IR 05000289/1973009
| ML19256D528 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/27/1973 |
| From: | Brunner E, Rebelowski T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D526 | List: |
| References | |
| 50-289-73-09, 50-289-73-9, NUDOCS 7910180839 | |
| Download: ML19256D528 (9) | |
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U. S. ATO?!IC ENEl CY C0!D11SSIO::
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DIRECTORATE OF REGULATORY CPETATIONS
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REGION I
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RO Inspection Report No.: 50-289/73-09 Docket No.: 50-289 Licensce: Metropolitan Edison Company License No.:CPPR-40
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Three Mile Island I Priority:
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Category:
B.1
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i Middletown, Pennsylvania
,, Location:
e l
Type of Licensce: B&W 871 MWe PVR
I) ' Type of Inspect. ion:
Special, Announced
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Dates of Inspection: August 14-15, 1973
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Dates of Previous Inspection: August 6-7, 1973 Reporting Insp tor:
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T.A.Rebelowsk[,ReactorInspector DXTE
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Accompanying Inspectors:
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Reviewed By:
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E./.Brunner, Chief DATE Fadility Test & Startup Branch
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SUMMARY OF FINDINGS A.
Enforcement Action (Test and Startun)
None B.
Licensee's Action on Previousiv Identified Enforcement Items (Test
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and Startup)
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None C.
Design Changes None
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D.
Unusual Occurrences
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None S
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t E.
Other Significant Findings
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1.
Current Findings i
I The licensee questioned the Regulatory Operations position of back-fi.tting,10 CFR 50, Appendix J, dated February 5,1973, effective i
March 16, 1973, in regards to 'the conteinment leak rate testing.
(Management Interview, Paragr' ph 1)
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2.
Status of Previousiv Reported Unresolved Items (Test and Startuo)
Not applicable, special inspection.
F.
Management Interview A management interview was conducted with Messrs. Klingaman, Barton, and Herbein on August 15, 1973 at the conclusion of the inspection.
The following items wera discussed:
1.
10 CFR 50, Appendix J, dated Februarv 5, 1973 The inspector stated that the RO:I review of Initial Reactor Building Leak Rate Test procedure would be reviewed against G
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I Appendix J,10 CFR 50 dated February 5,1973 and other appropriate documents.
The licensee stated that the FSAR commitment referenced Appendix J,10 CFR 50, dated August 27, 1971, and that present plant design might not totally reflect the present requirements of Appendix J.
(Details, Paragraph 2)
2.
Initial Reactor Building Leak Rate Test (ILRT) T/P 150/3 The inspector stated that a review of the draf t procedure of initial reactor building leak rate test was discussed with the licensee's representative and resolution to deficiencies are discussed in details.
(Details, Paragraph 3)
3.
Pre-Operational Test i
The inspector stated that the present Appendix J vould affect
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i testing program in areas of local leak rate testing, penetration pressurization, fluid block, and licensee's reporting require-i I
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ments.
The licensee agreed to review pre-operational procedures
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for provisions that would be in conflict with 10 CFR 50, Appendix J, dated February 5,1973.
If such areas are identified, the
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licensee will submit to the Directorate of Licensing the dis-
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(-.g crepancies found in these areas for resolution.
(Details,
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Paragraph 5)
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DETAILS
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1.
Persons Contacted j
I Metropolitan Edison Company Mr. R. M. Klingaman, Superintendent Mr. J. G. Herbein, Assistant Superintendent Mr. A. Conrad, Maintenance Foreman General Public Utilities Service Corporation Mr. J. J. Barton, Startup and Test Manager Mr. R. J. Toole, Assistant Test Superintendent
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Gilbert Associates Incorporated l
Mr. W. C. Sommer
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2.
10 CFR 50, Appendix J, Dated Februarv 5, 1973 The inspector's discussion with licensee concerning reference documents used in review of Initial Reactor Building Leak Rate procedure was questioned by licensee.
The licensee felt that the reference documents were not consistent with licensee's FSAR commitment.
The inspector referenced the February 5, 1973, 10 CFR 50, Appendix J, while licensee felt that its previous commitment in FSAR to a August 27, 1971 issue of Appendix J was proper.
The inspector
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j stated that the licensee's commitment must be revised in the FSAR to comply with current Code of Federal Regulations.
The licensee questioned the backfit as the design of the plant might not reflect the present code standards.
The licensee did agree to review areas of concern and submit problem areas to the Directorate of Licensing
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prior to Initial Reactor Building Leak Rat Test.
Tentative date of performance of initial reactor building leak rate test is late
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December 1973.
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Initial Leactor Building Leak Rate Test (ILRT) Test Procedure 150/3 The inspector's review of the draf t of the Initial Reactor Building Leak Ra';e Tes t, Test Procedure 150/3, resulted in the following
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deficie ncy / comments.
The deficiencies and the licensee's responses
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are indicated in the following paragraphs:
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Deficiency - The inspector stated that prerequisites in area of construction status are not detailed, in such a manner, that the test director would be able to identify system or areas
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that he has signed off as completed.
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Licensee's Response - The procedure would be revised to incorporate details of construction areas to be verified by e
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test director as completed.
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b.
Deficiency - The inspector stated that numerous numerical
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errors appear in the procedure as a result of a change to the
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technical specifications as to maximum allowable leak rate. A complete review of numerical values, such as Paragraph Nos. 1.1, 1.2, and the acceptance criteria, should be undertaken.
Licensee's Response - The test procedure will be reviewed to comply to new maximum leak rate criteria.
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c.
Deficiency - The inspector stated that under references, Paragraph 2.5, incorrect Code of Federal Regulations is listed.
Licensee's Response - Licensee agreed to correct the reference.
d.
Deficiency - The inspector stated that the test procedure, Para-h graph 4.3, states "no special environmental conditions" while in I
Paragraph Nos. 6.3 and 8.11, environmental conditions are specified limiting atmospheric conditions inside and outside containment structure, prior to and during testing.
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Licensee's Response - Paragraph 4.3 will be modified to reflect
environmental conditions.
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Deficiency - Additional references should include ANSI 45.4,
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NAVSHIPS SN-0852-0012 and 00027 to reference paragraph.
Licensee's Response - Additional references will be included.
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Deficiency - The inspector requested licensee to clarify the statement in Paragraph 6.6, " Personnel entering the reactor building at 14 psig must be in good health".
The inspector stated that medical certification of personnel is desirable and that the limitations, as noted in ANSI 45.4 should be included in the test procedure.
The inspector also requested the licensee l
to determine if state or local laws exist that limit personnel entry into areas under pressure.
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Licensee's Response - The licensee stated that he would in-vestigate local and state laws concerning entrance of personnel into areas under pressure.
The licensee also will include state-ments as noted in ANSI 45.4 and review reference document on depressurization tables.
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g.
Deficiency - The inspector expressed concern as to the manner in which the licensee was to establish access control in areas under pressure. A document listing the test director and his designated assistant and their method of limiting access should
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be developed.
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Licensee's Response - The licensee will issue maning requirements and during pre-test briefing and dry run, establish access limits.
The test director and the assistant test directors will have j
control of total access into the test area.
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Deficiency - Paragraph 6.9 is not, detailed as to the number and
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l location of various electrical closures and oil snubber reservoirs that require venting.
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Licensee's Response - The test procedure will list in detail the
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number of components to be vented in these areas.
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Deficiency - The inspector stated that recent (30-day) calibration data be included on all instruments from which data is to be used
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for determination of Initial Reactor Building Leak Rate Test.
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Licensee's Response - The licensee will calibrate all instru-i mentation including flow meters and thermocouples within 30 days prior to conduct of test.
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Deficiency - Paragraph 8.6 does not reflect FSAR.
Licensee's Response - Paragraph S.6 will be corrected.
4.
General Comments The inspector stated that certain additional statements are to be included in the test procedure.
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a.
Appendix J Requirements The licensee has agreed to include in procedure:
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(1) Requirements of Paragraph V.5 of 10 CFR 50, Appendix J, calls for general inspection of accessible interior and exterior surfaces of containment structures and components.
l to be performed prior to any Type A test.
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l (2) Requirements of Paragraph A.l.b of 10 CFR 50, Appendix J, that the closure of containment isolation valves are to be i
l accomplished by normal operation and without preliminary exercising or adjustments.
I b.
Additional Required Information (1) The inspector stated that a criteria for inmediate shut-down of test under certain identified conditions should be included in the procedure.
The licensee agreed to include this item in the procedure.
(2) The inspector stated that a minimum holding time af ter
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pressurizat ion to the 14, 30, and 55 psig plateaus prior to inspect!on or data taking, should be included.
The
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licensee i greed to include this item.
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(3) The insr ector expressed concern of a portion of a tese, that determiuc free volume in respect to the core flood tank structural proteccion.
The licensee agreed to verify structural stability of the core flood tank when exposed
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j to external design accident pressure while the tank itst_1f
at 0 pressure.
(4) The inspector stated that the criteria for temperature stabilization was not included in the procedure.
The
licensee agreed to provide such criteria.
i (5) The inspector stated that the procedure did not address the parameters of partial loss of test instrumentation during performance of the initial leak rate test. The licensee stated that a criteria will be established and enteren into test procedure.
5.
Pre-Onerational Test The inspector stated that Appendix J,10 CFR 50, dated February 5, 1973, ef fected other areas of the licensee's test program.
Areas such as local leak rate testing, penetration pressurization, fluid ()
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I block, and the licensee's reporting requirements are af fected.
Some examples were noted by the inspector such as areas of testing in direction of flow during Type C testing, and the pressure test of electrical pressurization penetration systems and the method of ascertaining total leakage criteria on fluid block systems for a 30-day period were discussed.
The licensee agreed to review the local leak rate testing penetration pressurizacion end fluid block
systems for possible exceptions that vauld be submitted to Directorate of Licensing prior to tescing.
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6.
The system lineups will be reviewed at a subsequent inspection j
upon issuance of a three-month review of the procedure.
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l MEMO ROUTE SUP s.. m. a o ut inis.
rer concurr.nc..
ror action.
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Form AEC-on (Rev. May 14.1947) AECM 0240 Not. and return.
For slenature.
X For Informa tion.
- TO (Nam. snc anit)
I puTIALS REMARK:
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RO Chief, Field METROPOLITAN 'dDISON COMPANY
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l Support & Enforcement THREE MILE ISLAND I Branch, Hy OAT:
RO:HQ (5)
RO Ffles INSPECTION REPORT 50-289/73-09 gTO f?'am. and unit)
ptrTIALS REMARKS 4Di. Central Files The at;tached report is being forwarded Central Mail & Files i
Regulatory Standards LTc a)
for information.
Distrioution tc PDR,
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~ 'jlegional Directors (4 i
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l 4" Directorate of Local PDR, NSIC, DTIE, and State af
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TG (Nams and unit)
peTLALS REMARKS Licensing (13)
Representatives will be made after proprietary review is completed by the o4T
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licensee.
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FROM (Nam. and unst)
REMARKS
E. J. Brunner l
Region I
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I PMont Mt1 CATE
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AUG 2 7 l973 USE OTHER $1DE FOC ADDITIONAL REMARKS cpo : 337: o.445 44,
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