IR 05000289/1973020
| ML19256D461 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/21/1973 |
| From: | Brickley R, Davis A, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D455 | List: |
| References | |
| 50-289-73-20, NUDOCS 7910180796 | |
| Download: ML19256D461 (13) | |
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U.S. ATOMIC ENERGY Com!ISSION
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DIRECTORATE OF REGUIATORY OPERATIONS
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REGION I
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50-289/73-20 Docket No._50-289 RO Inspection Report No.:
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Metropolitan Edison Company License No. : CPPR-40
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Three Mile Island 1
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Middletown, Pennsylvania
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Location:
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B&W 871 M'We'PWR Type of Licensee:
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T'ype' of Inspeetion:
Routine, Announced
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October 29-31, 1973 Dates. of Inspection:
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October 25, 1973 Dates of Previous Inspection:
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,R. L. Spessa/d, Reactor Inspector
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F Accompanying Inspectors:
Date R. H. Brij:kley, Reactor Inspector
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Other Accompanying P.cr'sonnel:
S. A. Folsom, Reactor Inspector Date
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Revicued by:
A. B. Davis, Senior Reactor Inspector, Reactor Operations Branch
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SUMMARY OF FINDINGS Enforcement Action
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A.
Violations
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The licensee failed to follow the Test Manual and Test Instruction No. 2 and 3 during the approval and issuance of the Test Manning
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Assignment Document for TP 200/4 Reactor Coolant System Hydrostatic Test in apparent violation of 10 CFR 50, Appendix B, Criterion V.
The licensee corrected this violation during the inspection and prior to the performance of TP 200/4.
This matter is closed.
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(Paragraph 7.b)
B.
Safe ty Items l
None Identified i
Licensee Action on Previously Identified Enforcement Items
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I A.
As of the cate of this inspection, the licensee had not yet submitted a letter in response to the violation identified in the R0:I letter
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dated October 23, 1973 and R0 Inspection Report No. 50-289/73-18;
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however, the corrective action taken by the licensee was reviewed during this inspection.
This matter is closo.d pending RO:I's review
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of the licensee's recponse letter. (Paragraphs 2.e.(3) and 5.b)
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Unusual Occurrences A.
Partial Oraining of Reactor Coolant System (Paragraph 6).
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Other Significant Findings
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A.
Current
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The Reactor Coolant System Hydrostatic Test was started during this inspection and was completed subsequent to this inspection.
This test was witnessed by RO:I inspectors. A separate RO Inspection Report (No. 50-289/73-21) will be issued to document findings
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relative to the performance of this test. (Paragraph 7)
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2.
Hot functional testing is scheduled to begin on December 19, 1973.
B.
Status of Previousiv Reoorted Unresolved Items No change Manacement Interview An exit interview was conducted on October 31, 1973 at the conclusion of the inspection.
Items discussed and personnel in attendance were as follows :
1449 203 Licensee's Representatives
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J. Herbein, Assistant Station Superintendent, Met Ed
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J. Colitz, Station Engineer, Met Ed G. Miller, Test Superintendent, GPUSC S. Levin, Unit 1 Project Engtaeer, GPUSC M. Stromberg, Site Auditer, CPUSC RC:I Representatives L. Spessard R. Brickley A.
Reactor Coolant System Hydrostatic Test Inspection findings relative to the licensee's implementation of administative requirements concerning the performance of this
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test were discussed.
This included the apparent violation of 10 CFR 50, Appendix B, Criterion V and the licensee's corrective action.
Additionally, the inspector stated, that as a result of
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the overall findings in this area, Test Instruction No. 3 needed to be revised to clearly define the intent of the program requirements relative to attendance of briefings when a Test
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Manning Assignment Document is in effect and relative to the major test evolutions requiring the issuance of a Test Manning
Assignment Document.
A licensee representative stated that Test L_f Instruction No. 3 would be revised to reflect program requirements.
The inspector stated that this matter would be reviewed during a subsequent RO inspection. (Paragraph 7)
With respect to the Reactor Coolant. System Hydrostatic Test which was in progress at the conclusion of this inspection, the inspector stated that a separate R0 Inspection Report would be written by the
inspector who was witnessing this test.
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B.
Partial Draining of Reactor Coolant System l
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Inspection findings relative to this event were discussed, and the inspector stated that he had no further questions on this matter
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at this time.
(Paragraph 6)
C.
Preoperational Test Procedures
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1.
Inspection findings relative to the review of TP 200/4, TP 201/2, I
and TP 202/7 were discussed. (Paragraph 2.c)
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2.
Inspection findings relative to the review of tests recencly I
completed and accepted by the licensee were discussed. (Ps.ragraph 2.d)
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Inspection findings relative to the review of previously reported
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test procedure deficiencies were discussed. (Paragraph 2.e)
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Initial Fueling Procedures and Instructions Inspection findings relative to the review of initial fueling procedures and instructions were discussed. (Paragraph 3)
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Shift Test Engineer Log-t Inspection findings relative to the review of the Shift Test Engineer Log were discussed. (Paragraph 4)
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Test Instructions, a
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Inspection findings relative to the review of revisions to TI-9
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DETAILS
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1.
Persons Contacted Metropolitan Edison Company R. Klingaman, Station Superintendent J. Herbein, Arsistant Station Superintendent J. O'Fanlon. Nuclear Engineer F. Grice, 5..dminis trato r R. Deakio, Radiation Protection Supervisor J. Floyd, Superviser of Operations G. Rec u, Chemist J. C litz, Station Engineer General Public Utilities Service Corporation J. Barton, Startup and Test Manager G. Miller, Test Superintendent
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R. Toole, Assistant Test Superintendent
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M. Nelson, Technical Engineer
j S. Levin, Unit #1 Project Engineer J. Spinak, Q.A. Engineer
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R. Fente, Q.A. Engineer S. Poje, Shift Test Engineer s
C. Gatto, Shift Test Engineer s_f I. Porter, Shift Test Engineer T. Hawkins, Shif t Test Engineer M. Stromberg, Site Auditor
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2.
Preoperational Test Procedures
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Status of Test Procedure Preparation, Review and Approval
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Preoperational Test Procedures Approved for Performance-61%
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Preoperational Test Procedures Awaiting Final Approval-4%
Preoperational Test Procedures Under Review by TWG & DOT-10%
Preoperational Test Procedures Written & Undergoing In-
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house Review
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Preoperational Test Procedures Not Started-12%
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Status of Preoperational Testing
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Preoperational Tests Completed and Accepted-15%
Preoperational Tests Completed and Under Review-0%
Preoperatic.ial Tests in Progress-19%
Preoperational Tests Not Started-66%
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RO:I Review of Preoperational Test Procedures c.
The inspectors discussed their review of the following preoperational test procedures:
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-5-V TP 201/2 Core Flooding System Functional Test TP '.!02/7 Makeup and Purification E.S. Test TP 200/4 Reactor Coolant System Hydrostatic Test The deficiencies identified during this review were corrected by issuance of an exception of the procedure. RO:I has no further questions on these rocedures at this time.
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RO:I Review of Preoperational Tes* Results
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The inspectors reviewed the completed test package as accepted by the licensee and are satisfied with the documentation of performance and results of the following tests :
TP 264/4 Decay Heat Closed Cooling System Functional Test TP 265/2 Condenser Circulating Water System Functional Test SP 195.1 Reactor Cooling System Cleaning Sequence
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Status of Previously Reported Test Procedure Deficiencies (1)
TP 200/1 Reactor Internals Vent Valve - Inspection Test (a)
The licensee has issued TCN-1 to specify that the vent valve exercise tool and long handling tool will be ()
scribed in a. clean area away from the open reactor vessel.
This item is resolved.*
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The licensee has issued TCN-1 to specify the cleanliness criteria of tools ente. ring the reactor vessel.
This item is resolved.**
(c)
The licensee has issued TCN-1 to specify the fully open dimension (7") of tool j aws.
This item is resolved.***
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TP 203/1 Decay Heat Removal Systen, BWST Functional Test
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A test of the heat tracing of the line from the BWST to the auxiliary building has been included in TP 250/2, Testing and Checking of Mechanical and Electrical Equipment. This test checks the operation of the thermostat, measures and verifies trace current, and checks the alarm light prior to and following heat trace insulation.
TCN-30 to the Master Test Index (MTX), which was approved by TWG on October 11,-1973 in accordance with the Test Manual, deleted test procedure F1104/46 since testing of all heat tracing will be accomplished by TP 250/2.
This item is resolved.****
- RO Inspection Report No. 50-289/73-06 Para 5.c(2)(a)
- R0 Inspection Report No. 50-289/73-06 Para 5.c(2)(b)
- RO Inspection Report No. 50-289/73-06 Para 5.c(2)(c)
- R0 Inspection Reports No. 50-289/73-01 Para 7.c(3) and 50-289/73-11 Para 2.d(6)
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(3)
TP 305/2 Reactor Protection System Response Time The licensee had replaced the marked up Official Field Copy of TP 305/2 with the smooth copy that was approved by the Test Work Group (TWG) af ter determining that the Met Ed Test Auditor had no comments on the test procedure.
Ad-ditionally, other test procedures, that had been approved by the TWG prior to the TWG's receipt and review of J e Met Ed Test Auditor's connents on those procedures, were withheld from issuance until his comments, where applicable,
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were incorporated in the procedure and approved by the TWG.
The licensee also revised Test Instruction No.18 to clarify the requirements for conducting TWG preliminary review meetings and processing the Met Ed Test Auditor's test procedure comments.
(Refer to Paragraph 5.b concerning TI-18 revisions).
RO:I has no further questions on this matter at this time.*
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3.
Initial Fuel Procedures (IFP) and Instructions (IFI)
The licensee's program consists of 39 procedures and 26 instructions
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for initial fueling. The inspector met with the licensee's
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representatives and discussed his review of unapproved copies of the following procedures and instructions :
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t IFP-100 Initial Fueling Control Document
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IFP-201 Preparation of Fuel Storage Building and Fuel Handling
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IFP-202 Receipt, Inspection, Fit Up and Storage of New f eel and i
Control Components IFP-301 Preparation of Reactor Building and Fuel Handling Equipment g
for Initial Fueling
IFP-312 Internals Assembly, Removal, Inspection and Reinstallation
IFP-320 Checkout of Main and Auxiliary Fuel Handling Bridges and
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Transfer System IFP-323 Inspection of Studs, Nuts and Washers
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IFP-401 Core Asser21y
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IFP-402 In-Core Instrumentation Installation and Checkout i
IFP-505 Closure Head Stud Tensioning and Seal Leakage Test i
IFP-514 Preparation of Reactor Building and Fuel Handling Equipment g
for Reactor Operation g
IFP-604 Damaged New Fuel and Control Components
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IFP-605 Recovery of Parts from Primary System, Core Components or (
Pools j
IFP-ll3 Auxiliary Neutron Detector Operating Instructions IFP-ll4 Reactivity Insertion Computations i
IFI-201 Document Control IFI-202 Personnel Control C
IFI-203 Radiological Control IFI-204 Emergency Plan
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- RO Inspection Report No. 50-289/73-18, Paragraph 2.a.(1)
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-7-p IFI-205 Tool control IFI-236 Cleaning and Cleanliness IFI-208 Quality Control IFI-209 System, Valve and Breaker Lineup Control
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The inspector obtained the licensee's commitment on each of the identified deficiencies. The significant deficiencies identified included the following:
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De ficiency: The IFP's and IFI's should be reviewed and approved by the PORC prior to issuance. (FSAR 12.5.2, 15.6.2.1.f and 15.6.2.2).
Licensee's Response: The signature of the Met Ed member of Initial Fueling Group (IFG) indicates that the PORC has reviewed and approved the procedure.
The Met Ed member of the IFG will verify that this has been done prior to signing the IFP or IFI.
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b.
Deficiencv:
The Co e Assembly procedure (IFP-401) does not
contain a requirement that the Plant Superintendent approve any change in sequence of detector or source locations.
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Licensee's Response:
If the FSAR specifies that only the Plant Superintendent can approve a change in sequence, then (_)
they may either change the IFP to require his approval or
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request a change to the FSAR.
If the FSAR does not specify the above, then the IFG will do the approving.
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Deficiency:
IFP-202 Receipt, Inspection, Fit Up and Storage of New Fuel and Control Components does not list acceptance criteria for the inspections planned.
In addition, the scope
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of the inspection program should be expanded to provide assurance that the fuel and control components have been fabricated to
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their respective specifications.
Licensee's Response: We will review the scope of the present inspectio. program and consider expanding this program.
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This area will be reviewed during subsequent RO inspections to
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verify resolution of the identified deficiencies, as committed by the licensee.
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Review of Shift Test Eneineers (STE) Log The inspector reviewed the STE Log covering the period September 1, j
1973 thru October 31, 1973 and found that the requirements of TI-17 Shif t Test Engineers Log have been implemented.
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Test Instructions The inspectors reviewed the following recently revised Test Instructions:
TI-9 Conduct of Test TI-18 Test Procedure Documents During this review, the following observations were made which were discussed with cognizant licensee representatives:
a.
TI-9 conduct of Test
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Revision 1 to TI-9 dated October 10, 1973 was approved on-October 25, 1973 in accordance with the Test Manual.
This revision included the requirement of the Shif t Test Engineer's (STE) review of all referenced drawings in the test procedure to assure the latest drawing revision, as contained in the i
aperture card file, is used in the test procedure preparation.
This revision also included requirements for the STE to evaluate all drawing revisions issued since approval of the
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tes t procedr.re to determine if test intent and performance are affected.
Dccumentation requirements for the STE's actions previously described were also included in this revision.
The previous RO:I finding relative to this matter
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is resolved.*
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b.
TI-18 Test Procedure Documents Revision 3 to TI-18 dated October 18, 1973 was approved on October 25, 1973 in accordance with the Test Manual.
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revision included the following:
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Specified the requirement for a preliminary review meeting by the TWG to be optional.
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Specified that changes to an approved test procedure must be made by a Test Change Notice (TCN) or an Exception to the procedure.
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(3)
Specified that a copy of a procedure be submitted to the i
Met Ed Test Auditor for review at the time it is decided to not have a preliminary review meeting by TWO.
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Specified that the Revision Nu=ber and/or TCN Number be included on test procedure cover page for all approved procedures.
RO:I has no further questions on this item at this time.**
RO Inspection Report No. 50-289/73-10, Management Interview Item B
RO Inspection Report No. 50-289/73-18, Paragraph 2.a.(1)
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Partial Draining of Reactor Coolant System The licensee informed the inspector on October 25, 1973 of this event pursuant to 10 CFR 50.55(e).
The inspector reviewed the licensee's Craf t Unusual occurrence Report for this event which had been prepared in accordance with the requirements of Test Instruction No. 8 and discussed the details of this event with cognizant licensee representatives.
The following information was obtained:
The plant was in the preoperational testing phase with no major systems in operation. The reactor coolant system was filled, vented, at ambient temperature (about 80 F), and pressurized with approximately 42 psig nitrogen.
The shif t foreman had instructed the control room operator to align specific values in the Decay Heat Recoval
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System in preparation for processing the water in the Reactor Coolant System through the Liquid Waste Disposal System precoat filters.
The operator was using an approved instruction and
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valve alignment, and while in the process of opening a series of valves, he inadvertently opened (misread procedure) DH-V6A, Decay Heat Removal Pump suction from the Reactor Building Sump,
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which completed a flow path from the Reactor Coolant System to the Reactor Euilding Sump.
The operator immediately realized his error and closed the motor operated valve (DH-V6A) before g,
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it reached full open.
Operating time for this valve is about 60 seconds.
During this event about 4000 gallons of water were drained to the su=p.
Pressurizer level changed from 150 inches to near 0 inches and pressure changed from 42 psig to about 15 psig.
The licensee's evaluation indicated that no proposed Technical
I Specifications were violated and no unresolved nuclear safety questions were involved.
The operator who made this error was cautioned to be cognizant of the implications of his actions.
The Reactor Coolant System was subsequently refilled, revented and repressurized to support the preoperational test program.
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7.
Administrative Controls Relative to the Performance of the Reactor Coolant System (RCS) Hydrostatic Test (TP 200/4)
The inspector reviewed the licensee's implementation of administrative requirements relative to the performance of TP 200/4, as specified in the Test Manual and Tust Ins tructions No. 2, 3, 9 and 10.
This review included discussions with cognizant licensee representatives, review o# pertinent facility records and observations prior to and during t's performance of TP 200/4.
The following observations were made:
a.
Prerequisite List for Initial Fill and Hvdro
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The Test Manual and Test Instruction No. 10 establish requirements for the prerequisite list, which contains all items that must be 1449 216
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the start of major events.
The list is also required to be periodically updated and reviewed prior to commencing the associated event.
The Official Field Copy of the Prerequisite
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List for Initial Fill and Hydro was approved by the Test Work Group (TWG) on September 10, 1973 and was periodically reviewed and updated by GPU Startup and Met Ed personnel prior to its final approval by the TWG on October 9,1973.
This prerequisite list was in conformance with Enclosure 1 of Test Instruction
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No. 10.
During the periodic reviews, deficiencies and exceptions
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i were identified, and the resolution and evaluation of each item was documented as required by Test Instruction No.10.
b.
Test Manning Assignment Document
=6um The Test Manual (Paragraph 3.5) and Test Instruction No. 3 (Paragraphs 2.D and 3.B) require a Test Manning Assignment
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Document which provides a listing of stations to be manned by designated personnel during a test be provided for the RCS
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Hydrostatic Test.
The Test Manning Assignment Document n r the RCS Hydro, which was prepared by GPU, approved by TWG on -tober 26, 1973 and issued, included specific personnel S
assigncents; however, the stations required to be manned by these personnel were.not identified.
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Test Instruction No. 2 (Appendix A, Paragraph III.A.1) requires
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the Test Manning Assignment Document, when applicable, be identified in the Test Plan.
The approved Test Plan for October 29-November 5,1973 did not identify the Test Manning Assignment Document for the RCS Hydro.
The above deficiencies were discussed with cognizant licensee representatives on October 30, 1973, and they were corrected on the same date by revisions to the Test Manning Assignment Document and the Test Plan.
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c.
Shif t Test Engineer (STE) Responsibilities and Duties The Test Manual and Test Instructions No. 3 and 9 establish duties and responsibilities of the STE relative to test
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performance.
The duties and responsibilities of the STE's who conducted the RCS Hydro Test were reviewed prior to the
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start of and during portiens of the initial phases (RCS pressure below 1500 psig) of this test. This included:
attendance of two briefings conducted by the STE on duty, inspection of the stations to be manned during the hydro including the installed test equipment, review of the Official
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Field Copy of TP 200/4 with the STE on duty, and observations s_
of the STE on duty. No deficiencies were identified.
The inspector observed that GPUSC-QA perr,onnel were auditing the performance to TP 200/4.
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d.
RCS Chemistry Requirements B&W Specification No. 2050/0173 establishes water quality requirements for the RCS and RCS Makeup water. Plant chemistry records for the period October 22-29, 1973 indicated water quality requirements were met.
During this period, water in the RCS was being cleaned by bleed and feed operations
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using the RC Bleed Tanks.
The bleed water was being processed through the precoat filters and mixed bed demineralizers to reduce suspended solids to <0.1 ppn (RCS Makeup water limit) prior to its reuse as RCS Makeup water.
Suspended solids in the RCS (letdown line sample) had been as high as 0.8 ppm during initial RC Pump runs on October 22, 1973 which caused plugging and partial collapse of the 5 micron RC Pump Seal Injection Filters and delayed testing until replacement filters could be procured.
Using bleed and feed operations,
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suspended solids in the RCS had been reduced to 0.13 ppm as of October 29, 1973.
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MEMO ROUTE SUP 5** m e * **u t ta's-For cecurrea"-
For actie-Form AEC-95 i Mev. May 14.1947) Af f.M 0240 Note ana retura-f or sleastvee.
X For latorw e ? loa.
TO (Nam. ana unit)
spist:Ats aguAnns R0 Chief, FS&EB METROPOLITAN EDISON COMPANY RO:HQ (5)
R0 Files THREE MILE ISLiND Central Mail & Files (
Regulatory Standards (3)
- 50-289/73-20 To <N.,n. ana uneo variau acMano
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Directorate of Licens-ng (13)
The above inspection report is forwarded Regional Directors
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(II, III, IV)
f r inf rmation.
Distribution will be made Dan OGC g
by this office to the PDR, Local PDR,
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To (N.m..no unio variats REMAAG NSIC, DTIE,, and State Representatives
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af ter review by the licensee for my proprietary information.
raoM (Name and unst)
atMand
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E. J. Brunner
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Region I PHOME PG DATE 8-337-1246
///)p 73
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