures
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j procedures and identified several apparent deficiencies which
required resolution. The results of this review and the licensee's comments relative to the deficiencies identified, were as follows:
a.
TP401/3 Station Battery Discharge and Charge Test
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(1) It was noted that the test procedure had been modified I
to*; test all battery chargers, record individual charg-
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er currents, and verify the functioning of the battery charger trouble and DC low voltage alarms. These mod-ifications had been incorporated as Tes't Change Notice-1.
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(2) Deficiency - It is not readily apparent that the discharge d
characteristics curve provided is accurate for the bat-I teries at Three' Mile Island.
Licensee Comment - A licensee representative agreed to i
contact the battery manufacturer and obtain the follow-
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(a) Confirmation that the curve is truly represan'.ative
of this battery.
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(b) Confirmation that this curve is developed from en-pirical data.
(3) Deficienev - It is not apparent that the sign-off for Sec-tion 8 (Prerequisite System Conditions) applies to all items within that sectiot.,
It appears that it may only apply to the last of the prerequisite conditions.
Inspector's Comment - The inspcetor stated that this question also applies to the otha.r procedures reviewed and that it should be resolved on a generic basis.
Licensee Comment - A licensee representative agreed that it was not clear in this procedure and others as to what
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- RO Report No. 50-289/72-13 Paragraph 7.d i
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l the signature under prerequisite system conditions and i
other prerequisites meant, i.e. whether it indicates I
completion of the last step or all steps. The licensee representative apeed to take.orrective action on a generic basis.
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b.
TP256/3 - Instrument and Control Air System Functional Test
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(1) The inspector verified that:*
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(a) The test procedure approval page has been revised and the procedure approved by TWG.
f (b) The procedure has been revised to include appro-i priate acceptance criteria.
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(c) The procedure has been revised to include a test of I
compressor capacity.
O (2) Deficiency - The quantitative acceptance criteria for I
these steps in this procedure are not sufficiently de-finitive to conpare the measured values against. Values are given; ho' wever, it is not stated whether these are minimum or maximum limits nor is any acceptable range specified.
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Licensee Comment - A licensee representative stated that
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these deficiencies will be corrected via the deficiency list attached to the procedure.
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(3'
Deficiency - One section of the procedure does not require recording data to compare with the acceptance criteria.
Licensee Comment A licensee representative stated that this deficiency would be corrected via the deficiency list attached to the procedure.
5.
Post-Erection Cleaning The inspectors conducted a review of TP250/4 - General Procedure for Cleaning and Flushing Systems and Components. This is a generic
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procedure _which is intended to insure that systems are cleaned to their desired cleanliness grade prior to system operation.
This c
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general procedure defines flushing philosophy that vill apply to all systems requiring cleaning or flushing except where the TWG decides that a specific cleaning procedure is required.
It also serves to identify the required documentation associated with flushing of systems and/or components.
The review of this pro-
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cedure indicated that it is consistent with the administrative controls defined in the test manual and,in Test Instruction 18.
It was noted that the procedure has been approved for performance by the Test Working Group.
The procedure stated the class of cleanliness to be applied to each of the piping systems at Three Mile Island and also defines this cleanliness classification in terms of qualitative and quantitative acceptance criteria.
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j During the review, some apparent deficiencies were noted which require resolution.
The apparest deficiencies which were iden-
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j tified and the inspector's and licensee's comment's rel.ative to i
these deficiencies were as follows:
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Deficienev - It was not apparent to RO:I durin'g their re-a.
O view that the method of determing pH of effluent water would be sufficiently accurate to provide data which could be ecm-pared against acceptance criteria.
- Licenaee Comment - The licensee agreed with this state =ent
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and indicated that corrective action would be taken.
It was indicated that a pH meter would probably be used rather than the pH paper specified in order to provide a number which
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could be used to cospare against the acceptance criteria.
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b.
Deficiency - The procedure required determination at the pre-sence or lack of presence of organics; however, it was not
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specified what method would be used.
Licensee Comment - The licensee indicated that considerati n would be given to clarifying the method to be used in the determination of organics.
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Deficiency - The procedure specifies a maximum chloride con-for influent water but no chloride specification for tent effluent water.
Licensee Com=ent - The licensee agreed to consider the need for a chloride specification on efflu.ent water for those systems in which chloride contamination can pose a problem.
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