IR 05000289/1975001
| ML19256D633 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/05/1975 |
| From: | Davis A, Spessard R, Sternberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D629 | List: |
| References | |
| 50-289-75-01, 50-289-75-1, NUDOCS 7910190593 | |
| Download: ML19256D633 (25) | |
Text
{{#Wiki_filter:- . RO:I Form 12 tact.74) (Rev) - .
v U. S. ATOMIC ENERCY C010!ISSION DIRECTORATE OF REGULATORY OPERATIONS .- ,
REGION I
- -;.
- . RO Inspection Report No: 50-289/75-01 Docket No: 50-289 - .... . Licensee: Metropolitan Edison Company License No: DPR-50 P. O. Box 542 Friority: .... - Reading, Pennsv1vania 19603 Category: C Safeguards = Group: - Location: Middletown, Pennsylvania (Three Mile Island 1) , _ PWR, 871 MWe (B&W) Type of Licensee: _ [pe of Inspection: Routine, Announced =- . T 1 of Inspection: January 6-9 and 17, 1975 SL ' ' Dates of Previous Inspection: December 10-12, 1974 - += Am /7 < i / < r -[. .i 70" E Reporting Inspector: R. L. Spessardf' Reactor Inspector / DATE
IV d. f.
7n'
'! 7( Acconpanying Inspectors: D. M. Sternberg, Reactor Inspector (1/6-8/75 only) DATE $ '.1!T!l.( ,- v i vs . J.'C. Mattia,fReactor Inspector DATE 6Aki Wr'h r 'DATE Other Accompanying Personnel: A. B. Davis, Senior Reactor Inspector w kN b/t/ $t[ / SS-I/{s R. B. Glasscock, Reabtor Inspector (1/17/75 DATE ~ 2- /'7 f
Reviewed By: ' DATE _ A. B. Davis, Senior Reactor Inspector Reactor Operations Branch 1452 183 J ~ go 59'3 _ .
. . . . . . SUM 1A51Y OF FINDINGS ' . Enforcement Action ' Items of snconoliance . A.
Infractions 1.
Contrary to Criterion VI, Appendix B,10 CFR 50 and the FSAR, Section lA, Operating Quality Assurtnce Plan, a plant heatup was performed on Not ember 19-?O,1974 using a Controlled Copy of OP 1102-1 which contained four invalid TCN's.
Additionally, on January 7,1975 the Control Roem's Controlled Copy of OP 1102-1 still contained these invalid TCN's and did not contain the one valid TCN.
(Detail 5.a) 2.
Contrarv to 10 CFR 50.59(b), the licensee's written safety < evaluations for nine design changes did not provide An ade-quate basis for the determination that an unreviewed safety question was not involved.
(Detail 6.b(1)) 3.
Contrary to criterion XVIII, Appendix B,10 CFR 50 and the FSAR, Section lA, Operating Quality Assurance Plan, audit ' ) reports for four QA audits were either not issued or were
not issued in a timely manner.
(Detail 7.f(l)) ' 4.
Contrary to Criterion XVI, Appendix B,'10 CFR 50 and the FSAR, Section lA, Operating Quality Assurance Plan, several , QA audit findings had not been corrected in a timely panner.
(Detail 7.f (2)) . B.
Deficieqcv Contrary to Technical Specification 6.1.I.3.e.8), the GORB had not reviewed the audits and audit progran of 'the Generation Division since the issuance of an operating license on April 19, 1974, and during April-October 1974 seven GORB meetings were conducted.
(Detail 7.f (3)) 1452 184 ~
- M w
. . . . -2-
. Licensee Action on Previousiv Identified Enforceme st Items Not inspected '- / Design Changes Documentation relative to nine design changes completed in accordance with 10 CFR 50.59 was reviewed.
(Detail 6) . Unusual Occurrences Noticeable piping vibration in the "A" Makeup Pump suction line from the Borated Water Storage Tank was observed.
(Detail 2.b(7)) Other Significant Findings ~ , .: A.
Current Findings - 1.
Acceptable. Areas (These are areas which were inspected on a sampling basis and findings did not involve an Item of Non-compliance, Deviation, or Unresolved Item) a.
Review of Plant Operations with the exception of the _ existence of piping vibrations.
(Detail 2) - ' b.
ReviewofAbnormalOccurrenceswiththeeNceptionof - , A0 50-289/74-32.
(Detail 3) . c.
Review of Safety Related Instrument Calibration.
(Detail 4) d.
Review of Limiting Conditions for Operations with* the excep- - - tion of the licensee's control of OP 1102-1.
(Detail 5) " e.
Review of Design Changes with the exception of the adequacy of written safety evaluations and the management controls ' applied.
(Detail 6) f.
Review of Audits with the exception of issuance of audit = reports, timely correction of audit findings, and GORB's review of Technical Specification Changes 4 and 5 and audit reports and audit program.
(Detail 7) - .. 1452 185 , wW e M* M% .
' - . - . ' 3- - '
- . O.p.
un ,- ' 2.
Unresolved Itens (These are items for which core inforcation is j required in order to determine whether itens are acceptable or Items of Noncompliance) _ / Piping vibration in "A" Hakeup Pump suction line.
a.
(Detail 2.b(7))
- '
b.
Final correction action for A0 50-289/74-32.
(Detail 3.b) Disposition of existing procedure TCN's.
(Detail 5.a(4)) c.
d.
Management control of design changes.
(Detail 6.b(2)) , ' e.
GORB. review of Technical Specification Changes 4 and 5.
(Detail 7.e) B.
Status of Previous Unresolved Items * . The following items were reviewed and are acceptable: 1.
Surveillance Procedure SP 1301-1.
(Detail 8.a) . 2.
Possible Piping / Penetration Contact on A and D Main Steam Lines.
(Detail 8.b) . ( ) 3.
Pipe Hangers on Makeup Pump Discharge Lines. - '(Detail 8.c) 4.
A0 74-15 Corrective Action.
(Detail 8.d) 5.
General Employee, Facility Access Control and Security Training.
(Detail 8.j) .. - 6.
Maintenance Personnel, Procedure Review / Indoctrination.
(Detail 8.k) 7.
General Employee Facility Contingency Procedure Training.
(Detail 8.1) 8.
Surveiance Procedure _ 1301-9.1.
(Detail 8.m) The following items were reviewed and remain unresolvad: 1.
Control Switch Replacement.
(Detail 8.e) - 2.
Operating Procedure OP 1102-4.
(Detail 8.f)
- Items identified in previous inspection reports as Open Items have been reclassified as Unresolved Items.
_ 1452 186 ' .. v
. . . -4- , ' . . ( [j 3.
Administrative Procedure fer Auxiliary Log Sheets.
(Detail 8.g) 4.
Evaluation of Existing Temporary Shielding.
(Detail 8.h) 2.
/ 5.- Snubber Seal Replacement Program.
(Detail 8.i) Management Interview Exit interviews were held onsite on January 8 and 9,1975 and at the Met Ed Corporate Office on January 9,1975 at the conclusion of the various phases of this inspection.
Personnel Attending . Mr. J. Herbein, Station Superintendent Mr. J. Colitz, Unit 1 Superintendent Mr. J. Floyd, Supervisor of Operations Mr. D. Shovlin, Supervisor of Maintenance Mr. W. Potts, QC Supervisor . Mr. L. Lawyer, Manager, Operational Quality Assurance Mr. R. Klingaman, Manager, Generation Engineering The 'following summarizes the items discussed: 1.
Review of Plant Operations including the licensee',s commitment.
) (Detail 2)
=
' llgg 2.
Review of Abnormal Occurrences including the repetitive infraction and the licensee's co=mitment.
0 Detail 3.b) _ _ _ _
- =
3.
Review of Safety Related Instrument Calibration.
(Detail 4) . 4.
Review of Limiting Conditions for Operationc including the repetitive infraction and the licensee's commitment.
(Detail 5) 5.
Review of Design Changes including the infraction.
(Detail 6) 6.
Review of Audits including the infractions and deficiency.
(Detail 7) =-. 7.
Review of the Status of previous unresolved and open items including the licensee's commitments.
(Detail 8) . . A management meeting was held at the Met Ed Corporate Office on 1-January 17, 1975 a. the licensee's request.
Personnel attending included Mr. R. Arnold, Vice President and Mr. L. Lawyer, Manager, Operational Quality. Assurance.
The following su=narizes the items discussed.
. l'452 187 , ..
- W
=
- . . - -5
. 1.
Inspection findings relative to design changes including the bases for these findings.
, - As a result of information provided by the licensee, the finding ' - relative to Met Ed Generation Eng'ineering's control of design ~~ ' changes taas changed to an unresolved item oending the inspector's - - - - - review of documentation to be provided by the licensee.
= -, . 2.
Inspection findings relative to audits including the bases for these findings.
_= . 1452 188 . -
- ".".
..... O =, - - .
-
- eh*
- - , .
. . . .. , - . . ,- ' DETAILS - _ ~ l.
Persons Contacted / a.
Onsite ,_ ' Mr. D. Barry, Technical Assistant Mr. W. Bonczek, ISC First Class Mr. E. Bulmer, Lead Mechanical Engineer Mr. J. Chwastyk, Shif t Supervisor Mr. J. Colitz, Unit 1 Superintendent , Mr.- W. Cotter, Mechanical Engineer Mr. J. Floyd, Supervisor of Operations Mr. D. Good, Test Coordinator Mr. C. Guthrie, Shift Foreman Mr. R. Harper, Instrument Supervisor Mr. C. Hartman, Electrical Engineer Mr. J. Herbein, Station Superintendent , Mr. J. 'O'Hanlon, Nuclear Engineer (PORC Chairman) Mr. V. Orlandi, Lead 16C Engineer Mr. W. Potts, QC Supervisor . Mr. M. Foss, Shift Supervisor __ Mr. J. Seelinger, Supervisor of Training . ~~~ g Mr. M. Shatto, Mechanical Engineer (PORC Secretary) ' ) Mr. D. Shovlin, Supervisor of Maintenance - Mr. J. Sipe, I&C Technician - Mr. J. Smith, Utilityman First Class - Mr. J. Wallace, Shif t Supervisor Mr. D. Weaver, I&C Foreman Mr. H. Wilson, I6C Foreman - Mr. S. Mingi, B&W Nuclear Service Engineer
- b.
Corporate Office Mr. R. Arnold, Vice President (GORB Member) g Mr. J. Bartman, Vice President (GORB Member) Mr. D. Grace, Licensing Engineer Mr. R. Klingaman, Manager, Generation Engineering Mr. L. Lawyer, Manager, Operational quality Assurance Mr. B. McCutcheon, Quality Assurance Engineer Mr. J. Thorpe, GPU Manager, Environmental Affairs (GORB Chairman)* =
- Contacted by t elephone while at Corporate Of fice.
14~52 189 .- .
. . , . -7- . . 2.
Review of Plant Onerations _, a.
Shift Loes and coeratine Records
- -
s ..-. The inspector reviewed the records listed below.
The review was governed by the licensee's administrative procedure (AP 1012).
- . "~ (1) Shif t Foreman and Control Room Logs: Entries made for the period December 21-31, 1974 were reviewed.
Documenta tion involving abnormal conditions provided sufficient detail to co=municate equipment status, lockout status, correction, restoration, and testing of redundant equipment, as appropriate.
"- (2) Log Book Reviews: The Control Room Log and the Shift Foreman's Log were observed to have been reviewed at least once per week by the Supervisor of Operations for the pe-riod December 21-31, 1974.
,,y (3) Operating Orders: Changes to the Standing Orders Book and the Operations Memo Book that were made subsecuent to the inspector's last review (Report 50-289/74-35) were reviewed, and no conflicts with the intent of Technical Specification recuirements were observed.
Additionally, the inspector observed that 27 of these instructions had been cancelled as part of the licensee's procedures updating program to better cor.colidate requirements.
" , (4) Jumper (Bypass) Log: Documentation for November 27, 1974-January 8,1975 relative to the use of jumpers, lif ted leads, and te=porary mechanical maintenance modification tags was reviewed and no bypassing discrepancies with Technical Specification requirements were observed.
=- b.
Tour of Accessible Areas - . . The inspector observed operations in the Control Room and accompanied the duty Shif t Supervisor on a tour of the Auxiliary and Fuel Handling Building on January 6,1974.
The following observations were made and these were discussed with the Shift Supervisor: (1) Monitoring Instrumentation: Nuclear Instrumentation - Channels NI 5, 6, 7, and 8, Borated Jacer Storage Tank Level Channels, Borated Water Stora e Tank Temperature Channels, Core Flood Tanks Level CLannels, and the com-puter calculated heat balance were observed to be in accordance with Technical Specification limits.
1452 190 y-s s e
. . . . -8- . . - p) (2) Annunciat or Alarms: ' The inspector observed various alarm - conditions that were received and acknowledged by the Con- ~~ trol Room Operator on duty.
These conditions were discussed with the duty Shif t Supervisor, and the Shif t Supervisor was knowledgeable on the alarms and the actions required of the Control Room Operator.
. (3) Shift Staffing: The inspector observed that the operating shift was staffed above the minimum requirements of Technical Specification 6.F.
(4) Radiation Controls: Five radiation control areas at Eleva-tion.281' in the Auxiliary Building were reviewed for proper posting, condition of step off pads, and disposal of SWP clothing.
Findings were acceptable.
c. (5) Plant Housekeeping Conditions: Storage of material and com- .[[f ponents was observed with respect to the prevention of safety
- . ;
and fire hazards, and no adverse conditions were identified.
. (6) Existence of Fluid Leaks: The inspector observed a fluid hh leak (packing) on valve BS-V3A (Reactor Building Spray
== Pump "A" Suction Valve from the BWST or RB Sump).
This - leak was investigated by the Shift Supervisor, and a work j request for appropriate maintenance action' was initiated.
The inspector has no further questions on this matter at l: this time.
. - (7) Existence of Piping Vibrations: The inspector observed a noticeable piping vibration in the vertical run of pipe in the vicinity of valve MU-V14A (Makeup Pump "A" Suction Valve from the BWST).
The Shift Supervisor investigated this con-dition and informed his superiors.
According to the li-censee, this condition had occurred nreviously, but is sporadic in nature, the licensce's AE was aware of the condition and would evaluate the condition when it recurred, and RO:1 would be kept informed on this matter.
This item remains unresolved pending completion of the licensee's review.
(8) Pipe Hangers / Seismic Restraints: Several pipe hangers and seismic restraints (snubbers) on safety related systems were r-observed.
Findings were acceptable.
(9) Valve Positions / Equipment Start Positions: The following ' valves identified in the Locked Valve Book vere observed 1452 191 -
e
. . , . -9- . . ] _I to be locked in their required position: BS-V4 9A, 21-V54A, BS-V17A, and BS-V53A.
Additionally, weekly reviews of this book were documented.
The alignment of the Nuclear Service ~~ Closed Cycle Cooling Water Pumps (LA,1B, and IC), Emergehey Diesel Generators (LA and 1B), and the Nuclear Service River Water Pumps (lA,1B, and IC) was observed to be in accord-ance with Technical Specification reauirements.
. (10) Equipment Caution / Lockout Tag Information: The active tag log was reviewed, and the inspector observed that eauipment , . under tag, which was primarily non-safety related, was con-sistent with the information contained in the Control Room Log Book.
Additionally, entries on the tagging applications (selective review) appeared to be proper.
(11) Plant Tour Shif t Supervisor: The inspector was informed that the last tour made by the Shift Supervisor, whom he was accompanying, occurred prior to assuming duty.
3.
Review of Abnormal Occurrences (AO's) Abnormal Occurrence review included inspection of plant records a.
and logs, Technical Specifications, Work Reauests, Plant Opera-tions and Review Committee (PORC) ceeting minutes and corrispon-s dence to the AEC.
,- b.
The below listed AO's were reviewed to verify that: , (1) the cause was identified and details clearly reported; (2) the corrective action described was taken to prevent recurrence; (3) each event was reviewed and evaluated by the licensee; and (4) safety limits, limiting safety settings, and limiting con-ditions for operation were not exceeded.
AO System 74-24 Reactor Coolant 74-09 (1) Auxiliary System-74-08 (1) Power Conversion _.. 74-18 Electrical System 74-31 Emergency Power 74-32(2) Containment 74-22 Containment Isola tion . 1452 192 . N
.
' . . . .. -. - 10 - - . %. (1) Signifies Non-routine reports vice abnormal occurrence _, reports.
.: (2) On December 26, 1974 with Reactor Coolant Sys tem a t a temi perature of 579'F and a pressure of 2155 psig both doors of the Reactor Building Personnel Hatch were simultaneously opened for a period of several minutes.
- This is an infraction of Technical Specifications paragraph
" 3.6.1 which sta us: . _..... " Containment integrity, as defined in Section 1.7 shall " - be maintained whenever all three of the-following condi-tions exist: a. Reactor coolant pressure is 300 psig or greater, b. Reactor coolant temperature is 200*F or greater.
...: c. Nuclear fuel is in the core."
""f.
.. _. _ _ This infraction is a repeat item of noncompliance.
-(Report 50-289/74-26, Detail 3) The licensee stated his corrective action for this AO would s ) include a modification of the door interlock indication system , / and a revision of procedures.
The procedure revisions were completed.
With respect to the modifi' ation the licensee c stated that this would be completed by mid-April 1975.
This item remains unresolved pending accomplishment of this modification.
- c.
Except as described above, findings were acceptable.
d.
The circumstances associated with the maintenance of two safety related pieces of equipment were revieued relative te Technical Specification reporting reouirements.
This included Reactor Building Isolation Valve RB-V7 (IGt 6317) and RPS-Reactor Coolant Pressure Buffer Amplifier (WR 6248).
Findings were acceptable.
4.
Safety Related Instrument Calibration a.
The below listed safety related plant instrumentation calibra- - tion data was reviewed to verify that: (1) the frequency of calibration has been met; 1452 193 / . W .
. . , . - 11 - - . . (2) service status of the system was in conformance with the ' applicable limiting conditions of operation during
calibration; _ .. (3) that the calibration procedures used to calibrate the com- _.
=- ponents were: (a) reviewed and approved as required; ~ (b) acceptance values for trip setpoints were as required by Technical Specifications; and (c) accomplished in a step by step manner.
, b.
The review consisted of a review of calibration procedures, com-pleted data sheets, design analyses, Technical Specification and departmental procedures.
c.
Component Calibrated System
- .
(1) Low Reactor Coolant Pressure Reactor Coolant (2) Nuclear Power Range Power Control (3) Flux-Flow Comparator . Core (4) Steam Generator Water Level Control Power Conv.ersion (5) Borated Water Storage Tank Level Auxiliary ) (6) 4 kv ES Bus Undervoltage Relays ' Electrical - ,. _,. / (7) Diesel Generator Protective Relays Emergency -Power (8) Reactor Building 4 PSIG Channel - ECCS (9) Sodium Hydroxide Tank Level ESF Findings were acceptable.
The inspector stated that.the format of-the data sheets used to record the results of the tests might result in unacceptable data being accepted since tolerances were stated in percentages rather than pre-calculating values of acceptable data. The licensee acknowledged the inspector's comments.
- d.
The inspector reviewed the training records for two personnel - involved in the calibration of plant instrumentation in order to determine cualifications compatible with the work assignment.
Findings were acceptable.
e.
Three instruments listed below, which are used as primary stand-ards for the calibration of other components, were reviewed to determine: i452 194 ' > .- . 7.,.,. .
' . . - 12 - - . G (1) Calibration frequency was met and accuracy verified.
s (2) Accuracy is traceable to National Bureau of Standards.
- / (3) Storage and control of this device proper.
Instrument Serial Number Manufacturer . 0-5000 psig gauge 11872 Heise Digital Volmeter 5525 Fluke Pneumatic Test Set 13700 Wallace & Tiernan Findings,were acceptable.
5.
Limitine Conditions for coerations (LCO) The inspector reviewed selected LCO's for the systems listed below to determine compliance with Technical Specification requirements.
This review consisted of direct observation of process instrumenta-tion monitoring current operations, direct observation of consoles, panels and annunciator boards for equipment out of service or proc-ess deviations, and review of monitoring instrumentation charts for historical review of operations.
j a.
Reactor Coolant System: Plant records were r,eviewed relative to , the RCS cooldown on November 17-18, 1974 and the RCS heatup on November 19-20, 1974. Findings t elative to the requirements of Technical Specification 3.1.2.1 and Figures 3.1-1 and 3.1-2 were acceptable.
, Additionally, the completed procedure (Controlled Copy) for the last plant heatup or. November 19-20,1974 (OP 1102-1, Revision 4, [j dated October 9,1974) was reviewed relative to procedure adher-afg; ence, and findings were acceptable.
However, during this review the inspector observed that this procedure contained four TCN's with approval dates preceeding the procedure's revision date.
This also applied to the Control Room's Controlled Copy of OP 1102-1.
Review by the licensee indicated that these TCN's were no longer valid and should have been deleted from the pro-cedure.
The licensee also discovered that a currently valid TCN, which was approved subsequent to the last plant heatup, was not attached to the procedure as recuired.
The inspector ~ determined that the four invalid TCN's were not followed during .. _ the heatup; however, during discussions with a Shif t Sucervisor the inspector was informed that had that Shift Supervisor been on duty he would probably have followed one of the invalid TCN's, 1452 195 ' -
w
. . , . . - 13 - - . f3 . U namely TCN No. 74-40 dated May 9,1974.
This TCN, which was gg approved prior to initial criticality, would have resulted in W violating the current procedure for establishing Containment Integrity (OP 1101-3), if used.
/ As a result of this finding, the licensee did or plans to do . the following: (1) OP 1102-1 was corrected relative to TCN status.
(2) All outstanding TCN's (about 175) were reviewed and a dis-posit 1on of each one was made.
, (3) A review of Control Room files was made to ensure all cor-rect procedure revisions and TCN's were present for Opera-ting, Surveillance, and Administrative Procedures.
The review also included selected Health Physics Procedures.
(4) The disposition of valid TCN's will be either to cancel the _ TCN if no longer required or to incorporate the substance of the TCN into the appropriate procedure or in the case.of Special Operating Procedures to maintain a useable index of these procedures to facilitate plant operation and maihte-j nance.
The Station Superintendent inform,ed the inspector ' this action would be completed by mid-March 1975.
This .. item is unresolved pending completion by the licensee.
The above finding is in noncompliance with Criterion VI, Appendix B,10 CFR 50 and FSAR Section lA, Operating guality Assurance Plan, Section V1.
.. This item of noncompliance is considered to be an infraction, and it is also a repeat item of noncompliance.
(Report 50-289/ 74-25, Details 13.e(l) and (2)) b.
Reactivity and Power Control: The inspector observed on January 6, 1975 that the source of concentrated boric acid solution, in addition to the Borated Water Storage Tank, was available and operable in accordance with Technical Specifica-tion 3.2.2.L.
c.
Core and Internals: The inspector observed on January 6, 1975 that oxygen, chloride, and fluoride cor.centrations in the pri-mary coolant were less than the maximum permissible concentra-tions identified in Technical Specifications 3.1.5.1, 2, and 3.
1452 196 .
' .
. - 14 - . k d.
Power Conversion Systems: Plant recorde indicated that during ' RCS heatup on November 19-20, 1974 the pressurization limita-tion on the steam generators, as identified in Technical Specification 3.1.2.2, was adhered to.
/ e.
Auxiliary Systems: The inspector observed on January 6,1975
that Nuclear Service Closed Cycle Cooling Water Pump 1C was in operation and Pumps 1A and 1B were in standby.
Findings rela-tive to requirements of Technical Specification 3.3.1.4.a vere acceptable.
f.
Electrical Systems: The inspector observed on January 6,1975 the status of the 230 kv lines and buses.
The findings relative to the requirements of Technical Specifications 3.7.1.c and d were acceptable.
g.
Emergency Power: The inspector observed on January 6,1975 the status of the Emergency Diesel Generators and Fuel Oil Storage Tank.
Findings relative to the requirements of Technical , Specification 3.7.1.e were acceptable.
h.
Emergency Core Cooling Systems: The inspector observed on January 6,1975 the status of the Borated Water Storage Tank.
.._.
Findings relative to the requirements of Technical Specifica-
' ) tions 3.3.1.1.a and e were acceptable.
- . The inspector was informed that the manual valve, required by Technical Specification 3.3.1.1.a to be locked open, was never installed when the plant was built.
This was confirmed by re-view of plant drawings.
The licensee stated this Technical Specification error would be corrected by license amendment.
The inspector has no further questions on this item at this time.
i.
Other Engineered Safety Features: The inspector observed on January 6, 1975 the status of the two Core Flood Tanks. Find-ings relative to the reauirements of Technical Specifications 3.3.1. 2.a. b, and d were acceptable.
6.
Desien Changes ~ a.
Facility records relative to selected design changes co=pleted .. - during calendar year 1974 (but subsecuent to OL issuance date of April 19, 1974) were reviewed, and discussions relative to these change.s were held with the licensee.
The following areas were examined during this inspection: 1452 197 . _ =p.,.
' . . . 15 - ', - , . k' (1) Written safety evaluations pursuant to 10 CFR 50.59.
(2) Review and approval of the change pursuant to the Technical Specifications and established QA procedures.
/ (3) Implementation of the change pursuant to formal procedures.
. (4) Acceptance test records verifying satisfactory performance.
(5) Review and approval of the performance of the modified equipment.
- . (6)~ Operating procedure, where applicable to the changes made.
(7) As-built drawings, changed to reflect the modifications.
The design changes reviewed were as follows: ' (1) C/M 0076, Modification to the Incore Monitor-Backup Recorder.
(2) C/M 0031, Modification of Control Circuit to Makeup and ' Decay Heat Motor Operated Valves MUV 16A-D, DHV 4A and.3, BSV 1A and B.
) ' ( - N ' (3) C/M 0068, Change Power Source for React 3r Coolant Pump - Instrumentation.
(4) C/M 0080, Modification of Diesel Cenerator Air Start System.
i (5) C/M 0039, Modification of Control Circuit of Makeup Pumps.
(6) C/M 0071, Modification of Containment Pressurization
Penetration.
(7) C/M 0048, Modification of the Emergency Feedwater Pumps (Steam and Motor Eriven).
' (8) C/M 0102, Modification of the Control Rod Drive Circuitry (Runback). (9) C/M 0135, Change to Allow Reactor Coolant Pump Startu'p with Reactor Power at 30%. b.
The following summarizes the inspector's findings: - 1452 198 _
. . . s . . . - 16 - ' - - . './ - - - (1) A written safety evaluation existed for each change; how-ever, the follovir.g apparent nonccmpliance to 10 CFR 50.59 was identified.
The licensee's administrative procedure, No. 1016, Section 7, reouires that a two page form be used for changes / modification.
Page 2, Item 5 of this form states to " Explain in detail why the change / modification does not involve an unreviewed safety ouestion as defined
in 10 CFR 50.59."
For all nine design changes reviewed 4.)
none of the detailed explanations addressed the following 10 CFR 50.59(a)(2) criteria for evaluating an unreviewed safety question: (a) Whether the probability of occurrence or the consequences of an accident or malfunction of aquipment important to safety previously evaluated in the Safety Analysis Report would be increased.
(b) Whether the assibility for an accident or malfunction r of a different type than any evaluated previously in the Safety Analysis Report could be created.
(c) Whether the margin of safety as defined in the basis.for any Technical Specification is reduced so as to require ' a change to the Technical Specification.
' . The licensee stated that they would modify Item 5 on Page 2 of their form to include the above requirements of 10 CFR 50.59.
The above finding of noncompliance is considered to be an infraction.
(2) During the inipection to determine if the design changes chosen were-leviewed and approved in accordance with the Technical 5pecifications or established QA/QC controls, an apparent noncompliance to the Technical Specifications was identified.
Sections 6.1.1.2.b.1 and 6.1.I.2.b.2 state that the Met Ed Corporate Technical Support Staff has the responsibility to control and review changes to equipment or systems having nuclear safety significance.
Contrary to this reouirement, the Met Ed Corporate Staff could not produce evidence of this control and review.
The licensee stated that the nine chosen plant design changes may have been handled during the time when the startup and test OA . progran was in ef fect, and objective evidence could be at GPU Corporate Of fice.
The licensee stated he would review the records and inform RO:I of the results of his review.
This item is unresolved, and it will be reexamined during a subsequent RO inspection.
. > ' 1452 199 ' __ e
' . . _ - 17 - . . (3) Each of the changes were impicmented in accordance with the established procedures.
(4) The acceptance test records indicate that the acceptance, criteria contained in the installation and test procedures were met for each change.
~ (5) The performance of the modified equipment was reviewed and approved for each change.
(6) The operating procedures were revised, where appropriate, to reflect the changes made to the plant equipment.
(7) The as built drawings, which were affected by Changes . Nos. 0048, 0076 ano 0031, were examined.
This review included drawings C-302-081, Revision 15, B804098. 7, Revision A and 208442, Revision 3.
The inspector ob-served that the drawings had been changed to reflect the modifications and had been processed in accordance with the established procedures.
7.
Audits Audit records for the calendar year 1974 were reviewed and discus- "~~ sions relative to these records were held with the, licensee.
The N ) following areas were examined during this inspection: a.
The records reviewed for both the Onsite (PORC) and Offsite _ (GORB) Review Committees indicated that the meetings were held in excess of the minimum frequency required by the Technical Specifications.
~ b.
The records reviewed for both the PORC and the GORB indicated that the membership quorum requirements of the Technical Specifications were satisfied, The records indicate that tests which affected nuclear safety c.
were reviewed ar.d approved as required by the Technical Specifications.
d.
The records for two Category II violations (RO:I letters with = enclosed Reports 50-289/74-25 and 74-23) were reviewed.
The inspector noted that there was evidence that the violations "~ were reviewed as reauired by the Technical Specifications.
1452 200 / -- . . ~.
. . . ' . - 18 - . . - , _.: . e.
.The records for three changes to the Technical Specifications, Nos. 2, 4 and 5, were reviewed.
The inspector noted that these '~ changes were processed in accordance with the Technical Specifi- ' cations.
The PORC and the CORB reviewed and approved these changes; however, the minutes which included GORB's review of Changes 4 and 5 had not been issued.
The licensee stated that . this GORB meeting (No.16) had been held on October 30-31, 1974.
This item remains unrecolved pending the inspector's review of those meeting minutes, f.
An inspection uas conducted of records relating to audits con-ducted by the licensee.
During this review, the following - areas of honcompliance were found: . (1) The licensee's six month audit schedule (last half of 1974 } vas used as a guide to select audit reports.
The inspector requested to see the audit reports for audits 74-13 (September 25,1974) and 74-27 (September 30,
1974).
These audits involved drawing control and design control, respectively.
The licensee stated that'both audits were partial audits and were terminated and that - no reports were issued.
The inspector asked if the audits " revealed any negative findings. The licensee stated that ,) the findings for audit 74-13 were favorable; therefore,, i ' they closed out the audit.
For Audit 74-27 the findings were unfavorable and extensive.
The inspector requested to see the audit reports for Audit No. 74-25, which was conducted on September'16, g 1974, and No. 74-29, which was conducted on October 28, 1974.
The licensee stated that these reports were still in draft stage and had not been issued. According to the , licensee, these audits involved activities of Generation Engineering.
The inspector noted that as of January 9, 1975 a period of 115 days for Audit No. 74-25 and 73 days for Audit No. 74-29 had elapsed since audit performance and the reports had still not been issued.
The inspector informed the licensee that failure to issue an audit report or failure to issue an audit report in a timely manner was contrary to Criterion XVIII, Aopendix B, 10 CFR 50 and FSAR Section lA, Operating Quality Assurance Plan, Section XVIII.
This item of nonccmpliance is consic-ered to be an infraction.
~ 1452 291 .
- . , . - . . - 19 - - . Q .
\\/ - ~ -(2) The inspector reviewed the licensee's method for controlling their audit findings.
The review revealed that there were - many audit findings, a total of twenty-four, that were tar- ' geted to have corrective action completed within a time period of January 15, 1974 to August 14, 1974.
At the time 'E of this inspection they were still not closed out.
The fol- - lowing are some examples listed on the licensee's " Status , ' of Audit Findings" dated December 27, 1974.
(a) Audit 73-16, Finding No. 5 was targeted for closecut January 31, 1974 and retargeted for February 15, 1974.
The listing indicated it was not closed out.
Subsecuent-discussion; with the licensee has indicated that this item was closed out on December 6,1974.
This finding involved the obtaining of locks (Removal of Red Tags) to comply with the station procedure for locked valves.
(b) Audit 74-11, Finding Nos. 4 and 6.
These two findings were targeted for close out by May 17, 1974 and the listing indicated they were still open. The audit findings involved preventative maintenance that was. not performed, as required, and the adding of electri-cal and mechanical test equipment items to the plan: ) administration list of calibration measuring and test equipment.
(c) Audit 74-12, Finding No. 3.
This finding was targeted for close out by July 20, 1974.
The list indicated it was still open.
The finding was a possible violation of the Environmental Technical Specifications'. The PORC was requested to review this finding by July 20, 1974 to evaluate if it was a violation of the Technical Specifications.
The PORC did not review this finding - until December 9,1974 (Meeting No. 260) in which they stated it was not a violation of the Technical Specifications.
The inspector informed the licensee that they were in non-compliance with Criterion XVI, Appendix B,10 CFR 50 and FSAR Section lA, Operating Quality Assurance Plan, Sec-tion XVI.
Additionally, Quality Assurance Procedure.
GP 4016, Revision 0, Item 12, requires the cognizant department head to take timely corrective action and to inform the Manager, Operational Quality Assurance, of the action taken and date completed. This item of non-compliance is considered to be an inf raction.
- 1452 202 .
- h-
. . . . 20 - - , , \\
~ (3) The Technical Specifications, Section 6.1.I.3.e.8) states that "The General Office Review Board (CORB) will review the audits and audit program of the generation division."
The " inspector reauested from the licensee documented evidence-that GORB reviewed the audit reports.
The minutes of GORB meetings for April 10,1974-September 9,1974 (Meetings Nos.11-15) were reviewed.
Evidence that the GORB had -- 1
reviewed t'ne audits could not be fo.und.
Discussions were held with two members of the GORB (Chairman and a member) to determine if, during Meeting No. 16 held in October 1974, the GORB had reviewed any audits or if the members had reviewed audits by another method, other than a meet-ing.. Based on these discussions, the inspector was in-formed that during the period April 10,1974-January 9, . 1975 (Operating License issued on April 19,19.74), the GORB had not reviewed the audits and audit program of the Generation Division, but that the GORB was in the process of establishing a subcommittee to perfoms such re, views.
_ Additionally, the CORB Chairman had been provided Quarterly Audit Summary Reports and some Aud!t Reports; however, these had not received GORB review.
The inspector informed the licensee that the submission of audit reports to the GORB Chairman was consistent with the requirement of the Techni-s cal Specifications, Section 6.1. I. 2.e. 3). .: .- The inspector informed the licensee that GORB's failure to review the audits and audit program since the issuance of an operating license (a period of about nine months) was " contrary to the Technical Specifications, Section 6.1.I.3.e.8).
This item of noncompliance is considered to be a deficiency.
g.
Discussions held with the licensee indicated that Corporate Management was involved in the review of the effectiveness of the overall Quality Assurance Program.
8.
Unresolved and Ooen Items from Previous R'O Insoections a.
Surveillance Procedure SP 1301-1 Reference: Report 50-289/74-35, Detail 2.a(1) The inspector observed that this procedure had been revised in accordance with the licensee's commitment to RO:I and that source checks were being accomplished pursuant to this proce-dure.
This item is closed.
1452 203 . ' ^ *, _@ h
. . . . . - 21 - ' , , ,-- . t b.
Possible Piping / Penetration Contact on A and D Main Steam Lines Reference: Report 50-289/74-35, Detail 2.b(7) =+ , Based on a review of records and discussions with the licensee, + the inspector determined that this matter uas reviewed by the licensee's AE and the PORC.
It was determined that there was ~ no contact, and the minimum observed clearance, which was two inches, was considered acceptable.
The crushed insulation was believed to have occurred during installation.
This item is clo~s ed. - m
c.
Pipe llancers on Makeue Pumo Discharme Lines Ref er ence: Report 50-289/74-35, Detail 2.b(8) Based on a review of records and discussions with the licensee, the inspector determined that this matter was reviewed by the .c 4 licensee's AE and the PORC.
It was determined that although 1 *.. the two hangers were improperly set, the resultant stress levels on the piping were not excessive.
Additionally, all. future work requests which can affect piping hangers will provide the fol-lowing hanger requirements: -- . sT (1) Blocking hangers before ccamencing work.
' - . (2) Unblocking hangers upon completing work.
(3) Verification of proper hanger settings af ter unblocking.
The-licensee was unable to detennine the cause of the improperly set hangers although it was believed this condition could have occurred during maintenance on the Makeup Pumps.
The inspector - observed that these two hangers had been reset.
This item is closed.
d.
A0 74-15 Corrective Action References: Report 50-289/74-32, Detail 7.a Report 50-289/74-35, Detail 3.b Based on discussions with the licensee, the inspector determined that the visual inspections had been completed and that no wiring errors sinilar to the one which caused A0 74-15 were identified.
This item is closed.
1452 204 - .
. . . .. . ' - 22 - . . /m \\ / ' e.
Control Switch Investication References: Report 50-289/74-32, Detail 11 ~ Report 50-289/74-35, Detail 3.c - RO Bulletin No. 74-15, dated December 6,1974 Met Ed Letter, dated January 8, 1975, Response to RO Bulletin No. 74-15 " The inspector observed that an operations nemo, which alerted operators of the care required when positioning the subject switches in.e o to insure correct switch positioning, did - exist.
The inspector has no further questions on the licensee's interim corrective actions at this time. The licensee's final corrective action is to replace the subject switches on the emergency diesel generators following completion of their design review, and this item remains unresolved pending completion of the change by the licensee.
f.
Revision to Ooeratine Procedure OP 1102-4
Reference: Report 50-289/74-35, Details 2.a(3) and 2.b(1)) ' Based on discussions with the licensee, the inspector deternined _a y that OP 1102-4 had been revised to incorporate requirements on ' steady state reactor core power, but that a revision relative i to the requirements of 10 CFR 50.36(c)(2) had not yet been made.
The licensee informed the inspector that this revision vould be completed by January 31, 1975.
This item remains unresolved pending completion by the licensee.
. g.
Administrative Procedure for Auxiliarv Loe Sheets Reference: Report 50-289/74-35, Detail 2.a(2) Based on discussions with the licensee, the inspector determined that this procedure, which is still under development, is to be completed by February 28, 1975.
This item remains unresolved pending completion by the licensee.
h.
Evaluation of Ter.norarv Shieldine Reference: Report 50-289/74-35, Detail 2.h(5) _ Based on discussions with the licensee, the inspector determined that the licensee's evaluation of the presently installed ter.po-rary shielding relative to the possible detrimental ef fect on . / 1452 205 ~ - .
. . ' . . - 23 - - / ' the operation of equipment and the operator surveillance program of equipment hidden by these walls is to be completed by mid-February 1975.
This item remains unresolved pending completion by the licensee.
Additionally, the inspector was infor=ed thde prior to installing temperary shielding in the feature, these - considerations would be included in their evaluation concernin-the installation.
The inspector has no further questions on this item at this time.
- 1.
Snubber Maintenance / Surveillance Prorram References: Report 50-289/74-35, Detail 2.b(8) ' A0 Reports 50-289/74-30, 25, 23 and 20 Met Ed Letter to DL dated February 14, 1974 Based on a review of records and discussions with the licensee, the inspector determined the following: . (1) Inspection of snubbers in the Turbine and Auxiliary Buildings were completed in accordance with the licensee's_ cocsiements.
(2) Surveillance Procedure SP 1301-9.9, Revision 1, dated January 2,1975 was approved and in use.
This procedure implements the surveillance requirements pf the Technical . Specifications (Table 4.1-2, Item 11) as amended by the licensee's more restrictive cocmitment identified in A0 Report 50-289/74-23.
All snubbers _have been inspected to the basic requirements of this procedure.
The inspector has no further questions on the implementation of,this aspect of the licensee's program at this time.
(3) Operator training on snubber design and operation with emphasis on routine inspection of snubbers is being con-ducted in accordance with the licensee's commitment iden-tified in A0 Report 50-289/74-23.. (4) The snubber seal replacement orogram is continuing. Docu-mentation relatiie to the implementation of this program was available; however, the inspector infor=ed the licensee that this matter would be reviewed during a subsequent RO inspection.
This item remains unresolved pending review by the inspector.
1452 206 P .
. . I . J - ~ 24 - . .
- p %-s/ j.
General Emnlovee, Facility Access Control and Security Traininc Reference: Report 50-289/74-32, Detail 2.c / Based on a review of records and discussions with the licensee, the inspector determined t t the licensee had established definitive requirements re ative to documentation, delineated program, and methods to evaluate training effectiveness.
Thase requirements are contained in Training Department Administrative Memo No. 2, dated October 31, 1974.
This item is resolved.
k.
Maintenance Personnel, Procedure Review / Indoctrination Reference": Report 50-289/74-32, Detail 3.b , Based on a review of records and discussions with the licensee, ~ the inspector determined that the licensee had established definitive requirements relative to a foreman's review of mainter.ance procedures prior to their implementation.
These requirements are contained in Maintenance Department Order No. 12, dated November 11, 1974.
This item is resolved.
~~ 1.
General Emnlovee Facility Contincency Procedure Training - s
Reference: Report 50-289/74-32, Detail 2.b I / , .. Based on a review of records and discussions with the licensee, the inspector determined that the licensee had implemented his defined training program covering Natural Disaster and Fire Procedures and Personnel Injury.
This progran was about 75% complete at the time of this inspection.
This item is closed.
m.
Surveillance Procedure 1301-9.1 Reference: Report 50-289/74-18, Detail 13.a (2) (a) " The inspector observed that Surveillance Procedure 1301-9.1, Inservice Tendon Surveillance Program, had been approved in accordance with the licensee's commitment.
This item is closed.
.. i452 207 t '~ . }}