IR 05000289/1973001
| ML19256D531 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 02/07/1973 |
| From: | Brunner E, Mcleod B, Rebelowski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D522 | List: |
| References | |
| 50-289-73-01, 50-289-73-1, NUDOCS 7910180841 | |
| Download: ML19256D531 (16) | |
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i U. S. ATOMIC ENERGY COMMISSION
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DIRECTORATE OF REGUIATORY OPERATIONS i
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REGION I
RO Inspection Report No.: 50-289/73-01 Docket No.:
50-289 i
Licensee: Metropolitan Edison Company License No.: CPPR-40
i Three Mile Island Nuclear Station Priority:
Category:
B Location: Middletown, Pennsylvania
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Type of Licensee: Power Reactor (PWR)
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Type of Inspection: Routine, unannounced (Test and Startup)
Dates of Inspection: Janue.rv 9, 10, and 11, 1973
{'DatesofPreviousInspection: Janusry 5, 1973 Prineipal Inspector:
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'? 03 B. K. McLeod, Reactor Inspector Date
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Reporting Inspectors:
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RebelowsK1, neactor inspector Date h$
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J. T. Shedlosky, Reactor Inspector Date Other Accompanying Personnel: NONE Reviewed By:
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E. J. Brunner, Chief, Facility Tasting and Date
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Startup Branch 1451 129 t
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(~h SUMMARY OF FINDINGS i
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Enforcement Action i
i None Licensee Action on Previously Identified Enforcement Items Corrective action relative to the failure _a establish a quality assurance
program as required by Criterion II of Appendix B, to 10 CFR 50, was not completed as stated by the licensee in his letter of November 20, 1972.
(Paragraph 5)
Design Changes None Unusual Occurrences i
None i
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Other Sinnificant Findings
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A.
Current Findings t
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.The licensee has committed to the functional testing and timing 1.
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of safety related active components.
(Paragraph 6.d)
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2.
The scope of the core flood flow test, while consistent with the g
FSAR, does not appear to provide a valid demonstration of the i
capability of this system to deliver coolant under emergency con-l ditions.
This item remains unresolved pending review by R0 Headquarters.
(Paragraph 7.c.2)
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The licensee has not committed to the functional testing of safety
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related alarms, to the extent practicable, during pre-operational
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testing.
This item remains unresolved pending licensee review of his program.
(Paragraphs 7.c.3 and 7.c.5)
4.
Significant personnel changes have been made in the licensee's operating staff.
(Paragraph 2)
5.
The RO esti= ate of the date for completion of construction has been revised.
(Paragraph 3)
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The licensee has agreed to revise the containment testing se-
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quence.
(Paragraph 6.e)
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B.
Status of Previousiv Reported Unresolved Items
1.
The licensee has expanded the number of pre-operational test pro-j cedures scheduled to be reviewed by the TWG, to include all those identified by RO as apparently requiring this review.
This item is considered resolved.
(Paragraph 6.a)
2.
.The licensee has defined his proposed test program for primary coolant leak detection and measurement systems.
This item re-j mains unresolved pending further RO review.
(Paragraph 6.c)
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3.
The licensee has reviewed his program for the testing relief and sa'fety valves on the primary and secondary coolant systems.
Based I
on commitments obtained from the licensee, this item is considered resolved.
(Paragraph 6.b)
Management Interview Management interviews were conducted with Messrs. Wise, Klingaman, and Herbien en January 10, 1973 and with Mr. Barton by telephone on January
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(,j 22, and 30, 1973.
The following items were discussed during these interviews:
i A.
RO Inspection Reports l
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The inspector inquired as to the desired distribution of RO Inspection Reports,'for proprietary review, within the licensee's organization.
The licensee provided the inspector with the preferred distribution for documentation letters and inspec*'on reports within the Met Ed/GPU organizations.
B.
RO Estimate of Core Load Date t
The inspector informed the licensee that as a result of the plant's construction status observed during this inspection, the R0 estimate
for core loading has been revised from September 1973 to November
1973.
(Paragraph 3)
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J C.
Observed Erratic Performance of Differential Pressure Transmitters The inspector informed the licensee of the observed erratic perfor-
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mance of certain models of a particular manufacturer's differential pressure transmitters, which may be used in safety related systems
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at nuclear power plants.
The licensee stated that an investigation l
would be conducted to determine if any of these transmitters were
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being utilized at Three Mile Island.
He indicated that the results of this review and any appropriate corrective action would be dis-cussed with the inspector during a subsequent inspection.
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D.
Pre-operational Test Procedures The inspector stated that R0:I review of selected pre-operational test procedures had revealed certain deficiencies which required resolu-tion.
He indicated that these had been discussed with members of the licensee's staff and that proper resolution of a number of items had been obtained.
The licensee stated that he was aware of the defi-ciencies and that he concurred with the commitmcats for resolution.
The inspector stated that the following items relative to pre-oper-ational test procedures, remain unresolved at this point in time.
Core Flood Flow Test - The inspector stated that while the test pro-()
cedure is consistent with the testing requirements in the FSAR, it did not appear to provide an adequate test of the system's capability to deliver the required volume of coolant.
The inspector indicated
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that this item would be reviewed by R0 Headquarters and that based
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on the results of that review, the test would either be acceptable to Regulatory or the licensee would be requested to revise the FSAR to include a more stringent test.
(Paragraph 7.c.2)
Testing of Safety Related Alarms - The inspector stated that it was
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j not apparent to RO that the functional testing of safety related I
alarms was being included in pre-operational test procedures to the
extent practicable.
The licensee agreed to review his program in i
this regard and to discuss this.with the inspector during a future
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inspection.
(Paragraphs 7.c.3 and 7.c.5)
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Vibration Data on Safety Related Rotating Ecuipment - The inspector stated i
that the vibration data required for safety related rotating equipment did not appear to provide any indication of the acceptability of the equipment or a base line to which future data could be compared.
The licensee stated i
i that this item had been identified by the licensee previously and that the construction contractor had been requested to review this question.
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l licensee indicated that the results of this review would be discussed j
with the inspector during a subsequent inspection visit.
(Paragraph 8)
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l E.
Quality Assurance l
The inspector stated that it was apparent that the licensee had not taken l
the corrective measures described in the response to the citation relative to quality assurance which was issued as a result of the last inspection by the Testing and Startup Branch.
The inspector stated that in that response, the licensee had indicated that the Test Manual would be ap-l proved by the Test Working Group and issued by November 30, 1972 and that Test Instruction No. 18 would also be approved and issued by November 15, 1972.
The inspector also indicated that the licensee's response implied that the licensee would be in full compliance as of that date.
He stated that contrary to those commitments the Test Manual is not yet approved, Test Instruction No. 18 is not yet approved, and no approved quality assurance program covering testing and startup activities has been issued.
The licensee s.ated that he realized that
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the committed date had since passed; however, that the Test Manual i
world be approved within the next week and that Test Instruction No.
18 ece currently being revised and would be approved by February 15, 1973.
The licensee also stated that the Test Manual was no longer going to be the QA program for a testing and startup phase and that a separate QA program was being prepared at the present time.
He stated that this program would be approved and issued on or before March 3, 1973.
The inspector stated that he was concerned about the ()
fact that the licensee had not fulfilled his previous commitments.
l He indicated that he would follow licensee action on the present l
commitments closely.
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F.
Testing of Safety Related Active Components The licensee stated that the inspector's concerns had been considered I
and that the pre-operational test program would be madified to assure
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that:
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All active comporents, the operating times of which affect the I
ability of systems designed to seismic Category I criteria to perform their design safety function, will be functionally i
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tested, where practicable, under the system conditions of tem-perature, pressure, differential pressure and flow that would be expected when those components are required to operate, and
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2.
During these functional tests, the elapsed time required for each of these components to reach its required operational state will be measured and verified to be within acceptable limits.
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DETAILS i
1.
Persons Contacted
l Metropolitan Edison Company R. M. Klingaman, Suoerintendent, Three Mile Island Nuclear Station J. G. Herbien, Assistant Superintendent, Three Mile Island Nuclear Station i
J. Colitz, Supervisor of Operations
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R. S. Deakin, Health Physics Supervisor
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R. Porter, Shift Supervisor General Public Utilities Service Corporation J. J. Barton, Startup and Test Manager (Acting Test Superintendent)
R. J. Toole, Assistant Test Superintendent
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M. A. Nelson, Technical Engineer 2.
Personnel Changes i
l The licensee informed the inspector of the following organizational changes:
Mr. J. L. Wise, former1v the Station Superintendent, is leaving the
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co=pany to accept another position.
Mr. R. M. Klingaman, formerly Assistant Superintendent, has been promoted to Plant Superintendent.
Mr. J. G. Herbien formerly Station Engineer, has been promoted to Assis-s tant Superintendent.
A replacement for Mr. Herbien, in the Station Engi-neer position, has not been announced.
3.
Plant Physical Insoection l
The inspectors conducted a physical inspection of the Three Mile Island
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I plant with emphasis on the following systems:
decay heat removal, core i
flood, decay heat closed cycle cooling, decay heat river water and sta-l tion batteries.
As a result of this inspectian, the R0 estimate of core loading date for Three Mile Island I has been revised from September 1973, i
to November 1973.
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4.
Log Book Review
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The inspectors reviewed the Shift Test Engineers Log for the period of February 22, 1972, to January 9, 1973.
This log is described in Test Instruction No. 17, as the official log for the test program.
The in-
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spectors noted that the Jog is, in general, being maintained as pre-scribed by Test Instruction No. 17.
Dur ing the review of this log,
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it was noted that several examples of the following type of problems were found:
a.
Failure to close-out identified problems.
b.
Lack of consistency and clarity of certain entries.
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Failure to reference the master test index No. on specific test pro-cedures being performed.
The licensee agreed to review the proper maintenance of the shift test engineers log with the shift test engineers and to stress proper main-i tenance of this log, in accordance with Test Instruction No. 17, in the l
future, f'
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Quality Assurance i
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The inspector stated that he wished to review the corrective actions taken in accordance with the commitments made by Mr. J. G. Miller in his letter of November 20, 1972, addrersed tc Mr. James P. O'Reilly in response to the notice of violation dated October 31, 1972.
Specif-ically, the inspector asked to review the test manual which, according to the licensee's letter, would be approved and 1. sued by November 30, 1972.
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A licensee representative stated that the test manual had not yet been approved but was expected to be approved within the next week.
The licen-see representative further stated that the test manual would no longer be the quality assurance program for the Three Mile Island I test pro-gram.
He stated that the separate QA program was being prepared.
The inspector inquired as to whether Test Instruction No. 18, which the licensee indicated would be approved.and issued by November 30, 1972, was approved. A licensee representative indicated that Test Instruction No. 18 is not yet approvec but is expected to be approved by February 15, 1973. The inspector stated that it was apparent that the licensee had not completed any of the corrective actions to which he had committed in the letter of November 20, 1972, and that the licensee was still in violation of AEC Regulations.
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Pre-operational Test Program
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Review of Safety Related Pre-operational Test Procedures *
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The licensee indicated that further consideration had been given to TWG review of the remaining test procedures which RO had in-
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dicated appeared to warrant that review.
The licensee repre-
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sentative stated that those test procedures would be reviewed
by TWG.
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b.
Testing of Safety and Relief Valves **
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i Licensee representatives indicated that they had reviewed their plans for the testing of safety and relief valves on the primary and secondary coolant systems.
They indicated that as a result of this review, which included discussion with the valve and NSSS vendor, their program would be as follows:
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(1)
The primary system power actuated relief valve will be tested in place during hot functional testing.
This testing will verify the set point, relief capacity, and the adequacy of piping restraints to withstand reaction forces.
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(2)
The primary system safety valves will be set and tested by the manufacturer prior to receipt on site.
Prior to con-sidering these valves acceptable for service, the licensee will conduct a review of the documentation supplied relative to the testing, shipping, storage and installation of these valves to verify that the testing and handling was such that the valves can be considered acceptable for nuclear plant service.
i (3)
The secondary -system safety valves will be tested in place with steam pressure in the line during hot functional test-
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The method of determining the lifting pressure of
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these valves will be to lif t them with a hydraset rather i
than by increasing system pressure to the set point.
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- RO Report No. 50-289/72-17, Paragraph 3.d
- RO Report No. 50-289/72217, Paragraph 3.b
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s Additionally, the licensee will instrument the exhaust lines from these valves and verify that during transient system testing each of the valves lifts.
This will also verify the adequacy of the discharge piping and restraints to withstand reaction forces generated during valve open-ing.
c.
Primary Coolant Leak Detection and Measurement
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The licensee indicated that in response to a question by the inspector during the last inspection visit, the plans for testing of the primary coolant leak detection and leak rate measurement systems during the preoperational test program had been reviewed. He described the licensee's proposed program as follows:
During hot functional testing, stable conditions would be established and a primary loop base leak rate calculated utilizing installed instrumentation and the procedure to be used in calculating a leak rate during normal operation.
This operation will be repeated several times to obtain a consistent base leak rate figure.
A known leak rate would then be established by bleeding coolant via the sampling sys-O tem or by another suitable means of bleeding coolant.
A leak rate'would then be calculated again using licensee operating procedures and installed instrumentation and this leak rate would be compared against the known increase in leakage and the base leak rate.
These operations would be repeated several times in order to establish a known accuracy of the leak rate monitoring systems.
The inspector indicated that R0 would review this proposed pro-gram and that he would discuss this subject with the licensee
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during the next inspection visit.
I d.
Functional-Testing of Safety Related Active Cocoonents i
The inspector stated that it was not apparent that the licensee's
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plans for the functional testing of safety related active com-l ponects would assure an adequate test of the system.
The inspec-tor indicated that his concern was that safety related active
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A L a components be functionally tested under conditions which, to the extent practicable, simulate those conditions in which the compon-ent would be expected to perform its design safety function.
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indicated that the functional test should include provisions to verify that the operating times for these components are within acceptable values.
A licensee representative indicated that such a program would be considered.
The inspector stated that this subject would be discussed during the management interview.
e.
Containment Testing The licensee inquired as to the RO position, if any, on the se-quence of containment testing; i.e.,
structura integrity and
leak rate tests. The inspector replied that the proposed Ap-
pendix J to 10 CFR 50, as presently written, states that all Type
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A tests shall be conducted in accordance with the provisions of the American National Standard N45.4 - 1972, Leakage Rate Testing of Containment Structures for Nuclear Reactors and that this standard requires that structural integrity tests shall pre-
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ceed leakage rate testing.
He indicated that the R0 position is that the testing will be conduct ' in the sequence speci-fied by these documents.
A licensee representative stated that it had been planned to conduct the leakage rate test prior ()
to the structural test but that the sequence would be changed j
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based on the inspector's comments.
He also indicated that,this change might be in conflict with statements in the FSAR and that
j this would be resolved with the Directorate of Licensing.
7.
Pre-operational Test Procedures I
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. Status of Test Procedure Preparation, Review, and Aoproval Preoperational Test Procedures Approved for Performance
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Preoperational Test Procedures Awaiting Final Approval
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Preoperational Test Procedures Under Review
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Preoperational Test Procedures Not Written
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Status of Preoperational Testing
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Preoperational Tests Completed and Accepted
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Preoperational Tests Completed and Under Review
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l Preoperational Tests in Progress
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Freoperational Tests Not Started
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c.
RO Review of Preoperational Test Procedures The insp_-tors conducted a review of the following pre-operational
I test prt.dures:
TP 180/3 Fire Protection System Functional Test TP 201/5 Cote Flood Flow Test i
TP 203/1 Borated Water Storage Tank Functional Test TP 263/4 Decay Heat River Water System Functional Test l ()
TP 264/4 Decay Heat Closed Cooling System Functional Test I
TP 267/4 Nuclear Service Closed Cooling Water System
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j Functional Test
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During this review, the inspectors identified a number of apparent deficiencies, which require resolution.
The deficiencies identi-fled and the licensee's and inspectors comments relative to these
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deficiencies were as follows:
(1)
TP 180/3 Fire Protection System Deficiency - It was not apparent to the inspectors that the licensee planned to test the Deluge and Halon 1307 Systems.
Licensee Comment - The licensee stated that additional pro-cedures are planned which will include the testing of these systems.
Deficiency - It does not appear that the valve lineup spe-cified in this procedure will allow verification of adequate water supply'to all system hydrants.
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Licensee Comment - The licensee stated that the procedure will be reviewed and revised to achieve a proper test.
Deficiency - It was not apparent that the melt point on the i
fuseable links has been verified and documented.
Licensee Comment - The licensee indicated that this matter would.be reviewed and discussed with the inspector during a subsequent inspection.
(2) TP 201/5 Core Flood Flow Test I
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Deficiency - The core flood flow test does not demonstrate j
CF system coolant delivery capability.
I Inspector's Comment - The inspector stated that a review
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of the FSAR indicated that the scope of the test was consis-l tent with the test description in Amendment 32 to that document; however, it was his position that the C (R did not specify a suitable test of CF system coolant delivery capability.
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Licensee Comment - The licensee stated that he planned to con-duct the test as described in the FSAR.
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. Inspector's Comment - The inspector stated that the matter of the adequacy of the core flood flow test, as described in the FSAR, would be forwarded to R0 Headquarters for review, eval-uation and possible action.
(3) TP 203/1 Decay Heat Removal System, Borated Water Storace Tank
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Functional Test Deficiency - It we.s not apparent to the RO inspectors that the licensee planned to functionally test and time the operation of the BWST isolation salves.
Licensee Comment - The licensee stated that functional testing and timing of these valves would be included in TP 250/7.
Deficiency - It was not apparent to the RO inspectors that the licensee planned to test the heat tracing of the line from tha BWST to the auxiliary building.
Licensee Comment - The licensee stated that a separate test procedure w'ill be written to functionally test all heat tracing.
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Deficiency - The procedure does not require a check of the BWST low temperature alarm setpoint.
Licensee Comment - A licensee representative indicated that
not including a test of this alarm in the pre-operational test procedure was consistent with the testing policy prom-ulgated by licensee management.
Inspector's Comment - The inspector stated that the subject
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appeared to Lc one which could best be resolved during the management interview and that he would discuss it further at that time.
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Deficiencv - The acceptance criteria does not include accuracy requirements for the level indicators (as compared to the mano-meter installed for the test) and the acceptance criteria for the accuracy of the level alarms is not specific as to the
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standard to be used for comparison.
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Licensee Comment - The licensee stated that the acceptance
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criteria for the level indication and alarm systems would
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be reviewed and the results of that review discussed with f
the inspector during a subsequent inspection.
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TP 263/4 Decay Heat River Water System Functional Test
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Deficiency - It was not apparent to the R0, inspectors that
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the licensee planned to test the following features of the
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system:
Automatic start of the DHRW pumps on an engineered safeguards actuation signal
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Automatic opening of the DERW pump discharge valves on an engineered safeguards actuation signal Licensee Comment - The licensee stated that these functions would be verified in the ES actuation test.
Deficiency - It was not apparent to the RO inspectors that the licensee, planned to demonstrate the heat removal capacity of the Decay Heat River Water System.
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Licensee Comment - The licensee stated that system heat removal capability would be verified during the unit cooldown test to be conducted at the completion of hot functional testing.
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Deficiency - The pump curve provided with the procedure is.
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scaled such that it does not provide a useful standard for evaluation of pump performance.
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Licensee Comment - The licensee indicated that the curve j
would be reviewed for possible clarification.
(5)
TP 264/4 Decay Heat Closed Cooling System Functional Test
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Deficiency - It is not apparent that the high and low level alarms on the Decay Heat Closed Cycle Cooling System Surge
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l Tanks will be functionally tested.
Licensee Comment - A licer.see representative indicated that not including a test of this alarm in the pre-operational test procedure was consistent with the testing policy es-tablished by licensee management.
Insocctos's Comment - The inspector stated that the subject
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I appeared to be one which could best be resolved during the management interview and that he would discuss it further at that time.
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Deficiency - It was not apparent to the LO inspectors that the licensee planned to demonstrate the heat removal capa-bility of the system.
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Licensee Comment - The licensee stated that system heat re-
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moval capability would be verified during the unit cooldown
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test to be conducted at the completion of hot functional testing.
Deficiency - It was not apparent to the R0 inspectors that the
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licensee planned to test the automatic start of the DHCCW pumps on an engineered safeguards actuation signal.
Licensee Comment - The licensee stated that this function would be verified in the ES actuation test.
(6)
TP 267/4 Nuclear Service Closed Cooling Water System Functional Test Deficiencv - The procedure does not require verification of coolant flow to several safety related components.
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Licensee Commeat - The licensee stated that the feasibility of determining pr oper flow to these components during pre-oper-ational testieg would be investigated, and that the results I
of that invest.gation would be discussed with the inspector
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during a subst.quent inspection visit.
Deficiency - The inspectors noted that the test of system restart capability following 1 station blackout, did not appear to test this capabilit?' under the most demanding conditions to be expected.
Licensee Comment - The licensee indicated that this item
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would be reviewed and that the results of this review would be discussed during a subsequent inspection visit.
8.
Post-Installation Comporent Testing The inspectors reviewed TP 250/2, Revision 2, entitled, " Testing and checking of mechanical and electrical equipment." This procedure j
defines the requirements for testing and checking of equipment after installation, and prior to turnover to Met Ed for functional and oper-ational testing.
The procedure also identifies the documentation required for those tests and prescribes the methods to be utilized f,)
for system turnover and acceptance for testing.
During this review, I
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j it was noted that the instruction, and accompanying data sheet, for
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measurement and recording of vibration data for rotating equipment do not appear to provide meaningful vibration data.
The licensee indicated that this deficiency was recognized and that efforts to resolve the problem with the construction contractor were in progress.
9.
Post-Erection Cleaning The inspector stated that during.a previous RO inspection * certain apparent deficiencies in the licensee's general procedure for clean-ing and flushing systems and components were identified which required resolution.
He stated that for two of these deficiencies, the licensee had indicated only that corrective action would be considered.
The in-spector inquired as to the licensee's plans for corrective action on
- RO Inspection Report No. 50-289/72-17, Paragraph 5
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these cwo items.
The licensee indicated that the following corrective actions would be taken:
TP 250/4 will be revised to define the method to be used in the
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determination of organics Effluent samples will be analyzed for chloride content at the conclusion of specified system flushing on the following systeme:
l Makeup System
Core Flood Decay Heat
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